menu bar

Valley of Lakes RICO Class Action against PNCBANK, et al.
ripped edge: exhibits
Valley of Lakes Letterhead


More than one month ago, a mailing was sent out by VOLCA to all Valley 
of Lakes property owners, advertising a "PIG ROAST" which they were to 
hold at Valley of Lakes.

This mailing was unauthorized and illegal !!!

VOLCA did not have permission to hold any function.

VOLCA is an organization of dissidents, whose expressed goal is the 
demise of C.B.G. and the takeover of operations at the Valley.  Their 
"Board of Directors", headed by Randy Galgon and Ray Dongelewicz, 
utilize fees and donations of unsuspecting and concerned property 
owners, to fund activities that threaten the developing way of life 
created by C.B.G. and the investments of every single property owner.

VOLCA intends to polarize the community by forcing property owners who 
are not members of VOLCA to pay twice the fee charged VOLCA members.

This is also unauthorized and illegal !!!

VOLCA intends to use this unauthorized function as a fund raising event, 
soliciting membership fees and contributions to further its destructive 

This is another illegal activity !!!

VOLCA ignored a letter sent to them by MLA Management, advising them of 
a denial of their request to hold a function and urging them to 
immediately file a new application with a property owner as the sponsor.  
Simultaneously, they were to send out a "corrective mailing" to all 
property owners they misinformed.

VOLCA then sent out an EAGLE EYE BULLETIN to all property owners which 
contained harmful and mis-leading information relative to C.B.G.'s 
financing status and re-advertised the PIG ROAST.  This mailer also 
renewed its solicitation of funds.

This mailing was another illegal act.

The "Board Members" of VOLCA, as individuals and property owners, have 
violated many sections of our Covenants and Restrictions and many of our 
Rules and Regulations.  The members of VOLCA who are not on VOLCA's


board, have very little knowledge of the actual activities of the "Board 
of Directors".  Isn't it strange that seven (7) different members on a 
nine member board have resigned in protest, one by one?  One board 
member, who was ousted by the Galgon/Dongelewicz clique was 
overwhelmingly voted back on the board at the May 15, 1993 VOLCA 
meeting.  This event took place when the membership who attended, heard 
on a "first hand basis", just what VOLCA's "clique" was doing, from the 
mouths of resigning board members.  That member became even more 
disenchanted at VOLCA's actions since May and has once again resigned in 

Following, are a few examples of misinformation distributed by VOLCA's 
"Board of Directors".

	a - MLA Management is not the bank's appointed property manager, 
as stated by VOLCA.  MLA is under contract with C.B.G. Limited and the 
bank has absolutely no control whatsoever over this relationship.

	b - Every penny of the utility fees collected by C.B.G. went into 
the MLA managed utility accounts. (just check your cancelled checks to 
verify this statement) VOLCA cast suspicion on C.B.G. motives in 
handling this past quarterly billing.  C.B.G. sent out an urgent message 
mailing to all property owners who were delinquent, offering its 
assistance upon request of any property owner.  C.B.G. intervened on 
those delinquencies wherein Judgements were obtained and Sheriff Sale 
proceedings were being initiated.  We were successful in assisting more 
than 50 property owners in saving their properties, avoiding expensive 
legal fees, deducting penalties and preventing tarnishment of their 
credit records.

	c - VOLCA's "Chapter 11 Update" mailed to all property owners 
contains harmful and misleading information relative to C.B.G.'s 
progress towards re-financing.  This has caused much anxiety among 
property owners, creditors and even those persons who are assisting 
C.B.G. in its re-financing efforts. (please read the "Status Report" 
recently mailed to all property owners) See copy of "Press Release" 
attached.  One property owner, receiving this information, was ready to 
"distress sale" their property at a "severe loss".

In this same mailing VOLCA assumes foreclosure and then proceeds to 
state what "VOLCA" will do after foreclosure, in cooperation with First 
Eastern Bank.  Let me explain the idiocy of these statements.

1.  VOLCA membership is comprised of less than one-tenth of the property 
owners, (if in fact they now remain members)and cannot speak for the 

2.  At the September 3, 1991, Sheriff's Sale, (if that were to take 
place) the entirety of the property will be sold to one or more buyers.  
First Eastern Bank has no obligation to any property owner now and will 
not have after the sale.  Property owners will now have to contend with 
the intentions of the new owners who are buying real estate, 
not inheriting obligations.


Unless a "total concept visionary firm", similar in design and intent to
C.B.G. Limited, buys the entire property, every property owner must 

			   - Why ??? -

a. Who will pay for the multi-million dollar lake and dam ???  
Non-lakefront property owners would naturally expect that 
only lakefront property owners should pay. (this would mean an 
assessment of more than $60,000 per lakefront lot owner)

b. Who will pay for the roads, water and sewer to service Section "EA" 
and the long line back to the sewage treatment plant?  Property owners 
not affected would expect that only "EA" property owners should pay. 
(This would mean an assessment of approximately $5,000 per lot owner) 
Not one penny has ever been assessed any property owner for construction of 
amenities or roads, water and sewer infrastructure, all completed by 

c. Just what do you think will happen to your Maintenance Fees?  Ask 
the owners in communities where a similar situation has happened and 
then get their reaction to the $360.00 per year, Valley of Lakes property 
owners pay.

d. Knowing how the VOLCA "Board of Directors" has operated in the past, 
can you imagine the size and type of assessments that could be involved 
under the "mandatory membership" espoused by Randy Galgon, etal in the 
July 19,1993 Eagle Eye Bulletin?

Please read carefully the Covenants and Restrictions and Rules and 
Regulations, pertaining to all property owners of lots in the Valley of 
Lakes.  One does not have to be a lawyer to see how many sections have 
been violated by VOLCA's "Board of Directors" and several cohorts.  Pay 
particular attention to Section IV Ownership Covenants - Article 15 on 
Page -11-.  This article gives any and every property owner the right to 
sue and/or prosecute any property owner who violates or even attempts 
to violate any of our covenants and restrictions and to recover damages for 
such violations.

Any property owner wishing assistance in these matters may contact 
C.B.G. Limited.

C.B.G. Limited solicits the support of every property owner in helping 
to protect and preserve our existence as a community and to move forward 
to completion of the overall masterplan.  A condemnation of VOLCA's 
behavior and withdrawal of support for this group, as it is presently 
constituted, would go a long way.

A "civic organization" should benefit the community, not help to destroy 

Valley of Lakes RICO Class Action against PNCBANK, et al.

Home | Court Decisions | News Articles | RICO Complaint | Exhibits