June 17, 1992 Tom Marcheski, Treasurer, VOLCA (CW-72) Lake Valley Drive P.O. Box 275 Oneida PA 28242 Dear Mr. Marcheski: It has been brought to my attention that Mr. Randy Galgon has made a number serious and untrue statements, as they apply to myself, the C.B.G. Limited Partnership and our operations in the conduct of our business. These statements, which I believe to be libelous, were made willfully, knowingly and with malice. In addition, I believe that he has been guilty of tortious interference in the Partnership's business and that his statements are harmful to myself, my family, C.B.G. Limited, our successful development of our property and assets and to the property owners who live here and have made substantial investments. Finally, I have been made aware that he is and has been guilty of trespass. This letter will serve to inform you that I am meeting with legal counsel to discuss the preparation of a suit seeking both compensatory and punitive damages, as well as a cease and desist order. Mr. Galgon has stated that he is acting on behalf of the "Property Owners Association" and on at least one occasion, was accompanied by the President of VOLCA. This letter is being directed to all board members of VOLCA seeking a written response as to whether or not Mr. Galgon was authorized by VOLCA to make such statements in their behalf. Absent the receipt of signed individual responses from each board member, stating that Mr. Galson acted without board approval, our legal action will be directed against each individual board member of VOLCA. I have no intention of suing innocent property owners. Yours truly /s/ Frank M. Cedrone General Partner FMC/va MR. GALGON HAS STATED THE FOLLOWING, CLAIMING TO REPRESENT VOLCA ____________________________________ 1. That I lied in my presentation at the first meeting of creditors. 2. That I did not have a bonafide lender commitment for $3.5 million. 3. That I have mentioned commitments in the past that were bogus or false. 4. That with the number of lots sold, there was a huge excess of funds that C.B.G. pocketed. 5. That the Federal Trustee took everything I said with tongue in cheek. 6. That I lied when I said I never received pay from any other company affiliated with C.B.G. and in fact, received a pay from every one of them. 7. That my income was guaranteed and I haven't missed a check . There are other alleged statements that are in the process of being verified.
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