Case 1:03-cr-00131-CC Document 374-2

Filed 06/08/11 Page 1 of 17

EXHIBIT B
FORMER D O C U M E N T 310 16 PAGES TO FOLLOW

Case 1:03-cr-00131-CC Document 374-2

-pase 1:03-cr-00131-CC Document 310

Filed 06/08/11 Page 2 of 17

Filed 05/23/11 Page 1 of 16

UNO ED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGL4 ATLANTA DIVISION JAMES UNITED STATES OF AMERICA Plaintiff
V.

IN

OFFICE

*
*

No.l:03-CR-131-CC

SCOTT HINTZ, Defendant MOTION FOR JUDICIAL NOTICE IN SUPPORT OF A L L PENDING MOTIONS Defendant requests tlie Court accept this filing and take notice ofthe items contained herein for all pending motions currently pending in case #1:03-CR-131 (Atlanta U. S, Distrtict Court). Defendant requests the Court expend all efforts necessary to ensure pro se constitutional rights are not further violated. The Court has been previously alerted to the following facts; (A) appointed counsel has specifically stated he was appointed by the Court for the very limited matter relating to the revocation proceedings of this case, (B) appointed coimsel and Defendant have both moved forthe removal of counsel; the serious conflicts of interest issues were brought presented to the Court during the first session of the April 13, 2011 hearing before Judge King. Appointed counsel has made it clear that Defendant is now without the assistance of counsel. Defendant has alerted the Court and the govemment to the egregious behavior of Robert Willison and some of his close associates. Willison has a long history of unethical and illegal behavior surrounding his world-class skills as a "master" manipulator, Robert Willison's CBS news video claims of being * n Beroie Madoff'^ may be correct this Defendant and many *o other Willison victims believe he is much worse! WilUson's uncanny manipulation skills have
^ http://www.cbs3tlarita.<:om/news/26986888/cletail,html Page l o f S

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131-CC Document 310

Filed 06/08/11 Page 3 of 17

Filed 05/23/11 Page 2 of 16

served him well in avoiding criminal scrutiny by setting up others for some of his own actions, or for the actions of those working on his behalf. Robert Willison and Jason Galanis call this ability to take gross advantage of others, without remorse, as the "Game"; see the attached, and herein incorporated Exhibit A (letter written by Robert Willison and sent to Jason Galanis and later copied by Willison and forwarded via email to others -including Mike Garone- a few years ago). The last Robert Willison/Jason Galanis power-struggle "Game" has long been settled. Now the endless trail of victims continues to grows, exponentially, in their wake. Defendant has known Willison for more than a decade and Willison often represented his ex-wife was a psychopath, apparently to explain away the 'curioiusly different' books Willison would read and to explain the actions Willison would take towards women. In 2010, Willison's actions and statements revealed a side of Willison that Defendant had never seen before. Willison admitted his regular use of projection and admitted, on his own, that he has long been a habitual liar. In 2010, Willison stated he seriously needs "counseling" to help him with his problems. Many of the concems about Willison were supported and verified by WilHson's long-time associate, Michael Garone. Garone described some of Robert Willison's plots to defraud the U.S. Goverrmient and various lending institutions. Garone said he was too scared to confiront Willison because of Willison's violent and anti-social past. Willison appears to have absolutely no conscience. The devastation in Robert WiUison's wake is mind-boggling. During 2009-2010, Willison made numerous promises and contractual obligations in order to fraudulently induce people to act for the benefit of Robert WiUison and his very close Gerova Financial Group - Net Five Group associates. It has become crystal clear that Robert Willison never intended to keep the promises and/or contractual obligations he made to Defendant, Stillwater investors, Gerova Financial Group investors, Westmoore investoi-s, various
Page 2 of si//

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131 -CC Document 310

Filed 06/08/11 Page 4 of 17

Filed 05/23/11 Page 3 of 16

managers/vendors, and numerous other victims. WiUison was, and is, out of controlas admitted by the numerous members of the management team, WiUison was representing that he was a controlling force behind Gerova Financial Group Ltd. WiUison % a submitting vs questionable, and even fiaudulent ('made up' expenses and overbilled items), invoices to Gerova Financial Group Ltd to be paid at shareholder expense (Robert WiUison was listed on the Gerova Financial Group Ltd invoices as a Director / Officer of Gerova Financial Group Ltd). The very actions Robert Willison has alleged against this Defendant are the actions that Robert Willison -and not this Defendant- was doing both at Gerova Financial Group Ltd and Net Five Group LLC. WiUison often submitted adult entertainment club receipts (5411 Inc) and other personal expenses to Gerova Financial Group Ltd for payment at shareholder expense; see attached and herein incorporated Exhibit B for just one example of Willison's employee invoices to Gerova Financial Group Ltd. Instead of owning up to his egregious behavior, Robert WiUison attempted to use projection to, again, avoid accountability for his heinous actions much like a toxic magician or as is described in The Unburdened Mind.^ Willison is of the notion that "even ifyou tell the trath perhaps because you teU the truth^no one will believe you." WUlison's notion has ser\^ed him well, to date, as people who tell the truth about him have not been believedlargely because of the "influence" WiUison has been able to buy now and m the past. It was: (a) WilHson's 2010 emotional unraveling before this Defendant, (b) Willison's selfadmitted statements of needing serious 'counseling' help, (c) Willison's vUe and uncaring words towards a African Americans affected by WiUison's uncaring and questionable actions in Ohio,

^http://www.damninteresting,com/the-unburdened-mind Page 3 of 5 S''^

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131-cc Document310

Filed 06/08/11 Page 5 of 17

Filed 05/23/11 Page4of16

and (d) Mr. Willison's decision to target a "bunch of Jews from New York" that not only made this Defendant see Robert Willison in a different light, but was also these items that disgusted Defendant and caused Defendant to talk to other company directors and officers about Willison. Unlike the false statements of Robert Willison (and the false statements of those who either knowngly, or unknowingly, repeat Willison's false statements) in record of these proceedings, Defendant was considered an integral and tmsted part of the "Gerova Financial Group Ltd " team for good reason. Defendant was in communication with the highest levels ofthe company during his tenure with Gerova and its subsidiaries as was often called upon to give advice and direction; see attached and herein incorporated Exhibit C. In fact, it was Defendant's constant demands that Robert Willison correct the unethical/illegal items that Defendant found (after Defendant reviewed many parts of the Gerova-Net Five stmcture and Robert Willison's activities) that eventually caused Willison to maliciously tum on Defendant. Willison wanted Defendant to stay quiet about what Defendant observed and wanted to discredit Defendant to the other directors and officers. Willison's campaign included financial threats to not honor stock and other fmancial obligations; it escalated to threats of causing unwarranted problems with Defendant's supervised release (the allegations were likely submitted through these proceedings instead of through other law enforcement agencies to avoid the typical 'innocent until proven guilty' standards found elsewhere), and to terroristic threats and assaults. In one of Willison's rages of anger (witnessed by others), Willison said, "if you think WE f .ked you ten years ago, wait until you see what we do to you this time around." This moment was a pivotal and forever changed the way Defendant would see Robert Willison. Willison's true nature came out when Defendant exposed Willison for his illegal actions. Willison's statements
Page 4 of 5 ^ / /

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131-CC Document 310

Filed 06/08/11 Page 6 of 17

Filed 05/23/11 Page 5 of 16

and rage prompted Defendant to dig even further into Willison's past. Defendant learned Robert Willison was much more than just tangently involved in the real estate transactions Usted in the 2003 proceedings ofthe case underlying these revocation proceedings^Willison personally profited and gained personal favor for helping others avoid scrutiny. The evidence Defendant has been provided from numerous Robert WiUison victims is much more than disturbing, WilUson's ties to, and business dealings with, the prominent associates who have been assisting him avoid criminal scrutiny during last couple of decades is likewise troubling. Additional evidence will be presented in open court. Defendant respectfully requests each upcoming court hearing have sufficient computer AN equipment, with USB connections^ to play audio and video evidence BO even more e\'ide]iice can be entered into the record of these proceedings. In light of aU the above. Defendant respectfully requests this Court act immediately to prevent further mterterence with Defendant's Constitutional First, Fifth and Sixth Amendment rights. CONCLUSION This Court should take judicial notice of aU of the above, and : (A) stay revocation hearings pending the fmal decision of 11**" Cirouit Appeal No.l 1-11905, and (B) move to hold an immediate hearing to release Defendant from home confinement and back into the community, or minimally order Defendant's release upon items already in the record. RespectfuUy submitted this 23'^ day of May 2011.

Pro Se Defendant
Page 5 of 5

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131-CC Document310

Filed 06/08/11 Page 7 of 17

Filed 05/23/11 Page6of16

Page 1 of 2

Jason, You must be on Crack! I assumed that the reason you approached me with the settlement offer was because Steve was suing you. Y o u stated that you wanted to settle both of our claims jointly. The structure that I took to Gross was a complete settlement with mutual releases (if had bothered to read the document you would have seen that). That is what Steve responded to by giving you tlie settlement figures. That's what Fve been working on the whole time. I told you before Christmas and in my last email that it was time sensitive. Why the hell would I assume you suddenly wanted to settle? I didn't think that you just woke up one day and decided to be a nice guy. Let me make myself perfectly clear Jason. I've busted my ass for you for over 3 years. There has never been a time when you've asked something of me that I haven't attempted to deliver. 1. You wanted Gross-1 got you Gross. 2. You wanted I-BiU I got you I-Bill. 3. Y o u wanted Greensburg's help-1 got you Greenburg both in Atlanta and in Europe. 4. You wanted funding for Penthouse-1 brought you Jim Lachance and Post. 5. You and Charlie both got your ability to leverage the Penthouse deal, though my delivery of Post's financing. The net effect of all this is that you jerked every one of these groups around and damaged my relationships with them and typically woimd up owing tliem money. I've made every attempt to be your partner, but most importantly your fiiend. Fve f o u ^ t battles with you and for you and covered your back since day one. I sent you an email yesterday askuig you for details on your new deal to possibly include your technology in the Greenburg play. And you respond by saying "bye"? I haven't made the first fucking dime with you. You gave me nothing of I-Bill despite repeated promises. I got nothing from Penthouse despite your leveraging it because of my lender. As a matter of fact, you never once in your life said "thank you' to me for anything that I did on your behalf. N o w you think you can dismiss the like a flunky? F m so fucking angry with you I could rip your head off. Don't you ever treat me like you do everybody else! Don't pull tiiat disposable bullshit with me. Y o u want to fuck me around because you haven't figured out that someone you screwed on a deal was probably going to sue you? Wake up, not everybody in this life lies down and takes a fucking, like you seem to believe ever>'body will. You owe me money, you agreed to pay me and I see nothing thst has changed that. I f y o u chose to hide behind some weak bullshit excuse: shame on you! Why don't you just be a man and say " I ' m going to fuck you"? F d respond to that more than this sniveling bullshit. Y o u want to fuck with me Jason and beat me out of what is owed, that's your choice but I won't be pushed aside as easily as most people you fuck over: I assure you.

Exhibit A

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131-CC Document 310

Filed 06/08/11 Page 8 of 17

Filed 05/23/11 Page 7 of 16
Page 2 of 2

The choice is yours. Y o u know all you have to do is sign the settlement agreement, with a stipulation that Gross will dismiss his lawsuit and it will all be history. Gross asked you for nothing more than specifics, instead ofthe same bullshit promises that have been given over the years. Our matter is totally different. If you really believe that I deserve to be fucked around after all efforts I've put forth on your behalf, I feel sorry for you, your so busy playing the game you forget that there are actually people's lives involved. Y o u know my situation and how important this settlement is to my future. I make one small suggestion to you - D O N ' T F U C K M E ! There is a lot o f easier targets than me- my friend. I'm not an enemy you willingly want to create. It's your choice.

Exhibit A

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131 -CC Document 310

Filed 06/08/11 Page 9 of 17

Filed 05/23/11 Page 8 of 16
Page 1 of 4

From: Robbie Willison <robfaie33i@>be1l 50uth.net> Sent: friday, April 16, 201012:54 PM To: Scott Hint! Subject l=W: Scanned image from Stillwater Capital Partners Attachments; AR-M237_a010041SJ92735.pdf (ISO KB) FVi Original Message From: Rachel Lanham <rlanham@gerova.com> Sent Thursday, April IS, 2010 7:47 PM To; Robbie WiUison <robbie33(g>bellsouth.net> Subject: FW: Scanned image from Stillwater Capital Partners Robbie Shannon said that you were wondering where 1 came up with the $219.28 figure on the expense report that I submitted on 4/12. Michael Hlavsa gave me a large amount of receipts for you and said that he v/anted me to sift through them and match them up with your already submitted expense reports from the 3rd, Sth, and ISth. I did that, but I found a few outstanding receipts from February that you submitted, but I could not find on any report, so I toolt the liberty of creating one for you, retroactively. So this is basically just money that had slipped through the cracks that I caught. See, I'm looldn out for ya Robbie

Rachel Original Message From; sharp#stlllwatercapttal.com <sharp@stillwatercap(tal.com> Sent: Thursday, April IS, 2010 7:28 PM To: l^achel Lanham <rlanham@>gerova,com> Subject: Scanned image from Stillwater Capltai Partners

DEVICE NAME: Stillwater Capital Partners DEVICE MODEL: SHARP AR-M237 LOCATION: 41 Madison Ave. {at 26th Street), 29th Floor FILE FORMAT: PDF G4 RgSOLUTION; 300dpi Attached file Is scanned image in PDF format. This file can be read by Adobe Acrobat Reader. The reader can be downloaded from the following URL: http://www.adobe.com/

Exhibit B

Case 1:03-cr-00131-CC Document 374-2

Filed 06/08/11 Page 10 of 17

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131-CC Document 310
Buckhead Pijjza Coipany 3324 Peacfrtree St-NE Atlanta, G 30326 A 1Ison/I Guests; 1 M Cheese P 'um D PepperonI Cheese S ''8't- Flatbread Sausage Sausage 3 Traditional M BiJd Light Blue ton Draft Casplete Subtotal 5 Itsms Subtotal Tax Total Balance Due 35.70 2.85 38.55 38.56 02/25/2010 12:02 A H 101 07 13,00 1.00 5.50 1.00 1.00 4,95 4.75 4.50 35.70

Filed 06/08/11 Page 11 of 17

Filed 05/23/11 Page 10 of 16
Page 3 of 4

Thanks and C m Again! o e

Jji-T
Columbus, OH 4323S ma

DUTY R E C E I P T

5 f7 Ki
?.%m-'f

Bri-srl

c o p y
Transaction Card Typei Entry; Batch No: Bse Amt .' Tip: Total Arnt; $. tt

'"^
3 uis^ Swiped gae , OO
MEOit m?

0-^2i/I0 T 5 6 R 23 S ' 'T E D mm T^I H iare is* SRW f UC

i^m mmm
22iJ5 22i2f. L l Sesulsr Fare Pt E If* 6.10 fT StSrcMJ C',.59 TOTfiU f TKftS'/jiQ.t^Q T C Wt T T C O C fC L
ma %

>2A'2/ie T 5 8 R 22

B.se

0.S9 roiftu * 6,.30 T f IS H C W T zmm lit O

Auth.Gade: 050103 Respon, APPROUED 0S0103 CUSTOHER copy ThanlNs for your business ALL SALES FIlSttL

Exhibit B

5^

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131-CC Document310

Filed 06/08/11 Page 12 of 17

Filed 05/23/11 Page 11 of 16
Page 4 of4

Table;16 Checks: 189873 Date: 02/20/10

Registers Guests: 10 Time: OS:Hpi

"[Seat 1] 1 Cociirs light 1 Bud tiyht 2 House Salad 1 Pi^za f Hanicottf 1/2 1 Pasta Harinara 1 Pasta Heat Sauce 1 Pasta 1/2 Portian Heat yaucB 1 Meatball 1 Pasta 1/2 P<.r1 ion Creajiy TomatL 1 Heatball 1 B l Wedding w 1 Chix Marsala 1 Pasta 1/2 Portion Meatballs 1 ttalian Sausage/Pep 1 Veal Picatta Subtotal: Tax: sub w/ Tax A t Due: m Visa Tip:

$2,25 $2.25 $15.-OO $11,00 $6,50 f;.50 $8.50 $7,45 $7.95 $3.95 $12.95 |6,50 *n.95 $16.00 $113.75 $8.07 $127.82 $127.82 1127.82 $0,00

Ife Have Gift Cards Available! Call to Inquire about our Bant^fet Rooqt! Have a Great: D a y !
ANGELA

T h a n k s - f o r D i n l n o at: C a s a De Emanuel C330) 382-9255

. 10 CURt-K

Exhibit B

-Sri

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131-CC Document 310

Filed 06/08/11 Page 13 of 17

Filed 05/23/11 Page 12 of 16
Pagel of 4

prom: Robert Willison <robble33@b8llsouth,net> Sent: Sunday, April 25.201010:14 PM To: Jason Galanis <jason@hoimbycompanis.com>; Paul Rohan <prohan246@aol.com>Eric Halter <erfc@hslending.com> 8cc: Soott Hintz Subject: Re: My thlnl<ing is to try to get support and acceptance within the city. I bunch of Jews from New Yori< are a great tarqet we need to change the dynamic, g&t support at Mayoral and Councilman level even State levelwe need to pit^ ' that we- are there to help build and revitalize communities and neighborhoods. we have to be the biggest single family home owners in the city, we should be able to make an impact. W just need to ot^ange the face of the ownership and have more of a good ole Boy., we want fo be part of the revitalizing fhe neighborhood approach, One of the mayor's campaign promises was to clean up the vacant and abandoned housing mess in tfie city. This should be a great platfonn for some councilman to loo)< really good in the community and if we can get ttie section 8 program working well. We wili be able to sell these homes in the 40 / 50k range- we are talking about 12-15 mil- nothing to pass over white we finish the bigger and more glamorous deals. From: Jason Galanis <jason@holmbycompanies.com> Sent: Sunday, April 25, 2010 11:49 PM To: Robert Willison <robbie33@bellsotith.net>; Paul Rohan <prohan248@aol.com> Cc: Eric Halter <eric@hslending,com>; Scott Hintz; George Turicovich <universalturk@hotmail.com> Subject: Re; Robbie My Ohio connection is a thousand times deeper. Former US Senator Mite Dewine. His chief of staff for 17 years Is our lawyer and oid family friend. Was also fonner assistant deputy attomey general under diok thornburg, Dewine is THE establishment there. We can get things done in Ohio. You need to identify what if is that is needed. Jason From; Robert Willison <rQbbie33@bellsouth.net> Date: Sun, 25 Apr 2010 20:41:45 -0400 To: Jason Galanis <iason@hoimbycompanies.com>; Paul Rohan <prohan246@aol.com> Cc: Eric Halter <er1c@hstending.com>; Soott Hintz; George Turkovich <universallurk@hotinai|.com Subject; Jay when we are with Sugarman, we need to get next to his pal from Ohio. This guy is a major contributor to the State politicians in Ohio. He could be a major key to our turning Columbus around R

Exhibit C

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131-CC Document 310

Filed 06/08/11 Page 14 of 17

Filed 05/23/11 Page 13 of 16
Page 2 of 4

From; Robert Willison <robbie33@bellsouth,net> Sent: Monday Aprl! 12, 2010 1:43 AM To: Scott Hintz Subject: FW: Attachments: shareholder letter sept 24th.pdf (6 MB); FMV Qualified Asset Summary v2.xls (150 KB) Hey Pal, it Iceeps coming up application not found Original Message- From: Keith Laslop <keith@laslop.com> Sent: Saturday, April 10,201011:15 PM To: Robert Willison <robbie33#beltsouth.net> Cc: Lucas Mann <Lmann@me.com>; Jason Galanis <jason@holmbycompafiies,com> Subject: RE: Robbie, Attached are a couple documents - one is a spreadsheet I attempted to put together when (visited MKA - basic info/descriptions on all the real estate, and trying to get an understanding of bool^ value vs appraised value (less senior debt). What f thought would be an easy exercise (as they must have all the info) ended up being very painful information was not forthcoming. You'll see from the attached that there are a lot of blanks in the spreadsheet. It also did not tie to their shareholder letter {also attached) which provides some evidence that they were just jerking me around. Hope you have better luck than me. Let me know if there are any questions. Kind regards Keith Original iviessage- From: Jason Galanis <jasori(a)holmbycompanies.com> Sent: Saturday, Aprl! 10, 2010 3:16 PM To; Keith Lastop <keith@lasfop.com> Cc; Robert Willison <robbie33@bellsQuth.net>; Lucas Mann <Lmann{a!me.com> Subject; Re: Weird auto correct Everything you have. ^Original MessageFrom: Jason Galanis <jason@holmbycompanies,com> Date: Sat, 10 Apr 201019:15:14 To: Keith Laslop <keith(3aslop.com> Cc: Robert Willison <robbie33@!betlsouth,net>; Lucas M3nn<lniann@me.cQm> KL Can you send robbie everything you jabe on MKA? Thanks! J

5if
Exhibit C

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131-CC Document 310

Filed 06/08/11 Page 15 of 17

Filed 05/23/11 Page 14 of 16
Page 3 of 4

From: Robert WtHison <robbie33@bellsouth.nel> Smi Tuesday, March 30,2010 10:19 A M To: Soott Hinlz Subject! FW: Ltnanti@me,com] jason@hotabycompanies.com> please forward all tlte details to these emails Front; Lucas Mann <I.mann'%nc.com> Sent: Tuesday, March 30,2010 12:23 P M To: Robbie WiUison <robbie33@bellsoulhjiet>; Jason Galanis <ja'}on@holmbycompanies.cjn> Cc: Paul Rohan <pnohan246@aol.eora> Subjtct; Re: Robbie we still need the excel sheet with apf>rai.sals on planet 5 that you showed me Jast week J got the doc with (Jie pictures Sentftotnmy Veriaon Wireless BlackBerry

From: Robbie Willisoii<robbie33@bellsouth..net> Date: Tuesday, March 30,2010 9:18 A M To; Jason Gtslanis <jason@i)olmbycompaaies.coni> Cc; Paul Rohan <prQhan246@aoLeoin> Sabjcct: Jay, r wil! be sending you a request shortly to expedite the liue tor Broome. We have a 5 mil eommitinent that we can complete. We will need a corporate resolution lo pledge various assete, a commitment that various future revenues will got pledged, like the sales of ttus Condos in Brooklyn, or other assets that have equity ttsat we can cross collateralize. I will said you a more detailed list shortly, but as I mentioned last night, ifyou arrange a short tenn line for 100k,, sa we can go really crank (he attomeys .lenders tile work etc . We can replace it in tiitl within 60 days. Each ofthe existing notes are going to need to be sorted in detiiil ,as well as find out all these miscellaneous side deals we keepfinding,We will put critical path together of-which mortgages need immediate attention, then prioritize them. Broome then Siuger obviously will be the most critical We just found out that the St Augustine loan has matured and the lender is requesting a S500,00 capital reduction , and $S5k of prepaid interest being placed with them in a reserve aceount. Bottom line is wc will need to go to eadi lender and structure workouts as quickly as we can I can get in as early as 4pm to the city if we can meet late aflemoom Let me know your sehcduJe. You should liave gotten the overview yesterday of the Planet Five properties, wc need to being thinking about tlie vend in strategy to Pubco and timing thereof, of Planet five asscbs. This will help Uie blend and increase the tools Paul and I have to work R Robert Wiltiion 678-644-3383

Exhibit C

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131-CC Document310

Filed 06/08/11 Page 16 of 17

Filed 05/23/11 Page 15 of 16
Page 4 of4

From: Robert Willison <:robbte33@bellsouth.net> Sent: Tuesday, Februaiy 09, 2010 9:40 PM To: Scolt Hintz Subject: FW: single family homes in Gerova portfolio Attachments: SKMBT_421100208193e0.pdf (BO KB); SKMBT_4211002091S300.pdf (278 KB); Ai(ron_A6_Properties_comps_and_renLxls (40 KB) Initial overview of some of the residenflal properHes From: Jason Galanis <jason@halmbycompanies,com> Sent: Tuesday, February 09, 2010 7:04 PM To: Robert Willison <robbie33@beKsouth.net> Subject: Fwd: single family homes in Gerova portfolio robbie here are two groups of properties totaling about $20,000,000 on a written down basis. we have many other properties as well, but it seems the main goal is to get free and clear Income producing properties performing to generate cash flow Jason Begin forwarded message; From: Tore Nag <tnag19@aoi.com> Date: Februaiy 9,2010 2:36:01 PM P5T To: Jason Galanis <]ason@holmbycompan(es.com> Subject: Fwd; single family homes in Gerova portfolio Jason An amended version. The Akron properties are managed directly by Stillwater. Those in the real estate fiind produce Income to Stillwater of beP-veen $15-20,000 per month. Those in the Asset Backed fund produce approx $25,000 monthly. The Columbus properties are being managed by a third party real estate management firm. No income is received by Stillwater on Coiumbus {Real Estate) while Columbus {Asset Backed) produces approx $ 35,000 monthly, net $20,000 after fees. Forthe Pennsylvania properties, the manager receives $300,000 annually (biweekly payments). Stillwater has no Income. In addition at the time a property in this last portfolio is conveyed or "closed" the proceeds shall be divided as follows: (a) Stillwater shall first receive a return of its investment in the pnsjeot, then (b) Stillwater shall receive a retum on its investment calcufated at thirty percent annualized yield, then (c) the manager shall receive a retum equai to that retum received by Stillwater under {is) (if there is insufficient funds the manager's share shall be limited to the amount remaining), and the balance, if any shall be equally divided between Stillwater and the manager. If you want further information, please let me know, Original Message From; Harry Silverman <hsi!verman@Cabotlnvestments.com> To: Tore Nag <tn,aq1 ^(aiaot.com> Cc: IS4ichael Grant <mikegrant1@gmail.com>; Richard Rudy <rrudy@stiItwaterGapi1al.com> Sent: Tue, Feb 9, 201O 3:56 pm Subject; single family homes in Gerova portfolio Enclosed ars four attachmentsthe finst attachment is the real estate single family homes in Pennsylvania and Delaware that are in the special purpose entity called Stillwater k8Sef,LLL, fhe sole member of which is Stillwater real estate fund. The second attachment are the singlefemilyhomes in Akron and Columbus that are in special purpose entities, the sole member being the real estate fund. The other two attachments are portfolios held by the asset backedfund. The columns which were not described before havebeen fiiied in and relate to information on comparable homes. As we have discussed, there is another single family home in the Gerova portfolio included in the Asset Backed Fund: A home in New Canaan,Conn., 3,$00 feet, built in 2006, currently vacant and listed for 1,295.000 to 1,325,000, wilh no mortgage.

Exhibit C

Case 1:03-cr-00131-CC Document 374-2

Case 1:03-cr-00131-CC Document 310

Filed 06/08/11 Page 17 of 17

Filed 05/23/11 Page 16 of 16

CERTIFICATE OF SERVTCF, I, Scott Hintz, certify I have served upon: AUSA Leslie J. Abrams 600 U.S. Courthouse 75 Spring Street, SW Atlanta, G A 30303 A true copy of the foregoing filing. This 23"^ day of May 2011 by sending the same in a sealed envelope with sufficient 1'* class postage for delivery. Respectfully,

Scott Hintz