federal civil action v lancaster county judicial addendum to complaint march 30 2007 amended...

www.amgglobalentertainmentgroup.com mailto:[email protected]

717.427-1621 Fax

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

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

__________________________________________________________________________________

STANLY J. CATERBONE : AND ADVANCED MEDIA GROUP PLAINTIFF : : v. : WENGER, ET AL :

DEFENDANTS : : CIVIL ACTION

: :

: CASE NO. 06-cv-4650 : : :

ADDENDUM TO COMPLAINT

AND NOW, on this 2nd day of April, 2007, I hereby file an Addendum to this Complaint. Respectfully submitted, _____________/s/_____________ Date: April 2,2007 Stanley J. Caterbone, Pro Se Litigant

1250 Fremont Street 717-427-1821 facsimile [email protected]

ADVANCED MEDIA GROUP Page 1 of 78 03.30.2007

____________________________________________________________________________________________

COMPLAINT _________________________________________________________________________________

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing ADDENDUM TO COMPLAINT has been served this 2nd day of

April 2007, by first class mail, Postage prepaid, by electronic mail upon, or by hand delivery:


Date: April 2,2007 Respectfully submitted,

____________/s/_______________ Stanley J. Caterbone, Pro Se Litigant 1250 Fremont Street Lancaster, PA 17603 717-427-1821 facsimile [email protected]

1. Mrs. Wiegand Of the Lancaster County Assistance Office P.0 BOX 4967 832 Manor Street Lancaster pa 17604-4967 2. Ms. JoLynn Stoy Of the Pennsylvania Housing Finance Agency 211 North Front Street, P.O. Box 15530 Harrisburg, PA 171 05-5530 3. Ms. Lynn Patch Of the Pennsylvania Housing Finance Agency 211 North Front Street, P.O. Box 15530 Harrisburg, PA 171 05-5530 4. Officer James McVey Of the Lancaster City Bureau of Police 39 West Chestnut Street Lancaster, PA 17603 5. Ms. Kerri Egan of Select Security/Access 150 North Queen Street Lancaster, PA 17602 6. Dr. Emily M. Pressley Of the Lancaster General Hospital 320 North Duke Street Lancaster. PA 17602 7. Mr. Randall O. Wenger Of The Lancaster County Office Of The Prothonotary 50 North Duke Street Lancaster, PA 17602 [email protected] 8. Mr. Mathew Bomberger Office Of The Lancaster County Public Defender 29 East King Street-Suite 213 Lancaster, Pa 17602 9. Lancaster County Judge Luis Farina 50 North Duke Street Lancaster, PA 17602 10. Lancaster County District Magistrate Kelly S. Ballentine, Esq. 123 Locust Street Lancaster, PA 17602 Fax (717)299-8375 11. Officer Michael K. Schaefer Of Millersville Boro Police 10 Colonial Avenue Millersville, PA 17551 12. Mr. Donald Totaro Lancaster County District Attorney 50 North Duke Street Lancaster, PA 17602 13. Ms. Bachman Of the Lancaster County Assistance Office P.O. Box 4967 832 Manor Street Lancaster, PA 17603

14. Mr. James Doran 26 Blue Rock Road Millersville, PA 17551

15. Mr. Steven J. Sikking Of the Eden Resort Inn 222 Eden Road Lancaster, PA 17601 16. Mr. John Buckwalter Of the Lancaster Newspapers, Inc. 8 West King Street Lancaster, PA 17603 17. Mr. Frank McCabe Of the High Hotels High Industries 1853 William Penn Way Lancaster, PA 17601 18. Mr. Shawn Long Of Barley Snyder, LLC 126 East King Street Lancaster, PA 17602-2893 19. Mr. David Pflumm Of Pflumm Contractors, Inc. 54 South Duke Street Millersville, PA 17551 20. Mrs. Bleicher Of the Lancaster County Assistance Office P.0 BOX 4967 832 Manor Street Lancaster pa 17604-4967 21. Lancaster County District Magistrate Stuart J. Mylin 25 East State Street Quarryville, PA 17566 22. Chief John Fiorill Of The Southern Regional Police Department 3284 Main Street Conestoga, PA 17516 23. Officer Robert M. Fedor Of The Southern Regional Police Dept 3284 Main Street Conestoga, PA 17516 24. JoLynn Steinman, Postmaster Conestoga Post Office Main Street Conestoga, PA 17516 25. Dauphin County District Magistrate Michael Smith 1281 South 28Th Street Harrisburg, PA 17111 26. County Detective Michael Landis Lancaster County District Attorney Office 50 North Duke Street Lancaster, PA 17602

27. Lancaster County District Magistrate Judge Denise Commins 15 Geist Road Lancaster, PA 17602 28. Lancaster County District Magistrate Stuart J. Mylin 25 East State Street Quarryville, PA 17566 29. Chief John Fiorill Of The Southern Regional Police Department 3284 Main Street Conestoga, PA 17516 30. Lancaster County District Magistrate William G. Reuter 77 Donegal Business Center Mount Joy, PA 17552

31. Lancaster County Judge Michael A. Georgelis Of The Court of Common Pleas 50 North Duke Street Lancaster, PA 17602

32. Lancaster County District Magistrate Leo Eckert, Jr. 841 Stehman Road Millersville, PA 17551 33. Lancaster County District Magistrate Judge Maynard Hamilton, Jr. 324 Beaver Valley Pike Willow Street, PA 17584 Fax 717 464-2824 34. Officer Ronald Bezzard Of The East Lampeter Police Department 2205 Old Philadelphia Pike Lancaster, PA 17602

35. Officer Adam Cramer Of The Southern Regional Police Dept 3284 Main Street Conestoga, PA 17516

36. Officer Robert Buser Of The Southern Regional Police Dept. 3284 Main Street Conestoga, PA 17516

37. Lancaster County Sherriff S. Bourne 50 North Duke Street Lancaster, PA 17602 38. Nelson Brewster, Investigator PA Attorney General Office/Civil Rights Enforcement 14th Floor, Strawberry Square Harrisburg, PA 17120 39. Ms. Sheryl Crow c/o Wendell W. Crow, Managing Partner Crow, Reynolds, Shetley & McVey, LLP 308 First Street P.O. Box 189 Kennett, MO 63857-0189


EXHIBIT C


www.amgglobalentertainmentgroup.com [email protected]

717.731.8184 Phone 717.427-1621 Fax

Stan Caterbone Advanced Media Group 1250 Fremont Street Lancaster, PA 17603

March 26, 2007

Harleysville Preferred Insurance Company Margery Lukens, AIC, AIS Claims Specialist Mid Atlantic Claims Service Center P.O. Box 1016 308 Harper Drive Moorestown. NJ 08057-0916 Fax 856.642.9415 Re: Claim No. M0-702274 (Stolen Property) Dear Ms. Lukens: On Friday, March 23, 2006, at approximately 11:00 am I visited the office of Parula Properties, LLC at 100 South Seventh Street, Akron, Pennsylvania. The office had no designation of Parula Properties, instead had 2 outside signs of Noble Real Estate. The receptionist would not acknowledge that Parula Properties existed and asked who I was and what I wanted. She called a gentleman from an adjacent office and I explained that I was looking for my personal property that was held in storage. I asked him that I wanted to inspect the property and demanded my 1991 Dodge Pickup Truck immediately. I also gave him an updated inventory or item list of all of my personal property that was missing. He told me that I could not inspect the property because it was far far away, and that he would deliver my vehicle to 1250 Fremont Street. I asked him when, and he said he would email me with a time.

He kept telling me that he wanted to deliver everything at one time to a location of my choosing. I tried to explain that I did not have anyplace for him to deliver the items. I am currently temporarily residing in 1000 square foot row home in Lancaster City, that is currently furnished, and that in no way will the contents of a 2,000 square foot home fit in this house. I became suspicious and asked him what he had in storage. I told him to email me, and gave him my business card with my email on it. He said he did not have a card, and that Parula Properties was a client. He would not give me his name. I left, and have still not received an email from him as promised. I have no evidence that my property was in his possession, or anyones at that location. Please see the enclosed documents. Additionally, enclosed is a document that I found yesterday, Notice of Sheriff Sale filed by Shawn Long, of Barley Snyder on behalf of Fulton Bank. This is the only document that I currently possess regarding my Foreclosure from Fulton Bank. Please note the following excepts from the Notice of Sheriff Sale: 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. My Position: I have done this and the matter was before the Superior Court on December 20th, 2006, the day of the Sheriff Sale. 3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney). My Position: Again, I have done this and the matter was before the Superior Court on December 20th, 2006, the day of the Sheriff Sale.


YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE

2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. My Position: I have raised this objection in both Civil Actions Nos. 07-00119 and 07-00366 filed in The Court of Common Pleas of Lancaster County, of Pennsylvania; and have included an Exhibit the 1099-A document which places the Fair Market Value of Real Property at $250,000, approximately $100,000 more than the Sheriff Sale price paid by Central Pennsylvania Settlement on December 20, 2006. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time. the buyer may bring legal proceedings to evict you. My Position: I have never vacated that property and the buyer never initiated any legal proceedings to evict me. On January 4, 2006, 2 movers ordered my uncle and myself off my property from Noble Real Estate and I was told hours later by Lt. Lancaster of the Lancaster County Sheriffs Department that the Southern Regional Police were summoned to the property because we were trespassing. On February 1, 2007, Common Pleas Judge, Michael Georgelis signed an ORDER by Shawn Long, of Barley Snyder, representing Fulton Bank, in the matter of CI-07-00119 Caterbone v. Fulton Bank, et al.

AND, NOW this 1st day of February ,2007, upon consideration of Stanley Caterbone's Petition to Set Aside Sale of Real Estate and Fulton Bank's response thereto, it is hereby ORDERED that said Petition is denied, with prejudice. Accordingly, the Sheriff is directed to make the scheduled distribution of proceeds from the December 20,2006 Sheriffs Sale of the property known as 220 Stone Hill Road, Conestoga, Pennsylvania and to deliver the Sheriffs Deed to such property to the purchaser at such Sheriffs Sale.

It should be noted that Fulton Bank filed that Response on January 30th, 2007, and I was only served a copy at 3:00 pm on January 31st, the day before the Hearing (which was held in the Judges office with no Oath administered). Common Pleas Judge, Michael Georgelis signed the ORDER that day, February 1st, 2006, without giving me an opportunity to first file my Reply, as prescribed by law. I filed my reply on February 6th, 2007. Shawn Long admitted in the meeting that he needed settlement for the property by Friday, February 2nd, 2007, for some unknown reason. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on or about January 19, 2007. This schedule will state who will be receiving the money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after January 19,2007.

Ms. Lukens, at this time, given these most recent developments, I must dispute your legal opinion in your letter of March 13, 2007 which you stated, Regarding yon personal property, 1 have been in contact with Central Penn Property Services. I was advised that their employee told you on January 4, 2007 to contact their office regarding your personal property. Central Penn Property Services will be sending you a letter regarding this matter. Your personal property was not stolen.

In addition, I would urge Harleysville to keep this claim open until every item of my personal

property is delivered, and inspected. I would expect that my personal property, be in the same condition as I left it on December 4, 2006, the last time I was in my residence and property. This was at the ORDER of Court of Common Pleas Judge Louis Farina, accompanied by 2 Lancaster County Sheriffs from the Lancaster County Prison to obtain legal files for my trial. I Remain, Stan J. Caterbone cc: Mr. Donald Totaro, Lancaster County District Attorney Court of Common Pleas Judge Michael A. Georgelis (CI-07-00119) Court of Common Pleas Judge Paul K. Allison (CI-07-00366) Enclosures


BARLEY SNYDER, LLC Shawn M. Long, Esquire Court I.D. Nu. 83774 126 East King Street Lancaster, PA 17602 (717) 299-5201

FULI'ON BANK, Plaintiff

STANLEY J. CATERBONE, Defendant

Attorneys for Plaintiff Fulton Bank

COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA CIVIL ACTION - LAW

No. CI-06-02271

ACTION IN MORTGAGE FORECLOSUM

NOTICE OF SHERIFF'S SALE OF REAL PROPERTY

TO: Stanley J. Caterbone 220 Stone Hill Road Conestoga, PA 17516

Your house (real estate) at 220 Stone Hill Road a/Wa Lot #5 Stone Hill Road, Township

of Conestoga, County of Lancaster, Pennsylvania is scheduled to be sold at Sheriffs Sale on

December 20,2006 at 1.30 p.m., by the office of the Lancaster County Sheriff in Courtroom A:

Second Floor, Old Courthouse, 50 North Duke Street, Lancaster, Pennsylvania to enforce the

court judgmer.! of $97,425.07 obtained by Fulton Bank, against you. NOTICE OF OWNER'S RIGHTS

YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE

To prevent this Sheriffs Sale you must take immediate action:

1. The sale will be canceled if you pay to Fulton Bank (the amount of the judgment

plus costs)(the back payments, late charges, costs, and reasonable attorney's fees due). To find

out how you 111ust pay, you may call Shawn M. Long, Esquire at (717) 299-5201.


Compaq_OwnerCopy

2. You may be able to stop the sale by filing a petition asking the Court to strike or

open the judgment, if the judgment was improperly entered. You may also ask the Court to

postpone the sale for good cause

3. You may be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below to find out how to obtain an attorney).

YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE

OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.

1. If the Sheriffs Sale is not stopped, your property will be sold to the highest

bidder. You may find out the price by calling the Sheriff of Lancaster County, at (717) 299-

8200.

2. You may be able to petition the Court to set aside the sale if the bid price was

grossly inadequate compared to the value of your property.

3. The sale will go through only if the buyer pays the Sheriff the full amount due in

the sale. To find out if this has happened, you may call the Sheriff of Lancaster county, at (717)

299-8200.

4. If the amount due from the buyer is not paid to the Sheriff, you will remain the

owner of the propcrty as if the sale never happened.

5 . You have a right to remain in the property until the full amount due is paid to the

Sheriff and the Sheriff gives a deed to the buyer. At that time. the buyer may bring legal

proceedings to evict you.

6 . You may be entitled to a share of the money which was paid for your house. A


schedule of distribution of the money bid for your house will be filed by the Sheriff on or about

January 19, 2007. This schedule will state who will be receiving the money. The money will be

paid out in accordance with this schedule unless exceptions (reasons why the proposed

distribution is wrong) are filed with thc Sheriff within ten (10) days after January 19,2007.

7. You may also have other rights and defenses, or ways of getting your house back,

if you act immediately after the sale. ,

YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO

NOT HAVE A LAWYER OR CANNOT AFFORD ONE. G O TO OR TELEPHONE THE

OFFICE LISTED BELOW TO FlND OUT WHERE YOU CAN GET LEGAL HELP.

Lawyer Referral Service The Lancaster County Bar Association

28 East Orange Street Lancaster, PA 17602

Telephone: (717) 393-0737


ALL That certain tract of land along Stone Hill Road situate in Conestoga Township, Lancaster County, Pennsylvania, and being more particularly shown on a survey prepared for Anna L. Mylin by Charles L. Roach, P.L.S., on September 30, 1994, and all the same being more fully bounded and described as follows:

BEGINNING at a railroad sdke set bv others near the center of the westbound lane of Stone Hill -- - Road; thence extending in Stone Hill Road, South eight (8) degrees thirty-five (35) minutes twelve (12) seconds East, a distance of two hundred eighty-nine and seventy-three hundredths (289.73) feet to a nail set by others near thc centerline ofsaid Stone Hill ~ o a d ; thence extending along land now or late of Floyd E. and Justinc L. Duke and crossing over an iron pin set twenty-three and sixty hundredths (23.60) feet from the last described point, South eight (8) dcgrees forty-four (44) minutes twelve (12) seconds West, a distance of three hundred thirty-five and forty-nine hundredths (335.49) feet to a stone, a comer of land now or late of Russel and Donna Lasch; thence along lands now or late of same, South eighty-seven (87) degrees twenty-one (21) minutes thirty-two (32) seconds West, a distance of one hundred ninety-five and fifty-seven hundredths (195.57) feet to an iron pin; thence extending along land now or late of Charles E. and Theda M. kneer, North five (5) degrees seventeen (1 7) minutes thirty (30) seconds West, a distance one hundred seventy (1 70.00) feet to a point; thence extending along land now or late of Harold F. and Mary Jane Baker, North six (6) degrees thirteen (1 3) minutes ten (10) seconds West, a distance of two hundred twenty (220.00) feet, having crossed over an iron pin set twenty-five and forty hundredths (25.40) feet from the next described point to a railroad spike set by others, the place of BEGINNING.

CONTAINlNG 1.982 acres

UNDER AND SUBJEC'I' TO any conditions, restrictions and rights-of-way of record.

IT BEING the same premises which Anna L. Mylin, by deed dated January 20, 1995 and recorded January 24, 1995 in the Office of the Recorder of Deeds in and for Lancaster County, Pcnnsylvm~ilia, in Record Book 4552, Page 0419, granted and conveyed unto Stanley J. Caterbone. his heirs and assigns, Grantor herein.

Tax Map No.: 120-32523-0-0000

SEIZED IN EXECUTION as the property of Stanlcy J. Caterbone, on Judgment No. CI-06-02271.


IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA C I V I L

FmTCN BAXK

1'.

STANLEY J. CATEAWGNE

No. CI-06-0227 1

Pa. R.A.P. 192Sfb) 0 R D E R

The Defendant has appealed my June 29, 20C6 Order granting the Plaintiffs Motion for

Judgment on the Pleadinss. He is directed to file. by August 25. 2006. a concise statement of the

matters complained of on appeal, pursuant to Pa. R.A.P. 1925(b). The Plaintiff is directed to file its

answer, specificaily addressing those matters identified by the Defendant, by September 8, 2006.

C o ~ i e s of each must he GeEivereb to mv Chzmhers bv those dstes.

BY THE COURT:

MICHAEL A GEORCFI 1s Jll?f;F

MICHAEL A. GEORCiELIS JUDGE AUGUST 1 1,2006

ATTEST: \.

< - * . C . 1 1 h ??A Cinxa U : I I D - - A Pn-n-+nrn D A !7

March 19, 2007

CERTIFIED MAIL

Stanley J. Caterbone 1250 Fremont Street Lancaster, PA 17603

RE: Your personal property from 220 Stone Hill Road, Conestoga, PA 17516

Dear Mr. Caterbone

Your personal property and your 1991 Dodge Dakota Pickup are secure and safe in storage and will be delivered directly to you at the location you specify. Please contact our office and give us a location as to where you want your things delivered to as well as a date and time.

Our phone number is 717-859-3311 and press zero for the operator.

Parula Properties, LLC.

Parula Properties, LLC 100 S 7th Street, Akron, PA 17501


Compaq_OwnerCopy

www.amgglobalentertainmentgroup.com [email protected]

717.427-1621 Fax


March 15, 2007

Parula Properties, LLC 100 S 7th Street, Akron, PA 17501 Re: 220 Stone Hill Road Dear Sir or Madam: I was never told by anyone regarding the location and/or status of my personal property. I dont know how you think you can get away with that statement. Law enforcement had a duty and obligation to disclose that information, and never ever communicated to me any such notion. We will address this situation in a professional manner. I am demanding the following information in order to take possession of my property:

1. Location of storage facility. 2. The submittal of an itemized inventory listing of all property returned to me. 3. Names of all individuals that have had access to my property. 4. Location of my 1991 Dodge Dakota Pickup. 5. Your specified requirements to take possession.

You must remember, the evidentiary materials and files are material to litigation in the

following Courts; United States District Court for the Eastern District of Pennsylvania; The Third Circuit District Court of Appeals; The Pennsylvania Supreme Court, The Pennsylvania Superior Court, The Commonwealth Court of Lancaster County, Pennsylvania, The Commonwealth Court of Dauphin County, Pennsylvania; The Commonwealth Court of Berks County, Pennsylvania; Magisterial District Justices Eckert, Commins, Stoltzfus, Roth, Simms, Ballentine, Sponaugle, Hamilton, Mylin, and James.

I will not being uses a telephone to communicate at this time. First, I do not have a

telephone, and second, I have no way of knowing or verifying you by telephone. In 2004, I have filed a complaint regarding persons misidentifying themselves on the telephone, and redirecting my calls. Agent Sarsfield of the Pittsburg Office of the Attorney General of Pennsylvania can verify and confirm this.

I expect you will expedite your response.

Respectfully, Stan J. Caterbone Cc: file


Compaq_OwnerCopy

March 13, 2007

CERTIFIED MAIL

Stanley 1. Caterbone 1250 Fremont Street Lancaster, PA 17603

RE: Your personal property from 220 Stone Hill Road, Conestoga, PA 17516

Dear Mr. Caterbone

Please be advised that we are still storing your personal propetty thai aas rs roved %or, 220 Stone Hill Road, Conestoga, PA 17516. We had told you on January 4, 2007 to contact obr office so that we could coordinate getting your things back into your possession. To date, we have not heard from you.

This is official notice that if you do not contact our office in 30 days to claim your personal property, it will be disposed of. We can be reached at 717-859-3311 and press zero for the operator.

Parula Properties, LLC.

Parula Properties, LLC 100 S 7th Street, Akron, PA 17501


Compaq_OwnerCopy

Goodpeople to know

March 13.2007

Stanley Caterbone 1250 Fremont Street Lancaster, PA 17603

Midatlantic Claims Service Center Tel $88.5959876 PO. Box l O l h Fax 856.h42.9415 308 Harper Drive Mooreslown. NJ 08057,0916 www.harleysviile,mo~p.~om

Claim No: MO-702274 Insured: Stanley Caterbone Loss Location: 220 Stone Hill Road, Lancaster, PA Date of Loss: 1 104107

Dear Mr. Caterbone:

Thank you for your letter of March 10, 2007. Please be advised that we have reviewed the information provided to date.

We are will be closing your claim. As stated in the docun~entation that you provided, your housc was sold and your I-eceived compensation for it. If you disagree with the amount of compensation, yon need to discuss that with Fnlton Financial Corporation.

Regarding yon personal property, 1 have been in contact with Central Penn Property Services. I was advised that their employee told you on January 4, 2007 to contact their office regading your personal property. Central Penn Property Services will be sending you a letter regarding this matter. Your personal property was not stolen.

Should you have any question, please feel free to contact me at (888) 595-9876.

Sincerely, 7

Margery Lukens, AIC, AIS Claims Specialist Mid-Atlantic Claims Service Center Ext: 2359

cc: Murray Insurance Assoc.

File

State law requires us to include the following statement - Any person who knowingly files a statement of claim containing any false or misleading informntion is subject to criminal and civil penalties.


Compaq_OwnerCopy

MSN Hotmail - http://by104fd.bay104.hotmail.msn.com/cgi-bin/getmsg?curmbox=0000...

1 of 2

[email protected] Printed: Saturday, March 24, 2007 11:04 AM

From : Stan Caterbone

Sent : Saturday, March 24, 2007 10:43 AM

To : [email protected]

CC : [email protected]

Subject : RE: In Response to your message to Senator Specter

Dear Senator,

I will not accept your explanation or response as satisfactory. I have given you evidence of awidespread civil and criminal conspiracy, to cover up my Federal False Claims Act complaint regarding selling arms to Iraq. Now, I notified you of the subject matter back in 1991 or 1992,during a personal meeting in Columbia, Pennsylvania. You have a statatory duty to at leastrefer this matter to someone in authority that can offer me assistance. I had someone attemptto take my life over these matters before, and you, being a Republican, cannot change yourobligation or duties; you are now privy to these matters.

I have given you enough evidence of Obstruction of Justice (for at least an interview), and being that Mr. Donald Totaro, the Lancaster County District Attorney was directely inovolved in these matters in 1987 (with fradulent and dismissed criminal charges), when these incidents began, (ISC Whistle-Blowing), and given your recent visits to Lancaster County over the past year, I am urging you to reconsider your position and your lack of willingness to uphold the rule of law, and your obligations.

You, Senator, took an Oath of Office, and if you do not at least give me an opportunity to discuss these matters with you or someone else, I will find a way to hold you accoutable for playing partisian politics. I have been interrogated in Austin Texas, in July of 2005 by 2Agents for the DOD Defense Intelligence Agency, and will not let this continue. Ever since Ibegan filing my Federal Civil Action in May of 2005 (052288), it has been a game of law enforcement engaging in a vigorius campaign to discredit me and my allegations, and most importantly, they have taken the Anti-SLAPP statutes of RICO to new heights.

I do not accept your reponse, your position, or your patisian politics.

I am begining to think that your staffer, Ms. Lisa Owings, was deliberatly positioned to meet me outside the Southern Market building before your talk on Crime, a few weeks ago, for some malicious reason.

I remain,

Stanley J. Caterbone

Advanced Media Group Stan Caterbone mailto: [email protected] www.amgglobalentertainmentgroup.com Fax: (717) 427-1621

Advanced Media Group 220 Stone Hill Road Conestoga, PA 17516

----Original Message Follows---- From: To: Subject: In Response to your message to Senator Specter Date: Fri, 23 Mar 2007 15:59:10 -0400

Dear Mr. Caterbone :


Compaq_OwnerCopy

MSN Hotmail - http://by104fd.bay104.hotmail.msn.com/cgi-bin/getmsg?curmbox=0000...

Thank you for your letter regarding legal matters. Unfortunately, the function of the Senate is primarily legislative, and we cannot intercede in matters which are under the jurisdiction of the courts.

While I know that our system of justice can at times be frustrating, I believe it is the finest system in the world, and I am confident that justice will eventually be served. In my role as a federal legislator and as Ranking Member of the Senate Judiciary Committee, I am working to improve the effectiveness of our system of justice and to ensure that our system continues to respect the rights of individuals and honor the rule of law.

I am sorry that I am not in the position to offer individual legal assistance, but I will keep your concerns in mind when relevant legislation is considered by the Senate. Should you have any further questions, please do not hesitate to contact my office or visit my website at www.specter.senate.gov .

Sincerely,

Arlen Specter


EXHIBIT D


[email protected]

717.427-1621 Fax


March 29, 2007

Harleysville Preferred Insurance Company Margery Lukens, AIC, AIS Claims Specialist Mid Atlantic Claims Service Center P.O. Box 1016 308 Harper Drive Moorestown. NJ 08057-0916 Fax 856-642-9415 Re: Follow up to Claim No. M0-702274 (Stolen Property) Dear Ms. Lukens:

I need to stress to you the importance of the stolen legal materials, evidence, and files that are part of my missing and stolen personal property.

On Tuesday, March 27th, 2007, the Supreme Court of the United States ruled on made it harder

for federal whistle-blowers to share in the proceeds from fraud lawsuits against government contractors. The False Claims Act allows individuals, acting on the government's behalf, to file fraud suits against companies that do business with the government. Business groups that wanted the court to limit whistle-blowers in false claims lawsuits cheered the outcome. Since Congress reinvigorated the Civil War-era law in 1986, those suits have returned $11 billion to the government. But Justice Antonia Scalia, writing in the 6-2 ruling Tuesday, said Stone was not entitled to recover any money because he lacked "direct and independent knowledge of the information upon which his allegations were based."

In case you are not aware, my civil actions in the Untied States District Court for the Eastern District of

Pennsylvania are the result of my whistle-blowing activities of 1987 against Lancaster defense contractor International Signal & Control, PLC (ISC). My documentation, fortunately, provides for evidence of direct and independent knowledge. There are (3) Federal Cases that are currently in litigation, they are 05-2288; 06-4650; 06-4734; and my Amici Curiae for case number 2006-2095/2006-2140 (ACLU v. the National Security Agency (NSA). This is why my property was stolen. Plain and simple.

I have been afforded continuances in most of my Federal Civil litigation until April 11, 2007; with the

exception of my Chapter 11 Bankruptcy Reorganization case, 05-23059; which requires a motions due at this time. I have also cases that require the same materials in the Pennsylvania Court of Common Pleas, the Superior Court of Pennsylvania (MDA 125-2006, MDA 435-2007), and the Pennsylvania Supreme Court (248 MAL 2007). The Pennsylvania State Courts have not afforded me Continuances, and I am in desperate need of these files. I also have to defend numerous summary criminal citations, the result of RICO Anti-SLAPP violations, that require these files for me to defend myself with all available elements of my defense. The criminal courts have afforded me all the continuances available.

Please review and add the attached materials to this case file.

I Remain, Stan J. Caterbone cc: Mr. Donald Totaro, Lancaster County District Attorney enclosures


Lancaster Online.com: Top Local News : Is Herley the next Chem... http://local.lancasteronline.com/4/2330

0

Homes | Cars | Jobs | Customer Care Center LancasterOnline KeywordGo

Home News Sports Business Entertainment Technology Health Weather Archives enEspaol Services

Classifieds Talkback eEditions Cars Real Estate Apartments Shopping Community VisitLancaster Personals Features

Celebrations Obituaries SpecialSections Columns Interests Advertisement

CustomerService

Subscribe

Is Herley the next Chem-Con or ISC?Manheim Township defense firm is 3rd here in 20 years accused of fraud.

By Tim MekeelLancaster New Era

Published: Jun 08, 2006 1:50 PM EST

LANCASTER COUNTY, PA - One localdefense contractor acted like it had bigoverseas contracts, putting emptycrates of inventory in warehousesworldwide.

A second local defense firm faked its own work records to show the production of boxcar-size Navy cargo containers was on schedule.

A third local defense contractor allegedly faked problems obtaining parts and making products, to justify the inflated prices it was charging.

Over the past 20 years, three defensefirms here International Signal &Control, United Chem-Con and nowthis week, Herley Industries havebeen indicted for fraud.

All were accused of orchestratingcharades to achieve the same goal pocketing millions of dollars.

But the alleged ruses were different. And whether the outcome of the cases is different as well remains to be seen.

Though the top executives at ISC andUnited Chem-Con pleaded guilty andserved years in prison, Herley and itschairman, Lee N. Blatt, have deniedany wrongdoing and say they willvigorously contest the charges.

The biggest and most complex of the three local cases involved ISC, once an apparently thriving firm that employed 1,800 here but then closed in the wake of the scandal.

A federal grand jury indicted 20individuals and companies in 1991 fortheir roles in ISCs $1.14 billionfake-contract scam, as well as a $50million scheme to smuggle weapons toSouth Africa.

Photos

Article ToolsLink to This Article Printer Friendly FormatOrder a ReprintEmail This ArticleRelated ArticlesMore Top Local News

Videos

Search LancasterOnline 6LancasterOnline Go

Newspaper Advertisements

GREAT FATHER'S DAY GIFT IDEA! Golf Mini-Saver at Lancaster Host Golf Club. For a limited time, only

$140. Click for details.

SPRING SPECIAL! All mulch wholesale cost at Thomas Trucking, Inc. Pick-up or Delivered. Click for

details.

ENTER TO WIN A $250 SHOPPING SPREE or an "EXTREME HOME

BAKEOVER". Click here for details.

FREE GAS CARD for all work scheduled by customers during June

at Martin's Excavating & Landscaping Services.

EARN CASH BACK and get a coupon for 15% off your next drycleaning

order from Clean Enterprises.

Click here for JUNE DINNER SPECIALS at T. Burk & Co. Deli

Restaurant.

RELAX...One call does it all! Clean Cut Design & Landscaping.

STOP Shaving, Waxing & Tweezing! Find out how, at, YOUR LASER

CENTER.

10-50% OFF at Bowman's Stove & Patio's 29th ANNIVERSARY SALE!

Click for details.

THIS WEEKEND at the Villa East Comedy Club. Jesse Joyce with Brian McKim, and your host, Pat

Lamb.

MarketplaceVisit the

Marketplace >>

Leola Village Inn/SuitesEnjoy A Romantic Weekend of Fine Dining & Shopping in Lancaster PA www.leolavillage.com

Lancaster HotelsStop Here First for Guaranteed Great Rates on Lancaster PA Hotels. www.OnlineHotels.com

PA Homes in Lancaster PaTools, Maps, and Photos Free and Unbiased Information www.Trulia.com

Welcome Edit


Compaq_OwnerCopy


CareCenter Place an Ad Advertising Contact Us Site

Site Map KeywordIndex RSS Feeds Need aWebsite?

ISC founder James H. Guerin pleaded guilty to eight counts of wrongdoing, admitting he orchestrated the crimes. He recently finished a 13-year prison sentence in Florida and returned to Lancaster County.

The fake contract scam was designed to portray ISC as a vibrant company, first so bankers would lend it money and later, so the British firm Ferranti, would buy it.

The decade-long scheme was remarkably detailed.

A Pakistani military man got a $250,000 bribe to say that ISC had a missile contract with his country. Fake missile contracts with that country, as well as the United Arab Emirates, China and South Africa, were drawn up, with forged signatures.

Supporting documents were fabricated, down to minutes from phantom meetings about the supposed contracts and invoices from imaginary suppliers.

Empty crates of inventory wereplaced in warehouses in Chile, Belgiumand South Africa, and a sham contractmanagement office in Greece opened,all for the benefit of Ferrantis auditorsand outside auditors.

Then, to support the illusion of all this business, ISC funneled hundreds of millions of dollars through a web of 47 front companies and 61 bank accounts around the world.

The scam at ISC was foreshadowed by the 1987 scandal at Chem-Con, a company which Guerin co-founded and was headed by president James B. Christian.

Again, an apparently robust defense contractor, with about 150 employees here, collapsed amid accusations of fraud. In 1988, the first indictments were filed. Ultimately, 15 people were charged.

Christian pleaded guilty to racketeering, tax evasion, mail fraud and conspiracy, serving 22 months on the federal charges. He then went to state prison to serve the rest of a two-year concurrent sentence for illegally dumping hazardous waste. He was released in 1991.

The heart of the Chem-Con case wasthe firms contract to make steel cargocontainers for the Navy. Chem-Conbilked the Navy out of $12 million in

James Street Strap Light #13

Olde Mill Lighting$160.00

Pineapple Dinner PlateOlde Mill House $11.00

14-kt. Gold & 1.0-ct. TW Diamond

Solitaire Earrings$1454.99

Camp Chef Outdoor Cooking Kit

$29.99

Advertise on this site

Ads by Google

Refinance Your

Mortgage

Get Low Refinancing Quotes From Top

Lenders Now. Free, No Obligation.

www.SmartMortgageUSA.com



payments and the companys leadbank, Meridian Bank, out of $3 millionin loans based on work it hadntperformed.

But it sure acted like it had.

In a blizzard of fake paperwork, Chem-Con submitted phony invoices, labor costs and production records to the Navy and the bank to hide the fact that it actually was behind schedule.

The containers, known as sea sheds,were made at Chem-Cons plant inRenovo, Clinton County.

Chem-Con used the same technique to hide the fact that a contract handled by its Lancaster plant, to make Army fuze cables, was being completed with a 90 percent failure rate.

Herley, with more than 300 employees here, and Blatt were accused this week of using another kind of fake paperwork to cheat the American military out of $2.8 million.

In a 35-count indictment, Herley and Blatt were charged with falsely inflating the prices that Herley charged the military for two components used in aircraft radar, giving Herley profits of more than 300 percent on them.

To support the prices, Herley and Blatt allegedly pretended that key parts would have to made in costly, alternative ways. Then, once its prices were accepted by the military, Herley allegedly reverted to the original ways.

The company and its chairman also allegedly fabricated expenses, including pretending to fund research for one component at Syracuse University and buying new production equipment for another.

Herley and Blatt also slowed or stopped production of early orders of the components, to pressure the military into accepting its prices on later orders, the indictment alleges.

Recent TalkBack comments about this article Comment on this article

Daisy Lee Myers06-08-2006

stock up today..

web link:

Herley Industries, Inc. (US:HRLY) - Stock Quotes - MSN Money

http://moneycentral.msn.com/detail/stock_q...ymbol=US%3AHRLY


January 23, 1997 Mr. Stan J. Caterbone 220 Stone Hill Road Conestoga, PA 17516 Ms. Christina Rainville 1300 Market Street Philadelphia, PA 19103 RE: Previously discussed matters. Dear Ms. Rainville: I thank you for your help regarding the enclosed materials. As I have discussed previously, I would appreciate your legal opinion as to the extent of my legal rights concerning the following circumstances. I will attempt to describe the many legal issues that are contained herein, and I have provided documentation substantiating my claims. Due to the complexity and sensitive nature of these issues, I have tried to reduce the paper to its simplest form, while also protecting the integrity of my claims. I have also provided authentic conversations, which I recorded merely in my defense as an accurate account of the activities surrounding my sudden demise. I possess many more forms of evidence, including over 9000 paper images that I had microfilmed in November of 1987. I realize that you offered to review only a few documents, however it was necessary to formulate the documents in a way that was sufficient to challenge the legal issues that I am questioning. Documents 1 & 2 would provide a glimpse into the legal merits of my claims. The following is an attempt to provide you with a brief description of the activities and actions contained in these matters. Please understand that I have not included any related activities that continued during 1991, especially concerning ISC and the Central Intelligence Agency (CIA). The following is a legend of the conversations contained on the Compact Disc: 2. 09/29/87 - A segment of the interview with the PA Securities and Exchange

Commission, Agent Howard Eisler, Attorney Robert Beyer, Client Millard Johnson, and myself, present.

3. 02/24/88 - Meeting with Attorney Sandra Gray, of San Diego, California. 4. 07/10/87 - Phone conversation with Chuck Smith, President of Lancaster

Aviation.

5. 07/07/87 - Phone conversation with Attorney David Drubner. 6. 07/21/87 - Meeting in Hollywood California with the owner of Gamillion Film

Studios, who was seeking my help to secure financing. Also present is Marcia Silen, a producer of the Digital Movie.

7. 10/27/87 - Telephone conversation with Pennsylvania Securities & Exchange


Compaq_OwnerCopy

Commission Agent, Howard Eisler.

8. 10/26/87 - Detective Boden, of the Pennsylvania Attorney Generals office. 9. 02/24/97 - ABC News 20/20 segment on International Signal & Control, and

Arms to Iraq. Please forgive the form of the following narrative, however it is especially draining to prepare these materials. This is the first time that I have attempted this task, with the exception of various efforts which were intended to merely defend myself, my person, my character, my reputation, or my assets. You will eventually discover that the question of my mental condition is of grave importance to my perpetrators. For the record, I do suffer from Bi Polar Mood Disorder, however, no where during all of these activities can anyone prove that I have acted irrationally or insane, the truth to my actions are well recorded, however the massive attack on my mental condition is proven to be centered around lies and hearsay. Any help pertaining to these matters, no matter how small, will be greatly appreciated. Please invoice me accordingly. The Background. Ten years ago I had built a financial firm, Financial Management Group, Ltd., (FMG). In 1985 I had conducted a marketing study that included interviewing more than 5 local physicians, all of substantial wealth or income. I had merely described my strategic plan for FMG, and they gave me feedback, all positive and enthusiastic. In 1986 I incorporated 11 different corporations, all under the ownership of FMG. To attract local talent, FMG was owned by not only the 3 principals, but stock was offered to every professional in the organization, including satellite offices. I had raised approximately $400,000 of capital to start the company, and I did it in compliance of the PA SEC Rule 144 Regulation D public offering. In one year, we had phenomenal growth. By June of 1987 we had invested approximately $50 million of client funds. We provided relatively most of the financial services necessary during ones lifetime. On the streets our organization was worth approximately $4 million, which is strictly correlated to the commissions paid out. We had at least 10 satellite offices, and covered 5 states. We also owned an interest in the PSG Broker Dealer, which was worth another $1.5 million. I was Executive Vice President and Secretary of FMG. I was President and Secretary of FMG Advisory, which was our Registered Investment Advisor (RIA). I had been pushing through the approval process with the Pennsylvania Securities and Exchange Commission for more than 6 months, concerning the RIA. In early 1987 I had developed a mortgage banking operation. I had negotiated with a large Southwestern mortgage firm to provide mortgages for Eastern Pennsylvania. Our lending capacity ranged from a minimum of $3 million and as high as $100 million. Even more important was the fact that this lending capacity was very and sometimes more competitive than other area lending institutions, I had shortly developed a very large list of clients for whom I was trying to secure financing for various types of projects. Combining the mortgage banking services with the ability of FMG to secure financing


through equity investment programs, I was very attractive the real estate community that had deals to finance. My second cousin, in Houston, TX, provided me with this opportunity. In the mater of 2 months, we had met not only with several large local developers, I had also begun business with companies located in more than 5 other states. I had provided a commitment letter for $5 million mortgage for Norris Boyd, of Boyd Wilson, for the Village of Old Hickory. Norris Boyd had personally informed me that I had a better deal than the Commonwealth National Bank (who will later illegally reposes my airplane), where the loan was currently secured. In February of 1987, because of our ability to raise capital, Scott Robertson requested that I assist him in visiting Power Station Studio, who was trying to secure financing for a movie. Reluctantly, due to the risk involved with motion picture investments, I went to Power Station Studios, in Manhattan. Tony Bongiovi built Power Station Studios to be among of an elite few. The names of stars that recorded there was very impressive. Tony also produced the sound track for Star Wars, which was very profitable, and still is. Another project, although controversial, was his cousin, Jon Bon Jovi. Power Station is where Jon Bon Jovi began his amazing career, under early development of Tony, his cousin. Contractual disputes ruined the relationship, which put large sums of money to risk. Jon Bon Jovi is one of the leading all time musicians, in terms of revenues. Tony described his project, which was not merely just a movie. Tony wanted to develop the first Digital Movie. Given my thirst for technology, along with a demonstrated knowledge, I became infatuated with the concept, the concept of providing the highest quality of sound, along with the highest quality of video. I had researched the merits of the technology, which complimented my own vision, and found a tremendously feasible project, one which would have the potential to have a major impact into the film and video industries. I had always personally believed that sound was as important as the picture for the truest sense of entertainment. The following documents will demonstrate my investment into this technology, along with my keen sense of perception. Today we call this Direct Broadcast Satellite DSS, which is currently causing the cable industry great pains. The consequences of digital technologies to the world of information is what now gives us the Information Highway, and all of its peripheral components. The following documents will easily confirm my interests to the preceding three businesses, FMG, the mortgage banking operation, and the Digital Movie project. The relationship to my partners was less than amicable. In developing FMG I agreed to let Mr. Robert Kauffman (Kauffman) act as President, upon the condition that we each own the same amount of stock. Mr. Michael Hartlett (Hartlett) did contribute to the early development of FMG. Since Kauffman could not control me, Kauffman and Hartlett would of attempt to buy me out, well after I created and incurred the most risk, and after the proven success of the organization. In the Spring of 1987, I had to personally take control of the Board of Directors to undue a merger that presented great risk to the company, and my investment. As part of our strategic plan, we agreed to purchase an interest in a Broker Dealer, rather than spending the capital and human resources in which it would require. I had personally traveled to Washington D.C., to visit this company, which was Kauffmans idea, and I literally found an empty shell. I found offices full of empty cartons, empy file cabinets, and this was the company that was responsible for processing all of the securities business that our brokers transact. This process was vital to our organization.


I immediately flew to Atlanta, GA, to visit another company, PSC, which had been courting our company for a relationship for almost a year. It was a company that provided technology, service, affiliates which accounted for several of the past presidents International Association for Financial Planners, of which I served as Vice President the Central Pennsylvania Chapter. (This association provided me with the national exposure to develop FMG.) In May of 1987, while traveling to a conference in Palm Springs, CA, the FMG Board of Directors approve the merger of PSG, I had voted via telephone from an airport in Chicago. The would be the last time that I would vote at an FMG Board of Directors meeting. This is when I loose virtually everything that is vital to a businessman, my assets, excellent credit rating and my spotless reputation, my professional designations and licenses, the opportunity to continue the vast business opportunities that I have developed, and most painfully, my dignity --- all without merit or reasonable cause. June 23, 1987 10:30 am. I have a schedule meeting with Mr. Larry Resch and Mr. Carl Jacobson,both of International Signal & Control, (ISC) and United Chem Con. The meeting was to discuss different financial deals. Upon arriving, Mr. Resch disclosed to me that they had to fly Carl out of the country this morning, he will not be here. I remember that there was a lot of names and places, all over the world, that mentioned. During our discussions, I had become annoyed at something, so I began making assertions that ISC and Mr. James Guerin was involved with fraudulent activities. I further described some of those activities. I did not know that Mr. Resch was as close to Mr. James Guerin as you could get. At approximately 3:00 that same afternoon, I had Russell Locksmith company change the locks to my office door. Between my partners and ISC, I apparently became concerned. 2 Days later, on June 25th, via telephone, Mr. Kauffman carelessly reported that 2 stock certificates were issued, without my authorization. First, I, acting as Secretary ,I must authorize and issue stock certificates, in accordance to the Articles of Incorporation. Secondly, Kauffman and company must have burglarized my office to gain access to the corporate records, which were under my custody, as defined in the Articles. Several days later, during the night, I had went into my office and removed all of my files, and upon finding a forged stock certificate with another Board of Director signing as myself and as Secretary, which violated several bylaws of the Articles of Incorporation. The next day I went to the office of my attorney, Mr. Joseph, who advised me to return all of the corporate files, and essentially suggested that I go home and get


some rest. Mr. Roda would later represent Mr. William Clark, corporate legal counsel for ISC against Mr. James Guerin in contract dispute for several million dollars. That afternoon, I loaded all of my files into my airplane, to transport to Stone Harbor NJ, where I was renting another house for the Digital Movie project. I had secured pilots from Romar Aviation to transport the files early the next morning. I had driven to New Jersey that evening. That next morning, the pilot that I had hired to fly my plane, telephoned me and informed me that my plane was repossessed and locked in a hanger, and he would not be able to deliver my files. Those files were the only means of substantiating the truth in order to protect myself from whatever was happening. My first payment to Commonwealth National Bank, was not due for another month. In short, I finally found a pilot at the Cape May Airport to fly to Lancaster to my files.He returned hours later with my files, and would only mention some incident involving a gun. Later I would be told that he died a mysterious death the next month. Not knowing that Commonwealth National Bank, the same bank that I was about to transfer $5 Million mortgage to my mortgage operations, had actually repossessed my titled airplane in the middle of the night. And conveniently with all of my files aboard. What bank repossesses legitimate possessions in the middle of the night? This will be the end of my life as I know it, I had demonstrated my success, my reputation was exemplified through my ability to develop FMG, and my financial credit was flawless. In the following months, I will suspiciously loose everything; including my assets, my business interests, my reputation, my credit, and the most valuable of all, my opportunity; and ultimately, my dignity. In reality, I was never even given the chance to fail. I will contend, and prove, that all of the actions were without merit and many of which were fraudulent themselves, and I know that I can substantiate that statement. According the Articles of Incorporation, I was never legally removed as Secretary, or any other official duties. Because, there cant be a Board of Directors Meeting without me, the Secretary. The record in the preliminary hearing transcript clearly proves that there was no legal Board of Directors Meeting that removed me. I never resigned from any positions or official duties of FMG, nor was I ever officially and legally removed from the same. I was a Tenant, with a $500,000 personal guarantee attached to the lease of FMG, Ltd. The forgery of stock certificates violated the bylaws of the Articles of Incorporation, thus, as Secretary, my duties were to safeguard the corporate records. The evidence indicates that all of the arrests were fabricated, the airplane repossession was illegal, and all of the allegations of insanity were malicious.


In September of 1987, in the Report to the Board of Directors of Ferranti International, raised a question of substantial risk, unlike that of which Ferranti was accustomed. The report cautioned any alliance due to the related CIA activities connected to ISC, and the lack of stability of the customers (Iraq?). At that same time, I was making public allegations against ISC. My conversations posed considerable risk to those connected with the pending deal with Farranti. I can substantiate my claim that; everything that transpired during the days immediately following the forged stock certificate, of FMG, Ltd., stock on June 25, 1987 was illegal and violated several of the bylaws of the Articles of Incorporation I was the only officer that was in compliance with the bylaws of the Articles of Incorporation, and the only officer that did not violate criminal codes. I can substantiate my claim that I had an interest in Digital Technologies, including patent research from Mr Joel Goldhammer, of the law firm of Seidel, Gonda, Goldhammer & Abbott, P.C. of Philadelphia, which violated several statutes of intellectual property rights. I can substantiate my claims that all of the arrests and hospitalizations were malicious and illegal, violating several of my civil rights. I can substantiate my claim that my allegations of fraud within International Signal & Control, Plc., were motive for many of my perpetrators. I can substantiate my claim that the Pennsylvania Attorney Generals Office, and the Pennsylvania Securities and Exchange Commission; aided and abetted in the sale of Arms and Technologies to Iraq, by virtue of the fact that I made formal complaints involving the same, and both agencies violated my constitutional rights to suppress the truth of my complaints. I can substantiate the legal validity of the recorded conversations for my defense. My interests in Digital Technologies, and my demand to be restored to whole, is the matter at hand. I Remain, Stan J. Caterbone Enclosure CD-ROM


Los Angeles Times: Archives http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...

1 of 19 6/4/2005 9:58 AM

MEMBER SERVICES SIGN UPJoin now!ARCHIVES HOME | HELP

NEWS ENTERTAINMENT OTHER SECTIONS CLASSIFIEDS JOBS CARS HOMES RENTALS SHOPPING nmlkji Site nmlkj Web Go

ARCHIVESBasic SearchAdvanced SearchSaved SearchLogoutAccount & PurchasesKnowledge CenterArchives Trouble Reportlatimes.com Site ServicesARCHIVES HELP &INFOAbout the ArchivePricingTerms of ServiceSearch TipsFAQStories Prior to 1985ObituariesRights and PermissionsOTHER SERVICESProf. Research ServiceBack IssuesFront Page ReprintsCommem. Front PagesBooks

Start a New Search | Back to Results Printer-Friendly Format

COLUMN ONE; A Bitter Lesson for Lancaster County; Judge says Pennsylvania community 'lost its soul' in push to convict woman of murder. Residents claim he, not they, are mocking justice. Right or wrong, his ruling challenges U.S. court system's balance of power. Series: * Second of two parts; [Home Edition]BARRY SIEGEL. Los Angeles Times. Los Angeles, Calif.: Nov 10, 1997. pg. 1

Full Text (8866 words)

search

JOBS CARS HOMES RENTALS

MORE CLASSIFIEDSSALES & DEALSBUSINESS DIRECTORYCoupons | Newspaper AdsPLACE AN AD


Compaq_OwnerCopy


2 of 19 6/4/2005 9:58 AM

Custom ReprintsPhotosOTHER RESOURCESOther ArchivesMicrofilm

(Copyright, The Times Mirror Company; Los Angeles Times 1997 all Rights reserved)

By midmorning on the first day of Lisa Michelle Lambert's federal habeas corpus hearing, U.S. District Judge Stewart Dalzell already could be seen displaying alarm over what he was hearing.

From the lawyers' briefs alone, he'd read enough to persuade him to grant Lisa's request for this uncommon federal review of a state murder conviction. He'd read enough to suspect that just possibly,Lisa Lambert, although sentenced to life without parole, hadn't killed Laurie Show over a teenage romantic rivalry. He'd read enough to surmise that just maybe, Lisa's boyfriend, Lawrence "Butch" Yunkin, along with a girl named Tabitha Buck, had killed Laurie.

Now, he was listening to evidence that served only to deepen his concerns regarding Lancaster County's prosecution of Lisa.

It was March 31. Computers, boxes of documents and piles of papers filled the small hearing room on the fifth floor of the federal courthouse in downtown Philadelphia. Lisa's parents sat in the first row, Laurie Show's behind them. Reporters and court personnel occupied the jury box. On the stand, an expert witness for Lisa's side, Northwestern University speech professor Charles Larson, was testifying.

Contrary to the autopsy report, Larson believed--as did three emergency medical technicians and the Philadelphia medical examiner--that Laurie Show's left carotid artery had been severed by whoever slashed her throat. This, he explained, left her unable to say "Michelle did it," as Laurie's mother, Hazel, had claimed. Her vocal tract was "destroyed," her left brain hemisphere "dying." She was "totally incapable of speech."

How, asked Lisa's attorney, Christina Rainville, could two doctors have signed an autopsy report saying that the carotid arteries weren't "involved"?

Those two doctors were both Lancaster County physicians, one the part-time coroner, the other an ear-nose-and-throat specialist.

"I don't think they were telling the truth," Larson replied.

Dalzell peered over gold wire-rimmed bifocals at the witness. "Oh," he said. "Well, OK."

So it went, hour by hour, for 15 days.

That this hearing was even being held appalled most in Lancaster County, about 75 miles west of Philadelphia. In the 1991 killing of Laurie Show, Lisa had already been found guilty of first-degree murder, Tabitha Buck of second-degree, Butch Yunkin of third-degree. Now here was Lisa, claiming her innocence, claiming all sorts of prosecutorial abuse. Now here was Lisa, seeking a federal order freeing her because the state had illegally imprisoned her.

For Lisa to cast herself as an innocent victim was maddening enough. For a federal judge to take her seriously was unimaginable. Yet that was just what was happening in this Philadelphia courtroom.

The second day of the hearing found Dalzell puzzling over two quite different versions of a videotaped police search of the Susquehanna River. The one initially provided by the Lancaster County district attorney, eight minutes long, had no soundtrack, and no images of police finding a pink bag Lisa said she'd thrown there. The second, obtained through discovery only after Rainville realized she'd been sent an edited tape, was four minutes longer. It had sound. It also had an officer kicking at a pink



3 of 19 6/4/2005 9:58 AM

bag while another asked, "What do you got, a bag?"

After watching these tapes, Dalzell removed his glasses and rubbed his eyes, something he'd do more than once during the three-week hearing. He studied Lisa, also something he'd do more than once, especially in the hearing's early days. Lisa, sobbing off and on, was staring down at the table where she sat, bent over, her hands between her legs. Dalzell looked as if he were trying to fathom her character.

The third day found Dalzell puzzling over Lisa's initial statement to the police. He listened to East Lampeter Police Det. Raymond Solt try to reconcile the typewritten first page, where Lisa says she wore her own clothes at the murder scene, and a handwritten last page where Lisa says she wore Butch's sweatpants. He listened to Solt explain how he destroyed all his notes from the interview. By the time Solt stepped down, the judge was referring openly to "Ms. Lambert's alleged statement."

With Det. Ronald Barley on the stand later that afternoon, Dalzell grew even more openly dissatisfied. Barley was a well-regarded detective in Lancaster County. A "very thorough investigator" is how Ted Darcus, chairman of Lancaster's City Council, considered him. Barley "dealt well with people in our community accused of crimes." Yet this wasn't apparent to Dalzell.

Barley, being questioned about the taped interview he helped conduct with Butch Yunkin--a tape full of laughter, clicks and obvious gaps--kept waffling so much that Dalzell finally snapped: "Answer her question! Yes or no?" Rather than heed the suggestion, Barley grew even more evasive. Asked about a critical spot where the recorder clicked off, he denied even being in the interview room at that moment.

Dalzell had heard enough. He called a recess and ordered all the lawyers into his chambers.

"I want to know what is going on here," he told Lancaster County Dist. Atty. Joseph Madenspacher. "I'm hearing perjured testimony. . . . As we had with Det. Solt, {Barley} is contradicting his own statement. . . . My patience has just run out. . . . I'm afraid the commonwealth is allowing perjured testimony in federal court. . . . I'm being lied to. . . . This man gives me the unbelievably fantasti statement that suddenly he 'evaporated.' It's totally incredible, and I'm afraid I'm going to have to refer this, if this keeps up, to the United States attorney. . . ."

Madenspacher shifted uneasily. This hadn't been his case to try. He'd left the prosecution to his seasoned first assistant, John Kenneff. "I understand what the court is saying . . .," he replied. "I don't know what I'm going to do, but I'm going to do something."

Little changed, though, when Barley resumed the stand. He didn't recall his colleague, Det. Ronald "Slick" Savage, turning the tape recorder on and off. He destroyed his notes after taking Butch's statement.

"No, no . . . please answer her questions. Will you do that?" Dalzell interrupted at one point.

"You knew . . . because you took the statement?" the judge asked later. "Or did you disappear for that part? . . . Oh, do you have that ability to appear and disappear at will?"

By the time Barley tried to explain how he "completely forgot" they'd found a pink bag during the river search--a pink bag that Lisa told them contained Butch Yunkin's bloodied sneakers--Dalzell was beside himself. It helped his mood little when, with Barley still on the stand, Rainville moments later played the segment of unedited videotape that showed an officer kicking the



4 of 19 6/4/2005 9:58 AM

pink bag, then waving the camera off.

"No, that's not me," Barley said.

Rainville inched the videotape ahead a moment. "No, no ma'am."

Again she moved the tape forward. Now the man at the river could be seen clearly.

"That is me," Barley allowed. "I don't know why I waved at that point."

Dalzell again peered over his eyeglasses. "Who were you waving to? The record should reflect that the witness definitely waved directly at the camera. What in the world were you doing, if you weren't waving to the camera?"

Barley looked blank. "I don't recall, sir."

Defendant Alleges Gang Rape

On the seventh day, Dalzell began to hear Lisa Lambert's story of being gang-raped by three policemen six months before Show's murder.

Lisa--her extravagant eye makeup toned down but still too thick for Rainville's taste--had started testifying the previous day. Now she described being stalked by an officer named Robin Weaver, of vainly calling his police chief to complain, of receiving threatening calls after the alleged attack. She explained how fear had kept her from telling this story before. Finally, she explained why she now was willing to talk.

In a deposition given to Lisa's attorneys before the hearing, Weaver, without being asked, had referred to the gang-rape accusation. He thought Lisa had cited it in her habeas petition, but she had not. The charge had never been raised publicly. To Lisa, Weaver's comment, therefore, provided independent proof of her claim: "There is no way that he could have ever known about that unless he was there and he did it. It was not raised in the petition."

Dalzell interrupted: "Is that true?"

"That is true, your honor," said Rainville, who had been appointed by the judge to represent Lisa on a pro-bono basis.

Dalzell again had heard enough: "We'll take another recess. . . . I want {Weaver} here this afternoon, and I don't want anyone to say a word about what has come up here. If he resists, please tell me. I will have the marshal arrest him, OK?"

Moments later, Dalzell learned that prosecutor John Kenneff already had discussed the rape allegation with Weaver.

"So he's been coached . . . ," Dalzell exclaimed.

The judge's budding animosity toward Kenneff was palpable. The prosecutor had not yet appeared before him, but the residue of his work at the Lambert trial was everywhere.

"I'm going to direct that Mr. Kenneff have no further contact with any witness in this case. . . ," Dalzell declared. "And he might want to consult with counsel. . . . I'm going to want to hear about this, because in the context of this case, Mr. Kenneff, God help



5 of 19 6/4/2005 9:58 AM

him, if he coached this witness. God help him. . . . Mr. Kenneff, at his election, should retain counsel for proceedings that may follow this one."

On the witness stand that afternoon, Weaver absorbed the full brunt of Dalzell's rancor. The judge grilled him: Have you talked to any human beings? You understand you're in federal court? You understand the laws of the United States apply? You understand you're under oath?"

Weaver said he did, and then denied any involvement in a rape of Lisa Lambert. Dalzell, though, wasn't finished.

Weaver had been among the first on the murder scene. It was he who'd initially questioned Hazel Show, and it was he who had written the police report. Yet, nowhere in it had he indicated that Hazel Show heard her daughter make a dying declaration about Lisa. Nor had he done so in a final report written three weeks later.

"Yes or no," the judge demanded. "Did you hear Hazel Show report a dying declaration?"

"I don't remember. . . . " Weaver replied. "She could have or she may not have."

"Is it your testimony that you would not have put it in a report if Hazel Show had told you about a dying declaration, that you would not have put it down in that report? Is that your testimony? Yes or no?"

"No."

"So the fact that you don't make reference to a dying declaration, is some evidence that she didn't tell you that. Correct?"

"You can infer that, yes, sir."

"Oh," the judge said. "I could infer it. Could I infer anything else from that?"

Mounting Anger Among Citizenry

Day by day, watching from afar or from a courtroom seat, the citizens of Lancaster County grew ever more amazed and furious as the Lambert hearing unfolded. This is shocking us, they declared. This is shaking our confidence in the American judicial system.

What troubled them, though, were not the revelations coming out of Dalzell's courtroom. It was, rather, Dalzell's conduct.

The judge was "making the county look bad." The judge sounds as if he "revels in publicly humiliating Lancaster County."

Most irksome of all was the judge's handling of Lancaster County authorities. He was "discourteous" to the police officers and John Kenneff. He sighed and rolled his eyes and looked at the ceiling as they testified. He interrupted with his own questions, as if to assist the defense. He acted as if he didn't believe them.

Many in Lancaster County just couldn't fathom such an attitude. The police and prosecutors were their neighbors, their friends, their protectors. They couldn't possibly manipulate evidence. They couldn't possibly lie.

By midway through the hearing, a certain tone of frantic fear could be heard in the county's response. Don't believe the "lies and



6 of 19 6/4/2005 9:58 AM

untruths" being aimed at our police, urged East Lampeter Supervisor Chairman John Shertzer. Don't "rush to judgment." It's "unfortunate that so much is being made of such insignificant points."

In his opening statement at the hearing, Madenspacher, the district attorney, had allowed that the investigation hadn't been "perfect," that maybe they'd been a little "careless," maybe a little "sloppy." Others, though, refused even to acknowledge that much. All sorts of citizens instead continued to offer glowing tributes to the police and prosecutors.

No one official drew more accolades than did John Kenneff. He is a big, heavyset man with a full, broad Irish face. Growing up in Lancaster County, Kenneff was considered a fine schoolboy, a high achiever. Not Harvard-level material, but his college, Villanova University, was nonetheless a good school. Not as good as the University of Pennsylvania, but the next step.

He'd come back after law school, opened a private practice, worked his way up through the D.A.'s office. He came to all the Fourth of July picnics; he brought his family, he brought his dog. He was known as a committed, persistent prosecutor, one of the fairest and most reasonable in the county.

Even the defense attorneys who went up against him said as much. Even they called him a decent, honest guy. To Terry Kauffman, a dairy farmer and chairman of the board of county commissioners, that particularly carried a lot of weight: "A lot of people I know here, from both sides of the aisle, say he's the best. I know them, and I've known Jack Kenneff for years. I don't know Stewart Dalzell."

Darcus--the chairman of the Lancaster City Council, a black man from West Virginia who followed a Boys' Club job to Lancaster 30 years ago and happily settled--believed he possessed an especially close take on John Kenneff's character. They'd been involved together in a "Weed and Seed" anti-crime development program in Lancaster's minority community. So Darcus saw Kenneff not just as a prosecutor, but a community leader. Also as a father: Kenneff's children went to the same Catholic school as Darcus' son.

"I've seen how he cares about people," Darcus said. "I've seen him deal with people in my community. I've seen him go beyond what was needed. Knowing Jack Kenneff, I just can't picture this man doing what the judge says. I wonder how that judge sleeps at night."

Denials From the Prosecutor

No, John Kenneff insisted. No, he didn't think Butch Yunkin's sweatpants were a critical issue at the murder trial. No, he had no recollection of looking at the sweatpants the state put into evidence.

It was April 15, the hearing's 11th day. Kenneff had taken the witness stand soon after court convened. Questioning him was Peter Greenberg, Rainville's husband, a partner at their law firm and one of Philadelphia's most-accomplished litigators.

At the trial, the state's theory of the murder had Lisa wearing Butch's extra-large men's sweatpants, found full of blood in a dumpster after the attack. Trial judge Lawrence F. Stengel accepted this theory and thought it significant. So Kenneff's answers now caused Dalzell to lean forward.

"Did you make a conscious judgment at trial as to who was wearing the clothing that you put into evidence?" Greenberg asked.

"It was my understanding that Miss Lambert had admitted to wearing the clothing . . . ," Kenneff replied.



7 of 19 6/4/2005 9:58 AM

Dalzell interrupted: "I don't think that's the question he asked you. And I think you ought to listen more carefully to Mr. Greenberg's questions because I don't think you're answering them. . . . That question can be answered yes or no."

So it went through much of the morning. Lancaster County citizens were right: Dalzell by then couldn't hide his dismay for their assistant district attorney. The moments when the judge removed his glasses and rubbed his eyes were adding up.

For 10 days he'd been exposed to an ever-more disturbing portrait of how Kenneff had prosecuted Lisa Lambert. He'd listened to the pathologist Isidore Mihalakis--a defense witness at Lisa's murder trial--describe private conversations with Kenneff that Dalzell thought constituted witness-tampering. He'd heard how authorities had concealed critical testimony by Hazel Show's neighbor Kathleen Bayan. He'd been presented evidence that convinced him the state had "lost" an earring of Butch's found on the victim's body. He'd been presented evidence that convinced him the state had edited critical video and audiotapes.

Now the man who oversaw the state's efforts sat before Dalzell on the witness stand.

No, Kenneff was testifying. He didn't recall looking at the river-search video.

"You didn't think it worthwhile to look at the video?" Greenberg asked.

"I didn't think what happened at the river was a contested issue," Kenneff replied.

This time, Greenberg snapped before the judge could: "You've been in this business long enough to know that when I ask a question you're supposed to answer it?"

"Right," Kenneff agreed.

Dalzell joined in now: "It would be nice if you would do that. . . . I want to warn you, sir, that, if you don't do that, you are going to put me into a position where this will have to get unpleasant. Do you understand that? . . . The record should reflect that you have been consistently unresponsive to the questions. . . . "

Greenberg turned back to the matter of Butch's sweatpants. Now, Kenneff has even resisted saying he based the case on the theory that Lisa wore Butch's clothing. He no longer, in fact, was sure whether the sweatpants were Butch's.

The pair he'd produced for the habeas hearing, after all, were much smaller than men's extra-large. "The sweatpants would have looked ridiculous if worn by 6-foot-1-inch-tall Butch," Kenneff had argued in a written response just before the hearing.

"You are the same person . . . " Greenberg asked, "saying that the sweatpants would have looked ridiculous on Butch, who put Butch on to testify in Lisa's trial . . . that they were his sweatpants, these very same sweatpants that would have looked ridiculous on him?"

"Correct."

"These are the same sweatpants that Judge Stengel found belonged to Butch?"

"Correct."



8 of 19 6/4/2005 9:58 AM

"And if you had your way, Lisa would have been executed based on that evidence, wouldn't she?"

Kenneff hesitated; Dalzell spoke: "Yes or no," the judge ordered.

"That would be correct."

Greenberg erupted: "Do you think this is some kind of game? . . . Do you realize that there is a human being sitting here who is in jail serving a life sentence based on the evidence you put on . . . that you are now disowning. . . . Not only are you disowning it, you are committing perjury. . . . Are you sure it is Miss Lambert who is a dangerous person in this courtroom?"

Handling of Letter Infuriated Judge

In the end, the commonwealth's handling of the controversial 29 Question Letter was what most inflamed Dalzell.

Lisa had written Butch from jail, asking a series of questions. The answers Butch had scrawled under each question, the judge felt, left no doubt that he was the murderer of Laurie, and that his accomplice was Tabitha Buck. That the letter was authentic seemed equally certain to Dalzell: Both the state and defense experts had affirmed there'd been no alteration.

Yet, Kenneff--after stipulating to the experts' opinions--had let Butch testify at Lambert's trial that the questions were altered. That the prosecutor knew his witness was committing perjury appeared obvious to Dalzell. At Butch's plea-bargain hearing after Lisa's conviction, Kenneff wanted to revoke their deal precisely because of this perjury.

Experts had reviewed the 29 Questions Letter and Butch's trial testimony, Kenneff told the judge at that Oct. 10, 1992, hearing. "They advised us that his testimony . . . regarding that {letter} that was false . . . . It is our opinion that he testified falsely . . . on that basis we feel we are entitled to withdraw from the original plea agreement."

There just was no ambiguity, Dalzell felt: Kenneff knew that Butch committed perjury on a material issue, regarding a document that established Lisa's innocence.

Under such circumstances, Dalzell believed Kenneff had an unambiguous ethical obligation to take remedial action with the court that convicted Lambert. The Pennsylvania Rule of Professional Conduct was clear about this: "A lawyer shall not knowingly . . . offer evidence that the lawyer knows to be false. If a lawyer has offered material evidence and comes to know of its falsity, the lawyer shall take reasonable remedial steps."

Yet far from complying with this rule, it looked to Dalzell as if Kenneff had encouraged Judge Stengel to accept Butch's perjured testimony. "I think he's just like any other witness," Kenneff told Stengel when Lisa's attorney moved for a mistrial based on Butch's perjury. "You can believe some of it, all of it, or none."

It was worse than that, in Dalzell's eyes. For, after obtaining a conviction based partly on this perjured testimony, Kenneff had coolly proceeded to seek the death penalty for Lisa Lambert.

Now, remarkably, Kenneff at this habeas hearing--and in written responses that looked to Dalzell to be blatantly false--was back to arguing that some of the 29 questions had been initially written in pencil, then altered. In other words, Kenneff, before Dalzell, was defending testimony by Butch that he had told two other judges was a lie.



9 of 19 6/4/2005 9:58 AM

"Do you want to take remedial actions with Judge Dalzell?" Peter Greenberg asked.

Here the judge interceded: "I was just going to ask that myself. . . ."

It was the morning of April 16, the hearing's 12th day. Kenneff had been on the stand for hours.

"Well, your honor," Kenneff responded. "I think I still feel the same way about the 29 questions. . . . That there is some type of tampering with it. . . . "

"No, no, no, sir," Dalzell interrupted. "I am going to jump in here. You said in your answer to me that there was pencil. And you have testified under oath here that your expert and the defense expert said there was no graphite. . . . "

"Judge," Kenneff began.

Dalzell spoke over him: "I want to warn you, sir, you are under oath, and you are subject to the rules of professional responsibility. . . . Do you retract that statement that you signed . . . as to pencil? Yes or no?"

"I just don't think I can answer that question yes or no, judge."

Dalzell turned to Madenspacher, Kenneff's supervisor. "Does the commonwealth retract it?"

Madenspacher rose. "Yes, your honor. We retract it."

"Thank you," Dalzell said. He turned back to Kenneff. "Your boss just retracted it. Next question."

Their confrontation hadn't peaked yet.

The climax came minutes later, when Greenberg began listing all the pieces of evidence that the district attorney's office kept from Roy Shirk, Lisa's attorney at her trial. What if Shirk had the names of the emergency medical technicians? What if he knew the police had found a pink bag? What if he had the unedited river-search video? What if he knew a neighbor had seen Butch at the crime scene?

"Well," Kenneff tried to answer, "the Pennsylvania Rule provides for certain . . . "

That's as far as he got. Dalzell exploded: "No. Excuse me. We're talking here--let me just make something clear to you. We're talking here about something called the United States Constitution, and in particular the 14th Amendment thereof, which has a clause in it that refers to due process of law. OK? Have you heard of that?"

"Yes sir."

"That's what we're talking about. . . . So we're not talking about the Pennsylvania Rules of Criminal Procedure. We're talking about due process of law here. . . . That's what we're talking about here. You got it? Do you understand?"

"Yes," Kenneff replied.



10 of 19 6/4/2005 9:58 AM

Biggest Drama Begins to Unfold

As it happened, the confrontation between Dalzell and Kenneff was neither the most dramatic nor revealing sequence to occur on this 12th day of Lisa's habeas hearing. The event that would eclipse it began only after Kenneff left the witness stand, and court adjourned for lunch.

Madenspacher, walking toward his hotel, bumped into Hazel Show's brother, who reported that his sister needed to talk to him. Back at the Holiday Inn in downtown Philadelphia, where both were staying, Madenspacher walked up to Show's room.

Sobbing as she talked, the murder victim's mother told him her story.

During the hearing that morning, she'd suddenly recalled the morning of the murder: As she drove up Black Oak Road to her condo, on her way to find Laurie's body, a brownish-colored car passed, heading out of the condo complex. It was Butch's car. She looked at Butch. There was recognition on his face. He pushed down someone with blond hair. There was also a third person in the back seat, with black hair.

She'd told this to Det. Ron Savage back then. Savage had come to her house saying one of her neighbors had seen Butch's car leave the complex. She'd started to say she had too. Savage had stopped her, told her not to dwell on that. They had so many wi

federal civil action v lancaster county judicial addendum to complaint march 30 2007 amended...

Documents

manor street lancaster

fremont street lancaster

locust street lancaster

north duke street lancaster

lancaster newspapers

north queen street lancaster

lancaster county office

west king street lancaster