Stan J. Caterbone LETTER To Matthew H. Haverstick Re MARTIN v. Reese CI-17-04626 March 5, 2017

Stan J.
Caterbone
ADVANCED MEDIA GROUP
Freedom From Covert Harassment &

Surveillance,
Registered in Pennsylvania
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
stancaterbone@gmail.com
717-528-2200
March 5, 2017
Matthew H. Haverstick (No. 85072)

Mark E. Seiberling (No. 91256)
Joshua J. Voss (No. 306853)
KLEINBARD LLC
One Liberty Place, 46th Floor
1650 Market Street
Philadelphia, PA 19103
Ph: (215) 568-2000
Fax: (215) 568-0140
Eml: mhaverstick@kleinbard.com
mseiberling@kleinbard.com
jvoss@kleinbard.com
Re: CSCOTT MARTIN (et al.)

vs.
MARK S. REESE
Case Number CI-17-01626
Dear Sirs,
I would file an AMICUS, however, that would add to the court drama and distract from the
important message that I want to deliver. First, I have a sincere respect for Mark Reese in that in
2008, as Deputy Sheriff, Mark had to inspect every piece of paper that I filed in the Lancaster
County Court of Common Pleas. You see, a certain Mr. Craig Stedman, and Judge James Cullen
tried to be cute with me, and have used a blotch of blood on a cover page to file an ORDER, that
was only intended to inconvenience and distract me from my court cases, as pro se. Needless to
say, it did not work, but it did give me the chance to meet with Mark Reese on most days. Mark
was always very professional, courteous, and respectful to both me and the office staff, from what
I observed. In addition, I was often seen behind the Lancaster County Courthouse smoking a
cigarette with my friend, former Judge Joe Madenspacher, and often Mark would be with us, just
talking about everyday things, nothing court related. For the record, on occasion I did ask Judge
Madenspacher his opinion regarding a few issues, of which had nothing to do with my cases.
Judge Joe Madenspacher, in my mind was one of the most honest and competent Judges that I
have been involved with.
Ever since the story of Mark Reese appeared, I always and still do have the same reaction
not the Mark Reese I know, not saying I know everything. Now, remember, sex has been used
against me for some 30 years, on so many ways. For the past 12 years, I have had to file
injunction after injunction with specific regards to female teasing and exploitation.
Letter to Haverstick, et.al., Page 1 of 190 Sunday March 5, 2017

My points are:
1. Mark Reese has never been charged with a crime by any law enforcement agency.
2. I am the AMICUS for Kathleen Kane in Superior Court, Case No. 3575 EDA 2016, and was
AMICUS on one other Superior Court Case and one other Supreme Court Case.
3. The Pennsylvania General Assembly tried in earnest to impeach Kathleen Kane and
remover he from Office, she resigned on August 16, 2016 ONLY AFTER SHE WAS
CONVICTED IN MONTGOMERY COUNTY COURT OF COMMON PLEAS.
4. I remember a few years ago, there was a group of concerned citizens trying to rid the
Commonwealth of the Row Officers, at least on the County Level.
Conclusion, I am of the OPINION that you are wasting taxpayer dollars, the root
of the problem is not Mark Reese, but the Pennsylvania Statutes originating the Row
Offices. They are very deceptive, in that the elected Row Officers can rarely be held
accountable for anything of consequence in their respective offices.
Respectfully,
_______________________
Stan J. Caterbone, Pro Se Litigant

Freedom From Covert Harassment & Surveillance,
1250 Fremont Street
Lancaster, PA 17603
717-528-2200
Notice and Disclaimer: Stan J. Caterbone and the Advanced Media Group have been slandered, defamed, and
publicly discredited since 1987 due to going public (Whistle Blower) with allegations of misconduct and fraud
within International Signal & Control, Plc. of Lancaster, Pa. (ISC pleaded guilty to selling arms to Iraq via
South Africa and a $1 Billion Fraud in 1992). Unfortunately we are forced to defend our reputation and the
truth without the aid of law enforcement and the media, which would normally prosecute and expose public
corruption. We utilize our communications to thwart further libelous and malicious attacks on our person, our
property, and our business. We continue our fight for justice through the Courts, and some communications
are a means of protecting our rights to continue our pursuit of justice. Advanced Media Group is also a
member of the media. Reply if you wish to be removed from our Contact List. How long can Lancaster County
and Lancaster City hide me and Continue to Cover-Up my Whistle Blowing of the ISC Scandel (And the Torture
from U.S. Sponsored Mind Control)?
ACTIVE COURT CASES

J.C. No. 03-16-90005 Office of the Circuit Executive, United States Third Circuit Court of Appeals -
COMPLAINT OF JUDICIALMISCONDUCT OR DISABILITY re 15-3400 and 16-1149; 03-16-900046 re ALL
FEDERAL LITIGATION TO DATE
U.S. Supreme Court Case No. 16-6822 PETITION FOR WRIT OF CERTIORARI re Case No. 16-1149
MOVANT for Lisa Michelle Lambert
U.S.C.A. Third Circuit Court of Appeals Case No. 16-3284; Case No. 16-1149 MOVANT for Lisa Michelle
Lambert;15-3400 MOVANT for Lisa Michelle Lambert;; 16-1001; 07-4474

U.S. District Court Eastern District of PA Case No. 16-4014 CATERBONE v. United States, et.al.; Case
No. 16-cv-49; 15-03984; 14-02559 MOVANT for Lisa Michelle Lambert; 05-2288; 06-4650, 08-02982;
U.S. District Court Middle District of PA Case No. 16- 2513 INJUNCTION; Case No. 16-cv-1751
PETITION FOR HABEUS CORPUS
Commonwealth of Pennsylvania Judicial Conduct Board Case No. 2016-462 Complaint against
Lancaster County Court of Common Pleas Judge Leonard Brown III
Pennsylvania Supreme Court Case No. 353 MT 2016; 354 MT 2016; 108 MM 2016 Amicus for Kathleen Kane
Superior Court of Pennsylvania 3575 EDA 2016 Amicus for Kathleen Kane; Summary Appeal Case No.
CP-36-SA-0000219-2016, AMICUS for Kathleen Kane Case No. 1164 EDA 2016; Case No. 1561 MDA 2015;
1519 MDA 2015; 16-1219 Preliminary Injunction Case of 2016
Lancaster County Court of Common Pleas Case No. 16-05815 Injunction; Case No. 16-08472 INJUNCTION re
Pain Meds; Case No. 15-10167 Film Commission; Case No. 08-13373; 15-10167; 06-03349, CI-06-03401
U.S. Bankruptcy Court for The Eastern District of Pennsylvania Case No. 17-10615; Case No. 16-10157

THIS PAGE INTENTIONALLY LEFT BLANK

PROTHONOTARY OF LANCASTER COUNTY
Katherine Wood-Jacobs George Alspach
Prothonotary Solicitor
SCOTT MARTIN (et al.)

Case Number
vs.
CI-17-01626
MARK S. REESE
PROTHONOTARY DOCKET ENTRIES

03/02/2017 COMPLAINT IN QUO WARRANTO FILED BY MATTHEW H. HAVERSTICK, ESQ.
FORWARDED TO PRESIDENT JUDGE REINAKER 3-3-17.

03/02/2017 CAPTION ENTRY IS: SCOTT MARTIN, IN HIS OFFICIAL CAPACITY AS SENATOR, AND RYAN P.
AUMENT, IN HIS OFFICIAL CAPACITY AS SENATOR V. MARK S. REESE
03/03/2017 Praecipe to Enter Appearance of Joshua J Voss Esq. obo Senator Scott Martin and Senator Ryan P.
Aument. Certificate of Service attached.
03/03/2017 Praecipe to Enter Appearance of Mark E. Seiberling Esq. obo Senator Scott Martin and Senator Ryan P.
Aument. Certificate of Service attached.
03/03/2017 Motion to Expedite with Certificate of Service FILED BY Matthew H Haverstick ESQ
03/03/2017 Brief in Support of Motion to Expedite FILED BY Matthew H Haverstick ESQ.
March 04, 2017
Letter to Haverstick, et.al., Page 5 of 190

(c) CountySuite Prothonotary, Teleosoft, Inc.
Sunday March 5, 2017

ENTERED AND FILED
PROTHONOTARYS OFFICE
LANCASTER, PA
***Electronically Filed***
Mar 02 2017 03:11PM
Ricarda Dehl
IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA

CIVIL DIVISION
SCOTT MARTIN, in his official capacity as No. CI-17-_________________________

Senator, and RYAN P. AUMENT, in his
official capacity as Senator, CI-17-01626
Plaintiffs,
v.
MARK S. REESE,
Defendant.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this complaint and notice are served,
by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS
OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO

PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Lancaster Bar Association

Lawyer Referral Service
28 East Orange Street
Lancaster, PA 17602
Telephone: 717-393-0737

ENTERED AND FILED
LANCASTER, PA
Mar 02 2017 03:11PM
Matthew H. Haverstick (No. 85072) Ricarda Dehl
KLEINBARD LLC
1650 Market Street
Ph: (215) 568-2000
Fax: (215) 568-0140
jvoss@kleinbard.com CI-17-01626
Attorneys for Plaintiffs

CIVIL DIVISION
SCOTT MARTIN, in his official capacity as No. CI-17-____________________

Senator, and RYAN P. AUMENT, in his
official capacity as Senator,
Plaintiffs,
v.
MARK S. REESE,
Defendant.
COMPLAINT IN QUO WARRANTO
Plaintiffs Senator Scott Martin and Senator Ryan P. Aument, by their attorneys, bring this
Complaint in Quo Warranto against Defendant Mark S. Reese, and in support thereof, aver as
follows:
PARTIES AND VENUE
1. Plaintiff Scott Martin is an elected Senator of the Pennsylvania State Senate,
representing Senate District 13. Senate District 13 includes Lancaster County. Senator Martin is
a plaintiff in his official capacity as Senator.

ENTERED AND FILED
CI-17-____________
LANCASTER, PA
Mar 02 2017 03:11PM
2. Plaintiff Ryan P. Aument is an elected Senator of the Pennsylvania State Senate,
Ricarda Dehl
representing Senate District 36. Senate District 36 includes Lancaster County. Senator Aument is
a plaintiff in his official capacity as Senator.
3. Defendant Mark S. Reese is a resident of Lancaster County.
4. Venue exists in this Court under Pennsylvania Rules of Civil Procedure
1112(c)(2) because Defendant Reese purports to be an officer of Lancaster County.

CI-17-01626
FACTUAL BACKGROUND
5. Defendant Reese was elected to the public office of Sheriff of Lancaster County
in 2011 and re-elected in 2015.
6. In July 2016, the Lancaster County Commissioners received an allegation that
Defendant Reese had sexually harassed a deputy.
7. On or about July 26, 2016, Defendant Reese purported to take a leave of
absence from his duties as Sheriff.
8. In connection with his leave, Defendant Reese relinquished his County-issued
weapon and all County-owned equipment in his possession.
9. The County Commissioners suspended Defendant Reeses unlimited access to
County buildings.
10. Upon information and belief, that suspension continues through the date of this
Complaint.
11. The duties of the Sheriffs Office in Lancaster County include the following:
a. Serving most original process in civil matters and obtain personal

jurisdiction for the court;
b. Providing Security/Protection to the Court of Common Pleas and the

Lancaster County Courthouse;
c. Conveying/transporting prisoners to and from court and state prisons;
2
ENTERED AND FILED
CI-17-____________
LANCASTER, PA
Mar 02 2017 03:11PM
d. Providing a K-9 explosive detection unit for use in all areas ofRicarda
the County;
Dehl
e. Assisting all other law-enforcement agencies as they may be needed;
f. Serving Protection from Abuse Orders;
g. Serving and making arrests for outstanding bench warrants;
h. Conducting investigations into and issue concealed weapons permits and

licenses to sell firearms; and
i. Conducting judicial sales of real and personal property, and determining

property ownership. CI-17-01626
12. Since July 2016, Defendant Reese has not performed any of the foregoing duties,
or any other statutory duty, of the Sheriff of Lancaster County.
13. Upon information and belief, since July 2016, Defendant Reese has not reported
to work at the Sheriffs physical office in Lancaster.
14. Defendant Reese continues to collect a salary as Sheriff of Lancaster County.
15. Defendant Reese continues to hold himself out as Sheriff of Lancaster County by,
among other things, continuing to collect a salary as Sheriff.
16. Based upon the foregoing, Defendant Reese resigned from the public office of
Sheriff of Lancaster County as a matter of fact.
17. Based upon the foregoing, Defendant Reese resigned from the public office of
Sheriff of Lancaster County as a matter of law.
18. Based upon the foregoing, Defendant Reese absconded from the County under
Section 412 of The County Code, 16 P.S. 412.
19. Plaintiffs have a special right or interest in this matter, distinct from the rights or
interests of the public generally, and also, Plaintiffs have been specially damaged.
20. Under Article IV, Section 8(a)-(b) of the Pennsylvania Constitution and under
Section 409 of The County Code, 16 P.S. 409, Plaintiffs, as elected Senators of the
3
ENTERED AND FILED
CI-17-____________
LANCASTER, PA
Mar 02 2017 03:11PM
Pennsylvania Senate, have distinct constitutional and statutory rights to receive fromRicarda
the Dehl
Governor nominations for the vacant public office of Sheriff and they have constitutional and
statutory rights to give or withhold consent on such nominations.
21. Plaintiffs special rights are being denied, and in consequence Plaintiffs are being
specially damaged, by Defendant Reese continuing to hold himself out as Sheriff of Lancaster
County even though the public office has been vacated as a matter of fact and law; his unlawful
CI-17-01626
holding of the title of Sheriff thwarts Plaintiffs right to receive a nominee for Sheriff and to give
or withhold consent on such a nominee.
COUNT I: QUO WARRANTO
22. Plaintiffs incorporate by reference the allegations in the foregoing paragraphs of
this Complaint as if set forth at length herein.
23. An action in quo warranto is the sole and exclusive method to try title or right to
office. Spykerman v. Levy, 421 A.2d 641, 648 (Pa. 1980).
24. An action in quo warranto challenges a defendants right to hold and exercise the
powers of the office at issue. Id.
25. Defendant Reese is unlawfully holding the title of Sheriff of Lancaster County.
26. By not performing the duties of the Sheriff for over six months, Defendant Reese
has resigned the public office as a matter of fact.
27. By not performing the duties of the Sheriff for over six months, Defendant Reese
has resigned the public office as a matter of law.
28. By not performing the duties of the public office of Sheriff of Lancaster County
for over six months and by not reporting to work, Defendant Reese has absconded from the
County under Section 412 of the County Code, 16 P.S. 412, and has vacated the public office
as a matter of law.
4
ENTERED AND FILED
CI-17-____________
LANCASTER, PA
Mar 02 2017 03:11PM
29. Based upon the foregoing, the public office of Sheriff of Lancaster County is Dehl
Ricarda
vacant.
30. Based upon the foregoing, Defendant Reese cannot continue to hold title to the
public office of Sheriff of Lancaster County.
WHEREFORE, Plaintiffs pray the Court:
i. Enter judgment that Defendant is barred from performing the duties of Sheriff of
CI-17-01626
Lancaster County.
ii. Enter judgment that Defendant is barred from collecting any further salary or
benefits as Sheriff of Lancaster County.
iii. Enter judgment declaring that Defendant resigned the public office of Sheriff of
Lancaster County as a matter of fact.
iv. Enter judgment declaring that Defendant resigned the public office of Sheriff of
Lancaster County as a matter of law.
v. Enter judgment declaring that Defendant absconded from the County under
Section 412 of The County Code.
vi. Enter judgment declaring the public office of Sheriff of Lancaster County is
vacant.
vii. Enter judgment declaring the Governor can immediately appoint a suitable person
to the public office of Sheriff of Lancaster County under Section 409 of The County Code.
viii. Grant such additional relief as the Court deems just and equitable.
5
ENTERED AND FILED
CI-17-____________
LANCASTER, PA
Mar 02 2017 03:11PM
Ricarda Dehl
Dated: March 2, 2017 _________________________________

KLEINBARD LLC
1650 Market Street
Ph: (215) 568-2000
Fax: (215) 568-0140 CI-17-01626
jvoss@kleinbard.com
6
ENTERED AND FILED
LANCASTER, PA
Mar 02 2017 03:11PM
Ricarda Dehl
VERIFICATION
I hereby verify that the statements made in the foregoing Complaint are true and correct
based upon my personal knowledge or information and belief. 1 understand that false statements
therein are subject to penalties of 18 Pa.C.S. 4904. relating to unsworn falsification to
authorities.
CI-17-01626
Dated: March 1, 2017
Senator Scott Martin

ENTERED AND FILED
LANCASTER, PA
Mar 02 2017 03:11PM
VERIFICATION Ricarda Dehl
I hereby verify that the statements made in the foregoing Complaint are true and correct
based upon my personal knowledge or information and belieE I understand that false statements
therein are subject to penalties of 18 Pa.C.S. 4904. relating to unsworn Ihisiuication to
authorities.
CI-17-01626
Dated: March 1.2017
tor Ryan P. Aument


ENTERED AND FILED
LANCASTER, PA
***Electronically Filed*****
Mar 03 2017 11:40AM
Matthew H. Haverstick (No. 85072) Nathan Renkes
KLEINBARD LLC
1650 Market Street
Ph: (215) 568-2000
Fax: (215) 568-0140
jvoss@kleinbard.com

CIVIL DIVISION
SCOTT MARTIN, in his official capacity as No. CI-17-01626

Senator, and RYAN P. AUMENT, in his official
capacity as Senator,
Plaintiffs,
v.
MARK S. REESE,
Defendant.
BRIEF IN SUPPORT OF MOTION TO EXPEDITE

BY PLAINTIFFS SENATOR SCOTT MARTIN AND SENATOR RYAN P. AUMENT
Despite having abandoned his elected public office, Defendant Mark S. Reese continues
to hold himself out as the Sheriff of Lancaster County, to the detriment of the County and the
Pennsylvania Senate. Because of Defendant Reeses conduct, expedited review of this matter is
warranted. Accordingly, Plaintiffs Senator Scott Martin and Senator Ryan P. Aument ask the
Court to grant the pending Motion to Expedite and enter an order setting an accelerated
disposition schedule.

No. CI-17-01626
I. FACTS
Plaintiffs Senator Scott Martin and Senator Ryan P. Aument are the duly elected State
Senators for Senate Districts 13 and 36, respectively. Each Senate District includes Lancaster
County. Defendant Mark S. Reese was elected to the public office of Sheriff of Lancaster County
in 2011 and re-elected in 2015.
In July 2016, the Lancaster County Commissioners received an allegation that Defendant
Reese had sexually harassed a deputy. On or about July 26, 2016, Defendant Reese purported to
take a leave of absence from his duties as Sheriff. In connection with his leave, Defendant
Reese relinquished his County-issued weapon and all County-owned equipment in his
possession. The County Commissioners suspended Defendant Reeses unlimited access to
County buildings. Upon information and belief, that suspension continues through the date of
this brief.
The duties of the Sheriffs Office in Lancaster County include the following:
a. Serving most original process in civil matters and obtain personal jurisdiction for
the court;
b. Providing Security/Protection to the Court of Common Pleas and the Lancaster
County Courthouse;
c. Conveying/transporting prisoners to and from court and state prisons;
d. Providing a K-9 explosive detection unit for use in all areas of the County;
e. Assisting all other law-enforcement agencies as they may be needed;
f. Serving Protection from Abuse Orders;
g. Serving and making arrests for outstanding bench warrants;

No. CI-17-01626
h. Conducting investigations into and issue concealed weapons permits and licenses
to sell firearms; and
i. Conducting judicial sales of real and personal property, and determining property
ownership.
Since July 2016, Defendant Reese has not performed any of the foregoing duties, or any
other statutory duty, of the Sheriff of Lancaster County. Upon information and belief, since July
2016, Defendant Reese has not reported to work at the Sheriffs physical office in Lancaster.
Defendant Reese continues to collect a salary as Sheriff of Lancaster County. Defendant Reese
continues to hold himself out as Sheriff of Lancaster County by, among other things, continuing
to collect a salary as Sheriff.
II. PROCEDURAL HISTORY
On March 2, 2017, Senators Martin and Aument filed a Complaint in Quo Warranto
seeking to resolve the status of the public office of Sheriff of Lancaster County. The Complaint
seeks a determination from this Court as to whether Defendant Reese can lawfully hold title to
public office where he has resigned the office by abandonment as a matter of fact or law and
where he has absconded from the County as a matter of law under The County Code, 16 P.S.
412 (The office of any county officer absconding from the county shall be vacant to all intents
and purposes.).

No. CI-17-01626
III. QUESTION INVOLVED
The Sheriff of Lancaster County has not reported to work or exercised his duties as
Sheriff for over six months. Such conduct shows that he has resigned public office by
abandonment or absconding. In light of these circumstances, should the Court order expedited
review of Defendants right to claim title to Sheriff of Lancaster County? Suggested answer: yes.
IV. ARGUMENT
Resolution of the status of the public office of Sheriff of Lancaster County is a matter of
immediate public concern and safety, warranting expedited review of this matter.
The public office of sheriff is so significant that under the Pennsylvania Constitution and
The County Code, immediately upon a vacancy in that office, the Governor shall appoint a
suitable replacement within 90 days of the vacancy and the Senate then has the right to
confirm the replacement. Pa. Const. Art. IV, 8(a)-(b); 16 P.S. 409.1 2 Further, the office is so
significant that the General Assembly made it a crime to neglect or fail to perform the duties of
1
Pa. Const. Art. IV, 8(a)-(b):
(a) The Governor shall appoint a Secretary of Education and such other officers as he
shall be authorized by law to appoint. The appointment of the Secretary of Education and
of such other officers as may be specified by law, shall be subject to the consent of two-
thirds or a majority of the members elected to the Senate as is specified by law.
(b) The Governor shall fill vacancies in offices to which he appoints by nominating to the
Senate a proper person to fill the vacancy within 90 days of the first day of the vacancy
and not thereafter. The Senate shall act on each executive nomination within 25
legislative days of its submission. .
2
16 P.S. 409:
In case of a vacancy, happening by death, resignation or otherwise, in any county office

created by the Constitution or laws of this Commonwealth, and where no other provision
is made by the Constitution, or by the provisions of this act, to fill the vacancy, it shall be
the duty of the Governor to appoint a suitable person to fill such office Such appointee
shall be confirmed by the Senate if in session.

No. CI-17-01626
sheriff (and other public offices as well): If any county officer neglects or refuses to perform
any duty imposed on him by the provisions of this act, or by the provisions of any other act of
Assembly, or by any rule of court, or other provision of law, he shall, for each such neglect or
refusal, be guilty of a misdemeanor, and, on conviction thereof, shall be sentenced to pay a fine
not exceeding five hundred dollars ($500). See 16 P.S. 411. These constitutional and statutory
regimes show that the people of the Commonwealth long ago decided having a proper officer
fulfilling the duties of sheriff was significant and of immediate public concern.
With the matter before the Court, the status of the public office of Sheriff of Lancaster
County is in doubt: the current purported title-holder has abandoned his post for over six months
while continuing to collect a salary. In the interim, he is depriving the people of the County the
services to which they are entitled (and for which they are paying), while also depriving the
Pennsylvania Senate of its constitutional and statutory right to give its advice and consent on a
replacement. In short, as set forth in the Complaint, the public office of Sheriff is vacant as a
matter of fact and law, and as such, Plaintiffs and their fellow Senators are entitled to have a
nominee to fill the office promptly submitted to them by the Governor so that the duties of this
important office can once-again be fulfilled. As long as Defendant Reese holds himself out as
Sheriff of Lancaster County, even though he has lost that right by abandonment or by
absconding, the public is harmed and Plaintiffs are denied their right to fulfill their constitutional
and statutory mandates.
This warrants expedited review by the Court of the merits of this matter.

No. CI-17-01626
V. CONCLUSION
For the reasons set forth above, Plaintiffs respectfully request the Court grant the Motion
to Expedite and enter an order setting the following accelerated schedule for the disposition of
this matter:
a. Defendant shall file an answer or preliminary objections, with a brief, to the

Complaint within 20 days of service of the Complaint upon the Defendant;
b. All discovery in this matter shall be completed within 21 days after service of the
Complaint upon the Defendant;
c. All pre-trial dispositive motions, if any, shall be filed within 7 days of the
completion of discovery; and
d. If necessary, a bench trial shall be held in this matter at the Courts earliest
convenience in April 2017.
Respectfully submitted,
KLEINBARD LLC
Dated: March 3, 2017 By:

KLEINBARD LLC
1650 Market Street
Ph: (215) 568-2000
Fax: (215) 568-0140
jvoss@kleinbard.com

CERTIFICATE OF SERVICE
I hereby certify that I am this day serving the foregoing Brief in Support of Motion to
Expedite upon the person and in the manner indicated below.
Via First Class Mail

Mark S. Reese
Defendant
Dated: March 3, 2017

KLEINBARD LLC
1650 Market Street
Ph: (215) 568-2000
Fax: (215) 568-0140
Attorney for Plaintiffs


STAN J. CATERBONE, PRO SE AMICUS FOR KATHLEEN KANE
COMMONWEALTH v. Kathleen Kane OPINION Page 1 of 137 Friday March 3, 2017



































































































COURT OF COMMON PLEAS OF MONTGOMERY COUNTY
DOCKET
Docket Number: CP-46-CR-0008423-2015
CRIMINAL DOCKET
Court Case
Commonwealth of Pennsylvania
Page 1 of 29
v.
Kathleen Granahan Kane
CASE INFORMATION
Cross Court Docket Nos: 1166 EDA 2016, 440 MT 2016, 108 MM 2016, 3575 EDA 2016, 3576 EDA 2016
Judge Assigned: Demchick-Alloy, Wendy Date Filed: 11/23/2015 Initiation Date: 10/01/2015
OTN: T 709032-2 LOTN: Originating Docket No: MJ-38120-CR-0000381-2015
Initial Issuing Authority: Cathleen Kelly Rebar Final Issuing Authority: Cathleen Kelly Rebar
Arresting Agency: Montgomery County Detective Arresting Officer: Bradbury, Paul M.
Complaint/Incident #: 1
Case Local Number Type(s) Case Local Number(s)
RELATED CASES
Related Docket No Related Case Caption Related Court Association Reason

Related
CP-46-MD-0002457-2015 Comm v Kane, Kathleen Granahan CP-38-46-Crim Case Transferred to Criminal
Case CR 8423-2015
STATUS INFORMATION
Case Status: Closed Status Date Processing Status Arrest Date: 10/01/2015
11/22/2016 Awaiting Appellate Court Decision
10/24/2016 Sentenced/Penalty Imposed
08/22/2016 Awaiting PSI Completion
08/16/2016 Awaiting PSI
08/16/2016 Awaiting Sentencing
08/08/2016 Awaiting PSI Completion
08/08/2016 Awaiting Sentencing
07/11/2016 Awaiting Trial
04/20/2016 Awaiting Appellate Court Decision
11/27/2015 Awaiting Formal Arraignment
11/27/2015 Awaiting Filing of Information
11/23/2015 Awaiting Formal Arraignment
11/23/2015 Awaiting Filing of Information
11/19/2015 Awaiting Pre-Trial Conference
Complaint Date: 10/01/2015
CPCMS 9082 Printed: 03/03/2017
Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial
System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assume any liability for inaccurate or delayed
data, errors or omissions on these reports. Docket Sheet information should not be used in place of a criminal history background check which can
only be provided by
COMMONWEALTH v.the Pennsylvania
Kathleen KaneStateOPINION
Police. Moreover Page
an employer
105who does not comply with the provisions of the Criminal
of 137 History March
Friday Record 3, 2017
Information Act may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183.
DOCKET
CRIMINAL DOCKET
Court Case
Page 2 of 29
v.
CALENDAR EVENTS
Case Calendar Schedule Start Room Judge Name Schedule
Event Type Start Date Time Status
Formal Arraignment 01/06/2016 9:30 am Video Room #1 Judge William T. Nicholas Scheduled
Miscellaneous 01/29/2016 1:00 pm Scheduled
Hearing
Hearing
Hearing
Miscellaneous 04/20/2016 9:00 am Scheduled
Hearing
Miscellaneous 07/26/2016 10:00 am Scheduled
Hearing
Jury Trial 08/08/2016 9:00 am Scheduled
Sentencing 10/24/2016 10:00 am Scheduled
DEFENDANT INFORMATION
Date Of Birth: 06/14/1966 City/State/Zip: Clarks Summit, PA 18411
CASE PARTICIPANTS
Participant Type Name
Defendant Kane, Kathleen Granahan
BAIL INFORMATION
Kane, Kathleen Granahan Nebbia Status: None
Bail Action Date Bail Type Percentage Amount

Bail Posting Status Posting Date
Set 10/01/2015 Unsecured $10,000.00

Posted 10/01/2015
Set 10/24/2016 Monetary $75,000.00
Set 10/24/2016 Monetary $37,500.00
Posted 10/24/2016
CHARGES
Seq. Orig Seq. Grade Statute Statute Description Offense Dt. OTN
1 1 F3 18 4902 A Perjury 03/16/2014 T 709032-2
2 2 M2 18 4903 A1 False Swearing - Offic Proceed 03/16/2014 T 709032-2
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CHARGES
Seq. Orig Seq. Grade Statute Statute Description Offense Dt. OTN
3 3 M2 18 5101 Obstruct Admin Law/Other Govt Func 03/16/2014 T 709032-2
DISPOSITION SENTENCING/PENALTIES
Disposition
Case Event Disposition Date Final Disposition
Sequence/Description Offense Disposition Grade Section
Sentencing Judge Sentence Date Credit For Time Served
Sentence/Diversion Program Type Incarceration/Diversionary Period Start Date
Sentence Conditions
Held for Court (Lower Court) Defendant Was Present

Lower Court Disposition 11/10/2015 Not Final
1 / Perjury Held for Court (Lower Court) F3 18 4902 A
2 / False Swearing - Offic Proceed Held for Court (Lower Court) M2 18 4903 A1
3 / Obstruct Admin Law/Other Govt Func Held for Court (Lower Court) M2 18 5101
Proceed to Court Defendant Was Not Present
Information Filed 08/08/2016 Not Final
1 / Perjury Held for Court F3 18 4902 A
2 / False Swearing - Offic Proceed Held for Court M2 18 4903 A1
3 / Obstruct Admin Law/Other Govt Func Held for Court M2 18 5101
Guilty
Jury Trial 08/08/2016 Final Disposition
1 / Perjury Guilty F3 18 4902 A
Demchick-Alloy, Wendy 10/24/2016
Confinement Min of 5.00 Months
Max of 11.00 Months
Other
Ct.2 merges with Count 1 for Sentencing purposes
Consecutive to 6239-15
Probation Min of 3.00 Years
Max of 3.00 Years
Other
2 / False Swearing - Offic Proceed Guilty M2 18 4903 A1
Merged
3 / Obstruct Admin Law/Other Govt Func Guilty M2 18 5101
Probation Min of 2.00 Years
Max of 2.00 Years
Other
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LINKED SENTENCES:
Link 4
CP-46-CR-0006239-2015 - Seq. No. 3 (18 5101 ) - Probation
Link 5
CP-46-CR-0006239-2015 - Seq. No. 5 (18 5301 1) - Probation
Link 6
Link 7
Link 8
CP-46-CR-0008423-2015 - Seq. No. 3 (18 5101 ) - Probation is Concurrent with
Link 1
CP-46-CR-0008423-2015 - Seq. No. 1 (18 4902 A) - Probation is Consecutive to
CP-46-CR-0008423-2015 - Seq. No. 1 (18 4902 A) - Confinement
Link 2
CP-46-CR-0006239-2015 - Seq. No. 1 (18 4902 A) - Probation is Consecutive to
CP-46-CR-0006239-2015 - Seq. No. 1 (18 4902 A) - Confinement
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COMMONWEALTH INFORMATION ATTORNEY INFORMATION
Name: Thomas W. McGoldrick Name: Joshua D. Lock
District Attorney Private
Supreme Court No: 078192 Supreme Court No: 017092
Phone Number(s): Rep. Status: Active
610-278-3126 (Phone) Phone Number(s):
610-278-3090 (Other) 717-234-4161 (Phone)
610-278-3095 (Other) Address:
Address: Goldberg Katzman PC
Montgomery CO Da's Office 4250 Crums Mill Rd Ste 301
PO Box 311 Harrisburg, PA 17112-2889
Norristown, PA 19404-0311
Representing: Kane, Kathleen Granahan
Name: Risa Vetri Ferman

District Attorney
Supreme Court No: 065228
Phone Number(s):
610-278-3100 (Phone)
610-278-3099 (Phone)
610-292-4950 (Fax)
610-278-3090 (Other)
610-278-3099 (Other)
Address:
Montgomery Cty Da's Office
PO Box 311
Name: Kevin R. Steele

Assistant District Attorney
Phone Number(s):
610-278-3098 (Phone)
610-278-3095 (Other)
610-278-3126 (Other)
Address:
Montgomery CO Da's Office
PO Box 311
Name: Michelle Ann Henry

Assistant District Attorney
Phone Number(s):
215-348-6344 (Phone)
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Address:
Bucks CO Da's Office
55 E Court St
Doylestown, PA 18901-4318
ENTRIES
Sequence Number CP Filed Date Document Date Filed By
1 10/01/2015 Rebar, Cathleen Kelly

Bail Set - Kane, Kathleen Granahan
2 10/01/2015 Kane, Kathleen Granahan

Bail Posted - Kane, Kathleen Granahan
1 11/19/2015 Kramer, Ross M.

Entry of Appearance/Arraignment Waived
1 11/23/2015 Court of Common Pleas -

Montgomery County
Original Papers Received from Lower Court
2 11/23/2015 MDJ-38-1-20
Formal Arraignment Scheduled 01/06/2016 9:30AM
Jan 6, 2016, service on 11/10/15
Kane, Kathleen Granahan
11/10/2015 Hand Delivered
1 11/24/2015 MDJ-38-1-20
Notes of Testimony
Preliminary Hearing, Ctrm B
Tuesday November 10, 2015. 1:00 pm
Judge Rebar
1 11/27/2015 MDJ-38-1-20
Original Papers Received from Lower Court
1 12/02/2015 MDJ-38-1-20
Amended Docket Transcript 12/2/15
2 12/21/2015 Demchick-Alloy, Wendy

Order Scheduling Case Management Conference
1/29/16 at 1:00, 1st Floor Chambers of the undersigned, Montgomery County Courthouse, Norristown,
Pennsylvania
Kramer, Ross M.
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ENTRIES
Service To Service By
Issue Date Service Type Status Date Service Status

12/21/2015 First Class
McGoldrick, Thomas W.
12/21/2015 Interoffice
1 01/29/2016 McGoldrick, Thomas W.

Information Filed
1 02/02/2016 02/01/2016 Demchick-Alloy, Wendy

Order Scheduling Pre-Trial Conference
February 5, 2016 at 1:00 p.m. Courtroom "B"

Scheduling Order
Deadline for Informal Discovery - 02/29/16
Deadline for Filing Pre-Trial Motions - 03/04/16
Deadline for Answers/Replies to Pre-Trial Motions - 03/11/16
Deadline for Briefs - 03/18/16

Order Scheduling Pre-Trial Motions Hearing
March 22, 2016 at 1:00 p.m. Courtroom "B"

Order Scheduling Trial
August 8, 2016 at 9:00 a.m. Courtroom "B"

Montgomery County
Notes of Testimony
Pretrial Conference, Ctrm B
Friday February 5, 2016. 1:35 pm
Judge Demchick-Alloy
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ENTRIES
1 02/17/2016 Commonwealth of Pennsylvania

Response to Motion to Quash Subpoena Direccted to Michael A. Schwartz, Counsel to
Reporter Christopher Brennan and Philadelphia Media Network, PBC
Filed by Thomas W. McGoldrick, DDA

Montgomery County
Notes of Testimony
Pretrial Conference Errata Sheet, Ctrm B
Friday February 5, 2016. 1:35 pm

Memorandum of Law in Support of its Response to Motion to Quash Subpoena Directed to
Michael A. Schwartz, Counsel to Reporter Christopher Brennan and Philadelphia Media Network, PBC
Filed by M. Stewart Ryan, ADA
1 03/04/2016 Kramer, Ross M.

Memorandum of Law
2 03/04/2016 Kramer, Ross M.

Omnibus Pre-Trial Motion
Filed by Gerald L. Shargel, Esq.
3 03/04/2016 Kramer, Ross M.

Memorandum of Law in Support of Attorney General Kathleen G. Kane's Omnibus Pretrial Motions

Motion for Pretrial Discovery and Inspection
Filed by Thomas W. McGoldrick, DDA

Attorney General Kathleen G. Kane's Answer to the Commonwealth's Motion for Pretrial Discovey and
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ENTRIES

Response to Defendant's Omnibus Pretrial Motion
CR 6239-15
8423-15
Filed by Kevin R. Steele, DA

Decorum Order Governing Pre-Trial Motions Hearing
Henry, Michelle Ann
Kramer, Ross M.
Steele, Kevin R.

Supplemental Pretrial Motions of Attorney General Kathleen G. Kane

Reply Memorandum of Law in Support of Attorney General Kathleen G. Kane's Omnibus Pretrial Motions

Affidavit of Ross M. Kramer
Filed by Ross M. Kramer, Esq.

Order Scheduling Pre-Trial Motion Hearing
April 20, 2016 at 9:00 a.m. Courtroom "B"
Kramer, Ross M.
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ENTRIES

Order Granting Motion for Pre-Trial Discovery and Inspection
Deft to Prepare Report of Examination or Tests by Any Expert Witness Defense Plans to Call to Testify
Deft Must Also Observe Continuing Duty to Disclose All Notices Within the Scope of Discovery
Minora, Amil Michael
1 03/25/2016 Gurney, Kaitlin M.

Motion of Philadelphia Media Network, The Morning Call, Alm Media, Block Communications, and
PA Media Group to Intervene for the Limited Purpose of Seeking Access to Judicial Records and Proceedings

Omnibus Pre-Trial Motions Order
1. A Decision on Point 3 is Deferred Until After Argument on Point 2 of the Supplemental Pre-Trial Motions of AG
2. The Relief Requested by Deft in the Remaining Points is Denied
Kramer, Ross M.

Montgomery County
Notes of Testimony
Pretrial Motions, Ctrm B
Tuesday March 22, 2016. 1:40 pm

Response to Defendant's Omniubs Pretrial Motion
Filed by Kevin R. Steele, District Attorney
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ENTRIES

Response to the Motion of Philadelphia Media Network, The Morning Call, ALM Media, Block
Communications, and PA Media Group to Intervene for the Limitd Purpose of Seeking Access to Judicial
Records and Proceedings

Motion Of Philadelphia Media Network Order
1. Moving Parties Granted Leave to Intervene for the Purpose of Seeking Access to Judicial Records and
Proceedings
2. Intervenors are Granted Leave to File, on or before 04/15/16, their Proposed Response in Opposition to Motion
to Permission to File Under Seal, Attached Exhibit A
3. AG Kane and the Commonwealth are Granted Leave to File, on or before 04/15/16, a Sur-Response to the
Interveneor's Response in Opposition to Motion to Permission to File Motion Under Seal
4. The Intervenors are Granted Leave to Participate in Oral Argument on Point Two of the Supplemental PreTrial
Motions of AG Kane at the Hearing on 04/20/16
Kramer, Ross M.

Decorum Order Governing The Pre-Trial Motions Hearing
Kramer, Ross M.

Amended Scheduling Order
Time Change ONLY for the 04/20/16 Pre-Trial Motions Hearing: Changed to 10:00 a.m.
Kramer, Ross M.
1 04/15/2016 Gurney, Kaitlin M.

Response of Philadelphia Media Network, The Morning Call, Alm Media, Block Communications, and
PA Media Group in Opposition to Attorney General Kathleen Kane's Motion for Permission to File Motion Under
Seal
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ENTRIES
1 04/20/2016 04/20/2016 Kramer, Ross M.

Notice of Appeal to the Superior Court
2 04/20/2016 04/20/2016 Kramer, Ross M.

Certificate of Service

Response to Defendant's Notice of Appeal

Motion of Attorney General Kathleen G. Kane to Quash Based on Selective and Vindictive Prosecution
FIled by Gerald L. Shargel, Esq.

Montgomery County
Notes of Testimony
Pretrial Motions, Ctrm B
Wednesday April 20, 2016. 10:04 am

Response to Defendant's Motion to Quash Based on Selective and Vindictive Prosecution

Reply Memorandum of Law in Support of Attorney General Kathleen G. Kane's Motion to Quash Based on
Selective and Vindictive Prosecution
Filed by Amil M. Minora, Esq.

Opinion
1/1 05/16/2016 05/16/2016 Demchick-Alloy, Wendy

Order Striking Motion to Quash Based on Selective and Vindictive Prosecution
Deft Granted 10 Days to File an Amended Motion - with a Support Brief within 10 Days if Commonwealth Files a
Response
Commonwealth is Ordered to File a Response (if Defense Files Amended Motion) within 10 Days
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ENTRIES

Kramer, Ross M.
1 05/17/2016 Weiss, Ann Thornburg

List of Documents sent to Superior Court, DA and Attorney

Certificate and Transmittal of Record to Appellate Court
2/1 05/26/2016 Kramer, Ross M.

Motion of Attorney General Kathleen G. Kane to Quash Based on Selevtive and Vindictive Prosecution
3/2 05/26/2016 Kramer, Ross M.

Memorandum of law in Support of Attorney General Kathleen Kane's Motion to Quash
4/1 06/06/2016 Commonwealth of Pennsylvania

Response to Defendant's Motion to Quash Based on Selective and Vindictive Prosecution
5/1 06/13/2016 Kane, Kathleen Granahan

Reply Memorandum of Law in Support of Attorney General Kathleen G. Kane's Motion to Quash Based on
Selective and Vindictive Prosecution

Order Denying Motion to Quash Based on Selective and Vindictive Prosecution
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ENTRIES

Order Scheduling Trial Management Conference
July 11, 2016 at 1:00 p.m. 1st Floor Chambers
Steele, Kevin R.
8/1 07/11/2016 Rosenblum, Douglas Keith

Entry of Appearance

Scheduling Order
Filing of Motions in Limine - 07/20/16
Responses to Motions in Limine - 07/22/16
Hearing on Motions in Limine - 07/26/16 at 10:00 a.m. Courtroom "A"
Voir Dire and/or Points of Charge - 08/03/16
Jury Trial Scheduled for 08/08/16 at 9:00 a.m. Courtroom "A"
Kramer, Ross M.

Order Scheduling Jury Trial
August 8, 2016 at 09:00 a.m. Courtroom "A"

Memorandum of Law in Support of Her Motion to Compel Production of Handwritten Notes of Interviews
Filed by Douglas K. Rosenblum, Esq.
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ENTRIES

Memorandum of Law in Support of Her Motion in Limine to Preclude Certain Testimony Regarding
Philadelphia District Attorney R. Seth Williams

Motion to Compel Production of Handwritten Notes of Interviews

Motion in Limine to Preclude Certain Testimony Regarding Philadelphia District
Attorney R. Seth Williams
Filed by Douglas K. Rosenblum

Motion in Limine to Admit Evidence of Prior Conversations by Joshua Morrow

Motion in Limine to Exclude Evidence of Selective and Vindictive Prosecution

Order Granting Request for Extention of Deadline for Filing Responses to Motions In Limine
Kramer, Ross M.

Reply in Opposition to Commonwealth's Motion in Limine to Exclude Evidence of Selective and
Vindictive Prosecution
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ENTRIES

Reply in Opposition to Commonwealth's Motion in Limine to Admit Evidence of Prior Conversations by
Joshua Morrow

Response to Defendant's Motion In Limine To Preclude Certain Testimony Regarding Philadelphia Distri
Response to Defendant's Motion In Limine To Preclude Certain Testimony Regarding Philadelphia District
Attorney R. Seth Williams.
Filed by, M. Stewart Ryan, ADA

Response to Defendant's Motion to Compel Production of Handwritten Notes of Interviews
22/1 07/27/2016 07/27/2016 Furber, William J. Jr.

Decorum Order Governing Voir Dire and Jury Trial

Motions in Limine Order
Commonwealth's Motion in Limine to Exclude Evidence of Selective and Vindictive Prosecution is Granted
Commonwealth is Granted Leave to Produce Evidence of Prior Conversations by Joshua Morrow after his
credibility is at issue
Deft's Motion in Limine to Preclude Certain Testimony Regarding DA R. Seth Williams is Denied - Right to Object
Retaines
Deft's Motion to Compel Production of Handwritten Notes of Interviews is Denied in light of Commonwealth's
Statement on Record that investigators made no handwritten notes
Rosenblum, Douglas Keith
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ENTRIES
24/1 08/01/2016 Superior Court of Pennsylvania -

Eastern District
Superior Court Order
Order Granting Motion to Quash.

Montgomery County
Notes of Testimony
Motions in Limine, Ctrm A
Tuesday July 26, 2016. 10:30 am
25/1 08/02/2016 Kramer, Ross M.

Praecipe to Withdraw Affidavit in Part
Filed by Gerald L. Shargel, Esq
26/2 08/02/2016 Kramer, Ross M.

Defendant's Applicaiton to Seal
27/3 08/02/2016 Kramer, Ross M.

Defendant's Emergency Application for Extraordinary Relief
Filed by D. Peter Johnson, Esq.
28/1 08/03/2016 McGoldrick, Thomas W.

Proposed Jury Instructions
Filed by Kevin Steele, DA
29/2 08/03/2016 Kramer, Ross M.

Defendant's Proposed Supplemental Voire Dire
Demchick-Alloy, Wendy
30/3 08/03/2016 Kramer, Ross M.

Defendant's Proposed Jury Instructions
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ENTRIES

Commonwealth's Proposed Voir Dire Questions
Filed by Kevin Steele, DA

Information Filed

Guilty

Sentence Deferred

Pre-Sentence Investigation Ordered

Amended Decorum Order Governing Voir Dire and Jury Trial
Kramer, Ross M.

Order Granting Immunity Petition
Joshua Morrow
Kramer, Ross M.

Immunity Petition
Filed by Thomas W. McGoldrick, ADA
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ENTRIES
36/1 08/12/2016 Gurney, Kaitlin M.

Intervenor Phialdelphis Media Network's Motion Seeking Access to Trial Exhibits Into Evidence
Intervenor Phialdelphis Media Network's Motion Seeking Access to Trial Exhibits Into Evidence and Material
Presented to the Jury
Filed by Amy B. Ginensky, Esq.
37/2 08/12/2016 Gurney, Kaitlin M.

Memorandum of Law in Support of Intervenor Philadelphia Media Network's Motion Seeking Trial Exhibit
Memorandum of Law in Support of Intervenor Philadelphia Media Network's Motion Seeking Access to Trial
Exhibits Entered Into Evidence and Materials Presented to the Jury
Filed by Amy B. Ginensky, Esq.

Montgomery County
Notes of Testimony
Trial by Jury, Ctrm A
Tuesday August 11, 2016. 1:24 pm

Montgomery County
Notes of Testimony
Trial by Jury/ A.M. Session, Ctrm A
Wednesday August 10, 2016. 8:49 am

Montgomery County
Notes of Testimony

Montgomery County
Notes of Testimony
Monday August 8, 2016. 9:27 am
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ENTRIES

Montgomery County
Notes of Testimony
Trial by Jury/A.M. Session, Ctrm A
Tuesday August 9, 2016. 8:52 am

Montgomery County
Notes of Testimony

Montgomery County
Notes of Testimony
Trial by Jury/A.M. Session, Ctrm A
Thursday August 11, 2016. 8:56 am
1 08/16/2016 Montgomery County Court

Administration
Sentencing Scheduled 10/24/2016 10:00AM

Montgomery County
Notes of Testimony
Friday August 12, 2016. 8:50 am
Judge Demchick-Alloy and a jury

Order Scheduling Hearing
Sentencing Hearing October 24, 2016 at 10:00 a.m. Courtroom "A"
Kramer, Ross M.
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ENTRIES

Montgomery County
Notes of Testimony
Monday August 15, 2016. 9:17 am
2 08/23/2016 Kramer, Ross M.

Exhibits Location Filed
1 08/25/2016 Kramer, Ross M.

2 08/25/2016 McGoldrick, Thomas W.

1 09/13/2016 Steinberg, Marc Robert

Entry of Appearance

Motion to Perform House Arrest Suitability Assessment
Filed by Marc Robert Steinberg, Attorney for Defendant

Decorum Order Governing Sentencing
Stew Ryan ADA served via order scanned and sent interoffice mail on 10/12/2016
Gerald L. Shargel, Esq., Seth C. Farber, Esq. served via order scanned and sent via first class mail on
10/12/2016
Henry, Michelle Ann
Kramer, Ross M.
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ENTRIES

Steele, Kevin R.
Steinberg, Marc Robert

Answer By
Commonwealth - Application for House Arrest Suitabilty Assessment - no later than 4:15 p.m. on 10/14/16
GERALD L SHARGEL ESQ AND SETH C FARBER ESQ SERVED VIA FIRST CLASS MAIL ON 10/13/2016
Henry, Michelle Ann
Kramer, Ross M.
Steele, Kevin R.

Response to Defendant's Motion to Perform House Arrest Suitability Assessment

Order Granting Motion to Perform House Arrest Suitability Assessment
Report due on or before 10/21/16
GERALD L SHARGEL ESQ, SETH C FARBER ESQ SERVED VIA FIRST CLASS MAIL 10/14/2016
M RYAN STEWART ADA SERVED VIA INTEROFFICE MAIL 10/14/2016
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ENTRIES

Henry, Michelle Ann
Kramer, Ross M.
Steele, Kevin R.

Sentencing Memorandum
CR 6239-15
8423-15

Thomas W. McGoldrick Deputy District Attorney

Sentnecing Memorandum
Filed by Marc Robert Steinberg, Esq.

2 10/24/2016 REGENSBURG, MARY P.

Bail Posted - Kane, Kathleen Granahan

Order - Sentence/Penalty Imposed
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ENTRIES

Order Modifying Bail


Order Modifying Bail

Motion to Withdraw as Counsel
Fiiled by Douglas K. Rosenblum, Esq.

Order Granting Motion to Withdraw as Counsel
Douglas Rosenblum Esq.

Filed by Seth C. Farber, Esq.


Filed by Ross M. Kramer, Esq.
51/1 11/01/2016 Demchick-Alloy, Wendy

Stipulation re: Waiver under Pa.R.Crim.P. 704(C)(3)
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ENTRIES

Seth Farber Esq.

Gerald Shargel Esq.

Ross Kramer Esq.

Filed by Marc Robert Steinberg, Esq.

Marc Robert Steinberg Esq.
GERALD SHARGEL ESQ, SERVED VIA FIRST CLASS MAIL 11/02/2016
11/02/2016
Henry, Michelle Ann
11/02/2016
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ENTRIES

11/02/2016
Steele, Kevin R.
11/02/2016

Montgomery County
Notes of Testimony
Sentencing, Ctrm A
Monday October 24, 2016. 10:03 am
57/1 11/21/2016 Minora, Amil Michael

58/1 11/22/2016 Lock, Joshua D.

Entry of Appearance

Notice of Appeal to the Superior Court
Filed by Joshua D. Lock, Esq.
59a/3 11/22/2016 Kane, Kathleen Granahan

Filed by Joshua D. Lock, Esq.

Amil M. Minora Esq.
11/22/2016
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ENTRIES

Montgomery County District Attorney's
Office
11/22/2016

1925(b) Concise Statement Order

Filed by Amil M. Minora, Esq.
63/1 12/09/2016 Lock, Joshua D.

Motion to Enlarge Time to File Concise Statement of Matters Complained of on Appeal Pursuant to Pa.
Motion to Enlarge Time to File Concise Statement of Matters Complained of on Appeal Pursuant to Pa.R.A.P.
1925(b)(2).
63a/2 12/09/2016 Kane, Kathleen Granahan


Order Granting Extension to File Statement of Matters Complained on Appeal
65/1 01/03/2017 Lock, Joshua D.

Concise Statement of the Matters Complained on Appeal
65a/2 01/03/2017 Lock, Joshua D.

66/1 01/04/2017 Lock, Joshua D.

Revised Statement of Matters Complained of on Appeal Pursuant to PA.R.A.P. 1925(b)
66a/2 01/04/2017 Lock, Joshua D.

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67/1 02/10/2017 Superior Court of Pennsylvania -

Eastern District
Order Dismissing Appeal as Duplicative

Opinion

Certificate and Transmittal of Record to Appellate Court

List of Documents Sent to Superior Court, DA, and Defendant's Attorney
PAYMENT PLAN SUMMARY

Payment Plan No Payment Plan Freq. Next Due Date Active Overdue Amt
Responsible Participant Suspended Next Due Amt
46-2016-P000016645 Monthly 09/18/2017 Yes $0.00
Kane, Kathleen Granahan No $15.01
Payment Plan History: Receipt Date Payor Name Participant Role Amount
11/30/2015 Payment Kane, Kathleen Granahan Defendant $9.00
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CASE FINANCIAL INFORMATION
Last Payment Date: 11/22/2016 Total of Last Payment: -$9.00
Kane, Kathleen Granahan Assessment Payments Adjustments Non Monetary Total
Defendant Payments
Costs/Fees
Copies (Montgomery) $9.00 $0.00 $0.00 $0.00 $9.00
Costs of Prosecution - CJEA $50.00 $0.00 $0.00 $0.00 $50.00
Judicial Computer Project $8.00 $0.00 $0.00 $0.00 $8.00
State Court Costs (Act 204 of 1976) $13.55 $0.00 $0.00 $0.00 $13.55
Appeal to Superior Court (Montgomery) $71.25 -$71.25 $0.00 $0.00 $0.00
Automation Filing Fee (Montgomery) $5.00 -$5.00 $0.00 $0.00 $0.00
ATJ $4.00 $0.00 $0.00 $0.00 $4.00
Automation Fee (Act 36 of 2000) $5.00 $0.00 $0.00 $0.00 $5.00
(Montgomery)
CJES $2.25 $0.00 $0.00 $0.00 $2.25
COC Processing Fee Misd/Fel $355.25 $0.00 $0.00 $0.00 $355.25
(Montgomery)
Commonwealth Cost - HB627 (Act 167 $20.30 $0.00 $0.00 $0.00 $20.30
of 1992)
County Court Cost (Act 204 of 1976) $29.65 $0.00 $0.00 $0.00 $29.65
Court Child Care (Act 105 of 2000) $5.00 $0.00 $0.00 $0.00 $5.00
(Montgomery)
Crime Victims Compensation (Act 96 of $35.00 -$9.00 $0.00 $0.00 $26.00
1984)
DNA Detection Fund (Act 185-2004) $250.00 $0.00 $0.00 $0.00 $250.00
Domestic Violence Compensation (Act $10.00 $0.00 $0.00 $0.00 $10.00
44 of 1988)
Firearm Education and Training Fund $5.00 $0.00 $0.00 $0.00 $5.00
JCPS $21.25 $0.00 $0.00 $0.00 $21.25
Variable Amount to be Distributed $12.00 $0.00 $0.00 $0.00 $12.00
CVC/VWS (Act 96)
Variable Amount to be Distributed $28.00 $0.00 $0.00 $0.00 $28.00
CVC/VWS (Act 96)
Victim Witness Service (Act 111 of 1998) $25.00 $0.00 $0.00 $0.00 $25.00
Costs/Fees Totals: $964.50 -$85.25 $0.00 $0.00 $879.25
Grand Totals: $964.50 -$85.25 $0.00 $0.00 $879.25
** - Indicates assessment is subrogated
only be provided by
an employer
10:51 A.M. STAN J. CATERBONE, PRO SE AMICUS FOR KATHLEEN KANE
Appeal Docket Sheet Superior Court of Pennsylvania

Docket Number: 3575 EDA 2016
Page 1 of 3
February 24, 2017
CAPTION
v.
Appellant
CASE INFORMATION
Initiating Document: Notice of Appeal
Case Status: Active

Case Processing Status: November 30, 2016 Awaiting Original Record
Journal Number:
Case Category: Criminal Case Type(s): Perjury
CONSOLIDATED CASES RELATED CASES
Docket No / Reason Type

3576 EDA 2016 Related
Same Case - Diff Docket
SCHEDULED EVENT
Next Event Type: Original Record Received Next Event Due Date: January 23, 2017
COUNSEL INFORMATION
Appellant Kane, Kathleen Granahan

Pro Se: No
IFP Status: No
Attorney: Lock, Joshua D.
Law Firm: Goldberg Katzman, P.C.
4250 Crums Mill Rd Ste 301
Harrisburg, PA 17112-2889
Phone No: (717) 234-4161 Fax No:
Amicus Caterbone, Stanley J.

Pro Se: Yes
IFP Status:
Pro Se: Stanley J. Caterbone
Address: 1250 Fremont St
Lancaster, PA 17603
Neither the
COMMONWEALTH v. Kathleen Appellate
Kane Courts nor the Administrative
OPINION Page 135 Office of Pennsylvania Courts assumes any liability Friday March 3, 2017
of 137
for inaccurate or delayed data, errors or omissions on the docket sheets.

Page 2 of 3
February 24, 2017
COUNSEL INFORMATION
Appellee Commonwealth of Pennsylvania

Pro Se: No
IFP Status:
Attorney: Steele, Kevin R.
Address: Montgomery County District Attorney's Office
PO Box 311
Phone No: (610) 278-3098 Fax No:
Attorney: Falin, Robert Martin

Law Firm: Montgomery County District Attorney's Office
Address: P.O. Box 311
Norristown, PA 19404
Phone No: (610) 278-3102 Fax No: (610) 278-3841
FEE INFORMATION
Fee Dt Fee Name Fee Amt Receipt Dt Receipt No Receipt Amt

11/22/2016 Notice of Appeal 85.50 11/30/2016 2016-SPR-E-002063 85.50
AGENCY/TRIAL COURT INFORMATION
Court Below: Montgomery County Court of Common Pleas

County: Montgomery Division: Montgomery County Criminal Division
Order Appealed From: October 24, 2016 Judicial District: 38
Documents Received: November 30, 2016 Notice of Appeal Filed: November 22, 2016
Order Type: Judgment of Sentence
OTN(s): T6863802 T7090322
Lower Ct Docket No(s): CP-46-CR-0006239-2015 CP-46-CR-0008423-2015
Lower Ct Judge(s): Demchick-Alloy, Wendy
Judge
ORIGINAL RECORD CONTENT
Original Record Item Filed Date Content Description
Date of Remand of Record:
BRIEFING SCHEDULE
None None
DOCKET ENTRY
Filed Date Docket Entry / Representing Participant Type Filed By

November 30, 2016 Notice of Appeal Docketed
November 30, 2016 Docketing Statement Exited (Criminal)

Superior Court of Pennsylvania
Neither the
of 137

Page 3 of 3
February 24, 2017
DOCKET ENTRY

December 9, 2016 Other
Eldridge, Lisa A.
Document Name: Per TC Judge's chambers - Extension granted throught 1/6/17 to file 1925(b) statement.
Comment: Opinion will be filed by 3/6/17.
December 16, 2016 Docketing Statement Received (Criminal)

December 28, 2016 Application for Leave to File Amicus Brief

Comment: Stan J. Caterbone, Advanced Media Group
January 19, 2017 Order

Per Curiam
Comment: Upon consideration of the Petitioner's "Request The Courtesy Of The Court To Appear Pro Se And To
File An Amicus Curaie [sic] Brief In Support Of The Following," filed by "Stan J. Caterbone," the
petitioner shall not be permitted to present oral argument.
Neither the
of 137
IN SUPPORT OF QUASHING THE CHARGES IN MONTGOMERY COURT CASE NO. CP-46-CR-0006239-2015
Stan J. Caterbone

Surveillance,
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
SUPERIOR COURT OF PENNSYLVANIA
IN RE: : Docket Number: 3575 EDA 2016
COMMONWEALTH OF PENNSYLVANIA : Lower Court Docket CP-46-CR-0006239-2015
v. :
KATHLEEN KANE :
REQUEST THE COURTESY OF THE COURT TO APPEAR PRO SE AND TO FILE
AN AMICUS CURAIE BRIEF IN SUPPORT OF THE FOLLOWING
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:

AND NOW comes before the said court Stanley J. Caterbone, appearing Pro Se, and Advanced
Media Group, request for Appearance to file an Amicus in the above captioned case to support the
following:
1. Quashing the charges in case Montgomery Court Case No. CP-46-CR-0006239-2015
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.
Rule 531. Participation by Amicus Curiae.

(a) Briefs.Anyone interested in the questions involved in any matter pending in an appellate court,
excluding Petitions for Allowance of Appeal, although not a party, may, without applying for leave to
do so, file a brief amicus curiae in regard to those questions.
(1) Unless otherwise ordered by the court, any amicus curiae shall file and serve its brief in the
manner and number required and within the time allowed by these rules with respect to the party
whose position as to affirm and or reversal the amicus brief will support, or with respect to the
appellant, if the amicus brief does not support the position of any party.
3575 EDA 2016 - AMICUS BRIEF Page 1 of 23 Friday December 23, 2016
(2) In an appeal proceeding under Rules 2154(b), 2185(c) and 2187(b), any amicus curiae shall file
and serve its brief within the time allowed by these rules for service of the advance text of the brief
by the party whose position as to affirm and or reversal the amicus brief will support or, if the amicus
brief does not support the position of any party, within the time allowed by these rules for service of
the advance text by the appellant. Alternatively, the amicus curiae may, but is not required to, serve
an advance text and then file and serve a definitive copy of its brief. If the amicus curiae chooses to
serve an advance copy and then file and serve a definitive copy, its deadlines for each are the same
as for the party whose position as to affirm and or reversal the amicus brief supports or, if the
amicus brief does not support the position of any party, as for the appellant.
(b) Oral argument.Oral argument may be presented by amicus curiae only as the appellate court
may direct. Requests for leave to present oral argument shall be by application and will be granted
only for extraordinary reasons.
Official Note
Where the amicus cannot comply with the requirements of this rule because of ignorance of the
pendency of the question, relief may be sought under Rule 105(b). The last eight words of the rule
are new. In Piccirilli Bros. v. Lewis, 282 Pa. 328, 336, 127 Atl. 832, 835 (1925) the court noted the
applicability of this rule to public officers who are represented by official counsel with an adverse
position.
The 2011 amendment to the rule clarified when those filing amicus curiae briefs should serve and file
their briefs when the appellant has chosen or the parties have been directed to proceed under the
rules related to large records (Rule 2154(b)), advance text (Rule 2187(b)) and definitive copies (Rule
2185(c)). Under those rules, the appellant may defer preparation of the reproduced record until after
the briefs have been served. The parties serve on one another (but do not file) advance texts of their
briefs within the times required by Rule 2187. At the time they file their advance texts, each party
includes certified record designations for inclusion in the reproduced record. The appellant must then
prepare and file the reproduced record within 21 days of service of the appellees advance text (Rule
2186(a)(2)). Within 14 days of the filing of the reproduced record, each party that served a brief in
advance text may file and serve definitive copies of their briefs. The definitive copy must include
references to the pages of the reproduced record, but it may not otherwise include changes from the
advance text other than correction of typographical errors. Those filing amicus curiae briefs may
choose to serve an advance text and then file and serve definitive copies according to the procedure
required of the parties or they may choose to file a definitive brief without citations to the reproduced
record.
December 23, 2016
Respectfully,
____________/S/____________

1250 Fremont Street
Lancaster, PA 17603
717-528-2200
Notice and Disclaimer: Stan J. Caterbone and the Advanced Media Group have been slandered, defamed,
and publicly discredited since 1987 due to going public (Whistle Blower) with allegations of misconduct
and fraud within International Signal & Control, Plc. of Lancaster, Pa. (ISC pleaded guilty to selling arms to
Iraq via South Africa and a $1 Billion Fraud in 1992). Unfortunately we are forced to defend our reputation
and the truth without the aid of law enforcement and the media, which would normally prosecute and
expose public corruption. We utilize our communications to thwart further libelous and malicious attacks
on our person, our property, and our business. We continue our fight for justice through the Courts, and
some communications are a means of protecting our rights to continue our pursuit of justice. Advanced
Media Group is also a member of the media. Reply if you wish to be removed from our Contact List. How
long can Lancaster County and Lancaster City hide me and Continue to Cover-Up my Whistle Blowing of the
ISC Scandel (And the Torture from U.S. Sponsored Mind Control)?
ACTIVE COURT CASES

3. J.C. No. 03-16-90005 Office of the Circuit Executive, United States Third Circuit Court of Appeals -
COMPLAINT OF JUDICIALMISCONDUCT OR DISABILITY re 15-3400 and 16-1149; 03-16-900046 re
ALL FEDERAL LITIGATION TO DATE
4. U.S. Supreme Court Case No. 16-6822 PETITION FOR WRIT OF CERTIORARI re Case No. 16-1149
MOVANT for Lisa Michelle Lambert
5. U.S.C.A. Third Circuit Court of Appeals Case No. 16-1149 MOVANT for Lisa Michelle Lambert;15-3400
MOVANT for Lisa Michelle Lambert;; 16-1001; 07-4474
6. U.S. District Court Eastern District of PA Case No. 16-cv-49; 15-03984; 14-02559 MOVANT for Lisa
Michelle Lambert; 05-2288; 06-4650, 08-02982;
7. U.S. District Court Middle District of PA Case No. 16-cv-1325 PRELIMINARY INJUNCTION FOR
EMERGENCY RELIEF; Case No. 16-cv-1751 PETITION FOR HABEUS CORPUS
8. Commonwealth of Pennsylvania Judicial Conduct Board Case No. 2016-462 Complaint against
Lancaster County Court of Common Pleas Judge Leonard Brown III
9. Pennsylvania Supreme Court Case No. 353 MT 2016; 354 MT 2016; 108 MM 2016 Amicus for Kathleen
Kane
10. Superior Court of Pennsylvania Summary Appeal Case No. CP-36-SA-0000219-2016, AMICUS for
Kathleen Kane Case No. 1164 EDA 2016; Case No. 1561 MDA 2015; 1519 MDA 2015; 16-1219
Preliminary Injunction Case of 2016
11. Lancaster County Court of Common Pleas Case No. 08-13373; 15-10167; 06-03349, CI-06-03401
12. U.S. Bankruptcy Court for The Eastern District of Pennsylvania Case No. 16-10157
Stan J. Caterbone/Advanced Media Group Biography
Present - Advanced Media Group, President, Owner, and Founder.
In 1987 AMICUS became a federal whistleblower for the case of local defense contractor
International Signal and Control, or ISC. ISC was a black ops program for the NSA and CIA that
was convicted in 1992 for an elaborate scheme to arm Iraq and other Middle Eastern countries
with a broad array of weapons, most notably cluster bombs. It was the third larges fraud in U.S.
History at that time. I have been a victim of organized stalking since 1987 and a victim of
electronic and direct energy weapons since 2005. I had also been telepathic since 2005. In 2005
the U.S. Sponsored Mind Control turned into an all-out assault of mental telepathy; synthetic
telepathy; hacking of all electronic devices; vandilism and thefts of personal property, extortions,
intellectual property violations, obstruction of justice; violations of due process; thefts and
modifications of court documents; and pain and torture through the use of directed energy
devices and weapons that usually fire a low frequency electromagnetic energy at the targeted
victim. This assault was no coincidence in that it began simultaneously with the filing of the
federal action in U.S. District Court, or CATERBONE v. Lancaster County Prison, et. al., or 05-cv-
2288. This assault began after the handlers remotely trained/sychronized Stan J. Caterbone with
mental telepathy. The main difference opposed to most other victims of this technology is that
THE AMICUS is connected 24/7 with the same person who declares telepathically she is a known
celebrity. Over the course of 10 years THE AMICUS has been telepathic with at least 20 known
persons and have spent 10 years trying to validate and confirm their identities without success.
Most U.S. intelligence agencies refuse to cooperate, and the Federal Bureau of Investigation and
the U.S. Attorney's Office refuse to comment and act on the numerous formal complaints that are
filed in their respective offices. Most complaints are focused on the routine victimization's of a
targeted individual including but not limited to stalking, harassment, threats, vandalism, thefts,
extortion, burglaries, false imprisonments, fabricated mental health warrants or involuntary
commitments, pain and torture to the body, and most often the cause of obstruction of justice is
the computer hacking.
THE AMICUS has a very sophisticated and authentic library of evidence of the use of U.S.
Sponsored Mind Control technologies on my father and brother that dates back to the 1940's
while my father was in the U.S. Navy after he graduated with honors from Air Gunners School in
Florida, including an affidavit motorized and authenticated by my father in 1996. My brother
served in the U.S. Air force and was victim to LSD experiments of the infamous MKULTRA program
in the late 1960's.
In 2016 THE AMICUS was the AMICUS for Pennsylvania Attorney General Kathleen Kane in the
Pennsylvania Superior Court Case No. 1164 EDA 2016 in the COMMONWEALTH OF PENNSYLVANIA
v. Kane which included perjury charges during the alleged leaking of grand jury information.
Kathleen Kane took on the Good Old Boy network regarding judicial reform in the
Commonwealth of Pennsylvania in an effort to rid the state of the long standing public corruption
ring that was evident from local law enforcement to Supreme Court Justices, and everyone in
between.
In 2015 THE AMICUS 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. THE AMICUS
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. THE AMICUS is in frequent contact with her co-
author, Dave Brown of Philadelphia, Pennsylvania.
In 2009 THE AMICUS 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. THE AMICUS again
reintroduced the bill to the Pennsylvania General Assembly in 2015 and frequented the
Pennsylvania Capitol trying to find support and a sponsor; which THE AMICUS still does to this
day.
In 2006 THE AMICUS 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. THE AMICUS has 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. THE AMICUS believes 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 THE AMICUS, 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 THE AMICUS was selected to attend the Clinton Global Initiative in New York City
after submission of an essay with and application. THE AMICUS received the invitation from
Bruce R. Lindsey, Chief Executive Officer of the William J. Clinton Foundation.
In 2005 THE AMICUS 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.
In 2004 THE AMICUS 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 THE AMICUS 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 THE AMICUS 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 THE AMICUS contributed to the debate, research, and implementation of strategies to
counter the effects of the global Y2K threat to the worlds computer technologies. THE AMICUS
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 THE AMICUS 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 THE AMICUS had done consulting for companies under KAL, Inc., during the time that
THE AMICUS was controller of Pflumm Contractors, Inc., THE AMICUS was retained by Gallo
Rosso Restaurant and Bar to computerized their accounting and records management from top to
bottom. THE AMICUS had also provided consulting for the computerization of accounting and
payroll for Lancaster Container, Inc., of Washington Boro. THE AMICUS 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. THE AMICUS 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 THE AMICUS 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.
In 1991 THE AMICUS 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 THE AMICUS had worked on developing voice recognition systems for the governments
technology think tank - NIST (National Institute for Standards & Technology). THE AMICUS 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 THE AMICUS 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.
THE AMICUS 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. THE AMICUS 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.
THE AMICUS 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 THE AMICUS 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 THE AMICUS 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 THE AMICUS 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 THE AMICUS 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.
In 1985 THE AMICUS 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 THE AMICUS 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.
AMICUS CURIAE IN SUPPORT OF KATHLEEN KANE'S (ATTORNEY GENERAL) MOTION
TO DISMISS CHARGES BASED ON SELECTIVE AND VINDICTIVE PROSECUTION
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
AND NOW comes before the said court Stanley J. Caterbone, appearing Pro Se, and Advanced
Media Group, as Movant, to file an Amicus in the above captioned case.
The Movant has an interest in this case as also being a victim of SELECTIVE AND VINDICTIVE
PROSECUTION by the Commonwealth of Pennsylvania and the Lancaster County District Attorney's
Office dating back to the myriad of prosecutions by the Commonwealth of Pennsylvania in 1987, 2005,
and 2006 while a resident of the County of Lancaster, Pennsylvania. Most of which have been
dismissed without any convictions, most without any trials, which according to law are false arrests and
false imprisonments. The MOVANT was a Federal Whistleblower in the United States v. International
Signal and Control, Plc., case of 1991.
This amicus provides a voice for the Movant as well as providing another perspective and opinion
that should benefit the courts; the parties; and the public-at-large. The matters presented in this
amicus have a direct relevancy in the disposition of this case as it does in the Attorney General's
(Kathleen Kane) fight to restore integrity and equity to the Judicial System of Pennsylvania, which
affects all of the residents of the COMMONWEALTH. The Attorney General has been quoted as 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 makes mistakes. I
knew there was a good old boy network, everyone does. I had no idea how deep and how
powerful that network actually ran. The fact that I took it on and I wasn't silent about it and
that I am determined to tear that down, I think that's what my legacy will show.
In a 1998 narrative the MOVANT wrote the following This story was perpetuated through a
gross miscarriage of justice: a tenure of malicious wrongdoing by both the law enforcement
community of Lancaster County and the Commonwealth of Pennsylvania, as well as
community leaders. A process that continues to obstruct Stan Caterbone's rights for justice.
It's mannerisms reach into the inner soul of political and judicial corruption. All in the name
of greed, and all in the honor of continuing the status quo of the "Good Ole Boy's" club of
Lancaster County. A process obsessed with keeping it's disclosure from escaping beyond the
confines of "Pandora's Box". It's a tenure of power that evolved from the days of this
country's earliest settlers, but an evolution that has somewhere strayed away from the
intent of our constitution; with total disregard for the law, in total disrespect for the
Constitution, and void of many of our civil liberties. This atrocity, like the Lambert case,
would have made our founding forefathers revel in disgust and bellow in despair. In
fact, their spirits and energies probably are!
In 2009 Opednews.com printed the narrative in full and the MOVANT wishes this said court
to consider it's content in it's final deliberations in support of dismissing all prosecutions against
the Attorney General of Pennsylvania. In addition attached are supporting documents to
advanced the credibility and integrity of the MOVANT. These documents are attached as
EXHIBITS.
Diary: Lancaster County, The CIA, and U.S. Sponsored Mind Control ,
http://www.opednews.com/populum/diarypagem.php?f=Lancaster-County-The-CIA-
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.
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.
HISTORY AND BACKGROUND OF MOVANT AND THE JUDICIAL SYSTEM

In 2015 the Lancaster County Court of Common Pleas began a campaign of DENYING In
Forma Pauperis Applications, and demanding that current cases with legitimate In Forma Pauperis
Status be DENIED in an effort to again subvert the laws of due process and obstruction of justice.
The Superior Court had followed, as did the U.S. District Court in this case by Judge Diamond.
This was an outright effort to extort monies from the MOVANT and in the long term make service
of the complaints cost prohibitive due to the fact that Pro Se Litigants with In Forma Pauperis
Status, by law, receive free service from the Lancaster County Sheriffs and the U.S. Marshalls.
This tactic, in the end, would have effectively dismissed all legitimate claims of the MOVANT. The
Judges used the excuse of monies in bank accounts as the rationale for the illegal tactic, however,
attached are 5 cases of GRANTED In Forma Pauperis applications in both the Lancaster County
Court of Common Pleas, the Pennsylvania Superior Court, and the United States District Court
with financial affidavits containing amounts of monies in bank accounts exceeding $10,000.00, all
prior to 2015.
This exhibit, like the previous EXHIBITS, is intended to help the Court understand the
complexity of the MOVANT'S obligation to provide the Court with the evidence and insight to
support the MOVANT'S claims and statements. These documents will also provide the Court with
sufficient knowledge of the MOVANT'S claim of the value of the
MOVANT's litigation of up to $50 million dollars as stated in the U.S. Bankruptcy Case No. 05-
23059. The MOVANT does not intend to overburden the Court with unnecessary filings, however
this burden of supporting the claims and statements falls on the shoulders of all those in the
government that ignored the MOVANT'S pleas for help to resolve these issues dating back to the
days immediately following the meeting with International Signal & Control, Plc., (ISC) Executive
Larry Resch on June 23, 1987.
This information could explain the COINTELPRO attributes of my situation and persons
under oath of law must refer this to the U.S. Attorney's Office and provide me with relief.
I am currently a recipient of the following type(s) of Benefits from the Social Security
Administration for Long Term Disability Benefits for illnesses and symptoms relating to U.S.
Sponsored Mind Control as evidenced by my documentation and the fact that no medical reports
or physicians were reported in the entire application process and there was never a psychiatric
evaluation for the same said purposes. I am receiving a net monthly benefit of $1330.00 and
have been since April of 2008 and was declared disabled in December of 2005, the same said
month that I reported that I became the victim of full-time synthetic telepathy, as well as other
related symptoms and illnesses.
If the Court would consider the leqal circumstances surrounding my Whistleblowing activities and
the Federal False Claims Act filing of the Petitioner as it relates to the past 28 years and the
myriad of violations of the Lancaster County District Attorney. The Petitioner wil argue that it is
wholly unfair and unconstitutional not to grant the Petitioner In Forma Pauperis Status. The
Petitioner has filed ample evidence of a pattern and relentless cycle of earning and accumulating
capital and assets, as well building substantial worth through his business interests, only to have
it all extorted through an elaborate civil and criminal scheme to defruad. Therefore any
attempt to subject the Petitioner to more court related fees is only a continuation of
that same said fraud.
Consideration should be given to Pederson v. South Williamsport Area School District,
where the courts interpreted due process, as Essentially fundamental fairness is exactly what due
process means. Furthermore, the United States District Courts in Perry v. Coyler (1978, 524 F
2d. 644) have concluded the following: Even the probability of unfairness can result in a
defendant being deprived of his due process rights. The focus of these claims are recorded in
the United States District Court for the Eastern District of Pennsylvania, 05-2288 and 06-4650. In
addition the Petioner is the MOVANT in the Lisa Michelle Lambrerrt Case and recently filed a
Motion for Summary Judgment, 04-2559, which was recently appealed to the Third Circuit Court
of Appeals. The preceding cases have been preserved by the Third Circuit Court of Appeals in
case no. 07-4474, see attached.
The prosecutorial misconduct the the Petitioner has been subject to has violated his
constitutional rights, but more importantly the abuse or process has prevented the Petitioner from
completing a wealth of claims in both state and federal Courts. 1983 Civil Rights Acts and 18
U.S.C.A. Acts state the following: The underlying purpose of the scheme of protecting
constitutional rights are to permit victims of constitutional violations to obtain redress, to provide
for federal prosecution of serious constitutional violations when state criminal proceedings are
ineffective for purpose of deterring violations and to strike a balance between protection of
individual rights from state infringement and protection from state and local government from
federal interference, 18 U.S.C.A. 241, 242; U.S.C.A. Const. Art. 2, 53; Amend. 13, 14, 5,
15, 2: 42 U.S.C.A. 1981-1982, 1985, 1988, Fed. Rules Civil Proc. Rule 28, U.S.C.A.
A case can be made for a RICO violation as defined in the case of United States v. Holck,
389 F. Supp. 2d. 338, criminal responsibility defines single or multiple conspiracies by the
following: Governments, without committing variance between single conspiracy charges in an
indictment and its proof at trial may establish existence at continuing core conspiracy which
attracts different members at different times and which involves different subgroups committing
acts in furtherance of an overall plan. This illustrates the legal analysis of the 1987 conspiracy to
cover-up my International Signal & Control, Plc., whistle blowing activities.
The 29 False Arrests, which under Pennsylvania Law, constitute a conspiracy that may be
proved by circumstantial evidence that is by acts and circumstances sufficient to warrant an
inference that the unlawful combination has been in front of facts formed for the purpose
charged. See Walcker v. North Wales Boro, 395 F. Supp. 2d. 219. In the same case the following
was supported: Arrestees allegations that the township (Conestoga) and its police officers were
acting in concert and conspiracy and with the purpose of violating arrestees constitutional rights
by subjecting him to unreasonable force, arrest, search, and malicious prosecution and the two
(2) or more officers acted together in throwing arrestee to the ground (April 5 th, 2006 and August
4th, 2006) and forcing him to take two (2) blood tests and holding him in custody. The preceding
pleaded civil conspiracy claims under Pennsylvania Law.
13. In order to state a claim for civil conspiracy and a cause of action under Pennsylvania Law,
a plaintiff must allege that two (2) or more persons agree or combine with lawful intent to
do an unlawful act or to do an otherwise lawful act by unlawful means, with proof of malice
with intent to injure the person, his/her property and or business. In the case of United
States v. Holck, 389 F. Supp. 2d. 338, criminal responsibility defines single or multiple
conspiracies by the following: Governments, without committing variance between single
conspiracy charges in an indictment and its proof at trial may establish existence at
continuing core conspiracy which attracts different members at different times and which
involves different subgroups committing acts in furtherance of an overall plan. 1983 Civil
Rights Acts and 18 U.S.C.A. Acts state the following: The underlying purpose of the
scheme of protecting constitutional rights are to permit victims of constitutional violations
to obtain redress, to provide for federal prosecution of serious constitutional violations
when state criminal proceedings are ineffective for purpose of deterring violations and to
strike a balance between protection of individual rights from state infringement and
protection from state and local government from federal interference, 18 U.S.C.A. 241,
242; U.S.C.A. Const. Art. 2, 53; Amend. 13, 14, 5, 15, 2: 42 U.S.C.A. 1981-1982,
1985, 1988, Fed. Rules Civil Proc. Rule 28, U.S.C.A.
Under RICO, a person or group who commits any two of 35 crimes27 federal crimes and
8 state crimeswithin a 10-year period and, in the opinion of the US Attorney bringing the case,
has committed those crimes with similar purpose or results can be charged with racketeering.
Those found guilty of racketeering can be fined up to $25,000 and/or sentenced to 20 years in
prison. In addition, the racketeer must forfeit all ill-gotten gains and interest in any business
gained through a pattern of "racketeering activity." The act also contains a civil component that
allows plaintiffs to sue for triple damages. When the U.S. Attorney decides to indict someone
under RICO, he has the option of seeking a pre-trial restraining order or injunction to prevent the
transfer of potentially forfeitable property, as well as require the defendant to put up a

performance bond. This provision is intended to force a defendant to plead guilty before
indictment. There is also a provision for private parties to sue. A "person damaged in his business
or property" can sue one or more "racketeers." There must also be an "enterprise." The
defendant(s) are not the enterprise, in other words, the defendant(s) and the enterprise are not
one and the same. There must be one of four specified relationships between the defendant(s)
and the enterprise. This lawsuit, like all Federal civil lawsuits, can take place in either Federal or
State court. http://www.dealer-magazine.com/index.asp?article=481
Where RICO laws might be applied1

Although some of the RICO predicate acts are extortion and blackmail, one of the most
Successful applications of the RICO laws has been the ability to indict or sanction individuals for
their behavior and actions committed against witnesses and victims in alleged retaliation or
retribution for cooperating with law enforcement or intelligence agencies. The RICO laws can be
alleged in cases where civil lawsuits or criminal charges are brought against individuals or
corporations in retaliation for said individuals or corporations working with law enforcement, or
against individuals or corporations who have sued or filed criminal charges against a defendant.
Anti-SLAPP (strategic lawsuit against public participation) laws can be applied in

an attempt to curb alleged abuses of the legal system by individuals or corporations
who utilize the courts as a weapon to retaliate against whistle blowers, victims, or to
silence another's speech. RICO could be alleged if it can be shown that lawyers and/or
their clients conspired and collaborated to concoct fictitious legal complaints solely in
retribution and retaliation for themselves having been brought before the courts. These
laws also apply to victims of clergy abuse where statute of limitations has run out.
References
RICO Suave (http://www.snopes.com/language/acronyms/rico.asp) . Snopes.com: (21 December

2004). Retrieved on 2006-03-26. 1.
External links
RICO Act from Cornell University'sU. S. Code database
(http://www.law.cornell.edu/uscode/html/uscode18/usc_sup_01_18_10_I_20_96.html) Detail of Tanya
Andersen's claim against Atlantic Records (http://recordingindustryvspeople.blogspot.com/2005/10/oregon-
riaa-victim-fights-back- sues.html) Retrieved from
http://en.wikipedia.org/wiki/Racketeer_Influenced_and_Corrupt_Organizations_Act Categories: Articles with
weasel words | United States federal legislation | Organized crime terminology
EXHIBIT FOR
CONSIDERATION
with accompanying DVD Titled
KANE AMICUS DVD
EXHIBIT DOCUMENT FILE LIST (38)
1. 0-LETTER to JAMES COMEY, DIRECTOR of FBI re PRO SE BILLINGS INVOICE Wednesday November 30, 2016.pdf
05.12.2016 624713 pdf
2. 01-COINTELPRO - Case Law The Assassination of Fred Hampton 47 Years Later , by Flint Taylor Attorney,
December 5, 2016.pdf 05.12.2016 34916121 pdf
3. 1-The Surreptitious Reincarnation of COINTELPRO with the COPS Gang-Stalking Program - Lancaster City Police
Stregic Plan, August 24, 2016.pdf 05.12.2016 280796 pdf
4. 2-STAN J. CATERBONE and CONFLICTS WITH THE TRUMP ADMINISTRATION - Monday November 14, 2016.pdf
05.12.2016 12736810 pdf
5. 3-FALSE IMPRISONMENT AND ILLEGAL INTERROGATIONS by U.S. Intelligence Agencies November 12, 2016.pdf
05.12.2016 90810967 pdf
6. 4-Amici Curiae Filed by Stan J. Caterbone 2007 to 2016 - Kathleen Kane - The National Security Agency NSA -
Lisa Michelle Lambert - Mehgan Liappatt - May 18, 2016.pdf 05.12.2016 6145848 pdf
7. 5-FEDS PROBE FULTON BANK and 3 other SUBSIDIARY BANKS of FULTON FINANCIAL with STAN J. CATERBONE
CIVIL ACTIONS and Mind Control Research of Monday November 7, 2016.pdf 05.12.2016 41215673 pdf
8. 6-Stan J. Caterbone LOCAL, STATE, and FEDERAL COURT DOCKET SHEETS as of November 12, 2016.pdf
05.12.2016 52519867 pdf
9. 7-Stan J. Caterbone United Nations Human Rights Council of Geneva Switzerland Complaint and Exhibit re U.S.
Sponsored Mind Control, Oct 4, 2009.pdf.pdf 05.12.2016 36042567 pdf
10. 8-CATERBONE v. the United States of America, et.al., COMPLAINT July 20, 2016 ver 3.0 July 22, 2016.pdf
05.12.2016 22161323 pdf
11. 9-MEMORANDUM FOR PRESIDENT OBAMA re Leniency for Edward Snowden by 15 FORMER INTELLIGENCE
MEMBERS November 28, 2016 with Director Comey Letter December 1, 2016.pdf 05.12.2016 2628625
pdf
12. 10-Superior Court Case No. Case No. 1219 MDA 2016 BRIEF IN SUPPORT OF APPEAL AND GRANTING OF
INJUNCTION Thursday December 1, 2016.pdf 05.12.2016 3166268 pdf
13. 11-Superior Court Case No. Case No. 1219 MDA 2016 MOTION TO CLARIFY RECORD FROM LOWER COURT
December 2, 2016.pdf 05.12.2016 1351274 pdf
14. 12-Superior Court of Pennsylvania Case No. 3576 EDA 2016 REQUEST FOR APPEARANCE re Kathleen Kane
Amicus in Support of Motion to DISMISS Charges November 30, 2016.pdf 05.12.2016 532479 pdf
15. 13 - Advanced Media Group ORIGINAL INVOICES and ACCOUNTS RECEIVABLES for November 30, 2016 Updated
December 1, 2016.pdf 05.12.2016 16735360 pdf
16. 14-Invoice to SECRETARY OF DEFENSE ASH CARTER for Victimization of U.S. Sponsored Torture Program
December 2, 2016.pdf 05.12.2016 3104639 pdf
17. 15-LETTER and DOCUMENT to Cappello & Noel, LLP of Santa Barbara, CA Friday November 25, 2016.pdf
05.12.2016 35068104 pdf
18. 16-Federal False Claim Act Filing of October 19 2006 4200 AUTHENTIC ORIGINAL DOCUMENTS November 26,
2016.pdf 05.12.2016 588809867 pdf
19. 17-Stan J. Caterbone BOOKMARKS and HISTORY December 5, 2016.pdf 05.12.2016 4212654 pdf
20. 18-Supreme Court of the United States Case No. 16-8822 COMPLETE FILE re CATERBONE v. Allison Hallet, re
Lisa Lambert Habeus November 22, 2016.pdf 05.12.2016 12700920 pdf
21. 19-Samuel Caterbone Jr Naval Air Gunners School Honors 1943.pdf 20.12.2016 258417 pdf
22. 20-Samuel Caterbone Jr Naval Air Gunners School Certificate 1.pdf 20.12.2016 104409 pdf
23. 21-Naval Air Gunners Training Manual June 1 1943.pdf 20.12.2016 3701618 pdf
24. 22-Samuel P. Caterbone (My Father) Criminal Charges.pdf 20.12.2016 70766 pdf
25. 23-Naval Air Technical Training Center Photo Album.pdf 20.12.2016 5899658 pdf
26. 24 Criminal Charges Dismissed 1987 to 2007.pdf 20.12.2016 347656 pdf
27. 24-Samuel Caterbone Naval Air Gunners Honors 1943.pdf 20.12.2016 139674 pdf
28. 25-Dismissed Criminal Charges April 6 2007.pdf 20.12.2016 1317168 pdf
29. 26-1975 United States Senate Select Hearings on MKultra.pdf 20.12.2016 1828709 pdf
30. 27-ADVANCED MEDIA GROUP - Mark Zuckerberg and his FACEBOOK MIND CONTROL STRATEGIES and KNOWN
ATHEIST Tuesday August 30, 2016.pdf 20.12.2016 2551914 pdf
31. 28-Authentic and ORIGINAL Documents of 1987 RESTORED ON DECEMBER 15, 2016.pdf 20.12.2016
71690158 pdf
32. 29-Calhoun Private Criminal Complaint Sept 22 2007.pdf 20.12.2016 245271 pdf
33. 30-Dave Plummer offers counsel in a crisis.pdf 20.12.2016 99087 pdf
34. 31-David Schuyler Franklin & Marshall - Reunion 2007 Schedule of Events.pdf 20.12.2016 930201 pdf
35. 32-Electronic Mind Control & Timothy McVeigh jan 3 2008.pdf 20.12.2016 132969 pdf
36. 33-Email to Paul Cambell re 3179-06 Appeal April 5 2008 CORRUPTION IN THE FLEEING CRIMINAL CASE AND
APPEAL June 28, 2016.pdf 20.12.2016 142674 pdf
37. 34-Exhibit D of Duke Street Samuel Caterbone Criminal File Mar 4, 2009.pdf 20.12.2016 3248306 pdf
38. 35-Letter to Epic Card re Complaint of Bonnie Lee Polygraph Solutions August11, 2015.pdf 20.12.2016
28004831 pdf
DVD EXHIBIT
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EXHIBIT AUDIO FILE LIST (28)
1. ALTANA Rooftop Bar June 25, 2016 - Conspiracy to Commit

2. Appointment with Dr. Brian Sullivan of Abbeyville Family Medicine-LGH re Pain Management of March
3. Audio Appointment with Psychiatrist Al Shulz in January of 1998 in his Office in York, Pennsylvania
4. Audio of Call to KENS TV5 re Broadcast of Dr. John Hall March 8, 2010
5. Audio of FFCHS Conference Call with Orville re Survey of TI's on Surge of EXTREME PAIN and TERROR on March
11, 2010
6. AUDIO of Fulton Bank Harassment on EXTREME PAIN and TERROR on March 11, 2010.mp3
7. Audio Recordings of 1987 - PA SEC-PA Atty Gen-Gamillion Film Studios-Power Station Studios-Sandra Gray Atty
8. Call to Assistant U.S. Attorney Chrystie Fawcett During Serving of 302 Petition on April 8, 2010
9. Conversation and Plea for Help with Pennsylvania Attorney Bodan on October 19, 1987
10. Conversation With Attorney David Drubner on July 10, 1987
11. Conversation With Lancaster Aviation President Chuck Smith re Illegal Reposession of Aircraft on
12. Dr. John Hall Radio Show of FFCHS Press Conference of April 19, 2010 in Louisville Kentucky
13. FFCHS Conference Call re Takeover December 15, 2015
14. Harassment and Malic at NovaCare Rehabilitation for Physical Therapy on April 1, 2010
15. Meeting With Attorney Sandra Grey in San Diego on February 24, 1988
16. Meeting with Howard Eisler, Investigator With The Pennsylvania Securities Commission re ISC of September 29,
1987
17. Meeting With Pennsylvania Securities Commission Agent Howard Eisler of September 29, 1987
18. Message from Liapatt Attorney Julie Cooper re Email March 15, 2010
19. Message From Lt. Detective Clark Bearinger re Psychiatric Appointment of April 23, 2010
20. My Appearance on FFCHS Talkshoe Conference with Orville April 1, 2010 Online Chat
21. Phone Conversation With Pennsylvania Securities Commission Agent Howard Eisler on October 17, 1987
22. Recording of Dale Graff on Coast to Coast re Remote Viewing - Project Stargate - DIA with My Commentary
February 17, 2010
23. Return Call from U.S. Attorney Christie Fawcett on February 22, 2010 9-58AM
24. Second Conversation With Atty Drubner & Meeting With Film Studio Gamillion Studios of Hollywood Jul
25. Segments of My Appearence and Interview on FFCHS Talkshoe Conference with Orville April 1, 2010
26. Sgt. Busser of Southern Regional Police 302 Fleeing Arrest AUDIO Recording With Commentary of Apr
27. The Jim Guest Show Week 3 with Dr. Hall and Dr. Robertson re Electromagnetic Weapons November 29, 2009
28. TS-340595 4-01-2010-My Appearence on FFCHS Talkshoe Conference with Orville April 1, 2010 Online Chat
DVD EXHIBIT
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Stan J. Caterbone

Surveillance,
1250 Fremont Street
Lancaster, PA 17603
717-669-2163
November 28, 2016
James Comey, Director

FBI Headquarters
935 Pennsylvania Avenue, NW
Washington, D.C. 20535-0001
(202) 324-3000
Re: ALLEGATION: COINTELPRO PROGRAM WITH HARASSMENT USED TO OBSTRUCT

JUSTICE IN MY CIVIL AND CRIMINAL COURT PROCEEDINGS
Dear Director Comey,
It comes with great regret and frustration that I must write you this unfortunate letter,
however, I see no other way to stop these attacks against me while I attempt to litigate in
Federal, State, and Local Courts. My most recent case, US Supreme Court Case No. 16-6822.
For your information COINTELPRO is defined as this:
COINTELPRO (a portmanteau derived from COunter INTELligence PROgram) was a series of

covert, and at times illegal,[1][2] projects conducted by the United States Federal Bureau of
Investigation (FBI) aimed at surveilling, infiltrating, discrediting and disrupting domestic
political organizations.[3]
FBI records show that COINTELPRO resources targeted groups and individuals that the FBI
deemed subversive,[4] including anti-Vietnam War organizers, activists of the Civil Rights
Movement or Black Power movement (e.g., Martin Luther King, Jr. and the Black Panther
Party), feminist organizations, anti-colonial movements (such as Puerto Rican independence
groups like the Young Lords), and a variety of organizations that were part of the broader New
Left.
FBI Director J. Edgar Hoover issued directives governing COINTELPRO, ordering FBI agents to
"expose, disrupt, misdirect, discredit, neutralize or otherwise eliminate" the activities of these
movements and especially their leaders.[5][6] Under Hoover, the agent in charge of
COINTELPRO was William C. Sullivan.[7] Attorney General Robert F. Kennedy personally
authorized some of these programs.[8] Although Kennedy only gave written approval for
limited wiretapping of King's phones "on a trial basis, for a month or so",[9] Hoover extended
the clearance so his men were "unshackled" to look for evidence in any areas of King's life they
deemed worthy.[10]
Obstruction of Justice is defined as this as it relates to me and this dire situation:

(1) Whoever kills or attempts to kill another person with intent to retaliate against any person
for
(A) the attendance of a witness or party at an official proceeding, or any testimony given or
any record, document, or other object produced by a witness in an official proceeding; or
(B) providing to a law enforcement officer any information relating to the commission or
possible commission of a Federal offense or a violation of conditions of probation, supervised
release, parole, or release pending judicial proceedings.
In the article by By Rahul D. Manchanda, Esq. Dated Aug 22, 2016, The
Surreptitious Reincarnation of COINTELPRO with the COPS Gang-Stalking
Program
linked here:
http://moderndiplomacy.eu/index.phpoption=com_k2&view=item&id=1686:the-
surreptitious-reincarnation-of-cointelpro-with-the-cops-gang-stalking-
program&Itemid=488
Mr. Manchanda writes,
In 1975 Senator Frank Church convened a joint senatorial/congressional

inquiry into the egregious human rights and civil liberties violations of the
Central Intelligence Agency (CIA), National Security Agency (NSA), as well
as the Federal Bureau of Investigation (FBI) against people both foreign and
domestic. Such blatant transgressions included the neutralization and
elimination of political dissidents, enemies of the state, real or imagined
threats to National Security, and anyone else on the proverbial shit list of the
Military Industrial Complex (MIC).
The Church Committee was the United States Senate Select Committee to Study
Governmental Operations with Respect to Intelligence Activities, a U.S. Senate
committee chaired by Senator Frank Church (D ID) in 1975. A precursor to the U.S.
Senate Select Committee on Intelligence, the committee investigated intelligence
gathering for illegality by the aforementioned agencies after certain activities had been
revealed by the Watergate affair.
Some famous examples which have since emerged include: (1) the FBI sending letters
to Martin Luther King Jr encouraging him to kill himself or else they would tell the world
about his sexual proclivities; (2) the planned or successful assassinations of foreign
leaders such as Fidel Castro, Patrice Lumumba, and countless other South American,
Middle Eastern or Asian leaders; (3) the wholesale undermining of entire foreign
economies if they democratically elected someone at odds with the elite power structure
deep state of the United States such as what occurred against Salvatore Allende of
Guatemala; (4) the possible assassination of John F Kennedy; (5) revelations of
Christopher Pyle in January 1970 of the U.S. Army's spying on the civilian population;
(6) the December 22, 1974 New York Times article by Seymour Hersh detailing
operations engaged in by the CIA over the years that had been dubbed the "family
jewels, involving covert action programs involving assassination attempts against
foreign leaders and covert attempts to subvert foreign governments were reported for
the first time; (7) efforts by intelligence agencies to collect information on the political
activities of US citizens; and (8) countless other examples, both overseas and
domestically.
The end result of the Church Committee Hearings was the outright banning on CIA
assassinations as well as the FBI/DOJ COINTELPRO gang-stalking programs. In 1975
and 1976, the Church Committee published fourteen reports on various U.S. intelligence
agencies' formation, operations, and the alleged abuses of law and of power that they
had committed, with recommendations for reform, some of which were later put in
place.
According to attorney Brian Glick in his book War at Home, the FBI used four
main methods during COINTELPRO:
(1) Infiltration: Agents and informers did not merely spy on political activists. Their
main purpose was to discredit and disrupt. Their very presence served to undermine
trust and scare off potential supporters. The FBI and police exploited this fear to smear
genuine activists as agents;
(2) Psychological warfare: The FBI and police used myriad "dirty tricks" to
undermine progressive movements. They planted false media stories and published
bogus leaflets and other publications in the name of targeted groups. They forged
correspondence, sent anonymous letters, and made anonymous telephone calls. They
spread misinformation about meetings and events, set up pseudo movement groups run
by government agents, and manipulated or strong armed parents, employers, landlords,
school officials and others to cause trouble for activists. They used bad jacketing to
create suspicion about targeted activists, sometimes with lethal consequences;
(3) Harassment via the legal system: The FBI and police abused the legal system to
harass dissidents and make them appear to be criminals. Officers of the law gave
perjured testimony and presented fabricated evidence as a pretext for false arrests and
wrongful imprisonment. They discriminatorily enforced tax laws and other government
regulations and used conspicuous surveillance, "investigative" interviews, and grand
jury subpoenas in an effort to intimidate activists and silence their supporters;
(4) Illegal force: The FBI conspired with local police departments to threaten
dissidents; to conduct illegal break ins in order to search dissident homes; and to
commit vandalism, assaults, beatings and assassinations. The object was to frighten or
eliminate dissidents and disrupt their movements.
Unfortunately I cannot leave my home with being stalked, harassed and threatened by
neighbors, passerby's, etc., On a daily basis I have someone, or groups of people entering my
home, vandalizing, stealing, and poisoning my food. To make matters worse, this protocol
follows me in federal, state, and local courthouses. Every electronic device that I have and use
is compromised and hacked in some fashion. Every online account is the same, and every
financial account, including checking accounts, vendor accounts, utilities, etc., contains some
form of fraud and theft by deception costing me money.
Well, the following links are my supporting evidence, and NOW I WISH YOU AND YOUR
FAMILY A VERY HAPPY AND MERRY CHRISTMAS. DON'T EVER TAKE YOUR FREEDOM FOR
GRANTED, SIR! I WISH I HAD THE FREEDOM YOU AND YOUR FAMILY ENJOYS.
STAN J. CATERBONE and CONFLICTS WITH THE TRUMP ADMINISTRATION -

Monday November 14, 2016 -
https://www.scribd.com/document/331068312/Stan-J-Caterbone-and-
Conflicts-With-the-Trump-Administration-Monday-November-14-2016
FALSE IMPRISONMENT AND ILLEGAL INTERROGATIONS by U.S. Intelligence
Agencies November 12, 2016 -
https://www.scribd.com/document/330869219/False-Imprisonments-and-
Illegal-Interrogations-by-U-S-Intelligence-Agencies-November-12-2016
Stan J. Caterbone LOCAL, STATE, and FEDERAL COURT DOCKET SHEETS as of
November 12, 2016 - https://www.scribd.com/document/330921500/Stan-J-
Caterbone-Local-State-And-Federal-Court-811-Pages-Bookmarks-Docket-
Sheets-as-of-November-12-2016
FEDS PROBE FULTON BANK and 3 other SUBSIDIARY BANKS of FULTON
FINANCIAL with STAN J. CATERBONE CIVIL ACTIONS and Mind Control
Research of Monday November 7, 2016 -
https://www.scribd.com/document/330528930/Feds-Probe-Fulton-Bank-
and-3-Other-Subsidiary-Banks-of-Fulton-Financial-With-Stan-J-Caterbone-
Civil-Actions-and-Mind-Control-Research-of-Monday-Novem
U.S. SUPREME COURT DOCKET, U.S. SUPREME COURT PEITIION, AND Letter
REQUEST FOR COMMUTATION of the Sentence of Lisa Michell Lambert to
President Obama, November 15, 2016 -
https://www.scribd.com/document/331393349/Supreme-Court-of-the-
United-States-Case-No-16-8822-DOCKET-and-COMMUTATION-LETTER-to-
OBAMA-Re-CATERBONE-v-Allison-Hallet-Re-Lisa-Lambert-Habeus-Nove
Stan J. Caterbone United Nations Human Rights Council of Geneva Switzerland
Complaint and Exhibit re U.S. Sponsored Mind Control, Oct 4, 2009.pdf
https://www.scribd.com/document/291083335/Stan-J-Caterbone-United-
Nations-Human-Rights-Council-of-Geneva-Switzerland-Complaint-and-Exhibit-
re-U-S-Sponsored-Mind-Control-October-4-2009-pdf
CATERBONE v. Unted States of America, et.al., Case No. 16-cv-0414 in the
United States Disctrict Court for Eastern Pennsylvania
https://www.scribd.com/document/318862497/CATERBONE-v-the-United-
States-of-America-Et-al-COMPLAINT-July-20-2016-Ver-2-0-Full
Respectfully,
___________/S/____________

1250 Fremont Street
Lancaster, PA 17603
717-669-2163
Notice and Disclaimer: Stan J. Caterbone and the Advanced Media Group have been slandered, defamed,
and publicly discredited since 1987 due to going public (Whistle Blower) with allegations of misconduct
and fraud within International Signal & Control, Plc. of Lancaster, Pa. (ISC pleaded guilty to selling arms to
Iraq via South Africa and a $1 Billion Fraud in 1992). Unfortunately we are forced to defend our reputation
and the truth without the aid of law enforcement and the media, which would normally prosecute and
expose public corruption. We utilize our communications to thwart further libelous and malicious attacks
on our person, our property, and our business. We continue our fight for justice through the Courts, and
some communications are a means of protecting our rights to continue our pursuit of justice. Advanced
Media Group is also a member of the media. Reply if you wish to be removed from our Contact List. How
long can Lancaster County and Lancaster City hide me and Continue to Cover-Up my Whistle Blowing of the
ISC Scandel (And the Torture from U.S. Sponsored Mind Control)?
PROOF
IN SUPPORT OF QUASHING THEOF SERVICE
CHARGES IN MONTGOMERY COURT CASE NO. CP-46-CR-0006239-2015
I hereby certify that on or about December 23, 2016 SERVICE VIA ELECTRONIC
MAIL WAS SENT TO THE FOLLOWING:
Lock, Joshua D.
Phone No: (717) 234-4161
Served: Kevin R. Steele

Service Method: Email
Email: ksteele@montcopa.org
Service Date: July 13, 2016
Address:
Phone: 610-278-3098
Representing: Appellee Commonwealth of Pennsylvania
Served: Robert Martin Falin

Service Method: Email
Email: rfalin@montcopa.org
Service Date: July 13, 2016
Address:
Phone: 610-278-3102
Served: Robert Martin Falin

Service Method: eService
Email: rfalin@montcopa.org
Service Date:July 13, 2016
Address: Montgomery County Courthouse
P.O. Box 311
Phone: 610-278-3104
DATE: DECEMBER 23, 2016
____________/S/____________

1250 Fremont Street
Lancaster, PA 17603
717-528-2200
4:36 P.M.

Page 1 of 3
December 23, 2016
CAPTION
v.
Appellant
CASE INFORMATION
Case Status: Decided/Active

Case Processing Status: December 22, 2016 Awaiting Remittal
Journal Number:

SCHEDULED EVENT
Next Event Type: Record Remitted Next Event Due Date: January 23, 2017
COUNSEL INFORMATION

Pro Se: No
IFP Status: No
Phone No: (717) 234-4161 Fax No:

Pro Se: Yes
IFP Status:
Pro Se: Stanley J. Caterbone
Address: 1250 Fremont St
Lancaster, PA 17603
Neither the Appellate Courts nor the Administrative Office of Pennsylvania Courts assumes any liability
4:36 P.M.

Page 2 of 3
December 23, 2016
COUNSEL INFORMATION

Pro Se: No
IFP Status:
PO Box 311
Phone No: (610) 278-3098 Fax No:

Phone No: (610) 278-3102 Fax No: (610) 278-3841
FEE INFORMATION


OTN(s): T6863802 T7090322
Judge
BRIEFING SCHEDULE
None None
DOCKET ENTRY


November 30, 2016 Application for Leave to File Amicus Brief

4:36 P.M.

Page 3 of 3
December 23, 2016
DOCKET ENTRY

Eldridge, Lisa A.
Document Name: Per TC Judge's chambers - Extension of time granted through 1/6/17 to file 1925(b) statement

December 21, 2016 Order

Per Curiam
Comment: Upon consideration of the Petitioner's "Request The Courtesy Of The
Court To Appear Pro Se And To File An Amicus Curaie [sic] Brief In Support
Of The Following," filed by "Stan J. Caterbone," the petitioner shall not be
permitted to present oral argument.
December 22, 2016 Dismissed Sua Sponte

Per Curiam
Comment: This appeal is hereby dismissed as duplicative of the appeal docketed at
No. 3575 EDA 2016.
DISPOSITION INFORMATION
Final Disposition: Yes

Related Journal No: Judgment Date:
Category: Disposed Before Decision Disposition Author: Per Curiam
Disposition: Dismissed Sua Sponte Disposition Date: December 22, 2016
Disposition Comment: This appeal is hereby dismissed as duplicative of the appeal docketed at
No. 3575 EDA 2016.
Dispositional Filing: Filing Author:
Filed Date:
4:37 P.M.

Page 1 of 2
December 23, 2016
CAPTION
v.
Appellant
CASE INFORMATION
Case Status: Active

Case Processing Status: November 30, 2016 Awaiting Original Record
Journal Number:

SCHEDULED EVENT
COUNSEL INFORMATION

Pro Se: No
IFP Status: No
Phone No: (717) 234-4161 Fax No:

Pro Se: No
IFP Status:
PO Box 311
Phone No: (610) 278-3098 Fax No:

Phone No: (610) 278-3102 Fax No: (610) 278-3841
4:37 P.M.

Page 2 of 2
December 23, 2016
FEE INFORMATION


OTN(s): T6863802 T7090322
Judge
BRIEFING SCHEDULE
None None
DOCKET ENTRY



Eldridge, Lisa A.
Document Name: Per TC Judge's chambers - Extension granted throught 1/6/17 to file 1925(b) statement.


Stan J. Caterbone LETTER To Matthew H. Haverstick Re MARTIN v. Reese CI-17-04626 March 5, 2017

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Stan J. Caterbone LETTER To Matthew H. Haverstick Re MARTIN v. Reese CI-17-04626 March 5, 2017

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Stan J.

Matthew H. Haverstick (No. 85072)

Re: CSCOTT MARTIN (et al.)

Case Number CI-17-01626

Letter to Haverstick, et.al., Page 1 of 190 Sunday March 5, 2017

ACTIVE COURT CASES

Letter to Haverstick, et.al., Page 2 of 190 Sunday March 5, 2017

Letter to Haverstick, et.al., Page 3 of 190 Sunday March 5, 2017

Letter to Haverstick, et.al., Page 4 of 190 Sunday March 5, 2017

SCOTT MARTIN (et al.)

PROTHONOTARY DOCKET ENTRIES

FORWARDED TO PRESIDENT JUDGE REINAKER 3-3-17.

03/03/2017 Brief in Support of Motion to Expedite FILED BY Matthew H Haverstick ESQ.

March 04, 2017

Letter to Haverstick, et.al., Page 5 of 190

Letter to Haverstick, et.al., Page 6 of 190 Sunday March 5, 2017

IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA

SCOTT MARTIN, in his official capacity as No. CI-17-_________________________

IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO

Lancaster Bar Association

Letter to Haverstick, et.al., Page 7 of 190 Sunday March 5, 2017

IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY, PENNSYLVANIA

SCOTT MARTIN, in his official capacity as No. CI-17-____________________

COMPLAINT IN QUO WARRANTO

PARTIES AND VENUE

1. Plaintiff Scott Martin is an elected Senator of the Pennsylvania State Senate,

a plaintiff in his official capacity as Senator.

Letter to Haverstick, et.al., Page 8 of 190 Sunday March 5, 2017

a plaintiff in his official capacity as Senator.

3. Defendant Mark S. Reese is a resident of Lancaster County.

4. Venue exists in this Court under Pennsylvania Rules of Civil Procedure

1112(c)(2) because Defendant Reese purports to be an officer of Lancaster County.

in 2011 and re-elected in 2015.

6. In July 2016, the Lancaster County Commissioners received an allegation that

Defendant Reese had sexually harassed a deputy.

7. On or about July 26, 2016, Defendant Reese purported to take a leave of

absence from his duties as Sheriff.

8. In connection with his leave, Defendant Reese relinquished his County-issued

weapon and all County-owned equipment in his possession.

9. The County Commissioners suspended Defendant Reeses unlimited access to

a. Serving most original process in civil matters and obtain personal

b. Providing Security/Protection to the Court of Common Pleas and the

c. Conveying/transporting prisoners to and from court and state prisons;

e. Assisting all other law-enforcement agencies as they may be needed;

f. Serving Protection from Abuse Orders;

g. Serving and making arrests for outstanding bench warrants;

h. Conducting investigations into and issue concealed weapons permits and

i. Conducting judicial sales of real and personal property, and determining

or any other statutory duty, of the Sheriff of Lancaster County.

to work at the Sheriffs physical office in Lancaster.

14. Defendant Reese continues to collect a salary as Sheriff of Lancaster County.

among other things, continuing to collect a salary as Sheriff.

Sheriff of Lancaster County as a matter of fact.

Sheriff of Lancaster County as a matter of law.

Section 412 of The County Code, 16 P.S. 412.

statutory rights to give or withhold consent on such nominations.

or withhold consent on such a nominee.

COUNT I: QUO WARRANTO

22. Plaintiffs incorporate by reference the allegations in the foregoing paragraphs of

this Complaint as if set forth at length herein.

office. Spykerman v. Levy, 421 A.2d 641, 648 (Pa. 1980).

powers of the office at issue. Id.

has resigned the public office as a matter of fact.