Valley of Lakes Racketeering Class Action against PNC Bank, N.A., et al.

(B) LAND DEVELOPMENT SCHEME

64. The land development scheme of defendants was patterned on High Vista Inc.'s schemes, artifices, courses of conduct, and devices; namely, High Vista Inc.'s fraudulent representations, pretenses and promises to complete a proposed lake known as "Lake Algonquin", to complete a nine hole and/or eighteen hole golf course, to complete a sewer collection system for the entire subdivision, to complete a water system for the entire subdivision, to maintain the recreational facilities and the roads, etc. See Exhibit 3.

65. A copy of the Property Report effective April 8, 1987, of C.B.G. Ltd. for the Valley of Lakes Development filed with the Office of Interstate Land Sales Registration, U.S. Department of Housing and Urban Development is annexed hereto and made a part of this complaint, and marked Exhibit 14-1 to 14-31. The term "Property Reports" appearing infra refers to the property reports filed with HUD and its state counterparts.

66. A copy of a New York State Public Offering Statement effective March 15, 1988, of C.B.G. Ltd. for the Valley of Lakes Development filed with State of New York, Department of State, is annexed hereto and made a part of this complaint, and marked Exhibit 15-1 to 15-53.

67. A copy of CBG Ltd.'s Statement of Record filed with the New Jersey Real Estate Commission on or about December, 1986, is annexed hereto and made a part of this complaint, and marked Exhibit 16-1 to 16-11.

68. Commencing on or about September 30, 1986, and continuing through the present, the Defendants FRANK CEDRONE, CBG, FIRST EASTERN BANK, ONEIDA WATER CO., VALLEY UTILITIES CO. INC., and other defendants, did knowingly and willfully devise a scheme and artifice to defraud lot owners and prospective lot owners in the defunct subdivision of High Vista Inc.'s "Valley of Lakes", through numerous false and fraudulent pretenses, representations, promises, acts, and practices, relating to C.B.G.'s land development plan for the subdivision, in violation of 18 U.S.C. 1341, 18 U.S.C. 1343, and fraud in the sale of securities by violating Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5, including but not limited to the following:

a. As of the present day, the paved ROADS in the areas designated in the "subdivision plan" as "SECTION A," "SECTION D," "SECTION J," "SECTION JA," "SECTION E," "SECTION EA," "SECTION H," and "SECTION I" have not been completed as:

(1) expressly represented in the "Property Reports" which defendants caused to be mail throughout the U.S. as part of their business course of conduct [E.g., Exhibits 14 and 15];

(2) expressly promised in numerous sales contracts with purchasers which defendants caused to be mailed throughout the U.S. as part of their business course of conduct, described infra;

(3) represented or implied in numerous print, radio, television, direct mail, billboard advertisements, in home video presentations which CBG undertook as part of its course of conduct, described infra; and

(4) represented in numerous lulling letters which the defendants caused to be mailed throughout the U.S. after CBG defaulted in completing the promised improvements, and other lulling letters mailed throughout the U.S. after CBG declared bankruptcy, described infra;

b. As of the present day, the WATER SYSTEM for property lots located in the areas designated in the "subdivision plan" as "SECTION E," "SECTION EA," have not been completed as:

(1) expressly represented in the "Property Reports" which defendants caused to be mail throughout the U.S. as part of their business course of conduct [E.g., Exhibits 14 and 15];

(2) expressly promised in numerous sales contracts with purchasers which defendants caused to be mailed throughout the U.S. as part of their business course of conduct, described infra;

(3) represented or implied in numerous print, radio, television, direct mail, billboard advertisements, in home video presentations which CBG undertook as part of its course of conduct, described infra; and

(4) represented in numerous lulling letters which the defendants caused to be mailed throughout the U.S. after CBG defaulted in completing the promised improvements, and other lulling letters mailed throughout the U.S. after CBG declared bankruptcy, described infra;

c. As of the present day, the SEWER COLLECTION SYSTEM for property lots located in the areas designated in the "subdivision plan" as "SECTION E," "SECTION EA," have not been completed as:

(1) expressly represented in the "Property Reports" which defendants caused to be mail throughout the U.S. as part of their business course of conduct [E.g., Exhibits 14 and 15];

(2) expressly promised in numerous sales contracts with purchasers which defendants caused to be mailed throughout the U.S. as part of their business course of conduct, described infra;

(3) represented or implied in numerous print, radio, television, direct mail, billboard advertisements, in home video presentations which CBG undertook as part of its course of conduct, described infra; and

(4) represented in numerous lulling letters which the defendants caused to be mailed throughout the U.S. after CBG defaulted in completing the promised improvements, and other lulling letters mailed throughout the U.S. after CBG declared bankruptcy, described infra;

d. As of the present day, the nine hole and/or eighteen hole golf course, represented to be "designed and managed by Arnold Palmer" has never been completed as:

(1) expressly represented in the "Property Reports" which defendants caused to be mail throughout the U.S. as part of their business course of conduct [E.g., Exhibits 14, and 15];

(2) expressly promised in numerous sales contracts with purchasers which defendants caused to be mailed throughout the U.S. as part of their business course of conduct, described infra;

(3) represented or implied in numerous print, radio, television, direct mail, billboard advertisements, in home video presentations which CBG undertook as part of its course of conduct, described infra; and

(4) represented in numerous lulling letters which the defendants caused to be mailed throughout the U.S. after CBG defaulted in completing the promised improvements, and other lulling letters mailed throughout the U.S. after CBG declared bankruptcy, described infra;

e. As of the present day, the proposed lake, referred to as "Lake Algonquin" has never been completed as:

(1) expressly represented in the "Property Reports" which defendants caused to be mail throughout the U.S. as part of their business course of conduct [E.g., Exhibits 14 and 15;

(2) expressly promised in numerous sales contracts with purchasers which defendants caused to be mailed throughout the U.S. as part of their business course of conduct, described infra;

(3) represented or implied in numerous print, radio, television, direct mail, billboard advertisements, in home video presentations which CBG undertook as part of its course of conduct, described infra; and

(4) represented in numerous lulling letters which the defendants caused to be mailed throughout the U.S. after CBG defaulted in completing the promised improvements, and other lulling letters mailed throughout the U.S. after CBG declared bankruptcy, described infra;

f. The promised "Support businesses--restaurants, ski slopes and an equestrian center--have closed for lack of CBG financial support."

69. As part of the defendant's land development scheme, First Eastern Bank, N.A., made development loans to C.B.G. Ltd., totalling more than $14 million (See Exhibit 113-11 to 113-12), which made it possible for C.B.G. Ltd. to carry out its schemes. At the time it made the loans, First Eastern Bank knew that: (a) High Vista Inc.'s "Valley of Lakes" development had been defunct and abandoned for approximately seven years; (b) C.B.G. Ltd. had not acquired the legal rights from High Vista Inc. to act as the successor of High Vista Inc. pursuant to the covenants and restrictions recorded by High Vista Inc.; (c) C.B.G. Ltd. had no legal right to collect maintenance fees in the name of "Valley of Lakes"; (d) C.B.G. Ltd. was fraudulently representing itself as the owner of the "Valley of Lakes" when in truth and fact it was only another "purchaser" pursuant to the covenants and restrictions recorded by High Vista Inc.; (e) that C.B.G. Ltd. was not completing the improvements as promised in its "Property Reports."

70. First Eastern Bank did wilfully and knowingly make the development loans, and place numerous mailings in the U.S. mail to complete and service these loans, in order to profit from the interest on the loans, and to profit from the inflated loans that it made to the purchasers of lots, which loans by First Eastern Bank were promoted by the sales force of C.B.G. Ltd., and purchased from C.B.G. Ltd.

71. The sale and purchase of lots in the subdivision by defendants was the sale and purchase of "securities," within the meaning of the Federal Securities Laws, to wit:

a. the developer, C.B.G., LTD., was pledged to provide extraordinary managerial efforts to make the subdivision "the Premier Resort in NorthEast" by the completion of numerous improvements, among others, an "Arnold Palmer designed and managed, professional caliber, golf course," a proposed lake known as Lake Algonquin, completion of a water system, sewer system and road system for the entire subdivision, operation of ski slopes with lodge/motel, completion of a commercial/office shopping strip, etc. ;

b. purchasers were offered both real estate and a collateral expectation of profit;

c. The success or failure of the venture did not depend on the skill or ingenuity of the individual purchasers;

d. The purchasers had more than a mere hope that their lots would appreciate through time as a result of a general increase in values concurrent with the development, and they expected to realize a "profit" through the efforts of the developer in the anticipated completion of the various promised improvements;

e. Only through the "enterprise" run by the developer could the purchasers of an unimproved lot hope to realize an increase on their initial investment, or hope that the property would even maintain its value.

f. Without the substantial improvements pledged by the developers the lots would not have a value consistent with the price which the purchasers paid, which price included as its basis the completion of the lake, golf course, sewer and water system, roads, and other amenities;

g. The purchase money from the lot sales were to be utilized to build the promised improvements;

h. The developer emphasized the investment potential of the real estate in their promotional campaign;

i. The developer encouraged the reliance upon his managerial efforts for the management and appreciation of the investment through his mailings discussed infra;

j. The developer encouraged investment purchases by promising lots would increase in value due to vendors' activities in developing and providing amenities

k. The developer led purchasers to believe trust would be established to construct and operate facilities for their common benefit.

l. The developer encouraged trading of lots, like securities, by granting a right to exchange a purchased lot during a certain time period.

72. Defendants used and employed manipulative and deceptive devices and contrivances in connection with the purchase and sale of securities, and perpetrated numerous predicate acts of fraud in the sale of securities by violating Section 10(b) of the Securities Exchange Act of 1934 and SEC Rule 10b-5. Such use and employment of manipulative and deceptive devices and contrivances involved the means and instrumentalities of interstate commerce and of the mails. Such manipulative and deceptive devices and contrivances, schemes, false statements, illegal acts and practices included:

a. Employment of a device, scheme and artifice to defraud;

b. The making of untrue statements of material facts and omitting to state material facts necessary in order to make the statements made in light of the circumstances under which they were made, no misleading; and

c. The engagement of acts, practices, in a course of business which operated as a fraud and deceit upon Plaintiffs.

73. Beginning on or about September 30, 1986, C.B.G. LTD., through the financing provided by First Eastern Bank, N.A., undertook a massive national media campaign touting the "Valley of Lakes" as the "The Premier Planned Residential/Resort community in the Northeast" and/or "The Premier Resort in Pennsylvania". See Exhibit 94-11, a copy of a document prepared by C.B.G. Ltd., describing its marketing program. In said document, C.B.G., Ltd., admits the following:

a. Regarding the breadth of the media campaign: "With a continual high level advertising campaign that has been conducted in newspapers and magazines, radio and television, by direct mail, billboard and special promotions, the Valley of Lakes message has been carried throughout seven states and the District of Columbia. However, news of this fine development has spread far beyond its normal market area. Property owners now include buyers from Europe, Asia and the Far East."

b. C.B.G. Ltd. defined its PRIMARY MARKET area as consisting of Pennsylvania, New York, and New Jersey and, and its SECONDARY MARKET area as consisting of Connecticut, Delaware, Maryland, D.C., and Virginia;

c. Regarding the results of its media campaign, C.B.G. Ltd., stated:

"Valley of Lakes and Eagle Rock Resort is now regarded as "The Premier Planned Residential/Resort community in the Northeast. Tours and inspections by reporters from all major media have resulted in glowing reports praising the creative planning, quality development and commitment to excellence shown by the developers, C.B.G. Limited.

Editorials in the New York Times, Real Estate Review, Hazleton Standard Speaker, Wilkes-Barre Times Leader and other local and major market news media have all highly praised the community.

The property has been featured in such leading publications as Time, Newsweek, U.S. News and World Report, Sports Illustrated, Golf Magazine and Philadelphia Magazine."

d. C.B.G. described the organization of its MARKETING TEAMS as follows:

"Direct employed sales teams headed by regional Managers in Pennsylvania, New York, and New Jersey, supplemented by independent and multiple broker networks who have signed referral agreements with CBG Limited, i.e., Weichert Realtors, E.R.A., Century 21, Caldwell-Banker, Prudential, etc., Independent and broker networks in all secondary markets."

e. Regarding, In-Home Presentations as:

"Appointments are set for in-home video presentations for prospects responding to media advertising. These presentations are conducted by our off-site, direct employed sales team members, as well as participating brokers. Offers to tour the property are made to qualifying prospects who are then sold by on-site sales team members."

f. Regarding "Special Promotions": "Special promotions are prosect generators and are conducted by on-site and off-site sales teams."

g. Regarding "Off site Promotions": include industry trade shows, home shows, boat shows shopping mall promotions, conventions, builder's expositions, etc. Off-site promotions are supported by media advertising and personality appearances.

h. Regarding "On-site Promotions", "On-site Promotions" include special events for property owners and their guests such as barbecues, games and contests, fishing tournaments, carriage rides, trial and hay rides, swim and tennis functions, etc. Other special events include the use of personalities.

i. Regarding the type of media: "All major media advertising is utilized."

"Newspaper Advertising. This medium is utilized in those markets, wherein we can respond with field personnel, either direct employees or broker personnel, for in-home presentations or invitations to "Preview Film Showings".

Radio Advertising. This is conducted in all primary markets, with overlap into secondary markets achieved by proper selection of strong signal stations. inquiring prospects are offered Valley "tours" and/or overnight stays. In the alternative, they are scheduled for an in-home presentation or attendance at a "Preview Film Showing" in their area.

Television Advertising. This is utilized on both network and cable TV channels and is limited to the primary market. Respondents are handled similar to radio inquiries.

Magazine Advertising is of two types, i.e Image and Response.

Image Advertising i.e. Time, Newsweek, U.S. News and World Report, and Sports Illustrated are selected for specific markets in our primary market area for subscription purchasers only. The threefold benefits are: low cost for major image, maximum distribution to high income subscribers as opposed to occasional readers (newsstands), and ability to state, "as advertised in", etc. in other forms of advertising, i.e. direct mail, posters, pamphlets, etc.

Response Advertising i.e. Golf magazine, is directed to special interest groups for particular product lead generation."

j. CBG used DIRECT MAIL, according to its own admission, as follows:

"All direct mail programs are response oriented and are used to promote or support special promotions. Specifically targeted to special interest groups, in the upper-income bracket and timed to reach them in a specific time period coupled with a maximum urgency factor, direct mail programs offer special products, special prices, absolute deadlines, etc."

k. According to C.B.G., "Billboards are utilized strictly for image and directional purposes only and are strategically located for maximum exposure." See Exhibits 207 to 209.

l. CBG used sophisticated PUBLIC RELATIONS programs, according to its own admission for the following purpose:

"Public relations programs are designed to enhance the community's and developer's image and support ongoing sales and marketing. These functions are promoted by our in-house agency, as well as our commercial agencies. They maintain coordination between advertising and special programs for our separate profit centers, i.e. restaurant, ski area, and motel, and our real estate products, i.e. lots and housing products, for maximum effect."

74. In the HUD reports, C.B.G. admitted that: "APPROXIMATELY 35% OF THE SALES PRICE OF YOUR LOT REPRESENTS OUR MARKETING, ADVERTISING AND SALES COMMISSION COSTS, WHICH YOU MAY NOT BE ABLE TO RECOVER IN THE EVENT YOU TRY TO SELL YOUR LOT." See Exhibit 14-19.

75. One, Neil Rodino, was hired on or about 11/1/89 as full time MEDIA DIRECTOR.

76. C.B.G. operated a phone room to solicit purchasers of property in the Valley of Lakes from Bellmawr, New Jersey. In Exhibit 94-12 , C.B.G. described its promotional efforts of Preview Film Showings as follows:

"In all market areas, held in local hotels, restaurant banquet rooms, etc., prospects selected by wealth category and proximity to film showing are solicited by phone room located in Bellmawr, N.J. Additional prospects are solicited by local area brokers to attend. Media blitz precedes film previews in each area by one week to enhance image and give instant recall to prospective attendees.

Addendees are solicited to tour Valley of Lakes based on qualifying financial data, exposed need and created desire. Prospects who do accept tour offer are sold by on-site sales team members."

77. A copy of a newspaper article titled "Development goes on at Valley of Lakes," by Jim Dino, published in the Hazleton Standard Speaker is annexed hereto and made a part of this complaint, and marked Exhibit 17.

78. A copy of an article titled "From the Desk of ... FRANK M. CEDRONE," by Frank M. Cedrone, published in CBG Ltd.'s newsletter, "Valley Views," in the July- August, 1987, edition is annexed hereto and made a part of this complaint, and marked Exhibit 18.

79. A copy of a newspaper article titled "New development at The Lakes," published on or about October 14, 1989, in the Evening Herald, Shenandoah, Pennsylvania is annexed hereto and made a part of this complaint, and marked Exhibit 20.

80. A copy of an advertisement for "Valley of Lakes" soliciting responses to "Valley of Lakes P.O. Box 2049 Hazleton, PA 18201" published in the Delaware County Daily Times on or November 9, 1988 is annexed hereto and made a part of this complaint, and marked Exhibit 19.

81. A copy of four pages of the CBG Ltd.'s Newsletter, "Valley Views," Spring, 1988 edition is annexed hereto and made a part of this complaint, and marked Exhibit 21-1 to 21-4.

82. A copy of CBG Ltd.'s Newsletter, "Valley Views," Winter 1989-1990 edition is annexed hereto and made a part of this complaint, and marked Exhibit 22-1 to 22- 12.

83. A copy of CBG Ltd.'s Newsletter, "Valley Views," Spring, 1990 edition is annexed hereto and made a part of this complaint, and marked Exhibit 23-1 to 23-7.

84. A copy of a seventeen page color brochure, advertising the "Valley of Lakes and Eagle Rock Resorts," distributed by CBG Ltd. in its course of business is annexed hereto and made a part of this complaint, and marked Exhibit 24-1 to 24-17.

85. A copy of a sixteen page color brochure, advertising the "Valley of Lakes and Eagle Rock Resorts," distributed by CBG Ltd. in its course of business is annexed hereto and made a part of this complaint, and marked Exhibit 25-1 to 25-16.

86. A copy of a forty page booklet, advertising the "Valley of Lakes and Eagle Rock Resorts," and including independent advertisements, distributed by CBG Ltd. in its course of business is annexed hereto and made a part of this complaint, and marked Exhibit 26-1 to 26-40.

87. A copy of a twenty-five page document titled "Where we were, Where we are, Where we're going," prepared by CBG Ltd., Frank M. Cedrone, Managing General Partner, and distributed to all owners of property in the "Valley of Lakes" subdivision in its course of business, circa 1989, is annexed hereto and made a part of this complaint, and marked Exhibit 27-1 to 27-26.

88. A copy of a letter, dated March 14, 1990, from Wayne F. Guidotti, Executive Office, P.O. Box 2039, Hazleton, PA 18201, on "Valley of Lakes and Eagle Rock Resort" letterhead, addressed to Mr. and Mrs. John Knox, 133 School Road, Wilmington, DE 19803, is annexed hereto and made a part of this complaint, and marked Exhibit 28.

89. A copy of a letter, dated March 26, 1990, from Wayne F. Guidotti, Executive Office, P.O. Box 2039, Hazleton, PA 18201, on "Valley of Lakes and Eagle Rock Resort" letterhead, addressed to John and Betsy Knox, 133 School Road, Wilmington, DE 19803, is annexed hereto and made a part of this complaint, and marked Exhibit 29.

90. A copy of an Addendum to the Sales Contract for Lot EA-275, dated February 28, 1990, signed by Frank M. Cedrone, on behalf of CBG LTD., seller, and John B. Knox and Betsy C. Knox, purchasers is annexed hereto and made a part of this complaint, and marked Exhibit 30.

91. A copy of a letter, dated November 28, 1990, from Wayne F. Guidotti, Executive Office, P.O. Box 2039, Hazleton, PA 18201, on "Valley of Lakes and Eagle Rock Resort" letterhead, addressed to John and Betsy Knox, 133 School Road, Wilmington, DE 19803, with an enclosure, a note signed "Wayne," is annexed hereto and made a part of this complaint, and marked Exhibit 31-1 to 31-2.

92. A copy of an Addendum to the Sales Contract for Lot ER-236, dated March 6, 1990, signed by Frank M. Cedrone, on behalf of CBG LTD., seller, and John B. Knox and Betsy C. Knox, purchasers is annexed hereto and made a part of this complaint, and marked Exhibit 32.

93. A copy of a Deed between CBG Ltd., Grantor and John B. Knox and Betsy C. Knox, His Wife, Grantees, for Lot No. 275 on Plat EA, of "Valley of Lakes Development," recorded in the Office for the Recording of Deeds, County of Schuylkill, Pennsylvania, in Deed Book 1440, Page 761 to Page 764, on or about April 17, 1990, is annexed hereto and made a part of this complaint, and marked Exhibit 33-1 to 33-4.

94. A copy of a letter, dated September 27, 1990, from Bette C. Politarhos, Director of Marketing, Executive Office, P.O. Box 2039, Hazleton, PA 18201, on "Valley of Lakes and Eagle Rock Resort" letterhead, addressed to "Valley of Lakes Property Owners" is annexed hereto and made a part of this complaint, and marked Exhibit 34.

95. A copy of a group mailing, from CBG Ltd., distributed on or about December 1990, to all owners of property in the "Valley of Lakes" subdivision in its course of business is annexed hereto and made a part of this complaint, and marked Exhibit 35.

96. A copy of a letter, dated July 10, 1991, from Wayne F. Guidotti, Executive Office, P.O. Box 2039, Hazleton, PA 18201, on "Valley of Lakes and Eagle Rock Resort" letterhead, addressed to Mr. and Mrs. Jack Knox, 133 School Road, Wilmington, DE 19803, is annexed hereto and made a part of this complaint, and marked Exhibit 36.

97. A copy of a Deed between CBG Ltd., Grantor and John B. Knox and Betsy C. Knox, His Wife, Grantees, for Lot No. 10 on Plat ER, of "Valley of Lakes Development," recorded in the Office for the Recording of Deeds, County of Schuylkill, Pennsylvania, in Deed Book 1468, Page 612 to Page 616, on or about August 26, 1991, is annexed hereto and made a part of this complaint, and marked Exhibit 37-1 to 37-4.

98. A copy of a letter, dated April 21, 1992, from Frank M. Cedrone, General Partner, P.O. Box 2039, Hazleton, PA 18201, on "Eagle Rock Resort" letterhead, addressed to Mr. and Mrs. Jack Knox, 133 School Road, Wilmington, DE 19803, is annexed hereto and made a part of this complaint, and marked Exhibit 38.

99. A copy of a group mailing distributed circa 1991, from Frank M. Cedrone, General Partner, Executive Office, P.O. Box 2039, Hazleton, PA 18201, on "Valley of Lakes and Eagle Rock Resort" letterhead, to all Property Owners in the "Valley of Lakes" subdivision in its course of business is annexed hereto and made a part of this complaint, and marked Exhibit 39.

100. A copy of a Truth in Lending Disclosure Statement from CBG Ltd., d/b/a "Valley of Lakes," as Creditor, to John B. Knox and Betsy C. Know of 133 School Road, Wilmington, DE 19803, dated February 8, 1990 is annexed hereto and made a part of this complaint, and marked Exhibit 40.

101. A copy of a letter, dated May 20, 1992, from Frank M. Cedrone, General Partner, P.O. Box 2039, Hazleton, PA 18201, on "Eagle Rock Resort" letterhead, addressed to Mr. and Mrs. Jack Knox, Eight Hill Spring Road, Chadds Ford, PA 19317, is annexed hereto and made a part of this complaint, and marked Exhibit 41.

102. A copy of a Sales Contract dated October 8, 1987, between CBG Ltd., Seller, and Lois A. Burns, Buyer, of 3 Meath Avenue, Huntington, N.Y. 11746, for Lot J-84, is annexed hereto and made a part of this complaint, and marked Exhibit 42-1 to 42-2.

103. A copy of a Deed between CBG Ltd., Grantor and Lois A. Burns, of 3 Meath Avenue, Huntington, N.Y. 11746, Grantee, for Lot No. 84 on Plat J, of "Valley of Lakes Development," recorded in the Office for the Recording of Deeds, County of Luzerne, Pennsylvania, in Deed Book 2251, Page 916 to Page 919, on or about November 12, 1987, is annexed hereto and made a part of this complaint, and marked Exhibit 43-1 to 43-4.

104. A copy of a Truth in Lending Disclosure Statement from CBG Ltd., d/b/a "Valley of Lakes," as Creditor, to Lois A. Burns, Debtor, of 3 Meath Avenue, Huntington, N.Y. 11746, dated October 8, 1987, is annexed hereto and made a part of this complaint, and marked Exhibit 44.

105. A copy of a Mortgage Payment Voucher Number 52, from C & E Credit, PO Box 17, Emerson, NJ 07630, Account Number 71-20 of Ms. Lois A. Burns is annexed hereto and made a part of this complaint, and marked Exhibit 45.

106. A copy of Recreational Lot Appraisal, dated December 17, 1992 from Louis S. Licurgo, Real Estate Sales - Appraisals, 650 McKinley St., Hazleton, PA 18201, to Ms. Lois A. Burns, 5 East Cranberry Avenue, West Hazleton, PA 18201, regarding Lot J-84 is annexed hereto and made a part of this complaint, and marked Exhibit 46-1 to 46-3.

107. A copy of a letter, dated September 8, 1992, from Francis J. Hoegen, Law Offices of Hoegen & Marsh, 25 North River Street, Wilkes-Barre, Pennsylvania 18701, addressed to Lois Burns, 7 E. Cranberry Avenue, West Hazleton, PA 18201, is annexed hereto and made a part of this complaint, and marked Exhibit 47.

108. A copy of a Deed between Raymond A. Pierce, of 80-86 Jericho Turnpike, Syosset, N.Y. 11791, Grantor and Francis X. Burns, of P.O. Box 991, Commack, N.Y. 11725, Grantee, for Lot No. 29 on Plat "A", of the "Valley of Lakes Development," recorded in the Office for the Recording of Deeds, County of Luzerne, Pennsylvania, in Deed Book 2336, Page 1046 to Page 1049, on or about January 2, 1989, is annexed hereto and made a part of this complaint, and marked Exhibit 48-1 to 48-4.

109. A copy of a Deed between C.B.G. Limited, Grantor and Ger D. J. Smit and Sia J. Smit, His Wife, Grantees, of 125 Edison Furlong Road, Doylestown, Pennsylvania 18974, for Lot No. 92 on Plat EA, of the "Valley of Lakes Development," recorded in the Office for the Recording of Deeds, County of Schuylkill, Pennsylvania, in Deed Book 1429, Page 0077 to Page 0080, on or about June 10, 1989, is annexed hereto and made a part of this complaint, and marked Exhibit 49-1 to 49-4.

110. A copy of a Sales Contract dated July 10, 1988, between CBG Ltd., Seller, and Laura Burns, Buyer, of 64 Wheatfield Lane, Commack, N.Y. 11725, for Lot A-22, is annexed hereto and made a part of this complaint, and marked Exhibit 50-1 to 50-2.

111. A copy of a Deed between CBG Ltd., Grantor and Laura Burns, of 64 Wheatfield Lane, Commack, N.Y. 11725, Grantee, for Lot No. A-22, of "Valley of Lakes Development," recorded in the Office for the Recording of Deeds, County of Schuylkill, Pennsylvania, in Deed Book 1417, Page 699 to Page 702, on or about October 12, 1988, is annexed hereto and made a part of this complaint, and marked Exhibit 51-1 to 51-4.

112. A copy of HUD Settlement Statement, for Laura Burns, Borrower, of 64 Wheatfield Lane, Commack, N.Y. 11725, and C.B.G. Limited, Seller, P.O. Box 2039, Hazleton, PA 18201, prepared by Wayne A. Tomaino, Settlement Agent, dated October 12, 1988, is annexed hereto and made a part of this complaint, and marked Exhibit 52-1 to 52-3.

113. A copy of a Deed between CBG Ltd., Grantor and Laura Burns, of 64 Wheatfield Lane, Commack, N.Y. 11725, Grantee, for Lot No. 73, on Plat A, of "Valley of Lakes Development," recorded in the Office for the Recording of Deeds, County of Schuylkill, Pennsylvania, in Deed Book 1400, Page 134 to Page 137, on or about December 12, 1987, is annexed hereto and made a part of this complaint, and marked Exhibit 53-1 to 53-4.

114. A copy of a Truth in Lending Disclosure Statement from CBG Ltd., d/b/a "Valley of Lakes," as Creditor, to Laura Burns, of 64 Wheatfield Lane, Commack, N.Y. 11725, dated July 10, 1988, is annexed hereto and made a part of this complaint, and marked Exhibit 54.

115. A copy of a Mortgage Payment Voucher Number 57, from C & E Credit, PO Box 17, Emerson, NJ 07630, Account Number 71-16 of Ms. Laura Burns is annexed hereto and made a part of this complaint, and marked Exhibit 55.

116. A copy of a letter, dated September 3, 1992, from Martin K. O'Dea, C & E Collection Services, 16 Chestnut Street, P.O. Box 299, Emerson, NJ 07630, addressed to Laura Burns, 5 East Cranberry Lane, West Hazleton, PA 18201 is annexed hereto and made a part of this complaint, and marked Exhibit 56.

117. A copy of a Deed between Charles Bud Crawford and Carol Crawford, His Wife, both of St. Johns Road, St. Johns, Luzerne County, Pennsylvania 18247, Grantors and Senta M. Sheridan, of 50 Tremont Avenue, Patchogue, New York 11772, Grantee, for Lot No. CW-81, of "Valley of Lakes Development," recorded in the Office for the Recording of Deeds, County of Luzerne, Pennsylvania, in Deed Book 2301, Page 264 to Page 265, on or about February 28, 1989, is annexed hereto and made a part of this complaint, and marked Exhibit 57-1 to 57-2.

118. A copy of a letter, dated February 2, 1989, from Assistant Vice President and Regional Mortgage Loan Coordinator, First Eastern Bank, N.A., addressed to Senta M. Sheridan is annexed hereto and made a part of this complaint, and marked Exhibit 58-1 to 58-2.

119. A copy of a Contract dated October 19, 1988, between Bud Crawford General Contractor, of P.O. Box 39, Saint Johns, Pennsylvania, 18247, and Senta Sheridan, of 50 Tremont Avenue, Patchogue, New York, 11772, is annexed hereto and made a part of this complaint, and marked Exhibit 59-1 to 59-8.

------------------

BACK TO MAIN COMPLAINT

Home | Court Decisions | News Articles | Exhibits