Free Amended Document (NOT Motion/Complaint) - District Court of Arizona - Arizona

EXHIBIT G
Case 2:04-cv-00078-FJM Document 199-11 Filed 04/18/2008 Page 1 of 24

ALL PAYMENTS RECEIVED FROM CLS Shimko, et al v. Woodcock, et at Case No: CIV-04-78-PHX-FJM

11/26/2001 11/29/2001 12/7/2001 12/17/2001 12/27/2001 1/8/2002 1/18/2002 1/22/2002 1/29/2002 2/4/2002 2/13/2002 2/27/2002 3/20/2002 3/22/2002 4/5/2002 4/30/2002 5/17/2002 9/4/2002 9/13/2002 9/20/2002 9/30/2002 10/8/2002 10/16/2002 10/16/2002 10/24/2002 11/6/2002 11/21/2002 12/6/2002 1110/2003 1/17/2003 1/27/2003 1/28/2003 1/31/2003 2111/2003 2/11/2003 2/11/2003

Incoming Wire Transfer Incoming Wire Transfer Deposit Incoming Wire Transfer Incoming Wire Transfer Incoming Wire Transfer Incoming Wire Transfer Incoming Wire Transfer Incoming Wire Transfer Incoming Wire Transfer Incoming Wire Transfer Incoming Wire Transfer Incoming Wire Transfer Incoming Wire Transfer Incoming Wire Transfer Incoming Wire Transfer Incoming Wire Transfer Deposit Deposit Deposit Deposit Deposit Debit - Return Item Debit - Return Item Charge Incoming Wire Deposit Deposit Deposit Deposit Deposit Deposit Check #3148 Check #3162 Check #1095 Check #1096 Check #1094

26,750.26 13,755.00 30,590.04 22,339 00 16,450.00 9,240.00 4,760.00 15,785.00 27,685.00 10,150.00 10,500.00 7,385.00 9,835.00 6,755.00 15,120.00 11,987.50 19, 740.00 20,000.00 10,000.00 10,000.00 10,000.00 10,000.00 (10,000.00) (10.00) 20,000.00 10,000.00 20,000.00 20,000.00 12, 500.00 12,500.00 12,500.00 50,000.00 25,000.00 12, 500.00 25,000.00 75,000.00 603,816.80

C:\Documents and Settings\Rich McDaniel\Local Settings\Temporary Internet Files\Content.lE5\3P62MLGO\649010_1 [1]

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 2 of 24

1 2 3

Timothy A. Shimko (PRO HAC VICE) (OSBN 0006736) David A. Welling (PRO HAC VICE) (OSBN 0075934) TIMOTHY A. SHIMKO & ASSOCIATES 2010 Huntington Building 925 Euclid Ave. Cleveland, Ohio 44115 Tel. (216) 241-8300 Fax (216) 241-2702 Attorneys for Plaintiffs IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA SHIMKO & PISCITELLI, et al.,

Case No. 2:05-cv-01387-JWS PLAINTIFFS' RESPONSES TO DEFENDANT WOODCOCKS' NON-UNIFORM INTERROGATORIES

10 v.

Plaintiffs,

PAUL WOODCOCK, et al., Defendants.

NOW COME Plaintiffs, by and through undersigned counsel, and hereby respond to 16 Defendant Woodcocks' Non-Uniform Interrogatories as follows:

1. Itemize in detail all payments received from any of the Defendants or CORF related entities including date, amount, and manner of payment (check, wire, etc.). See attached and also see invoices in Defendants' possession.

23 24 25 26

2. Describe in detail your involvement (including the amount of any investment) with AZTEC, any tissue banks, or any other ventures or operations done in connection with or related to any of the Defendants or CORF-related entities. Objection, the interrogatory is completely irrelevant to any issue of liability or damages in this case. However, without waiving said objection, I was an investor contributing cash and my legal services to the venture. 1 Case 2:04-cv-00078-FJM Document 199-11 Filed 04/18/2008 Page 3 of 24

1. 2 3. Describe in detail the amounts you alleged are owed you for work done on behalf of the Woodcocks. (Include the date the work was performed, who performed it, what was done, why the work was allocated to Woodcock, and the amount billed.) See invoices already in Defendants' possession. All work done for Woodcock, Ross, Guenther and Goldfarb was done jointly.

9 10

4. Describe in detail the amounts you alleged are owed you for work performed on behalf of each of the other Defendants, the CORF related entities, and CORF officers and employees (including Brill and Ritchie). For each person or party break out in detail the amounts you alleged are owned you for work done for that party. (Include the date the work was performed, who performed it, what was done, why the work was allocated to that particular party, and the amount billed.) See invoices already in Defendants' possession. All work done for Woodcock, Ross, Guenther and Goldfarb was done jointly.

5. Describe in detail every instance in which any of the Defendants acted to lead you to believe he was acting as a general partner. The Defendants told Plaintiff and they acted as and treated each other as equal partners and each had equal control and equally benefited from the partnership's operations. Each had active day to day management and/or sales responsibilities.

22 23 24 25 26

6. Describe in detail any and all advice you gave any of the Defendants about the limitations of their actions and activities as limited partners; the risks and dangers of being seen as acting as general partners; and what they should do to minimize their risks as limited partners. Objection. This interrogatory calls for facts far too numerous to be answered in this form of discovery. This broad subject should be addressed during a deposition. Without waiving said objection, I informed Defendants that their status as general and/or limited partners offered them no protection because the claims being brought against the Defendants were being brought in their individual capacities, for the fraud being alleged based on the Defendants' personal and collective acts of misconduct. 2 Case 2:04-cv-00078-FJM Document 199-11 Filed 04/18/2008 Page 4 of 24

4 5

7. Describe in detail all steps you took to review the partnership agreements or other documents related to the formation of the CORE related entities and advice you gave to the partners about the risks involved and steps they could take to minimize their exposure.

6 Objection. This interrogatory calls for facts far too numerous to be answered in this form of 7 discovery. This broad subject should be addressed during a deposition. Without waiving said objection, I advised them that I could not minimize their personal exposure against alleged acts 8 already committed by each of them. Defendants had already decided to settle the claims being filed against them and to get full releases. I further advised the Defendants to no longer actively 9 participate in the seminars and if any of the alleged misconduct was true to discontinue the practice. 10

8. Describe in detail your actions as general counsel for the CORF related entities, including dates of service, duties, and responsibilities. I was not general counsel. CORP had other lawyers. I served as general litigation counsel. In that capacity, I negotiated settlements and defended lawsuits.

9. Describe in detail any and all warnings, advice and guidance you gave Defendants, the CORF related entities, and CORP officers and employees (such as Brill and Richie) about possible conflicts in your representation of them and the implications of such conflicts. Objection. This interrogatory calls for facts far too numerous to be answered in this form of discovery. This broad subject should be addressed during a deposition. Brill and Ritchie were added to later lawsuits. As Defendants assured me that the alleged misconduct was not true, and since the goal was to protect the assets of the Defendants, I perceived no conflict at that time. 23 24 25 26 10. When and why did you believe that Paul Woodcock was acting as general partner? Describe in detail each and every occasions. 3 Case 2:04-cv-00078-FJM Document 199-11 Filed 04/18/2008 Page 5 of 24

1 2

See response to Interrogatory No. 5.

11. Please describe in detail any and all discussions and communications you had with Woodcock warning him of the risks of acting as or being seen acting as general partner? See response to Interrogatory No. 6.

12. Please answer interrogatories #9 and #10 with respect to each of the other Defendants.

See response to Interrogatory No. 6.

17 18 19 20 21 13. Please explain why you contended in discovery responses and in defending the depositions of Defendants in the underlying CORP cases that they Defendants were limited partners.

22 That was a defense each of them had in common, regardless of its weaknesses. 23 24 25 26 4

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 6 of 24

RESPECTFULLY SUBMITTED on this //ay of April, 2008. TIMOTTIBy: 6 7
rte.. SHI

` / O & AS .^ IAT S

. imko (OS IN 0006736) (Pro Hac Vice) Timothy David A. elling (OSBN 0075934) (Pro Hac Vice) 2010 Huntington Building 925 Euclid Ave. Cleveland, Ohio 44115 Tel. (216) 241-8300 Fax (216) 241-2702
Counsel for Plaintiffs

7_
13 14

COPY of the foregoing electronically filed and served this day Mareir, 2008, upon: dp,,/Zcj Roger L. Cdhen, Esq. #004409 JABURG & WILK, PC 3200 North Central Ave., Ste. 2000 Phoenix, Arizona 85012 Phone: 602-248-1000
Counsel for Defendants Ross

Richard J. McDaniel, Esq. 11811 N. Tatum Blvd., Ste. 1051 Phoenix, Arizona 84208
Counsellor Defendants Woodcock

20 21 22 23 24 25 26

Milton and Kathi Guenther 3642 E. Rockwood Phoenix, Arizona 84032
Defendants in pro per

David and Rhonda Goldfarb 11437 N. 53 rd Place Scottsdale, Arizona 8525
Defendants in pro per

5
Case 2:04-cv-00078-FJM Document 199-11 Filed 04/18/2008 Page 7 of 24

22901 MILL CREEK BLVD. HIGHLAND HILLS, OH 44122 (216) 206-1234 TOLL CALLS: 1-888-2METRO24

METROPOLITAN
BANK & TRUST

M

OHIO IOLTA SHIMKO & PISCITELLI 2010 HUNTINGTON BLDG 925 EUCLID AVE OH 44115-0000 CLEVELAND

STATEMENT PERIOD FROM 11/01/01 TO 11/30/01
YOU CAN ACCESS YOUR ACCOUNT INFORMATION 7 DAYS A WEEK WITH METRO24 BY CALLING 216-206-1234 OR 1-888-2METRO24.

INTEREST ON LAWYER TRUST ACCOUNT

DEPOSITS AND OTHER ADDITIONS
DATE
-a.***

DESCRIPTION INCOMING WIRE TRANSFER INCOMING WIRE INCOMING WIRE TRANSFER INCOMING WIRE

AMOUNT

11/26

C
'

26,750.26

.^...11/29

13,755.00)

OTHER DEBITS AND FEES
DATE DESCRIPTION AMOUNT

CHECK REGISTER
CHECK DATE PAID AMOUNT CHECK DATE PAID AMOUNT CHECK DATE PAID AMOUNT

* INDICATES NON-CONSECUTIVE CHECK NUMBER(S).

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 8 of 24

22901 MILL CREEK BLVD. HIGHLAND HILLS, OH 44122 (216) 206-1234 TOLL CALLS: 1-888-2METRO24

METROPOLITAN
BANK & TRUST

OHIO IOLTA SHIMKO & PISCITELLI 2010 HUNTINGTON BLDG 925 EUCLID AVE OH 44115-0000 CLEVELAND

STATEMENT PERIOD FROM 12/01/01 TO 12/31/01

YOU CAN ACCESS YOUR ACCOUNT INFORMATION 7 DAYS A WEEK WITH METRO24 BY CALLING 216-206-1234 OR 1-888-2METRO24.
INTEREST ON LAWYER TRUST ACCOUNT

J CREDIT - INTEREST YTD INTEREST INTEREST RATE SERVICE CHARGE YTD WITHHOLDING ANNUAL PERCENTAGE YIELD EARNED (APY-E)
DEPOSITS AND OTHER ADDITIONS

DATE DESCRIPTION s 12/07 DEPOSIT12/17 INCOMING WIRE TRANSFER TNCOMING WIRE 12/27 INCOMING WIRE TRANSFER INCOMING WIRE
OTHER DEBITS AND FEES

AMOUNT C30,590.04} 22',339.00

1Ti,450.00 l

DATE DESCRIPTION

AMOUNT

CHECK REGISTER

DATE CHECK PAID

AMOUNT CHECK

DATE PAID

AMOUNT CHECK

DATE PAID

AMOUNT

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 9 of 24

* INDICATES NON-CONSECUTIVE CHECK NUMBER(S).

22901 MILL CREEK BLVD. HIGHLAND HILLS, OH 44122 (216) 206-1234 TOLL CALLS: 1-888-2METRO24

METROPOLITAN
BANK & TRUST

PIt

OHIO IOLTA SHIMKO & PISCITELLI 2010 HUNTINGTON BLDG 925 EUCLID AVE OH 44115-0000 CLEVELAND

STATEMENT PERIOD FROM 01/01/02 TO 01/31/02 YOUR ATM/METRO CHECK & CASH CARD IS NOW PART OF THE STAR NETWORK, MEANING YOU CAN USE YOUR CARD WHEREVER YOU SEE THE RED STAR LOGO. THE CARD CAN BE USED AT MORE THAN 180,000 ATMS AND 720,000 RETAILER LOCATIONS ACROSS THE U.S. YOU CAN ACCESS YOUR ACCOUNT INFORMATION 7 DAYS A WEEK WITH METRO24 BY CALLING 216-206-1234 OR 1-888-2METRO24. INTEREST ON LAWYER TRUST ACCOUNT

CREDIT - INTEREST YTD INTEREST INTEREST RATE PRIOR YEAR INTEREST

SERVICE CHARGE YTD WITHHOLDING ANNUAL PERCENTAGE YIELD EARNED (APY-E) PRIOR YEAR WITHHOLDING DEPOSITS AND OTHER ADDITIONS

DATE -" 01/08

DESCRIPTION INCOMING WIRE TRANSFER INCOMING WIRE

AMOUNT, NT, 9,240.00

01/18 01/22

INCOMING INCOMING INCOMING INCOMING

WIRE TRANSFER WIRE WIRE TRANSFER WIRE

('

4,760.00 15,785.00

01/29

INCOMING WIRE TRANSFER INCOMING WIRE

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 10 of 24

22901 MILL CREEK BLVD. HIGHLAND HILLS, OH 44122 (216) 206-1234 TOLL CALLS: 1-888-2METRO24

METROPOLITAN
BANK R: TRUST

OHIO IOLTA SHIMKO & PISCITELLI 2010 HUNTINGTON BLDG 925 EUCLID AVE OH 44115-0000 CLEVELAND

STATEMENT PERIOD FROM 02/01/02 TO 02/28/02 YOUR ATM/METRO CHECK & CASH CARD IS NOW PART OF THE STAR NETWORK, MEANING YOU CAN USE YOUR CARD WHEREVER YOU SEE THE RED STAR LOGO. THE CARD CAN BE USED AT MORE THAN 180,000 ATMS AND 720,000 RETAILER LOCATIONS ACROSS THE U.S. YOU CAN ACCESS YOUR ACCOUNT INFORMATION 7 DAYS A WEEK WITH METRO24 BY CALLING 216-206-1234 OR 1-888-2METRO24. INTEREST ON LAWYER TRUST ACCOUNT

CREDIT-INTEREST YTD INTEREST INTEREST RATE PRIOR YEAR INTEREST

SERVICE CHARGE YTD WITHHOLDING ANNUAL PERCENTAGE YIELD EARNED (APY-E) PRIOR YEAR WITHHOLDING DEPOSITS AND OTHER ADDITIONS

DATE DESCRIPTION

"'°r 02/04 INCOMING WIRE TRANSFER INCOMING WIRE 02/13 INCOMING WIRE TRANSFER INCOMING WIRE 02/27 INCOMING WIRE TRANSFER INCOMING WIRE

OTHER DEBITS AND FEES
DATE DESCRIPTION AMOUNT

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 11 of 24

22901 MILL CREEK BLVD. HIGHLAND HILLS, OH 44122 (216) 206-1234 TOLL CALLS: 1-88S-2METR024

METROPOLITAN
BANK & TRUST

M

OHIO IOLTA SHIMKO & PISCITELLI 2010 HUNTINGTON BLDG 925 EUCLID AVE OH 44115-0000 CLEVELAND

STATEMENT PERIOD FROM 03/01/02 TO 03/31/02
BOUNCING A CHECK CAN BE EMBARRASSING AND FRUSTRATING. AT METROPOLITAN WE WANT TO DO OUR PART TO SAVE YOU FROM THE POSSIBILITY OF EVER HAVING THIS OCCUR. THAT'S WHY WE CREATED BOUNCE PROTECTION. PLEASE CONTACT YOUR LOCAL OFFICE FOR INFO. YOU CAN ACCESS YOUR ACCOUNT INFORMATION 7 DAYS A WEEK WITH METRO24 BY CALLING 216-206-1234 OR 1-888-2METRO24.

INTEREST ON LAWYER TRUST ACCOUNT

CREDIT - INTEREST YTD INTEREST INTEREST RATE PRIOR YEAR INTEREST

SERVICE CHARGE YTD WITHHOLDING ANNUAL PERCENTAGE YIELD EARNED (APY-E) PRIOR YEAR WITHHOLDING

DEPOSITS AND OTHER ADDITIONS
DATE DESCRIPTION AMOUNT

-^' 03/20 INCOMING WIRE TRANSFER INCOMING WIRE 03/22 INCOMING WIRE TRANSFER INCOMING WIRE

OTHER DEBITS AND FEES
DATE DESCRIPTION AMOUNT

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 12 of 24

22901 MILL CREEK BW HIGHLAND HILLS, OH {^41^22 (216) 206-1234 TOLL CALLS: 1-888-2METRO24

METROPOLITAN
BANK & TRUST

M

l

OHIO IOLTA SHIMKO & PISCITELLI 2010 HUNTINGTON BLDG 925 EUCLID AVE OH 44115-0000 CLEVELAND

STATEMENT PERIOD FROM 04/01/02 TO 04/30/02
YOU CAN ACCESS YOUR ACCOUNT INFORMATION 7 DAYS A WEEK WITH METRO24 BY CALLING 216-206-1234 OR 1-888-2METRO24.

INTEREST ON LAWYER TRUST ACCOUNT

CREDIT - INTEREST YTD INTEREST INTEREST RATE

SERVICE CHARGE YTD WITHHOLDING ANNUAL PERCENTAGE YIELD EARNED (APY-E)

DEPOSITS AND OTHER ADDITIONS
DATE DESCRIPTION
-r--

AMOUNT

'04/05

INCOMING WIRETRANSFER INCOMING WIRE INCOMING WIRE TRANSFEF INCOMING WIRE

15, 120 .0^^)
·T

04/30

\ 11,987. 50 r

OTHER DEBITS AND FEES
DATE DESCRIPTION AMOUNT

CHECK REGISTER
DATE CHECK PAID AMOUNT CHECK DATE PAID AMOUNT CHECK DATE PAID AMOUNT

* INDICATES NON-CONSECUTIVE CHECK NUMBER(S).

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 13 of 24

22901 MILL CREEK BLVD. HIGHLAND HILLS, OH 44122 (216) 206-1234 TOLL CALLS: 1-888-2METRO24

METROPOLITAN
BANK & TRUST

M

OHIO IOLTA SHIMKO & PISCITELLI 2010 HUNTINGTON BLDG 925 EUCLID AVE OH 44115-0000 CLEVELAND

STATEMENT PERIOD FROM 05/01/02 TO 05/31/02
NOW'S THE TIME FOR A HOME EQUITY LINE OF CREDIT FROM METROPOLITAN. WHETHER YOU NEED TO CONSOLIDATE BILLS, PAY FOR HOME IMPROVEMENTS OR A LONG-AWAITED VACATION, ASK ABOUT OUR LOW RATE AND FLEXIBLE OPTIONS. STOP IN OR CALL YOUR NEAREST OFFICE. YOU CAN ACCESS YOUR ACCOUNT INFORMATION 7 DAYS A WEEK WITH METRO24 BY CALLING 216-206-1234 OR 1-888-2METR024.

INTEREST ON LAWYER TRUST ACCOUNT

CREDIT - INTEREST YTD INTEREST INTEREST RATE

SERVICE CHARGE YTD WITHHOLDING ANNUAL PERCENTAGE YIELD EARNED (APY-E)

DEPOSITS AND OTHER ADDITIONS
DATE DESCRIPTION 05/17 INCOMING WIRE TRANSFER INCOMING WIRE 19,740.00

OTHER DEBITS AND FEES
DATE DESCRIPTION

AMOUNT

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 14 of 24

22901 MILL CREEK BLVD. HIGHLAND HILLS, OH 44122 (216) 206-1234 TOLL CALLS: 1-888-2METRO24

METROPOLITAN
BANK & TRUST

M

l.I,.t

I,,,U,,d61,1,,66i

OHIO IOLTA SHIMKO & PISCITELLS 2010 HUNTINGTON BLDG 925 EUCLID AVE OH 44115-0000 CLEVELAND

STATEMENT PERIOD FROM 09/01/02 TO 09/30/02
DECIDING TO INVEST IS AN IMPORTANT STEP IN PLANNING YOUR FUTURE. CALL OR STOP BY YOUR NEAREST OFFICE AND MEET WITH ONE OF OUR LICENSED FINANCIAL REPRESENTATIVES. WELL HELP YOU MAKE THE RIGHT CHOICES TO SHAPE YOUR FINANCIAL FUTURE. YOU CAN ACCESS YOUR ACCOUNT INFORMATION 7 DAYS A WEEK WITH METRO24 BY CALLING 216-206-1234 OR 1-888-2METRO24.

INTEREST ON LAWYER TRUST ACCOUNT

CREDIT - INTEREST YTD INTEREST INTEREST RATE

SERVICE CHARGE YTD WITHHOLDING ANNUAL PERCENTAGE YIELD EARNED (APY-E)

DEPOSITS AND OTHER ADDITIONS
DATE 09/04 - 09/13 `' 09/20 "`` 09/30 DESCRIPTION DEPOSITDEPOSITDEPOSITDEPOSIT AMOUNT 20,000.00 10,000.00

OTHER DEBITS AND FEES
DATE DESCRIPTION AMOUNT

CHECK REGISTER
CHECK DATE PAID AMOUNT CHECK DATE PAID AMOUNT CHECK DATE PAID AMOUNT

* INDICATES NON-CONSECUTIVE CHECK NUMBER(S).

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 15 of 24

22901 MILL CREEK BLVD. HIGHLAND HILLS, OH 44122 (216) 206-1234 TOLL CALLS: 1-888-2METRO24

METROPOLITAN
BANK & TRUST

M

I,L^LL,I,IIILuIII,I II.ullIul
OHIO IOLTA SHIMKO & PISCITELLI 2010 HUNTINGTON BLDG 925 EUCLID AVE OH 44115-0000 CLEVELAND

STATEMENT PERIOD FROM 10/01/02 TO 10/31/02
DECIDING TO INVEST IS AN IMPORTANT STEP IN PLANNING YOUR FUTURE. CALL OR STOP BY YOUR NEAREST OFFICE AND MEET WITH ONE OF OUR LICENSED FINANCIAL REPRESENTATIVES. WE'LL HELP YOU MAKE THE RIGHT CHOICES TO SHAPE YOUR FINANCIAL FUTURE. YOU CAN ACCESS YOUR ACCOUNT INFORMATION 7 DAYS A WEEK WITH METRO24 BY CALLING 216-206-1234 OR 1-888-2METRO24.

INTEREST ON LAWYER TRUST ACCOUNT

CREDIT - INTEREST YTD INTEREST INTEREST RATE

SERVICE RA RGE --A YTD WITHHOLDING ANNUAL PERCENTAGE YIELD EARNED (APY-E)

DEPOSITS AND OTHER ADDITIONS
DATE DESCRIPTION 10/08 DEPOSIT 10/24 INCOMING WIRE INCOMING WIRE ' AMOUNT 10,000.00

OTHER DEBITS AND FEES
DATE 10/16 10/16 DESCRIPTION DEBIT-RETURNED ITEM MAKER - CORE LICENSING SERVICES L DEBIT-RET ITEM CHARGE MAKER - CORF LICENSING SERVICES L AMOUNT 10,000.00 10.00

CHECK REGISTER
CHECK DATE PAID AMOUNT CHECK DATE PAID AMOUNT CHECK DATE PAID AMOUNT

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 16 of 24

* INDICATES NON-CONSECUTIVE CHECK NUMBER(S).

22901 MILL CREEK BLVD. HIGHLAND HILLS, OH 44122 (216) 206-1234 TOLL CALLS: 1-888-2METRO24

METROPOLITAN
BANK & TRUST

IlI,IIlIuIIuIIuuII 'I,IIII IIlI
OHIO IOLTA SHIMKO & PISCITELLI 2010 HUNTINGTON BLDG 925 EUCLID AVE OH 44115-0000 CLEVELAND

STATEMENT PERIOD FROM 11/01/02 TO 11/30/02
DECIDING TO INVEST IS AN IMPORTANT STEP IN PLANNING YOUR FUTURE. CALL OR STOP BY YOUR NEAREST OFFICE AND MEET WITH ONE OF OUR LICENSED FINANCIAL REPRESENTATIVES. WELL HELP YOU MAKE THE RIGHT CHOICES TO SHAPE YOUR FINANCIAL FUTURE. YOU CAN ACCESS YOUR ACCOUNT INFORMATION 7 DAYS A WEEK WITH METRO24 BY CALLING 216-206-1234 OR 1-888-2METRO24.

INTEREST ON LAWYER TRUST ACCOUNT

CREDIT - INTEREST YTD INTEREST INTEREST RATE

---

-- SERVICE CHARGE YTD WITHHOLDING ANNUAL PERCENTAGE YIELD EARNED (APY-E)

DEPOSITS AND OTHER ADDITIONS
DATE DESCRIPTION AMOUNT

11/06

DEPOSIT-

10,0On.00

11/21

DEPOSIT-

L 20,000.00

OTHER DEBITS AND FEES
DATE DESCRIPTION AMOUNT

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 17 of 24

22901 MILL CREEK BLVD. HIGHLAND HILLS, OH 44122 (216) 206-1234 TOLL CALLS: 1-B88-2METRO24

METROPOLITAN
BANK & TRUST

M

I,I,,I,i,,InuII,,,IIIIIInIuIuI
OHIO IOLTA SHIMKO & PISCITELLI 2010 HUNTINGTON BLDG 925 EUCLID AVE OH 44115-0000 CLEVELAND

STATEMENT PERIOD FROM 12/01/02 TO 12/31/02
ARE YOU LOOKING FOR A GREAT MORTGAGE RATE AND CONVENIENCE? VISIT METROPOLITAN'S NEW MORTGAGE WEB SITE. WWW.METMORTGAGE.COM . GET THE RATE YOU WANT, APPLY ON-LINE AND GET YOUR LOAN APPROVED IN MINUTES WITHOUT LEAVING YOUR CHAIR. WWW.METMORTGAGE.COM YOU CAN ACCESS YOUR ACCOUNT INFORMATION 7 DAYS A WEEK WITH METRO24 BY CALLING 216-206-1234 OR 1-888-2METR024,

INTEREST ON LAWYER TRUST ACCOUNT

CREDIT - INTEREST YTD INTEREST INTEREST RATE

SERVICE CHARGE YTD WITHHOLDING ANNUAL PERCENTAGE YIELD EARNED (APY-E)

DEPOSITS AND OTHER ADDITIONS
DATE DESCRIPTION DEPOSITAMOUNT l 20,000.00

--- 12/06

OTHER DEBITS AND FEES
DATE DESCRIPTION AMOUNT

CHECK REGISTER
CHECK DATE PAID AMOUNT CHECK DATE PAID AMOUNT CHECK DATE PAID AMOUNT

* INDICATES NON-CONSECUTIVE CHECK NUMBER(S).

Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 18 of 24

22901 MILL CREEK BLVD. HIGHLAND HILLS, OH 4412 (216) 206-1234 TOLL CALLS: 1-888-2METRO24

METROPOLITAN
BANK & TRUST

M

IIIIIIIIIIIIIIIIIIIIIIIIIIIIIIII OHIO IOLTA SHIMKO & PISCITELLI 2010 HUNTINGTON BLDG 925 EUCLID AVE OH 44115-000D CLEVELAND

STATEMENT PERIOD FROM 01/01/03 TO 01/31/03
ARE YOU LOOKING FOR A GREAT MORTGAGE RATE AND CONVENIENCE? VISIT METROPOLITAN 'S NEW MORTGAGE WEB SITE. WWW.METMORTGAGE.COM . GET THE RATE YOU WANT, APPLY ON-LINE AND GET YOUR LOAN APPROVED IN MINUTES WITHOUT LEAVING YOUR CHAIR. WWW.METMORTGAGE.COM YOU CAN ACCESS YOUR ACCOUNT INFORMATION 7 DAYS A WEEK WITH METRO24 BY CALLING 216-206-1234 OR 1-888-2METR024.

INTEREST ON LAWYER TRUST ACCOUNT

CREDIT - INTEREST YTD INTEREST INTEREST RATE PRIOR YEAR INTEREST

SERVICE CHARGE YTD WITHHOLDING ANNUAL PERCENTAGE YIELD EARNED (APY-E) PRIOR YEAR WITHHOLDING

DEPOSITS AND OTHER ADDITIONS

DATE

DESCRIPTION

AMOUNT

01/10 DEPOSIT01/17 DEPOSIT 01/27 DEPOSIT-

OTHER DEBITS AND FEES
DATE DESCRIPTION

AMOUNT

CHECK REGISTER

DATE CHECK
PAID

AMOUNT CHECK

DATE PAID

AMOUNT CHECK

DATE PAID

AMC "`NT

* INDICATES NON-CONSECUTIVE Document 199-11 Case 2:04-cv-00078-FJM CHECK NUMBER(S).

Filed 04/18/2008

Page 19 of 24

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7272E. INDIAN SCHOOL RD.. STE 540 SCOTTSDALE, AZ 85251
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Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 20 of 24

1096
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722 E INDIAN SCHOOL RD.. S SC Or'SDALE. AZ 85251

ANK ARIZONA. N.A. WELLS FAR VPNWGOEBLS FARGO.COM

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Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 21 of 24

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Document 199-11

Filed 04/18/2008

Page 22 of 24

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Case 2:04-cv-00078-FJM

Document 199-11

Filed 04/18/2008

Page 23 of 24

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Case 2:04-cv-00078-FJM

Document 199-11

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