Letter to Dianne Nast Re Fulton Class Action Jan 25 2008

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Stanley J. Caterbone, Pro Se Litigant Advanced Media Group 1250 Fremont Street Lancaster, PA 17603

January 25, 2008 Ms. Dianne M. Nast, Esq. RodaNast, PC 801 Estelle Drive Lancaster, PA 17601 Re: Fulton Bank Class Action & Shareholder Complaints Dear Dianne: I hope this letter finds you well; it has been awhile since we have communicated to one another.

I am a shareholder of record of Fulton Financial Corporation (Fulton) since July of 2005. Fulton is listed on the NASDAQ stock exchange. Since the subprime fiasco and the credit crises I have been watching attentively at the fallout of Fultons problem with an acquisition a few years ago of Resource Bank, and what I consider a negligent Board of Directors. Resource bank has been the source of approximately $24,000,000 of losses to Fulton shareholders. More losses may be ensuing. In December of 2007, Fulton had expensed $900,000 to review the Resource problems and the write-downs of the $24 million dollars.

On July 11, 2007 I had posted a message on the Yahoo Finance Message Board for Fulton stock investors and traders that suggested that any dissatisfied shareholders should collaborate if they feel so compelled to pursue litigation or a class action lawsuit. There were many investors posting their dissatisfaction with Fulton senior management on the Resource Bank issue and the last few years of declining stock value. One poster responded with an affirmative message the she was willing to contribute several thousand dollars toward a class action lawsuit, and acknowledged that she know of other other large shareholders that are willing to contribute. That message is attached.

On December 13th, 2007 I personally had delivered a letter to the Fulton Board of Directors and requested the resignation of R. Scott Smith, Jr., for negligence and misconduct. The Board of Directors responded in a letter dated December 28, 2007, which is attached. They have been requesting that I put my allegations with any supporting evidence in writing.

In the letter of December 28th, 2007 they stated: Additionally, I would like to request that you please provide the "evidence of negligence, incompetence, and possible criminal conduct within the Fulton Financial Corporation" you mention in your letter, or a summary of the evidence supporting your claims, so Fulton can fully evaluate your claims.

I have responded in a letter, which is attached, and in essence told Fulton that I would not be able

to meet the deadline of a few weeks. Fulton responded and requested the information by January 30, 2008. I have since provided Fulton with a CD-ROM of my correspondence, research, and other related

Advanced Media Group Page 1 of 14 January 25, 2008

files on the subject matter. I did not provide any detailed summary of the requested allegations, but merely sent them raw data in case I was unable to deliver a summary and detail of my allegations.

Before I submit my allegations in writing, as requested, I would like an opinion from a qualified

class action attorney that may be interested in these matters. Of course, with your spectacular record as a class action litigant, I would like to meet with you to discuss my options. Also attached is a letter from Ms. Stephanie Carfley, of Barley Snyder, LLC, the Fulton attorney involved in these matters, stating and answering my question of conflict regarding her past employment with your firm, RodaNast, P.C. and Joe.

Would you please contact me at your earliest convenience regarding these matters? I apologize

for the lateness in contacting you, however my own litigation schedule has been quite extensive.

With Kindest Regards, Stan J. Caterbone, Pro Se Advanced Media Group Enclosures Cc: Stephanie Carfley, Barely Snyder, LLC.


Stan J. Caterbone

Barley Snyder LLC ATTORNEYS AT LAW

126 East King Street Lancaster, PA 17602-2893 Tel 717.299.5201 Fax 717.291.4660 www.barley.com

Stephanie Carfley, Esquire Direct Dial Number: 717.399.1536

E-mail: [email protected]

January 8, 2008

Stanley J. Caterbone 1250 Fremont Street Lancaster, PA 17603

Re: Letter to Board of Directors and Ethics Point Report

Dear Mr. Caterbone:

I am in receipt of your letter of January 1, 2008 regarding the above referenced matters. You raise a number of issues in your letter, to which we would like to respond.

Initially, in response to your request for verification that Barley Snyder is authorized to act on behalf of Fulton with regard to these matters, I direct you to the November 14> 2007 letter from R. Scott Smith, Jr. to you, in which he states: "If you have any matters that you wish to communicate, please direct them to our counsel: Stephanie Carfley, Barley Snyder, LLC ...." The role of Barley Snyder in the context of the claims made by you in the December 13, 2007 letter and the December 21, 2007 Ethics Point Report is to advise Fulton and serve as a conduit for communications between yourself and Fulton. Please be assured though that the actual investigation of the claims will be conducted by Fulton itself. In light of the above, we again request that you forward the information and documents supporting your claims to this office and we will ensure that it is shared with Fulton. If you still have concerns about providing the requested evidence to Barley Snyder, you may, as previously mentioned, enter the details of your Ethics Point Report and upload documents and information related to your report directly on the Ethics Point website. Again though, we ask that you upload only those documents that directly relate to the claims made in your Ethics Point Report and/or the December 13th letter.

In your letter, you also reference your extensive litigation schedule and the need for additional time to provide the documentation referenced in your December 13th letter and your Ethics Point Report. While the allegations made by you in those communications are of a very serious nature and Fulton would like to investigate these claims as soon as possible, Fulton is willing to extend the time period for you to produce evidence supporting your allegations until January 31, 2008. That said, however, in the event that evidence in support of your claims is not received by January 31 st, Fulton will deem your allegations to be unsubstantiated and the matters will be closed. This would not preclude you from renewing the allegations in the future if and when you provide evidence that directly supports the claims.

Lancaster York Harrisburg Reading Berwyn Hanover


January 8, 2008 Page 2

Finally, you indicate in your letter that you will provide the documentation addressed in the Ethics Point Report, and in the letters to Fulton. In order to most efficiently and effectively investigate your allegations, at your earliest convenience, kindly advise as to whether or not the "evidence of negligence, incompetence, and possible criminal conduct" you mention in your letter is the same evidence supporting the claims of "misconduct or inappropriate behavior" made in your Ethics Point Report.

Thank you in advance for your anticipated cooperation with regard to the above. Should you have any questions, please let me know.

Very truly yours,

SC/SC:2145342.1 cc: George R. Barr, Jr.

Paul G. Mattaini

Stephanie Garftey


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Stanley J. Caterbone, Pro Se Litigant Advanced Media Group 1250 Fremont Street Lancaster, PA 17603

January 1, 2008 Ms. Stephanie Carfley Barley Snyder LLC 126 East King Street Lancaster, PA 17602 Re: Letter of December 28, 2007 re: Letter to Board of Directors and Ethics Point Report Dear Ms. Carfley: I am in receipt of your letter of December 28, 2007. As you have confirmed, on Monday December 31, 2007 I sent via email my proof of ownership of Fulton Financial Corporation stock. I will address your letter and your demands. First, I would definitely need some verification from Fulton Financial Corporation that authorized you to author that letter. I have had recent direct communications from Mr. R. Scott Smith, Jr.,. Secondly, I would require that I deal with these issues with other counsel outside of Barley Snyder, LLC, or a member of the Board of Directors. I will not communicate these issues with any member of Barley Snyder, LLC due to the past problems and bad faith efforts to litigate on behalf of Fulton Bank. The no trespass notice that was initiated by both Mr. Shawn Long and Mr. Ronald H. Pollack were totally unjustified and issued for the sole reason to intimidate and discredit my litigation. I do not believe that Barley Snyder, LLC has litigated in good faith. You must remember that I have been wronged by Fulton Bank, as far back as 1987 to the present, and Fulton Bank has been unjustly enriched. I would love nothing more than to litigate these matters in a civil manner, however, it is apparent that I am the only litigant that has demonstrated that objective. Thirdly, I have had persistent problems litigating my court schedule due to the persistent barrage of computer hacking, computer sabotage, and thefts of my personal property. I realize that these are not your responsibilities, however as pro se, I am not able to provide the expediency in delivering documents and evidence that other counsel enjoys. As you are aware, my litigation schedule is extensive at the present time. I am in the midst of the appeal process of MD 879-2007, a private criminal complaint that at the moment indirectly involves your client, Fulton Bank. Unfortunately, I must deal with the Lancaster County District Attorneys Office and their continued disdain for misstatements and false statements regarding the record. I am currently in talks with the County of Lancaster to consider a mediation process to work through some of these extraneous problems that involve thefts of my property and evidence, harassment, and the lack of protection from law enforcement. Of Course, at the present, Caterbone v. Lancaster County Prison, et.al., (05-2288); which Fulton Bank is a defendant, is in the Third Circuit, and requires my attention.


I will provide the documentation that I addressed in the Ethics Point Report, and in the letters to Fulton Financial Corporation. It just will not be within the next 2 weeks. I would like Fulton Corporation to provide a letter authorizing Barley Snyder, LLC to negotiate the terms and conditions of addressing your demands in the letter of December 28, 2007, and with whom they would like to represent them, outside of Barley Snyder, LLC. Respectfully, Stan J. Caterbone, Pro Se Advanced Media Group cc: file


126 East King Street Lancaster, PA 17602-2893 Te1717.299.5201 Fax 717.291.4660

December 28,2007

Stephanie Carfley, Esquire Direct Dial Number: 717.399.1536

E-mail: [email protected]

Stanley J. Caterbone 1250 Fremont Street Lancaster, PA 17603

Re: Letter to Board of Directors and Ethics Point Report

Dear Mr. Caterbone:

As you know, our firm represents Fulton Financial Corporation ("Fulton") in connection with the allegations lodged against Fulton by you.

Fulton is in receipt of your December 13,2007 letter requesting the resignation of R. Scott Smith, Jr. as Chairman and CEO, and it has been shared with the Board of Directors. In that letter, you indicate that you are a shareholder of Fulton. At your earliest convenience, would you kindly verify that you are, in fact, a shareholder and provide me with evidence of your status as a current shareholder of Fulton. Additionally, I would like to request that you please provide the "evidence of negligence, incompetence, and possible criminal conduct within the Fulton Financial Corporation" you mention in your letter, or a summary of the evidence supporting your claims, so Fulton can fully evaluate your claims.

Fulton is also in receipt of your December 21,2007 Ethics Point Report in which you allege that Fulton has engaged in "misconduct or inappropriate behavior." Fulton intends to investigate and address your report in accordance with its existing procedures for Ethics Point ~ e ~ o r t s . However, in order to assess the merit and substance of your report in accordance with these ~rocedures. Fulton will reauire the "written details" to which you allude in that report. Please note that specific details, not simply reference to your company's website, are required to make this assessment. If the evidence in support of your report is the same as that to which you refer in your December 13th letter, kindly provide a statement verifying that fact.

We ask that you provide the requested information within the next two weeks. The information should be forwarded to this office and we will ensure that it is shared with Fulton. Alternatively, you may enter the details of your Ethics Point Report and upload documents and information related to the report directly on the Ethics Point site. We ask that you upload only


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Stanley J. Caterbone Advanced Media Group 1250 Fremont Street Lancaster, PA 17603

December 13, 2007 Board of Directors Fulton Financial Corporation One Penn Square P.O. Box 4887 Lancaster, Pennsylvania 17604 Re: Formal request for the resignation of R. Scott Smith, Chairman, and Chief Executive Officer Dear Board of Directors:

I, Stanley J. Caterbone (shareholder) and Advanced Media Group, would like to formally request that R. Scott Smith, Jr., tender his resignation as Chairman, and Chief Executive Officer of Fulton Financial Corporation effective immediately.

I have enough evidence of negligence, incompetence, and possible criminal conduct within the Fulton

Financial Corporation. I would welcome the opportunity to discuss this with you in person, should you find the time and

courage to do so.

Respectfully, Advanced Media Group Stan J. Caterbone www.amgglobalentertainmentgroup.com Visit Our Blog Visit Our Video Biography Copy to file Deliver to Stephanie Carfley, Barley Snyder, LLC


Fulton Financial Corporatior? L ,. ONE PENN SQUARE, P.O. BOX 4887, LANCASTER. PENNSYLVANIA 17604 71 7-291-25M3 FAX 71 7-295533 2

R. Scon SMITH, JR. CHAIRMAN CHIEF Ex= -A AND ~ S I D M

Mr. Stanley J. Caterbone Advanced Media Group t 250 Fmont Street Lancaster, PA 17603

Dear Mr. Caterbone:

November 14,2007

Thank you for taking a few moments to introduce yourself yesterday, as we passed on the sidewalk. At the time of our m d g , I did not inmmdately recall in what connection I recognized your name. Upon returning to my oBce, I realized that we had previously corresponded on several subjects, and that you have filed a number of lawsuits against Fulton Bank, some of which are still pending.

Unfortunately, given that you are actively engaged in litigation against Fulton Bank, I will not be able to acummodate your request to schedule a meeting with me. If you have any matters that you wish to communicate, please direct them to our counsel:

Stephanie Catfley Barley Snyder, LLC 126 East King Street Lmcaster, PA 17602

Thank you for complying with our communication preference.

R. S ~ t t Smith, Jr. Cbabnm, President and Chief Executive Officer

.1

cc: Stephanie M e y , Barley Snyder, LLC


My July 11th 2007 Post In It's Entirety 13-Dec-07 07:10 pm

"We dissatisfied shareholders need to collectively collaborate and formerly propose a management plan to the Board of Directors. This process will accomplish several tactics toward getting the Board of Directors to listen to our concerns. First, it will be recorded. Secondly, when and if they violate our shareholder rights, they can be held accountable. Thirdly, it will provide all participants with a benchmark for future litigation against the present management if they are found negligent in their respective duties. This could include performance issues and a decline in shareholder value. If you want to study and research how this is done, review articles about Carl Ichan. He is often viewed as an adversary until a comparison of his proposals with future results proves that he proposed alternatives that would have succeeded in increasing shareholder value. He will often put the Board of Directors in a position of being greenmailed. www.amgglobalentertainmentgroup.com Advanced Media Group" Rating :

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Re: My July 11th 2007 Post In It's Entirety 14-Dec-07 10:48 am

First of all thank you for sending your letter to the BOD. I personally don't think you will get a response as I have also sent many letters to R. Scott Smith and did not receive any response. Personally I would like to bring a law suit against every BOD and R. Scott Smith. I would be more than willing to contribute a few thousand dollars to make it happen. I also know a few other large shareholders that are willing to contribute. As you know that untill someone stops this "Little Boys Club" in Lancaster our stock will continue to decline. They must and will be stopped if I have anything to do with it. Looking forward to your response. P.S. Your right on the money with your charge of negligence and incompetence which also includes the boaard members. Thanks much Rating :

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Letter to Dianne Nast Re Fulton Class Action Jan 25 2008