& SMITHEAW.cRouP September 12, 2016 VIA US FIRST CLASS MAIL, AND EMAIL: rkline@pasenate.com Robert J. Kline Director of Administration Office of the Democratic Leader Senate of Pennsylvania Senate Box 203043, Harsisburg, PA 17120 Re: Pennsylvania Liberty Alliance Dear Mr. Kline, We are in receipt 0° letter dated August 29, 2016, which appears to be signed by you and cloaked with all the authority vested in the great Senate of the Commonwealth of Pennsylvania. A copy is atlched for your ease of reference, ‘Your leter purports to inform my clients, Dean Klopp and the PA Liberty Alliance, where they may and whee they may not travel and advocate for their beliefs within the ‘Commonviealth Inthe fog of your power trip, you may be confusing Pennsylvania with North Korea or China, or the Soviet Union of the 1980s. It may do you well to be reminded that this ‘Commonvvealth is the cradle of freedom in the New World and the birthplace of our Bill of Rights, including the right toffee speech, and the right to freely assemble and to freely associate, all of which have miraculously survived hundreds of years of legislatures containing all-o ‘many self-serving individuals such as yourself. Accordingly, si, your crass attempt to stifle these rights in any citizen f this Commonwealth is a disgraceful abuse of your office and is, accordingly, firmly rejected A bit of factual background is appropriate for the benefit of those copied on ths letter. (On August 27, 2016, individual citizens took heed to the eall of my client, PA Liberty Alliance, and canvassed Senator Tepltz’s neighborhood, a they have done in many neighborhoods across the Commonwealth, advocating against a property tax that unfairly bankrupts too many of its senior citizens. AS with all of PLA’s outreach efforts, the canvassing was peaceful, calm informative, and well-received by those in Senator Teplit's neighborhood. Contrary to your selFserving assertions, ther: was no “disturbance,” there were no frightened children, and when Sen, Teplitz made frantic calls hours after the canvassers had left and gone home, the police correctly informed him that no criminal activity had occurred, and no charges were going to be filed. Disappointed with the education he'd received, it would appear that Senator Teplitz convinced you of the justice to be had by invoking the full force and authority of the Pennsylvania Senate to addtess his very private concern, 14135 Kotatow Road, PO, Box 626 | Festwood, Pennsylvania 19522-0626 pone 610048406 | jx 610.944.8408. | jenitnuminlnngsp somSeptember 12, 2016 Page 2 Despite your absurd claim that door-knockiag and pamphletering amount to “wespssing,” the law ofthe Commonwealth allows any person to approach any home and knock cn the door unless affimaive actions are taken by the homeowner (such as the faniliar “No “Trespssing” or “No Solicing” signs) to inform the visitor that he i nat welcome. OF course, Senator Tepit knows thi alto well a he “knocked on ot of doors” during his campaign in 2012, and “pans to work as hard and knock on as many doors” again this year? Your lt, Seat on Beha ofthe office of Senator Jay Costa and the Pennsylvania Nena, makes Senalor “Teplit’s private preference known to my’clens for the frst ime. From now on, my client will agree not to vist Senator Teplitz’s home, Please inform Senator Teplitz that he is likewise unwelcome at the home of Mr: Klopp. Neither Senator Telit, nor the Pennsylvania Senate, however, have authority to restict my client’ righ to visi, advocate or canvas in his neighborhood, to prohibit my cient fom Visiting publisly-fonded goverment office buildings, to prohibit etzens fom posting pstres ‘ot subject to any reasonable claim of privacy on soci media, orto keep my’ lint fom showing up at public evens. hasten to advise you that neither you no Senator Teplit nor the Pennsyvania Senate have 2over to create floating bubble of warm and fuzzy around "any place where he or his sta ae doing busines” The steps you've taken nan temps to insulte Senator Tepitz and his aff from viewpoints that make him uncomforable re not jst unconstitutional, theyre pathetic, They're pathetic becuse the power you seek to invoke belongs to the People, not you, not Senator Costa and not Senator Teplitz. Indeed it doest even belong tothe Pennsylvania Senate ‘Trying to intimidate my client with vague threats of government aetion on government letterhead is, to quote you, “not only counterproductive, but also subject{s} you ... to potential legal liability.” As our Supreme Court ruled just this year, the use of government resources for personal use is a violation of the public’s trust. Office of Disciplinary Counsel v. Preski, 134 ‘A3d 1027 (Pa. 2016). Certainly, as public servants, both Senators Costa and Teplitz should ‘understand thatthe “[pubi: trust isan indispensable prerequisite tothe effective administration ‘of government. When a public official violates that trust, he or she undermines the integrity of the entre system.” Presi 134 A.3d at 1033. But asa licensed attomey, Senator Teplitz should bbe especially aware that the public trust placed in him is even more precious, as the Supreme ‘Court noted in the same case: “If anything, the transgressions of a lawyer who is also a public setvant are even more injurious to the reputation ofthe bar because they bring dishonor both to the profession and to our democratic institutions.” Id Your use of the oficial letterhead, complete with the official seal of the Senate of Pennsylvania, constitutes a nisuse of government property and publicly-funded office staff time, and “crosses the line,” as yeu would say, between personal and public business. Your use of the letterhead in a brazen attempt to dissuade Mr. Klopp and those affliated with PLA from "Davia Wenne, Pen Lie, Nov. 7.2012 Rob Teplis combined party's growth and olifarioned campaign town Seate sea, vaable aii pea com miss ndex ss 2012 a tpi Mn sien Murphy, Pern Line, an. 6,2016,aveable at nnise-pennlvecomipaliisindsx 20160 tel, ansounces Unc o mlSeptember 12, 2016 Page 3 engaging in activities they clearly have the constitutional right to engage in may’ also constitute official oppression. Conseguently, by copy of this fetter, we are asking thatthe Attorney General investigate whether the use of official letterhead and the slate seal (9 intimidate a citizen from ‘engaging in lawful activity violates the Pennsylvania Crimes Code or other regulations designed to prohibit tis sort of misuse of taxpayer-funded public property In conclusion, sir, you are directed to immediately cease and desist from any further directo indirect personal communications to Mr. Klopp or the PA Liberty Alliance, and further instructed to direct all ture correspondence through this office and to my attention, Pending receipt of a decision by the Atdomey General, we will look forward to receiving. ‘your writen apology. ‘Very truly yours, Enel cc: Bruce R. Beemer, Eiq., Pennsylvania Attomey General (via email: Beemer @attomeygeneral gov) (via mail: Stawberry Square, 15* Floor, Harrisburg, PA 17120) Susquehanna Township Police Department c/o Chiet Robert A. Martin (via email: rnartin@susquehannatwp.com) (via mail: 1990 Linglestown Road, Harrisburg, PA 17110) Sen. Rob Teplitz, Distt 15 (via email: senatoneplitz@pasenate.com) (via mail: Serate Box 203015, Harrisburg, PA 17120) Sen. Jay Costa, Distict 43, Democratic Leader (via email: easia@pasenate.com) (via mail: Serate Box 203043, Harrisburg, PA 17120) Pennsylvania Capitel Police (via mail: Aeministrative Offices ~ Room 7OE, Capitol East Wing, Harisburg, PA 17125) Senate Security (via mail: Seate of PA ~ Room B38, Main Capitol Building, Harrisburg, PA 17120)