joan lichtmanPlaintiffTwo Penn Center, Ste. 1110Philadelphia, PA 19102

joan lichtman : Commonwealth of Pennsylvania: County of Philadelphia

Plaintiff :: Civil Action

v :: February Term 2015

Jewell Williams : Docket no. 01231in his personal and professional capacity :

Sheriff, Philadelphia :Land Title Building :Philadelphia, PA 19110 :

:Defendant :

COMPLAINT

Plaintiff, joan lichtman, an individual, seeks Jewell Williams, the Defendant, to obey and to uphold

the Law, his specific performance, and damages, (compensatory, in excess of $50,000, punitive, et al.) in

amounts to be determined at trial, as well as relevant legal proceedings, which may include prosecution and

incarceration, to the fullest extent allowed by law, and Sheriffs loss of his job and pension.

1. Defendant is Sheriff of Philadelphia County.

2. On 16 June 2008, Defendant executed a Writ of Possession and physically removed Plaintiff from

Plaintiffs home.

3. Sheriff simultaneously seized Plaintiffs home, as well as all of Plaintiffs personal, professional, private

and intellectual property, including private papers, and all others of Plaintiffs assets, including

Plaintiffs business equipment, inventory, and means of livelihood, which were contained within the

Filed and Attested byPROTHONOTARY

13 FEB 2015 03:46 pmK. KALOGRIAS

2home1. The door lock was changed and the sole key was given to the manager of the building to protect

Plaintiffs property and assets from loss.2

4. Over Plaintiffs objections, Sheriff conducted an illegal real estate sale on 2 February 2010 of

Plaintiffs shares of stock (collateral interest) in the corporation, which owns the building, housing

Plaintiffs home3.

5. The Writ of Execution (Writ 266-663), represented by Sheriffs Distribution Policy, shows the expenses

of Sheriffs Sale, which are then deducted from the sale price, leaving the excess sale proceeds.

Sheriff received a cash payment, in full, for the 2 February 2010 Sale on/about 28 February 2010. The

excess sale proceeds, per Sheriffs Distribution Policy, are approximately $195,000.4

6. Despite Plaintiffs ongoing demands for payment of the excess sale proceeds, during the last five years,

Sheriff has refused to release one penny.

7. On behalf of Under-Sheriff Vignola, in February 2012, Sgt. Monte Guess offered to pay Plaintiff

approximately $35,000. Despite Sheriffs office having the information and paperwork, necessary to

make payment, Under-Sheriff Vignola has gone out of his way to prevent the check from being cut.

1 No judgment permitted Sheriffs seizure of Plaintiffs personal, business, intellectual property, private papers, and otherassets. Moreover, Philadelphia laws require that the landlord allow an evicted tenant access to tenants home, after a legaleviction, so tenant can remove the kinds of property which remained in Plaintiffs home, after 16 June 2008. The landlord, atthe illegal direction of the landlords attorney, ordered the illegal blockade of tenant from the building, altogother, includingthe exclusion of tenant from the buildings lobby and access to a locked United States Post Office mailbox. That is aFEDERAL FELONY. Plaintiff never changed her address. Plaintiff has never received any of the mail sent to that boxsince her eviction, six-and-one-half years ago. The building has since invaded Plaintiffs home without Plaintiffs knowledgeor permission. The building posted pictures of Plaintiffs home online which prove that some of Plaintiffs property remainsin the home, but most of Plaintiffs property was removed also without Plaintiffs knowledge or permission. The buildinghas also advertised online that the building has made physical changes to Plaintiffs home also without Plaintiffsknowledge and permission. Plaintiff has no idea what landlord did with Plaintiffs property and assets, illegally seized, norwhere that property went. That renders Sheriff accountable and liable for all of Plaintiffs property, given that Sheriffforcibly and physically removed Plaintiff from the home, changed the lock, and handed the key to the building management.Plaintiff has had no access to any of Plaintiffs seized home or property, since 16 June 2008.2 Management of the building has since changed, and that manager is no longer employed by the building.3 Plaintiff is a resident-owner of Rittenhouse Plaza, Inc. a housing Cooperative. Owners of the corporation are required to livein the building. That makes Plaintiff both a tenant and part owner of the building. Sheriff is prohibited from selling intangibleassets as if real estate. Sheriffs Sale of Plaintiffs home at a Sheriffs real estate Sale was legally impossible even thoughSheriff claims to have sold Plaintiffs home to the attorney who represented the building, seeking Plaintiffs (illegal) eviction.Sheriffs used a Writ of Execution to consummate the sale of Plaintiffs home. Sheriff then claimed to have registered a deedwith the City, supposedly representing the transfer of ownership. However, the registered owner of the building remains thecorporation, as required by law. As a matter of law, no deed of sale was or could be issued. Plaintiff remains the legaltitleholder to Plaintiffs ownership in the corporation. Therefore, Sheriffs Sale of 2 February 2010 was an illegal sham andconspiracy with the attorney, representing the building as to Plaintiffs, also illegal, eviction.4 Sheriffs Distribution Policy presumes that Sheriffs Sale was legal and that all the information as to the expenses is correct.As to this particular Sale, neither of those assumptions was true, and neither is borne by the facts and evidence.

38. On March 13, 2012, Plaintiff met with Under-Sheriff Joseph Vignola in his office. Alan Kurtz a

special consultant to Sheriff, who is paid by the City over objections by Alan Butkovitz, et al.,

because Sheriff failed to secure City approval was present for the entire meeting, and a witness.

9. During that meeting, Plaintiff forced Under-Sheriff Joseph Vignola to read and to discuss

Philadelphia Code, 9-1603 9-1605, which are criminal statutes, addressing unlawful eviction

practices. Under-Sheriff Vignola, in charge of Sheriffs real estate and accounting programs, is also

an attorney. Accordingly, Vignola has no excuse for refusing to obey and to uphold those statutes.

10. During that meeting, Vignola showed his possession of court documents, which prove that the

eviction Complaint was wilfully perjured by the attorney representing the landlord. Plaintiff asked

Vignola, in the presence of Kurtz, what is the legal requirement for a judge, who is presented with

evidence proving that a Complaint is perjured. Without hesitating, Vignola responded that the case

must be dismissed, because the court does not have jurisdiction.

11. Vignola was then forced to admit that Sheriff never had legal authority to serve and enforce the Writ

of Possession, by which Sheriff evicted this Plaintiff on 16 June 2008. Per the Philadelphia Code

statutes, which Plaintiff and Sheriff had just discussed at length, Vignola admitted that Sheriff was

required to reinstate Plaintiff into Plaintiffs home.

12. Since March 2012, Vignola has refused to obey Philadelphia Code, 9-1603 9-1605, by

reinstating Plaintiff into Plaintiffs home. Accordingly, Vignola has known, and still knows, that

Vignola is in criminal violation of the very laws, which Sheriff is supposed to obey and to enforce.

13. Sheriff Williams is ultimately responsible and liable for the operations of Sheriffs office and for the

conduct, including the misconduct and malfeasance, of Sheriffs employees.

14. Despite Plaintiffs long-standing demands that Sheriff Williams obey the law by reinstating Plaintiff

into Plaintiffs home and by Sheriffs releasing and returning all of Plaintiffs property, assets, and

moneys, illegally seized, stolen, and/or sold by Sheriff, under the invalid Writs of Possession and

4Execution, Sheriff wilfully continues Sheriffs criminal refusals to comply with the law, which the

public servant Sheriff is publicly paid to obey.

15. When illegally seizing, stealing, and/or subsequently selling everything Plaintiff owned, as a result

of Sheriffs illegally and forcibly removing Plaintiff from Plaintiffs home on 16 June 2008, Sheriff

knowingly, wilfully and deliberately walked Plaintiff out of Plaintiffs home, out of the building,

and literally left Plaintiff in the sewers of the City of Philadelphia, literally to die: homeless,

destitute, with no place to go, no way to get there, and not even enough money to buy supper. That

is a Death sentence.

16. As a result of Sheriffs illegal eviction and seizure, theft, and sale of everything Plaintiff owned,

Plaintiff has been, and remains, an adjudicated pauper in Pennsylvania courts.

17. Plaintiff is lucky to be alive. Plaintiff was literally rescued from Philadelphias sewers by Good

Samaritans, who provided Plaintiff shelter and food, while Plaintiff continues to demand the return

of Plaintiffs property, assets, moneys, and home.

18. No more charity nor loans are available to Plaintiff, and Sheriff still refuses to make payment of the

excess sale proceeds and to return Plaintiff to Plaintiffs home.

19. Accordingly, Sheriff knowingly, wilfully and deliberately is criminally withholding property which

does not belong to Sheriff and without which Plaintiff cannot survive: i.e., Sheriffs conduct proves

Sheriffs intent to secure Plaintiffs engineered untimely Death.

WHEREAS the above, Plaintiff demands the immediate return of Plaintiffs property, home, assets,

and moneys, protection for Plaintiffs physical and financial safety, and damages, as well as Sheriffs

loss of pension, and prosecution of Sheriff to the fullest extent allowed by Law, and other remedies,

determined by the court.

Dated: 3 February 2015 _________/s/___________joan lichtman, Plaintiff

5joan lichtmanPlaintiffTwo Penn Center, Ste. 1110Philadelphia, PA 19102

joan lichtman : Commonwealth of Pennsylvania: County of Philadelphia

Plaintiff :: Civil Action

v :: February Term 2015

Jewell Williams : Docket no.in his personal and professional capacity :

Sheriff, Philadelphia :Land Title Building :Philadelphia, PA 19110 :

:Defendant :

MEMORANDUM OF LAW

As Sheriff of Philadelphia, a law-enforcement officer in the Commonwealth, Defendant is required

both to obey and to uphold the law. Among Defendants duties is service and enforcement of Writs of

Possession.

In the event of a legal judgment of eviction from the courts, Sheriff performs the eviction and may

seize/sell property to pay a money judgment. After an eviction, Sheriff may conduet a Sheriffs Sale to pay

the judgment creditor. If the proceeds from the sale of property exceed the amount of the money judgment,

Sheriff is required by law to pay the excess sale proceeds to the property owner.

If an eviction judgment is void, or otherwise illegal, Sheriff is required to reverse enforcement of

Writs, which derived from the improper judgment.

Sheriff is in criminal violation of Philadelphia Code, Ch. 9-1600, entitled Prohibition against

Unlawful Eviction Practices. Per 9-1605, each day Sheriff refuses to reinstate Plaintiff into Plaintiffs

home, Sheriff commits a new crime. To date, the total of Sheriffs crimes is nearly 2,400 and still climbing.

Per the statutes, Sheriffs crimes carry fine and incarceration as penalties.

Sheriffs calculated engineered attempt on Plaintiffs life is unconscionable, given that saving

Plaintiffs life is Sheriffs PUBLICLY PAID DUTY.

6By conspiring and colluding in the underlying crimes, Sheriff Jewell Williams is a willing and

wilful party to, and a participant in, the criminal acts. Under the Pennsylvania Public Employe Pension

Forfeiture Act, Sheriffs conduct fits within the definitions and descriptions of prohibited acts under that

act, which qualify for pension forfeiture: to wit, from PUBLIC EMPLOYEE PENSION FORFEITURE

ACT, Act of Jul. 8, 1978, P.L. 752, No. 140

"Public official" or "public employee." Any person who is elected or appointed to anypublic office ...

7VERIFICATION

I, joan lichtman, do hereby verify the allegations set forth in the forgoing are true and correct to

the best of my knowledge, information and belief. I make this verification pursuant to the penalties of

18 Pa.C.S.A. Section 4904.

Dated: 3 February 2015 ______/s/___________joan lichtman, Plaintiff

8joan lichtmanPlaintiffTwo Penn Center, Ste. 1110Philadelphia, PA 19102

joan lichtman : Commonwealth of Pennsylvania: County of Philadelphia

Plaintiff :: Civil Action

v :: February Term 2015

Jewell Williams : Docket no.:

Defendant :

CERTIFICATE OF SERVICE

Plaintiff, joan lichtman, hereby certifies that service of this complaint was made upon Sheriff Jewell

Williams in keeping with the requirements of the electronic filing system of the Court of Common Pleas.

Dated: 3 February 2015 /s/ joan lichtman, Plaintiff