Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 1 of 16

UNUED STATES DISTRICT COURT FILED IN CLERK'S OfFICE

u,s,o.c .AfI~
NORTHERN DISTRICT OF GEORGIA

ATLANTA DIVlSION

UNITED STATES OF AMERICA *

Plaintiff •
•

v. • No.1 :03-CR-131-CC
•

SCOTT HINTZ, •
Defendant •
MOTION FOR .JUDICIAL NOTICE IN SUPPORT OF ALL PENDING MOTIONS

Defendant requests the Court accept this filing and take notice of the items contained herein

for all pending motions currently pending in case # I :03-CR-13I (Atlanta U. S. Distrtiet 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 fact~:

(A) appointed counsel has specit1cally stated he was appointed by the Court for the very limited

matter relating to the revocation proceedings of this case, (B) appointed counsel 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 government 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. Robel"t Willison's CBS

news video claims of being "no Bemie Madoff,1 may be conect -- this Defendant and many

other Willison victims believe he is much worse! Willison's uncanny manipulation skills have

, http://www.cbsatlanta.com!news!26986888!detail.html

Page 1 of 5 sit
 Case 1:03-cr-00131-CC Document 310 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 scnt to Jason Galanis and latcr

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 concerns about Willison were supported and verified by

Willison's long-time associate, Michael Garone. Garone described some of Robert Willison's

plots to defraud the U.S. Government and various lending institutions. Garone said he was too

scared to confront Willison because of Willison's violent and anti-social past. WiJlison appears

to have absolutely no conscience. The devastation in Robert Willison'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 Willison and his very close Gerova

Financial Group - Net Five Group associates. It has become crystal clear that Robert Willis()n

never intended to keep the promises andlor contractual obligations he made to Defendant,

Stillwater investors, Gerova Financial Group investors, Westmoore investors, various

Page 2 of 5 J'H
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 3 of 16

managers/vendors, and numerous other victims. Willison was, and is, out of control-as

admitted by the numerous members ofthe management team. Willison was representing that he

was a controlling force behind Gerova Financial Group Ltd. Willison was submitting

questionable, and even fraudulent ('made up' expenses and overbilled items), invoices to Gerova

Financial Group Ltd to be paid at shareholder expense (Robert Willison 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 tbis Defendant are tbe actions that

Robert Willison -and not this Defendant-- was doing both at Gerova Financial Group Ltd

and Net Five Group LLC. Willison often submitted adult entertainment club receipts

(5411 Inc) and other personal expenses to Gerova Financial Group Ltd for payment at

sharebolder 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 Willison 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 2 Willison is of the notion that "even if you tell the truth-

perhaps because you tell the truth-no one will believe you." Willison's notion has served him

well, to date, as people who tell the truth about him have not been believed-largely because of

the "influence" Willison has been able to buy now and in the past.

It was: (a) Willison's 2010 emotional unraveling before this Defendant, (b) Willison's self-

admitted statements of needing serious 'counseling' help, (c) Willison's vile and uncaring words

towards a African Americans affected by Willison's uncaring and questionable actions in Ohio,

, http://www.damninteresting.com/the-un burdened-m ind

Page 3 of 5 ~11
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 4 of 16

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

knowingly, or unknowingly, repeat Willison's false statements) in record of these proceedings,

Defendant was considered an integral and trusted part of the "Gerova Financial Group Ltd"

team for good reason. Defendant was in communication with the highest levels of the 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

structure and Robert Willison's activities) that eventually caused Willison to maliciously turn 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 financial 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 ~H
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 5 of 16

and rage prompted Defendant to dig even funher into Willison's past. Defendant learned Roben

Willison was much more than just tangently involved in the real estate transactions listed in the

2003 proceedings of the 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 Willison victims is much more than disturbing.

Willison'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 AfV equipment, witb USB connections, to play

audio and video evidence so even more evidence can be entered into the record of tbese

proceedings.

In light of all the above, Defendant respectfully requests this Court act immediately to prevent

further interference with Defendant's Constitutional First, Fifth and Sixth Amendment rights.

CONCLUSION

This Court should take judicial notice of all of the above, and: (A) stay revocation hearings

pending the fmal decision of II th Circuit Appeal No.II-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.

rd
Respectfully submitted this 23 day of May 2011.

Scott Hintz,
Pro Se Defendant
Page 5 of5
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 6 of 16
Page 1 of 2

Jason,

You must be on Crack I I assumed that the reason you approached me with the settlement
offer was because Steve was suing you. You 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 (ifhad
bothered to read the document you would have seen that). That is what Steve responded to by
giving you the settlement figures. That's what I've 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- I got you Gross.
2. You wanted I-Bill I got you I-Bill.
3. You wanted Greensburg's help- I got you Greenburg both in Atlanta and in Europe.
4. You wanted funding for Penthouse- I 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 wound up owing them money. I've made every
attempt to be your partner, but most importantly your friend. I've fought battles with you and
for you and covered your back since day one. I sent you an email yesterday asking 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 ofI-Bill despite
repeated promises. I got nothing from Penthouse despite your leveraging it because ofmy
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. Now you think you can dismiss the like a flunky? I'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 that disposable bullshit with me.
You 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 everybody will.
You owe me money, you agreed to pay me and I see nothing that has changed that.
If you 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"? I'd respond to that more than this sniveling bullshit.
You 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.

Sf!
Exhibit A
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 7 of 16
Page 2 of2

The choice is yours. You 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 of the 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. You know my situation and how
important this settlement is to my future.
I make one small suggestion to you -DON'T FUCK ME! There is a lot of easier targets
than me- my friend. I'm not an enemy you willingly want to create. It's your choice.

5t1
Exhibit A
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 8 of 16
Page lof4

From: Robbie Willison <robbie33@bellsouth,net>

Sent: Friday, April 16, 2010 12:54 PM
To: Scott Hintz
Subject: fW: Scanned image from Stillwater Capital Partners
Attachments: AR·M237 _20100415_192735.pdf (lS0 KB)

FYi

---Original Message--­
From: Rachel Lanham <rlanham@gero'l<l.com>

Sent: Thursday, April 15, 20107:47 PM

To: Robbie Willison <robbie33@bellsouth,net>
Subject: FW: Scanned Image from StlUwater Capita! Partners

Robbie ­

Shannon said that you were wondering where! .:ame up wlth the $219.28 figure on the expense report that J submitted on
4/12. Michael Hlavsa gave me a large amount of receipts for you and said that he wanted me to sift through them and match
them up with your already submitted expense reports from the 3rd, Sth, and 15th. I did that, but! found a few outstanding
receipts from February that you submitted, but I could not find on any report, so I took 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 lookin out for ya Robbie
:-)

Rathe!

----Original Message---­
From: [email protected] <[email protected]>
Sent: Thursday, AprillS, 2010 7:28 PM
To: Rachel Lanham <rlanham@gerova,com>
Subject: Scanned image from Stmwater Capital Partners

DEVICE NAME: Stillwater Capital Partners DEVICE MODEL: SHARP AR-M237

LOCATION: 41 Madlson Ave. (at 26th Street), 29th floor

FilE FORMAT: PDF G4

RESOLUTiON; 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!

'5H

Exhibit B
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 9 of 16

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arrc.tl~aa oOf amount and for other individual For Accounting Purposes Only __ I Col\.lffi$ A Sand C NET AMOUNT DUE $2'$0.s.:
)~Co E':tC:P....,.ndltures of$2S.00 or more. Account No. Amount Account No. Amount MUST b. described CASH AOVANCrl;:

--­
I"}-SU1tSlI"")t. 00 second sheet. DUE COMPANY ro:i
Due EMPLOYEE $219.
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to day of woak
DUE EMPLOYEE In USD
PAID
$219.

DATE
Pt"4~-_ CliECK NUMBER
- - - __ OUT PURPOSE OF VISIT FIELD

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 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 10 of 16
Page30f4
Buckhead PI'lZa COillPany
3324 Peactrrree St'NE
Atlanta. GA 30326
02/25/2010
12:02 AM
10011
MO Cheese Pi !za 13,00
Pepperoni 1.00
Cheese & "6"b Flatbread 5,50
SauSage 1.00
Sausage 1.00
8M Tradttional 4,95
Bud Ught
Blue Moon Draft
4.75
4,50 T!tv;.u. ~ f'.e.-b
Complete Subtotal 35.70 ev.~ that (}..ye­
5 Items
Subtotal
~ NOT. V"e.;He e:l--eal cIvt ~
35.70
Tax 2.86 e.",~~
Total 38.56
Balance Due 38.56
Thanks and Come Again!

""'" 's4ii 'j~~'" ..... "OFF W;'T' RECE;Pl

5411 Bethe I Sa.... I I I Ctl'

(~'/n/lIj 22:;;,,;

Columbus. OH 43235
'111># 5W
(614)764-0500

MID 000027430000<1889_001
Dri'J:i;Ti e46OR£':
·JE POOCR[lO~i'N
CO? or
02/19/2010 00;05;16
SALE --- liEDtI 9K67
(12/','2/13 TR ,5282
NEO# 9K61 ,:IART END MILES
Transaction ~ ~
Card T~pe: VISA 0;1.;2"/10 TR 528:; 22 ;j 9 22126 1.1
Ace: M*w*****~w*W1023 STQ~T £lID MILES R':9fJhr Fare
Entry: Swiped 2J11823:16 @.e ~IlTE 11$ 6.18
Batch No; 636 R."hr Fu. SlJRfH; $ 8.50
Bse Amt; 40. 00 RATE 1:$ 5.~~ StS(C/!L$ (j.~
SIJ~CH:I a.58 TOTAL: S ",;0
$. _ _ . ­ SlSrchl$ 6.50 THA;·;,S 1Q.It,O
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THI1IiJ(S DIAL ,3+1 '-.
Total Amt; $__. _ . __ TO CONTACT TLC
Dflil. J-H
Auth,Code; 050103
Respen. APPROVED 050103

CUSTOMER COpy

Thanks for yOur business

*M~"**.MWM*.*WNW".MW"NN
ALL SALES FINAL
stf
Exhibit B
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 11 of 16
Page 4of4

-
~.

Table: 16 Register'
Check#: 199673 Dueols: 10
Date; 07/20/10 TiJllP: 08; IIpm

--[Seat 1J-- ---' - ---. .---------- ---­

I
- i
t Goors li gilt $2.25
1 Bud li6>ht $2.25
2 House Salad $15;00
1 Pllza $11.00
1 ;laniCllttl 1/2 $6,50
1 Pasla $/.50
Marinara
1 Pasta $8_50
Heat Sauce
1 Pasta 1/2 Portion $7,45
Meat Sauce
1 Heatball
1 Pasta 1/2 Peri ion $7.95
CreallY Tomah 0,.. ;1
1 Meatball
1 Bwl Wedding $3_95
1 Chix Marsala $12.95
1 Pasta 1/2 Portion $6.50
Meatballs
1 Italian Sausage/Pep $11 ,95
1 Vea I Picatta $16,00
Subtotal: $119,15
Tax: $B,Ol
Sub w/ Tax $127.62
Amt Due: $127.82

Visa $121,82
Tip: $0,00

We Have Gift Cards Avai lable!

Cal! to Inquire about our Banquet Room!
Have a Great Day!
ANGELA
Thanks for Dining at
Casa De Emanuel
(330) 382-9255

sri
Exhibit B
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 12 of 16
Page 1 of4

From: Robert Willison <[email protected]>

Sent: Sunday, April 25, 201010:14 PM

To: Jason Galanis <[email protected]>; Paul Rohan <prohan246@aoLcom>;

Eric Hafter <[email protected]>

Bee: Scott Hintz

Subject: Re:

My thinking is to try to get support and acceptance wnhin the city. I bunch of Jews from New York are a great target,

we need to change the dynamic, get support at Mayoral and Councilman level even State level-INe need to pitch

that we are there to help build and revltalize communIties and neighborhoods.

we have to be the biggest single family home owners in the city. we should be able to make an lmpact , We just need
to change the face of the ownership and have more of a good ole Boy.•
we want to be part of the revitalizing the neighborhood approach, One of the mayor's campaign promises was to
clean uP the vacant and abandoned housing mess in the city.
This should be a great platform for some councilman to look really good in the community and if we can get the

section 8 program working well. We will be able to sell these homes in the 40 150k range- we are talking about 12-15

mil- nothing to pass over while we finish the bigger and more glamorous deals.

From: Jason Galanis <[email protected]>

Sent: Sunday, April 25, 2010 11 :49 PM

To: Robert Willison <[email protected]>; Paul Rohan <prohan246@aoLcom>

Cc: Eric Halter <[email protected]>; Scott Hintz; George Turkovich <[email protected]>

Subject: Re:

Robbie

My ohio connection is a thousand times deeper. Former US Senator Mike Dewme. His chief of staff for 17 years is

our lawyer and old family friend, Was also fanner assistant deputy attorney general under dick thornburg.

Dewine is THE establishment there. We can get things done in ohio.

You need to identify what it is that is needed.

Jason

From: Robert Willison <robbie33@bellsouth,net>

Date: Sun, 25 Apr 2010 20:41:45 -0400

To: Jason Galanis <[email protected]:>; Paul Rohan <prohan246@aoLcom>

Cc: Eric Halter <[email protected]>; Scott Hintz; George Turkovich <universalturk@hotmaiLcom>

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

-:-A

Exhibit C
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 13 of 16
Page 20f4

From: Robert Willison <robbie33@bellsouth,net>

Sent: Monday April 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 keeps coming up application not found

·-·-original Message-···
From: Keith laslop <[email protected]>
Sent: Saturday, April 10, 2010 11:15 PM
To: Robert Willison <[email protected]>
Ce: lucas Mann <[email protected]>; Jason Galanis <[email protected]>
Subject: RE:

Robbie,

Attached are a couple documents· one is a spreadsheet I attempted to put together when I visited MKA
• basic info/descriptions on all the real estate, and trying to get an understanding of book value vs
appraised value (less senior debt).

What I 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 Message-··
From: Jason Galanis <[email protected]>
Sent: Saturday, April 10, 20103:16 PM
To: Keith Laslop <keith@laslop,com>
Cc: Robert Willison <[email protected]>; lucas Mann <[email protected]>
Subject: Re:

Weird auto correct. Everything you have,

·····Original Message·····
From: Jason Galanis <[email protected]>
Date: Sat, 10 Apr 201019:15:14
To: Keith laslop <keith@laslop,com>
Cc: Robert Willison <fobbie33@bellsouth,net>; lucas Mann<[email protected]>
Kl Can you send rabbie everything you jabe on MKA?
Thanks!
J

'5H
Exhibit C
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 14 of 16
Page 3 of 4

From: Robert Willison <[email protected]>

Sont: Tuesday, March 30, 201010:19 AM

To: Scott Hintz

Subject; FW:

l.rnann@me,com)[email protected]> please fornmd aU the details to these emalls

From: Lucas Mann <[email protected]>

Se.'; Tuesday, March 30, 2010 12:23 PM

To: Robbie Willison <[email protected]>; Jason Galanis <ja.'IDfl@holmbycompanies,oom>

Cc: Paul Rohan <[email protected]>

Subject: Rc:

Robbie we still need the excel sheet with appraisals on planet 5 that you showed me last week

1 got the doc with the pictures

Sent trom my Verizon Wireless BlackBerry

From: Robbie Willison <[email protected]>

D.te; Tuesday, March 30, 2010 9: 18 AM

To: Jason Galanis <jason@holmbycompanies,com>

Cc; Paul Rohan <prohan246@aoLoom>

Subject:

Jay. r will be sending you a request shortly to expedite the line for Broome. We have a 5 mil commitment that we can complete,
We wiU need a corporate resolution to pledge various assets:, a commitment that various future revenues will get pledged, like
the sales of the Condos in Brooklyn, or other asset,,, that have equity tbat we can cross collateralize.

1 \\-ill send you a more detailed list shortly. but as I mentioned last night. if you arrange a short tom line for lOOk, so v.'e can go
reaUy cronk the attorneys ,lenders tile work etc. We can replace it in [uti within 60 days. Each of the existing notes are going to
need to be sorted in detail ,as well as fmd out aU these miscellaneous side deals we keep finding. We will put a critical path
togetber ofwi1ich mortgages need immediate attention, then prioritize them. Broome then Siuger obviously will be the mast
eritical
We just found out that the 8t Augustine loan has matured and the lender is requesting a S500,OO capital reduction, and $85k of
prepaid interest being placed with them in a reserve acwunt.

Bottom line is we "Will need to go to eaeb lender and strueture workouts as quickly as we can

I can get in as early as 4pm to the city if we can meet late afternoon. Let me know your schedu1c.

You should have gotten the overvlcw yesterday of the Planet Five properties, v,,'e need to being thinking about the vend in
strategy to Puboo and timing thereof, of Plane! five asset.'>,
This will help the blend and increase the tools Paul and I have (0 work
R
Robert Willison
678·644·3383

Stl
Exhibit C
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 15 of 16
Page 4of4

From: Robert Willison <[email protected]>

Sent: Tuesday, February 09, 2010 9:40 PM

To: Scott Hintz

Subject: FW: single family homes in Gerova portfolio

Attachments: SKMBT_42110020819360.pdf (60 KB); SKMBT_42110020916300.pdf (278 KB);

Akron_AB_Properties_comps_and_rentxls (40 KB)

Initial overview of some of the residential properties

From: Jason Galanis <jason@holmbycompanies,com>

Sent: Tuesday, February 09,20107:04 PM

To: Robert Willison <[email protected]>

Subject: Fwd: single family homes in Gerova portfotio

rabbie

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 <[email protected]>

Dare: February 9, 2010 2:36:01 PM PST

To: Jason Galanis <jason@holmbycompanies,com>

Subject Fwd: single family homes in GerQva portfolio

Jason

An amended version.

The Akron properties are managed dIrectly by Stillwater. Those in the real estate fund produce income to Stillwater of

belween $15-20,000 per month. Those in the Assel 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

Columbus (Real Estate) while Columbus (Asset Backed) produces approx $ 35,000 monthly, net $20,000 after fees.

For the 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 project, then (b) Stillwater shall receive a

return on its investment calculated at thirty percent annualized yield, then (c) the manager shall receive a retum equal

to that retum received by Stillwater under (b) (if there is insufficient funds the manage!'s share shall be limited 10 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 <[email protected]>

To: Tore Nag <tnag19@aotcom>

Cc: Michael Grant <mikegrant1@gmaitcom>; Richard Rudy <rrudy@stillwatercapJ1aLcom>

Sent: Tue, Feb 9, 2010 3:56 pm

Subject: single family homes in Gerova portfoliO

Enclosed are four attachments-the first attachment IS the real estate single family homes in Pennsylvania and

Delaware that are jn the special purpose entity called StiUwater kesef,LLL, the sole member of which is Stillwater real

estate fund. The second attachment are the single family homes in Akron and Columbus that are in special purpose

entities, the sole member being the real estate fund. The other two attachments are portfolios he!d by the asset

backed fund. The columns which were not described before have been filled 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 Sacked Fund: A home in New Canaan,Conn., 3,600 feet, bum in 2006, currently vacant and listed for

1,295,000 to 1,325,000, wilh no mortgage.

>if
Exhibit C
 Case 1:03-cr-00131-CC Document 310 Filed 05/23/11 Page 16 of 16

CERTIFICATE OF SERVICE

I, Scott Hintz, certify I have served upon:

AVSA Leslie J. Abrams

600 V.S. Courthouse
75 Spring Street, SW
Atlanta, GA 30303

A true copy of the foregoing filing.

This 23,d day of May 2011 by sending the same in a sealed envelope with sufficient 1" class

postage for delivery.

Respectfully,

~.
Scott Hintz