Professional Documents
Culture Documents
9:51 A.M.
Commonwealth of Pennsylvania
v.
Kathleen Granahan Kane
Appellant
CASE INFORMATION
Initiating Document:
Notice of Appeal
Case Status:
Active
Journal Number:
Case Category:
Criminal
Case Type(s):
Criminal Conspiracy
Other
Perjury
CONSOLIDATED CASES
RELATED CASES
Docket No / Reason
Type
Related
SCHEDULED EVENT
Appellant
Kane, Kathleen Granahan
Pro Se:
No
IFP Status:
No
Attorney:
Minora, Amil Michael
Minora, Minora, Colbassani, Krowiak, Mattioli & Munley
Law Firm:
Address:
700 Vine St.
Scranton, PA 18510
Phone No:
(570) 961-1616
Fax No: (570) 963-1691
Attorney:
Address:
Phone No:
Attorney:
Address:
Shargel, Gerald L.
Winston & Strawn, LLP
200 Park Avenue
New York, NY 10166
(212) 294-2637
Neither the Appellate Courts nor the Administrative Office of Pennsylvania Courts assumes any liability
for inaccurate or delayed data, errors or omissions on the docket sheets.
9:51 A.M.
Fax No:
Amicus
Caterbone, Stan J.
Pro Se:
Yes
IFP Status:
Pro Se:
Stan J. Caterbone
Address:
1250 Street
Lancaster, PA 17603
Phone No:
(717) 669-2163
Fax No:
Appellee
Commonwealth of Pennsylvania
Pro Se:
No
IFP Status:
Attorney:
Steele, Kevin R.
Address:
Montgomery County District Attorney's Office
PO Box 311
Norristown, PA 19404-0311
Phone No:
(610) 278-3098
Fax No:
Attorney:
Law Firm:
Address:
Phone No:
Fee Dt
Fee Name
04/21/2016
Notice of Appeal
Receipt No
Receipt Amt
2016-SPR-E-000686
Court Below:
County:
Order Appealed From:
Documents Received:
Order Type:
OTN(s):
CP-46-CR-0006239-2015
Lower Ct Judge(s):
Demchick-Alloy, Wendy
Judge
Neither the Appellate Courts nor the Administrative Office of Pennsylvania Courts assumes any liability
for inaccurate or delayed data, errors or omissions on the docket sheets.
85.50
9:51 A.M.
Filed Date
Content Description
None
None
DOCKET ENTRY
Filed Date
Participant Type
Filed By
Appellant
May 2, 2016
May 5, 2016
Commonwealth of Pennsylvania
Amicus
Caterbone, Stan J.
Amicus
Caterbone, Stan J.
Other
Neither the Appellate Courts nor the Administrative Office of Pennsylvania Courts assumes any liability
for inaccurate or delayed data, errors or omissions on the docket sheets.
:
COMMONWEALTH OF PENNSYLVANIA :
v.
KATHLEEN KANE
2. In support of any other relief this Court deems just and proper.
The following Amicus should provide this Court with the proper jurisdiction for legal standing
to consider this Amicus according to Rule 531 of the Pennsylvania Rules of Procedure.
Page 1 of 2
_____
Stanley J. Caterbone, Pro Se
Freedom From Covert Harassment and Surveillance
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com
scaterbone@live.com
(717) 669-2163
Page 2 of 2
COMMONWEALTH OF PENNSYLVANIA :
v.
KATHLEEN KANE
saying she is in a battle with the 'old boys' network' of Pennsylvania and the MOVANT has written
extensively about this same select group over the years beginning in 1998. In an interview with
Brian Taff of WPVI on February 16, 2016 the Attorney General is quoted as saying Everybody
Page 1 of 48
EXHIBITS.
Diary: Lancaster County, The CIA, and U.S. Sponsored Mind Control,
http://www.opednews.com/populum/diarypagem.php?f=Lancaster-County-TheCIA-by-Stan-Caterbone-091125-169.html
In addition the MOVANT wrote to the ATTORNEY GENERAL on November 12, 2015 and
stated the following Back in 1998 I had a meeting with an NSA (National Security
Agency, Ft. Meade, Md) operative in a parking lot of a former car dealer in York, PA. I
had just attended a job fair and he approached me as I was about to get into my car.
He introduced himself as being from the NSA and I questioned him about why they
would not leave me alone. His response was "It is not US (NSA) it's the Good Ole
Boys". I also have a huge problem with modified, stolen, and planted documents. We
parted ways in an amicable fashion.
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The ATTORNEY GENERAL returned a letter the following day that stated Dear Mr.
Caterbone, Thank You for your correspondence to the Office of Attorney General, we
will keep your information in our files. These are attached as EXHIBITS.
Superior Court
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CourtNo.
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/S/
Stanley J. Caterbone, Pro Se
Freedom From Covert Harassment and Surveillance
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com
scaterbone@live.com
(717) 669-2163
Page 3 of 48
Thursday,
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April 28, 2016
Superior Court
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Amicus
re Kathleen Kane
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by
both
the
law
enforcement
community
of Lancaster
County
and
the
AT ISSUE
The central issue in this story is a cover up, a cover up of mass proportions, and of perplexing
design, with national consequences. The fact of the matter is that this cover up has had
ramifications throughout this world; specifically the Middle East The cover up would be
emphatically unbelievable without the wealth of evidence, especially the recorded conversations
with Pennsylvania officials. A cover up that permeates from what will later emerge as the 4th
largest financial fraud (Billion Dollars) in the history of the United States coupled with the
covert sales of arms to Iraq. And five years after this cover up began, these same munitions
were used against our own troops in the Persian Gulf War. And of course, there are admitted
ties to the Central Intelligence Agency (CIA) and the National Security Agency (NSA).. And this
cover up and story, which began in June of 1987, in Lancaster County, preceded criminal
indictments by the United States Attorney General, the Federal Bureau of Investigation (FBI),
the Internal Revenue Service (IRS), the Department of Justice and Commerce, and more. A
vast array of criminal activities conspired from the ultra conservative Lancaster County, where
God is supposedly supreme, and it's hard line approach to crime is said to be preeminent. In
June of 1987, Lancaster County was immersed in a dynamic twist of fate, with a host of players
which may never be fully identified.
The irony of this story is how Lancaster County manages the disclosure of the very same
criminal activities that this story proves that it condoned, prior to the intervention of federal
authorities. It most dramatically will prove the nature of it's integrity, or lack thereof.
International Signal & Control, (ISC) is the controversial player in this web of conspiracy. In
1987, ISC was the third largest employer in Lancaster County, a non-discrete defense
contractor. In all due respect to our beloved country, this report is in no way challenging the
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transpire.
The
CIA
remains
immune,
while
everyone
outside
suffers
the
consequences.
The fact that the CIA, or anyone of the other intelligence community, may have been involved,
does not grant a blanket of immunity over activities which were not material to protecting our
national security. If a company provides a service to anyone in the intelligence community, our
constitution, our laws, and it's respective commercial regulatory authorities, must still have the
full sense of their jurisdiction. The intelligence community may not have the right of
intervention into the commercial enterprise, or organization, circumventing the rights of its
employees, shareholders, creditors, and customers. No United States law or statute suggests
that there is any involuntary mandate that requires any of the preceding to compromise his or
her interests in the respective enterprise for the sake of national security, or the respective
intelligence agency. There must be considerations paid to all involved for those rights and
interests that compromise such a relationship. Otherwise, the CIA could effectively gain control
of any domestic corporation it so desires, without ever owning one share of its outstanding
stock, simply by enlisting its product or services for the sake of national security. The CIA
requires a formal vehicle to enlist the aid of our domestic commercial enterprises. ISC is a
proven and unfortunate example of that.
Stan Caterbone was a shareholder of record of International Signal & Control (ISC) for the
previous four years prior to when this tragic ordeal began. Stan Caterbone was to purchase the
stock from now Republican Pennsylvania Senator Gib Armstrong, who was in the brokerage
business at the time and selling ISC stock. The stock was sold over the London Securities
Exchange, supposedly for reasons to suppress information. Stan Caterbone was interested in
the stock because of his appetite for technology, and was more curious about the business of
ISC, than anything. In fact, Stan Caterbone had never made any inference to any of the illicit
dealings with Iraq. However, the perpetrators of this story, attempt to hide behind a vale of
"national security," in an effort to find legal immunity from all wrongdoing. In accordance, the
record will prove that this is merely a smoke screen used to intimidate and obstruct Stan
Caterbone's access for due process of the law.
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Superior Court
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Superior Court
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/S/
Stanley J. Caterbone, Pro Se
Freedom From Covert Harassment and Surveillance
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com
scaterbone@live.com
(717) 669-2163
Page 16 of 48
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EXHIBIT
Superior Court
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re Kathleen Kane
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Stan J. Caterbone
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
Stan J. Caterbone
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 18 of 48
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Superior Court
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Amicus
Amicus
re Kathleen Kane
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Superior Court
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EXHIBIT
Superior Court
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CourtNo.
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8423-15
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Amicus
re Kathleen Kane
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Stan J. Caterbone
ADVANCED MEDIA GROUP
Stan J. Caterbone/Advanced
Superior
Superior
Court
CourtNo.
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Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
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In 2009 I Proposed an ORGANIZED STALKING AND DIRECTED ENERGY WEAPONS HARASSMENT BILL
to Pennsylvania House of Representative Mike Sturla (Lancaster, Pennsylvania) and City of Lancaster
Mayor Richard Gray in 2009. The draft legislation is the work of Missouri House of Representative Jim
Guest, who has been working on helping victims of these horrendous crimes for years. The bill will
provide protections to individuals who are being harassed, stalked, harmed by surveillance, and
assaulted; as well as protections to keep individuals from becoming human research subjects, tortured,
and killed by electronic frequency devices, directed energy devices, implants, and directed energy
weapons. I again reintroduced the bill to the Pennsylvania General Assembly in 2015 and frequented
the Pennsylvania Capitol trying to find support and a sponsor; which I still do to this day.
In 2006 I began his role as an Activist Shareholder for Fulton Financial, which is listed as "FULT" on the
NASDAQ stock exchange. As a founder of Financial Management Group, Ltd., a full service financial firm,
Stan J. Caterbone has drawn upon the success in developing the strategic vision for his company and
the experience gained in directing the legal affairs and public offering efforts in dealing with Fulton
Financial. I have been in recent discussions with the Fulton Financial Board of Directors with regards to
various complaints dealing with such issues as the Resource Bank acquisition and the subprime failures.
I believe that Fulton Financial needs management to become more aggressive in it's strategic planning
and the performance it expects from it's management team in order to increase shareholder value.
Expanding the footprint of the regional bank has not yielded an increase to the bottom line that is
consistent with the expectations of shareholders. Lancaster County has seen several local banking
institutions acquired by larger regional banks, thus increasing the competition Fulton Financial will see in
it's local marketplace as well as in it's regional footprint.
In 2005 I, as a Pro Se Litigant filed several civil actions as Plaintiffs that are in current litigation in the
United States District Court for the Eastern District of Pennsylvania, the United States Third District
Court of Appeals, the Pennsylvania Supreme Court, The Pennsylvania Superior Court, the
Commonwealth Court of Pennsylvania, The Court of Common Pleas of Lancaster County, Pennsylvania.
These litigations include violations of intellectual property rights, anti-trust violations, and interference
of contracts relating to several business interests. Central to this litigation is the Digital Movie, Digital
Technologies, Financial Management Group, Ltd,/FMG Advisory, Ltd., and its affiliated businesses along
with a Federal False Claims Act or Federal Whistleblowers Act regarding the firm of International Signal
and Control, Plc., (ISC) the $1Billion Dollar Fraud and the Export violations of selling arms to South
Africa and Iraq. This litigation dates back to 1987. Stan J. Caterbone was a shareholder of ISC, and was
solicited by ISC executives for professional services. The Federal False Claims Act is currently part of
RICO Civil Complaint in the United States District Court for the Eastern District of Pennsylvania and the
Third Circuit Court of Appeals, as docket no. 05-2288.
In 2005 Advanced Media Group/Project Hope filed a Civil Action in the Court of Common Pleas of
Lancaster County against Drew Anthon and the Eden Resort Inn for their attempts to withhold the
Tourism Tax and Hotel Tax that supports the Downtown Lancaster Convention Center & Marriot. We also
proposed an alternative plan to move the Convention Center to the Hotel Brunswick and Lancaster
Square to all of the major stakeholders. The Lancaster County Convention Center is finally under
construction with a March 2009 Opening date.
In 2005 I was selected to attend the Clinton Global Initiative in New York City after submission of
an essay with and application. I received the invitation from Bruce R. Lindsey, Chief Executive Officer of
the William J. Clinton Foundation.
In 2005 I began our philanthropic endeavors by spending our energies and working with such
organizations as; ONE.org, Livestrong.org, WoundedWarriors.org, The Clinton Global Initiative,
Lancaster Convention Center Authority, Lancaster Chamber of Commerce, Toms Project Hope, People to
People International, GlobalWarming.org, Contact Lancaster/24 Hour Suicide Hotline, Schreiber Pediatric
Center, and numerous others.
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In 2004 I embarked on our past endeavors in the music and entertainment industries with an emphasis
on assisting for the fair and equitable distribution of artists rights and royalties in the fight against
electronic piracy. We have attempted to assist in developing new business models to address the
convergence of physical and electronic mediums; as it displaces royalties and revenues for those
creating, promoting, and delivering a range of entertainment content via wireless networks.
In 2000 to 2002 I developed an array of marketing and communication tools for wholesalers of the
AIM Investment Group and managed several communication programs for several of the company
wholesalers throughout the United States and Costa Rica. We also began a Day Trading project that
lasted until 2004 with success.
In 1999 I developed a comprehensive business plan to develop the former Sprecher Brewery, known as
the Excelsior Building on E. King Street, in Lancaster, Pennsylvania. This plan was developed in
conjunction with the Comprehensive Economic Development Plan for the Revitalization of Downtown
Lancaster and the Downtown Lancaster Convention Center for the former Watt & Shand building.
In 1999 I contributed to the debate, research, and implementation of strategies to counter the effects
of the global Y2K threat to the worlds computer technologies. I attended the U.S. Sponsored Y2K
symposium and Conference in Washington, D.C. hosted by the Senate Y2K Subcommittee and Senator
William Bennett.
In 1998 I had began to administer the charity giving of Toms Project Hope, a non-profit organization
promoting education and awareness for mental illness and suicide prevention. We had provided funding
for the Mental Health Alliance of Lancaster County, Contact Lancaster (The 24/7 Suicide Prevention
Hotline), The Schreiber Pediatric Center, and other charitable organizations and faith based charities.
The video "Numbers Don't Lie" have been distributed to schools, non profit organizations, faith based
initiatives, and municipalities to provide educational support for the prevention of suicide and to bring
awareness to mental illness problems.
In 1996 I had done consulting for companies under KAL, Inc., during the time that I was controller of
Pflumm Contractors, Inc., I was retained by Gallo Rosso Restaurant and Bar to computerized their
accounting and records management from top to bottom. I had also provided consulting for the
computerization of accounting and payroll for Lancaster Container, Inc., of Washington Boro. I was
retained to evaluate and develop an action plan to migrate the Informations Technologies of the Jay
Group, formally of Ronks, PA, now relocated to a new $26 Million Dollar headquarters located in West
Hempfield Township of Lancaster County. The Jay Group had been using IBM mainframe technologies
hosted by the AS 400 computer and server. I was consulting on the merits of migrating to a PC based
real time networking system throughout the entire organization. Currently the Jay Group employees
some 500 employees with revenues in excess of $50 Million Dollars per year.
In 1993 I was retained by Pflumm Contractors, Inc., as controller, and was responsible for saving the
company from a potential bankruptcy. At that time, due to several unpaid contracts, the company was
facing extreme pressure from lenders and the bonding insurance company. We were responsible for
implementing computerized accounting, accounting and contract policies and procedures, human
resource policies and procedures, marketing strategies, performance measurement reporting, and
negotiate for the payment of unpaid contracts. The bonding company was especially problematic, since
it was the lifeline to continue work and bidding for public contracts. The Bank of Lancaster County
demanded a complete accounting of the operations in order to stave off a default on the notes and loans
it was holding. We essentially revamped the entire operation. Within 3 years, the company realized an
increase in profits of 3 to 4 times its previous years, and record revenues.
Stan J. Caterbone/Advanced
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Group Biography
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In 1991 I was elected to People to People International and the Citizen Ambassador Program, which
was founded by President Dwight D. Eisenhower in 1956. The program was founded to To give
specialists from throughout the world greater opportunities to work together and effectively
communicate with peers, The Citizen Ambassador program administers face-to-face scientific, technical,
and professional exchanges throughout the world. In 1961, under President John F. Kennedy, the State
Department established a non-profit private foundation to administer the program. We were scheduled
to tour the Soviet Union and Eastern Europe to discuss printing and publishing technologies with
scientists and technicians around the world.
In 1990 I had worked on developing voice recognition systems for the governments technology think
tank - NIST (National Institute for Standards & Technology). I co-authored the article Escaping the Unix
Tar Pit with a scientist from NIST that was published in the magazine DISC, then one of the leading
publications for the CD-ROM industry. Today, most all call centers deploy that technology whenever you
call an 800 number, and voice recognition is prevalent in all types of applications involving
telecommunications.
In 1989 I had founded Advanced Media Group, Ltd., and was one of only 5 or 6 U.S. domestic
companies that had the capability to manufacture CD-ROM's. We did business with commercial
companies, government agencies, educational institutions, and foreign companies. I performed services
and contracts for the Department of Defense, NASA, National Institution of Standards & Technology
(NIST), Department of Defense, The Defense Advanced Research Projects Agency (DARPA), and the
Defense Mapping Agency, Central Intelligence Agency, (CIA), IBM, Microsoft, AMP, Commodore
Computers, American Bankers Bond Buyers, and a host of others. I also was working with R.R,
Donnelly's Geo Systems, which was developing various interactive mapping technologies, which is now a
major asset of Map Quest. Map Quest is the premier provider of mapping software and applications for
the internet and is often used in delivering maps and directions for Fortune 500 companies. We had
arranged for High Industries to sell American Helix, the manufacturer of compact discs, to R.R. Donnelly.
We had brokered a deal and the executives from Donnellys Chicago headquarters flew to Lancaster to
discuss the deal and perform due diligence of the manufacturing facility located in the Greenfield
Industrial Park.
In 1987 Power Station Studios of New York and Tony Bongiovi retained me as executive producer
of a motion picture project. The theatrical and video release was to be delivered in a digital format; the
first of its kind. We had originated the marketing for the technology, and created the concept for the
Power Station Digital Movie System (PSDMS), which would follow the copyright and marketing formula
of the DOLBY technology trademark.
We had also created and developed marketing and patent research for the development and
commercialization of equipment that we intended to manufacture and market to the recording industry
featuring the digital technology. Sidel, Gonda, Goldhammer, and Abbot, P.C. of Philadelphia was the lead
patent law firm that We had retained for the project. Power Station Studios was the brainchild of Tony
Bongiovi, a leading engineering genius discovered by Motown when he was 15. Tony and Power Station
Studios was one of the leading recording studios in the country, and were responsible for developing Bon
Jovi, a cousin. Power Station Studios clients included; Bruce Springsteen, Diana Ross, Cyndi Lauper,
Talking Heads, Madonna, The Ramones, Steve Winwood, and many others. Tony and Power Station
Studios had produced the original Sound Track for the original Star Wars motion picture. It was
released for distribution and was the number one Sound Track recording of its time.
Tony Bongiovi was also active in working and researching different aerospace technologies. * We had
developed and authored a Joint Venture Proposal for SONY to partner with us in delivering the Digital
Movie and its related technologies to the marketplace. The venture was to include the commercialization
of technologies, which Tony Bongiovi had developed for the recording industry simultaneously with the
release of the Digital Movie.
Stan J. Caterbone/Advanced
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I also created the concept for the PSDMS trademark, which was to be the Trademark logo for the
technology, similar to the DOLBY sound systems trademark. The acronyms stand for the Power Station
Digital Movie System. Today, DVD is the mainstay for delivering digital movies on a portable medium, a
compact disc.
In 1987 I had a created and developed FMG Mortgage Banking, a company that was funded by a major
banking firm in Houston Texas. We had the capability to finance projects from $3 to $100 million dollars.
Our terms and rates were so attractive that we had quickly received solicitations from developers across
the country. We were also very attractive to companies that wanted to raise capital that include both
debt and equity. Through my company, FMG, we could raise equity funding through private placements,
and debt funding through FMG Mortgage Banking. We were retained by Gamillion Studios of Hollywood,
California to secure financing of their postproduction Film Studio that was looking to relocate to North
Carolina. We had secured refinancing packages for Norris Boyd of and the Olde Hickory and were in the
midst of replacing the current loan that was with Commonwealth National Bank. We had meetings and
discussions with Drew Anton of the Eden Resort, for refinancing a portion of his debt portfolio. We were
quickly seeking commitments for real estate deals from New York to California. We also had a number of
other prominent local developers seeking our competitive funding, including Owen Kugal, High
Industries, and the Marty Sponougle a partner of The Fisher Group (owner of the Rt. 30 Outlets). We
were constantly told that our financing packages were more competitive than local institutions.
In 1986 I had founded Financial Management Group, Ltd (FMG); a large financial services organization
comprised of a variety of professionals operating in one location. We had developed a stock purchase
program for where everyone had the opportunity for equity ownership in the new firm. FMG had
financial planners, investment managers, accountants, attorneys, realtors, liability insurance services,
tax preparers, and estate planners operating out of our corporate headquarters in Lancaster. In one
year, we had 24 people on staff, had approximately 12 offices in Pennsylvania, and
several satellite offices in other states. We had in excess of $50 million under management, and our
advisors were generating almost $4 million of commissions, which did not include the fees from the
other professionals. We had acquired our own Broker Dealer firm and were valued at about $3 to $4
million.
In 1985 I developed the Easter Regional Free Agent Camp, the first Free Agent Camp for the
Professional Football industry; which was videotaped for distribution to the teams scouting departments.
(See Washington Post page article of March 24, 1985) Current camps were dependant on the team
scouts to travel from state to state looking for recruits. We had developed a strategy of video taping the
camp and the distributing a copy, free of charge to the teams, to all of the scouting departments for
teams in all three leagues FL, CFL and WFL. My brother was signed at that camp by the Ottawa
Roughriders of the CFL, and went on to be a leading receiver while J.C. Watts was one of the leagues
most prominent quarterbacks. My brother also played 2 years with the Miami Dolphins while Dan Marino
was starting quarterback. We were a Certified Agent for the National Football League Players
Association. Gene Upshaw, the President of the NFLPA had given me some helpful hints for my camp,
while we were at a Conference for agents of the NFL. The Washington Post wrote a full-page article
about our camp and associated it with other camps that were questionable about their practices.
Actually, that was the very reason for our camp. We had attended many other camps around the
country that were not very well organized and attracted few if any scouts. We had about 60 participants,
with one player coming from as far away as Hawaii. We held the camp at Lancaster Catholic, with a
professional production company filming the entire camp, while I did the editing and produced the video.
The well respected and widely acclaimed professional football scout, Gil Brandt, of the Dallas Cowboys,
had given me support for my camp during some conversations We had with him and said he looked
forward to reviewing the tapes for any hopeful recruits.
Stan J. Caterbone/Advanced
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In 1985 I was elected Vice President of the Central Pennsylvania Chapter of the International
Association of Financial Planners, and helped build that chapter by increasing membership 3to 4 times.
We had personally retained the nationally acclaimed and nationally syndicated Financial Planner, Ms.
Alexandria Armstrong of Washington D.C.; to host a major fundraiser. More than 150 professionals
attended the dinner event that was held at the Eden Resort & Conference Center. Ms. Armstrong
discussed financial planning and how all of the professions needed to work together in order to be most
effective for their clients. We attracted a wide variety of professionals including; brokers, lawyers,
accountants, realtors, tax specialists, estate planners, bankers, and investment advisors. Today, it has
become evident that financial planning was the way of the future. In 1986 executives approached us
from Blue Ball National Bank to help them develop a Financial Planning department within their bank.
In 1984 I had helped to develop strategic planning for Sandy Weill, former President of Citi Group (the
largest banking entity in the U.S). We were one of several associates asked to help advise on the future
of Financial Planning and how it would impact the brokerage and the investment industry at large. Mr.
Weil was performing due diligence for the merger of American Express and IDS (Investors Diversified
Services). We were at that time a national leader in the company in delivering Fee Based Financial
Planning Services, which was a new concept in the investment community and mainstream investors.
That concept is now widely held by most investment advisers.
Stan J. Caterbone, Pro Se Litigant
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
Stan J. Caterbone/Advanced
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page27
6 of 48
6
Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016
EXHIBIT
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 28 of 48
Thursday,
Thursday,April
April 28, 2016
Stan J. Caterbone
ADVANCED MEDIA GROUP
Stan J. Caterbone
Superior
Superior
Court
CourtNo.
1164
8423-15
Story
Amicus
and
Amicus
Evidence
re Kathleen
of Kane
a TI
Targeted
Page
Page
Individual
291of
of48
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
In 2015 I filed an amicus curie on behalf of Lisa Michelle Lambert who was convicted in 1992 of
the murder of Laurie Show, both of Lancaster, Pennsylvania. I currently am in litigation in the U.S. Third
Circuit Court of Appeals and in February of 2016 Lisa Michelle Lambert published her book titled
Corruption in Lancaster County My Story, which is available in bookstores and on Amazon.com. I
am in frequent contact with her co-author, Dave Brown of Philadelphia, Pennsylvania.
In 2009 I Proposed an ORGANIZED STALKING AND DIRECTED ENERGY WEAPONS HARASSMENT
BILL to Pennsylvania House of Representative Mike Sturla (Lancaster, Pennsylvania) and City of
Lancaster Mayor Richard Gray in 2009. The draft legislation is the work of Missouri House of
Representative Jim Guest, who has been working on helping victims of these horrendous crimes for
years. The bill will provide protections to individuals who are being harassed, stalked, harmed by
surveillance, and assaulted; as well as protections to keep individuals from becoming human research
subjects, tortured, and killed by electronic frequency devices, directed energy devices, implants, and
directed energy weapons. I again reintroduced the bill to the Pennsylvania General Assembly in 2015
and frequented the Pennsylvania Capitol trying to find support and a sponsor; which I still do to this
day.
In 2005 I, as a Pro Se Litigant filed several civil actions as Plaintiffs in the United
States District Court for the Eastern District of Pennsylvania, the United States Third District
Court of Appeals, the Pennsylvania Supreme Court, The Pennsylvania Superior Court, the
Commonwealth Court of Pennsylvania, The Court of Common Pleas of Lancaster County,
Pennsylvania. These litigations included violations of intellectual property rights, anti-trust
violations, and interference of contracts relating to several business interests, harassment,
extortion, fraud, etc.,. . Central to this litigation is the Digital Movie, Digital Technologies,
Financial Management Group, Ltd,/FMG Advisory, Ltd., and its affiliated businesses along
with a Federal False Claims Act or Federal Whistleblowers Act regarding the firm of
International Signal and Control, Plc., (ISC) the $1Billion Dollar Fraud and the Export
violations of selling arms to South Africa and Iraq. This litigation dates back to 1987. In
1987 I microfiched some 10,000 pages of documents that prove this story without any doubt.
I also have recorded conversations of persons and government officials.
Stan J. Caterbone, Pro Se Litigant
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
Stan J. Caterbone
Superior
Superior
Court
CourtNo.
1164
8423-15
Story
Amicus
and
Amicus
Evidence
re Kathleen
of Kane
a TI
Targeted
Page
Page
Individual
302of
of48
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3113of
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Thursday,
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April 16,
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Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3224of
of
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Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3335of
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Evidence
re Kathleen
of
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Kane
a TI
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1164
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re Kathleen
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Evidence
re Kathleen
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Kane
a TI
Targeted
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1164
8423-15
Story
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Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
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1164
8423-15
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Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
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Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
40
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Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
41
11
13of
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27
29
THE ADVANCED MEDIA GROUP
Page 35 of 41
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
06/10/2007
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
42
12
14of
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27
29
THE ADVANCED MEDIA GROUP
Page 36 of 41
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
06/10/2007
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
43
13
15of
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29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
44
14
16of
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27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
45
15
17of
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27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
46
16
18of
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29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
47
17
19of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
What is CCHR?
1 of 2
http://www.cchr.org/about-us/what-is-cchr.html
ABOUT US
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Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
48
18
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Thursday,April
April 16,
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11/6/2015 12:42 AM
www.amgglobalentertainmentgroup.com
mailto:amgroup01@msn.com
717.427-1621 Fax
Stanley J. Caterbone
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
__________________________________________________________________________
:
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__________________________________________________________________________________
_________/s/_______________
Date: February 20, 2007
02/21/2007
__________________________________________________________________
TABLE OF CONTENTS
_____________________________________________________________
I.
II.
III.
ARGUMENT 21
Page 2 of 20
02/21/2007
__________________________________________________________________
STATEMENT OF INTEREST OF AMICUS CURIAE
__________________________________________________________________
Stanley J. Caterbone is a private citizen and the majority shareholder of the United States
incorporated business Advanced Media Group.
shareholder in 1987 involving the United States Defense Contractor International Signal & Control,
Plc., known as ISC. In 1992, International Signal & Control was indicted and found guilty of among
other things a Billion Dollar Fraud and export violations concerning illegally shipping cluster bomb
technologies, missile defense systems, and other defense systems to foreign interests including South
Africa, Iraq and Saddam Hussein. Cluster bombs and related technologies are known to have been
exported to Iraq by the Chilean Arms Dealer Carlos Cardoen, a joint venture partner of International
Signal & Control.
program to arm Iraq during the 1980s with close ties to International Signal & Control, which
allegedly included the help of the National Security Agency, a former end user of International Signal &
Control technologies under the early 1980s program Project X. A Presidential Finding in 1984 by the
Bush Administration was executed to implement the program of arming Saddam Hussein and Iraq with
the cluster bomb technologies. Serious allegations of these programs were the focus of investigations
that included the knowledge and supervision of then appointed nominee for the Director of Central
Intelligence Agency, Robert M. Gates.
Since 1987, Stanley J. Caterbone has been the victim of vast civil conspiracy that started in
1987 to cover-up allegations of fraud within International Signal & Control during the negotiations and
merger of International Signal & Control and Ferranti International of England. Stanley J. Caterbone
alleges that warrantless surveillance was used to obstruct justice and moot his constitutional rights in
an effort to divert attention away from his allegations of fraud within International Signal & Control
back in 1987, and afterwards to the present as a means to deny his access to the courts for remedy
and relief, and Federal False Claims Act violations. The business of Advanced Media Group has been
greatly compromised and intellectual property stolen during the late 1980s and early 1990s that
included information technology contracts with the United States Government.
In January of 2006, Stanley J. Caterbone was detained at every airport security check point,
which was during a policy of random checks, and taken out of line during travel from Philadelphia,
Pennsylvania, to Houston, Texas, and on to Puerto Vallarta, Mexico. At the Houston Airport, Stanley J.
Caterbone was falsely accused of carrying plastics explosives and taken to an interview room by
Homeland Security officials. Stanley J. Caterbone was also detained for three days in Mexico, and was
not provided with an opportunity to gain access to a flight out of the country by Mexican Officials.
Page 3 of 20
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The interest of amicus in this case is ensuring that constitutional rights of private citizens are
not compromised and justice subverted through information obtained from warrantless surveillance
upon which there is no just cause for any allegations or association with terrorism. Whistle-Blowers
are inherently supportive of a system of checks and balances within our government that go beyond
our constitutional doctrines regarding the same.
universally applied to all government officials in all branches of government. The Federal False Claims
Act and its provisions protect individuals from abuse of power, while providing relief and remedies for
those that were wronged and those that had the courage to cite a wrong.
It is too easy for present and future administrations to abuse their power and utilize
warrantless surveillance as a means of subverting and obstructing justice for those that are engaged in
Whistle-Blowing cases that concern National Security.
review, a Whistle Blower can be place on terrorist lists for malicious reasons without the knowledge or
just cause. This is in direct conflict with keeping our democracy free of corruption while adhering to
the spirit of the constitution in the manner our founding fathers envisioned.
Page 4 of 20
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__________________________________________________________________________
__________________________________________________________________
Background Information: The following transcripts from National Broadcast Television, ABC News
Nightline and ABC News 20/20; provide material information as to the activities of International Signal
& Control and the importance of these matters with regard to National Security.
ABC NEWS 20/20 FEBRUARY 1, 1991
[Lynn Sherr ABC News 20/20 Correspondent] This is the story of how this deadly weapon,
designed for the U.S. military made its way form this country to Iraq. And how American Soldiers may
face the devastation of a cluster bomb if a ground war breaks out in the Persian Gulf. Federal Officials
believe Saddam Hussein got his arsenal thru a lethal combination bureaucratic foul ups in the U.S.
Government and simple greed.
Here is how the cluster bomb works. An artillery shell, an airplane, or a rocket launcher sends the
bombs toward their targets.
grenades. Cluster bombs can be used against ground troops or tanks, and can even scatter mines to
lie dormant for days. The bombs can spray thousands of pounds of sharp objects pins or even razor
blades. The shrapnel can rip through anyone or anything in its way, causing massive casualty among
civilians or ground troops.
You can see the destruction in these buildings in Lebanon after a cluster
bomb attack.
How did Iraq obtain the cluster bombs and the ability to make their own? It was incredibly simple.
Investigators believe it started with International Signal & Control, A government contractor with
5,000 employees based in Pennsylvania, which build key components of cluster bombs in a subsidiary
in California. 20/20 has learned Federal Investigators believe ISC provided the technology, that is the
plans, to this man, Carlos Cardoen, Chilean arms dealer.
If the cluster bomb technology actually left the county, that is illegal
without U.S. Government permission, investigators say ISC never got. It is also illegal for a foreigner,
like Cardoen, to take the plans out of the United States without a license, which sources tell us, he
never obtained. The man who opened the door to Iraq for Cardoen, was this man Nasser Bedouin. He
is a Lebanese born middleman for Cardoen who is based in the United States. Bedouin traveled often
to Bagdad, and arranged for sale cluster bombs and other military hardware to Saddam Husseins
army. In his first television interview, he told us about the business of dealing in deadly weapons.
Page 5 of 20
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[Nasser Bedouin, Arms Dealer] I can sell you a knife to peel an apple, if you cut someones
throat, thats your business. Weapons do not kill, who behind them kill.
[Lynn Sherr ABC News 20/20 Correspondent] With slick promotional videos, Cardoen marketed
his arms throughout the world. Arab countries were favorite customers.
[Cardoen Marketing Video] Each one of the bomblets of the cluster bomb is multi purpose and
contains an incendiary, anti personnel and anti armor detection.
[Lynn Sherr ABC News 20/20 Correspondent] This letter from Cardoen authorizes Bedouin to
sell cluster bombs to Saddam Hussein during his war with Iran.
willing to take its share in helping Iraq in its time of need. We can provide you with our cluster bombs
at the lowest possible price. According to these contracts the sale of cluster bombs to Iraq was an
extremely lucrative business. February 24, 2984 3,000 cluster bombs sent to Saddam Husseins army
worth $21 million dollars.
dollars.
A few months later, another 3,000 cluster bombs, another $21 million
The supply of cluster bombs eventually totaled more than $400 million dollars.
In fact,
That was one of the first attacks by the military when the attack began.
Its unknown
But why didnt they find out about him sooner? He has been selling cluster
bombs to Iraq for nearly a decade. The U.S. Patent Office knew about Cardoen back in 1986. But
they didnt tell anyone else in the Federal Government about them. In a move that went apparently
unchecked in the highest levels of the government, Cardoen applied for his own patent for cluster
bombs in 1986. Based on some changes on previous designs, he received the patent two years later.
Getting the Patent is not illegal. But at a time when U.S. shipments of arms to Chile were banned, as
to all sales to Iraq, Why didnt the Patent Office raise any questions why was this foreigner dealing in
U.S. arms?
Page 6 of 20
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State, and Defense, are supposed to control arms sales, and communicate with one another.
[Anthony Cordazman, Correspondent] - Even today, the same squabbling goes on, every day
within the Commerce, State, and Defense. The Administration can never agree on what
kinds of laws
weapons are wrong. But they are a fact. And we have to live with facts.
The former head of ISC, James Guerin, who dealt with Chilean, said he did not provide anything to Cardoen to build
weapons. But Nasser Bedouin tells a different story.
[Nasser Bedouin, Arms Dealer] I believe that Dr. Carlos Cardoen got the plans to build the
cluster bombs from the United States.
[Lynn Sherr ABC News 20/20 Correspondent] Questions about the cluster bombs come at a
time when questions are being focused on how so many American designed weapons got into the
hands of Saddam Hussein. Senator John McCain.
[Senator John McCain] Theres not just one Saddam Hussein on this globe. Theres lots and lots
of them who at this time as we speak are acquiring technologies to give them the capabilities of
weapons of mass destruction because its a way of gaining victory on the cheap.
[Lynn Sherr ABC News 20/20 Correspondent] McCain has introduced legislation that would
severely penalize and company or countries that would sell weapons illegally or harbor arms dealers.
[Senator John McCain] To provide many of the kinds of weapons that we have today to many
nations, which are clearly offensive in nature, and are clearly far exceed their requirements to defend
themselves, is frankly unconscionable and must be brought to a stop.
[Lynn Sherr, ABC News 20/20 Correspondent] Basically what you are saying is hit them in the
pocketbook.
Page 7 of 20
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[Senator John McCain] Hit them in the pocketbook and public exposure. No corporation or nation
likes to be branded as a nation that is involved in this illicit trafficking.
[Lynn Sherr ABC News 20/20 Correspondent] But public exposure and pressure will not shield
American Soldiers. If Saddam Hussein uses the cluster bombs he already has.
[Senator John McCain] And if there is one good thing that has come out of this Persian Gulf war
its to dramatically heighten the awareness of the people of the world to the American people of how
dangerous this proliferation of weapons of mass destruction can be.
[Hugh Downs, ABC News 20/20 Correspondent] God those things are vicious. Have there been
any indictments yet Lynn?
[Lynn Sherr ABC News 20/20 Correspondent] Ah, no Hugh, no indictments yet.
Carlos
Cardoen has not been indicted, even though Federal Agents raided his headquarters office in Miami.
And U.S. Customs people took a number of documents, but no indictments yet, but there are
investigations going on.
[Hugh Downs, ABC News 20/20 Correspondent] If these things are dropped from airplanes,
and we have air supremacy, as it now has been said by our leaders, is there that much to worry about
for our troops?
[Lynn Sherr ABC News 20/20 Correspondent] Were told yes, because you dont need to an
airplane to a cluster bomb, they can also be used on rocket launchers and on unguided missiles, both
of which Iraq has. And incidentally, we talked about that bomb factory, even if it was badly damaged,
the cluster bomb factory he already has, were told in three to six months it can be operational again,
and anyway he likely has a big stockpile.
[Hugh Downs, ABC News 20/20 Correspondent] We of course, have these weapons also, and I
understand they are called something different?
[Lynn Sherr ABC News 20/20 Correspondent] Yes, if youre listening to a Pentagon Briefing,
dont listen for the term cluster bomb, there calling them Aerial Denial Weapons.
[Hugh Downs, ABC News 20/20 Correspondent] Thank you Lynn.
END
Page 8 of 20
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Network.
The U.S.
Government knew, and turned a blind eye. Sophisticated Military Technology was illegally transferred
from a major U.S. company in Lancaster, Pennsylvania (International Signal & Control),
to South
Africa, and Chile, and from there onto Iraq. The Iraqi borne designer of a chemicals weapons plant in
Lybia, set up shop in Florida, producing and shipping to Iraq chemical weapon components. The CIA,
FBI, and other U.S. agencies were made aware of the operation and did nothing to prevent it.
During the 1980s and into the 90s senior officials of both the Bush and Reagan Administration
encouraged the privatization of foreign policy, certainly towards Iran and Iraq. The policy may have
had merit - but there werent willing or in some instances werent successful in fighting it out in Capital
Hill so they found other ways. They made a mockery of the Export Control System, and they found
ways of encouraging foreign governments to do what our laws prohibited. They even knew or if not
were guilty of the grossest incompetence that U. S. companies were collaborating with foreign Arms
merchants in the illegal transfer of American Technology that helped Sadaam Hussein build is
formidable arsenal.
Page 9 of 20
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This week, the CIA again told ABC News Nightline that our allegations over the past few months
regarding covert operations to supply Iraq with U.S. Arms and weapons technologies simply were not
true.
The CIAs Inspector General said a statement from the Agency [On Screen] - Has found to factual
support whatsoever for such an operation or for the involvement of Mr. Gates.
[Ted Koppel] At least one member of the Senate Intelligence Committee, Bill Bradley of New
Jersey, feels that there may be reason to doubt both those claims, and hell raise the issues next week
during the Gates Confirmation Hearings, next week.
The CIA also told us that its Inspector General has found no evidence of any off-the-books illegal
activity.
Precisely so that
Page 10 of 20
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His
connection with Robert Gates has not. By the mid 1980s Cardoen was the largest private supplier of
weapons to Iraq.
In all he has believed to ship a half billion dollars worth of arms and advanced
technologies to Bagdad.
thousands of bombs and other equipment, absolutely essentially to Iraq during its eight year war with
Iran.
The material would be loaded aboard regular Iraqi airway flights flown from Santiago to Bagdad.
Cardoen did not simply ship weapons, he set up entire factories capable of producing bombs and other
explosives the components would be shipped from all over the world and then assembled in Iraq. One
of those factories turned out Cluster Bombs.
As we first reported on the 24th of May, much of the sophisticated military technology that Cardoen
was shipping to Iraq came from the United States. This company in sleepy Lancaster, Pennsylvania, is
believed to be the source for some of the Cluster Bomb technology. But there was more.
Nasser
Bedouin is also an arms dealer. He acted as a middleman between Carlos Cardoen and Iraq.
[Nasser Bedouin on Video] I am aware of Carlos Cardoen getting some type of technology from
the air fuel bomb from the United States. I believe Iraq has a viable fuel air explosive.
[Ted Koppel] These explosives are designed to explode just above ground level like miniature
atomic bombs, literally sucking all available oxygen out of the air. It is clear that Carlos Cardoens
special relationship with the United States was not known by all Departments. When the Commerce
Department inquired about that relationship in early 1987, it received a cable from the U.S.
Ambassador to Chile saying although Cardoen is involved with the sale of armaments, and he has
made his fortune from it, he is considered to be a responsible recipient of U.S. products. In fact by
1987, the covert relationship between the CIA and Cardoen was already well established.
In 1983 the Reagan Administration had become alarmed at how poorly the Iraqi military was doing
against Iran. A decision was made at the highest level of Government to begin helping Iraq.
Indeed ABC News has learned only today, that around that time, in 1983 Ronald Reagan issued a
highly classified Presidential Finding stating that it was important to the National Interests that arms
and technical assistance be covertly funneled to Iraq
More on the
Page 11 of 20
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What it unleashed was a flood of US help to Iraq. A former CIA operative who was involved in the
program has told us of a series of covert operations, in which loads of 727s were flown into Iraq. On
one such mission in 1987 our source tells us he accompanied a planeload of Soviet built one hundred
twenty-two missiles.
The Soviet equipment was shipped because it would be compatible with what
the Iraqis already had. By 1987, there was at least one such flight a week into Bagdad.
Our former CIA source recalls bringing in $100 dollar bills in a bowling bag, they would also carry
whiskey, cartons of cigarettes and copies of Penthouse magazines to speed up the unloading process,
which usually took place at night.
Program to Iraq, the CIA took over. In effect the former CIA operative told us the covert operation
amounted to here is what we want you to do, and we really dont want to know too much about how
you do it.
Our source tells us that he has at least one meeting in 1986 in Florida between Robert Gates and
Carlos Cardoen, the Chilean Arms Dealer. Other sources have told us of other such meetings. Here in
the United States and in Europe. Which brings us to an unsolicited statement that was telephoned in
to Nightline from the Central Intelligence Agency almost a month ago on June 17th. Allegations, the
statement read that Robert Gates facilitated illegal shipments to Iraq during the 1980s are totally
without basis. Since we had never requested a statement of Mr. Gates, we didnt know quite what to
make of it at the time. But then today we learned of that Presidential Finding, authorizing the Covert
shipment of arms to Iraq.
It would be true then that Robert Gates did not facilitate illegal shipments to Iraq, under the
Presidential Finding, the shipments would have been quite legal.
confirmation hearings, back in 1987, Robert Gates assured the Senate Confirmation Committee that he
would always keep the Committee current on ongoing covert operations. Indeed the CIA is supposed
to provide the Intelligence Committee with quarterly reports. According to well-informed sources on
the Committee it has had no briefings on the Covert arms pipeline to Iraq.
the Committee would be a total breach of trust. What would it do to the Gates Nomination? I asked.
It would probably be enough said the Senator, to derail the Nomination.
Again, an excerpt from Mr. Gates Testimony before the Senate Intelligence Committee in 1987:
[Robert Gates 1987 on video] If you cannot have a system in which you can have some
confidence between A the branches of government, and confidence between the senior officials of the
Government, A that they abide by the rules, and B that they will deal with one another honestly, then
I think the system begins to collapse.
Page 12 of 20
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[Ted Koppel] Late this evening, the Whitehouse communicated its response to the charges
contained in this report, the Whole story is unfounded. There were never any sales; covert or overt
to Iraq or Iran through a third country. And Mr. Gates never met with Carlos Cardoen.
Well be back with more, in a moment.
[Ted Koppel] For the viewers, this is Alan Freidman, New York Correspondent for the Financial
Times of London, and a member of the team investigating Robert Gates. Alan Id like to begin by
repeating a statement, and let me put my specs on for a moment, the White House. This story is
unfounded and there were never any sales covert or overt to Iraq or Iran through a third country. And
Mr. Gates never met with Carlos Cardoen.
Ah, ah a fairly carefully drafted statement one would think.
[Alan Friedman, New York Correspondent for the Financial Times of London] Yes Ted, I
think that is right, I would agree with the statement that there were never any sales Iraq through a
third party.
Indeed what we found was that some of the cluster bomb technology and fuel air
technology was given smuggled down to Chile, for use that were used and made and shipped on
through to Iraq.
In terms of the um statement by the White House that there were never any
meetings between Mr. Gates and Mr. Cardoen, we have a number of sources, some of them personally
involved in these operations, one of them who was personally and physically an eye witness present at
a meeting, in Florida, with Mr. Gates and Mr. Cardoen in 1986. And who was told my Mr. Gates, about
other meetings that he had with Mr. Cardoen.
[Ted Koppel] Now Congressman Gejdenson, I realized that we sort of unleashed an awful lot of
material on you today, but to what degree does this fit in with those thousands of documents that you
subpoenaed with the information that you have?
[House Representative Sam Gejdenson of the House Foreign Affairs Committee] Well we
just got the documents after a several month battle with the Administration to pry them loose and it
took the vote of a subpoena by the subcommittee to start the flow of those documents, but its
certainly consistent with the information that we got with Committee staffs with some of those people
that said they were at those meetings, ah as well. I think that the important thing to remember here
is that the United States in 1982 under the Reagan Administration took Iraq off the terrorist list at a
time when some of the worst terrorist of the world were being harbored by Saddam Hussein, and we
suddenly changed our policy and continued to keep Iraq off the terrorist list, enabling the export of
dual use, ah items that can be used for dual use from the United States to Iraq, as well as these sales
that went indirectly to Iraq.
Page 13 of 20
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So, all through a time when they were harboring terrorists, and they killed 5,000 Kurds in 1988, and
as recent as six days before the invasion of Kuwait, when I and several members of Congress, tried to
stop the subsidy of grain sales to Iraq, the Bush Administration continued to impose any sanctions
against Iraq.
[Ted Koppel] Well of course theres a huge difference between grain sales and the shipment of
entire plants for the building of a cluster bomb factory.
[House Representative Sam Gejdenson of the House Foreign Affairs Committee] Except for
what I think you find is that a pattern by both the Bush and Reagan Administrations to trying to assist
Saddam Hussein. What we found at one Hearing was a document from the State Department, ah that
said that the United States was ready to sell weapons to Iraq as long as they were for the personal
protection of Saddam Hussein. A policy that ignored all the outrages, a policy that ignored I think the
intent of the Congress and the American People. And that the allegations that weve gotten from a
number of sources seem to be consistent with that. The United States did everything it could under
the Reagan and Bush Administrations to assist Saddam Hussein.
[Ted Koppel] Alan, I know that one of the things that we discovered in our investigations was and
Id like you to elaborate on it a little bit was that frequently there was Federal Agencies, Law
Enforcement Agencies that was trying to uncover what was going on we found that they were stymied
at every turn. Can you talk about a that a little bit?.
[Alan Friedman, New York Correspondent for the Financial Times of London] Yes I think
that if we look back at other discoveries that we made, you can say that when we found ISC, the
company in Lancaster, Pennsylvania, that was, that had cluster bomb technology, shipped down to
Chile that was part of this covert operation for Iraq, we found that the CIA had detailed knowledge
over a period of 4 years of all sorts of shipments from ISC to South Africa, some of which were later
trans shipped to Iraq, we found that Federal Law Enforcement Officers and Agencies were unable to do
anything about it because they just werent told. Likewise, we were just told of the case that the man
that built the Rapta Chemical Weapons plant in Libya, who ah, even though the CIA were tracking him
very carefully here in the United States, was allowed to build a chemical weapons plant here in Florida,
and shipped dangerous cyanide with the help of CIA Contract Shippers to Iraq.
were going on and the investigators seem unable to do anything about any of these things. We seem
to have part of the Government trying to investigate, and part of the Government trying to ship.
[Ted Koppel] Congressman Gejdenson Id like to get your reaction to that and see if your
experiences have been similar in some of the findings that ah or some of the conclusions that you
have reached, but well take a break first and be back in just a moment.
Page 14 of 20
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[House Representative Sam Gejdenson of the House Foreign Affairs Committee] Well we
saw it ah from across all of the agencies. We had Dennis Kloskey who was then in charge of export
licensing at Commerce testify before our committee in April that he suggested to Mr. Gates and others
that ah meetings at White House to stop the export of dangerous technologies to Iraq. The following
day ah Mr. Kloskey resigned from the Government.
House, the people in that room representing the President argued for a policy that assisted Saddam
Hussein in getting dual use technologies. We had Congressman Rose who I know has been on your
show testifying about the grain sales being tied up with funding weapons to Iraq as well. So across
the government, this thing went on. Its hard to believe that somebody like Mr. Gates in his position
didnt know about it.
[Ted Koppel] We are suggesting a lot more that he knew about it. Were suggesting that he was
actively involved in it let me just pass on a little information that we have gathered today, having to
do with the Confirmation Hearings and was told earlier this afternoon. Alan Fryers, Senior Officer with
the CIA and Clair George are not likely to be testifying voluntarily, indeed Alan Fryers said he will not
be testifying before the Senate Intelligence Committee.
throughout the day is putting on some pressure to get those Hearings underway before the August
recess, August 2nd, of course, the Senate goes into recess. Ah, and there are indications now that a
week from Monday, indeed the Hearings will begin, Mr. Gates will be asked to testify at that time, but
Ive been also told that there is no way that the Hearing will no way be completed before the August
recess.
And that Mr. Gates will be told that he will be recalled again
testified, after the August recess. So these Hearing now, are destined to go into September.
[House Representative Sam Gejdenson of the House Foreign Affairs Committee] I think that
is terribly important, because we have to what we have to remember here, unlike other appointees of
the President, what the head of the CIA does is not transparent. If youre the Secretary of Housing,
like Jack Kemp is, and I disagree with one of his programs, not only do I know about it, but the
average citizen knows about what Jack Kemps doing. Sometimes you agree with it and sometimes
you disagree with him. In the case of the Director of the CIA, as is clear from repeated experiences,
often times even the people in Congress were suppose to know about these activities are not
informed. This has to do with National Security the standard ought not be somebody that can get by
the Hearing process with White House pressure. The White House ought to be with us on this one, we
ought to make sure that we have someone fully discloses what is going on to the appropriate
committees and to Congress. Not someone involved in Iran Contra and not someone who hasnt told
the entire truth. And not someone who is in question about these activities. This has to be a definitive
decision by the Congress, that this individual will come clean with the Congress and fulfill not just the
letter of the law, but the spirit of the law.
Page 15 of 20
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[Ted Koppel] Alright, let me just interrupt here for a moment, because were down to our last
minute and a half or so, Alan, it is inevitable in this kind of investigation that you run into a lot of
sleazy characters and I just want to get from you for our audience some sense of how much of the
information that we have compiled here comes from the sleazy characters and how much comes from
the few that we can really rely upon?
[Alan Friedman, New York Correspondent for the Financial Times of London] I think, ah Ted
the important thing to remember here is that we have had all kinds of allegations for the last three
months when our team has interviewed dozens of people, weve been acidulously cross checking and
weve waited to go ahead with this story until weve had very credible witnesses. Those who were
documented CIA operatives and those who were physically with Mr. Gates during those meetings, and
we asked some of them why would Mr. Gates take the risk and go out and meet with Mr. Cardoen and
get directly involved and get his hands dirty in these operations, especially as he was deputy director
of the CIA at the time himself.
improvtoire in order to make sure the job got done. Weve talked to a number of top people and cross
checked.
[Ted Koppel] Alright, Alan Friedman thank you very much, Congressman Gejdenson, thank you
very much, Ill be back in a moment.
END
Page 16 of 20
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Whistle-Blowing Activities Starting in June of 1987, local, state, and federal authorities were
called by Stanley J. Caterbone, including the Federal Bureau of Investigation, the Federal Securities
and Exchange Commission, Congressman Robert Walker, the Pennsylvania Attorney General, the
Lancaster District Attorney, Manheim Township Police, and a host of others.
The following is a memo of a meeting with ISC executive Mr. Lawrence Resch and Mr. Stanley J.
Caterbone at his office at Financial Management Group, Ltd., which took place on June 23, 1987. Mr.
Lawrence Resch, of San Clamente, California, was a long time associate of Mr. James Guerin who
worked as a marketing consultant, and was an ISC executive prior to the company going public in
1982. He served as Director of Marketing and head of Lancaster operations for then defunct United
Chem Con, an affiliate of ISC. He was sued by Ferranti International in 1990 for $189 million dollars
and indicted and found guilty by prosecutors for his role with ISC and served a jail term.
Upon the arrival of Mr. Larry Resch, Stan Caterbone met him in the lobby of Financial Management
Group, Ltd, at which time Larry Resch said "Carl Jacobson could not attend, we had to suddenly fly him
out of the country early this morning (flew to Chile) The meeting was started with the subject of the
financial difficulties of United Chem Con and possible alternatives. Larry Resch specifically addressed
the possibility of moving the operations of United Chem Con to another facility, with specific regards to
the Renovo Plant. Larry Resch specifically addressed the financing capabilities of Stan Caterbone,
along with possible management opportunities. Larry Resch also gave financial statements and
documents to Stan Caterbone for the latest fiscal year for United Chem Con. Stan Caterbone went on
to allege that United Chem Con had embezzled some $15,000,000 from the United States
Government for contracts that contained improprieties. Stan Caterbone also alleged improprieties of
International Signal & Control and James Guerin, with specific regards to its role in the United Chem
Con, and its business activities as related to government contracts. Stan Caterbone noted that he, as a
legal shareholder of International Signal & Control was concerned about improper business activities.
Larry Resch was taken by surprise by all of the above. Stan Caterbone became quite upset by the
evasiveness and the lack of specifics with regards to Larry Resch's conversation. In efforts to thwart
any further communication from James Guerin, United Chem Con, or International Signal & Control,
Stan Caterbone demanded a retainer fee of $10,000 before anyone contacted him again.
The following is a transcript of a meeting with Agent Howard Eisler, of the Pennsylvania Securities
Commission on September 29, 1987. The meeting was solicited at the bequest of Agent Howard Eisler
supposedly for an investigation into securities violations at Financial Management Group, Ltd.,
However, that also turned out to be untrue, or Agent Eisler also ignored all of the violations that
occurred at the company headquarters.
Stanley J. Caterbone. Also present were attorney Mr. Robert Byers, and client of Stanley J. Caterbone,
Mr. Millard Johnson. Agent Howard Eisler, in November of 1987, requested that Stanley J. Caterbone
Page 17 of 20
02/21/2007
put any complaints or grievances in writing and never did anything with information or testimony from
the meeting.
[Stanley J.
Management Group, Ltd., and President of FMG Advisory, Ltd.,] - Chem Con is the big local
minority-held corporation that was doing a lot of Defense contracts-it was associated with ISC. They
went under last spring, beginning of the summer, and there was a lot of criminal allegations made,
none of them substantiated. And I was connected with that. They sent a board member in to see me a
week before this happened. Why. I don't know. Jim Christian owned it - now I hear rumors that I was
tied to ISC and I am close to several people in that organization. Why they sent someone in to
California to see me, I don't know. They wouldnt answer me. They wanted me to talk to a guy from
D.C., New York, a guy from the Caribbean. I don't know what the hell is going on.
[Mr. Robert Byer, Criminal Attorney for Stanley J. Caterbone] the supposition was - I don't
know how true it was a front for ISC.
[Stanley J.
Management Group, Ltd., and President of FMG Advisory, Ltd.,] - It was, I'll tell you why.
Because when Chem Con was started, back to their inception, you look at ISC's books. They didn't
have any money. Well, the fist thing Chem Con did was they went and got all that free money from
the government and you look where that money went. I bet I know where it went. This guy named
Guerin, James Guerin. And I know that they were selling contracts back. He runs ISC and he also has
his fingers pretty deeply into Chem Con. He's the one who started Chem Con, Guerin is the one who
started it.
[Mr. Millard (Bill) Johnson, Client of Mr. Stanley J. Caterbone] - Wasn't there some allegations
about a tie to Wedtech? (Defense Contractor of New York)
[Stanley J.
Management Group, Ltd., and President of FMG Advisory, Ltd.,] - You bet. They were tied, you'd
better believe they were tied with Wedtech. The same guys in Wedtech were invoked with ISC and
Chem Con.
ISC is sold over the London Exchange. (I bought my shares from Pennsylvania State
Senator Gibson Armstrong) I owned a thousand shares. I sold it when things started to hit the fanthey just did a multimillion dollar merger with a company in London. They probably think this is going
to cover their tracks. What they did was, they fronted all that money and started the contracts, went
bankrupt, and now the government is stuck for $18,000,000.
viewpoint, I stole money, I am insane, and I am a lunatic I tell you I will not condemn Jim Christian
until he tells to my face what happened. "I was framed and set up. I dont know maybe Jim Christian
doesn't have the money. Maybe Guerin has it or somebody else has it.
Advanced Media Group
Page 18 of 20
02/21/2007
__________________________________________________________________
ARGUMENT
__________________________________________________________________
Keith, 407 U.S. at 313-14. There, the Court explained that
[n]ational security cases . . . often reflect a convergence of First and Fourth Amendment values . . . .
Fourth Amendment protections become the more necessary when the targets of official surveillance
may be those suspected of unorthodoxy in their political beliefs. The danger to political dissent is acute
where the Government attempts to act under so vague a concept as the power to protect domestic
security.
Id. The Court thus concluded that Fourth Amendment freedoms cannot properly be guaranteed if
domestic security surveillances may be conducted solely within the discretion of the Executive Branch.
The Fourth Amendment does not contemplate the executive officers of Government as neutral and
disinterested magistrates. . . . The historical judgment, which the Fourth Amendment accepts, is that
unreviewed executive discretion may yield too readily to pressures to obtain incriminating evidence
and overlook potential invasions of privacy and protected speech. . . . [T]his Court has never sustained
a search upon the sole ground that officers reasonably expected to find evidence . . . and voluntarily
confined their activities to the least intrusive means . . . . The Fourth Amendment contemplates a prior
judicial judgment, not the risk that executive discretion may be reasonably exercised.
Page 19 of 20
02/21/2007
CERTIFICATE OF SERVICE
I hereby certify that on February 21, 2007, I have mailed by U.S. Postal Service, by electronic means, or by
facsimile the foregoing paper to the following (funds permitted) :
ANN BEESON
Attorney of Record
JAMEEL JAFFER
MELISSA GOODMAN (admission pending)
CATHERINE CRUMP (admission pending)
National Legal Department
American Civil Liberties Union Foundation
125 Broad Street, 18th Floor
New York, NY 10004-2400
(212) 549-2500
MICHAEL J. STEINBERG
KARY L. MOSS
American Civil Liberties Union Fund of Michigan
60 West Hancock Street
Detroit, MI 48201-1343
(313) 578-6814
Kate Martin
CENTER FOR NATIONAL SECURITY STUDIES
60 1 Thirteenth Street, N. W.
1120 19th Street, N.W.,
Washington, DC 20036
(202) 72 1-5650
Joseph Onek Erin N. Linder
Sharon Bradford Franklin
THE CONSTITUTION PROJECT
1025 Vermont Avenue,
Washington, DC 20005
(202) 580-6920
Donald B. Verrilli, Jr.
JENNER & BLOCK LLP
S. 800 Suite 1200 South
Washington, DC 20005
(202) 639-6095
JENNER & BLOCK LLP
330 N. Wabash Avenue
N. W. Chicago, IL 60611
(312) 222-9350
Randy Gainer
Davis Wright Tremaine LLP
1501 Fourth Avenue, Suite 2600
Seattle, WA 98101 - 1688
Douglas N. Letter
Thomas N. Bondy
Anthony A. Yang
Attorneys, Appellate Staff
Washington, DC 20530
Civil Division, Room 7513
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530
____________/s/________________
Stanley J. Caterbone, Pro Se Litigant
1250 Fremont Street
Lancaster, PA 17603
717-427-1821 facsimile
Page 20 of 20
02/21/2007
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www.amgglobalentertainmentgroup.com
mailto:amgroup01@msn.com
717.427-1621 Fax
Stanley J. Caterbone
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
Respectfully,
Stan J. Caterbone
Pro Se Lititgant
http://eedition.lancasteronline.com/pages/news/edition/NEPM/2008...
1 of 2
2/19/2008 4:21 PM
http://eedition.lancasteronline.com/pages/news/edition/NEPM/2008...
The law does makes provisions for emergencies, but the paperwork
still must be completed within a few days.
Democrats who let the FISA law expire insist America is no less safe
from another terrorist attack. But can they be so sure?
The only thing certain is that Americans are not now getting the full
benefit of FISA protection. This is unacceptable.
We should be protecting the American people, not the terrorists.
The eavesdropping won't end; it just makes the task that much
harder for our intelligence officials.
2004-2007 Lancaster Newspapers
2 of 2
2/19/2008 4:21 PM
Stan J Caterbone
Project Hope Foundation
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
:
:
CD 6 208A
Respectfully Submitted:
__________________
__________________
SSS
Stanley J. Caterbone, Pro Se
Project Hope Foundation
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com
Page 1 of 35
TABLE OF CONTENTS
1. BACKGROUND OF MOVANTS
Page 3
a. Stanley J. Caterbone
b. Project Hope
c. Advanced Media Group
2. PREFACE TO ISSUES BEFORE THE COURT
Page 7
Page 8
Page 11
5. CERTIFICATE OF SERVICE
Page 12
6. EXHIBITS ___
Page 13
Page 13
Page 16
Page 29
f.
Page 22
Page 24
Page 28
Page 33
Page 2 of 35
BACKGROUND OF MOVANTS
Stanley J. Caterbone (CATERBONE)
CATERBONE has been following very closely the case of Meghan Lippiatt and was a witness
to the trial on one of the few last days before the Honorable Judge James P. Cullen in the
Lancaster County Court of Common Pleas to hear the testimony of Psychiatrist Dr. Gotlieb of the
Lancaster General Hospital.
known law expert and constitutional scholar Jonathan Turnley on December 19, 2007 days after
the conclusion of the trial. Jonathan Turley, like other national experts, had posted an opinion on
the Lippiatt case after the verdict and conclusion of the trial. The response is EXHIBIT A.
CATERBONE has been involved with Project Hope Foundation for more than 10 years and
has conducted extensive research in the field of mental illness and has been an advocate for
mental illness for almost 3 decades.
1960s and has been an extremely challenging dilemma resulting in the untimely and suspicious
deaths of two brothers in their 30s.
Christmas day of 1984 with the death being ruled a suicide, but now known to have been a
murder. In 1996 his youngest brother, Tom had committed suicide and the circums tances are
currently being litigated in the federal courts as a wrongful death complaint.
CATERBONE has
researched and investigated the causes of both deaths as it relates to the issue of mental illness
and has conducted research and instigations into his own malicious diagnosis of his own mental
health record. His father, Samuel, has a history of mental health records however; he too has a
history of psychic phenomena and a history of suspicious activities with the United States
Government and the Lancaster community. His mental health record is also in dispute. He was a
very successful businessman and had served in the U.S. Navy as a radioman and graduated from
gunner school with honors. He also developed new technologies for the Dry Cleaning industry. He
has also conducted extensive research into areas concerning U.S. Government activities.
CATERBONE has developed relationships with mental health professionals for his work with
Project Hope and has been the main person responsible for coordinating and administrating the
mission of creating awareness and education to the community-at-large with the distribution of
Project Hopes video Numbers Dont Lie; including to the Mental Health and Retardation
Department of the County of Lancaster this past year. CATERBONE has worked extensively with
Contact Lancaster, the Mental Health Alliance of Lancaster County, and other mental health
organizations as well faith based organizations.
professionals and organizations in the field; especially since C. EvreTt Koop, the former U.S.
Surgeon General and Tipor Gore made mental health awareness a top priority in 1998. Tipor Gore
also received the Project Hope video for distribution as a resource for other non-profit
organizations. CATERBONES research includes national and local trends of suicides; symptomatic
Page 3 of 35
behavior in bi-polar and manic depression; and the issues and stigma confronting those affected
with mental illnesses.
CATERBONE brings a unique perspective to the courts that may help to shed light into how
people with mental illnesses are treated unfairly by family, friends, and the community-at-large.
It should be noted that CATERBONE is also telepathic with a history of psychic traits in his family
dating back 2 generations. CATERBONE is currently engaged in extensive litigation challenging his
own mental health record, treatment, and diagnosis in federal and state courts. His own mental
health record includes 2 fabricated suicide stories that are part of the record in hospitals and with
police departments; this is in addition to the 30 false arrests. Mental health and criminal records
can be very damaging in destroying a persons credibility and reputation and ultimately his
professional and personal life if not respected by all.
CATERBONE is presently the founder of Advanced Media Group and conducts his business
from Lancaster County, Pennsylvania. For the past several years, in addition to appearing before
the courts as a pro se litigator, Advanced Media Group has been developing several business
interests in the revitalization of downtown Lancaster,
Copy and Shipping Store; the Theater at Hotel Brunswick; and the Excelsior Place Business Plan,
In 2006 CATERBONE began his role as an Activist Shareholder for Fulton Financial, which
is listed as "FULT" on the NASDAQ stock exchange. As a founder of Financial Management Group,
Ltd., a full service financial firm, CATERBONE has drawn upon the success in developing the
strategic vision for his company and the experience gained in directing the legal affairs and public
offering efforts in dealing with Fulton Financial.
In 2005 CATERBONE, as a Pro Se Litigant filed several civil actions as Plaintiffs that are in
current litigation in the United States District Court for the Eastern District of Pennsylvania, the
United States Third District Court of Appeals, the Pennsylvania Supreme Court, The Pennsylvania
Superior Court, the Commonwealth Court of Pennsylvania, The Court of Common Pleas of
Lancaster County, Pennsylvania. These litigations include violations of intellectual property rights,
anti-trust violations, and interference of contracts relating to several business interests. Central to
this litigation is the Digital Movie, Digital Technologies, Financial Management Group, Ltd,/FMG
Advisory, Ltd., and its affiliated businesses along with a Federal False Claims Act or Federal
Whistleblowers Act regarding the firm of International Signal and Control, Plc., (ISC) the $1Billion
Dollar Fraud and the Export violations of selling arms to South Africa and Iraq. This litigation dates
back to 1987. CATERBONE was a shareholder of ISC, and was solicited by ISC executives for
professional services. The Federal False Claims Act is currently part of RICO Civil Complaint in the
United States District Court for the Eastern District of Pennsylvania and the Third Circuit Court of
Appeals, as docket no. 05-2288.
Page 4 of 35
A complete biography and history is located on the website of Advanced Media Group at:
www.amgglobalentertainmentgroup.com
PROJECT HOPE
Project Hope Foundation was founded in 1996 after the untimely suicide of Thomas P. Caterbone,
brother of Stanley J. Caterbone.
W. Caterbone of Austin Texas, and other friends and relatives that wanted to continue the legacy
of Tom Caterbone and make a contribution to the community-at-large in dealing with mental
health issues and mental health awareness.
In 1996 Project Hope Foundation produced the extremely successful instructional video Numbers
Dont Lie for helping teenagers deal with suicide and help them to identify kids which may be at
risk. The video was produced and directed by Dr. Phil Caterbone & Psychologist Craig Crabtree,
both of Austin, Texas. The video is a approximately 20 minutes and is accompanied by an
instructional workbook for the monitors and a workbook for the students. "Numbers Don't Lie"
has been sold to the Texas School Board of Education to pay for its development and production.
The video has been provided to other Faith Based non-profit organizations, school districts, church
groups, and municipalities by CATERBONE and Advanced Media Group over the past 10 years.
The video can be viewed online at: www.advancedmediagroup.youtube.com and clic king on the
Numbers Dont Lie video.
Project Hope provided funding for the Mental Health Alliance of Lancaster County, Contact/Lifeline
of Lancaster (The 24/7 Suicide Hotline), The Schreiber Pediatric Center, and other charitable
organizations and faith based charities. In 1999 Project Hope donated and constructed a soccer
field on the new Headquarters of the Schreiber Pediatric Center on Goods Road, in Lancaster.
Tom's Project Hope is funded by an annual golf tournament on the 1st Saturday in August, called
the Tommy Caterbone Memorial Golf Tournament.
The Lancaster County Mental Health/Mental Retardation department is currently using the video
as a resource Mental Health/Mental Retardation Department.
ADVANCED MEDIA GROUP
In 1989 CATERBONE founded Advanced Media Group, Ltd., which was one of only 4 or 65
U.S. domestic companies that had the capability to manufacture CD-ROM's.
Advanced Media
Group also developed tools, applic ations, and provided consulting to information technologies.
Page 5 of 35
Advanced Media did business with commercial companies, government agencies, educational
institutions, and foreign companies including the Department of Defense; NASA, National
Institution of Standards & Technology (NIST); Department of Defense, The Defense Advanced
Research Projects Agency (DARPA); and the Defense Mapping Agency, Central Intelligence
Agency; (CIA), IBM; Microsoft, AMP; Commodore Computers, American Bankers Bond Buyers;
and a host of others. I also was working with R.R, Donnelly's Geo Systems; which was developing
various interactive mapping technologies, which is now a major asset of Map Quest. Map Quest is
the premier provider of mapping software and applications for the Internet and is often used in
delivering maps and directions for Fortune 500 companies.
Advanced Media Group now has interests in various business and fields including the film and
entertainment industries; information technologies; revitalizations of downtown Lancaster;
Research and Study in Mind Control and ESP; and the fulfillment and distribution of past
intellectual property assets.
PREFACE TO ISSUES BEFORE THE COURT1
Upon the verdict of the lower court trial of not guilty by reason of insanity, CATERBONE
posed the question of why a condition for release of a psychiatric evaluation was not issued by
presiding Judge James P. Cullen. This is evident in the Jonathan Turley Post of December 19,
2007 which states the following:
Here is a brief synopsis; In the VERDICT ORDER there did not seam
to be any condition for Ms. Liappatt to be held in custody until a
further psychiatric evaluation could be performed. This set in motion
a number of court filings by the District Attorney, the Defense
Counsel, and others trying to recommit her to a treatment facility.
There has been much research done on the subject of conditional releases in not guilty by
reason of insanity cases throughout this country and most all have concluded that conditional
releases are a very acceptable and successful legal alternative to quell the public fear and
animosity of persons getting away with murder.
variety of post verdict mental health treatment plans that may include community participation
The legal opinion of Stan J. Caterbone was formulated on or before December 19, 2007 prior
to conducting any research on the topic or using any internet search engine to define the words
conditional release or any similar terminology. Stan J. Caterbone again is suspicious of the
dates of the post on the Jonathan Turley blog of December 19, 2007. The post may have been
posted prior to that date.
Page 6 of 35
until it can be proven by a certified psychiatrist that the person no longer poses any threat to
society before being released into the community.2 3
SECTION 304 OF THE PENNSYLVANIA MENTAL HEALTH PROCEDURES ACT P.S. 7304 IS
OPEN TO THE PUBLIC.
2. DID THE COURT GIVE DUE CONSIDERATION TO THE CLAIMS BY MEGHAN LIPPIATT
REGARDING RETALIATION BY THE PUBLIC DURING AND AFTER A PUBLIC HEARING ON
THE ISSUES.
Geoge M. Parker, MD Under conditional release, such acquittees are released into the
community with various conditions imposed; for example, they are often required to live in
specified housing and not to use illegal drugs. They remain under the jurisdiction of a criminal
judge or a central monitoring agency, such as a psychiatric security review board. Adherence to
mental health treatment in the community is almost always a condition of release. As leverage,
this type of mandated community treatment uses both avoidance of jail and avoidance of
hospitalizationboth a brief jail stay and rehospitalization are possible consequences of
violation of the conditions of release, depending on the state. See Exhibit B.
3
See Exhibits A thru D.
Page 7 of 35
Under Section (e) 4. of the Section 304 of the Pennsylvania Mental Health Procedures
Act P.S. 7304 it clearly states the following:
The hearing shall be public unless it is requested to be
private by the person or his counsel.
In Judge James P. Cullen ORDER and OPINION of July 11, 2008 Judge Cullen appears to
be abusing his discretion by mandating a higher burden and threshold for showing good cause
why Ms. Lippiatt is entitled to her request of a closed hearing. It also appears that Judge Cullen
is trying to pacify the public interest and outcry when Meghan Liappitts was released at the
conclusion of her trial, which should have been addressed with a condition for release, which
Judge James P. Cullen failed to address in his VERDICT ORDER of December 13, 2008.
HIPAA CONSIDERATIONS
The privacy laws of health records addressed with the passage if the Health Information
Portability and Accountability Act (HIPAA) in 1996 may have some controlling interest in these
matters. A summary of HIPAA is as follows:
A major upshot of the Health Insurance Portability and Accountability Act
(HIPAA) of 1996 is a series of federal rules that have a considerable impact on
providers and patients their interactions, their rights, and their responsibilities.
In sorting through the details and compliance requirements of the privacy rule in
particular, it helps for practitioners to know something of the historical and
political context in which HIPAA and the rules that resulted from this law took
shape.
Under HIPAA, Congress tasked the Department of Health Human Services (HHS)
with developing federal rules that govern how patient records are handled,
shared, and protected in the health care system. The transactions rule, the
first rule promulgated by HHS, provides for standard formatting of electronic
patient records for health care claims and other purposes. This rule benefits
health professionals by making it easier for them to work with uniform rather
than multiple claims forms. While more rules will follow, the 800-pound gorilla
of the series, the privacy rule, was finalized last April. The privacy rule
provides some important protections for psychology records, with provisions that
will impact the confidentiality of the psychologist-patient relationship. 4
See Exhibit F: A Look Behind the Scenes of HIPAA and the Privacy Rule by Doug Walter, J.D.
Page 9 of 35
An Open Hearing would be placing mental health records in the public domain
and may be a violation of the rights of Ms. Lippiatt as defined in the HIPAA code.
The general public really has no interest in the process or the Section 304 of the
Pennsylvania Mental Health Procedures Act P.S. 7304 hearing, but rather has an interest in the
conclusion of the hearing in protecting itself from someone whom may pose a danger or threat
to others. That danger and or threat to the community-at-large is not compromised nor is it
supported by an open hearing. That danger and or threat is only of importance and relevant if
Ms. Lippiatt is found to have a mental health illness and is not committed for treatment. The
question of an open or closed hearing is not relevant, only the conclusion of the matters that
will be presented to the courts.
II) DID THE COURT GIVE DUE CONSIDERATION TO THE CLAIMS BY MEGHAN LIPPIATT
REGARDING RETALIATION BY THE PUBLIC DURING AND AFTER A PUBLIC HEARING ON
THE ISSUES?
Stanley J. Caterbone has been subject to an unprecedented history of retaliation and
intimidation that has been the result of a stigma due to his mental health record. Although this
mental health records validity and authenticity is being challenged in several courts, the stigma
and treatment by the community-at-large is real and can be used to substantiate Ms. Lippiatts
claim of retaliation in her opposition to an open hearing. Subjecting Ms. Lippiatt to unnecessary
intimidation and retaliation for information that would be made public during an open hearing is of
concern to all who may face similar circumstances.
Stanley J. Caterbone has a criminal record of some 30 false arrests in Lancaster County
that would have never been possible without his mental health record. Law enforcement relied
upon the fact that Stanley J. Caterbone had a history and mental health record to discredit him
before the courts, in his arrests, although he was successful in having those arrests and
convictions dismissed and overturned.
Stanley J. Caterbone also must endure a systematic and problematic attack of harassment
in public that is also due to the same mental health record and his fabricated and diminished
reputation caused by the same.
The fact that Ms. Lippiatt was found not guilty by reason of insanity of murdering her small
children should compel the court to consider her claims of retaliation more seriously. If the courts
do no recognize the risks involved to Ms. Lippiatt and others that may come before the courts in
similar circumstances, the courts should be compelled to provide the burden of proof that would
Page 10 of 35
CONCLUSION
The Lippiatt case is apparently precedent in the County of Lancaster of a person being found
not guilty by reason of insanity. That being the case, the court should take extra precaution in
protecting all parties in all related matters and should be careful when reaching opinions and
conclusion that will be precedent to future and similar parties that will come before the courts.
Judge Cullens ORDER and OPINION of July 11, 2008 fails to protect the rights of Ms. Lippiatt
and others that may come before the courts, but does so unnecessarily. Closing the hearing to
the general public would not diminish the public interest, nor would it make the general public
safer. Only a conclusion of an involuntary commitment of Ms. Lippiatt IF she does now possess a
mental health illness that does pose a threat or danger to others.
__________________
__________________
Respectfully Submitted:
Page 11 of 35
CERTIFICATE OF SERVICE
Service was made on this 21s t day of July 2008 upon the following by way of electronic
mails; first class U.S. mails; or personal delivery at the addresses set forth below:
__________________
__________________
Respectfully Submitted:
Page 12 of 35
EXHIBIT A
Page 13 of 35
Pa. Woman Who Killed Her Two Children Found Not Guilty by
Reason of Insanity
Published 1, December 11, 2007 Criminal law , Justice by Jonathan Turley
Meghan Lippiatt has been found not guilty by reason of insanity in a Lancaster court. Lippiatt
admitted suffocating her infant son and drowning her 2-year-old son in 2004.
The killing two-year-old Silas and his four- month-old brother Miles occurred weeks after a
break-up with her husband.
Lippiatt called 911 and told the operator: I did something really bad, I just killed my kids.
She later tried to kill herself and left a note which read: I am sorry, I didnt want to hurt
anyone. I am sorry, goodbye, please help me from the grave.
There is growing interest in allowing greater use of the insanity defense after it was heavily
curtailed after the shooting of President Ronald Reagan.
For a prior column on the insanity defense, click here
For the full story, click here
This is my analysis. And for the record, I did attend the trial and sat to hear
Gottlieb, the psychiatrist testify and be cross-examined. I have also studied
mental health issues for Project Hope, for my own case, and for my familys
different cases, especially my father and brothers Sam and Tom; for over 20
years. So I am not uneducated with the issues.
Being that this is the first such verdict of not guilty by reason of insanity in
Lancaster County, as reported, I think this whole case was purposely
mismanaged so that the next time such a verdict is before a Lancaster County
jury, they can say see, if you find the defendant not guilty by insanity, that
person may be released and freed without any treatment or conditions.
I think Judge Cullen should have to explain why he did not issue a
condition in his verdict to have Ms. Lippiatt held in Lancaster County
Prison or transferred to a mental health facility until the outcome of a
psychiatric evaluation. I dont understand why he did not do this, unless
the law prevented him from doing that. I will have to research this.
I would love to hear your opinion, if you find the time. Hope to meet you in the
future.
STAN J. CATERBONE
Advanced Media Group
Page 15 of 35
EXHIBIT B
Page 16 of 35
Professor Turley received his B.A. at the University of Chicago and his J.D. at Northwestern. (In
2008, he was given an honorary Doctorate of Law from John Marshall Law School for his
contributions to civil liberties and the public interest).
For further information: Ms. Kristen Hilderbrand 202-994-0537
Page 18 of 35
EXHIBIT C
Page 19 of 35
Letters
Conditional Release and Mandated Outpatient Treatment
George F. Parker, M.D.
To the Editor: In the thoughtful and stimulating article on mandated outpatient treatment by
Monahan and colleagues in the September 2001 issue (1), little mention was made of the fairly
substantial literature on mandated treatment of forensic populations in the community.
Conditional release has been used for decades as a technique for managing the risks inherent in
returning a person found not guilty by reason of insanity to the community.
Under conditional release, such acquittees are released into the community with various
conditions imposed; for example, they are often required to live in specified housing and not to
use illegal drugs. They remain under the jurisdiction of a criminal judge or a central monitoring
agency, such as a psychiatric security review board. Adherence to mental health treatment in
the community is almost always a condition of release. As leverage, this type of mandated
community treatment uses both avoidance of jail and avoidance of hospitalizationboth a brief
jail stay and rehospitalization are possible consequences of violation of the conditions of
release, depending on the state.
I recently conducted a thorough literature search, using PubMed and manual strategies, on the
topic of conditional release for persons found not guilty by reason of insanity. I found more than
60 articles, including more than 30 published in the past ten years. Many of the earlier studies
on conditional release focused on the demographic characteristics of persons found not guilty by
reason of insanity. However, most of the articles on this subject for the past 30 years have
reported arrest rates and hospitalization rates of persons on conditional release. A recent metaanalysis on this issue, based on statewide results from New York, California, and Oregon, found
estimated annual arrest rates to range from 3.4 to 7.9 percent, while the estimated annual
hospitalizatio n rates ranged from 14.5 to 25.8 percent (2,3). I recently presented a poster at
the annual meeting of the American Academy of Psychiatry and the Law showing that among
persons receiving assertive community treatment the annual arrest rate was 1.2 percent and
the annual hospitalization rate was 14.5 percent (4). In addition, some of the published reports
have included statistical models for factors that are predictive of the granting or revocation of
conditional release (5).
The literature on conditional release of persons found not guilty by reason of insanity thus may
hold some of the answers to the many questions about mandated community treatment posed
by Monahan and colleagues. In particular, the issues of the process of mandating treatment,
the outcomes of programs both for the individual and for the systemthat do mandate
treatment, and the legal, ethical, and political questions that result from mandating treatment
in the community have all been discussed, to greater or lesser degrees, in the conditional
release literature over the past 30 years.
Footnotes
Dr. Parker is associate professor of clinical psychiatry at Indiana University School of Medicine
in Indianapolis.
References
1. Monahan J, Bonnie RJ, Appelbaum PS, et al: Mandated community treatment: beyond
outpatient
commitment.
Psychiatric
Services
52:1198-1205,
2001[Abstract/Free Full Text]
2. Wiederanders MR, Bromley DL, Choate PA: Forensic conditional release programs and
outcomes in three states. International Journal of Law and Psychiatry 20:249-257,
1997[CrossRef][Medline]
Page 20 of 35
3. Harris VL: Insanity acquittees and rearrest: the past 24 years. Journal of the American
Academy of Psychiatry and the Law 28:225-231, 2000[Medline]
4. Parker GF: Low reoffense rate in a conditional release program. Poster presented at the
annual meeting of the American Academy of Psychiatry and the Law, Boston, Oct 25-28,
2001
5. Callahan LA, Silver E: Factors associated with the conditional release of persons
acquitted by reason of insanity: a decision tree approach. Law and Human Behavior
22:147-163, 1998[CrossRef][Medline]
Page 21 of 35
EXHIBIT D
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Monitored treatment in the community, also known as conditional release, has been described
a s the most important advance in the treatment of insanity acquittees in the last decade.
Despite the importance of the development of conditional release, however, there has been
relatively little written about relevant issues and planning principles important in designing and
implementing conditional release systems. The present paper discusses important
considerations relevant to conditional release that are associated with key decision points
within systems for persons found not guilty by reason of insanity (NGRI). Four planning
principles, generalizable to all NGRI systems, are then presented in a way that integrates the
previous discussion. It is concluded that conditional release plays a crucial role in the treatment
of insanity acquittees and that mental health administrators may either proactively modify their
systems, in a way that balances public safety with individual rights and treatment needs, or
wait for the modification mandate to be forced upon them in the wake of a highly publicized,
heinous offense.
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EXHIBIT E
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management process.
By the mid 1990s, the insurance and business lobbies began pitching to Congress that a
uniform, electronic patient records system to standardize health insurance claims processing,
dubbed administrative simplification, would save the health care system billions of dollars
and relieve the inefficiency and fragmentation in health care claims management. Insurers
were also looking for a federal law that legitimized their demands for broad access to patient
records. While organized psychology supported administrative simplification, it could not come
at a cost to records privacy.
APA was at the forefront of groups concerned that the onerous MCO demands for patient
records disclosures often for administrative purposes not directly related to patient care
had eroded confidentiality. Provider and patient organizations advocated for privacy and
security safeguards that would be needed if Congress were to mandate uniform electronic
claims processing.
The stage for political conflict therefore was set by the time President Clinton included both
patient records privacy and administrative simplification provisions in his Health Security Act
of 1993, which failed to win passage. The inclusion of these provisions shed light on the
bitter fight brewing between patients/providers and MCOs over control of records and
foreshadowed the rancorous congressional debate to come. The underlying conflict, which
continues to this day, was the force that shaped HIPAA law in general and the privacy rule
specifically.
Battle Pits Provider Groups Against Insurers
The advocacy battle began in earnest when Senator Robert Bennett (R-Utah) introduced the
Medical Records Confidentiality Act in late October 1995. The Practice Directorate was
concerned by the Bennett bills bipartisan co-sponsorship by powerful members of Congress
and by the strong support of insurers and other influential organizations. The concern arose
from APAs taking a careful look at the bills details. The directorates analysis revealed
substantial weaknesses in protecting the rights of patients and providers with respect to the
privacy of records. APA and allied groups mobilized to prevent the Bennett bill from being
included in broader health care legislation that Congress also was seriously considering that
fall. That broader legislation eventually was enacted as HIPAA.
A "Final" Rule Is Subject to Change
The political battle between insurance and patient and provider organizations continues to
this day. President George W. Bushs Administration put the HIPAA privacy rule into effect
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the rules privacy protections, and even expanding them. For example, the MHLG
continues to urge that the special privacy protection given to psychotherapy notes as
defined in the rule (see article on page 5) should be broadened to apply to other sensitive
information such as psychological testing data.
For several months, the directorates government relations staff worked to educate Congress
and the public about the need for a strong federal privacy bill, or at least a bill that would not
undermine existing state privacy laws that protected patients rights. APAs lobbying push
successfully countered the insurance industrys efforts to win inclusion of the Bennett bill in
HIPAA. In place of the Bennett bill, Congress incorporated a few sentences into HIPAA to
provide a timeline for action. Legislators gave themselves three years, until August 1999, to
enact a federal law governing records privacy and further directed that HHS would establish a
privacy rule within six months of Congress failure to meet its deadline.
Shortly after HIPAAs passage, it became increasingly clear that the patient and provider
lobbies and the insurance lobby were entrenched in polar positions. APA assessed that
Congress would not likely pass legislation. While the association continued to advocate for
appropriate privacy legislation in Congress, APA began focusing efforts on the Administration
in anticipation of a rule from HHS. Organized psychology sought a rule that would recognize
the particular privacy requirements of records associated with mental health treatment,
including the need for heightened protection for psychotherapy notes and other mental health
records.
Too Hot for Congress to Handle
Indeed, the privacy issue ultimately became too controversial for members of Congress to
handle, and HHS ended up proposing a federal privacy rule in November 1999. It looked like a
compromise for both sides of the debate. Insurers saw their broad access to records
recognized in the proposed rule. At the same time, consumers and providers had won strong
protections for records each time they were disclosed to insurers.
Throughout 2000, APA worked to ensure that the proposed rules strong patient protections
were preserved in a final rule. Meanwhile, the insurance lobby pushed to void the rule or at
least substantially weaken its protections. HHS released the final privacy rule in the last days
of the Clinton Administration in much the same form as the proposed rule. The Practice
Directorate considered the final rule a success, with qualification. For example, APA reiterated
in written comments to HHS that the privacy rule allowed insurers too much access to records
for administrative purposes not directly related to treatment. It appeared the conflict and
compromise characteristic of the legislative and rulemaking processes was reflected in the
final rule once it ultimately took effect last April.
The following chronology illustrates from 1993 through 2001 the major events and players
related to the HIPAA law and the final privacy rule from HHS.
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EXHIBIT F
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created their own records which were not subject to the confidentiality provisions of New York
law. Under HIPAA, the likelihood of this problem is substantially decreased since these entities
must now maintain strict confidentiality or face the penalties under the law.
Access By Individuals to Their Own Records
HIPAA creates a general right for an individual to access his or her own health records
subject to a number of exceptions. Additionally, the comments to the regulations state that
individuals have a right of access to information used to make health care decisions or
determine whether an insurance claim will be paid. The four exceptions to the general right of
access to records are:
1) psychotherapy notes;
2) information compiled in reasonable anticipation of, or use in, a civil, criminal or
administrative action and proceeding;
3) where access is prohibited by the Clincial Laboratory Improvements Amendments of
1988: or
4) records that are exempt under the regulations of the Clinical Laboratory
Improvements Amendment. The Clinical Laboratory Improvements Amendments of 1988 is an
act which forbids laboratories doing tests on human specimens to disclose the results to anyone
except the individual or entity who requested the test.
The definition of psychotherapy notes is notes recorded in any medium by a health
care provider who is a mental health professional documenting or analyzing the contents of a
conversation during a private counseling session or a group, joint, or family counseling
session.
Psychotherapy notes are intended to refer to a mental health professionals own
personal notes of a therapy session. Notes do not count as psychotherapy notes unless they
are kept separately from the patients medical chart.
Reviewable Denial of Access to Records
Under HIPAA, other than the unreviewable reasons discussed below, the right of a
patient to see his own chart can be restricted in only three circumstances. Each of these
circ umstances is reviewable by an appeal process.
First, a licensed health care professional may deny access if in the exercise of his
professional judgement it is determined that such access is reasonably likely to endanger the
life or physical safety of the individual or other person. Under this reason for denial, covered
entities may not deny the access on the basis of the sensitivity of the health information or the
potential for causing psychological or emotional harm. A health care professional must find
that the individual has exhibited suicidal or homicidal tendencies and that access to the records
would reasonably result in murder, suicide or other physical violence.
Second, there is a reviewable exception when the requested information relates to
another person (other than the health care provider) and in the professional judgement of the
licensed health care professional, the access would likely cause substantial harm to such
person.
Third, if the personal representative of an individual makes the request rather than the
individual himself, the request may be denied if the provision of access to records to the
personal representative is reasonably likely to cause substantial harm to the individual or other
person.
This scheme is somewhat different from that found in the New York Mental Hygiene
Law. Under New York law, the treating practitioner may review the information requested. If
after consideration of all factors, the practitioner determines that the requested review could
reasonably be expected to cause substantial and identifiable harm to the patient, client or
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others, the facility may deny access to all or a part of the record and may grant access to a
prepared summary of the record.
Unreviewable Denial of Access to Records.
Under HIPAA, there are five areas where an entity may deny access to records without
an opportunity for review of this denial. The areas are:
1) the exceptions to the right of access described above
2) the request of a prison inmate to see his records if obtaining such copy would
jeopardize the health, safety, security, custody or rehabilitation of the prisoner or other
inmates or the safety of the correctional staff.
3) if the protected health information is
contained in records subject to the Privacy Act;
4) the information was obtained from someone other than a health care provider under
a promise of confidentiality and the access would be reasonably likely to reveal the source of
the information.
5) a research subjects request to see his records during research, if the consent form
for the research advised that access to records would be suspended during research and the
patient signed the consent form.
Process of Review of Denial of Access
The review of a denial of the access is to be conducted by a health care professional
designated by the covered entity. This professional may not have been directly involved in
the original denial of the request for access. The review must be conducted in a
reasonable time period but the regulations do not impose deadlines on any entity. There is
no provision for judicial review of this denial.
New Yorks review procedure for a denial of access appears to be more helpful to
consumers. Under the New York Mental Hygiene Law, if access to a psychiatric record is
denied, a patient has the right to appeal for review by the Clinical Records Access Review
Committee. A client must be notified by the facility of his right to a review of the denial by
the appropriate clinical record access review committee. If the client requests this review,
the facility must within ten days of the request, transmit the record to the chairman of the
appropriate committee with a statement setting forth the specific reasons access was
denied. If access is denied by the records access review committee, a patient has a right
to seek judicial review of this denial. Court review must be commenced within 30 days of
receiving notification of the committee decision.
Procedure for Correcting Records
Under HIPAA, an individual has the right to have a covered entity amend protected
health information or records about the individual in a designated record set. An
individuals request for amendment may be denied if the health information or record:
1) was not created by the covered entity;
2) is not part of the designated record set;
3) would not otherwise be available for inspection by the individual;
4) is accurate and complete.
An individual should make a request for the amendment in writing. The entity may
require [that omit DN] the individual to provide reasons to support a requested
amendment to a record. An entity must act on the request within 60 days of the request
for an amendment although this time may be extended once for 30 days if it notifies the
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EXHIBIT G
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Though the mention of the Health Information Portability and Accountability Act (HIPAA)
privacy rule compliance date--April 14--can make some psychologists anxious, most applaud
the new law for increasing privacy protections.
Especially interesting to practitioners is the psychotherapy notes provision, says Russ Newman,
PhD, JD, APA's executive director for practice. The provision recognizes that certain kinds of
mental health information need to be protected more than other types of information. Under
HIPAA, psychotherapy notes are defined as "notes recorded in any medium by a mental health
professional documenting or analyzing the contents of conversation during a private counseling
session." These notes, which capture the psychologist's impressions about the patient and can
contain information that is inappropriate for a medical record, are similar to what psychologists
have historically referred to as "process notes."
HIPAA affords psychotherapy notes more protection--most notably from third-party payers-than they'd been given in the past. Under HIPAA, disclosure of psychotherapy notes requires
more than just generalized consent; it requires patient authorization--or specific permission--to
release this sensitive information. And, whereas in the past insurance companies have
requested entire patient records--including psychotherapy notes--in making coverage
decisions, now health plans cannot refuse to provide reimbursement if a patient does not agree
to release information covered under the psychotherapy notes provision.
"In the past, patients could refuse to have this type of information released, but then the
company might refuse to cover services," notes Newman. "The HIPAA privacy rule protection
stops that kind of practice from taking place."
Psychologists take note
The privacy rule gives rights to health professionals, as well as to their patients. Under the new
law, psychologists can decide whether to release their psychotherapy notes to patients, unless
patients would have access to their psychotherapy notes under state law (see the article about
HIPAA and state laws in last month's Monitor). Though the privacy rule does afford patients the
right to access and inspect their health records, psychotherapy notes are treated differently:
Patients do not have the right to obtain a copy of these under HIPAA. And when a psychologist
denies a patient access to these notes, the denial isn't subject to a review process, as it is with
other records.
There is a catch in the psychotherapy notes provision. HIPAA's definition of psychotherapy
notes explicitly states that these notes are kept separate from the rest of an individual's record.
So, if a psychologist keeps this type of information in a patient's general chart, or if it's not
distinguishable as separate from the rest of the record, access to the information doesn't
require specific patient authorization. According to the Department of Health and Human
Services (HHS), it makes good sense to keep the notes separate since this type of information
should not be available automatically.
This may, says Newman, be a practical difference from the way some psychologists have
previously stored patient information. But, "if psychologists want higher protections for
psychotherapy notes, then they should keep the information separate," he urges.
Daniel Abrahamson, PhD, professional affairs coordinator for the Connecticut Psychological
Association, adds that psychologists "shouldn't jump the gun." Keeping records separate is an
option and "each practitioner will need to determine whether the benefits of maintaining extra
protection outweigh keeping the records distinctly separate from medical records," he says. In
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other words, some psychologists may decide that, for some patients, the information doesn't
particularly need the extra level of protection. If a particular treatment evolves and the
psychologist wants to keep the psychotherapy notes separate, he or she can choose to do that.
"It's part of good clinical judgment," says Abrahamson. "In the past, clinicians didn't include
some information in a record and therefore wouldn't be able to later document that
information. Now they have the option to include detailed content in separate notes."
In addition to keeping these notes separate from other patient information, psychologists
should be aware, says Newman, that there are certain parts of a record that are expressly not
considered psychotherapy notes--and that don't require patient authorization for disclosure-under the HIPAA privacy rule. This information includes medication prescription and monitoring,
counseling session start and stop times, modalities and fre quencies of treatment, results of
clinical tests, and any summary of diagnosis, functional status, treatment plans, symptoms,
prognosis or progress.
This portion of the rule is likely to leave some "potential for interpretation," says Newman.
"What if a managed-care company says it needs a summary of the themes from psychotherapy
sessions? They may say that's outside the psychotherapy notes provision. We'd argue that
divulging themes of the conversations in psychotherapy is tantamount to giving away the whole
conversation," he says.
In the same vein, testing information, like summary information, isn't included under
psychotherapy notes. APA submitted comments to HHS on both the proposed and final rules
asking that psychological test data be included in the provision. Disclosing this type of
information, says Newman, could divulge intimate details about a patient much like the
information from psychotherapy sessions. Unfortunately, he says, HHS declined to expand the
definition.
Despite the exclusion of certain information, however, the psychotherapy notes provision
should be heralded "as a significant victory for privacy advocates," says Nanci Klein, PhD,
professional affairs coordinator for the Utah Psychological Association. "Practitioners have long
found it onerous to have to release psychotherapy notes for additional treatment authorization
by managed-care companies." Now, she says, managed-care companies are only entitled to
certain types of information, not including psychotherapy notes.
"I think this defines the psychologist as the treating expert whose professional analysis and
opinion represent the core information necessary for making judgments about the necessity for
continued treatment," she adds.
This article is the second in a three-part series on HIPAA topics. The next piece, on HIPAA's
minimum necessary requirement, will appear in March.
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