Current DRAFT

First Phase – Highjack Shell Corps and Established Brands and Tradenames
Issue: Does this conduct require systemic override disregard of the Ethical standards governing
attorneys and those in public service, private practice, etc.,
Short Answer: Yes.
Issue: Is technical compliance with minute nuances of the statues, rules, regulations sufficient to
circumvent liability for disregard for the purpose of the rule, regulation or statute that is
ultimatel4y violated notwithstanding technical compliance?
Short Answer:
No. See Lorenzo and line of cases thereunder. Technical compliance is irrelevant if the purpose of
the underlying rule is violated.

§ 1101.1. Purpose
(a) Declarations.--The Legislature hereby declares that public office is a public trust and that any
effort to realize personal financial gain through public office other than compensation provided by
law is a violation of that trust. In order to strengthen the faith and confidence of the people of this
Commonwealth in their government, the Legislature further declares that the people have a right
to be assured that the financial interests of holders of or nominees or candidates for public office
do not conflict with the public trust. Because public confidence in government can best be
sustained by assuring the people of the impartiality and honesty of public officials, this chapter
shall be liberally construed to promote complete financial disclosure as specified in this chapter.
Furthermore, it is recognized that clear guidelines are needed in order to guide public officials and
employees in their actions. Thus, the General Assembly by this chapter intends to define as clearly
as possible those areas which represent conflict with the public trust.
(b) Recognition.--It is recognized that many public officials, including most local officials and
members of the General Assembly, are citizen-officials who bring to their public office the
knowledge and concerns of ordinary citizens and taxpayers. They should not be discouraged from
maintaining their contacts with their community through their occupations and professions. Thus,
in order to foster maximum compliance with its terms, this chapter shall be administered in a
manner that emphasizes guidance to public officials and public employees regarding the ethical
standards established by this chapter.
(c) Legislative intent.--It is the intent of the General Assembly that this chapter be administered
by an independent commission composed of members who are cognizant of the responsibilities
and burdens of public officials and employees and who have demonstrated an interest in promoting
public confidence in government.

See https://www.ethics.pa.gov/Ethics-Act/Ethics-Act/Pages/Section-1101.1.aspx
1773 – Richard Ellis founded at 126 Fenchurch Street, London, UK

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The 1930 Deed referenced in Chain of Title Presented to EvE and corroborated by title
insurer (No block/lot 86p 150 or 102 contrary to all deeds allegedly forming chain of title to
unit 308:

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3

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4

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5

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June 14, 1930: PPG reports on Sheriff sales scheduled for July 1930 includes the above-described.

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November 4, 1935: Eisner & Himmler, Inc. was incorporated in such records recorded with the
Pennsylvania corporation’s division and then the corporate name and shell is transferred.1’]
1936 – US name change to Coldwell, Banker and Company.
1940 – UK Richard Ellis Partnership was transferred to Richard Ellis Holdings Ltd (becoming
Insignia Richard Ellis Ltd) along with the regional Richard Ellis corporate businesses.
November 4, 1935: Eisner & Himmler, Inc. was incorporated in such records recorded with the
Pennsylvania corporation’s division and then the corporate name and shell is transferred.’]
1944: Stanley Arnheim and Eisner/Himmler merge. The surviving entity is Stanley W. Arnheim,
Inc. recorded with DOS, Bureau of Charities and Corporations and then the corporate name and
shell is transferred.
19__ US Sup Court holds Arnheim & Neely has Enterprise liability. Analogous facts in labor
law context. CITE

19– through 1974 see Allegheny County property cards in relevant part from 1956 through 1974
Property History Card for the Apartment Building at 5600 Munhall.

1
When initially inputting record requests for Arnheim & Neely with the PA-DOS the retrieved documents in every
instance historically are those associated with Eisner entity.

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INSERT BACK OF CARD I
Card II -- See 1979 for detail on evidence of Fraudulent Entries as of this General Date 2

See both sides of card in 1979.

3

2
In or about 1998 (see also Row Offices issues), DellaV. as Recorder of Deeds eliminated the use of Property History
cards (PHC). CITE
3
This is a true document of the property history for 5600 under the Prop Hist Search, Alleg. Cty. US land. Card #1
of 2.

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1963 to the Present: The Act of July 3, 1963 (P.L. 196, No. 117), known as the Unit Property
Act, (UPA) governed 4 (assuming for the sake of argument, that a Condominium was ever
created at 5600 Munhall as admitted by Jug, in the Feb. 2021, pleadings: . Complaint in Equity
and Motion for Special Injunctive relief), the Unit Property Act governed or applied during all
applicable periods. The UPA is as follows:

4
As admitted a fraudulent series of misleading and abusive papers filed by coconspirator Fred Jug. See Compl. and
PIM. This admission demonstrates that all times prior the 2021 abusive pleadings against me/estate, Jug and his
Partner perjured themselves and suborned perjury in multiple complaints filed on behalf of the control group of 5600
Munhall today (see 1994 onward). The fraudulent BOD of 5600 including Bernstein and Goldberg made and continue
materially false statements to tenants in this regard consistent with false amendments filed to with recorder at all
relevant times from 1998 onward. See 1998 for detail.

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10

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11

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12

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13

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14

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15

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16

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1965 – Richard Ellis forms Australian partnership.
1968: The Interstate Land Sales Full Disclosure of 1968 Enacted
Overview of Interstate Land Sales Full Disclosure Act the Interstate Land Sales Full Disclosure
Act requires the registration of all "subdivisions" with the Secretary of the Department of
Housing and Urban Development ("HUD") unless the subdivision falls within one of 16
exemptions, eight that exempt the subdivision from all provisions of the Act ("Full Exemptions")
and eight that exempt the subdivision from only the registration requirements under the Act

17

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("Partial Exemptions"). Under a Partial Exemption, compliance with the anti-fraud provisions of
the Act is still required.
The Act defines a "subdivision" as "any land which is located in any State or in a foreign country
and is divided or is proposed to be divided into lots, whether contiguous or not, for the purpose
of sale or lease as part of a common promotional plan."
The Act defines a "common promotional" as a "plan, undertaken by a single developer or a
group of developers acting in concert, to offer lots for sale or lease; where such land is offered
for sale by such a developer or group of developers acting in concert, and such land is contiguous
or is known, designated, or advertised as a common unit or by a common name, such land shall
be presumed, without regard to the number of lots covered by each individual offering, as being
offered for sale or lease as part of a common promotional plan."
A developer "registers" with HUD by filing a Statement of Record. Most developers seek an
exemption because the filing is often both time consuming and expensive.
Of the sixteen possible exemptions (eight full and eight partial), the following two are the most
relevant and most commonly used exemptions:
Improved Lot Exemption (15 U.S.C.§1702(a)(ii)). This Full Exemption applies to lots that are
completed at the time of the signing of the purchase contract or which the Developer has
absolutely and unequivocally committed to complete within two years of the date the purchase
contract is signed. This two-year completion obligation can be extended for Acts of God, force
majeure, casualty losses, material shortages, etc. However, the Developer will not be able to
limit the Buyer's remedies in the Contract upon a seller default if this Improved Lot Exemption is
relied upon. 2. 100 Lot Exemption (15 U.S.C.§1702(b)(i)).
Registration is not required for the sale or lease of lots in a subdivision containing fewer than
100 lots. The 100 Lot Exemption is a Partial Exemption. In determining the number of lots to be
counted, all lots that are sold or offered for sale under a "common promotional plan" must be
counted. However, lots that are exempted under a Full Exemption may be excluded -- None of
the exemptions are applicable herein. See Kenny Ross facts/. See Microsoft Word - Client Alert
recission Applicable Under ILSFDA.032108.DOC (bhfs.com)

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 Therefore, while the Developer could exclude lots exempted under the Improved Lot
Exemption (a Full Exemption), it could not exclude lots otherwise exempted under the Single-
Family Lot Exemption (a Partial Exemption). The 100 Lot Exemption is not automatic; to satisfy
the anti-fraud provisions of the Act, the purchase and sale agreements must contain express
language which discloses to purchasers which utilities and recreational amenities seller shall
agree to complete. Discussion of the Recent Adverse Decisions The Act prohibits developers and
their agents from (1) engaging in the sale or lease of any lot "not exempt under Section 1702"
without registering by filing a statement of record with the United States Department of Housing
and Urban Development and providing buyers/tenants with a property report; and (2) engaging
in the sale or lease of any lot "not exempt under Section 1702(a)" without complying with the
anti-fraud provisions of the Act(which, among other things, prohibit the use of untrue statements
or omissions of material fact and require contractual obligations on the developer to complete
advertised infrastructure improvements and amenities). 15 U.S.C. § 1703(a). Section 1702(a) of
the Act sets forth the "full exemptions" from the Act, which include the sale or lease of lots in a
subdivision containing less than 25 lots, the sale of improved land or the sale of land to be
improved where the contract contains an absolute obligation on the developer to complete the
contracted improvement on the land within 24 months from the date of contract, subject only to
force majeure defenses which are accepted in the jurisdiction where the property is located.
Section 1702(b) sets forth the "partial exemptions" which are exempt only from certain
provisions of the Act but not the anti-fraud provisions. Such partial exemptions include, for
example, the sale or lease of lots in a subdivision containing fewer than 100 lots.

1969: Coldwell Banker begins trading stock.

——
1979: Michael Della Vecchia (hereinafter, Della V)(see sham injunction and forcible entry ex
parte 2021), is elected to serve s as Recorder of Deeds, Allegheny County while simultaneously
working as an attorney. 5 He was also Democratic Committee head. At all relevant times, he
touted his ability to record more conveyances annually than any other recorder and touted the
profitability of the Office -- which is almost certainly of the quid pro quo/kickback scheme
reflected in fabricated (5600) property and deed taxes/fees or highly inflated property taxes
based upon fraudulently inflated appraisals. The coconspirators needed Della V. to retain the
position and thus ensured that via fraudulent means he would be retained year after year until he
was appointed to the Court but as described herein the deed/mortgage fraud continues through
the present and DellaV. is a key player and debt collector on behalf of his control group -- the
control persons of the Banks/lenders, etc. See applicable definitions of control under all
statutory schemes as well as control aka enterprise liability.
The Only True Developer with Claim to Development of the Attempted Condominium of 5600
Munhall -Kenny Ross Takes Steps to Develop Property

5
“Prior to the bench [June 2001], Judge Della Vecchia practiced law in Allegheny County for 30 years with the firms
of Evashavik & Della Vecchia; Rose, Schmidt, Hasley & DiSalle; and Brennan, Robins & Daley.” See Full Biography
for Michael A. Della Vecchia (smartvoter.org) )( candidate reported information). Viewed April 4, 2021.

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March 1, 1974: Kenny files with the PA DOS- S R N D Corporation fictitious name for
Domestic Corp filed. Entity No. 22655146
1974: Post-Gazette reports that, IH condominium conversion project at 5600 started by Kenny
Ross as a condominium dev’t through a $4 to 7 Million mortgage via Fort Pitt Federal Savings
and Loan for a [ten] story, [141] unit condominium on 1.6 acres of land with included amenities
such as a rooftop tennis court and indoor parking for 150 cars.
Also, in 1974, , Property History Card No. 2 7was updated as follows:

8
April 8, 1974: Kenny Ross prepares a the :” Imperial house Family condominium Plot Plan” aka
site plan date stamped as 4-9-74 and 7-29-75 by Tennyson and Reid not recorded.9 A plot plan is
not a plan of
of Decl. as required by the UPA to create a condominium. A plot plan is basically a formal
sketch for municipality and zoning approval as an initial step to a development. The Plot Plan
was fraudulently recorded as a Declaration Plan in furtherance of the overall scheme. The 1978-
79 control group have no legitimate relationship with the Original Developer as demonstrated in
following chronology.
A copy of the title page of the plot plan sketched in 1974-74 was recorded by John P Exler,
Recorder 1947-79 when Dellav took over in all respects. See PBV 110-190.

6
There is no existing online record as to S R N D corp that I can find. Simply assume a corporate shell for Kenny
Ross, et al. (underlying records available only upon written request to Harrisburg)

7
PHC were used until 1999 -- See Welcome to the Allegheny County Recorder of Deeds Online Search
(uslandrecords.com) and description of available records:

All available cards prior to 1999

Property History Cards

8
Front and back of Property History per public records. See e.g., Real Estate | Online Records Search | Allegheny
County; Welcome to the Allegheny County Recorder of Deeds Online Search (uslandrecords.com); See instructions,
only identifiable by ID Parcel search:
9
See later, Recorded fraudulently as a Decl. Plan, 1978.

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. \ 10
11
1974: PPG reports marketing and sales of Condo units:
“Developers of 140-Unit Imperial House Condominium…received numerous inquiries about the
nine-story structure, have taken a new approach to marketing the building…. Imperial House being
built by United Construction Co. is scheduled for a summer, 1975 opening…. special office has
been set up at Murray Ave. at Phillips, where buyers can view models, maps, transparencies,
furniture displays…. Dave McLaughlin, General Manager and Bill Ragan, Sales Manager [state]
building will have 124 two-unit apartments each with 1040 square feet 12 with pre-construction
prices at $40,000 to $45,000 and 16 three-bedroom units with 1,750 sq. feet at $52-$55,000 per-
construction prices. …. Added to the building has been roof-top tennis courts, provisions for an
integral parking spot for each apartment…. McLaughlin said, the Bell telephone security system
will be displayed in weeks and financing has been arranged through a local savings and loan.
1974: Thomas a primary coconspirator beginning in 1979 when he joined the scheme while a
target for contract murder by members of his gang, including Codfish Bricker released from jail
after committing multiple murders. See PPG story as follows:

10
What is a site plan? A site plan (also named plot plan or survey) is a plan of the entire property, drawn to scale, that
shows the location and dimensions of all property lines, any existing and proposed structures, and any proposed
exterior work. .... Yes, most projects must be submitted on a professionally stamped site plan completed by an
architect, surveyor or engineer, except fences, residential HVAC/generators, chicken coop, and wall signs. If there is
conflicting data about the location of a property line, a surveyor’s stamp will be required. Zoning staff will make the
final determination of whether or not a project requires a professional survey. See Site Plan Requirements |
pittsburghpa.gov viewed Mar. 29, 2021; see also Planning Division | Allegheny Places. What is not a Declaration
Plan of Condominium? A plot pan or site map. See 1979 fraudulent Plan supra at p. See 1978-79 when the control
group fraudulent recorded the plot plan as a Decl. Plan as described. On its face, this plot plan as recorded could not
and did not satisfy the conditions of a Condominium Plan required to be recorded before a condominium is created as
a matter of law. See entire plot plan copy as recorded, supra. .

11
See e.g., Bricker’s 2000 obituary.
12
My mother’s unit is 1100 sq. feet.

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. Feb. 28, 1975: Duquesne Light Co. Right of Way Agreement executed by David S.
McLaughlin, Esq. a President on behalf of Imperial House, Inc. fka SRND Corporation and Vice
president for the purposes of executing Agmt. 13 DB Vol. 5459, p. 99
See 1994, DLC PNC CHANGE IN CORP ENTITY AND CONSP. SEE ALSO VALLEY OF
THE LAKES CLASS ACTION.
Imperial House, Inc. fka SRND Corp., grantor in consideration of $1.00 grants DLC right to
erect, maintain, use, renew ….re.:
(1) overhead electrical system (one anchor, guys, etc.) and
{2) underground electrical system consisting of cables, conduits, transformer and other fixtures
belonging in one concrete electrical vault ….” Overhead and underground electrical system shall
be located on “print of DLC drawing no .11037.71, a copy of which has been given to grantor,
McLaughlin. IH, inc. fka SRND.
“fronting on Munhall Road” See Decl. Plan which is inconsistent with Rights Agreement. 14

13
In 1975, McLaughlin was Kenny Ross’ counsel or Vice President.
14
Utility Easements run with the owner not the land, meaning that absent assignment or transfer of the agreement,
DLC has no ability to perform any activity as described in the Agreement. Furthermore, the subsequent Decl. Plan
appears inconsistent with the Right-of-Way and all current BOD representations re: the indoor vault, etc. DLC does
not has any rights to access meaning that the building may be a risk of imminent harm for the same reasons described
in Duquesne v. Long Vue.

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See Pa. Sup. Court Case: Utility easement or right of way runs with owner not land. And see
DLC v. Long Vue (danger can’t enter to replace electrical utility) and then see the fraudulent
submetering bills to EvE and now me from 2015 onward. And see collaborative harassment this
past week. Shut down threat non-compliant with any related law.
The Kenny Ross Developer Group marketed and promoted the yet to be finished units.
Examples follow:

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April 21, 1975: Kenny Ross as President and Secretary, David S. McLaughlin (incorporators
dba “Imperial House, Inc.”) record articles of incorporation of “Imperial House Condominium
Association, Inc.” a non-profit corporation located at 5600 Munhall Road, Pgh. PA 15217
(perpetual), describing its purpose as follows: Executed by Kenny Ross, President and his then
Secretary, David S. McLaughlin, Esq.

1975 Bankruptcy/Receivership and the Interstate Land Sales Disclosure Act 15

At all relevant times, the Interstate Land Sales Full Disclosure Act (“ILSFDA”) was applicable
to the then-proposed Condominium conversion. As described in the following public records,

15
Passed by Congress in 1968, ISFDA is intended to protect purchasers of newly constructed residential property
from insufficient disclosures and developer misrepresentations. In general, the statute requires the developer of
projects containing in excess of one hundred units to register the project with the Department of Housing and Urban
Development (“HUD”) and to provide all prospective purchasers of units with a federal property report which contains
detailed disclosures regarding the developer and the property. The statute also imposes separate anti-fraud provisions
on developments containing in excess of twenty-five units.

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the K. Ross attempted condominium conversion failed within one year. During that period of
time, as Developer, Ross was mandated to register the project with Department of Housing and
Urban Development (“HUD”) and to provide all prospective purchasers of units with a federal
property report which contains detailed disclosures regarding the developer and the property.
The statute also imposes separate anti-fraud provisions on developments containing in excess of
twenty-five units. Unless Ross was able to obtain an exemption from registration (highly
unlikely), 16 he could not offer and sell the units of the proposed development absent registration.

16
There are eight statutory exemptions which exempt a project from the entire statute (i.e., both the anti-fraud and
registration/reporting requirements). Six of the eight apply to special sale situations such as the sale of debt
instruments, sale of real estate investment trust stock, sale of lots to governmental entities, sale of cemetery lots and
the sale of lots to other developers (who presumably would have to comply with ILSFDA themselves when marketing
units). See e.g., The Interstate Land Sales Full Disclosure Act: Residential Developers Beware! – Levin Ginsburg
(lgattorneys.com) viewed March 24, 2021; see also, 2014 email UvE to AK, etc. Re.: Jack Halperin, Defendant, SEC
v. Spongetech Delivery Systems, Inc., as follows: Re: Pentium, Steve’s Op. Ltr: ....
Furthermore, what follows is a quick, rough summary of some of my further investigative findings.
of last night and today. First, Halperin is a convicted felon. Specifically, on July 25, 1980, a Federal Grand Jury
returned a thirty-three (33) count RICO indictment charging him and a related entity violation of 15 U.S.C. Sections
1703 and 1717, and 18 U.S.C. Sections 2 and 1341, the Interstate Land Sales Act and the Postal Fraud Statute,
respectively. The indictment alleged that he willfully and knowingly submitted false and misleading information to
HUD's Office of Interstate Land Sales Registration in order to continue selling properties in a development commonly
known as Valley of Lakes. The indictment also charged him with fraudulent use of the mails in connection with an
alleged scheme to defraud prospective purchasers. As a result of his conviction, he was also debarred in a HUD
proceeding for a period of 5 years. Relevant documents are attached.” See follow-up request to FBI for confirmation
same defendant (no reply); See also, UvE to alleged BOD of alleged Imperial House Condominium, dated Dec. 24-
28, 2020, also requesting copies of registration or exemption therefore among other things, triggering all ongoing
retaliation including abuse of process and official oppression:

And to the extent this BOD obstructs payments, willfully violates any law, rule, regulation, and/or
charges usurious and excessive fees, interest for violations of rules and regulations that do not
exist in order to prevent me or anyone else asserting any rights whether under the UCA, the UPA,
or the laws enacted to
protect civil and constitutional rights this BOD then these following cases illustrate why such.
conduct is problematic. See e.g., http://www.legalaction.com/enter.htm ; Valley of the Lakes,
class action RICO complaint at Count 227. “In furtherance of the conspiracy the control group of
the association “promulgated its own "General Rules and Regulations" for the common areas, and
MLA asserted that it "reserves the right to refuse the use of the facility to owners not in good
standing, for failure to pay outstanding maintenance fees, or property owners with outstanding
violations of covenants and restrictions or rules and regulations” and related actions Pennsylvania
Attorney General, http://www.legalaction.com/ag1.htm; and criminal indictment and plea
(developer, Jack Halperin/Phillip Cohen; see also similar conduct described in a more recent HOA
Board scandal (http://www.legalaction.com/listcrim.htm; see also facts (“ The Las Vegas legal
community is currently witnessing the unfolding of a cautionary tale of how a few plaintiffs’
lawyers gained control over several Homeowner Associations, transforming them into
construction defect plaintiffs, and in the process, pocket millions of dollars. Dozens of individuals
have been indicted. Twenty-four participants have already pled guilty. The original investigation
and prosecution by local law enforcement has now been taken over by the U.S. Justice Department
due to concerns that local officials and politicians were connected to the scheme. Jeff German,
“Federal Prosecutors Under Investigation for Alleged Obstruction of Justice in HOA Probe”, Las
Vegas Review Journal (March 2, 2011). Rumors of judicial and political involvement in the
scheme have continued to circulate but have not been validated. Adding to the sensation is the
mysterious death of two of the attorneys who were allegedly the masterminds of the scheme.
Jennifer Abbey, “Attorneys in Nevada Homeowners Association Scandal Dead” ABC News

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The most likely exemption potentially available to him was the exemption for the sale of
improved land under a contract obligating a developer to build the unit within a period of two
years from contract signing. While it is not unlikely that Ross did avail himself of this
exemption, he did not and could not complete the units within two years of signing because he
was in bankruptcy within one-year. 17
When the condominium conversion failed, the ILSFDA required that he repay all purchasers of
the pre- units. Based upon the Property History Cards for ID Parcel , at most 18, Ross only
sold the following units prior bankruptcy: 302, 305, 306, 406, 510, 511, 602, 617, 703, 815, 817,
916 ,1001.
The following are clearly handwritten and added on some date unknown: 210, 211, 216, 401,
508.
704, 709, and 902.
Assuming for the sake of argument that Kenny Ross sold these properties pre- , the law the
ISLDA among other laws required that all buyers be refunded their monies because there no
longer existed any potential property interest in an individual unit.
Failure to register a project and to furnish a property report to a prospective purchaser at the
time of contract signing could permit that purchaser to revoke his or her contract for a period of
two years after contract signing. 19

(March 28, 2012)”; and more recently https://www.justice.gov/opa/pr/eleven-defendants-

indicted-alleged-roles-schemefraudulently-control-homeowners-associations and
https://www.justice.gov/iso/opa/resources/179201311517481711118.pdfand
https://vegasinc.lasvegassun.com/business/tourism/2012/jun/03/hoa-scandal-involving-millions-
dollars-andthousan/(illegal fees, assessments, kickback and control).

The seventh exemption is for projects of under twenty-five units. While it is clearly intended to exclude small projects,
ISLFDA and the related HUD regulations provide elaborate rules regarding the aggregation of units which are part of
a common promotional plan. As such, a developer cannot fit within this exemption merely by splitting a project into
different phases or dividing ownership of lots among different “developer” entities. Id. see also, HUD Full Disclosure
Act Exemptions | HUD.gov / U.S. Department of Housing and Urban Development (HUD) To qualify for the
exemption, a developer would need to agree that a purchaser may bring a claim for full monetary damages (including
consequential damages) in the event the unit is not delivered within two years. In many respects, the realities of
qualifying for this exemption may not be much better than the realities of complying with the statute. id.

17
The problem with using this exemption is that standard industry practice is for developers to limit their liability for
failure to timely delivery units. In fact, most developers are reluctant to contractually obligate themselves to deliver
a unit within a specific time frame. HUD and the courts have consistently held that for the two-year delivery exemption
to apply, developers may not limit a purchaser’s legal and equitable rights in any fashion.
18
Because Property History Cards ## 1 and 2, appear to evidence document fraud i.e., all post-bankruptcy entries; it
is unknown whether or not these above-described units are attributable to Kenny Ross or if they represent fictitious
entries of fictitious sales of apartment units. In either case, these are the only known sales arguably attributed to the
Kenny Ross.
19
Purchasers are also permitted to terminate purchase contracts under the Act for a period of two years after contract
signing in the event the purchase contract does not provide (i) the purchaser with notices of the purchaser’s default,

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1975 (date unk): Fort Pitt Federal Savings and Loan forces Ross into bankruptcy and receivership
before the condominium created. Fort Pitt obtains a bankruptcy order from Allegheny County
Court of Common Pleas court “when Ross ran out of money before completion”. 20 See also,
public records corroborating that, Kenny Ross goes bankrupt and IH development is forced into
Bankruptcy and placed in a receivership by Allegheny County Court. It is reported that he never
completes the promised amenities and significant construction and other litigation ensued
including with respect to the roof construction by Triangle Roof. 21.

(ii) the purchaser with at least a twenty-day cure period to cure such defaults, and (iii) that a defaulting purchaser may
recover the portion of the purchaser’s forfeited earnest money which exceeds fifteen percent (15%) of the purchase
price. Moreover, ILSFDA may permit purchasers who have closed on the purchase of a unit to revoke the contract for
up to two years from the date of contract signing. In such cases, the purchaser may be entitled to tender title to the unit
back to the developer and to receive a return of all amounts paid under the contract. Additionally, purchasers can also
recover damages, including attorneys’ fees, from developers for violations of the disclosure requirements and anti-
fraud provisions of ILSFDA. Violations of ILSFDA may also subject a developer to civil and criminal penalties, the
latter of which may include up to five years’ imprisonment. See

20
Sat. Dec. 17, 1977, p. 13 Pittsburgh Post-Gazette, News of Real Estate, paragraph 1.
21
See, Sunday, Feb. 5, 1978, background to story entitled, “Area, Ohio Investors Buy Imperial House” in Pittsburgh
Post-Gazette, Real Estate Building News. Section.

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Dec. 16, 1975 -- Post-Gazette reports that, the condominium project failed because of the
massive unanticipated costs in attempting to shore up the subsidence issues caused by an
abandoned coal mine beneath the property:

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In Oct. 1975: The Post-Gazette reported that the failed condominium development would
instead continue to offer rentals in the apartment building. The Receiver, Sanford Lampl is
quoted in the following article:

Nov 18, 1977 : Pittsburgh Post-Gazette publishes a “ Notice of Public Sale” in Re: Fort Pitt
Fed. S &L v. Imperial House, Inc., GD 75-23287, Block 86-P LOT 150 and Block 86P-Lot 102,

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“A 140 Unit Apartment Building” reporting that Receiver, Sanford M. Lampl, has an offer from
Lhormer Real Estate as follows:

22
December 15, 1977: PPG reports “LHORMER Real Estate, Inc. of Clairton” purchased the
“Imperial House Apartments” at 5600 Munhall which has been in receivership since 1975. The
nine-story, 140-unit complex includes…on 1.6-acre site. Purchase Price was “$5,130,000”
although the property was appraised with a FMV of $5.8 Million nearly $700k more than the

22
Nov. 18, 1977, p 23, 1 Pittsburgh Post-Gazette (Pittsburgh,)

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purchase price. It produces annual income of $394,000 after expenses.” 23 This legitimate
incorporated entity never purchased the project. However, using a name confusion type fraud,
the Arch Lhoermer control confused the entities beginning in 1979. Compare PPG ARTICLE
OF FEB. 5: 24

.
The primary purpose of this false document is to shift all tax liability from the owner of Apartment
building, likely the bank, to the defrauded bona fide purchasers of an undisclosed apartment sold
by an individual who had no ownership over the unit in the place. No one owns any unit at 5600
because it is an apartment building.

Because this above entity is and was the sole possible purchaser of the Development Project, in
or about 1988, in furtherance of the then-control group’s scheme (including Skelton, Frank, and
Tozzi’s), Della Vecchia or created a false property assessment based on a fictitious 1977 sale of
the property as if it had occurred. Upon information and belief, he did not have the ability to
create such a fraudulent before the 1988-ish merger of property assessment office into the
Recorder of Deeds. See press and Row Offices, reports. The fictitious sale allows for the
assessment of taxes to the alleged owners of the unit that do not exist such as my mother, Thus,
the apartment building pretending to be a condo and its control group has successfully shifted all
taxation liability to defrauded bona fide buyers like my mother. See 1988 for detail. It is this
fictitious entry that is attached to the ID Parcel for the entire development versus a unit.

23
Sat. Dec. 17, 1977, p. 13 Pittsburgh Post-Gazette, News of Real Estate.
24
Id. Upon information and belief, the previously reported Lhormer deal fell through and there was no other purchaser
willing to take on the condo conversion. Given the concurrent Savings & Loan crisis, it appears that the Receiver,
Bank, Arch Lhoermer individually and contractors who lost money on the failed conversion, entered into a criminal
conspiracy to circumvent the laws regulating condominium developments, related mortgage, and tax laws all so that
the already likely failing S &l

could conceal its losses to attempt to avoid its own failure. Accordingly, the coconspirators seem to have come up
with a scheme to effectively highjack the apartment which was held for investment purposes and to fraudulently sell
apartments to straw purchasers or innocent bona fide senior citizens who could pay cash up front up front -- like my
mother who was victimized by more than one-million dollars and now even her estate continues to be preyed upon
by, among other things, under color of law violations aided, abetted, and made possible by Michael DellaVecchia \

31

Eve_10/11
See Allegheny county online property tax search. Note this Parcel ID is identical to that used by
subsequent conspirators Arthur L. Goldberg as well as Andrew Silk and Lawrence Silk to obtain
air loans using the development plan property which is likely owned by PNC and/or Huntington
Bank aided and abetted by Royal Bank of Scotland d/b/a Citizens Bank. See later chrono.
The alleged purchase is $4 Million per the above article. Direct evidence of the knowing falsity
of the tax assessment is demonstrated by the fact that no one purchased the property, and the
subsequent fictitious purchase did not occur until 1979. It is impossible for the property
assessment record to be true, yet it has served to allow the criminals to shift all their own tax
liability for nearly 30-years to innocent, unsuspecting victims.
in fact, the entity that was created in furtherance of the scheme had no corporate existence until
1978 as follows:
Jan. 1, 1978:” I imperial House Associates” is created per PA DOS: County Orphan. Status
County Orphan. No information available online or by online request. Must write Harrisburg for
copy of document. No record as to who created the fictitious name used by Lhormer Realty et. al.
The Control Group Attorneys Scheme to Circumvent the Law and Take Control 25
Feb. 5, 1978: Pittsburgh Post-Gazette reports that a sale of the 140-unit Apartment building has
been completed. Notes that many amenities left unfinished and that the plan is to complete the
amenities and offer a luxury apartment building. , Arch Lhormer, Stuart Barman, and Bill Seach
are identified a buyer and allegedly pay $4 Million plus an addition 1 million as described
below. . And that they plan to convert garage to attendant garage which will increase spaces
from 150 to 200.26 Here the buyer is Arch Lhormer “of” the company originally identified as
the buyer. Upon information and belief, his “partners” were contractors on the initial project

25
See Bank Civil Money Penalty 2019-055 (occ.gov) the control group caused CitiBank engage in violations of
law, rule, or regulation, specifically, the laws relating to the holding period of other real estate owned (“OREO”), 12
U.S.C. § 29 and 12 C.F.R. § 34.82. WHEREAS, in the interest of cooperation and to avoid additional costs associated
wit.
26
Id.

32

Eve_10/11
who lost their money and right to payment in bankruptcy. It appears that the initial control
group conspired with the Original lender and Receiver as part of scheme to illegitimately get a
return of their investments and recover the $5-7 million dollar mortgage loan.

Again the 1974 Plot plan was and could not be recorded as a Plan of Condominium then or
anytime thereafter. See UPA and description of each document and contents thereto.
CITE or see the UPA, etc. requirements for creating and recording governing documents of a
condominium assuming one existed. There was no condominium Hence the recorded
documents constitute document Fraud. None of the following documents necessary for the
control to collect unlawful debt from prospective buyers or renters would ever be drafted or even
recorded simultaneously
.
June 24, 1978: The Lhoermer joint partnership (d/b/a Imperial House Associates (“IH
Associates’) 27 allegedly executes before a Notary in Ohio, the “, Code of Regulations
Governing Imperial House” but it is not recorded until June 31,

27
Imperial House Associates does appear to have a corporate existence although the same cannot be said for the
various entities allegedly comprising the membership of the partnership. Imperial House Associates is NOT the
fictious Imperial House Condominium, Inc., that has asserted unlawful control over 5600 since 1998 as described
supra. The current control counted on name confusion in search for title records and as defense to threats to their
unlawful scheme to collect unlawful debt, evade taxes, and protect assets of criminals like Frank, Skelton, and Tozzi
from Forfeiture as described herein.

33

Eve_10/11
1979, DBV 6063-136. See infra for detail.
II.

June 25, 1978: An alleged “ Amendment to Declaration of Condominium Imperial House” is

allegedly executed before a notary in Ohio but is not recorded until January 31, 1979. See infra
f
or detail. DBV 6063-123. This “Amendment” is executed by multiple parties and entities not

34

Eve_10/11
 r
eferenced in any subsequent recorded document to the best of my knowledge.

III.

June 29, 1978: An alleged, “Declaration of Condominium Imperial House” is executed and

allegedly notarized in Ohio. Not recorded until 1979, see infra for detail. In comparison to the

alleged Declaration, only Harold Levine dba , Stuart J. Barman, and Arch Lhormer are

signatories to this document later recorded at DBV 6063-1. See 1979 for detail. Here, the latter

35

Eve_10/11
 i
ndividual executed the document as the “First Members of Council of Imperial House” :

28
See dox as recorded in January 1979, infra.
September 13, 1988-Lhoermer Group buy first piece of Property in consideration of 60K, near
the Failed Project (86-P-107)) in the name of Imperial House Assoc -- this the property that will
be Munhall Road.

28
After due diligence, including searching PA, Ohio public records and nationwide, I cannot identify any evidence
that the Barman, Levine entities existed then or today.

36
37
38
12-26-1978: Exler records the next day at 6003-102

39
September 26, 1978-Lhoermer Group buy piece of Property in consideration of $78k, near the
Failed Project (86-P-108)) in the name of Imperial House Assoc -- this the property that will be
Munhall Road I think....

40
41
42
Sept 29, 1978 Exler records at DBV-911

43
Shortly before Thomas Skelton joins the conspiracy in November 1979, Norman McGovern is
murdered and upon information and belief Skelton is a primary target of criminal authorities
going forward until his eventual arrest in 1980. See supra.;
Oct 1978: PPG reports syndicate Banks Mortgage fraud settlement retroactive to 1976 the group
includes original Lender --DOUBLE-CHECK.

44
Nov. 14 , 1978: Contract Hit -- McGovern is shot to death on his front porch by contract killers
allegedly hired by Thomas “Robert” Skelton. At the time he ran ACME and spinoff entities as
part of an apparent criminal enterprise together with his lawyer Alan F. Frank, his alleged
common-law wife, Donna Tozzi and her son, Dean Tozzi all of whom joined the conspiracy and
were primary architects of the scheme at all relevant times. Upon information and belief former
attorney Alan F. Frank in his then-role as counsel aided and abetted criminal activity and tax fraud
with respect to Skelton controlled companies. While this murder as well as other murders
allegedly committed around the same time period Skelton was not formally charged with homicide
until 1982. In the interim, press reports highlighted the horrific activity of Skelton’s alleged hit
men and associates, as described in an exemplar press report at the time:

45
Overt Acts - January 1979
Buy property in furtherance and draft fraudulent amend to Decl.

January 29, 1979: DBV 6063-315. The Lhoermer Group dba Imperial House Associates,
executes a deed at Parcel ID 86-P-135 purchasing a property for $150k that it used for its Office
while promoting the units in 5600. See below and press reports describing the offices of the
“developer”:

46
The Certificate of Residence is false

47
48
January 31, 1979 -- Della Vechhia’s Immediate Predecessor (Exler) Records the above-
identified Deed for an unrelated parcel of land; Decl. of Plan of Condominium, the Decl. Plan,
and the Amendment thereto simultaneously 29

29
Note, the description of Property, the ID Parcel Identifier and the identities of counsel (who cannot be named
until events that never occurred occur but most notably for my current need have no connection whatsoever to
anyone in the current control group. Under the UPA and the applicable sections of the 1980 Uniform
Condominium Act, there is no Condominium without a legally enforceable Declaration which contains
mandatory information and is recorded by a Developer who actually owns the Parcel. Also, Jug cites this Decl.
against me when it suits him, but no one ever recorded any Declaration potentially applicable to this building
until 2009 when 1979 records were practically antique and could not be obtained online. Also, likely because
of actual overlap with securities fraud, at all relevant times the conspirators used multiple aliases or the names
of associates or family members to make it nearly impossible to trace any deed or mortgage because Della V.
helpfully and as part of the conspiracy instituted a new indexing system which mandates all recorded
documents are indexed by the first initial of the grantor and/or grantees first name. (see e.g., ever DellaV
recording dox is slightly different; plus, all conspirators routinely use slightly different v. versions of Imperial
House; and Lawrence Sik for uses his disabled daughter’s name with no shame whatsoever. While Goldberg
has at least four different aliases and uses the Trust device to shield himself from personal. See Deeds and
other conveyances and carve-outs for detail.- also the language regarding Special Declarant Rights (none), unit
descriptions including Unit 208 (141 Units) and Plot plan demonstrating that the first and current fraudulent
groups converted units into common elements so that the tenants their personal rent and for their personal
money generating business (hotel unit in the illegally converted office which was to have been converted to unit
had the building ever been converted. This is largely irrelevant because there is no condo as a matter of law.
That said, even if somehow Kenny Ross created a condominium by conversion; the current and former
conspirators would still be engaging in identical fraudulent just to a lesser degree. Under no possible set of
possible facts is the building but a means to a corrupt profit-generating, investment, real estate, tax, mortgage,
deed fraud.
See.

PARCEL ID - 86-P-150 -- See also air loans on the instant parcel ID by Goldberg and Silk, Stewart et al, dba
IMP. House Condo. Assoc. Inc. (1998 onward)

49
At 12:10 PM Records Fraudulent Declaration of Imperial House at DBV 6062-1 despite its
obvious deficiencies plus that all documents could not legitimately be ready for recording at the
same time, , he overtly deficient, fraudulent Decl. Plan is recorded. In no way, does it satisfy
the minimal statutory requirement of the UPA mandating what must be included in a legitimate
Decl. sufficient to create a condominium (Ref in EvE deed and certain fraudulent bylaws and
amended decls. filed by Rea, Jug, and Burkhart between 1998 and the present,

12:13 PM Exler records the above Berger Indenture Deed at DBV-318 -- the single piece of

property that Lhoermer Group has purchased which is not yet attached to 5600 Development of

1974,

3:30 PM at DBV Exler records the Amendment to Decl. which will

allow the Lhoermer to file a fraudulent Plan using the property just purchase.
With the exception of the Berger Deed all “Governing Dox recorded on the same date follows:

50
30

30
See land description in Decl. relating back to the 1930 recorded document.

51
and reference to 86-P-150 and 86-po-126, as parcel lot ID and compare to recorded dox which is the only link to any
claimed ownership of 5600 Munhall.

52
53
54
55
56
57
58
.

Then Declaration Recorded

First, IH not Imperial House Associates, Inc, plus Declaration had not yet been recorded nor
assigned a DBV (see 1979)

59
Second, there was no Declaration Plan ever recorded by Ross ever. He had only the draft Plot
Plan which was not recorded -- until ’79 by the hijacking coconspirators. The Property
decryption is material and proves the fraudulent intent and active by Jug, et al, in fraudulent
litigation against me. See 1998 Recorded “Proposed Revised Bylaws” filed by Jug’s then-
partner Henry Rea. 31

31
Upon information and belief, Henry Rea is the son or grandson of renowned Black Hand mafia leader Phillipe Rei
see other alias. PA mobster. Everyone in this matter is connected to old school mobsters in Pennsylvania.

60
61
62
63
64
65
66
67
68
69
70
71
June 1, 1979, Stanley Markovitz drafts an Amendment to the Fraudulent Decl. the Purpose of
which is solely to allow for the fraudulent Plot Plan to be recorded as Decl. Plan. See also, all
fraudulent subsequent conveyances cite the fraudulent plot plan -- NOT -- the Decl., obviously
they believed that the Fraudulent Plan was more convincing than the Declarations and Code
because it would be easier for any experienced professional to recognize the legal inadequacy of
the latter versus a Decl Plan versus a Plot 32. Internet was barely used in 1979 and there was no
Google. 33 This is not Recorded until July 1979
June 10. 1079: The conspirators execute and have Notarized the Plot as a Decl. Plan using
Addendum to allow them to record the PLOT Plan with plausible deniability -- They added
some stamps to original Plot map under the pretext of adding Parcel B per the cover page.
Compare with the 1974 v. infra. DBV -

32
33
Note, all recorded papers contain hallmarks red flags and items specifically identified by recorders as basis for
rejection consistent with document fraud and rubber stamp notarization. See e.g., Admittedly, the above-identified
notary commission expired 6-days before he allegedly notarized the execution of the document.

72
See Amend Decl. and Amended Plot Plan Aka Decl. Plan

July 1979 Wait Six-Months to Make it look Good and then Record Amendment to Declaration
adding the Land they Just Amended to Declaration of Imperial House -- Intentionally Drafted as
an Amendment because there is no Other Way to Circumvent the Existing Decal and they have
to Add Property to Carry it off and get a ROI --DBV 6134-337

73
Overt Act -- July 1979 - Record 1974 Ross Plot Plan as a Declaration Plan as Amended by
Parcel B (solely to create the appearance of legitimacy)
The Fraudulent Recorded Document was drafted and executed 30 -days earlier in June. See
28th.
SITE PLAN FRAUDULENTLY IDENTIFIED AND RECORDED AS DECL. PLAN.
Imperial house Family House Condominium Plan recorded. (ARCH LHORMER, HAROLD
LEVINE MANAGING PTR. UNITED IMPERIAL and Stuart Barman, Diversified Imperial, a
partnership, acknowledge themselves to be the owners in fee simple of the of the Imperial House
Family Condominium Association.
July 13, 1979: DBV 6134-337 a is recorded by Exler

74
75
76
77
78
JULY 19, 1979: at PBV- 110-190 Records the Amended Plot Plan adding “Parcel Creating
more distance between the Hijackers and the 1974 Plot Map attached to the only known
prospective Developer -- ROSS. s recorded as a Plan of Condominium is also recorded JULY
19 , 1979: With three days to make it look good record the June executed Fraudulent Decl Plan
at PBV 110-90 (Forever referred to in fraudulent Prop History Cards In the real world the Plan
of Declaration which would be a first step in establishing a condominium under the UPA but
never occurred. Specifically, after buying certain parcels of property near 5600 as part of the
scheme to file a fraudulent Condominium Plan as mandated by Pennsylvania law as a first step in
creating a condominium association. Because none of alleged owners did in fact own the
property, they circumvented the law by recording the Plot Plan that Kenny Ross ordered and then
attached it to what was described as Part B addition to the Declaration. However, as a matter of
law, neither the 1974 plot plan nor the Part Amended Plan incorporating minor parcels of land
acquired by Arch Lhormer in no way satisfied the requirements for a minimally legally sufficient
Decl. Plan. See e.g., PBV 110-90 conflating 974 Site Map with “Parcel B Amendment.
Neither the ’74 nor ’79 plans satisfy minimal See Supra June.

79
August 18, 979 PPG reports on Grand Opening and the LIE -- Lhoermer and his alleged
Partners Fraudulently Claim they are Converting the Apartment Building to a Condominium.
They don’t own Develop only the Bank Owns. And they cannot lawfully convert -- see ILSDA,
etc.

80
81
82
From this date onward, no unit could be lawfully sold as a condominium. The building was then
and is now an apartment building. The overwhelming evidence is that going forward the
majority of alleged purchasers were in fact straw buyers and conspirators. The exception
appears to be senior citizens willing to pay cash up front having no idea that in fact they were
paying advance rent on a unit that they did not own. And after paying a heavily overinflated
appraisal price, these bona fide purchasers were forced to additional rent disguised assessments,
special assessments all of which was unlawful and constitutes usury. See detail infra as the
chronology progresses.
.
Also, Summer of 1979: PPG reports:

“With nearly 50% OF THE 140 Units sold, owners plan to open Imperial Dr. a new road to the

83
Apts. on Sunday, Sept. 9, The event will be a street party, said Jack Barman, of Diversified
Construction, one of the owners of the nine-story …. Barman said he believes the remaining
units at IH which are being converted to condominiums---will be sold by Spring. Sales could be
completed by the end of next year. Special financing has been arranged with interest rates at
9.5% with 30 % down payment. 9.7 percent is avail with 20 percent down and 20 percent brings
10 percent interest. Barman said two other “Div.-Con” APARTMENTS BEING DEVELOPED
AT Fox Hill and Westpointe in Robinson. 34 (are these Morgan properties from the indictment

Nov. 14, 1979: Skelton joins conspiracy and allegedly purchases Unit 415 which has always
been and will always likely be an apartment. Unit 415 was not sold by the original developer.
Specifically, Skelton and others join the control group’s fraudulent scheme by making straw
purchases of non-existent condo units for the purposes of quickly flipping for cash -- mortgage
loan.

11/20/1979 Skelton gets mortgage on 415 from National First Mortgage Corp of Pennsylvania
$78,400. (Pool 900494) FN1650594654 . Cite 1994 alleged assignment and 1995 Satisfaction:

See 1994 for recorded dox. 35

11/21/1979: mortgage recorded MBV 6868-380 by exler. I have not obtained the original papers.

34
PPG story Street Party to Open Imperial House,
35

84
See Prop. Hist. Card. . fraudulent entities Either Exler or Della Vecchia or his agent made
fraudulent entries on the docket which (1) falsely describe a non-existent interest; (2) omitted
any record of the Mortgage; (3) falsely described a subsequent conveyance to the Reese Bros.
See supra.

36
On November 20, 1979: See US Land Search “Skelton” to find MB recorded in 1994 and
1995 by Della Vechhia to find information regarding the 1979 Mortgage. Nothing was
electronic until after 1999. Pre-1980 property records are not searchable or accessible on
Allegheny County search page. See the only record, I can obtain as follows: than one week
after the alleged purchase of Unit 415 for 95K, Skelton assigned his non-existent ownership in
the apartment to National First Mortgage Corp. of Pennsylvania, and it was securities or put in an
investment pool: See MB 141 P. 059 recorded in 1994 in connection with another assignment --
six-years after Skelton disappeared. Della V. recorded all property records related to Skelton
and Unit 415.
Note, I found the Mortgage and Satisfaction by trial and error.; Nothing connects to 5600
Munhall. See 1995 for more detail: Name search pulled up Mortgage and Mortgage
Satisfaction which refer to the 1979 Mortgage. See below.

36
The card is suspect on its fact. Furthermore, upon information and belief the property card would reference a
Declaration absent which there is no condo. Further, DellaVecchia the Plan did not even minimally satisfy the
requirements for a legally enforceable Plan of Condominium.

85
Nov. 21, 1979. According to 1994, 1995 recorded documents, Della Vecchia also recorded the
Fraudulent Mortgage of an Apartment at MBV 6068-380 in the county of Allegheny). 37 See
above.
Jan. 18, 1980: – UNIT 208, SOLD TO DAVID BROPHIE AND WIFE by “IMPERIAL
HOUSE ASSOCIATES” a PENNSYLVANIA PARTNERSHIP COMPRISED OF ARCH
LHORMER, DIVERSIFIED IMPERIAL, A PARTNERSHIP, AND UNITED PARTNERSHIP,
DATED JAN. 18, 1980. See DB 6134, P. 337. See Nov. 18, 1998 for Hijack Control of 5600
via units 208 and 415.l
1980: Coldwell Banker acquires New York commercial real estate firm Sutton & Towne, Inc.
1980: Jac k Halperin (see HO-11156-A), was indicted by a Grand Jury in the City

37
Absent for Skelton there is no way anyone would know of these transactions by a simple deed search. All the latter
information was discovered via a search under his name which ultimately revealed the two-page recorded document
recorded in 1995 by DellaVecchia.

86
of Scranton in the Middle District of Pennsylvania. The
Indictment charged the Defendant with thirteen (13 Counts
of Interstate Land Sales violation and twenty (20) Counts
of Mail Fraud. See CRIMINAL NUMBER 80-00080-1 (Valley of the Lakes)
1981: Sears, Roebuck & Co. acquires Coldwell Banker.
1981 June 201: Skelton, Codfish Bricker, Chucky Proscedemo are arrested for murder subject
the penalty of death. Skelton was arrested in “his home” Unit 415. While Skelton was eventually
acquitted (according to PR, because the government only put up 3 cooperating Ws who got deals
in return testimony) there is no dispute that those arrested and convicted were members of his
crew, including:

87
Skelton’s associates and alleged co-conspirators included Codfish Bricker a notorious killer who
was convicted for the murder of McGovern among others and was sentenced to death. This
individual who presumably frequented the company of Skelton and Frank at 5600 Munhall is
described as follows in his 2000 obituary which described the series of murders in Pgh at this
time and his status as one of the most notorious killers in the history of Pennsylvania.:
1978 onward: Frank, Tozzi, and others-controlled Acme and related entities. Predicate leading
to next hijack: According to 1987 Press reports and a subsequent grand jury investigation,
Skelton and Alan Frank his then-attorney and partner in ACME Music likely came up with a
scheme to protect Skelton’s assets from forfeiture. Specifically, a likely fictitious sale of the
business to Frank by Skelton. See Dec. 1987.

88
 38
Convicted coconspirator Rende was murdered in 2019. His obituary describes the context of
the alleged killings and Skelton’s roll not just with the alleged murder but also ACME:

38
Bricker had already been convicted for murder as early as 1974:

89
 39
1981 onward: Per later 1987 ) Press reports and a subsequent GJ investigation, Skelton and
Alan Frank his then-attorney and partner in ACME Music likely came up with a scheme to
protect Skelton’s assets from forfeiture. Specifically, a likely fictitious sale of the business to
Frank by Skelton. See Dec. 1987.
1982 Nov. 11: PPG reports on the contract hit and that Skelton resides at 5600 Munhall.

39
Convicted coconspirator Rende was murdered in 2019. His obituary describes the context of the alleged killings
and Skelton’s role not just with the alleged murder but also ACME. See https://www.post-gazette.com/news/crime-
courts/2019/12/30/samuel-rende-contract-killing-hazelwood-pittsburgh-dead-obituary/stories/2019123.

90
Oct. 15, 1982 —- DBV 6656-62. And PHC -dellavechia- fictitious sale of 415 from Skelton to Uncle
Wilbert Knox (Skelton in jail on Contract Hit case looking at the death penalty) seemingly recorded
at DBV 6556-82 (in fact no interest to convey see MB at ____) Likely the fraudulent entry was
made in 1987, see supra.
1982 through at least Nov. 1986: Skelton is in jail.
1982 through at least Nov. 1986: According to a later sworn testimony subject penalty perjury,
in fictitious lawsuit filed by Tozzi against Frank (see press report below)Alan Frank “rents” and
lives in unit 415 through early 1988 not “uncle” Knox. While Skelton was in jail or a fugitive
from justice or dead; at all relevant times Alan Frank lived in unit 415 which he allegedly
“rented” from Skeleton. See 1987 onward.

91
 While Skelton was in jail or a fugitive from justice or dead; at all relevant times Alan Frank
lived in unit 415 which he allegedly “rented” from Skeleton according to Tozzi and Frank who
by then came up with another scheme to preserve their illegal proceeds and continue the fraud at
5600 without detection.
Oct. 15, 1982 —- DBV 6656-62: As a first step in the latter conspiracy, Della V. apparently made
fraudulent entries to the Property History Card for Unit 415 in furtherance of the overall scheme
by adding an entry of fictitious sale of Unit 415 Skelton to alleged “ uncle” Wilbert Knox (Skelton
in jail on Contract Hit case looking at the death penalty) seemingly recorded at DBV 6556-82 (in
fact no interest to convey see MB at ____). Notably, Della V. omits any reference to fact that he
recorded a fictitious mortgage on the Unit in 1979 which was not satisfied and of itself a fraudulent
fiction. Based on the 1994/95 recorded, accessible assignment, the fictitious mortgage was
unsatisfied so even if there was somehow a condominium it could not be conveyed to a third-party.
In sum, there is no way that any of Della V. recorded conveyances could have happened even if
there was a property interest to convey -- which was there not, and everyone knew it. See 1986
supra where Frank, Tozza et al. come up with fictitious lawsuits against each other to ensure that
no one knew that they were conspiring with Skelton and others known and not known. As time
progressed, the court pleadings and public filed by Tozzi and Frank alleged that Frank resided in
the unit from 1982-1988 and that he failed to pay rent. See exemplar press report and subsequent
recorded documents:
.
1983: A. Lhormer retires at the age of 80. 40Because there is no conceivable basis for continuing
the fiction of Lhormer Arch control, the then-control group of 5600 Munhall, come up with a
new scam. The control group undoubtably includes Skelton, Tozzi mother and son, Alan F.
Frank, Michael Della Vecchia, the Control persons of PNC and/or Huntington Bank or Citizens
Bank, etc., the goal is to protect Skelton’s fraudulent asset in Unit 415 while ensuring that the
tenants of 5600 Munhall pay all taxes and illegal fees, etc. to illegitimate control persons.
So, the conspirators come up with a new scam while the criminal homicide is still unresolved
and Tozzi, Frank, Skelton, etc. are all under investigation for tax fraud as a consequence of
evidence elicited during the criminal homicide trial. The new scheme is elaborate and depends
upon fictitious lawsuits and allegations of dispute between tizzy and Frank while maintaining the
fiction that Skelton is likely dead.
1984: ish Skelton acquitted murder - only Witnesses informers Witness Prot) —-but then target
of massive tax fraud evasion case with Frank Tozzi etc. re acme and if enterprises.
Allegedly the last time anyone saw Skelton alive after he became aware that he was a target of a
tax fraud investigation involving ACME and a controlled business JEF. Judge Manning was
AUSAF on the first trial.... After release from jail on murder charges, he went back to ACME.
Skeleton disappears. Garshak hints probably murdered. Others not sure. Owed the like 300k in
taxes even then. See “Missing” PPG article. Due to testimony at trial, Tozzis, Frank targets of
massive tax fraud evasion investigation re ACME and related shell companies.

40
Sat. Oct. 7, 1989, Arch P. Lhormer, Pittsburgh Post-Gazette, Obituaries at p. B, 4.

92
9 PPG ARTICLE
The Uncle Wilber Knox Fiction and everybody Perjured themselves TAX Evasion 41
1983 or 1984: “Uncle Knox” allegedly dies42 (and Frank is allegedly executor of Will according
to press reports but on paper see— See DBV 09339-047
1984-ish Skelton acquitted murder - only Witnesses informers Witness Port) —-but then target of
massive tax fraud evasion case with Frank Tozzi etc. re acme and if enterprises —-/Skeleton
disappears. Garshak hints probably murdered. Others not sure. Owed the like 300k in taxes even
then.
1985: The criminal trials continue. Multiple parties get the death penalty.
1985 See PPG article as follows:

41
Evidence of intent: In furtherance of the scheme to avoid all and any possible convictions and to ensure that
Skelton’s assets were safe from forfeiture at all times, the fictious Estate Lawsuit was commenced as described below.
The fraud is that Wilbur Knox was never in the chain of title on Unit 415. Upon information and belief, it is highly
unlikely that he ever knew about any of this. The scheme that DellaVecchia, Tozzi, Frank, et al., cooked up was to
initiate a fictious dispute regarding Unit 415 which they fraudulently alleged was transferred to Wilbur Knox. Tozzi
and a James Aztutto claimed to the Estate Administrators for Wilbur Knox the owner post-Skelton’s disappearance.
Frank and Tozzi connected another fraudulent feud between them as Tozzi alleged (and admitted ) that Unit was an
apartment in which Frank lived after Skelton allegedly disappeared. Accordingly, she filed a lawsuit that was entitled
to back rent. All of this is smoke, and mirrors intend to ensure that they were perceived as enemies by the applicable
finders of fact and public. See PHC entries by DellaV because Knox not needed until Skeleton’s incarceration.

42
After research, there was a Wilbert Knox who may have been related to Skelton but he n ever lived at 5600 - either
Skelton or Frank at all relevant. I believe his obituary was 1994. I doubt he ever knew anything about this.

93
 43
1986 -Lhormer Dies New Control Group Need for Frank/Skelton
1986: Lhormer Arch dies. Obituary notes he Retired at the age of 80. Survived by son Barry
whom he helped found Busy Bee, which was sold to Cyclops Steel in 1972, 44 With no Lhoemer
ready or available to perpetuate the ongoing fraud, the coconspirators had to come up with a new
plan to maintain control over the building per the fictitious scheme. Unit 415 (Skelton’s
interest)and another unit 208 were the means by which the new control group seized control.
To perpetuate the fraudulent scheme, ,k it was necessary for - Della V. or his agent had to make a
false entry on the property history card for Unit 415 to support the fiction that Skelton sold the unit
to his “uncle” Wilbert Knox in 1982. First, Unit 415 is and was a rental unit and thus it could not
be sold to Knox or Skelton for that matter. Second, whether or not Knox was related to Skelton,
public record search confirms he never resided at 5600 Munhall. Third, in multiple criminal
records and during fictitious litigation Tozzi alleged and Frank did not dispute that he lived in Unit
413 from 1982 through 1988.
Second, also in 1986, Frank likely represented Tozzi and alleged Knox Cousin, James Astuto, in
obtaining by fraudulent sworn and unsworn official statements, “Letters of Administration” to
Tozzi and Astuto (needed fiction of Knox because Skelton was not declared dead (just missing aka
fugitive from justice), and Tozzi/Frank needed to ensure that the tax/deed/mortgage fraud at 5600
Munhall was not discovered as a consequence of a forfeiture proceeding. By the fictitious Knox
scheme, the Unit was not subject to forfeiture because it was not an asset of either Tozzi or Frank
as consecutive representatives of the estate but see press and Frank/Tozzi story that Frank was
administrator 1983-86)(not according to deed )perjury)
1986 - First Della V. or his agent had to make a false entry on the property history card for Unit
415 to support the fiction that Skelton sold the unit to his “uncle” Wilbert Knox in 1982. First, Unit
415 is and was a rental unit and thus it could not be sold to Knox or Skelton for that matter.
Second, whether or not Knox was related to Skelton, public record search confirms he never
resided at 5600 Munhall. Third, in multiple criminal records and during fictitious litigation Tozzi
alleged and Frank did not dispute that he lived in Unit 413 from 1982 through 1988.
Second, also in 1986, Frank likely represented Tozzi and alleged Knox Cousin, James Astuto, in
obtaining by fraudulent sworn and unsworn official statements, “Letters of Administration” to
Tozzi and Astuto (needed fiction of Knox because Skelton was not declared dead (just missing aka

43
See 2019 Rende Obituary.
44
Id. .

94
fugitive from justice), and Tozzi/Frank needed to ensure that the tax/deed/mortgage fraud at 5600
Munhall was not discovered as a consequence of a forfeiture proceeding. By the fictitious Knox
scheme, the Unit was not subject to forfeiture because it was not an asset of either Tozzi or Frank
as consecutive representatives of the estate. But see press and Frank/Tozzi story that Frank was
administrator 1983-86)(not according to deed )perjury)
(1986 - ltrs of admin given to Tozzi and Astuto (needed fiction of Knox because Skelton was not
declared dead (just missing aka fugitive from justice) so no letters of admin possible absent an
Uncle Knox. Also, if convicted Skelton etc. didn’t want to lose the unit to government. But see
press and Frank/Tozzi story that Frank was admittatur 1983-86)(not according to deed
)perjury) The Letters. granted despite fact, Tozzi under criminal investigation at criminal tax
charges and multiple criminal civil actions including convictions for tax fraud.
April 29, 1986: Per Detail in article Below -- With Frank convicted, he had come up with a
way to get the fraudulent Wilbert know unit 208 out of his hands to Tozzi.
April 12, 1986 - He steps down as Executor the of the fictitious Knox Estate -- meaning he
must a forged a will because he could not otherwise be an Executor versus Admin. See charges
for forgery on Skelton papers. . They get two new conspirators -- the Astutos and Tozzi who is
also under indictment applies to be administrator.

95
1986: Letters of admin to Tozzi/ Astuto despite tax charges and multiple criminal civil actions
including convictions for tax fraud.
1987
January 1987: Tax evasion charges filed against Alan Frank who disappears. See below Dec.
1987 press articles. See Ju ne 12, 1987: PPG report Union Bank and Lehman Bros. try to get asset
freeze on monies Tozzi is allegedly suing Frank pursuant another fictitious lawsuit.
June 12, 1987: PPG reports:

96
Frank becomes a Fugitive from justice and absconds.

November 5, 1987: Frank arrested after evading justice by disappearing --sailing in Caribbean on
yacht.
November 1988: PPG reports on Tozzi’s second trial. Cite 3rd Cir Appeal for facts.
1987 April 29: Alan Frank Grand re: Tax re a JEF Entertainment, an apparent joint venture
between Frank and Skelton. Tozzi and Frank appear to have concocted a scheme to avoid
prosecution including by fabricating a fictious lawsuit between the two of them and Tozzi
regarding an asset purchase of Skelton controlled assets. And concurrently, the Tozzis, Alan F
Frank and others known and not conspired to conceal the massive mortgage, deed, and tax fraud
that they orchestrated by seizing unlawful control of the Apartment Building when all along

97
everyone involved knew that there was no condominium and no one other the original pre-1979
purchasers from Kenny Ross ever had or could have any legitimate ownership of any unit. 45
December 4 and 5, 1987: PPG reports Tozzi, Skelton in abscensia (dissappeared in 1984),
Frank, are indicted by Grand Jury on income tax evasion charges. The case involves involves
likely fraudulent spinoffs of controlled entity, ACME for the purposes of tax evasion allegedly
begining in 1978, the same year as the McGovern murder and one year before Skelton/Frank,
etc., joined the conspiracy to control the apartment building at 5600 Munhall.

December 11 1987: The fictious lawsuit re Unit 415 -- First, Frank never had to pay rent on the
fake condo. Second, Wilbur Know conveyance was a fiction to protect Skelton fictious asset.
Third, everyone involved in 1978 knew that Skelton had conspired with Bank to get mortgage on
non-existant ownerhip of Unit 415, which Bank immediately sold to instutional investors as part
of pooled Mortgage Back securites scheme. Tozzi was not married to Skelton and even if she
was, she knew she was going to jail for the tax fraud on Acme. Alan Frank also perjured himself
and demonstrates his active role (likely as the mastermind/architect of the scheme) given that

45
Evidence of intent: In furtherance of the scheme to avoid all and any possible convictions and to ensure that
Skelton’s assets were safe from forfeiture at all times, the fictious Estate Lawsuit was commenced as described below.
The fraud is that Wilbur Knox was never in the chain of title on Unit 415. Upon information and belief, it is highly
unlikely that he ever knew about any of this. The scheme that DellaVecchia, Tozzi, Frank, et al., cooked up was to
initiate a fictious dispute regarding Unit 415 which they fraudulently alleged was transferred to Wilbur Knox. Tozzi
and a James Aztutto claimed to the Estate Administrators for Wilbur Knox the owner post-Skelton’s disappearance.
Frank and Tozzi concocted another fraudulent feud between them as Tozzi alleged (and admitted ) that Unit was an
apartment in which Frank lived after Skelton allegedly disappeared. Accordingly, she filed a lawsuit that was entitled
to back rent. All of this is smoke, and mirrors intend to ensure that they were perceived as enemies by the applicable
finders of fact and public. See

98
there was no Wilber Know estate over which he could serve as Adminstrator or Executor. It is
all theatre. See MB recorded by DellaVecchia in 1995 at P.
\

As part of the conspiracy to create the illusion of a fraction between conspirators, sues Frank for
rent. He acts as administrator of fictitious Wilber Knox ownership of unit 415 see PHC. Will
contest. Then Tozzi and astuto claim to be administrators of Knox - estate. Tozzi appeals
through 1990.

1988 -- OVERT ACTS -CONTROL UNITS 208 TO 415 - THIS CONSPIRACY CONTIUES
THROUGH THE PRESENT ALBEIT THE COMPOSITION OF THE CONTROL GROUP
CHANGED IN 1994 -1995.
June 10, 1988: PPG at p. 8 Frank and Tozzi found guilty after 6-week trial for tax evasion, etc.
See Aug. 19, 1988 Press report. See references to 5600 Skelton, Frank living here -- Frank
though 1988.

99
June 27, 1988 : Rita Bi-Weekly. mortgage 68,000 K in unit 509 says deed to be recorded. MBV
9840-631 dba 64102
August 19, 1988: PPG reports Frank sentenced to 6-years’ incarceration.

100
November 17, 1988: PPG reports facts leading to mistrial and 1989 Order for New 3rd Trial.
Story important because it describes the relationships and fraud on the courts to this date.
Skelton, Acme, Frank, and Dean/Donna Tozzi

101
 89 Order for New Trial.
Nov 18, 1988: Frank and Donna Tozzi was convicted under 18 U.S.C. § 371, for conspiring to
defraud the United States of income tax due and owing. The circumstances leading to this appeal
are as follows. An indictment was returned in the Western District of Pennsylvania charging
Tozzi, and certain other defendants, with tax issues relating to Acme Music Company, which
owned coin operated vending machines generating substantial sums of cash. The prime operator
of Acme was, at least for some time, Robert Thomas Skelton, who was also indicted but who,
according to the briefs, is a fugitive and has not been apprehended....there can be no doubt, but
that Acme did not "le tax returns reflecting substantial sums of income. tax fr. Frank sentenced
to six-years’ incarceration. See PPG Frank does not begin his sentence util January 1979 --
accordingly, time is of the essence:
The Very Next Day the Conspirators Attempt to Get Property in Fictitious Name of Imper.
House Condominium, Inc. a non-existent corporation to Protect the Scheme and for
Frank/Skelton avoid forfeiture and continue to evade taxes.
Nov 19, 1988: Before MD Notary, An Indenture Deed as executed by Grantor attorney, Gloria
Silver under a Power of Attorney recorded POA VOL. 160, P. 153 and Imperial House
Condominium Association, Incl. by Herbert R. Miller, President: Silver on behalf of Brophie

102
sells Unit 208 to “Imperial Condominium House Associates, Inc., a for -profit Corp46.” in
consideration of $70,00. 47– See Dec. 1, recorded dox by Della Vechhia. as “{O of C”) see Dec.
1.
“BEING THE SAME PROPERTY CONVEYED TO DAVID BROPHIE AND WIFE by DEED
OF “IMPERIAL HOUSE ASSOCIATES” a PENNSYLVANIA PARTNERSHIP COMPRISED
OF ARCH LHORMER, DIVERSIFIED IMPERIAL, A PARTNERSHIP, AND UNITED
PARTNERSHIP, DATED JAN. 18, 1980 (AND RECORDED DB 6134, P. 337. 48
Note, it is two different entities one for-profit, one not -- first known use of the IHCA, Inc.
fraudulent corporate name. First, the fictitious sale of a fictitious interest in an Apartment
Building is conveyed from an original straw purchaser *Probe” by and through Atty POA in
Maryland. The document is rife with evidence of Document fraud.

46
False Statement see PA recorded dox.

47
Brophie was an original straw purchase and conspirator in the fraudulent sales and purchases of apartments.
48
Maryland resident Brophie allegedly sells unit 208 in consideration of $70k by indenture deed to Imperial House
Condominium Assoc., Inc. (no record of this entity in Pa biz records because the Indenture was recorded in Maryland
on . see DE Book Vol. 7919, p. 179-181.

103
`In Maryland, allegedly, an alleged Indenture Deed as executed by Grantor attorney, Gloria
Silver under a Power of Attorney recorded POA VOL. 160, P. 153 and Imperial House
Condominium Association, Incl. by Herbert R. Miller, President: Silver on behalf of Brophie
sells Unit 208 to “Imperial Condominium House Associates, Inc., for conspirators rely on name
confusion, trying to use the defunct shell of Imperial Associates but perhaps Lhormer son

104
objected, and they had to stoop to fictious name similar the previously recorded dox. The
language of the conveyance is as follows.

Nov. 23, 1988

On or about, Nov. 23 the conspirators meet at 4919 Butler Street, Pgh. PA at a time unknown
and prepare, execute and notarize a bunch of separate forms as a single Mortgage loan with
appropriate Riders. The control group d/b/a Imperial House Condominium Association, Inc,
pledges as collateral its fictitious interest in Unit 208 and 208 Munhall in one document which

105
consists of multiple partial excerpts of various Freddie/Fannie MAC forms which is evidence of
document fraud in and of itself.
The new Control Group gets Mortgage Loan on fictitious Brophie interests See Allegheny
County US Land Records, Name Search, results “Imperial House Condominium Assn. Inc.”
versus Imperial House or Imperial Associates to find any evidence of either Deed or Mortgage.
The Mortgage is recorded as described below on Dec. 1, 1988 by Della V as an 18-page
Mortgage beginning MBV-10069-460 copies. The entire document is entirely consistent with
fraud on its face.

First, , MB 10069-460 is a single-page instrument purporting to be a mortgage loan on Unit 208

which was allegedly conveyed to IMCA, Inc. on Nov. 16. See Id. While the instrument is
entitled “Mortgage” in small print in the footer is the following language: Multistate
Condominium Rider -- single family Freddie/Fannie Single Family Uniform Instrument, Form
3140 v. 12.83 -- Meaning it is an old version of a FM Form but only including one page of
several. Note the collateral for a $56k loan is Unit 208 described as follows
:

`
community savings Association 6319 Butler St. for the amount of $56,000 due and

payable unknown December 1, 2003 for unit 208 and together with \a .664904%

and divided interest in the common elements appurtenant thereto the condominium

project known as Imperial house, and at as shown as defined in the declaration plan

as
r
ecorded in the recorder's office of Allegheny County plan book volume 108, pages

126 to 39, and as amended by plan recorded in plan book volume 110 page 190 and
i
n the D declaration of condominium being recorded in volume 6134 page 337 and
t
ogether… Said unit 208 and .6690% undivided interest in the common elements

granted thereto
... mortgage is in favor of
Note. there is not Condominium Project, and everyone knows it. Community Savings

106
MB-10069-461, The next page of recorded document contains language from a different
Freddie/Fannie From, namely MULTISTATE CONDOMINIUM RIDER --SINGLE FAMILY
RIDER -- FORM 3146 12/83 WHICH DESCRIBES A NON EXISTANT ADDRESS AND
INTEREST IN THE FICTICIOUS CONDO PROJECT -- SPECIFICALLY, THE RIDER IS
FOR ‘208 IMPERIAL HOUSE, 14TH WARD, PGH PA 15217 A “CONDIMUM PROJECT”
NOT UNIT 208 OF 5600 MUNAHLL
This IS EXECUTED BY A HERBERT R. MILLER AS President, Imperial House
Condominium Association, including the long defunct corporate shell of Kenny Ross.

107
Second, at MB Vol. 10069-462, is a one-page document unrelated to prior form documents
which are mutually inconsistent. Specifically, this is FM Standard MULTISTATE Form 1-4
FAMILY RIDER, ASSIGNMENT OF RENTS , FORM 3079 12/05. The 1-4 family rider
(versus single family ridder above) CLAIMS AN ASSIGNMENT IN ALL RENT ROLLS OF
208 IMPERIAL HOUSE “. Again, the assignor is the defunct corporate shell IMPHCA INC.

108
Mortgage Rider executed by IMCA, Inc., Herbert R. Miller and another individual as secretary
and references a non-existent property as follows: 208 Munhall Road, Pittsburgh PA 15217
NOT 5600 Munhall Road, Unit 208. conveying interest in the “Condominium Project” known as
“Imperial House.” This record constitutes evidence of mortgage and deed fraud because it
refers and describes a non-existent Condominium Project at 208 Munhall Road NOT 5600

109
Munhall, Unit 208

110
Third, at MB Vol 10069-463-465 are seemingly, conflated, excerpts of versions of different
Freddie/; Fannie Uniform Instrument, namely, Form 3170 and 1685, styled as a 1-4 Family
Rider 49 and - Assignment of Rents. See MB Vol. 10069-462-465. These pages described and
referenced the interest conveyed to Bank as specific to the nonexistent “Condominium Project at
208 Munhall Road.” and the instrument was executed a Herbert R. Miller in front of Community
Saving Bank, counsel: Michael Georgalas, who allegedly notarized the instruments. Id. at 465.
50 See entire 1999 supra for satisfaction of mortgage fraudulently recorded as related to a
different entity, supra, Section 1999 and MB 10356-344, searchable and discoverable under the
name, “Imperial Associates” -- the long defunct joint partnership.

49
Use of the 1-4 Family Rider is mandatory for all Mortgages secured by 2–4-unit properties and originated using the
single-family Fannie Mae/Freddie Mac Uniform Instruments. See e.g., Exhibit 4 (freddiemac.com) viewed Mar. 25,
Typically, a 1-4 Family Rider = any residential property of 1 to 4 units that is rented out (i.e., investment property).
If the vacation home is also rented for more weeks than is allowed (there's a margin allowed, don't remember how
many weeks that is), or alternatively - if the borrower doesn't live in the vacation home for the required minimum
number of weeks, it's going to fall under this category.
50
Moreover, based on public records regarding a standard Form 3170 strongly suggests that the conspirators conflated
at least two different Fannie/;Freddie Uniform Instrument Forms to conceal that (1) that the units constitute
unregistered securities for rent being held for investment purposes, (2) to conceal the fact that Bank was trying to
make up its losses on the original investment by a scheme to evade the applicable disclosure laws to regulators and
investors; and (3) to evade taxation for the rental building by shifting the tax liability to unsuspecting bona fide
purchasers who effectively pay hundreds of thousands of dollars up front to “rent” not buy an apartment. See supra
2006 EvE facts. See e.g., 2021. See also, SEC Edgar at Multifamily Deed of Trust, Assignment of Leases and Rents,
Security Agreement (PNC detail description of the parameters and implications of this interest which is limited to
investment units and rentals albeit with respect to another property). Public records regarding a standard Form 3170
strongly suggests that the conspirators conflated at least two different Fannie/;Freddie Uniform Instrument Forms to
conceal that (1) that the units constitute unregistered securities for rent being held for investment purposes, (2) to
conceal the fact that Bank was trying to make up its losses on the original investment by a scheme to evade the
applicable disclosure laws to regulators and investors; and (3) to evade taxation for the rental building by shifting
the tax liability to unsuspecting bona fide purchasers who effectively pay hundreds of thousands of dollars up front to
“rent” not buy an apartment

111
112
113
Note, the check-off boxes for type of Rider are materially inconsistent with the foregoing Riders
and Form excerpts.

114
Nov. 30 1988 -- THE INDENTURE DEED BTWN BROPHIE AND IHCA INC IS
EXECUTED AND NOTARIZED BY GEORGELAS AT BUTLER Street.
Specifically, within one week subsequent to the Mortgage Loan, the Brophie Deed is conveyed
to Bank and executed, notarized by Georglas, Counsel to Bank, and Miller. Note the owner’s
residence is certified as being the BANK’S Address (but such conveyance is not reflected in the
fictitious chain of title for Unit 208 or the fictitious Condo Project at 208 Munhall. See Bropie
IH DEED at DBV 7919-182. See above at 11/19.
The Fraudulent Deed and Mortgage are unrelated on their Face because they describe two
different properties: Fraudulent Deed and separate but related Mortgage on unit 208 and “208
Imperial House”, respectively is executed

and witnessed in Allegheny County by Bank Lawyer at bank. Herbert

Miller on behalf of corp., that is not Imperial House witnessed by Michael Georgalas, bank
attorney

at then-named Community Bank.

115
December 1, 1988 - DellaV affirms, adopts, and makes official the Fictitious Deed and Mortgage
by Recording as follows."
.
Della Vecchia records multiple alleged conveyances at once:
●3:41 PM DellaV. records “Brophie “Deed” to INHC assoc. inc) s assigned to Bank. Recorded
with Brophie sale at Deed BK Vol. 7919-182, See 11/19 and 11/30 above.

116
●3;42PM DellaVecchia records mortgage MB Vol- 460 - 464 " executed by a “Herbert R
Miller as president of Imperial Hall house condominium Association Inc”. executed the
document in front of Michael George ballasts attorney 603 bank power 307 4th Ave. PA 15222
See Nov. 23, 1988, supra. and Recorded Documents. Bank’s security interest in Unit 208 which
is fictitious collateral because it is an apartment, is described in the Mortgage as if it were
secured interest in 208 imperial House NOT 5600 Munhall Unit 208. The intended effect is as
if it were a separate property and an entire development not just a unit therein as part of this
recorded deed, DELLAV. includes at pps 460-464 a paper as an As-is-Deed, which is in fact a
mortgage on “208 Imperial House” NOT UNIT “208” --the piece of the recorded paper is
executed by “Herbert R Miller president of Imperial Hall house condominium Association Inc”.
witnessed by BANK’s attorney, Michael Georgalas \ e 307 4th Ave. PA 15222. See Deed
Book, Allegheny County pages 460 etc. on December 1, 1988 recorder Michael Della Vecchio at
3:42 PM
If one searches by first initial the electronic index, the name search identifies a whole lot of
entities while the property tax assessment search.
\
Property History @Willbert Knox 1982-1994 - Property card. Dellavecchia altered the property
card. “ Forged Altered fox
Press Reports demonstrate Frank lived in 415 (see also fake litigation, Tozzi against Front back-
rent.
●3:41 PM DellaV. records “Brophie “Deed” to INHC assoc. inc) s assigned to Bank. Recorded
with Brophie sale at Deed BK Vol. 7919, p. 182, 178-81, no rider by or certified by Michael
George Gowers certifying that precise residence of the grantee is community savings Association
4319 Butler St., Pittsburgh PA 15201 witnessed on November 30, 1988 but recorded on
December 1. The Deed is witnessed and notarized by Michael George Gowers certifying that
precise residence of the grantee is community savings Association 4319 Butler St., Pittsburgh
PA 15201 witnessed on November 30, 1988 but recorded on December 1. The recorded
document is described as As-is-Deed by DellaV and there is no reference to the simultaneous
fraudulent mortgage. The Certificate of Residence required to be signed by “OWNER” is not
the entity on the deed but rather the BANK.
“{ precise residence of the grantee is community savings Association 4319 Butler St., Pittsburgh
PA51 15201.”
●3;42PM DellaVecchia records mortgage MB Vol- 460 - 464 " executed by a “Herbert R
Miller as president of Imperial Hall house condominium Association Inc”. executed the
document in front of Michael George ballasts attorney 603 bank power 307 4th Ave. PA 15222
See Nov. 23, 1988, supra. and Recorded Documents. Bank’s security interest in Unit 208 which
is fictitious collateral because it is an apartment, is described in the Mortgage as if it were
secured interest in 208 imperial House NOT 5600 Munhall Unit 208. The intended effect is as
if it were a separate property and an entire development not just a unit therein as part of this
recorded deed, DELLAV. includes at pops 460-464 a paper as an As-is-Deed, which is in fact a
mortgage on “208 Imperial House” NOT UNIT “208” --the piece of the recorded paper is

51
See bank history, CSA acquired by Three Rivers Trust Bank then Sky Banc and ultimately Huntington Bank. The
mortgage may have securitized or sold to some third-party debt buyer. See www.sec.gov at Edgar for all relevant
filings by the related public companies.

117
executed by “Herbert R Miller president of Imperial Hall house condominium Association Inc”.
witnessed by BANK’s attorney, Michael Georgalas \ e 307 4th Ave. PA 15222. See Deed
Book, Allegheny County pages 460 etc. on December 1, 1988 recorder Michael Della Vecchio at
3:42 PM 52
Accordingly, it is near impossible absent time and money to identity and/or relate the fictitious
deed with the interest therein assigned to the BANK at all relevant times until the alleged
satisfaction recorded in 1999 after the Fraudulent Control Group seizes unenforceable authority
to collect unlawful debt by virtue of fraudulent fictitious governing documents filed by JUG
BURKHART ET AL. SEE AUGUST 1999.
If one searches by first initial the electronic index, the name search identifies a whole lot of
entities while the property tax assessment search is by then TRB or
The ultimate result is that online searches for Unit 208 by name turn up results such as this
:

Click

52

118
53
See alleged satisfaction 1999 indexed under Community Bank which was nonexistent as a bank
by 1999.
June 15, 1989:
1988
Property History @Willbert Knox 1982-1994 - Property card. Dellavecchia altered the property
card. “ Forged Altered fox
Press Reports demonstrate Frank lived in 415 (see also fake litigation, Tozzi against Front back-
rent.
See alleged satisfaction 1999 indexed under Community Bank which is by then TRB or
See December 1, 2019 for recordation of all conveyances by della v. See Allegheny County US
Land Records, Name Search, results “Imperial House Condominium Assn. Inc.” reflecting the
following entry as recorded):
1988 aporix Tozzi and frank, Skelton indicted. Ultimately two trials. In the first trial,
“An indictment was returned in the Western District of Pennsylvania charging Tozzi, and certain
other defendants, with tax offenses relating to the affairs of Acme Music Company, which owned
coin operated vending machines generating substantial sums of cash. The prime operator of
Acme was, at least for some time, Robert Thomas Skelton, who was also indicted but who,
according to the briefs, is a fugitive and has not been apprehended. For some period, Tozzi was
involved in the operation of the business, signing checks, handling cash, ordering parts, and
signing employee withholding forms. There can be no doubt, but that Acme did not "le tax
returns reflecting substantial sums of income. Tozzi was tried twice.
cite 3rd circuit appeal of new trial.

53
.

119
1989: Coldwell Banker Commercial Real Estate Group sells unregistered securities when no
safe harbor or exemption is available to it because it was previously involved in reverse merger
transaction and because at some point in its corporate history it was a shell corporation.
Accordingly, its control group circumvented the law by using a fraudulent spinoff to resell
restricted stock as free trading stock into the market for profit and to cover its losses for illegal
conduct in violation of Section 5 of the Securities Act.54 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."55
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 registration statement is a form
containing detailed information that the issuer must file with the SEC. 56Moreover, a spinoff
may only57: Stock may be distributed in an unregistered “spin-off” 58transaction if certain
conditions are met59.
Among other things, the shares distributed by a parent company in the “spin-off” must have
been held for at least two years; the “spin-off” must be for a valid business purpose; the shares
must be “spun-off” pro rata to the parent’s shareholders; the parent shareholders may not
provide consideration for the “spun-off” shares; and 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.

54
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 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 commerce.
55
56
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
57
SEC v. Capital Gains Research Bureau, Inc., 375 U.S. 180 (1963). The Supreme Court stated 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 Investment Advisors 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,

58
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:
Corporate Spin-Offs as a Device for Public Distribution Without Registration, 42 U. Colo L. REv. 11
(1970).
59

120
 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 Securities 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.” 60
In the criminal landscape, a 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).
See e.g., SEC v. Spongetech Delivery Systems, Inc. HO-1156-A UvE to the OUSA-NJ, 2015.
CITE

May 1989: Tozzi granted new trial on Tax Evasion. SEE FACTS FROM 3RD CIRCUIT
APPEAL

60
See SEC v. Datronics Engineers, 490 F.2d 250 (4th Cir. 1973) (rev’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.)60see 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 Security 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 security60

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. 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 criminal prosecutor’s burden to
“establish the essential elements of knowledge and willfulness as to a conspiracy to sell unregistered securities via a
fraudulent spinoff scheme. Alternatively stated, 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).60

121
May 1989: Tozzi granted a New Trial. Later the US appealed this Order to Third Circuit --
appeal cite for facts.
“first, she was tried with a co-defendant, Alan Frank, who was convicted on two counts and
acquitted on one. The jury, however, was unable to reach a verdict in her case and thus there was
a mistrial as to her. At the second trial, at which she 1 Charles D. Sheehy, Acting U.S. Atty.,
Constance M. Bowden (argued), Pittsburgh, Pa., for appellant. Victor H. Pribanic (argued),
Pribanic and Pribanic, McKeesport, Pa., for appellees. Before SLOVITER, GREENBERG and
SEITZ, Circuit Judges. OPINION OF THE COURT GREENBERG, Circuit Judge. The United
States, pursuant to 18 U.S.C. § 3731, appeals from an order of May 31, 1989, granting appellee,
Donna C. Tozzi, a new trial following her conviction under 18 U.S.C. § 371, for conspiring to
defraud the United States of income tax due and owing.

The circumstances leading to this appeal are as follows. An indictment was returned in the
Western District of Pennsylvania charging Tozzi, and certain other defendants, with tax offenses
relating to the affairs of Acme Music Company, which owned coin operated vending machines
generating substantial sums of cash. The prime operator of Acme was, at least for some time,
Robert Thomas Skelton, who was also indicted but who, according to the briefs, is a fugitive and
has not been apprehended. For some period, Tozzi was involved in the operation of the business,
signing checks, handling cash, ordering parts, and signing employee withholding forms. There
can be no doubt, but that Acme did not "le tax returns reflecting substantial sums of income.
Tozzi was tried twice. At the "first trial, she was tried with a codefendant defendant, Alan Frank,
who was convicted on two counts and acquitted on one. The jury, however, was unable to reach
a verdict in her case and thus there was a mistrial as to her. At the second trial, at which she 1
Charles D. Sheehy, Acting U.S. Atty., Constance M. Bowden (argued), Pittsburgh, Pa., for
appellant. Victor H. Pribanic (argued), Pribanic and Pribanic, McKeesport, Pa., for appellees.
Before SLOVITER, GREENBERG and SEITZ, Circuit Judges. OPINION OF THE COURT
GREENBERG, Circuit Judge. The United States, pursuant to 18 U.S.C. § 3731, appeals from an
order of May 31, 1989, granting appellee, Donna C. Tozzi, a new trial following her conviction
under 18 U.S.C. § 371, for conspiring to defraud the United States of income tax due and owing.
June 15, 1989: Immediately thereafter, the Conspirators move forward to Retain Control of
Skelton./Frank Controlled Unit -415
1989 --Unit 415 (Skelton/Frank Unit) and Obstruction of Justice (DellaV) in
June 15,1989: Thorpe Reed files a Certificate of LIEN against Tozzi and Astuto (the fictitious
Estate Administrators at the same day, Della V records this transaction in the Deed Book at DB
8035-651 which allows for inference that Imperial House Condominium a non-existent corporate
entity without standing was in fact a legitimate creditor. Also, for purposes of confusion and to
evade detection Dela V described the Deed as of “O of c” :
” 61

61

https://pa_allegheny.uslandrecords.com/palr/controller?commandflag=searchByNameID&optflag=SearchCommand

122
Then download the document and see actual recorded document which Court is imposed Lien
on Unit 415. See later Rees Bros get it for a dollar. And reading the court papers, I now identify
a fraud on the court because this proceeding and lien references unit 415 -- See also reference to
Code of Covenants a term of art referring to a non-existent governing document never recorded
by only known Developer -- Ross.
January 31, 1989 - Dellav records fraudulent conveyance.
Recorded by DellaV at DBV 0835-648 : As a reminder, the story testified to by Tozzi, Frank,
et al., was that he owed the estate bank rent on the unit. However, there is the only known action
is by the fictitious corporation against the fraudulent administrators solely for the purpose of
maintaining and obtaining control over at least two units in the Building in furtherance of the
overall scheme.

Astuto Knox and Tozzi to “Imperial House Condominium”. Certificate of Lien filed against

Astuto and Toto [re 415 the unit they allegedly sold to Reese Bros for amounts that run with the
l
and not the owners even though Astuto/Knox no longer own property per 1994.
Recorded Indenture deed above] described individuals by counsel for IHlllC, Thorpe

Reed at G. D. No. 6069 009912. Recorded dox are the Court papers filed by Thorpe Reed (the
lien)
“Re. Unit 415 recorded by deed [Oct. 28, 1992 ] [NO. — Skelton in 1979]. presumably
when Defendants (Knox et al) as “owners of unit 415 “agreed to the “Imperial House
Condominium” (owner of the Development
“Declaration of Covenants of Record” (as then maintained in the Office of the Recorder of
Deeds, Recorded at Volume 6062, pps. 1-10 as amended by Deed Book Vol. Volume 6134, pps.
337-344, and Deed Book Vol. 6436, pps. 220-223 that “provides that monthly and special
assessments “run with the land” [as do all other covenants and promises between developer and
unit owner] are a lien on the property.”
See Nov. 1994: AT ALL RELEVANT TIMES THE FRAUDULENT 1979 MORTGAGE ON
UNIT 415 IS UNSATISFIED AND OUTSTANDING, MEANING NONE OF THE
CONVEYANCES POSSIBLE KNOWLEDGE OF ALL PARTIES OF THE SCHEME.

&county=pa003&userid=null
&userCategory=7&nameid=417059&partytype=&name=IMPERIAL%2BHOUSE%2BCONDOMINIUM&officeid
=60&fromdate=01/01/1986&todate=02/02/2021&lastname=imperial%20house See description single recorded
paper. Identified as O of C filed 6/15/1989 at DE/8035/648. See above Property Assessment Deed Book Ref. for the
alleged purchase of $4,000,000 for the development and see also the same property by Parcel Id No. which was
collateralized for Art Goldberg 150k open loan.

123
124
125
1989 Frank/Tozzi i convicted
1990s
1990s Imperial House required multiple phases of misconduct.
First Phase – Highjack Shell Corps and Established Brands and Tradenames
Early 90’s: Jeffrey Ackerman makes public statements per the July 1996 article next page that
Coldwell Banker begins scouting for a local broker that will give it a Pittsburgh Presence.
1990 March 34: The Third Circuit reversed a prior order of May 31, 1989, granting Tozzi a new
trial will be reversed, the verdict will be reinstated, and the matter will be remanded to the
district court for further proceedings consistent with this opinion. Accordingly, she was
convicted of 18 U.S.C. § 371, for conspiring to defraud the United States of income tax due and
owing. See US v. Skelton, 893 F.2d 40 (3d Cir. 1990)

126
May 4, 1990: Andrew Stewart and Leonard Silk create entity First Allegheny Management
Company located at 425 Craig Street, Pittsburgh PA 15213. Stewart is President and Treasurer
Silk is Secretary.
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. DATE 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]
In 1993, HFS represented it 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]
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 the Company prior to the Acquisition when the Company was
wholly owned by Sears). see 1995, 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:
Oct. 5, 1993: The Fremont Group, Inc. acquired the stock of predecessor company (vs. its
current identity for merger purposes) Coldwell Banker Residential Holding Company and
Subsidiaries).
In approximately 1993, Sears Roebuck spun off. See fraudulent spinoff analysis. And see
integrated offering analysis 62. Spongetech citing,
Feb. 2, 1994, The control group begins the first phase of a pump and dump aka violations of
Section 5 for simplicity. The Johnson Control l Group creates a shell corporation and discloses
that Putnam is the parent company. See www.sec.edgar at. 63
Relevant excerpts follow:

62
At all relevant times, HFS control persons are waiting for the right partner to try to go public which is the ultimate
goal in all these scams.

63
Between Feb. 2, 1994 and May 5, 1996, multiple Sch 13 G forms filed identifying 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.

127
 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. Specifically 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 ....
Item 3. If this statement is filed pursuant to Rules 13d-1(b), or
13d-2(b), check whether the person filing is a:
(g) (X) Parent Holding Company, in accordance with Section
240.13d-1(b)(ii)(G). See 1994.
Date: January 26, 1994, Executed Frederick S. Marius Assistant Vice President and Associate
Counsel 64
199_ Faith Weinstein, executed initial fraudulent property records recorded at Recorders Office.
1993: Unit 702. $1.0. Ostrowski Stan and Kim (now targets of the board);
1994: In SEC filings the control group touted multiple acquisitions and mergers as follows: ,
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]
The ID Parcel Scheme using Skelton/Frank Controlled Unit 65
November 2 and 30, 1994
November 2, 1994 - Coconspirators including Tozzi, Astuto, and the “Reese Bros”, DellaV execute,
notarize, and record fraudulent documents for a fictious condo unit and fictitious Condominium
Development. convey Unit 415, Parcel ID 8-6-150

64
The assumption is that the control persons of MMC and Putnam have decided to try to take a shell company of some
sort of 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 unregistered transaction when there was no exemption or safe harbor available See
Aff, for detail

65
DellaV Records Multiple Overtly Fraudulent Conveyances as Part of the Ongoing Conspiracy to Control 5600
Munhall the Same Conduct is Direct Evidence of Conspiracy with Skelton, Frank, and Tozzi not only the scheme but
also obstruct Justice by his Concealing Knowledge that Skelton was alive and well as late as 1995.

128
First, at time UNK: Tozzi, Astuto, and the “Reese Bros”, DellaV execute, notarize, and record fraudulent
documents for a fictious condo unit and fictitious Condominium Development. convey Unit 415, Parcel
ID 8-6-150 The coconspirators execute, notarize and mail to attorney a deed. Specifically, Tozzi and
Astuto allegedly convey Unit 415 (fraudulent identified as Parcel ID LOT/BLOCK No. as 86-P-150 (the
entire property not a unit therein) to Ralph and Barry Reese as tenants in common66 ( “Reese Brothers”)
in consideration of $182, .00 an insanely inflated value which DellaV uses to calculate Property tax).
While the deed specifically IDs Unit 415, the entire transaction is attached to the Property as a whole
allowing for higher mortgage loans, higher value in the securitized loan, and higher property taxes to
Allegheny County and financial, personal, professional gain for DellaV while financial states are
overstated, and the criminals avoid any taxation which is shifted to all tenants at the apartment building
known as IMPERIAL HOUSE CONDO at 86-p-150. and charges realty tax DBV - 09339-a fictitious
sale from Tozzi/Astuto sell convey Unit 415 to Reese Bros in consideration of $182,500 (100K profit)
— deed no reference to 1989 conveyance to Imperial House as if it never happened). See no reference
to the fraudulent 1988 recorded O of C as a Deed to IMCA INC.
Second, at 4:12 PM, 4:12 PM DellaV records the fictitious conveyance at DE Vol 9339/45 and
fraudulently uses a fictitious property ID 86-p-150 (see later air loans Control Group 200S and
Goldberg using the same fictitious Property ID SUB MERGER OF PROPERTY ASSESSMENT
INTO DEED RECORDER ROW OFFICE.
DellaV records an Indenture Deed purporting to be a conveyance of Frank/Skelton Unit 415 to the
Reese Bros. who have their own issues . The Deed is recorded at DBV 9339-- 45. The Indenture
reflects that Barry and [ ] purchase Unit 415 in consideration of $182,500 on the same date as the
deed was recorded. The fraudulent deed states that Tozzi//Tozzi Co-Administrator for fictitious
Wilbur Knox estate which was purported recorded as conveyed to Imperial House per the recorded
Lien above, in 1992 when it was last convenient for the conspirators to use the Unit 415. . Yet
notwithstanding that recorded conveyance of which is there is no mention whatsoever, the
conveyances is described as follows:

....whereby the co-administrators convey all interest in Unit 415 to the Reese Bros as tenants in

common in consideration of &182,500 certifying that unit no 415 “with an undivided 1.01457

percent interest in the common elements appurtenant thereto, that the condominium project

known as the Imperial House situated in the 14th ward ... as “shown and described in the
Declaration of Condominium as recorded in [recorder’s office] in Plan Book Vol. 108, pps. 126-

139, as amended by Plan recorded in Plan book volume 110, pg. 190, and the “Declaration of C

condominium ‘being’ recorded at de book Vol 6062, pg. 1; and the Amendment to the

“Declaration” [] being recorded in Deed Book Volume 6134, pg. 337; and .... 1.01457 percentage

66
At all relevant times through the present, the occupant is identified in internal and public records as “
Rita Reese” who according to DellaV recorded deeds allegedly purchased a different apartment altogether in 1988.
Public record searches do not support that either Rita or the Bros ever lived. Upon information and belief, Frank,
Tozzis, Skelton probably still control the unit. See 1995 assignments/transactions. My guess is that the MERS
electronically recording system is obstructing the ability to identify subsequent illegal conveyances likely now
reflecting MERS and whatever financial entity used to perpetuate the fraud, making it impossible for anyone to search
and identify any conveyances via an Index Search. See e.g.,

129
undivided common elements....
Imperial House Condominium” (owner of the Development), “Declaration of Covenants of

Record” (as then maintained in the Office of the Recorder of Deeds, Recorded at Volume 6062,

pps. 1-10 as amended by Deed Book Vol. Volume 6134, pps. 337-344, and Deed Book Vol. 6436,

pps. 220-223 ...“Also, for consideration ... “be responsible ... for charges for common elements . .
as may be assessed by “the Council” in accordance with the Unit Property Act.... such charges
follow `
land .... lien. “

130
131
132
133
134
135
 67

67
As part of the conduct, the kickback is in part the tax charged for a fictitious conveyance of a fictious property at a
price inflated 3 or 4 times its value if any given the massive3 structural defects, etc.

136
Nov. 30, 1994 - Skeleton is alive and well according to his mortgage.
November 30, 1994. An Assignment of Skeleton 1979 Mortgage loan First National Mortgage loan,
Pool # 900494, FNM 165094654 to Atlantic First Mortgage and Investment Co, Jacksonville
Fl. 32216 in consideration of $1.00 (loan amt. 78,400). Accordingly, Skelton is presumably alive as
paying mortgage or it would have been discharged as a matter of law. Della records one-year later
along with the satisfaction of the fictitious mortgage. See March 1995.
November 30, 199468

68

137
. Irrespective of the latter conveyance, the 1979 Skelton Mortgage on Unit 415, is assigned from
First National Mortgage loan to Atlantic First Mortgage and Investment Co, Jacksonville Fl. 32216
in consideration of $1.00 (loan amt. 78,400). Pool # 900494, Fnma 165094654. Note any search on
US land the Recorder will never turn up any of the Unit 415 conveyances in a fashion that links
them together. So basically, after the fictitious sale of the fictitious condo unit, the BANK assigns
the fictitious securitized collateral to another bank.
1994 Nov. 30: Unit 415 -- MB 14717-059 Re Pool # 198606, AMIC Loan #198606, From
Thomas Skelton (dated Nov. 20, 1979 in the amount of $78,400 to Atlantic Mortgage &
Investment Corporation, Jacksonville Fl., recorded on Nov. 21, 1979 at MBV 6068-380 in the
county of Allegheny) MB 14717-059 purports to record an assignment from AMIC to National
Mortgage of Pennsylvania in consideration of $1.00, executed on the Nov. 30, 1994 by Barry
Wells as president of NMC of PA and the Asst Secretary. There is no corporate seal. The
Notary stamp appears to be a rubberstamped copy. Upon information and belief, the two-pg.
document recording a mortgage and assignment were never recorded by DellaVecchia until June
23 and July 24, , 1995 as the Reese Brothers join the scheme. . None of this appears on any
related Unit 415 chain of title as described above. 69 The evidence is contained in an excerpt of
the intentionally untimely recording in a fashioned to evade detection of fraudulent scheme by
DellaV.

See: MB 14171-59 (recorded by DellaV in 1995 below).

1995 - Skelton, dELLAV
1995: In a Form 8-k furnished to the Commission by Coldwell Banker, the control group of
Putnam d/b/a HFS, announced merger with Coldwell Banker,
March 28, 1995
March 28, 1995: Skelton allegedly satisfies the 1979 Mortgage in the amount of $78,400 dated
11/21/1979 in favor of Fort Pitt S&L (NOT FMC as stated above in assign) Last Assignee AMIC
Loan No. 192606. Note S & L original lender Ross. Nothing is recorded until June 1995.
See date of certification.,
July 24, 1995: MB 15065-289, Michael Della

69
See MB 147171-059 to 060.

138
 See Google search linking Skelton as current owner of parade street 300K residence aka Thomas
Skelton. Also, Donna and dean Tozzi now in presto pa. And apparently has a condo in Fla worth
at least 1 million.

June 23
June 23, 1995. MBV 14717-059, Della Vecchia records the alleged 1994 assignment. Absent any
other allegation or fraud, on June 23, 1995, he knows Skelton is alive. Rather, than report his
knowledge to any regulator or law enforcement authority, he records it. FIRST MORTGAGE TO
AMIC DellaVecchia knows Skelton was alive in 1994. Vecchia records Satisfaction Atlantic
Mortgage/Skelton 2 pg. dox Mortgage satisfaction notarized in FL addressed to “The Estate of
Wilbur Knox” at 4823 Parade Street, Pgh. PA 15207 (donna Tozzi??). Everyone knows he’s alive
and that the whole thing is a blatant tax, Mortgage, deed fraud.
MB 14717-059 purports to record an assignment from National First Mortgage of Pennsylvania to
Atlantic Mortgage and Investment Co. )AMIC) in consideration of $1.00, executed on the Nov.
30, 1994 by Barry Wells as president of NMC of PA and the Asst Secretary. There is no corporate
seal. The Notary stamp appears to be a rubberstamped copy.
In comparison, the recorded 1995 satisfaction the original lender is identified as First.
As a POC, the routinely, use defunct, shells, nominees, aliases, former bank names to confuse and
evade detection. Fort Pitt Federal S &L as compared to the recorded assignment, the lender on
the hook in the bankruptcy; while the separately recorded 1995. The consequence of which makes
it almost impossible to trace any of these alleged conveyances by a Title Search using Grantors or

139
Grantees name. Similarly, because of fraudulent ID Parcel scheme, one cannot identify the
fraudulent control of fictitious development using ID Parcel Unit Lot/Block 86-P-150 versus for
example 86-P-1500-0415 or some version thereof in either US land searches or Allegheny Tax
assessment public records.
Similarly, DellaV et al., falsely identify the date of recording of the Assignment as Jan. 23, 1995
instead of June (it’s possible that I am getting the date wrong because largely indecipherable.
see excerpt from recorded dox:

140
June 24, 1995
July 24, 1995: MB 15065-289, Michael Della Vecchia records Satisfaction Atlantic
Mortgage/Skelton 2 pg. dox Mortgage satisfaction notarized in FL addressed to “The Estate of
Wilbur Knox” at 4823 Parade Street, Pgh. PA 15207 (donna Tozzi??). Everyone knows he’s alive
and that the whole thing is a blatant tax, Mortgage, deed fraud. See Google search linking Skelton
as current owner of parade street 300K residence aka Thomas Skelton. Also, Donna and dean
Tozzi now in presto pa. And apparently has a condo in Fla worth at least 1 million. See DellV
recorded on June 23 at MB 15065-2898 below for complete recorded dox 5065-289, Michael
Della Vecchia records the fictious Satisfaction of Fort Pitt to Skelton (referring to unrecorded
assignment Fort Pitt to First Mortgage) as allegedly assigned to Atlantic Mortgage/Skelton 2 pg.

141
dox Mortgage satisfaction notarized in FL addressed to “The Estate of Wilbur Knox” at 4823
Parade Street, Pgh. PA 15207 (donna Tozzi??). Everyone knows he’s alive and that the whole
thing is a blatant tax, Mortgage, deed fraud. See Google search linking Skelton as current owner
of parade street 300K residence aka Thomas Skelton. Also, Donna and dean Tozzi now in presto
pa. And apparently has a condo in Fla worth at least 1 million. DellaV if not involved would
report this to FBI, US ATTY, DA, IRS TAX, PROBATE COURT, ETC. HE IS LAWYER AND
HAS NO PLAUSIBLE DENIABILITY GIVEN THE ETHICAL RULES OF HIS PROFESSION.

142
See (Facts April through August 1998, when DellaV records fraudulent alleged governing dox
for fictitious develop IP Parcel 86-P-150 using 208 and 415 together with the fraudulent ID
scheme. See also EVIDENCE THAT DELLAV LAUNDERED THE ILLEGAL PROCEEDS
THROUGH PROPERTY AND IDENITICAL MORTAGAE FRAUD WITH SAME POC -- 322
Gladstone Road and Devonshire Road, supra.)
August 1995
-- Ackerman, Silk, Steward, Zehfuss and others join the Conspiracy becoming member of the
Fraudulent Control Group
In August 1995, the control group NHS DBA CENDANT DBA DBA CBRE DBA
REAOLOGY touted the acquisition of Century 21, a franchised chain of brokerages,
from MetLife for $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 Banker for $740 million, making HFS
the largest franchisor of real estate brokerages in the U.S.[17]service, for up to $825
million.[22][23]. See e.g., 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 ultimate goal in all these scams.
Sept/21/1995: Laurence Silk, Secretary, and Andrew Stewart, President and VP, d/b/a First
Allegheny Management Company, file fictitious name, “The Silk and Steward Development
Company eff 9/21. Address is, 5812 Darlington Road, Pgh. PA 15217. Accordingly, Silk,
Stewart d/b/a Silk and Stewart. 70 Accordingly, Silk, Stewart d/b/a Silk and Stewart in their
incorporated form take next steps to conceal their control and the scheme by use of multiple shell
corps.

In a June 1996 article detailed on that date, it was reported that Silk and Stewart developed MILLION worth of strip
70

malls in Pgh and Tennessee and that they Founded Arabica.

143
1995: Art Goldberg: Joins Conspiracy and engages in multiple mortgage frauds using 815 and
1009 d/b/a Trustee for Goldberg Trust Units 815 and 1009 (sold in 2016) notorious violator of
securities laws from at least 1990 through the present. Series of suspect transactions using shell
corporations. But see Bellrock Controls and Bellrock Intelligence securities fraud 71
Sept/21/1995: Laurence Silk, Secretary, and Andrew Stewart, President and VP, d/b/a First
Allegheny Management Company, file fictitious name with PA DOS, “The Silk and Steward
Development Company eff 9/21. Address is, 5812 Darlington Road, Pgh. PA 15217.
1996
1996: CB Commercial acquires L.J. Melody & Company mortgage bankers; the company goes
public.
April 1996, Jeffrey Ackerman et. al. report to the press that pre-death version of Stanley A.
Arnheim national corp was acquired by himself and 3 investors identified as, Silk, Steward, and
Zehfuss. This is a false statement on multiple fronts. See public records as described herein.
See Pittsburgh Post-Gazette (PPG)
May 8, 1996: Merger announced at HFC filings in a form 8-K press release announcing a
merger with Coldwell Banker which then describes the public view of Coldwell Banker’s
Historical corporate evolution and slips in what is alleged to be the consolidated financial records
of all entities. Co-Conspirators and members of the control group now include Deloitte Touché
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. 72
Shell company, HFS, which on May 7, 1996 had no known business operations is 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

71

72
Between Feb. 2, 1994 and May 5, 1996, multiple Sch 13 G forms filed identifying the then control group of Putnam
d/b/a HFS. See https://www.sec.gov/cgi-bin/browse-

144
 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 February 12,
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 Group, 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]
1996 National Realty Trust was formed when 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]
June 19, 1996: Jeffrey Ackerman, Andrew Stewart (d/b/a Coldwell Banker and Edward Zeffuss
(then d/b/a Arnheim & Neely) file creation documents with the DOS. at entity no. 2701294,
address 200 Law & Finance Building with Stewarts address as VP, Zehfuss as Treasurer, Jeffrey
Ackerman as secretary and President all located at ste 200429 4th Ave., Pittsburg 15219 Going
forward, the control group does business at times as, CBA&N Inc., 73 Accordingly, the initial
control group of the Imperial House in its incorporated form is formed and initially d/b/a as
CBA&N Inc.
Also, on June 19, 1996: Silk, Jeffrey Ackerman (dba Coldwell Banker) and Zeffhuss then d/b/a
Arnheim & Neely, respectively, incorporate shell company CBA&N Inc., 74 Specifically, they
file creation documents with the PA DOS at entity no. 2701294 (Stewart’s address as VP),
Zeffuss is listed as Treasurer, Jeffrey Ackerman as secretary and President all located at STE
2004 29, 200 Law & Finance Building 4th Ave., Pittsburg 15219. Accordingly, the initial
control group of the Imperial House in its incorporated form is formed and initially d/b/a as
CBA&N Inc. 75
July 28, 1996: PPG reports that Arnheim & Neely, Inc. are merging with Coldwell Banker based
upon fraudulent statements by the control group that were materially false and misleading
73
On or about the same date, the above-described individuals create the CBA&N Broker Partners Entity.
74
On or about the same date, the above-described individuals create the CBA&N Broker Partners Entity.
See 2006, overt acts., i.e., Zehfuss on behalf of A & N change of address, on paper merger of CBA & N with
75

A&N, surviving corp is the above-described individuals d/b/a & Neely and then see also press reports and quotes by
Ackerman et al. See public records indicating that A&N goes out of business in 2019 when purchased by RJ
Community Management.

145
because at most, they created a franchisee branch after paying for the use of Coldwell Banker
brand and simply highly hijacked the well-regarded defunct shell of the original Arnheim &
Neely, presumably in furtherance of the control group of Real ology sale of billions of dollars of
unregistered securities. See www. sec.gov at Edgar; see also PPG story as follows:
National Home-Grown Broker, Arnheim & Neely Inc., will partner with National real estate
giant Coldwell Banker Commercial launching business office in Pittsburgh. The company
according to Jeffrey Ackerman “will be known as CB Commercial/Arnheim & Neely once the
deal takes effect in late summer. Leonard Silk, one of Arnhem’s owners said that the deal would
be good draw in out-of-state retailers. While Ackerman represented, he will be president and
managing broker for new firm and that, (1) CB would purchase a minority stake in A & N
devoted to commercial real estate; while (2) the A & N residential property division would be
split off and operated as separate entity to be headed by Edward Zehfuss.
1997: CB Commercial acquires Koll Real Estate Services.
1997: HFS and CUC underwent a reverse merger and named the surviving 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.
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: Stanley Angrist: unit 312. On paper obtained property for $K more ($183,000) than
purchase price two years earlier ($●Going forward, it was initially all about getting money to pay
the co-conspirators personal debt the $K loan plus interest.
1997: Weinkle. In corporate form obtain unit 815 in 1997 for $1.00. (Insurance contact
intermediary)
For example, almost every single individual claiming to be the BOD of IH from 1999 through
the present were and are straw purchasers. All but Bernstein were installed in the building
before August 1998, when the illegitimate control commenced.
1998 Unit 208 and 415 Highjacked New Control Group
As described supra, the control group of Unit 208 including Bank d/b/a Huntington Bank today,
first used the deceptive tactic of name confusion to infer ownership of the Property versus Unit
208 and used an almost identical corporate name for purposes of mortgaging Unit 208, and from
then forward the control group of Unit 208 for which the mortgage was not paid off until 2001
used the single unit as its claim to being the original developer or successor thereto with posers
and authority pursuant the never recorded 1998 Declaration referenced in the 1998 Bylaws, etc.
which were recorded
1998 In January 1998, Cendant purchased Jackson Hewitt, a franchised chain of tax
preparation offices, for $480 million.[28][29]

146
1998, Apollo and Cendant controlled entity, NRT expanded to intrastate market.
1998: CB Commercial acquires REI Ltd. and becomes CB Richard Ellis (CBRE); Hiller Parker
also is acquired.
April 1998 the Control Group of Cendant was forced to admit publicly and falsely that it,
“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-scandal. 76

April 16, 1998: New Law firm for new Control, Rea, Jug, et al., Draft “Restated, Superseding
Decl. which is NEVER recorded yet was used as the governing document at all relevant times
until at least 2009 when Jug filed the first fraudulent amendment thereto. I assume the reason
that Henry Rea, et al, failed to record it is because it was copied and pasted from another Decl
and does not and did not described 5660 Munhall. 7778 But see 2005 Ltr., ltr Angrist.(and
proof of fraudulent intent emails and IHCA website March through May 2021. Exhs.

76
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]

77
As part of the fraudulent scheme, the co-conspirators disseminated the never-recorded, fraudulent declaration as the
official declaration granting their powers and authority. Absent the alleged 1998, Decl. the current co-conspirators
never have any authority or power to take any of the hundreds of corporate actions from 1998 to the present allowing
for fraud, theft, collection of unlawful debt, extortion, etc. First, the UPA requires a decl. be recorded to be effective.
Second, even assuming no underlying fraud and recordation, the alleged decl. would not be enforceable absent 100%-
unit owner vote because it was represented to supersede and replace the existing Decl. . see e.g., Unit Property Act
and applicable caselaw.
78 NEVER RECORDED. NO ONE WHO OBTAINED ANY MONEY ASSESSMENT FROM MY MOTHER
FROM THIS DATE ONWARD COLLECTED UNLAWFUL USING THE INSTRUMENTALITIES OF
INTERSTATE COMMERCE. AT ALL RELEVANT TIMES THE ILLEGITIMATE BOD AND ITS CONTROL
PERSONS DBA AS Arnheim Neely and since 2008 as RJ development defrauded my mother and deprived her of her
civil rights to the extent that their violations of FHA and other laws are an indirect, foreseeable cause of my Eve’s
wrongful death and the years of financial exploitation that preceded her death. While not recorded, the fraudulent
document has been disseminated to all unit owners over the years as an integral part of the fraud. See Oct. 5, 2006 --
EvE.

147
 Control Group Draft Proposed Bylaw and Draft Amended, Restated, Declaration. Neither
complies with the provisions of the UPA and are materially incomplete. See Recorded dox. AT
ALL RELEVATN TIMES THIS IS ONLY DECL EVER RECIEVED FROM CORRUPT
CONTROL GROUP
And see EvE 2006 purchase, where she is provided per applicable laws a Binder which includes
the never r4ecorded Amendment which she relied upon up through her death as did I until late
2020 when I and the estate were targeted for unlawful debt collection, unlawful collection of
debt not owed, multiple predicates under all manner of criminal laws including RICO, CIVIL
RIGHTS, FRAUD, CONTRACT, ETC. UNDER COLOR OF LAW -- DELLAV SEE 2021
OFFICAL OPPRESSION, FRAUD, TERRORISTIC THREATS, HOME INVASION, ETC.
May 16, 1998: Draft “duly authorized BOD of 208 Imperial House authorizes restated bylaws at
special meeting. see Proposed Bylaws. Which is recorded as is August 1988 as the governing
document by which the Current Control Group has used to defraud everyone including my
mother. They use the fraudulent Bropie transactions identifying the Property as 208 Munhall.
At all relevant times, it is by control of this single unit that the conspiracy hijacked this
Apartment building. Note the fictious mortgage is paid off and recorded as satisfied in 2001
using money extorted from tenants at 5600 via fraudulent governing documents recorded by JUG
AND BURKHALT AND ONCE BY ANOTHER ASSOCIATE.
August 17,1998: DellaV who is preparing to be appointed to the bench records the April 1998
Draft Proposed Revisions of Bylaws (previously Code of Regulations” at DBV 10270- 162-175
-- Appears someone papered the public recorder records by recording the papers in the DEED
book because it was not a Deed nor was it a Decl. Furthermore, Bylaws are not typically
recorded, and it appears that they were recorded for the appearance of legitimacy. [Evidence of
Public Corruption – falsified official doxes] 79 On date that the Bylaws were filed, the Control
Group did not even own as much as Unit 208 – Bank owned Unit 208 so the claim of Control
was an utter lie. Drafted and Notarized by Jug then-Partner Henry Rea who seems to have taken
from Markowitz.
Among other things, he records a fraudulent “By laws” as a Deed in the DBV. The recorded
document is NOT a deed.

79 See also Online property assessment records: There is no corresponding deed or reference to chain of title on
Allegheny County Property assessment public online search record.

148
149
150
Highlighted copy follows:

151
152
153
154
155
156
157
158
159
160
161
162
1999 - the Control Group now Including the Rea, Jug Law firm and silk and Stewart Gets a roe

163
Jan. 31, 1999: 80 At MB 19356-344, DellaVecchia fraudulently records the satisfaction of
alleged 1988 mortgage loan on 208 Munhall a/k/a Unit 208 as attached to an entirely different
entity only discoverable upon a name search of “Imperial Associates” -- the long defunct joint
partnership. See Nov. 18 through December 1988, infra.

Not community Bank.

Has been acquired see infra.

The Satisfaction allegedly occurring on Jan. 26, 1990 is attached to all mortgage records
previously copied and pasted above but begins at MB 8356 p. 343. UNIT 209
Subsequently, Jug and Burkhalter file multiple fraudulent dox recorded by DelllV obviously,
kickbacks.
Della V. launders his profits through the purchase of 322 Gladstone and likely funnels non-
disclosed monies to support his election to Judge of Court of Common Pleas and see 2006 for

80
Moreover, based on public records regarding a standard Form 3170 strongly suggests that the conspirators conflated
at least two different Fannie/;Freddie Uniform Instrument Forms to conceal that (1) that the units constitute
unregistered securities for rent being held for investment purposes, (2) to conceal the fact that Bank was trying to
make up its losses on the original investment by a scheme to evade the applicable disclosure laws to regulators and
investors; and (3) to evade taxation for the rental building by shifting the tax liability to unsuspecting bona fide
purchasers who effectively pay hundreds of thousands of dollars up front to “rent” not buy an apartment. See supra
2006 EvE facts. See e.g., 2021. See also, SEC Edgar at Multifamily Deed of Trust, Assignment of Leases and Rents,
Security Agreement (PNC detail description of the parameters and implications of this interest which is limited to
investment units and rentals albeit with respect to another property). Public records regarding a standard Form 3170
strongly suggests that the conspirators conflated at least two different Fannie/;Freddie Uniform Instrument Forms to
conceal that (1) that the units constitute unregistered securities for rent being held for investment purposes, (2) to
conceal the fact that Bank was trying to make up its losses on the original investment by a scheme to evade the
applicable disclosure laws to regulators and investors; and (3) to evade taxation for the rental building by shifting
the tax liability to unsuspecting bona fide purchasers who effectively pay hundreds of thousands of dollars up front to
“rent” not buy an apartment

164
evidence Della V commits mortgage fraud with his own properties -- 322 Gladstone and
Devonshire See also Laurence Silk -- 700 Devonshire
September 10, 1999: DellaV. and Napier Wilson (aka my former neighbor, Mr. Wilson sold
322 Gladstone to Dellav. for $366K y cash payment (likely significantly more). See Della V.
salary and financial disclosures for election.
.

165
166
Sept 13, 1999 - Della V. records it himself. While I think this is a bona fide purchase for cash,
the indenture is incomplete and has signs of document fraud. Best guess, he and Wilson agreed
that he would pay more cash to Wilson that neither would report as part the effort to launder the
money. Likely, he was in a hurry because he was up for a judgeship. See Exh Carve Out to
demonstrate difficulty of identifying any of these conveyances or related conveyances. See also
Charitable Contribution Scheme

167
2000s - Focus on 2004 onward as Mortgage Crisis approached and crashed. The Next Phase of
Undisclosed Control begins in 2004-iish and see Della V. Mortgage Fraud begging in 2006,
supra.
July 6. 2001: DellaV or successor Record at DBV-1113-267, jUGS/Burkhalter drafted and
notarized Fraudulent “Amendment to Rules and Regulations” solely for the intent of giving the
corrupt control the appearance of formality and legitimacy and as the means to defraud all
tenants of the Building. It is very possible that certain straw purchasers had no idea that they
were defrauded as well on the big picture fraud -- no condo.” Also, this Amendment was to
ensure that the conspirators could get loans and would not get sued for unregistered sales of a
security -- more likely with Rentals.... Rules & Regs are not typically recorded. Jug/Burkhalter
needed to circumvent the fact that they had failed to record a Decl that could plausibly
demonstrate a right to any legitimate authority over 5600. See 2009 for first Fraudulent
“AMEND TO DECL)

168
169
See unusual Recorder Stamp.

170
171
172
2000s
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.
2001: CBRE is privatized.
August 1 through 2000: The straw Purchasers installed by Unit 208 Control Group took control
of the BOD while simultaneously the Control Group of the entity dba as Arnheim & Neely
controlled the BOD albeit covertly because at all relevant times it described itself as the property
management retained by the BOD and paid by the collection of unlawful debt at all relevant
times which was funneled to each of the control group members for profit, investment, to pay off
debt, and to fund the related illegal businesses that they began to run out of the Imperial House
after fraudulently asserting and acting upon a non-existent right to control all the original
declarants offices which would have not succeeded to the control group even if they were
legitimate because no Special Declarant rights were ever passed to anyone based upon review of
all available public records to date that I can access.
s See each fraudulent Amend to Decl. Bylaws, Rules, Regs etc. each and every one utterly
fraudulent and baseless but intended to facilitate the collection of unlawful debt.
June 2001: Governor Tom Ridge appoints Michael A. Della Vecchia to serve as a judge in the
Court of Common Pleas of Allegheny County. 81
June 2001 -- Using tenant funds extorted via fraudulent governing dox pay off Mortgage on Unit
208 owed to Community Savings Bank now d/b/a Three Rivers Bank. See also Cicero

81
Full Biography for Michael A. Della Vecchia (smartvoter.org) (note, “This information is provided by the
candidate”). ( viewed Apr. 4, 2021.).
81
Id.

173
Indictment.,

see also.

174
Nov. 2001: DellaV elected to serve on bench. s subsequent election in November 2001. 82
2004: CBRE goes public on the New York Stock Exchange.
In February 2004, RJ Development Co. was formed in Cranberry Township by Robert
Gillenberger, Jr. to help serve the needs of Homeowners and Condominium Associations in the
Western Pennsylvania region 83. That was a false statement because it is just a shell company
for Labovitz who created RJ Community.
OCTOBER 2005: Stan Angrist executes a letter on behalf of co-conspirators which contains false
representation including regarding illegitimate declaration as part of white binder that the was
handed to my mother after purchase in Nov. 2006 which contained the fraudulent, unrecorded
declaration and multiple subsequent overt and fraudulent taken to defraud at all relevant times
through her death and now even after death by ongoing theft, fraud, deception intended to defraud
her Estate and her beneficiaries.
RJ Development Website [FALSE]
2006 Della V. EvE - OVERLAP
2006: SEC Cendant likely without out disclosing likely liability for the class actions lawsuits,
uses a fraudulent spin-off scheme to dumps its liabilities while dumping.

82
See (note, “This information is provided by the candidate”).
83

175
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 head
of those individuals.
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 & N was for all intents and purpose the control group of the Condominium – 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.
March 24, 2006: Della V. gets Mortgage on 229 Gladstone Rd. for $400,000 which absent
old family, could qualify for -- it’s almost papered.

176
177
178
179
lU. No 1ransrer. lVlongagur agn:t: u1cu, auy a11;,,, \..u11v'-'ya.i11,.,1,.,, vi
vLJ..l\,.;l.
transfer of title to the Mortgaged Property, or any interest therein (whether voluntarily or by
operation of law), without Mortgagee's prior written consent, shall result in acceleration of the
loan, requiring payment in full of all sums due hereunder and under the Note within three (3)
months of the date of such sale, conveyance, further encumbrance or other transfer.

180
181
182
183
184
185
186
March 31, 2006: VALERIE _MCDONALD new control person of _r records the March 6,
2002 Mortgage at MB see below. To find this document you would go through 50 or so
random Della v. or Elizabeth dell V name searches or you would have to search all Bank entries.
Next see improper Mortgage Modification April 2007.

187
2006: EVE at 77 years old with a critically ill son is pressured to an almost immediate cash sale.
Below in Red bold are facts learned 02.01.2021 after randomly searching property records after
events of the past couple week. My probate atty looked for records, these papers were timed and
papered to be concealed.

188
A buyer needed because the control persons of the banks were drowning in debt because they
were falsifying the books and records -- se mortgage crisis.
September 2006: Prior owner and coconspirator straw purchaser promotes and advertises the
Unit description/advertisement Nielsen advertisement regarding unit 309.
September 26, 2006 E executes the following documents:
West Penn multi-list Inc. seller disclosure statement
Caldwell banker mortgage estimated costs settlement
Vendor advertising via Caldwell banker.
September 27, 2006 Agent executes outside of mother’s presence or Eve meets again:

Coldwell Banker Consumer Guide Sumer guide to real estate services, customers for life -- half
the pages are torn out and it for mortgage buyers. Everything is papered as if she were getting a
mortgage which she never intended to do and did not do., Coldwell Banker “Buyer Services
Guarantee” footer: 2005 Coldwell Banker real estate Corporation each office independently
owned and operated except those operated by N RT Inc (aka Realology et. al.) |
Standard agreement for the sale of real estate: Melanie Lavera (Coldwell Banker real estate is the
broker Phyllis LaSalle and ISS EL broker affiliation executed by EVE 59 27 2007)
Seller Discl. Lead
SEP 28, 2006: ML executes the following two documents:
Pennsylvania Realtor form and
A/S/R1 of 10 pages revised 9/05.
Oct 3, 2006 EVE gets home inspection report independent Essential Home Inspections. No
roof or electrical access/
Oct. 5. 2006: Resale Cert prepared by Arnheim Neely, Edward Zeffhuss Referencing
Mortgage. 84
With Resale Certificate, 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 head of those individuals.
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 & N was for all intents and purpose the control group of the Condominium – not a separate,

84
See e.g., Fraud at IH is evident by RJ representations and corporate records. For example, a press report quotes
Robert Gillenberger, Jr. is the owner of RJ Development, a company that for a fee services HOAs' maintenance needs
and manages sometimes-unpleasant administrative affairs. Take, for example, someone's failure to pay association
dues. "As soon as you buy into a plan, you're issued a resale certificate," Gillenberger explained. "This is a legal
document. If there are any dues owed before the seller leaves, they have to pay them; if there were any exterior
violations, they would have to repair them. So if they owed $500, they'd have to pay that as part of their closing costs,
or else they can't close. https://patch.com/pennsylvania/cranberry/inside-cranberrys-mini-governments "If a
homeowner who lives in a plan falls behind, we can go to the local magistrate's office to collect the dues. And if they
don't pay that, we could go as far as to place a lien on their property or a sheriff's sale."

189
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.
ML provides EvE List of Utility Providers directs DLC.
Oct. 13, 2006: Nisells take out a $120,000 mortgage on Unit 309 WHICH MCDONALD
RECORDS WITHIN ONE WEEK OF RECORDIGN THE FRAUDULENT CONVEYANCE
TO MY MOM on Nov. 22 (see supra) . Which of course required the HOA co-conspirators to be
involved to provide lenders papers and info that my mother did not. AND the value of the
property is inflated to the point where she thought she was getting a deal at $175. See date of
recording -- one week after mom recorded her meaningless title. See below and see also

190
Certifcate of Residency. Nissels always lived in Ohio. Total scam.

191
192
193
194
Oct. 17, 2006” Cert of Zoning NOT the mandatory Cert. of Occupancy under cover of letter.
from Keystone closing services executed by Zo Kelly
October 17, 2006 [Perhaps forged. Not sure if it should have been Cert. of Occupancy]
Research demonstrates that my mother was charged as if she were taking out a mortgage instead
of being a cash buyer. She paid thousands more to but his property than it was worth given the
fraudulent deed, representations, conflicts of interests, coordinated fraud at all sides of the
transactions from papers to the pursue. The appraisal was inflated. All p participants were

195
concealing that they were controlled by Reaology d/b/a under the various aliases or shell
company identification each participant.
EVE PAYS 175,000 by way of Check from PNC Bank thanks to a fraudulently inflated
appraisal.
Everybody on the deal were controlled by.
November 14, 2006
Eve unit 309 Deed is recorded by Valerie McDonald when it overtly deficient and fraudulent
while charging EvE a fortune on an inflated appraisal. Consistent with POC since at least 1979
to present, there is no reference or citation or index rule compliant record of the non-existent
property or the fraudulent Mortgage of just 30-days earlier. The Deed is incomplete and
contains language that violates Pennsylvania’s mandatory language to conceal the fact that the
imperial house is built on top of a coal mine and that the subservient rights are not conveyed and
that there is a high of subsidence or that it already occurred. It is not even a real deed. Lines
scratched out. etc. This is 77-year-old woman. And i was unable to obstruct this fraud because I
was serving a 1 5hour day every day in a 6-month detail as a Special US Attorney for the EDVA

196
and could not take off because of nature of the detail. WTF.

197
198
199
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November 22, 2006: McDonald records the OCT 13, 2006 Fraudulent Mortgage in which
Nissels conveyed Unit 309 to PNC D/B/A NATIONAL CITY BANK as security for a
loan. he criminal Nissels with their coconspirators record their mortgage on the property that
they got 175000 while my mother was charged for all their mortgage fees and costs. Obviously,

201
that

202
203
See January 27, 2021 for recorded satisfaction.
is why it was papered like a mortgage contingent sale? They got a loan and made 40k profit off
my mom.
December 26, 2006: Satisfy the mortgage with my mom’s money. Pay everyone off and go
home to hell, I hope.
December 26, 2006: The Nissels use EvE cash payment to satisfy Mortgage. While McDonald
did not record until January 2007, the fax marks at the bottom pg., indicate that McDonald
intentionally delayed recording in furtherance of the fraud and to avoid detection thereof.

204
205
206
On December 29, 2006 and December 31, 2006: Silk, Stewart, Ackerman, and Zehfuss d/b/a filed
papers with PA DOS as CBA&N reporting it merged with Arnheim & Neely reported that it had
merged with and into the known as be a & and, Inc. Pennsylvania court and Arnheim & Neely Inc.,
is the surviving entity.
December 30. 2006: The very next day the same article of merger form was filed with
Pennsylvania Department of State, by CBA & N on behalf of both A&N and itself as if they were
two separate unrelated entities. then reporting the same information and stating that in both
instances the merger would become effective 112 31 2006 both documents are executed by Edward
Seth house ZEHFUSS as president of R and Chaim Neely you crack.
December 31, 2006: Edward Zeffhuss d/b/a Arnheim & Neely, President, files change of
registered address form with the DOS, from 3010 Grant Street to 425 Craig Street.
January 9, 2007: McDonald records the alleged satisfied mortgage at MBV 33214-328.
Meanwhile see Goldberg mortgaging the non-existent property for which the fraudulently forged
property assessment papers describe as purchase for 4 Million dollars. Note, no taxes ever
assessed or paid.

February 9, 2007: William Labovitz incorporates RJ Development, 203 Whitetail Ridge,

Cranberry. See 2016, where my mother victimized by the Respa fraud scheme albeit as buyer
not seller.
Feb 15, 2007; EVE mail from Zoe Kelly of Keystone closing services 200 Fleet St. Suite 600
Pittsburgh PA 15220 sends EV E `the enclosed original owner's title policy issued by Censtar
Title insurance Controlled entity -- Reaology see sec filings (subsidiaries) 85
December 31, 2006: Edward Zeffhuss d/b/a Arnheim & Neely, President, files change of
registered address form with the DOS, from 3010 Grant Street to 425 Craig Street.
On December 29, 2006 and December 31, 2006: Silk, Stewart, Ackerman, and Zehfuss d/b/a filed
papers with PA DOS as CBA&N reporting it merged with Arnheim & Neely reported that it had
merged with and into the known as be a & and, Inc. Pennsylvania court
December 30, 2006: The very next day the same article of merger form was filed with Pennsylvania
Department of State, by CBA & N on behalf of both A&N and itself as if they were two separate
unrelated entities. then reporting the same information and stating that in both instances the
merger would become effective 112 31 2006 both documents are executed by Edward Seth house
ZEHFUSS as president of R and Chaim Neely you crack.
February 22, 2007: Attorney William Labovitz, Esq., filed a certification of organization with the
DOS creating the LLC known as RJ Development Co., LLC in Cranberry Township on 203
Whitetail Ridge.
See Eve Ross Avenue and class action lawsuits. 86 Accordingly, Bob Gillenberger’s representations
on the public website are false; specifically,

85
See Eve Ross Avenue and class action lawsuits. See also, RJ Community Facebook representations, also materially
false. For example, Gillenberger’s represents on Facebook at elsewhere, that he alone created RJ Development in
2004.

86
https://colliersinternationalpittsburgh.com/2020/10/01/colliers-international-pittsburgh-assists-rj-community-
management-with-office-search/amp/, viewed Jan. 21, 2021.

207
February 22, 2007: Attorney William Labovitz, Esq., filed a certification of organization with the
DOS creating the LLC known as RJ Development Co., LLC in Cranberry Township on 203
Whitetail Ridge. 87
February 22, 2007: Attorney William Labovitz, Esq., filed a certification of organization with the
DOS creating the LLC known as RJ Development Co., LLC in Cranberry Township on 203
Whitetail Ridge. 88
March 23, 2006: DellaV first steps Mortgage Fraud. Same POC MB 31722-283 see March 31
recordation. Della V. starts looking for a buyer for 299 Gladstone. Accordingly, as an overt act
in furtherance of his personal mortgage fraud, he obtains a 30-days almost certainly as soon as he
learns he has a buyer on the hook (229) . Later recorded First, he conveys all interest in 229
Gladstone in consideration for $399,000k from United American Savings Bank. The terms of the
Agmt are clear, he cannot sell without permission, etc. . Looks like two separate Form dox
conflated to be one.
This mortgage comes up under a name search in MB not Deed Bk.

https://colliersinternationalpittsburgh.com/2020/10/01/colliers-international-pittsburgh-assists-rj-community-
management-with-office-search/amp/
87
https://colliersinternationalpittsburgh.com/2020/10/01/colliers-international-pittsburgh-assists-rj-community-
management-with-office-search/amp/, viewed Jan. 21, 2021.
88
https://colliersinternationalpittsburgh.com/2020/10/01/colliers-international-pittsburgh-assists-rj-community-
management-with-office-search/amp/, viewed Jan. 21, 2021.

208
NOTE: In all instances, the satisfaction is documented together with the M even though they
have different MB pg. numbers, etc. All of this is carefully timed and structured to conceal the
mortgages from a potential buyer and to evade detection of the decade’s long property fraud.

209
210
211
212
213
March 31, 2006: Della V. takes the mortgage loan to buy 512 Devonshire in consideration of
$370.000K.

214
215
216
\

217
See reference to 10/23/2007 Promissory Note. And see Mortgage satisfaction in March 2007 on 229.
Presumably Della V. made a down payment?? with a promise to pay in full in 2007 once he could
sell 229 or something along those lines.
Contemporaneously, Valerie MacDonald records both the Mortgage and the purchase
simultaneously. also, on March 23 See DBV 12795-463.

218
April 18, 2007: Gets a buyer for 229 when he still has a mortgage on the property and has to pay
off 512 Devonshire. Upon information and belief, knowing he has a buyer on the hook and has
obtained a down-payment, he very likely uses the money to paper his qualifications for
modification on the mortgage and security interest. He is by now intent on moving up to
Devonshire St. likely by his neighbor and co-conspirator Lawrence Silk (identical POC at 700
Devonshire). Accordingly, the next overt act is to get a mortgage modification providing a lower
interest rate (almost certainly lowered due to the need to make a significant profit on the deal for
kickback purposes to all involved. See EvE) (due to crisis probably could not get as much as he
anticipated based on an almost certain fraudulently inflated appraisal -- Zefhuss?). I do not believe
he qualified for a modification. REVISE?

219
220
221
222
April 23, 2007: MB
Valerie McDonald intentionally records and indexes modification is indexed differently than the
name search for purposes than the immediately preceding mortgage. Structuring. Prior index is
linked to ELIZABETH V. MICHAEL ETC.

223
April 23, 2007: V-MD Records Mortgage Modification in MB and the cover sheet by name search
on US Land search is intentionally crafted to reflect Elizabeth not Michael as mortgager because he
is a Judge and the modification is evidence of impropriety. Research back up somewhere. See
carve out for name search, literally have to review a zillion name search docs to get this.

224
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Next skip ahead to July 2007 note in each dox, there is always a gap between act and recording
which all leverage to their advantage.
July 11, 2007: Before satisfying the m mortgage and before 10/23/2007 promissory note comes due
on 512 Devonshire, Della V and wife allegedly sell by indenture deed 229 Gladstone to Husband and
Wife, Sitharaman in consideration for $499,0000. On July 7, 2007, the BANK has all conveyable
interest in 229 Gladstone. Likely victimized by the same conduct as my mother, the new buyer
pays for an interest that Della V is not free to sell and by the now the loan has likely been
securitized to prop up the failing MBS pool....
:

--
:

226
227
228
Assuming these are bona fide buyers who I have no reason to doubt, then they just paid for a non-
conveyable property which almost certainly was immediately securitized.
July 6, 2007: Deed Recorded at DBV 13296-187.

229
July 28, 2009: VMD records under the name of some non-existent entity “Imperial House Condo
Assn” an Amended Decl. Condo that Jug/Burkhalter drafted which is utterly fraudulent for the
reasons described herein.

230
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232
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234
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236
2010: After-effect of Mortgage crisis continues to impact this Building and the Economy.

The current much stricter mortgage underwriting guidelines and standards imposed by lenders
and secondary mortgage market makers, such as Fannie Mae, Freddie Mac, the FHA and the
VA, make it much more difficult to finance or refinance condominium units. We are seeing a
significant spike in mortgage foreclosures, tax sales, bankruptcy filings, uninsured property,
deferred repairs, mechanics liens, utility shutoffs, and just late or delinquent payments affecting
developers, investors and unit owners. Any and all of these events are dangerous and can be
catastrophic for a condominium association and its owners. Associations must be more 89

89
Legal Issues for Condominiums Impacted by Recession, 2010. Cite later.

237
Strategy to Combat Transnational Organized Crime: Executive Summary
The Strategy to Combat Transnational Organized Crime applies all elements of national power to
protect citizens and U.S. national security interests from the convergence of 21st century
transnational criminal threats. This Strategy is organized around a single unifying principle: to
build, balance, and integrate the tools of American power to combat transnational organized
crime and related threats to national security—and to urge our foreign partners to do the same.
The end-state we seek is to reduce transnational organized crime (TOC) from a national security
threat to a manageable public safety problem in the United States and in strategic regions around
the world. The Strategy will achieve this end-state by pursuing five key policy objectives:
Protect Americans and our partners from the harm, violence, and exploitation of transnational
criminal networks.
Help partner countries strengthen governance and transparency, break the corruptive power of
transnational criminal networks, and sever state-crime alliances.
Break the economic power of transnational criminal networks and protect strategic markets and
the U.S. financial system from TOC penetration and abuse.
Defeat transnational criminal networks that pose the greatest threat to national security by
targeting their infrastructures, depriving them of their enabling means, and preventing the
criminal facilitation of terrorist activities.
Build international consensus, multilateral cooperation, and public-private partnerships to defeat
transnational organized crime.
The Strategy also introduces new and innovative capabilities and tools, which will be
accomplished by prioritizing within the resources available to affected departments and agencies.
A new Executive Order will establish a sanctions program to block the property of and prohibit
transactions with significant transnational criminal networks that threaten national security,
foreign policy, or economic interests.
A proposed legislative package will enhance the authorities available to investigate, interdict, and
prosecute the activities of top transnational criminal networks.
A new Presidential Proclamation under the Immigration and Nationality Act (INA) will deny
entry to transnational criminal aliens and others who have been targeted for financial sanctions.
A new rewards program will replicate the success of narcotics rewards programs in obtaining
information that leads to the arrest and conviction of the leaders of transnational criminal
organizations that pose the greatest threats to national security.
An interagency Threat Mitigation Working Group will identify those TOC networks that present
a sufficiently high national security risk and will ensure the coordination of all elements of
national power to combat them.
For decades, the United States and other countries have dismantled scores of criminal
organizations around the world. The U.S. experience with La Cosa Nostra, as well as Colombia’s
experience with the Medellin and Cali Cartels—and even the FARC—prove that it is possible to
constrain, shrink, disrupt and dismantle criminal and insurgent groups once considered to be
untouchable.
This Strategy builds upon such past experience. Today the threat from TOC is more complicated
because criminal networks are more fluid and are using increasingly sophisticated tactics. TOC

238
can exploit the interconnected nature of our modern trading, transportation, and transactional
systems that move people and commerce throughout the global economy and across our borders.
Countering TOC today requires an integrated and comprehensive approach. This Strategy sets
out such an approach to raise international awareness about the reality of the TOC threat to
international security; galvanize multilateral action to constrain the reach and influence of
TOC; deprive TOC of its enabling means and infrastructure; shrink the threat TOC poses to
citizen safety, national security, and governance; and ultimately defeat the TOC networks that
pose the greatest threat to national security. TOC presents sophisticated and multi-faceted threats
that cannot be addressed through law enforcement action alone. Accordingly, we will establish
an interagency Threat Mitigation Working Group to identify those TOC networks that present a
sufficiently high national security threat as to merit the focused use of complementary law
enforcement and non-law enforcement assets and that may be vulnerable to whole-of-
government responses. The Working Group will ensure the coordination of all elements of
national power to effectively protect our borders, people, economy, and financial system from
the threats posed by the most dangerous and sophisticated of these transnational criminal
networks.
This Strategy sets out five overarching policy objectives that are consistent with the vision and
priorities of the National Security Strategy:
1. Protect Americans and our partners from the harm, violence, and exploitation of transnational
criminal networks. Our priority is the safety, security, and prosperity of American citizens and
the citizens of partner nations. We will target the networks that pose the gravest threat to citizen
safety and security, including those that traffic illicit drugs, arms, and people—especially women
and children; sell and distribute substandard, tainted and counterfeit goods; rob Americans of
their prosperity; carry out kidnappings for ransom and extortion; and seek to terrorize and
intimidate through acts of torture and murder.
2. Help partner countries strengthen governance and transparency, break the corruptive power of
transnational criminal networks, and sever state-crime alliances. The United States needs willing,
reliable and capable partners to combat the corruption and instability generated by TOC and
related threats to governance. We will help international partners develop the sustainable
capacities necessary to defeat transnational threats; strengthen legitimate and effective public
safety, security, and justice institutions; and promote universal values. We will also seek to sever
the powerful strategic alliances that form between TOC and states, including those between TOC
networks and foreign intelligence services.
3. Break the economic power of transnational criminal networks and protect strategic markets
and the U.S. financial system from TOC penetration and abuse. TOC networks—using bribery,
fraud, and violence—have the capacity to disrupt economic activity and put legitimate busi-
nesses at a distinct competitive disadvantage. We will attack the financial underpinnings of the
top transnational criminals; strip them of their illicit wealth; sever their access to the financial
system; expose their criminal activities hidden behind legitimate fronts; and protect strategic
markets and the U.S. financial system.
4. Defeat transnational criminal networks that pose the greatest threat to national security, by
targeting their infrastructures, depriving them of their enabling means, and preventing the
criminal facilitation of terrorist activities. We will target, disrupt, and defeat the TOC networks
that pose the greatest threat to the safety and security of Americans and U.S. national security
interests. These include criminal networks—including transnational criminal gangs—that traffic

239
drugs, bulk cash, arms, people, sensitive documents, or other contraband. Further, we will seek
to prevent collaboration between criminal and terrorist networks and deprive them of their
critical resources and infrastructure, such as funding, logistical support for transportation, stag-
ing, procurement, safe havens for illicit activities, and the facilitation of services and materiel,
which could include WMD material.
5. Build international consensus, multilateral cooperation, and public-private partnerships to
defeat transnational organized crime. We will build new partnerships—with industry, finance,
academia, civil society and non-governmental organizations—to combat TOC networks that
operate in the illicit and licit worlds. We will also fight criminal networks with an alliance of
legitimate networks and ensure the freedom of the press so that the media and journalists may
safely expose the harms inflicted by TOC. We will expand and deepen our understanding,
cooperation, and information sharing at home with State and local agencies, with foreign
partners, and with multilateral institutions. Internationally, we will further international norms
against tolerating or sponsoring crime in all its forms, including in cyberspace.
Strategy to Combat Transnational Organized Crime: Strengthen Interdiction, Investigations, and
Prosecutions
This Strategy sets priorities and objectives to help law enforcement and other applicable agencies
at the Federal, State, local, territorial and tribal levels work together in a collaborative manner to
target TOC networks—their leaders as well as their enabling means and infrastructure—in the
United States and abroad. It is equally important that we build strong working relationships with
our international partners to harmonize our efforts, and to ensure that they have the capabilities
and regulatory and legislative frameworks to prevent, reduce, and eliminate TOC threats.
Building upon the improved information sharing described earlier, the United States will
leverage consolidated TOC databases to provide more accurate intelligence on known TOC
members and their associates so they can more easily be denied entry to the United States or
access to lawful immigration status, employment, or secure facilities.
This Strategy pursues TOC through criminal investigations and interdiction focused on both the
net- works and their leadership. Criminal investigations will use an integrated approach that
incorporates financial, weapons, and TOC-related corruption investigations into a comprehensive
attack on the entire criminal organization. Interdiction efforts will focus on depriving TOC
networks of their products, proceeds, infrastructure, and enabling means. The use of multi-
agency task forces such as the ICE-led Border Enforcement Security Task Forces will remain
essential to our efforts to investigate and interdict TOC threats at our borders.
To address recent TOC trends, the Administration will work with Congress on a range of
legislative sol tions to allow or enhance the prosecution of TOC enterprises and significant TOC
activity that affects the United States. We will also enhance our anti-money laundering and
forfeiture authorities to target TOC networks that pose threats to national and international
security.
Actions
Work with Congress to enhance U.S. authorities to identify, investigate, interdict, and prosecute
top transnational criminal networks.
Utilize rewards programs to assist in gathering information leading to the arrest or conviction of
top transnational criminals.

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Issue a new Presidential Proclamation under the Immigration and Nationality Act to refuse visas/
deny entry to TOC-affiliated aliens, corrupt foreign officials, and other persons designated for
finan cial sanctions pursuant to the International Emergency Economic Powers Act.
Develop a strategy that denies TOC networks and individuals in the United States access to their
infrastructure and their enabling means.
Deny visas to TOC members and associates and capture top TOC figures who take refuge in the
United States or partner countries.
Fully integrate financial, weapons, and TOC-related corruption investigations into
comprehensive organizational attack activities and operations.
Strengthen cooperation with international police organizations, such as Interpol, Europol,
Ameripol, and the International Association of Chiefs of Police (IACP), to facilitate cross-border
police cooperation.
Strengthen efforts to interdict illicit trafficking in the air and maritime domains.
Develop and implement a whole-of-government plan to counter kidnapping for ransom in order
to disrupt the funding for terrorists, pirates, and other bad actors.
Deny TOC access to secure facilities and locations.
The U.S. Secret Service’s Cyber Intelligence Efforts
The U.S. Secret Service leverages technology and information obtained through private
partnerships to monitor developing technologies and trends in the financial payments industry.
The information obtained is used to enhance the U.S. Secret Service’s capabilities to prevent and
mitigate attacks against the financial and telecommunications infrastructures. This approach to
intelligence collection and sharing has resulted in the successful apprehension of individuals
charged with committing some of the world’s most advanced cybercrimes during such
investigations as those of the Heartland and TJX Intrusions, Maksym Yastremskey, Albert
Gonzalez, and others. In FY 2010, the U.S. Secret Service arrested 1,217 suspects for cybercrime
related violations, with a fraud loss of $507 million.
2011 July 11: President Obama Executive Order - TOC National Emergency

241
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Sept 11, 2011: DOJ WDPA issues PR which omits any reference to deed, property, or TOC fraud:
Licensed Appraiser Pleads Guilty in Mortgage Fraud Scheme

U.S. Attorney’s Western District of

OfficeSeptember 07, 2011 Pennsylvania
PITTSBURGH, PA—A resident of Pittsburgh has pleaded guilty in federal court to a charge of
wire fraud conspiracy in connection with a mortgage fraud scheme, United States Attorney
David J. Hickton announced today.
Howard Reck, 45, pleaded guilty to one count before Senior United States District Judge Donetta
W. Ambrose.
In connection with the guilty plea, the court was advised that Reck was a licensed appraiser who
operated a company named Citizen’s Appraisal Services, which provided appraisal services.
Reck participated in a mortgage fraud conspiracy in which other members of the conspiracy
represented to the lenders that sales prices for properties were higher than the true sales prices.
Reck then provided appraisals that falsely represented that the market values of the properties
serving as collateral for the loans were higher than the true values of the properties.
Reck’s appraisals reported values that were often double that of the true market values of the
properties. There were two main methods that Reck used to inflate the values of the properties.
He typically “cherry-picked” comparable, meaning that when seeking properties purportedly
comparable to the subject properties, he selected properties that were superior in location and
condition, and often ignored truly comparable properties. Rack’s second method was to overstate
the conditions of the subject properties. By representing that the subject properties were in better
condition than they actually were, Reck was able to compare subject properties to superior
comparable properties as if they were truly comparable.
Judge Ambrose scheduled sentencing for Jan. 3, 2012. The law provides for a total sentence of
20 years in prison, a fine of $250,000, or both. Under the Federal Sentencing Guidelines, the
actual sentence imposed is based upon the seriousness of the offense and the criminal history, if
any, of the defendant.
Assistant United States Attorney Brendan T. Conway is prosecuting this case on behalf of the
government.
The Mortgage Fraud Task Force conducted the investigation leading to the prosecution in this
case. The Mortgage Fraud Task Force is comprised of investigators from federal, state and local
law enforcement agencies and others involved in the mortgage industry. Federal law
enforcement agencies participating in the Mortgage Task Force include the Federal Bureau of
Investigation; the Internal Revenue Service, Criminal Investigations; the United States
Department of Housing and Urban Development, Office of Inspector General; the United States
Postal Inspection Service; and the United States Secret Service. Other Mortgage Fraud Task
Force members include the Allegheny County Sheriff’s Office; the Pennsylvania Attorney
General’s Office, Bureau of Consumer Protection; the Pennsylvania Department of Banking; the
Pennsylvania Department of State, Bureau of Enforcement and Investigation; and the United
States Trustee’s Office.
Upon information and belief, Reck lives in my mom’s building and is a member of the control
group. An examination of the PA Deeds will reflect the identical red flags of overt deed fraud and
systemic fraudulent appraisals in Allegheny County.

244
2007-2013: Have records but not time incorporate into this document given the current fraud and
collection unlawful targeting me and the estate and my personal safety.
2007-2013: Have records but not time incorporate into this document given the current fraud and
collection unlawful targeting me and the estate and my personal safety.
2013
April 22, 2013: Keystone closing files a “foreign Limited Liability” amendment without any detail
appears to have been filed in compliance with the requirements of 15 PA. C. S. §8585, executed by
Lauren Vadney, special manager90
April 22, 2013: Keystone closing files a “foreign Limited Liability” amendment without any detail
appears to have been filed in compliance with the requirements of 15 PA. C. S. §8585, executed by
Lauren Vadney, special manager91
Oct 2013 (albeit unknown to me until 2021, when Probate Atty conduct became a glaring red
flag) ty and Cicero are partners, control persons, and franchisees of acting as “First Realty Title

90

91

245
Ins). See press. They are involved in the big picture fraud. See here and later upon discovery

triggering retal by G.

246
Oct. 18, 2013: Robert Gillenberger, files fictitious Name RJ Community Management, with
DOS identifying RJ Development as other party n-interest. See Feb. 2007. Labovitz co. and see
lien. Atty. Dornish Law Offices and Robert Gillenberger, Jr. file an application for fictious
name, at 20475 Route 19 Cranberry describing the purpose as “Community and Homeowners
community association community management. Gillenberger lists a single entity, namely, RJ
Development as having an interest in the corporation, namely, RJ Development Co., LLC which
is controlled by Labovitz per the 2007 record above. 92 Both entities are not located at 20475
Rte. 19, Cranberry/
Oct. 18, 2013: Robert Gillenberger, files fictitious Name, RJ Community Maintenance papers
with DOS. RJ Dev’t owner d/b/A RJ Development.
Oct. 18, 2013: Dornish Law Offices and Robert Gillenberger, Jr. file an application for fictious
name, RJ Community Management at 20475 Route 19 Cranberry describing the purpose as
“Community and Homeowners community association community management. Gillenberger
lists a single entity, namely, RJ Development as having an interest in the corporation, namely, RJ
Development Co., LLC which is controlled by Labovitz per the 2007 record above. 93
2015
April 23, 2020: Debtor, Imperial House Condominium Association, Inc., c/o Arnheim Neely,
425 Craig, Street, Secured Party, Commonwealth Bank, Butler Street [THIS ENTITY HAS
BEEN INACTIVE SINCE 19997. TRB then Sky Bank then Huntington Bank. See filings.

92
. In mid-August 2013, owner Robert Gillenberger Jr. made the decision to change the name of Rj Development Co
and begin a rebranding process that would take the company to another level.
https://colliersinternationalpittsburgh.com/2020/10/01/colliers-international-pittsburgh-assists-rj-community-
management-with-office-search/amp/.
93
. In mid-August 2013, owner Robert Gillenberger Jr. made the decision to change the name of Rj Development Co
and begin a rebranding process that would take the company to another level.
https://colliersinternationalpittsburgh.com/2020/10/01/colliers-international-pittsburgh-assists-rj-community-
management-with-office-search/amp/.

247
Initial financing No.

Nov. 11, 2015: Gillenberger, file another fictitious name. RJ Property Maintenance, with Rj
Dev’t the control entity (Larrow) address for both at 20475 Rte. 19, Cranberry,
+++Labovitz executes as OWNER.
Feb. 2016: My brother RTVE suffers a massive stroke and is hospitalized for two weeks. I am
unable to stay in Pittsburgh to manage his health as his POA nor assist my mother with
Alzheimer’s diagnosis My brother is released to my mothers against me, and my mothers’
wishes at the time simply because she could not control or care for him at that time.

248
April 23, 2016: My brother Tobias suffers a catastrophic Brainstem stroke. My mother and pay
a fortune so that I can manage and monitor. Because the illegitimate Control Group of Imperial
never complied with the FHA or Pennsylvania’s thereby refusing to allow me and my ESA to
live with my mother while we will be dealt with catastrophic losses and injuries. At all relevant
times, the alleviate BOD violated law to my mother’s financial, personal, medical detriment
which foreseeably was an indirect cause of their unlawful death.
6/10/16: RTvE who is recovering from a massive stroke while his brother is in ICU after also
suffered a catastrophic stroke is targeted for improper and illegal unlawful collection of debt:
His notes reflect: Some baseless demand for money to which he tried to respond.
RTvE: to clarify payment for June and may mix-up for 5600 Munhall Rd, flex bill condo fee
Arnheim & Neely contact 425 North Craig Street, Suite 100 • Pittsburgh, PA 15213 Office: 412-
391-1900 • Fax 412-316-0090 Arnheim & Neely.
Spoke today with Becky Ewing 94412 316-0086 in accounting very nice. fixed the penalties for
$50.00 dollars for late fees related plumbing billing mix up with Stahl after speaking with Stan
Angrist the president of Imperial House.
April 2016 through August 2: Controlled Franchisee Keller Williams control persons including
its attorney, William Labovitz alleged counsel for Eve Chase McClister all conspired to defraud
EVE a senior citizen with Alzheimer’s and money by collaborative false statements, lies, by use
of fraudulent documents including a non-existent contract leveraging upon my ICU based, not
expected live brother’s catastrophic brain damage to conceal the true facts which included my
brothers of the alleged offer, fraudulent mortgage papers, and the fact that the alleged buyer
never signed any contract.
July 2 through August 5: The control persons of PNC and their affiliates, nominees, associates,
etc., violate by circumvention Pennsylvania’s Power of Attorney by honoring it on service but
blocking and obstructing my ability to access the account and denying my mother’s and my
instructions. At all relevant times, her retailed elder lawyer and long-time property lawyer both
of whom knew of my brother’s major disability and risk of financial exploitation to my mother
turned a blind eye to the unlawful conduct of the control persons of PNC.
2016: After Greg Jordan, Esq, my former colleague and General Counsel of PNC and his agents,
representatives, nominees and affiliates (including as it turned out my mother’s lawyers, then
elder lawyer, Carol Sikov Love aka Carol Gross, Carol Sikov aka Carol Love aka Trustee 95 a
known affiliate of Robert Bernstein and my mother’s other lawyer, Chase McClister 96) who
together affirmed, adopted, and ignored blatantly retaliatory and illegal conduct by PNC
resulting in the utterly indefensible violations of Pennsylvania’s POA law, 97 Caused PNC by

94
Same accountant today posts the sham acquisition or merger.
95
Upon review of USLAND.RECORDS.ALLEGHENY, SHE IS ENGAGED IN THE SAMSE CONDUCT AS
WELL IN TAX EVASION BY CHARITABLE CONTRIBUTION SCHEME. See e.g. US v. Naftali Tzi Weiss
and HO-11156-A (Clearview Nominee Account);US v. Clearview)
96

97
Both attorneys’ which I assisted my mother in retaining to protect her from my disabled brothers’ potential financial
exploitation at least violated the RPC in turning a blind eye to illegal, abusive conduct that foreseeably and ultimately
caused, triggered, and aggravated my mother’s subsequent financial losses which are immense, and each violation of
law, rule, or regulation satisfies the standard for negligence per se. Specifically, my mother was in a protected class
who her lawyers had a duty to protect as did all financial institutions pursuant First, she was a disabled, senior citizen

249
and through its controlled employees and his nominees, affiliates, s agents, representatives, and
others known and not known retaliate against me for having asserted my rights to assist my
mother and seeking to ensure 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 together 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.
August 5-12, 2016: Brother took EvE to Citizens to open a joint account. At that point, she
could not remember conversations from one minute to the next. The stress and trauma of recent
weeks together with the false allegations against me, were very difficult for all of us. For
instance, when I walked her through the accounts statements and showed the monies my brother
had improperly withdrawn from the account, she was naturally horrified and intended to ensure
that I was protected as I would protect, however. But because my brother lived with her while I
was committed to caring for my younger on a 24-hour per day schedule at the residence that the
trust was supposed to pay for I could not provide the constant reaffirmation or truth saying that
she needed. My brother had access and I did not.
When my mother went to the bank, she with my brother taking lead had literally emptied out two
bank accounts at dollar bank and PNC respectively, yet not one person contacted anyone in a
position to help my mother despite my disabled brother’s overt impairment and the red flags
indicative of financial exploitation. My mother is and was then 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 $K from my mother’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
becoming Administrator, I have multiple instances of overt red flag financial transactions that
everyone ignored as they all simultaneously preyed upon my mother and brothers while
harassing me mercilessly. 98
From 2016 through the summer of 2020: EvE periodic statement infer that the alleged monthly
assessment charges were paid to the following: Arnhem & Neely Ach Debit 200707 095039.
Upon information and belief, Citizens Bank conspired with the undisclosed control persons of
5600 to process Account Receivable Conversion as preauthorized ACH debits without any legal
basis to do so whatsoever from 2016 through Oct 5, 2020, when my mother’s death and the
established of a business checking account required the co-conspirators to circumvent the

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
98

250
applicable law in a different because the business accounts cannot used for ARC conversions
given specific MCIR codes on each individual check. See Feb. 2021 Facts. 99
2017
March 30, 2017 Debtors, Bill Larrow, Esq. and Robert Gillenberger, Secured Party, Sheffield
Financial, Division of Branch Banking and Trust Company.

October -24-2017: RTvE call Linda [Zeffhuss] about direct withdrawal before 2:00pm at 412
316-0062 His contemporaneous notes are:
Bought Arnheim Neely new management 08-2020 https://www.rjcmgt.com/
Direct Deposit continues Robert Gillenberger Jr President
See website RTvE Copied that Date.
Rj Community Mgt. is moving! We 've moved to:
4900 Perry Highway
Bldg. 1, Ste. 300
Pittsburgh, PA 1522
Our new phone number is 412-550-0003. 17
2018
July 30, 2018: Title Resource Group d/b/a as Keystone closing services Inc. filed a transfer of
foreign registration document importing a merger and that the surviving corporations title is,
secured land transept transfers LLC New Jersey Corporation with the associate session’s
jurisdiction of formation in Delaware and cheated by Seth Truitt Keystone closing services LLC
and Seth by Truitt Senior VP assistant secretary, title resource group LLC sold so member.
2019 100
August 12, 2019: Brother took EvE to Citizens to open a joint account. My mother is and was
then y 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 $K from my mother’s

99
, I learned for the first time that at all relevant times, members of the control group of CBs 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 an Electronic Funds Transfer properly authorized by the payee/bank customer by mandatory notice and
agreement thereof. At no time, was any payment to 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. 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

100

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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. See facts from Aug. 5, 2016, when my brother emptied all
mom’s accounts and moved her money. Everyone who was paid to protect her either turned a
blind eye or actively facilitated my brother’s fraud because it either benefited an ongoing fraud
by predators’ lenders or banker or alternatively the conduct served to shut me up and further
impair my credibility or ability to help my mother. 101
Nov. 19, 2019: Debtors: L. Steward & A. Silk 102 at Darlington Road Address UCC lien – S&T
Bank Creditor

2020
Feb. 2, 2020: AG controlled unit. Unit 807 Heidi Krupp (Krupp Limousine Service to Keren
Gilboa (Art Goldberg’s daughter) allegedly for $250K see Pgh Post-Gazette). Limo service
highly suspect and illegal because residential only building. Bod control membership changed
slightly over time: Membership changed slightly over time.
Bernstein
Carol Lampe (as of at least.
Deborah Knox
APRIL 13, 2020:
April 23, 2020: Debtor, Imperial House Condominium Association, Inc., c/o Arnheim Neely,
425 Craig, Street, Secured Party, Commonwealth Bank, Butler Street. Continuation of 2015
financing Collateral copied and pasted Initial Financing No. Exhibit A.

101
It was only in Feb. 2021, that I learned that, 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. Indeed, 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 $K 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.

102

252
253
Spring 2020: Colliers International brokers Edward Lawrence and Paul Horan assisted RJ
Community Management in the selection of their newest office location at 4900 Perry Highway.
With a move in date of August 2020, the 9,350 RSF suite allowed RJ Community Management
to consolidate their Cranberry location and Arnheim & Neely’s Oakland location, a firm they
acquired in August of 2019. https://colliersinternationalpittsburgh.com/2020/10/01/colliers-
international-pittsburgh-assists-rj-community-management-with-office-search/amp/. 103
July 2020: RJ Facebook page announces, “We are excited to formally announce Arnheim &
Neely will be joining Rj Community Mgt to create the second largest community management
firm in Pittsburgh! “As of August 1, 2020 Arnheim, & Neely will be changing their name to Rj
Community Management. Combined Rj Community Management will manage over 140
community associations, 10,000 households, and oversee more than 20 million in association
funds! 104
2020: Imperial House Board announces that Arnheim & Neely the alleged HOA property
management company was sold to RJ Development. The same is reported in the Press by
Robert Gillenberger 105. However, per DOS Corporate records, there has been no corporate

103
Colliers International brokers Edward Lawrence and Paul Horan assisted RJ Community Management in the
selection of their newest office location at 4900 Perry Highway. With a move in date of August 2020, the 9,350 RS
suite allowed RJ Community Management to consolidate their Cranberry location and Arnheim & Neely’s Oakland
location, a firm they acquired in August of 2019. https://colliersinternationalpittsburgh.com/2020/10/01/colliers-
international-pittsburgh-assists-rj-community-management-with-office-search/amp/.

104
https://www.facebook.com/ANMgtPgh/
105
https://colliersinternationalpittsburgh.com/2020/10/01/colliers-international-pittsburgh-assists-rj-community-
management-with-office-search/amp/

254
action or filing since the Oct. 2007 change of address to 425 Craig Street 106 -- t although Bob
Gillenberger was added as President of the entity on a date unknown. 107
August 18, 2020: Debtor: Debtor, Deb Knox UCC Lien Secured Party:

August 8. 2020: Norman S. member of IH control Group demands POA to provide another key
to EVE. After research, I realize for the first time that the lack of statutory notice of the
revocation effectively nullified the revocation of the POA together with the fact that every time
my mom spoke and I reminded of the transactions that were in fact made by my brother not me,
she always, always directed that I be the POA unless and until my brothers recovered.
However, due to the elder lawyer’s malfeasance I never knew and therefore was not in a position
to protect since I had been discredited art every turn by all those defrauding me or my mother.
See Chart RTvE provided the POA to Norman who gave him the key. 108
August 23, 2020: EvE dies after suffering traumatic injury to her arm, hand, and horrible dental
pain while being effectively starved to death. See Coroner referral. Subsequently, I learn that all
persons who exploited, injured, or knew of the same as well as of the risk of financial
exploitation by my disabled brothers of my mother in every instance failed to comply with
statutory mandatory reporting.
\Aug Moved
The past month I learned of persons that control Citizen’s Bank in Pennsylvania and its branch
location who actively conspired with all previously identified bad actors to defraud my mother
for personal profit and/or in furtherance of endless effort to shut me given my history at the SEC
and subsequent thereto (basically I have a knack for quickly identifying fraudulent schemes
which I think are just mistakes but end up being intentional subjecting to harsh retaliation from at
least 2000 through the present. Just saying. 109

106

https://www.corporations.pa.gov/search/corpsearch

107
In fact, these representations are fraudulent and false, the only corporate filed with the DOS during the relevant
time period are changes of Registered Agent address and at some point, Robert Gillenberger is listed as President of
the entity together with all historical control persons (i.e., Silk, Stewart, and Zehfuss. This is the only DOS corporate
record attached to Arnheim & Neely, all other records linked to Arnheim & Nelly are the corporate records of: Eisner
& Himmler, Inc. was incorporated in such records recorded with the Pennsylvania corporation’s division and then the
corporate name and shell is transferred the November 4, 1935.
108
At all relevant times as part of the scheme, the co-conspirators intentionally avoid putting anything in writing and
all blatantly false or deceptive statements are in person or by phone.

109
See e.g., email to Secretary Boockvar, latest revelations regarding the Freygold/Wecht and Williams conspiracy,
all emails regarding investigative conclusions on all fraud-related investigations at the SEC.

255
2020- present (as limited to this fraud) All co-conspirators target my mother Estate (and me
through multiple related schemes)

September 3, 2020: Unbeknownst to me because I do not have back account access, TIAA Cref
deposits 2,7201 into mom’s account which well have owed to her depending on the terms of her
contract. See Sept. 290.
Sept. 28, 2020: Obtained Ltr. of Admin. Short Form Certificate. Contacted CB by phone
immediately that day to set up new account, close old account, etc. Farhan said he could not
take any action without formal papers other than the short from death certificate or the EIN
which I could not obtain until after the Short Cert Form was issued. He refused to close my
mom’s checking or credit card account.
Sept. 28, 2020: Farhan immediately initiated a reclamation of a TIAA deposit of more three
weeks earlier on 09/03/2020. A fact I learned only on Feb. 1, 2021. First this conduct is illegal
and subject them to liability because it had been credited to the account and they are no legal

256
basis whatsoever to reclaim or reverse a deposit which we may have been entitled to. See e.g.,
Treasury Green Book. “Accordingly, all acts and conduct going forward was fraudulent what
they knew and what they did when they learned it.
/
Sept. 29, 2020: Contacted Citizens Bank and spoke to Farhan Z. at the Squirrel 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 simplicity. 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: Farhan and I exchanged several emails, where I successfully transmitted the death
certificate and short-form certificate, but Farhan 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
associated with my mother’s checking account, but Farhan insisted that it would have to wait
until I was able to personally appear. See emails, Farhan to UVE, Subject Hi.
Oct. 2, 2020, Emailed Farhan 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 is 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/rds. including a
½ each of the improperly deposited SSA payment for October 2020.
October 5, 2020: First, 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 affect the
unlawful ACH debits. There is no plausible basis to believe anything 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.110
Form 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 affect the unlawful
ACH debits. There is no plausible basis to believe anything else and it appears that the co-
conspirators simply transferred money from the Estate Account to their own personal accounts

110

257
held at Citizens Bank in its role as Depository Financial Institution. 111 I also went to CB in
Squirrel Hill and the following occurred:
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.
I was not provided any disclosures or agreements;
I requested all bank statements but was only given what the staff could personally print out that
day,
I was told I could not obtain copies of her bank statements directly from the bank;
Jay Luzier reiterated that we were responsible to pay SSA back and that the deposit had been
received on Oct. 4 as he also told my brothers when they appeared to withdraw their monies one
day earlier. In retrospect given the utter of lack of notice or information about the TIAA alleged
reclamation, Luzier’s intense interest in our understanding our liability is suspect particularly
since he was knowingly lying since he knows that the liability was theirs all along.’
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.
I never received any account opening statements or disclosures.
On the same date requested and received copies of some account statements from the bank. Told
no internet access. No access to EvE credit card statements which I still do not have. When I
reviewed the few statements I obtained, there was ample evidence of financial fraud in addition
to the fraudulent alleged ach withdrawals by the Silk Stewart Zehfuss Ackerman Guise and
Gillenberger and Labovitz the undisclosed persons of IMC aided and abetted by the in-building
fraudulent BO and all attorneys who knowingly aided and abetted the scheme by witnessing,
preparing, etc. fraudulent real estate papers with the property recorded which were fraudulently
recorded improperly, blah, blah
At no time, thereafter, did I ever receive a complete monthly statement by mail. And as I
realized only after I became suspicious of Jay that the online account statements are one of
several pages so that there was no way to get any detail on IH transactions which I only realized
the week of January 13, 2021 See email
The bank statement which included September 2020, demonstrated indisputably that Citizens
knew my mom was dead as of September 21, when TIAA reclaimed my mother’s monthly
payment. f
: Truist fka SunTrust dba Light Stream violates all manner of laws for purpose of defaulting
loan.
Light Stream’s/SunTrust's systems. SunTrust and its division Light Stream are a federally
registered service mark of SunTrust Banks, Inc.

111

258
259
On Friday, October 1 ,2020, Admin took necessary actions to close out the decedent’s financial
accounts on October 1, 2020, within three business days of obtaining the legal authority to do so.

260
Further, necessary actions were taken to open an Estate Account to pay for all estate
administration expenses, loan payments, etc.
Friday night, Oct. 1 through Sunday October 3, 2020:
Administrator attempted to contact LightStream by phone to obtain instructions on next steps;
however, LightStream does not publish such information nor does LightStream website or loan
contract identity SunTrust as a point of contact or even as a material party to the loan contract
itself.
Nowhere on the existing contract or on Light stream’s website is any reference to SunTrust nor
any seemingly applicable provision, etc.
Oct. 1 through Sunday, Oct. 3, 2020: Obtained access to your customer, the decedent’s email
communications to and from LightStream which referenced an upcoming payment albeit a
payment date seemingly inconsistent with prior ACH withdrawals which appear to occur on
random dates between the 6th and 8th of the month.

261
262
Mon 10/5/2020, UvE Email to LightStream from EvE’s email account.
From: Elsa V <elsavoneck@gmail.com>
Sent: Monday, October 5, 2020 12:18 PM EST
To: Light Stream <customerservice@lightstream.com>; Uta von Eckartsberg
<uvoneck@outlook.com>
Subject: Re: NoTification Re.: Number Ending in 2881 (Estate of Elsa von Eckartsberg)
Dear Lightstream Customer Service Team:
I am the administrator of the above-identified Estate. Dr. von Eckartsberg recently passed away
and was probate just opened week and her bank account closed on Friday, Oct. 3, 2020. The
loan is a debt of the estate and we want to provide with the account and routing number for the
monthly auto-debit going forward. I recognize that this is last minute, but I hope under the
circumstances you will waive any potential penalty to the extent that I am somehow unable to
provide the new account number before the auto debit attempt from the now closed account.
Please advise at your earliest convenience. If I provide the new account information,
Lightstream can deduct the scheduled payment as early as today. Please reply to me at
uvoneck@outlook.com today and going forward please substitute my email address.
Attaching email dated 09.29.2020 re upcoming payment.
From: Elsa V <elsavoneck@gmail.com> Sent: Monday, October 5, 2020 2:05 PM est
To: LightStream <customerservice@lightstream.com>
Subject: Fwd: NoTification Re.: Number Ending in 2881 (Estate of Elsa von Eckartsberg)
Forwarding original email with my email instruction and adding: PS is it possible for you to
confirm receipt of this email notice? I am unable to identify a customer service phone
number. Thanks.
The remainder of the day through Tuesday Oct. 6, 2020: Admin is attending to multiple other
time-sensitive matters; however, I checked my email account for a response from lightstream.
Not receiving a reply, I assume LS will act appropriately to ensure no prejudice to Estate of EvE
given timely and detailed notice. At a bare minimum, I assume the Oct. 6, debt will be
cancelled until LS figures out what it needs from the Estate. On Tues. Oct 6, 2020, I continue

263
to check my email but am tied up and distracted by other seemingly more urgent matters and
assume given timely notice under the circumstances, there will be no issue.
Wednesday Oct. 7, 2020: Having still not received any follow-up or response from
Lightstream; I access my mother’s online email account and see the following three emails from
Lightstream which ignore my instruction and provide conflicting instructions which omit
material facts necessary to prevent a claim by LightStream/SunTrust that the Estate failed to
honor its obligation on the loan contract and/or that any default increased loan interest should be
imposed on the loan account.
Specifically, SunTrust d/b/a Light Stream’s emails my mother, the decedent twice late
afternoon on Monday, Oct. 5, 2020, as follows. :
From: LightStream <customerservice@lightstream.com>
Sent: Monday, October 5, 2020 3:47 PM [1 HOUR BEFORE COB EST]
To: Elsa V elsavoneck@gmail.com [Ignores request to email me directly or even to copy me and
simply continues to email a now deceased individual]
Subject: Re: NoTification Re.: Number Ending in 2881 (Estate of Elsa von Eckartsberg) -
Reference Number Ending in 2881
In order for the loan to be handled by the correct department, please submit the death certificate
via fax at (844) 728-5305. No info or reference to |dept. likely SunTrust]
If you have access to the client's online account, please let us know in order to open an area to be
able to upload the death certificate through LightStream.com. [Obviously, Lightstream could
have simply opened the area – no harm, no foul if I did not have access; rather insist on
confirmation from me while knowing or being reckless in not knowing that Admin may not have
access to decedent’s email on an ongoing basis and further that I would clearly be expecting LS
to follow-up with me directly per my emails which include my phone number]
Your information has been forwarded to the department that will be assisting you moving
forward. [No contact info or other identifying info re “Dept”*
“Adrian”
Next, at 5:00pm EST, a Stephanie writes the decedent a stand-alone email (which unlike the
others does not contain or reference my timely emails with correct contact info)
From: LightStream <customerservice@lightstream.com>
Sent: Monday, October 5, 2020 4:54 PM
To: Elsa V <elsavoneck@gmail.com>
Subject: Fwd: NoTification Re.: Number Ending in 2881 (Estate of Elsa von Eckartsberg) -
Reference Number Ending in 2881
For further assistance, please contact us at (866) 635-1330 [No reference to any prior email
exchanges nor the prior instruction re.fax]
Also on Oct. 7, 2020, at 2:30AM EST LS customer service again emails the decedent writing:
From: LightStream <customerservice@lightstream.com>
Sent: Wednesday, October 7, 2020 2:23 AM
To: Elsa Voneckartsberg <ElsavonEck@gmail.com>
Subject: Payment Confirmation - Account Number Ending in 2881
This email confirms that we received your payment of $372.29 on October 6, 2020.

264
[Which I interpret as evidence strongly suggestive of the fact that Truist/Lightstream/SunTrust
never attempted to stop or reschedule the payment despite knowing or being reckless in not
knowing as of noon, Monday, Oct. 5, that the payment account was closed and thus arguably
engaged in conduct intended to trigger a default, or higher interest rate which would of course be
in violation of all manner of consumer protection laws as well as all applicable laws regulating
the conduct of banks and other financial institutions]
On wed. after leaning for the first time that LS had simply continue to write my mother and gone
ahead to process the payment from the closed account, I hurriedly responded to each of the three
emails in response to Lighstream’s emails of i Mon, Oct 5, 2020 at 3:46 PM instruction re: Fax.
From: Elsa V <elsavoneck@gmail.com>
Sent: Wednesday, October 7, 2020 2:08 PM
To: LightStream <customerservice@lightstream.com>
Subject: Re: NoTification Re.: Number Ending in 2881 (Estate of Elsa von Eckartsberg) -
Reference Number Ending in 2881
Will do. However, I just received by separate email a notice that the payment due this month
was processed successfully? That cannot be true because the account numbers you have been for
closed account. I am not sure what to do now? As ns initial matter, I will upload a copy of the
death certificate and a certificate demonstrating my role as administrator of the estate. Please
provide with a link at your earliest convenience. [relating back to the Oct. 5, 2020 email in
which Lightstream failed to simply open a link allowing me to upload the requisite dox in a
timely fashion]/
3:00 to 4/;00 PM 5305Tied up with other foreseeably urgent matters and still expecting good
faith conduct from my mother’ s lender.
October 7, 2020 4:03 PM : Successfully fax Death Certificate and Ltr. Of Admin to: (844) 728
even though I have not received any direct follow-up from ST/Lstrm. Note, , I also included a
certified letter of administration demonstrating I have legal authority over the Estate of Elsa von
Eckartsberg as of Sept. 28, 2020. The Fax cover provides my contact information and the
following comments restating and reiterating the applicable notices, requests, etc.:

Per your request and for your information, please find attach a copy of the Certified.
Death Certificate and Letter of Administration issued on and effective Sept. 28, 2020.
On October 4, 2020, the payment account for the instant loan. On Oct. 5, 2020, I
attempted to provide Lightstream with new payment account information by email and
phone (albeit I could not identify a customer service number on Lightstream’s website,
etc.).
Unfortunately, I did not see the reply until yesterday after COB. In the interim it appears
an attempt was made by Lightstream to affect the auto deposit from the now closed.
account. Again, I am just trying to provide you with bank account info for the Estate.
account going forward.
Go back to other matters and then having received no response or even an acknowledgement of
receipt of Estate fax, I go back to my deceased mother’s email account and see yet another
untimely, non-responsive, uninformative email which utterly ignores all prior communications

265
and is sent as a stand=alone email to give the appearance of an unrelated communication;
specifically, as follows:

From: LightStream <customerservice@lightstream.com>

Sent: Wednesday, October 7, 2020 3:16 PM
To: Elsa V <elsavoneck@gmail.com>

Please call (866) 635-1330 for further assistance [NOTE BY NOW IT IS AFTER COB EST]
[THEY ARE ON PST]
s
7:00 EST Admin Phone call to 866.635.1330: Connect with a very kind, appropriately
apologetic, CS rep (Mr. Elsa) who also for the very first time offers condolences to me for the
loss of my mother, your customer who has never once missed a payment during the applicable
time period. After hearing the context and reason for my call, he informs me that he cannot help
because I need to speak to the “Division” that has responsibility and authority for the instant
matter. Reluctantly and only upon prodding (and I assume the reluctance to share any
appropriate info is a management-imposed policy) he provided the following information to me,
more than 72 hours after initial notice on Oct. 5:

▪
Confirms Fax received by appropriate “Division”;
▪informs he has no access to email communications or prior events (calling into question the
basis from Oct. 5 onward to ever instruct me to call this particular number);
▪Identifies the “Division” as SunTrust’s Life Event Account Planning and Support (LEAP);
▪When Admin asked to be transferred to LEAP, he apologetically explained while Lightstream
reps are based nationwide and are often available after 5pm EST; the same does not hold true for
LEAP because it is part of SunTrust located in Florida and observes EST banker’s hours.
▪ I now recognize that all that was required to avoid an attempted ACH withdrawal and any
negative consequences for the rejected attempt, would have been for “Lightstream” to provide
me with the above-described necessary information. Full Stop.
Oct. 7, 2020: Before following up with SunTrust during business hours, I once again checked
the decedent’s email only to see the following notice from “Lightstream”:
,
Our recent attempt to debit your monthly payment was unsuccessful due to your account being
closed. Please sign in to your account online to update your banking information. [demonstrating
that initial email requiring the Estate to confirm access to account was a deceptive and
misleading since now that the due date is past Lightstream makes option to upload
documentation freely available] Once your bank account information has been updated, we will
debit your monthly payment of $372.29 within 2 to 3 business days. At this time your account
is being sent to the Collections department at SunTrust for further action [the very first written
reference to Sun Trust as having any direct role on this matter] . If you have questions regarding
this email, please contact the SunTrust Collections team at 844-297-2317 Monday through
Thursday 8 a.m. to 9 p.m., Friday 8 a.m. to 7 p.m., and Saturday 8 a.m. to 1 p.m., ET. [But no

266
address or direct contact info whatsoever in violation of the FDCPA, and Pennsylvania’s
FCEUA among other things] This communication is an attempt to collect a debt and any
information you provide whether written or verbal, will be used for that purpose. [Who is the
debt collector? Lightstream the sender of this email? SunTrust the collections entity?]

267
268
Oct. 15, 2020: Found (3) new emails: In addition to the instant email, I found new two (2) new
emails falsely representing that I updated the “work number” and email for EvE –False (When I
was online trying to upload the new account info and was unable to do so I did input my email
instead of mother’s but then reconsidered and left it all alone. I did check back to ensure that no
changes were reflected on her online account.
From: LightStream <customerservice@lightstream.com>
Sent: Friday, October 9, 2020 9:41 PM
To: Elsa Voneckartsberg <elsavoneck@gmail.com>
Subject: Regarding Your Monthly Payment - Account Number Ending in 2881

Dear Elsa Voneckartsberg,

This is a reminder that we have not received your monthly payment that was due on
Tuesday, October 6, 2020. The invoice is available for download in the Documents
tab of your account.
Please mail your payment along with the invoice to the address provided or sign
into your account online to schedule a one-time payment.
SIGN IN
At this time your account is being sent to the Collections department at SunTrust
for further action. If you have questions regarding this email, please contact the
SunTrust Collections team at 844-297-2317 Monday through Thursday 8 a.m. to 9
p.m., Friday 8 a.m. to 7 p.m., and Saturday 8 a.m. to 1 p.m., ET.
Thank you,

269
 LightStream
A Division of SunTrust Bank
This communication is an attempt to collect a debt and any information you provide
whether written or verbal, will be used for that purpose.

LEGAL DISCLAIMER The information transmitted is intended solely for the individual or
entity to which it is addressed and may contain confidential and/or privileged material. Any
review, retransmission, dissemination or other use of or taking action in reliance upon this
information by persons or entities other than the intended recipient is prohibited. If you have
received this email in error, please contact the sender and delete the material from any computer.
By replying to this e-mail, you consent to LightStream's/SunTrust's monitoring activities of all
communication that occurs on LightStream's/SunTrust's systems. SunTrust and its division
LightStream are a federally registered service mark of SunTrust Banks.

270
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 statements. Per his direction, I faxed the Short form cert, the letter. 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.

271
272
 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 Record.
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 overtly 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
On or about Nov. 22, 2020: Bill Larrow, Financial Manager of the alleged property management
co. aka control group emailed and said that the delay was due to new electronic program of some
sort.
debit from the estate account.

273
 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, deceit, and misrepresentation. It was necessary for me to contact them once I
recognized that the scheduled payments for what.
deducted. See attached, a redacted version of the so-called preauthorization form which directed
me to also provide a voided check. 112 See Exhibit Form and voided check. 113 The bank
obviously did not act as a gatekeeper.
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 acceptable for a one-time electronic check conversion NOT a
reoccurring preauthorized debit which must be initiated an authorized by the client directly; and
that the check is a business account check which is not and has not ever been eligible for any
kind of check conversion whatsoever. Specifically, it contains an “on-us” symbol which CB
knew at all relevant times precluded any.
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 preauthorization form which
directed me to also provide a voided check.114 See Exhibit Form and voided check. On
Sunday, January 24, 2021, I learned for the first time that.
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 guess – PNC is the other banking entity
involved);

112
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.
113
On Sunday, January 24, 2021, I learned for the first time that 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 guess – PNC is the
other banking entity involved);
114
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.

274
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 acceptable for a one-time electronic check conversion NOT a
reoccurring preauthorized debit which must be initiated an authorized by the client directly; and
that the check is a business account check which is not and has not ever been eligible for any
kind of check conversion whatsoever. Specifically, it contains an “on-us” symbol which CB
knew at all relevant times precluded any debit from the estate account.
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 5th of the
month, banking staff processed a transfer to the illegitimate 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 in artfully describing the transaction as follow, Imperial House Condo dues 115
The rules protecting business accounts that were blatantly violated are in place to protect
fiduciary funds such as estate account and for the express purpose of providing business
customer tools to combat ACH debit fraud to their business customers. 116 At no time, has
Citizens ever protected this estate or my mother’s account before me from any improper or illegal
financial fraud. The only person who is blocked from accessing estate funds is the only person
legally entitled to access such funds – me.
On or about December 1, 2020: Letter. 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. Unbeknownst to me at the time, the letter was rife with
materially false, unfair, and deceptive representations all intended to shift Citizens’ liability for
its failure to comply with rules, regulations, and contracts to the Estate by deceit although none
of that was known to me until recently. In the letter, Ms. Paulo falsely and baselessly
representant 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 beneficiary 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

On or about the week of January 13 through the 29th, I figured out what the scheme is and how it is facilitated after
115

much research of things that I would not and could not know absent insider information. See ______.
116
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.

275
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 comfort whatever. EXH Audiotape of call.
On or about December 5, 2020: Pennsylvania DOS sent me a REV 1543 which contained false
and fraudulent information about me and my tax liability personally. At the time, I thought it
was a mistake and a corrected form would be submitted to the Dept. of Revenue upon Request.
CB local branch employees inputted false information into a form which is certified as truthful
and submitted to the Dept of Revenue likely subject penalties for false statements and/or perjury.
In the form the co-conspirators again falsely ascribing income to me that I never had.
Specifically, the information provided to the DOS is that I am the beneficiary 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 certifications as part of the
conspiracy to defraud my mother and now her estate while simultaneously 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 Farhan 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
email and its attachments to Jay Luzier. I did not receive any response.
On or about, December 23, I resent the email to Farhan 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
Condominium 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 Develop and its failure to timely process the then-unknown fraudulent
assessment charges. Specifically, he wrote,

Re.: “Dues Payments”

276
As an owner on Direct Debit payments through RJ Community Mgmt.’s office, 117 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 Document that I was required to execute entitled, “ACH Authorization Agreement for
ACH Payments.” See infra, t Oct. 9, 2020 for detail as to my discovery that this Form is in fact a
badly revised altered version 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, Farhan replied ignoring my instructions and writing that I should just
fill out the form and send it to DOS 118. , Farhan replied ignoring my instructions and writing
that I should just fill out the form and send it to PA Dept. of Revenue, which would require ME
to make a false statement in furtherance of the scheme to defraud and the estate. See REV 1543
Form language.
Same Day I replied by EMAIL: TOLD HIM TO FORWARD TO JAY.
December ____, 2020: I realized that the alleged HOA assessments were not debited on the 5th
of October or November.
January 7, 2021: Farhan responded with a stand-alone email providing Jay’s email address.
Also, January 7, 2021: 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, See December notes above. Accordingly, I
began to research the issue to understand the consequences of delay. And I subsequently
learned that t the December 8, demand letter was materially false, misleading, in breach of CB’s
contract with treasury and required CB staff to make false certifications to treasury and SSA.
After investigation, I also learned:
(1) Citizens had a nondiscretionary duty to send the copy of the reclamation notice to me which
was not done;
(2) they were not to contact me at all.;
(3) CB either (1) failed to timely comply with it notify the government of its account holder’s
death or (2) deferred notice intentionally with the intent of defraud the estate of its customers.
(4) CB’ Bank knew or was reckless in not knowing of my mother’s death because it facilitated
or initiated a reclamation by TIAA on Sept 28, 2020, without notice to the beneficiaries

117
118
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 Document that I was required to execute
entitled, “ACH Authorization Agreement for ACH Payments.” See infra t Oct. 9, 2020 for detail as to my discovery
that this Form is in fact a badly revised altered versions 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.

277
(5) despite knowing or being reckless in not knowing that once credited to the account, CB had
no authority to initiate or facilitate any reclamation because the accounts belonged to the
passbook beneficiaries and the estate;
(6) Given the above reclamation, its CB is charged with constructive notice as of that date’
(7) CB agents would not suspect that a layman would know anything about reclamation so upon
information and belief, the employees who had indisputable notice as of October 1 per email
exchanges between me and. Farhan Z., chose not to act in furtherance of the scheme to leverage
and profit upon its customer’s death.
(8) and without knowing whether or not that monies which was credited to my mother’s 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 reasonable notice of death and the failure to do results
in strict liability for the bank. 119
Accordingly, 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 act. See audio tape available upon
request to any independent investigative authority.
Next, I spoke to a Lynn M. who was identified as Saundra’s supervisor and with her permission,
I audio taped this a 23-minute 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 liability to the
estate using unfair, fraudulent, and deceptive tactics due to its own noncompliance. During both
calls, I referenced 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, Farhan graced me with a response to the latest follow-up email sending
Jay’s email address by stand-alone email meant to conceal his blatant denial of my repeated
requests albeit today I recognize that Jay probably instructed him to conduct himself this way.

119
This week I learned that the whole was collection of unlawful debt as a part of scheme to funnel my mothers’ SSA
payments to themselves in violation of all manner of laws thereby defrauding the state and treasury. The control
persons effectively stole all 3,009 from my mother’s estate and then forced me to pay them another K for the money
that they never returned to SSA and because of the fraud to steal the m money, the SSA has now sent the Estate a 1000
which reflects that my mother did receive the Sept and October payment and now should pay income tax on the money
the co-conspirators stole from my mother and now her estate.

278
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 beneficiary 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 Farhan, 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 conspiracy 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 Friday, 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 constitute
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 were not by a Citizen’s employee, I
would have disputed this charge as fraudulent from the outset. And I do dispute it. I have a
fiduciary duty to the estate. And you and Citizen is arguably having a fiduciary duty to the Estate
or at least a basic duty of good faith and fair dealing. 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

279
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. 120
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 12, 2021: Jay Luzier responds by phone not writing for obvious reasons in retrospect.
Exhibit, Audiotape recording of vm message.
January 13, 2021: I do not receive the message, so I resend the above-described email with the
material attachments which unbeknownst to me revealed and threatened two related schemes to
defraud me, the estate, and/or my mother. First, I was threatening to expose a long-time
conspiracy wherein ACR payments were illegally induced and accepted by Citizens Bank as part
of conspiracy between the undisclosed control person of IHG d/bay/ RJ fka Arnheim fka CBRE
inc., etc., etc. He falsely represented that while he did not agree with my concerns about
improper conduct by the ROP group in Rhode Island, he would definitely make sure someone
followed up with me and (2) he falsely represented that he understood that the information
certified to the Dept of Revenue was inaccurate and would see if he could ensure that a corrected
Rev 1543 was submitted to REV 1543 -- subsequent conduct and investigate results demonstrate
his personal complicity in a major financial fraud preying primarily n senior citizens. And
finally, because I trusted him and because I knew that the IH control group was trying to export
confidential information from in return for their not pursuing illegal, baseless, fines in excess of
$100 per day for protected conduct without even the presence of due process procedural or
substantively. And because of the overt attempt to seemingly paint me as member not in good
standing and the failures to timely process what the control group fraudulent claimed was due
them, I was concerned that there would be illegal debits out of the account for unlawful debt
collection not owed for hundreds if not thousands without notice to e. Without sharing all of
that, I asked Jay if he would be so kind as to put a stop payment order in against the entity that
had I believe d that I had preauthorized to make ACH withdrawals on a recurring monthly basis
for monthly condominium assessments. He looks ed at my account statements identified the
specific transactions noting the lack of information beyond -- IH HOA dues -- and assured me
that no further action on my part was necessary and the Stop Payment Order was entered and
effective that date. Subsequent events demonstrate that he lied to me in furtherance of an
ongoing conspiracy to defraud my mother specifically and upon information and belief all
legitimate unit owners at the Imperial House Condominium. ate materially false and fraudulent
representations including but INSERT.

120
Attaching oath 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 malicious
retaliation all of which constitutes at bare minimum a UDAAP.

280
January 13, 2021: Jay and I connected on the phone. By now, the harassment and retaliatory
conduct in my home had escalated to the point that the corrupt control group co-conspirators
threatened and continue to threaten me with exorbitant 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 121.
protected under multiple federal and state laws, of which I have no notice without any
substantive or procedural due process made materially false statements about me to others in
the building and collaboratively lied and concealed material facts all the while threatening me
with outrageous fines for violations of Rules which they refused to provide a copy of, defamed
me public ally, 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 122.
** Our funeral director represented he informed social security of my mother’s death so I was
shocked to find that not just one, but two payments were dep and that he told my brothers that
they and now I would they knew or should have known.
Follow the Money:
What does the monthly condo fee cover?
See website Imperial House.
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

121
Later I learned that absent criminal complicity the Bank could not process any of the alleged debits absent violation
of law, regulation, and statute for multiple reasons, primarily 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
payee’s side is an ARC transaction and there was no acceptable form of authorization that could be or was provided
to the bank by my mother at all relevant times from 2007 through the present.
And since her death, by virtue of the establishment of an estate account they had to Comey either me or even the payee
and because as a business account, the account was entirely 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 the payee used to affect the withdrawals which were
false identified on al period statements or online records as “Ach Debits” when this description is materially false.

122
And the President of the fictitious HOA association was and is personally harassing, threatening, 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 targets of my long term investigation of organized crime on Wall Street which was
so successful that I was harassed and bullied out of my job, lost everything and have been subject to ongoing retaliatory
harassment and racketeering including by governmental official ever since. And the cherry on top is to learn that as
a consequence 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 members of his control also include certain corrupt insiders at the
SEC and elsewhere.

281
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. 123
2120.01.29: COB Friday. Goldberg Exh. Ltr. Note. video photo

123
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, and financial
administration of a professional manager.

282
EXHIBIT

Plus: One Phone Call Audiotape VM and 5 letters to date. Either re: ESA or fake water alarm
today

283
284
 \

285
286
287
288
289
290
291
 124

124
No reference to Complaint. False Certification service and see docket -- no injunction motion paid for, filed, or
served.

292
293
294
295
296
297
298
 \
Attaching Material Confidential Info to my Atty who I know is a coconspirator in the overall
Mortgage Fraud and a member of TOC. See JP MORGAN HACK CONSPIRATOR INCL
GOLDBERG
Attaching multiple doc which contain material info that could represent a risk to me and others -
- I did not know he was a criminal who conspired with those who defrauded my mother. see
cicero case.

299
300
301
302
303
304
305
306
2021

307
308
Feb through Present; Target me (Attys. Judge Dv and his staff aided and abetted by the
Deliberate Silence of Probate Atty

309
See Police Report; #
See 911 call audio.
Contemporaneous video
Constable lied to Officer Henry: Powers, Authority, Magistrate violated every possible Ethical
Rule.
See email to Washington county.
and subsequent false reports to police risking catastrophic harm to me.
Post Home Invasion

Learn who Goldberg Hired and that he had and has no Authority to break and enter much less
refuse to leave and physically restrain my ability to come and go out of my bedroom. Almost
certainly no insurance.

310
311
312
313
314
315
316
ongoing threats and harassment

Goldberg contracted the Constable who was criminally tried in Allegheny County and is almost
certainly not certified.

317
318
April 6, 2021
I do not appear for fraudulent hearing on fraudulent pi.

319
320
321
April 7, 2021: I am a non-pros on fraudulent Complaint in Equity -- the goal of all involved
after Home Invasion.
As of April 10, 2021: Nothing on the docket except for proof that there was no Notice on Home
Invasion assuming for the sake of argument that there was a real injunction ever filed.
MAIL FRAUD REPRESENTATIVE EXAMPLES -- THE BOD
Email Evidence -- Emails UvE through Feb triggering the above
From: Uta von Eckartsberg <uvoneck@outlook.com>
Date: November 26, 2020 at 2:40:21 PM EST
To: Norman Stankewicz <i.housecondo@yahoo.com>
Subject: IH Notices and Information - IH internal Office email list (Unit 309)
Hello,
Please add my email address (uvoneck@outlook.com) to the IH email list for the purposes of all
IH notices, information, and communications going forward.

322
 Also please update the IH address book to include my information.
Lastly, I reiterate my in-person request of Nov 2, 2020 for copies of all current IH bylaws, rules,
regulations, procedures, and policies (and other applicable information typically provided to a
new owner or resident). If possible, please send me the applicable documents and materials
electronically by pdf and/or zip file as necessary. If not, please email me with dates/times when
it will be convenient for me to come pick up the hard copies.
Thank you in advance for your kind attention to this matter.
Best,
Uta
Unit 309
On Sat, Dec 5, 2020 at 4:10 PM Uta von Eckartsberg <uvoneck@outlook.com> wrote:
Hello,
I am sorry to impose upon you, but I understand you are the member of the BOD responsible for
communications. I am the daughter of Dr Elsa von Eckartsberg, the current resident, a legal
representative, Court-appointed estate administrator and the voting representative of Unit 309 per
the UCA, the UPA, and the few governing documents that I have been able to identify on my
own.
To date, I have not received any statutorily mandated notice, information, or materials for either
the annual meeting of Nov. 9 or the meeting sets for this Tuesday. I have known Norman and
Diane for many years and have the utmost respect for them. That said whether in person, by
email, or phone I cannot get their attention. To date, I am not on the internal email list and have
yet to receive the documents described below. To the extent that Diane and/or Norman are not
the appropriate contacts for the requests described herein, perhaps you will be kind enough to tell
me who is?
I have not waived any right to notice or vote. To the extent that what has occurred in my
situation is SOP, I respectfully suggest that a gap in communication that obstructs or impedes
statutorily mandated as well as contractual obligations is problematic for obvious reasons that go
well beyond my personal situation.
I am not making a formal complaint; rather I am simply seeking your informed guidance to
resolve the current communication gap in a timely manner for instance, please let me know if
Bob G. versus Norman/Diane is the appropriate POC albeit with would be remiss if I did not
mention that I have noticed a big communication gap between internal and external property
management.
As you can imagine, this is a difficult time for me and my family so any assistance or guidance
you may offer will be greatly appreciated. Thank you in advance for your kind attention to this
matter.
From: Deborah Knox <deb@knox412.com>
Sent: Saturday, December 5, 2020 5:54 PM
To: Uta von Eckartsberg <uvoneck@outlook.com>
Cc: Arthur Goldberg <artgoldberg@verizon.net>
Subject: Re: IH Notices and Information - IH internal Office email list (Unit 309) Assistance
Requested

323
Hello Uta,
I'm copying this to our Board President, Art Goldberg. The minutes from previous meetings and
notices of upcoming meetings are posted in the lobby and on our Imperial House Facebook
Group Page. All owners are welcome to Zoom in and participate There are no other special
invitations.
I just checked the Allegheny County Real Estate Portal, and your mother is still listed as the
Owner. Have papers been filed to change ownership? As I understand it, we would need some
type of ownership documentation for the binder with our bylaws and information. Usually, it is
coordinated through our management company. I'm not sure of what is going on with this, but
I'm sure we can figure it out easily and am sorry your request hasn't been resolved. Your late
mother should have had a copy of the bylaws in the condo. We are in the process of updating
our bylaws, so your timing is good.
Here's a link to join our group.
https://www.facebook.com/groups/662037827311401
Is there something specific you are looking for? We have a few specialty committees that might
be able to help - and we all work to support Norman and Diane - and all of our owners. I can
forward your contact information to our Communication Committee that maintains our list.
Your mother was a lovely woman, and I had the pleasure of talking to her a few times, even
though she was quite frail. Our next meeting is Friday December 18 at 8:30 AM.
Regards,
d
From: Arthur Goldberg <artgoldberg@verizon.net>
Sent: Saturday, December 5, 2020 7:04 PM
To: 'Deborah Knox' <deb@knox412.com>; 'Uta von Eckartsberg' <uvoneck@outlook.com>
Cc: 'Robert Bernstein' <robert.s.bernstein@gmail.com>; 'Norman and Diane Stankewicz'
<i.housecondo@att.net>
Subject: RE: IH Notices and Information - IH internal Office email list (Unit 309) Assistance
Requested
Thank you, Deb, for including me on the email. By copy to Norman, I am asking him to
respond to Uta and for Bob Bernstein and Norman o include her on or email list.
Uta – the Board meeting agenda is distributed and posted by Norman a few days before each
meeting and as Deb said our next meeting is Dec. 18 at 8:30 am. Due to current conditions we
meet via zoom and the agenda includes the zoom link.
Art
Arthur L. Goldberg
201-819-1848
From: Uta von Eckartsberg <uvoneck@outlook.com>
Sent: Saturday, December 19, 2020 12:42 AM
To: Bob Giese <bgiese@rjcmgt.com>; Arthur Goldberg <artgoldberg@verizon.net>
Cc: 'Robert Bernstein' <robert.s.bernstein@gmail.com>; 'Norman and Diane Stankewicz'
<i.housecondo@att.net>; Arthur Goldberg <artgoldberg@verizon.net>; 'Deborah Knox'
<deb@knox412.com>

324
Subject: RE: IH Notices and Information - IH internal Office email list (Unit 309) Assistance
Requested (
Importance: High
Thanks. Although, I would have thought selective enforcement and prosecution of rules and regs
would be frowned upon. Rob, you are the ethics expert according to your website – what’s is
your basis for believing and/or acting otherwise? In any event, consistent with my initial
concern regarding internal communications below, there is in fact a clear disconnect between
Bob, the BOD, and Norman/Diane – and this disconnect is materially and negatively impacting
me as a member of a protected and the estate by causing undue expenses and time spent caused
by miscommunications and or what appears to be a problematic lack of due diligence. Indeed,
the internal miscommunications are interfering with my own fiduciary duties. I address several
issues of concern and attach some representative emails for your convenience and confidential
review.
Bob, I address you in this email because all confusion appears to be related to a call, he made to
me on Nov. 13. During the call, Bob told me that the BOD requested a letter from my doctor
simply for housekeeping purposes pursuant my gratuitous offer to do so at all relevant times
from August 2018 through the present. I believe the emails corroborate my understanding of our
conversation.
The letter was presumably transmitted to the BOD on a highly confidential basis in trust and
confidence of the BOD’s good faith and compliance with its fiduciary duties. I fail to understand
how a good faith response of providing my doctor’s letter somehow is being interpreted as a
request for accommodation when none has been made because none is needed as affirmed and
adopted by Diane, Norman, and Bob at all relevant times since 2018 through December 2020.
Obviously, I would not have uprooted my entire life to move here while I settle the estate absent
such confirmation. And my dog is licensed appropriately though the end of the year. See
attached. And I have applied for the applicable license for Pittsburgh. It is illegal to charge pet
fees or other costs for an Emotional Assistance Animal. Attempting to oppose arbitrary,
capricious, and unreasonable fines has the optics of attempting to circumvent the statutory
framework of the FHA and the HRA. If you disagree, I strongly suggest you seek the opinion of
your legal counsel before attempting to assert or enforce any such fines or penalties on an
emotional assistance or support animal.
Also, Bob, it appears the BOD does not know that I am definitively the authorized representative
of the estate pursuant the legal papers that I have faxed and emailed to you on multiple
occasions. Will you please ensure that you address whatever questions the BOD may have in this
regard? Frankly, Norman and Bob have known since at least 08/7/2020, when my brother
provided the requested to Norman in order to obtain an FOB. See attached.,
Third, Bob, what is the issue with the monthly auto debits? Not one debit has been timely or even
accurately processed since Oct 9. And attempted debits have been made to my mother’s closed
without any authorization or basis to do so. The December debit has yet to be processed more than
a one week after the date set. What is the problem? Please provide me with all records related to
the refusals of two attempted debits on my mother’s closed account versus the estate account. I
cannot be expected to oversee RJW in the timely processing of auto debits. Please figure this out
and get back to me with confirmation of when the December auto debit will be processed. I have
exchanged multiple emails with Bill Larrow today, but he did not have an opportunity it seems to
get back to me on this outstanding questions.

325
Fourth, once again will someone please provide me with copies of all governing documents
including the original declaration and any amendments thereto, the original bylaws and all
amendments thereto; and whatever version of the Rules and Regulations with which I am
currently expected to comply,
Fifth, I believe that I have not once received timely notice of any meeting nor any of the
materials mandated to be provided to me (including budget, financial records, any anticipated
change in the assessment, etc., etc.) from August 2020 through the present. Furthermore, this
unit has been deprived of its voting rights since at least August 2020. We have had no
representation nor notice sufficient to comply with the mandatory provision of the Bylaws under
the Unit Property Act. All of this conduct together and separately is causing undue and
unnecessary burdens on the estate and on me personally as a member of a protected class.
Sixth, contrary to Deb’s suggestion I doubt that forcing unit owners to search through three years
of FB posts to try to identify applicable rules, regulations and policies even vaguely satisfies
minimum notice requirements.
Seventh, it seems to me that this Board would benefit from legal review of all policies, practices
and procedures connected to your ESA forms, etc. From even a cursory review of FHA, DOJ,
and Pennsylvania’s Human Rights Act as well as the Assistance Animal Integrity Act, your
policies leave you and all of us exposed to massive legal costs and regulatory investigations that
would cost hundreds of thousands of dollars to defend and ultimately would impair the resale
value of this property.
This email is a good faith attempt to force internal communication before this situation escalates
out of control. Finally, I am 100% good standing as a member of this association and any
assertion or claim to the contrary is defamatory and wholly baseless. Thank you in advance for
your kind attention and due diligence in these matters. Happy Holidays.
Uta
2021 April : Identify fact case re First Allegheny mgmt. aka undisclosed control get pop
loan (Pnc citizens — that is where our money going, and that’s citizens lied transferred money
to pay off loan)
CBRE gets ppp loans.
Goldberg dba Bellrock gets ppp loan.
rom: Arthur Goldberg <artgoldberg@verizon.net>
Sent: Monday, December 21, 2020 2:04 PM
To: 'Uta von Eckartsberg' <uvoneck@outlook.com>
Subject: Read: IH Notices and Information - (Unit 309) Assistance Requested (Trying again and
now copying Bob G.'s supervisor since he is apparently unavailable)
Importance: High.
rom: Arthur Goldberg <artgoldberg@verizon.net>
Sent: Monday, December 21, 2020 2:04 PM
To: 'Uta von Eckartsberg' <uvoneck@outlook.com>
Subject: Read: IH Notices and Information - (Unit 309) Assistance Requested (Trying again and
now copying Bob G.'s supervisor since he is apparently unavailable)
Importance: High.

326
rom: Arthur Goldberg <artgoldberg@verizon.net>
Sent: Monday, December 21, 2020 5:56 PM
To: 'Uta von Eckartsberg' <uvoneck@outlook.com>
Subject: RE: IH Notices and Information - IH internal Office email list (Unit 309) Assistance
Requested (
Uta – I received your long email and while I was not aware of your professional background I
am impressed. It my dealings with the SEC I never was involved in any matter in your branch.
Instead of spending so much time and effort in writing legal memos please note the key points in
my email to you which is below.
We have no letter from a physician attesting to the need for a comfort animal. What we have is a
letter without any identification written by an unknown party. That obviously cannot meet our
reasonable need for granting an accommodation to you.
Ringo’s medical records are so faint that they cannot be read. Do you have a better copy?
It would be easier for both of us if we can resolve this between us. I will get you information
tomorrow on how to have the monthly HOA charged to whatever bank account you wish, if you
prefer that or you can mail in a check each month. As to your status, as an attorney I am sure
you could obtain a court document verifying your executrix status and get a copy for us.
Let’s do this the easy way, Uta. Since as I noted I am your point of contact with Imperial House
please do not copy anyone else. Bob is retired and several others have nothing to do with this.
Thank you.
Art
Arthur L. Goldberg
201-819-1848
From: Arthur Goldberg <artgoldberg@verizon.net>
Sent: Wednesday, December 23, 2020 2:19 PM
To: 'Uta von Eckartsberg' <uvoneck@outlook.com>
Subject: RE: IH Notices and Information - IH internal Office email list (Unit 309) Assistance
Requested (
Uta – I have been informed by Becky Ewing of RJ Management, that you did provide banking
information and the December HOA was paid in that manner. I suggest that you contact her at
412-550-0003 to authorize the November HOA to be similarly charged or mail her a
check. Imperial House uniformly charges a penalty and interest on late payments.
Please call me to discuss our other matters at your convenience.
Art
Arthur L. Goldberg
201-819-1848
From: Bill Larrow <bill@rjcmgt.com>
Sent: Wednesday, December 23, 2020 12:06 PM
To: Uta von Eckartsberg <uvoneck@outlook.com>
Subject: RE: IH Notices and Information - IH internal Office email list (Unit 309) Assistance
Requested (

327
Hi,
I recall speaking to you last week and explaining what happened in regard to the direct debits.
Was the information I provided unclear? I don’t see any communication from you that went
unanswered after we emailed last week.
Regards,
Bill Larrow
Rj Community Mgt.
Phone: 412-550-0003 | Fax: 412-227-9003
4900 Perry Hwy., Bldg. 1, Ste. 300, Pittsburgh, PA 15229
This email and any files transmitted with it are confidential and intended solely for the use of the
individuals or entity to whom they are addressed. If you have received this email in error, please
notify Bill@RjCMgt.com and delete this email from your system. This message contains
confidential information and is intended only for the individual named. If you are not the named
addressee you should not disseminate, distribute or copy this email. If you are not the intended
recipient you are notified that disclosing, copying, distributing or taking any action in reliance on
the contents of this information is strictly prohibited.
From: Uta von Eckartsberg <uvoneck@outlook.com>
Sent: Monday, December 28, 2020 12:30 PM
To: i.housecondo@att.net; Norman Stankewicz <i.housecondo@yahoo.com>;
board@imperialhousepittsburgh.com; Bob Giese <bgiese@rjcmgt.com>; Bill Larrow
<bill@rjcmgt.com>; Robert Bernstein <robert.s.bernstein@gmail.com>; Arthur Goldberg
<artgoldberg@verizon.net>; Deb Knox <deb@knox412.com>
Cc: lizhrenda@comcast.net; shandel.gilbert@verizon.net; sylvholland@aol.com;
stlrfanpgh@aol.com; pj92926@gmail.com; shirleykmeyers@msn.com;
ethelweikers1@gmail.com; @cmu.edu; frisch@duq.edu; bloberant@yahoo.com;
rgrif@cmu.com; nloberant@yahoo.com; stephen.tirone@gmail.com; antis1209@comcast.net; 1
neil.cosgrove@verizon.net; roblschwartz@aol.com; reiko.becker@gmail.com;
dandee26@verizon.com; mjmckenna42@hotmail.com; maxifish1@aol.com; bunkerc@pitt.edu;
william.lindgren@sru.edu; joeldon@aol.com; danehower@gmail.com;
vicky.humphrey23@gmail.com; reneeramo@gmail.com; johnstonann@att.net;
wjjohnston@firstcommand.com; patmiles1@aol.com; nanwm@verizon.net;
jbaccordion@gmail.com; smithkmt@gmail.com; bonnie17961@gmail.com;
amq02@comcast.net; rmolyneauxrmx@gmail.com; sheilaryannp@aol.com;
eiko.becker@gmail.com; ritzec@comcast.net; shirleykmeyers@msn.com; pj92926@gmail.com;
hwerstil@aol.com; lew@andrew.cmu.edu; hellman@pitt.edu; amq02@comcast.net
Subject: Fwd.: Imperial House- Minutes (response to knowingly false, defamatory, baseless
representations on Facebook, email, and verbally for seemingly retaliatory and obstructive
purposes)
Importance: High
I am now resending and recirculating the email below given that I learned today that this BOD
deleted the post below within minutes of my posting it. I believe that such conduct is a violation
of my right to free speech. Further, I also learned tonight that each of you have collaboratively
allowed for the false statements regarding me, my ESA, and my status as member in good
standing to be published on every floor in this building. Furthermore, it seems your group email

328
address does not include all or even most of the resident unit owners in this building. Rob,
how is this conduct consistent with your “communications” policy and espoused commitment to
open and transparent dialogue?
Furthermore, not only is this BOD instructing its’ external property manager (whose salary the
unit owners pay in their assessments) not to process my monthly assessment but also has now
removed my ability to pay online on the external property manager’s website (specifically
removed IH from the RJW website’s list of properties that may pay online (notably out of
abundance of caution I memorialized the website options immediately before and after the email
announcing my intent to pay via this option if you collaboratively refused to process my monthly
assessment. See e.g., attached email, attachments deleted.
You are to cease & desist from illegal and retaliatory conduct designed to falsely paint me as a
“member not in good status” in order to obstruct a complaint to AG Shapiro as described below.
Furthermore, while I do not infer or suggest that this BOD or those under common control or
those controlled by it, are engaging in racketeering conduct I have identified several cases which
do seem to cite certain predicate facts consistent to what I am experiencing in this building.
And to the extent this BOD obstructs payments, willfully violates any law, rule, regulation,
and/or charges usurious and excessive fees, interest for violations of rules and regulations that do
not exist in order to prevent me or anyone else asserting any rights whether under the UCA, the
UPA, or the laws enacted to protect civil and constitutional rights this BOD then these following
cases illustrate why such conduct is problematic. See
e.g., http://www.legalaction.com/enter.htm ; Valley of the Lakes, class action RICO complaint
at Count 227.
“In furtherance of the conspiracy the control group of the association “promulgated its own
"General Rules and Regulations" for the common areas, and MLA asserted that it "reserves the
right to refuse the use of the facility to owners not in good standing, for failure to pay
outstanding maintenance fees, or property owners with outstanding violations of covenants and
restrictions or rules and regulations” and related actions Pennsylvania Attorney
General, http://www.legalaction.com/ag1.htm; and criminal indictment and plea (developer, Jack
Halperin/Phillip Cohen; see also similar conduct described in a more recent HOA Board scandal
(http://www.legalaction.com/listcrim.htm; see also facts (“ The Las Vegas legal community is
currently witnessing the unfolding of a cautionary tale of how a few plaintiffs’ lawyers gained
control over several Homeowner Associations, transforming them into construction defect
plaintiffs, and in the process, pocket millions of dollars. Dozens of individuals have been
indicted. Twenty-four participants have already pled guilty.
The original investigation and prosecution by local law enforcement has now been taken over by
the U.S. Justice Department due to concerns that local officials and politicians were connected to
the scheme. Jeff German, “Federal Prosecutors Under Investigation for Alleged Obstruction of
Justice in HOA Probe”, Las Vegas Review Journal (March 2, 2011). Rumors of judicial and
political involvement in the scheme have continued to circulate but have not been validated.
Adding to the sensation is the mysterious death of two of the attorneys who were allegedly the
masterminds of the scheme. Jennifer Abbey, “Attorneys in Nevada Homeowners Association
Scandal Dead” ABC News (March 28, 2012)”; and more
recently https://www.justice.gov/opa/pr/eleven-defendants-indicted-alleged-roles-scheme-
fraudulently-control-homeowners-associations and

329
https://www.justice.gov/iso/opa/resources/179201311517481711118.pdf and https://vegasinc.las
vegassun.com/business/tourism/2012/jun/03/hoa-scandal-involving-millions-dollars-and-
thousan/ (illegal fees, assessments, kickback and control).
. Quit harassing me. Immediately, process the outstanding payment for December if any
(given that mother almost certainly paid one month in advance). And all requests for the BOD
to simply address with back-up documents that all unit owners are entitled to receive as a matter
of law and fact, remain outstanding. Deleted FB post and follow-up email is below for your
convenience.
Thank you in advance for your kind attention to these matters.
Uta von EckartsbergFrom: Uta von Eckartsberg <uvoneck@outlook.com>
Date: January 11, 2021 at 12:26:00 AM EST
To: Bill Larrow <bill@rjcmgt.com>
Subject: RE: IH Notices and Information - IH internal Office email list (Unit 309) Assistance
Requested (still no auto-debit)

Hello,
I just saw this. Thanks for the response and for the corr. of 12/29/2020. You seem like a good
guy but as of tonight no auto-debit has been processed since Dec. 9. So yes, there is a major
problem. And I cannot pay online because I do not have any requisite information since RJ does
not post IH information on its website in contrast to practically all other associations RJ seems to
represent. I need the Associate account number, lock box number, etc. etc. Obviously, this
HOA will improperly assess all manner of fines and usurious fees and fines, etc. Have you
processed on my account per this email or the correspondence of 12.29.2020? If not, why not?
If you cannot process the authorized debit, then please provide me all information that I need to
initiate a payment from my bank to your Nevada payment processor or to submit a payment
through the RJ website.
Thanks.
Uta
Uta von Eckartsberg, Esq.
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
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