STAN J. CATERBONE AND THE LISA MICHELLE LAMBERT CASE January 22, 2017 PDF

Laurie is never far from their minds - LancasterOnline: News
1 of 5
January January
Sunday
22, 201722, 2017
http://lancasteronline.com/news/laurie-is-never-far-from-their-minds/artic...
Page 1 of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
Laurie is never far from their minds

CINDY STAUFFER Staff Writer | Posted: Monday, December 19, 2011 9:17 pm
Lisa Michelle Lambert is 39 years old and lives inside a Massachusetts prison. The
convicted killer earned a college degree behind bars, where she has spent almost
all of her adult life, save for a 10-month period of freedom.
Tabitha Buck is 37 and housed at a state prison for women in Muncy in
northeastern Pennsylvania, where she has tutored other inmates as she serves out a
life sentence that began before she graduated from high school.
Lawrence Yunkin is 40. Now freed from prison and living in the area, he has
become a good bowler and has 302 friends on Facebook.
But Laurie Show is forever 16, a pretty, dark-haired teen who was looking forward
to getting her driver's license and hoped to some day be a nurse or a hairdresser.
Laurie is never far from their

minds
Exactly 20 years ago this morning, Yunkin drove Lambert and Buck to Laurie's
mom's East Lampeter Township condominium.
Decorations adorn Laurie Show's gravesite

Monday evening in the Bridgeville
Evangelical Congregational Church
cemetery in East Earl Township. (Marty
Heisey / Staff)
The two young women burst inside and attacked Laurie. Lambert slit the young
woman's throat and killed her in a fit of jealous rage, while Buck sat on Laurie's
legs.
The case is perhaps the county's best-known murder case.
It catapulted onto the national stage in the late 1990s, when Lambert appealed her life sentence. She alleged prosecutors
tampered with evidence to frame her for the murder so they could silence her about an alleged gang rape by police, a charge
later rejected by the court.
A federal judge agreed, briefly freeing Lambert from prison in a move that stunned many here. She then had a series of
well-publicized appeals - one which reversed the federal judge - that went all the way to the U.S. Supreme Court.
The highest court refused to hear Lambert's case in 2005. In recent years, the national spotlight has turned to Amanda Knox,
Casey Anthony and others involved in lurid crimes.
Time, and life, has moved on.
The district attorney at the time became a county judge.
The county judge who heard her case and declared her guilty - twice - became a federal judge who works in the same
courthouse as the federal judge who freed Lambert after declaring her "actually innocent."
The two see each other regularly but never speak of the case.
The Philadelphia attorney who handled Lambert's defense appeal moved to Vermont, where she now works on the other side of
the lawyering aisle, prosecuting sex crimes.
Life marched on for Show's parents, John Show and Hazel Whitehead, who lost their only daughter on Dec. 20, 1991.
But much remains painfully unchanged.
Divorced from John Show at the time of the murder, Whitehead , now 60, remarried 10 years ago but is separated. She works at
a local outlet store.
She has stayed in the same condominium. Despite the murder, it is the spot of her happiest memories with her daughter, she said,
and she would not consider leaving it.
Whitehead feels her daughter's presence there, she said, when her television set and vacuum cleaner switch on by themselves or
7/24/2015 5:23 AM
2 of 5
January January
Sunday
22, 201722, 2017
Page 2 of 2301
1299
a light flickers.
"It makes you more comfortable to think she's nearby," she said. "I know, technically, she's in heaven, but sometimes I think she's
saying, 'Hey mom, I'm still here. I'm watching out for you.' "
Show, 60, retired from his job working for a farm machinery manufacturer a few years ago, but then got called back to work.
He enjoys his godchildren but thinks about the grandchildren he never will have. He speaks to others who have lost loved ones,
and hosts an annual candlelight service for them.
To most people, he will always be simply Laurie Show's father.
"It makes me feel good," he said, his voice breaking. "I'm proud that they remember her."
A horrific day
Hazel Whitehead left her home 20 years ago today for what she thought was an appointment with her daughter's guidance
counselor at school.
She did not know the call was a ruse to get her out of the house.
1991 had brought a difficult fall for Whitehead and her daughter. Yunkin had briefly dated Laurie, during a time he had broken
up with Lambert.
Later, Lambert and Yunkin got back together, and Lambert allegedly was furious that Yunkin had dated the younger girl.
Lambert called Laurie's home, harassed her and made plans to cut off her hair, Whitehead and other witnesses said.
Things were about to come to a terrible climax.
After Whitehead left her home, Yunkin dropped off Lambert and Buck nearby, according to trial testimony. Buck knocked on the
door, the two forced their way in and Laurie was killed in a terrible struggle.
Buck said Lambert sliced Laurie's throat. Lambert said Buck and Yunkin did the killing.
A 1992 trial followed, and Lambert chose to have her case heard solely by a judge. Lancaster County Judge Lawrence Stengel
got the case.
"I remember the high level of emotion," said Stengel, now a U.S. District Court judge who has offices in Philadelphia and
Reading. "It was a horrific story that was difficult to believe."
At the end of the trial, Stengel found Lambert guilty and sentenced her to life in prison.
In separate proceedings, Buck was found guilty and also sentenced to life in prison. Yunkin pleaded guilty and was sentenced to
10 to 20 years for his part in the murder - driving the two young women back and forth and helping to get rid of evidence.
Lambert doggedly appealed her case. In 1997, after a three-week federal hearing, U.S. District Judge Stewart Dalzell freed her,
saying she was "actually innocent" and noting there was "wholesale prosecutorial misconduct" in the handling of her case.
Joseph Madenspacher was the district attorney, the county's top prosecutor at the time. On that day, he asked Dalzell if Lambert
could be reimprisoned or placed on bail during her pending appeal.
Newspaper accounts from the time noted that Dalzell chuckled and peered over his bifocals at Madenspacher, saying, "Motion
denied."
It was a rough moment but Madenspacher, now a Lancaster County judge, said he was "virtually 100 percent certain" at the time
that the full court would reverse Dalzell's decision.
It did.
Almost 10 months later, Lambert was returned to prison. She then ended up in Stengel's courtroom again as he presided over a
hearing in her case that drew national attention with its wide-ranging and often bizarre accusations of prosecutorial misconduct.
Lambert's Philadelphia attorneys, Christina Rainville and Peter Greenberg, accused prosecutors of moving Show's body to shoot
7/24/2015 5:23 AM
3 of 5
January January
Sunday
22, 201722, 2017
Page 3 of 2301
1299
bogus crime-scene photos, switching pieces of evidence, tampering with crime-scene videotapes and committing dozens of
deceitful acts.
All of the prosecutors were later cleared following a federal probe of the case. Dalzell, whose chambers are in the same federal
building as Stengel's, declined to comment when contacted about the case.
Christy Fawcett was the prosecutor in the case before Stengel. Then with the state attorney general's office, she's now a U.S.
attorney in Harrisburg.
The Lambert case consumed three years of her life, she said. The elements of it - the teenage love triangle, the "lurid allegations"
of prosecutorial misconduct - made it a riveting case.
Fawcett said the case came along just as court cases began to capture the entire country's attention on television.
The national media descended on Lancaster for the hearing before Stengel. ABC later featured it on "20/20." The Los Angeles
Times wrote about it. The New York Times editorialized on it. There was a book and television movies.
The case also helped to spawn state anti-stalking laws in Pennsylvania.
"It was totally engrossing," Fawcett said, noting that she still thinks about it.
She believes the case showed how important is the responsibility of a lawyer, and the danger of becoming overzealous in
representing a client.
Though her job and her life has changed in the past 20 years, her opinion of the case has not, she said.
Lambert was and is guilty, she said.
Still innocent
Rainville disagrees.
Now 48 and living in Bennington County in southern Vermont, Rainville said the Lambert case still deeply disturbs her, as does
the fact that Lambert remains in prison.
Rainville and Greenberg retired to Vermont in 2005, the same year that the U.S. Supreme Court declined to hear Lambert's case.
She volunteered for a while at her children's elementary school, volunteered at a public defender's office and then, bored, decided
to go back to work. Greenberg remains retired, she said.
Rainville is the chief deputy state's attorney in Bennington County, a role similar to that of an assistant district attorney in
Pennsylvania. She feels comfortable as a prosecutor in Vermont, where she said the procedural rules are different from
Pennsylvania's.
She specializes in the prosecution of child sex offenders, work she finds satisfying.
"Working with children and giving them a voice, it's very rewarding work and I totally love it," she said.
Though her professional contact with Lambert ended, her personal contact did not. Rainville said she remains in touch with
Lambert, and communicated with her as recently as a few weeks ago.
While in prison, Lambert earned a degree from Boston University, graduating with honors, Rainville said. She believed Lambert's
major was criminal justice.
"She's just an exemplary person," Rainville said. "And she's lived an exemplary life in prison."
Lambert's time in prison, however, has not gone smoothly.
She has bounced around, spending time in prisons in Pennsylvania, Delaware, New Jersey and Massachusetts.
In 2007, Pennsylvania paid her $35,000 to settle her allegations of sexual abuse by prison guards. One of those guards was fired
and convicted of indecently assaulting her.
In addition to earning a degree behind bars, Lambert became a mother.
7/24/2015 5:23 AM
4 of 5
January January
Sunday
22, 201722, 2017
Page 4 of 2301
1299
She was pregnant with Yunkin's baby at the time of Laurie Show's murder. She gave birth to a daughter a few months later.
Her parents, Leonard and Judy, obtained custody of the child. The couple divorced in 2009, local court records show.
Now a 19-year-old, Lambert's daughter is the same age her mother was at the time of Laurie Show's death.
It is not known where she lives. Rainville said she did not want to discuss the personal details of Lambert's life.
Rainville said she has never wavered in her belief that Lambert is innocent.
"Not one bit," she said. "I think all the more she didn't do what she was convicted of."
"For me, professionally, it remains the most disturbing outcome of any case," she said. "It's upsetting to think of her being in jail
that long.
"That's a life lost."
The life forever lost
For Hazel Whitehead and John Show, the life that has been lost is that of their only child.
There has been no graduation from high school or college to celebrate. No one to walk down the aisle. No grandchildren to hold.
Though 20 years have passed, for them, the loss of their daughter seems like it happened just yesterday.
Whitehead said she has worked hard not to become angry. She gets up and faces every day and tries to make it the best she can.
"I just look back on the life that I had with Laurie, and the good times, and try to stay focused on that," she said.
She keeps things to herself, she added. Other people's lives have moved on, and she does not want to bore them with talk of her
16-year-old daughter who is never far from her thoughts. Her daughter's photos remain in her house. Her memories remain vivid.
"I don't see me, in my lifetime, at a point where she's not in my present thoughts," she said.
Show said he is glad he is still working. It keeps him occupied and busy. He's grateful for his godchildren and tries to treat them
like his own grandchildren.
An only child, he is the last of his immediate family. Both of his parents have died since Laurie's death.
Today, he'll carry a single rose to the cemetery where his daughter is buried.
"It hurts," he said. "I see people who have children, family. Hazel and I don't have any grandchildren. It's tough and it hurts."
Neither he nor Whitehead have run into Yunkin since he was released from prison in 2003.
Yunkin's probation ends today, on the 20th anniversary of Laurie's killing.
Since his release, newspaper records show he was a regular bowler at Garden Spot bowling alley in Strasburg, the same bowling
alley where he bowled with Lambert and Buck before the killing and where he was arrested afterward.
Yunkin returned to Garden Spot about two years after he left prison and continued bowling there until a fire destroyed the alley
this summer.
He has a Facebook page, which shows a tattoo of a purple ribbon with the words "Live Strong" and "Just Do It."
He could not be reached for comment.
Whitehead said she receives an occasional restitution payment from Yunkin. He was ordered to pay almost $12,000, and still
owes more than $7,000, court records show.
It's her reminder that he's out there, and that he has to think of her daughter from time to time, she said.
"The money doesn't matter but he should be made accountable for what he helped to do," she said.
Whitehead and Show also have not heard much about Buck in recent years.
Her family left the area after her arrest and are believed to live in Oregon, thousands of miles away from where she is
7/24/2015 5:23 AM
5 of 5
January January
Sunday
22, 201722, 2017
Page 5 of 2301
1299
imprisoned.
In the past two decades, Whitehead said she has had time to come to a certain sort of peace about what happened.
"Life goes on," she said. "You have to do your best to continue to do what you can to make your life better and to help others.
"I truly believe God has a plan for me. I don't know if I've totally figured out what it is, but I'll keep working at it."
cstauffer@lnpnews.com
7/24/2015 5:23 AM
January January
Sunday
22, 201722, 2017
Page 6 of 2301
1299
Advanced Media Group

220 Stone Hill Road
Conestoga, PA 17516
www.amgglobalentertainmentgroup.com
infor@amgglobalentertainmentgroup.com
717.731.8184 Phone
717.427-1621 Fax
HAD LANCASTER COUNTY (Pennsylvania) LOST ITS

SOVEREIGNTY BEFORE IT LOST ITS SOUL?1
Authored in May of 1998
Each time a man stands up for an ideal, or acts to

improve the lot of others, or strikes out against
injustice, he sends forth a tiny ripple of hope. And
crossing each other from a million different centers
of energy and daring, those ripples build a current
which can sweep down the mightiest walls of
oppression.. by Robert F. Kennedy
In 1987 This Plaintiff Had Unjustly Lost His Freedoms, His Rights, And His
Pursuit Of Life, Liberty And Justice.
The following report (most identities purposely omitted from this

version) is an amazingly true and factual account of an extraordinarily bizarre
tragedy that has turned one mans life into an eleven (11)2 year free fall into
Dantes Hell.
On the surface, this is a story of a victim struggling to seek the truth, but in
reality, the evidence will conclude that this is a victim, literally, held hostage by
virtue of his truth. Later, the preponderance of evidence that the victim has
1
In April of 1997, Federal Court Judge Stuart Dalzall said Lancaster County had
lost its soul in the worst case of prosecutorial misconduct ever found in the
English speaking language regarding the Lisa Michelle Lambert hebeas corpus
hearing in the notorious Laurie Show murder case.
ADVANCED MEDIA GROUP
Page 1 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 7 of 2301
1299
amassed and his obsession for meticulously documenting his ordeal might seem
eccentric, yet his demonstrated ability to react to events before they unfold
appears mystical. And this was his manner in which he tactfully defended and
protected his life. It is these actions that have painted the landscape with a dire
vengeance for his ruin. His actions will ultimately serve to protect, preserve, and
foster the truth of his story, incriminating the culpability of his many perpetrators,
while at the same time being twisted and tainted in a relentless manner to attack
his credibility.
This is a story of a human being endearing for his rights, living in fear of
his life, and the remedial actions required for the truth to set him free. A victim
forever believing in his accomplishments and his visions, yet forced to adhere to
a life of their diversions. Fatefully, ten years after being taken as a political
hostage, with the aid of numerous arrests and false imprisonments conveniently
falling short convictions , a Federal Judge, Judge Stuart Dalzall, of the Eastern
District Court of Pennsylvania, opened a Pandoras Box into the true colors of
the inner workings and politics of ultra conservative Lancaster County,
Pennsylvania. A supposedly Gods country. His findings reeled a dramatic and
emotional response from the Lancaster County community that was akin to the
assassination of JFK . A community where obstructions of justice strikes a
startling and stark contrast to the image it so desperately embraces. A
community proud of its tough on crime judges, a community of plain folks and
Amish, and a community settled in a beautiful landscape abundant in an
agricultural bounty. This is not a community of compromising integrity. Or so it
has been perceived.
Judge Dalzalls extremely controversial findings were responsible for

Pennsylvanias own crafting of the Laurie Bill, the retaliation by the
Commonwealth of Pennsylvania intended to curb the Federal Courts interference
within the respective states own jurisdictions and proceedings. Or was it a
political maneuver to close the lid on Pandoras Box? The Pennsylvania
Attorney General and the Lancaster County District Attorney have both thrown all
Page 2 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 8 of 2301
1299
their might and all their muscle at turning the tides of Judge Dalzalls findings.
This story and this victims rights have been violated and abused by some of the
very same principals that were responsible for Judge Dalzalls unsettling
revelations. Lancaster County prosecutors were found to have engaged in one of
the grossest acts of prosecutorial misconduct found in the English speaking
language, which allegedly occurred in this now famous Lisa Michelle Lambert
case, a murder trial which began in the summer of 1992. Subsequently, it is now
in the midst of a treacherous appeal process convened by Judge Dalzall. And if
so by fate, in Philadelphia, Pennsylvania, the home of the Freedom Fighters.
It is this public disclosure, that casts a new light and sudden hope for
freedom into this victims unbelievable and horrid story, that begun just four
years prior to the murder of Laurie Show. It is the decisive similarities of how both
victims were subjected to a very calculated and politically motivated attempts to
frame and fabricate circumstances to obtain the results that justified the
means for illicit self-serving interests. This very same conduct, committed by
public servants, elected and enlisted to enforce the law, to which Judge Dalzell
found so appalling. Conduct, which violated the very same rights their respective
offices are commissioned to protect. Conduct which strikes the meaning of We
The People from our nations very own Constitution.
Fortunately, this victims story is laced with a thread of faith, a faith in

God. And because of his faith, this victim will forever regard Lisa Michelle
Lambert3 and Laurie Show as his little Angels of Justice, a Godsend. An
answer to his many prayers, that for the first time in ten years provided a small
glimmer of hope, and a few moments of solitude that have materially justified his
own tragic experience. The realization that the truth is that much more believable
because of the trials and tribulations of Lisa Michelle Lambert. Unfortunately, this
3 The author admitted in an affidavit in 1998 that he did not know the criminal
culpability of Lisa Michelle Lambert, and further argues that it was because of the
prosecutorial misconduct and the erroneous handling of the crime scene that the
truth evaded both the prosecution and the defense as to who actually killed
Laurie Show.
Page 3 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 9 of 2301
1299
revelation came at the unfortunate and untimely death of Laurie. However, it just
may be Gods intentions of a Higher Purpose.
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 obstruct this victims rights for
justice. Its 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 Boys club of Lancaster County. A process obsessed with
keeping its disclosure from escaping beyond the confines of Pandoras Box. Its
a tenure of power that evolved from the days of this countrys 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!
AT ISSUE
The central issue in this story, is a cover up, a cover up of mass
proportions, and of perplexing design, with national consequences. The fact of
the matter is that this cover up has had ramifications throughout this world,
specifically the Middle East The cover up would be emphatically unbelievable
without the wealth of evidence, especially the recorded conversations with
Pennsylvania officials. A cover up that permeates from what will later emerge as
the 4th largest financial fraud (Billion Dollars) in the history of the United States
coupled with the covert sales of arms to Iraq. And five years after this cover up
began, these same munitions were used against our own troops in the Persian
Gulf War. And of course, there are admitted ties to the Central Intelligence
Agency (CIA) and the National Security Agency (NSA).. And this cover up and
story, which began in June of 1987, in Lancaster County, preceded criminal
indictments by the United States Attorney General, the Federal Bureau of
Page 4 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 10 of 2301
1299
Investigation (FBI), the Internal Revenue Service (IRS), the Department of

Justice and Commerce, and more. A vast array of criminal activities conspired
from the ultra conservative Lancaster County, where God is supposedly
supreme, and its hard line approach to crime is said to be preeminent. In June of
1987, Lancaster County was immersed in a dynamic twist of fate, with a host of
players which may never be fully identified.
The irony of this story is how Lancaster County manages the disclosure of
the very same criminal activities that this story proves that it condoned, prior to
the intervention of federal authorities. It most dramatically will prove the nature of
its integrity, or lack thereof. International Signal & Control, (ISC) is the
controversial player in this web of conspiracy. In 1987, the third largest employer
in Lancaster County, a non-discrete defense contractor. In all due respect to our
beloved country, this report is in no way challenging the policies or the activities
of the Department of Defense, or the vast agencies of the Intelligence
Community, especially the CIA or the NSA (National Security Advisory). with
regards to ISCs foreign dealings. Trying to protect the world of malicious and evil
empires is a process which never ends, and whos players are constantly
changing. And our respective intelligence agencies are continually challenged
with the task of trying to make a difference, in accordance with protecting our
national security. Unfortunately, given the nature of their discrete activities, and
given the CIAs history of avoiding congressional approval in certain situations,
our current laws are void of effectively dealing with the peripheral catastrophes of
such activities that inherently transpire. The CIA remains immune, while
everyone outside suffers the consequences.
The fact that the CIA, or anyone of the other intelligence community, may
have been involved, does not grant a blanket of immunity over activities which
were not material to protecting our national security. If a company provides a
service to anyone in the intelligence community, our constitution, our laws, and
its respective commercial regulatory authorities, must still have the full sense of
their jurisdiction. The intelligence community may not have the right of
Page 5 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 11 of 2301
1299
intervention into the commercial enterprise, or organization, circumventing the

rights of its employees, shareholders, creditors, and customers. No United States
law or statute suggests that there is any involuntary mandate that requires any of
the preceding to compromise their interests in the respective enterprise for the
sake of national security, or the respective intelligence agency. There must be
considerations paid to all involved for those rights and interests that compromise
such a relationship. Otherwise, the CIA could effectively gain control of any
domestic corporation it so desires, without ever owning one share of its
outstanding stock, simply by enlisting its product or services for the sake of
national security. The CIA requires a formal vehicle to enlist the aid of our
domestic commercial enterprises. ISC is a proven and unfortunate example of
that.
This victim was a shareholder of record of International Signal & Control

(ISC) for the previous four years prior to when this tragic ordeal began. The
victim was to purchase the stock from now Republican Pennsylvania Senator
Gib Armstrong, who was in the brokerage business at the time and selling ISC
stock. The stock was sold over the London Securities Exchange, supposedly for
reasons to suppress information. The victim was interested in the stock because
of his appetite for technology, and was more curious about the business of ISC,
than anything. In fact, the victim had never made any inference to any of the
illicit dealings with Iraq. However, the perpetrators of this story, attempt to hide
behind a vale of national security," in an effort to find legal immunity from all
wrongdoing. In accordance, the record will prove that this is merely a smoke
screen used to intimidate and obstruct the victims access for due process of the
law.
The trials and tribulations of this victim are unprecedented in terms
of emotional and psychological duress, fortunately his indestructible faith in God,
and his enduring belief in himself and the truth, endures his life. There was one
attempt on the his life, days within the public disclosure of the CIAs involvement
with the local Lancaster County defense contractor (ISC), which Ted Kopel
Page 6 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 12 of 2301
1299
reported on ABC News Nightline, on May 23, 1991, 4 years after the initial cover
up began. This story will depict a series of systematic and strategic offensive
attacks upon this victim and his businesses that will result failed business
enterprises, and a Hollywood motion picture, deserted. An impeccable
professional reputation and a flawless credit rating purposely sabotaged.
Financial opportunities, that in 1987, were almost impossible to extrapolate, Vast
financial opportunities and aspirations forever a part of history. This horrendous
crime was perpetrated for the interest of a cover up, further protecting the corrupt
enterprises of Lancaster County's International Signal & Control (ISC). A quest
for justice that polarized every relationship the victim maintained, in Lancaster
County and beyond, including friends and family. This story demonstrates a
methodology of his perpetrators for keeping this victim quarantined from justice
and public disclosure, through a malicious means of credibility proponents, and
horrendously deceptive tactics. Financial motives prominently displayed in the
hands of all of the perpetrators, which absolves the burden for a traditional
conspiracy..
The emotional response to the truth of this story is compelling, to say

the least. Subsequently, the startling keen sense of perception that the victim
had demonstrated, is even more intriguing. It is this extraordinary quality that is
responsible for saving his life, while yet at the same time providing his
perpetrators with an alibi and a vehicle for discrediting his startling allegations
and his story. This story embellishes a dichotomy of perception that had
Hollywood producers from his film project call his work genius, while his
perpetrators from the Lancaster County Community conveniently and maliciously
labeling him as insane and emotionally disturbed."
THE LANDSCAPE
The perplexing question of the victims intelligence, or lack thereof, is
best analyzed as a question of perception. However it terms of the legal
consequences of the activities contained herein, they are of little if any relevancy.
Page 7 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 13 of 2301
1299
The fact of the matter is that the mental deficiencies have very little relevancy to
this story, other than serving as a means to discredit the victim, a vehicle to
facilitate the cover up, and a blanket of immunity for all of the perpetrators.
The heart of this victims legal dogma is best described as follows: If a

person, is perceived to have a mental deficiency; yet whose actions and
decisions are always proven to be instinctually and amazingly prudent, always
abiding within the law, and in the best interest of his affairs, what rights and
protection do the laws afford him from persons abusing that perception, in order
to yield political and financial rewards, as a direct consequence of his demise?
Furthermore, how does the law protect his rights, if any and all malicious acts
against this victim, are constantly and immediately disregarded because he is
perceived to not to be credible? As this story unfolds, these questions will
become even more troubling and appalling. Although the victim could never
describe the pain of his trauma, he would often say that the closest situation that
may compare is that of a woman being continuously raped, night after night,
helplessly praying for relief, struggling to free herself from her captor, all with no
avail. He would call it as being brain f------.
The victim, coming from the lower middle class of Lancaster City, was
only 29 years old when this tragedy began. Coming from a broken home, he was
the third of six boys. While at a very young age, he would help his mother run a
dry cleaning business, in an amazing similarity like Lisa Michelle Lambert, he had
also nursed his mother during bouts of depression. While in high school, he was
nursing his mothers depression, while at same time tending to his older brothers
bouts of schizophrenia. The victim had learned to listen to the obscenities of
mental illness since he was a child. He learned to fill the shoes of his absent
father in helping his mother raise his three younger brothers.. The victim was
often called the little old man because of his extraordinary maturity as a child.
The victim was determined to break the barrier of the Good Ole Boys club or
the power elite, and had always felt a sense of compassion for those less
fortunate, and those neglected by those of material means, the oppressed and
Page 8 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 14 of 2301
1299
impoverished. He had an undivided aspiration to someday make a difference to

those that could not help themselves, especially his older brother. Through his
ingenious, resourceful, and honest business approach, he was relentlessly
growing his business and their respective missions, in constant reminder of his
oppression. His in depth understanding of computer technology and his vision
were his most powerful allies. Always pushing the envelope for advanced
technologies and seeking solutions for the most efficient means of his
operations.. He knew that every break was going to be few and far between, he
dedication himself to his work, and married his business affairs, always
embracing his projects with a passion.
In 1986, after serving on the Board of Directors for the Central

Pennsylvania Chapter of International Association of Financial Planners (IAFP),
the victim had made a large contribution to increasing its membership and its
awareness among local professionals, as its vice president. In an effort to
promote the organization, the victim solicited a nationally recognized and
prominent financial planner from Washington, D.C., to be a headline speaker at a
dinner meeting. Ms. Alexandra Armstrong, one of the most nationally recognized
financial planners, often headlined in Money Magazine, attracted 100 industry
professionals to the Treadway Resort Inn. The attendance was unprecedented
for the local IAFP chapter. The IAFP is the authoring organization for certification
as a financial planner. It was through the direct conversations with Ms. Armstrong
regarding his ideas and her experience, that inspired the victim to pursue his
ambitions of growing his own financial firm, which he began in the following
months.
Disgruntled with the conflicts of interest and the lack of incentive for
various professionals to work together in managing ones wealth, a process
which lacked efficiency, this entrepreneur founded the firm Financial
Management Group, Ltd., or FMG as it was often called. The firm was to
incorporate a one-stop-shopping strategy and incorporate financial services,
legal, accounting, tax preparation, real estate, insurance, mortgage banking, and
Page 9 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 15 of 2301
1299
estate services all in one firm, all residing in one location, all taking advantage of
the synergistic approach toward managing wealth. And to provide the
professionals long term security and equity participation, all participants were
encouraged to purchase stock in the company. This was a new and innovative
approach that attracted a lot of attention from investors and clients, but also
came a lot of nervous twitches from competitors, especially in conservative
Lancaster County.
The victim began recruiting professionals from all of the other firms, with
great success. He had enlisted two partners whom he had worked with at
IDS/American Express, to carry out his mission, which he began after extensive
market studies and his early version of the company, Pro Financial Group, Ltd.,
His two partners had followed the victim to an independent broker dealer in
Atlanta, named Financial Services Corporation, where Ms. Alexandra Armstrong
was associated, and encouraged the victim to visit, during their discussion after
dinner. Within one year, by June of 1987, the firm had invested over $40 million
for respective clients.
The company had developed satellite offices throughout Pennsylvania and

in several other states, through his unique design. This firm was causing the
other financial services companies and the local banks in Lancaster County a run
for their money. The firm had built a new 20,000 square foot office building just a
few miles north of the city. The firm was attracting clients, associates, and
nervous attention from, well just about everybody. Considering the capabilities,
legal, real estate, insurance, financial services, accounting, FMG was making as
many enemies as it was making friends. And the victim always believed in the
premise that its always better to have people talking about you, regardless of the
matter, than to have no one notice you. And they were talking. The victim was
only in his late twenties when he started this organization,. He held several
positions, he was Executive Vice President and Secretary of Financial
Management Group Ltd, and President of FMG, Advisory, Inc., which was one of
the many subsidiaries parent company owned. The victim acted as the architect
Page 10 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 16 of 2301
1299
and legal administrator of the organization, in addition to building his own

financial planning clients. He filed all of the articles of incorporation in the
Commonwealth of Pennsylvania and submitted all of the tedious and rigorous
filings necessary for the Pennsylvania Securities Commission, which were very
demanding considering the victim was selling stock of his company to his
associates and investors. The victim and his associates had also attracted some
very prominent Lancastrianss to invest in his venture, coming from various
professional circles, all infatuated with this extraordinary and intriguing concept of
this young victim. All had seen its potential for success and financial reward.
Many of his friends were involved, and in Lancaster, everyone knows

everybody, so it seams.. And everyone talks, gossip is as common as jogging.
This exaggerated trait of Lancaster County, will later to come back to haunt this
victim, in a way that is most sickening. In a way that will parallel the attitudes
and sentiments in the Lisa Michelle Lambert story.
In 1987, his business affairs were reaching a point of incredible success.

In fact, most of his family and friends, have always questioned the merits of their
legitimacy. He always conducted his affairs with the presumption that time could
not afford the opportunity to complete his agenda, while at the same time
disclosing his business affairs to persons that were not directly involved..
Accomplishing his mission was first and foremost. But in Lancaster County, that
was difficult. Lancastrianss have a notion to fear what they dont know, and will
always believe what they think they know, regardless of its merits. In Lancaster
County new ideas are shunned unless coming from their own, and their own
ideas are often kept close at bay, inhibiting progress and stymieing learning. By
June of 1987, a majority of his business affairs were conducted out of the grasp
of Lancaster County, his unknown activities made others curious, especially in
Lancaster County, where the blessing of the power elite was essential for
success. But, deep down inside, he knew he could never be accepted, because
he did not descend from a family of social grace. This fueled his aspirations for
Page 11 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 17 of 2301
1299
success even further, committed to prove that intelligence was innate and
learned, not a direct correlation to material wealth or social grace.
One of his most cherished testimonials to his concept, his reputation, and
his mission, was provided by an elder attorney, Mr. Kenellm Shirk, a very
respected and prominent older Lancaster attorney, who was part of the status
quo. Mr. Shirk had petitioned the Pennsylvania Bar Association, after meeting
with the victim, to obtain their blessing and their knowledge of any laws which
would forbid his firm to provide a satellite office in the headquarters of Financial
Management Group, Ltd., (FMG) Mr. Shirks firm was to provide a partner, and
estate services to the clients of FMG. The Pennsylvania Bar provided a lengthy
recommendation that did not prohibit a relationship, although cautioned it to
proceed with careful review. The fact that the very young and unknown victim
could attract an elder, conservative Lancaster County attorney to associate with
his firm was an encouraging sign of respect. Ironically, Mr. Shirk is the father of
Roy Shirk Jr., Lisa Michelle Lamberts first attorney who represented her during
trial of 1992, the proceeding which was the center of Judge Dalzalls
controversial and appalling findings.
The victim prided himself on his
entrepreneurship , and after building the foundation for FMG, he set out to take
advantage of its resources and its synergism.
By June of 1987, the victim had developed a fairly substantial mortgage

banking relationship with a Houston, Texas banker. That operation was capable
of providing lending to potential developers and businesses in the range of $ 3
million to $100 million. And the lending packages were as competitive if not
more competitive than the local lending institutions of Lancaster County, capable
with even higher lending limits. In a matter of months of securing this
relationship, the victim and his partner were evaluating deals from Pennsylvania,
New Jersey, New York, Florida, and as far away as California.
There was a uniqueness to his capabilities that was very appealing to

potential borrowers. Because of the vast array of services of FMG, potential
Page 12 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 18 of 2301
1299
developers had the opportunity to obtain both debt and equity financing through
his companies. In plain terms, most shopping centers raised capital by raising
funds through investors coupled with a mortgage. This gave potential developers
one place to take down the deal rather than dealing with many other
professionals at the same time. It was a much more efficient process for all. The
victim was capable of providing a mortgage, while at the same time selling
shares in a shopping center through its vast client base of investors at FMG.
This also gave the victim a formidable presence into the venture capital markets,
by way of his strong ability to raise capital through his vast portfolio of clients of
FMG. And this was a rarity that developers and investors loved. Investors were
attracted because they could invest in equity type real estate projects with real
sense of knowing the developer, or kicking the bricks of the project. This was
far different than investing in a nationally syndicated project, with properties
scattered all over the country, and with developers that they did not know. The
synergistic approach to his organization began paying dividends by developing
other peripheral markets and businesses.
Given the complex nature of the victims design of FMG, internal

struggles within the organization readily became the challenge. Orchestrating the
relationships among all of the different professionals, and trying to adhere to the
interests of the clients, the professionals and of the firm, FMG, managing the
daily activities required immense thought and prudence on the part of the
principals. Of, course, the victim assumed honesty and integrity to be a given.
And for most it was. However there were times when the senior partner engaged
in tactical rights of power.
In the later part of 1986, after the victim had developed FMG to the point
where its future was on stable grounds, his two partners conveniently attempted
to circumvent his position and regain control of his stock and the firm. In fact,
after the victim refused to collaborate on a scheme to set up his other partner,
the remaining two partners began to attempt to regain the victims control.
Through intimidating techniques, the partners began to attack his presence. The
Page 13 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 19 of 2301
1299
victim became agitated, especially because he played the lead role and was
responsible for the formation of the company, methodically designing and
developing its foundation, with great success. And now after the company was
beyond its point of greatest risk, due to in large part the victims efforts, the
other two partners wanted to take advantage of his work, and take the cream of
the pie for their own financial gain. It was a difficult task to carry out because the
victim was the most respected of all three partners, consistently keeping their
respective policies in the best interest of the firm and of the other associates and
stockholders. In fact, most feared that the loss of control of the victim would
ultimately lead to adverse consequences. However the two partners trued
unsuccessfully to weaken his position, and when that didnt work, they focused
on weakening the victim, via intimidation and humiliation The coup and hostile
environment caused a state of depression for the victim, although he kept to his
daily duties and responsibilities, accordingly, he called a client and friend who
was a psychiatrist, whom he trusted and respected. It was easy access to a
professional, yet on a very informal basis. Because the victim had a family
history of mental deficiencies, he wanted to seek the proper help.
The psychiatrist had diagnosed the victim as having Bi Polar Mood

disorder. The psychiatrist had quickly discounted any correlation between the
current state of affairs, and his partners abuse. The psychiatrist rationale was
that because the startup of the company was so successful in such a short
period of time , and his demonstrated intelligence and creativity, the victim must
have been in a state of mania, and of course now, was subsiding in a state of
depression, the typical cycle for manic depressants. The victim complied with
the psychiatrist. And after refusing to sell out to his partners, vowed to regain his
business and rescind any efforts to give up his claim to his accomplishments.
The depression soon faded. The victim never disclosed the fact that he had
sought help to anyone other than family members. This coup lead to the victims
aggressive approach to grow the business, and to posture himself in projects that
would ultimately remain in his control, out of the influence of his partners.
Page 14 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 20 of 2301
1299
Particularly the mortgage banking activities and the digital movie, which he did
successfully, but apparently too successfully.
THE DIGITAL MOVIE
Through an act of fate, in February of 1987, the victim found himself in a
meeting with Tony Bongiovi at Power Station studios. Through one of his
partners, he reluctantly traveled to New York to consider financing a motion
picture. The victims own lack tolerance for the risk associated with film
investments was overshadowed by the opportunity to visit a recording studio.
Although his associate was a friend of Tonys, he was not familiar with his
accomplishments, or his work, so he thought. If nothing else, it was a weekend
away from Lancaster, and a chance to visit the Big Apple. Intriguingly, he found
more than he had ever imagined on that weekend excursion. Tony Bongiovi, a
musical genius, whos credits include one of the most recognized recording
studios in the country, Power Station Studios. Tony Bongiov produced the sound
track for Star Wars, and is responsible for the format of one of the most
successful recording artist of the 80s, Jon Bon Jovi, his cousin. Power Station
has recorded the albums for some of the most influential artists of all time,
including Diana Ross, Madonna, The Rolling Stones, Steve Winwood, Bruce
Springsteen, etc., Tony, an eccentric genius, of Italian decent, had many talents,
from music to aerospace engineering. The victims associates sister met Tony
while he flew his plane into Lancasters airport for repairs. They dated for some
time and the victims associate and Tony became friends, which led the victim
to Tonys Power Station Studios.
Tony was looking to finance his new project, which was to be the first
digital movie. And, given the victims extreme appetite for technologies,
coupled with his amazing sense of perception, he dramatically recognized the
future evolution for the technical merits of delivering digital video and digital audio
entertainment to the mass markets. By June of 1987, the victim was positioned
as the Executive Producer, collaborating with Flatbush Films of Hollywood
California, the movie producers, entrusted with the mission of finding investors to
Page 15 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 21 of 2301
1299
provide funding for the first digital movie, and to manage the ensuing business
elements it required.
The movie was to be shot on-location at the Jersey shore points, mostly
in Wildwood. Tony strategically envisioned making a movie in the horror genre.
There were several specific reasons that supported this strategy. First, he
determined that it was the least expensive format to produce, we all estimated a
budget of $4 million for the production and post production. Secondly, the horror
genre would compliment a very intense sound track. The sound track was
important to enhance the new digital format, and also provide the means to
introduce a new band that he had been grooming in his studio for the past
several years, French Lick, his predecessor to Bon Jovi. There had been bad
blood between Tony and his cousin Bon Jovi, which resulted in legal disputes
pertaining to Tonys financial interests in Jons success. It was an unfortunate
situation considering Tonys father and Jons father were brothers living in the
same area. It was a subject that Tony never wanted to discuss, except for his
contributions toward Jons career.
If by another act of fate, the victim had the privilege of meeting one of the
many superstars while working at Power Station studios. While growing up, at an
early age, the victim would sneak up into the bedroom of his oldest brother, and
start up his old General Electric stereo phonograph and listen to his favorite
album - Diana Ross and the Supremes. It was a passion and a ritual that
provided an early infatuation to music, and to Diana Ross. The victim was only
10 or 11 years old. And at this early age, he noticed and listened to the annoying
hiss, that conventional hiss that always seemed to overshadow the music,
whether played on an album, on the radio, 8-track tape, or cassette.
And in a mystical twist of fate, while engrossed in a project dedicated to

delivering music without that hiss (digital) - the victim opened the door to the
recording suite to pack his bags for the journey back to Lancaster; - and there
she sat, with a glowing array of beauty, more beautiful than any picture could
Page 16 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 22 of 2301
1299
ever tell, Ms. Diana Ross. She was pregnant and in the middle of a recording
session, for a new album. Her assistant quickly demanded, in a stern and
protective voice, that we leave, and the victim and his associate replied this is
our makeshift bedroom, we are just gathering our belongings. The victim
walked toward Diana Ross, who was seated near his bag, and she asked and
who are you?, the victim calmly replied his name and absorbed as much of her
beauty as his eyes could behold before walking out the door. The room that was
his bedroom the nigh before, and suddenly transfixed into the recording suite of
Diana Ross, thinking back some twenty years earlier, one of the many gifts that
God would bestow upon him. A living memorial and reminder to his older brother,
who died on Christmas day of 1985, his best friend who taught him two of his
greater pleasures in life, Diana Ross, and listening to music. He prayed that his
brother was watching from above.
And so, the digital movie project that the victim had embraced in 1987
had personal significance, and he never ever doubted his instincts regarding the
technical merits of the project. The victims perception that the entertainment
industry would deliver full length motion pictures in a truly digital medium will later
become a truly remarkable vision.
The technical merits of this project and at this particular time with respect
to the victims extreme sense of perception require analysis. To truly understand
this time perception, some of the attributes of digital technologies need to be fully
understood. In 1987, Compact DISC (CD) technology was only now being
introduced to the commercial markets. The victims own crafting of his joint
venture proposals, dominated by the term digital movie, is in itself some 4 or 5
years away. In 1987, there was very little use of the term digital, with the
exception of research and development engineers. The victim will, throughout the
documentation of this story, will have preceded a terminology that has literally
become the root of most technological advancements in the computer and
telecommunications industries of our present day, 10 years after the victims
Page 17 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 23 of 2301
1299
vision. Today, digital is found to be part of or referred to in just about every

product available in the commercial markets.
During May of 1987, the victim had created a joint venture proposal for
SONY Entertainment, Inc., for the digital movie. After weeks of researching the
current state-of-affairs within SONY, and after his proposal was completed,
SONY publicly announced their desire to open the markets for new and emerging
technologies on the cover of TIME magazine, another demonstrated sense of
perception. It was this proposal, when delivered to one of the Hollywood
producers in Santa Monica, California, after reading a draft of the proposal she
said you are a genius. The proposal was introduced to Tony Bongiovi at the
Wildwood Boardwalk, where many of scenes were to be shot, and he approved
of the proposal and thought that it had great merits. Tony, who wanted very to do
with the business elements of his project, gave the victim complete authority to
secure the financing of the project, with a salary as Executive Producer, and a
percentage of the profits on the back end.
After review of the victims research and proposals, his vision and his
passion, unfortunately without his efforts, has come to be known as Direct
Satellite System, or DSS, which is Sonys satellite entertainment system (TV),
delivering digital audio and digital video entertainment. That technology is fast
eroding at the cable industry. The victim had his patent research center around
the PSDMS system, the Power Station Digital Movie System. And that was in
1987, some seven years before SONY delivered his dreams. Later the victim
would also accurately predict that the 90s would become the Information Age
because of the direct contributions and advancements of digital technologies,
which is directly responsible for the development of the INTERNET.
The victims obsession with his digital movie has proven to be one of his
most remarkable demonstrations of his keen sense of perception.
Page 18 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
REQUEST FOR COMMUTATION

Page 24 of 2301
1299
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Stan J. Caterbone
Freedom From Covert Harassment & Surveillance,

Registered in Pennsylvania
1250 Fremont Street

Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
stancaterbone@gmail.com
717-598-2200
November 15, 2016

PRESIDENT BARRACK OBAMA
THE WHITE HOUSE
1600 PENNSYLVANIA AVE NW
WASHINGTON DC 20500-0003
Re:
REQUEST FOR COMMUTATION OF THE SENTENCE OF LISA MICHELLE LAMBERT

SEE THE ENCLOSED FILE: SIGNED Third Circuit Case No. 16-1149 LAMBERT Habeus Corpus PETITION FOR
WRIT OF CERTIORARI to the United States Supreme Court, October 12, 2016
Dear Mr. President,

I am hopeful this letter finds you well. First I must honestly state that I was very disappointed
on the morning of November 9, 2016 as the results of the election were final. In 2008 I officially
campaigned for Hillary and saw you speak at the Thaddeus Stevens College. I made the rounds that
year and saw Hillary, Bill and Chelsea all speak on every occasion they were in a 40 mile radius of
Lancaster County. The CLINTONS are owed a debt of gratitude for their public service. In 2005 I was
selected to attend the first CLINTON GLOBAL INITIATIVE in New York. I had submitted an essay and
was selected by the Executive Committee to attend, however, my litigation attracted the wrong kind of
attention as my father would say. That being said, the other matters are not of interest to me and I
hope they are not of yours for now, if they are at all.
The Lisa Michelle Lambert is a story of an injustice that only you can resolve in a timely fashion.
I am hoping the last weeks of your tenure are enough time. As her MOVANT in the U.S. District Court
Case 14-cv-02259, and the APPELLANT in 2 Third Circuit Cases, 15-3400 and 16-1149 respectively,
(both closed) I believe I can come before you with an argument to support my request. In addition, I
have been intimately involved in the case since 1997 having attended the PCRA Hearing in the
Lancaster County Court of Common Pleas, and having signed an AFFIDAVIT to the HONORABLE
STEWERT DALZALL in 1998, and having had her original Attorney Christina Rainville review my
ALLEGATIONS OF PROSECUTORAL MISCONDUCT.
I believe that I made a very sound and prudent argument in my WRIT, so I will argue to you the
same argument, if you don't mind. You will find it on the next page.
To President Obama re Lisa Lambert
Page 1 of 91
Wednesday November 15, 2016
January January
Sunday
22, 201722, 2017

Page 25 of 2301
1299
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
That being said there is a broader issue that is woven through the history of this
unprecedented case starting; with the original HABEUS CORPUS written and filed by
PETITIONER Lisa Michelle Lambert in 1997, the findings of U.S. District Judge Stewert
Dalzall's that this case contained one of the worst cases of prosecutorial misconduct in the
English speaking language and releasing Lisa Michelle Lambert from prison; and ultimately
the contamination of wrongdoings in this case.
This again is another case of JUDICIAL
MISCONDUCT and PROSECUTORIAL MISCONDUCT at the WORST or a case of ERRORS and
OMMISSIONS at best regarding the adjudication of the APPELLANT'S original Amicus Curie
Brief and Motion for Summary Judgment in PETITIONER'S Lisa Michelle Lambert's Habeus
Corpus of May of 2014.
This case was of national importance and received national attention immediately
following the findings of U.S. District Judge Stewert Dalzall and the release of Lisa Michelle
Lambert from prison in 1997. A&E TV did a documentary, which aired on national television
titled American Justice: A Teenage Murder Mystery and also sells the DVD online today. See
Appendix H. The LA Times published a 3-part series beginning on November 10, 1997 by
Journalist Barry Seigel. See Appendix I.
It is in the public's best interest to restore integrity to the COURTS and to the
Prosecutors and Judges and the COURTS that are honest and fair; and provide the means to
which Lisa Michelle Lambert's meritorious plight for RELIEF and RELEASE from Prison can
then be accomplished, as it should.
I have enclosed a CD-ROM that contains every pertinent document that I could think of you
would require to consider my request and to perform your due diligence of my active situation. I pray
for your help in my advocacy for Lisa Michelle Lambert and to help right an injustice. I also believe that
President Elect Trump deserves that every person in this country conducts themselves as first an
AMERICAN, then a Republican or Democrat. This country needs our help to restore it back to the days
when we were the BEACON OF DEMOCRACY for everyone to follow.
Thank you and your lovely family for your service!
Respectfully,
___________/S/____________
Stan J. Caterbone, Pro Se Litigant
1250 Fremont Street

Lancaster, PA 17603
717-669-2163
Page 2 of 91
January January
Sunday
22, 201722, 2017

Page 26 of 2301
1299
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
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 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. 16-1149 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-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-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 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. 08-13373; 15-10167; 06-03349, CI-06-03401
U.S. Bankruptcy Court for The Eastern District of Pennsylvania Case No. 16-10157
Page 3 of 91
'He got off light': Students ponder verdict after Millersville University's fi... http://lancasteronline.com/insider/he-got-off-light-students-ponder-verdic...
1 of 6
Sunday January 22, 2017
Page 27 of 2301
8/8/2016 8:01 AM
2 of 6
Page 28 of 2301
8/8/2016 8:01 AM
3 of 6
Page 29 of 2301
8/8/2016 8:01 AM
4 of 6
Page 30 of 2301
8/8/2016 8:01 AM
5 of 6
Page 31 of 2301
8/8/2016 8:01 AM
6 of 6
Page 32 of 2301
8/8/2016 8:01 AM
Remembering Karlie Hall: Student's death at boyfriend's hands spurs fam...
1 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
Page 33 of 2301
8/8/2016 7:57 AM
2 of 9
Page 34 of 2301
3 Ways To Stop
Dementia
Learn the 3 simple habits that
can stop dementia dead in its
tracks
8/8/2016 7:57 AM
3 of 9
Page 35 of 2301
8/8/2016 7:57 AM
4 of 9
Page 36 of 2301
8/8/2016 7:57 AM
5 of 9
Page 37 of 2301
8/8/2016 7:57 AM
6 of 9
Page 38 of 2301
8/8/2016 7:57 AM
7 of 9
Page 39 of 2301
8/8/2016 7:57 AM
8 of 9
Page 40 of 2301
8/8/2016 7:57 AM
9 of 9
Page 41 of 2301
8/8/2016 7:57 AM
Chester Springs man co-authors murder novel
1 of 2
http://www.dailylocal.com/general-news/20160607/chester-springs-man-...
Page 42 of 2301
Daily Local News (http://www.dailylocal.com)

Dave Brown collaborates with Lisa Michelle Lambert for novel titled Love, Murder and Corruption in Lancaster County: My
Story
By Linda Stein, lstein@21st-centurymedia.com, @lsteinreporter on Twitter
Tuesday, June 7, 2016
After writing four sports-related books, local author and lawyer, Dave Brown, took a walk on
the dark side.
His most recent title is a true crime tome: Love, Murder and Corruption in Lancaster County:
My Story, co-written with Lisa Michelle Lambert, who was convicted of the Dec. 20, 1991
murder of her romantic rival, Laurie Show.
I had followed Lisa Lamberts case in the papers over the years, dating back to the 1990s,
said Brown, 55. I always thought she got a raw deal. I thought it was very unfortunate.
Although he specializes in workers compensation cases and has no desire to branch out into
criminal law practice, Brown said that as a reader, he has an interest in true crime in general.
He believes a lot of people are wrongly convicted based on misconduct by police and
prosecutors.
Brown was thinking about what topic to write about next and decided that Lamberts story
would make for a compelling book. He wrote Lambert a letter then went up to the womens
state prison in Framingham, Mass., where Lambert, who maintains her innocence, is serving a
life sentence and spoke with her.
She herself is quite articulate, he said.
Lambert, 43, earned a college degree from Boston University while in a prison program and
finished a valedictorian, he said. Lambert had also written some chapters about her turbulent
childhood and abusive boyfriend and the abuse she suffered in prison, he said. (In 2007 the
state of Pennsylvania paid Lambert $35,000 to settle allegations of sexual abuse by prison guards. She was also assaulted by other
inmates at a prison in New Jersey, where she had been transferred.)
She wrote probably 80 percent of the book, said Brown. She writes so well that I was proud to write with her.
They decided to collaborate on the book with Lambert telling her story and Brown writing legal commentary. Their four-year long
collaboration entailed drafts sent back and forth in the mail and resulted in an 800-page manuscript that the publisher deemed too long.
Now cut in half, the book was published in February by Camino Books.
I talked to (Lambert) on the phone a couple hundred times since this started, about once a week, Brown said.
One interesting aspect of the case is that a federal judge, Stewart Dalzell, cited wholesale prosecutorial misconduct and threw out
Lamberts conviction in 1997. Dalzell held the misconduct was so outrageous the commonwealth should never be given an opportunity
to retry her, Brown noted.
However, Dalzells decision was overturned on appeal and the same judge, Lawrence F. Stengel, who convicted Lambert during a bench
trial in Lancaster County, convicted her again at a retrial. Brown said Dalzell was overturned on a technicality, because Lambert had
not exhausted her state court remedies before appealing to the federal court system.
The (Lancaster) community had it out for Lisa Lambert, said Brown. They didnt know all the facts. The two other people (Tabitha
Buck and Lawrence Yunkin) were the ones who really carried out the murder. Buck is serving a life sentence without the possibility of
parole and Yunkin served about 12 years out of a 10 to 20 years sentence for his role in the crime.
6/14/2016 2:00 AM
2 of 2
Page 43 of 2301
Stengel took umbrage that Dalzell walked all over his original decision, said Brown. Although Lambert appeared to have exhausted her
appeals after being rebuffed by the U.S. Supreme Court, Brown said new evidence has come to light and he is hopeful she will be
exonerated at long last.
Brown said that new evidence is an admission of misconduct that John Kenneff, the assistant district attorney who prosecuted Lambert,
allegedly made before his death.
Incredible corruption pervaded the Lancaster judicial system, Brown said.
Brown also hopes to find a new criminal lawyer in Pennsylvania to take up the cudgel on Lamberts behalf, working with a Los Angeles
attorney who is interested in the case.
Shes looking at a life sentence unless we can get this reversed, said Brown.
Brown, who grew up in Strafford and graduated from Conestoga High School, loved to read and write since I was a little kid. He went
to Gettysburg College, worked awhile and then attended law school at Dickinson. Although he likes practicing law, I always wanted to
publish a book more than anything.
I enjoy being a lawyer but my true passion is writing, said Brown.
He has also been a big sports fan since childhood, hence his interest in writing about sports, especially baseball. Brown lives in Chester
Springs with his wife, Kim, and their two sons, ages 12 and 11, and their 7-year-old daughter.
Brown will be signing copies of Love, Murder and Corruption in Lancaster County: My Story at three Barnes & Noble branches on
June 18: 10 a.m. at Fairless Hills; 1 p.m. at Neshaminy; and 4 p.m. at Plymouth Meeting.
URL: http://www.dailylocal.com/general-news/20160607/chester-springs-man-co-authors-murder-novel
2016 Daily Local News (http://www.dailylocal.com)
6/14/2016 2:00 AM

Letter to Lisa Michelle Lambert
Page 44 of 2301
Page 1 of 63

Saturday, May 28, 2016

Page 45 of 2301
Page 2 of 63


Page 46 of 2301
Page 3 of 63


Page 47 of 2301
Page 4 of 63


Page 48 of 2301
Page 5 of 63

220 Stone Hill Road
Conestoga, PA 17516
infor@amgglobalentertainmentgroup.com
717.731.8184 Phone
717.427-1621 Fax
HAD LANCASTER COUNTY (Pennsylvania) LOST ITS

SOVEREIGNTY BEFORE IT LOST ITS SOUL?1

In 1987 This Plaintiff Had Unjustly Lost His Freedoms, His Rights, And His
The following report (most identities purposely omitted from this
version) is an amazingly true and factual account of an extraordinarily bizarre
tragedy that has turned one mans life into an eleven (11)2 year free fall into
Dantes Hell.
On the surface, this is a story of a victim struggling to seek the truth, but in
reality, the evidence will conclude that this is a victim, literally, held hostage by
virtue of his truth. Later, the preponderance of evidence that the victim has
1
In April of 1997, Federal Court Judge Stuart Dalzall said Lancaster County had
lost its soul in the worst case of prosecutorial misconduct ever found in the
English speaking language regarding the Lisa Michelle Lambert hebeas corpus
hearing in the notorious Laurie Show murder case.
Page 1 of 18
04.11.2007

Page 49 of 2301
Page 6 of 63

amassed and his obsession for meticulously documenting his ordeal might seem
eccentric, yet his demonstrated ability to react to events before they unfold
appears mystical. And this was his manner in which he tactfully defended and
protected his life. It is these actions that have painted the landscape with a dire
vengeance for his ruin. His actions will ultimately serve to protect, preserve, and
foster the truth of his story, incriminating the culpability of his many perpetrators,
while at the same time being twisted and tainted in a relentless manner to attack
his credibility.
This is a story of a human being endearing for his rights, living in fear of
his life, and the remedial actions required for the truth to set him free. A victim
forever believing in his accomplishments and his visions, yet forced to adhere to
a life of their diversions. Fatefully, ten years after being taken as a political
hostage, with the aid of numerous arrests and false imprisonments conveniently
falling short convictions , a Federal Judge, Judge Stuart Dalzall, of the Eastern
District Court of Pennsylvania, opened a Pandoras Box into the true colors of
the inner workings and politics of ultra conservative Lancaster County,
Pennsylvania. A supposedly Gods country. His findings reeled a dramatic and
assassination of JFK . A community where obstructions of justice strikes a
startling and stark contrast to the image it so desperately embraces. A
community proud of its tough on crime judges, a community of plain folks and
Amish, and a community settled in a beautiful landscape abundant in an
agricultural bounty. This is not a community of compromising integrity. Or so it
has been perceived.
Judge Dalzalls extremely controversial findings were responsible for
Pennsylvanias own crafting of the Laurie Bill, the retaliation by the
Commonwealth of Pennsylvania intended to curb the Federal Courts interference
within the respective states own jurisdictions and proceedings. Or was it a
political maneuver to close the lid on Pandoras Box? The Pennsylvania
Attorney General and the Lancaster County District Attorney have both thrown all
Page 2 of 18
04.11.2007

Page 50 of 2301
Page 7 of 63

their might and all their muscle at turning the tides of Judge Dalzalls findings.
This story and this victims rights have been violated and abused by some of the
very same principals that were responsible for Judge Dalzalls unsettling
revelations. Lancaster County prosecutors were found to have engaged in one of
the grossest acts of prosecutorial misconduct found in the English speaking
language, which allegedly occurred in this now famous Lisa Michelle Lambert
case, a murder trial which began in the summer of 1992. Subsequently, it is now
in the midst of a treacherous appeal process convened by Judge Dalzall. And if
so by fate, in Philadelphia, Pennsylvania, the home of the Freedom Fighters.
It is this public disclosure, that casts a new light and sudden hope for
freedom into this victims unbelievable and horrid story, that begun just four
years prior to the murder of Laurie Show. It is the decisive similarities of how both
victims were subjected to a very calculated and politically motivated attempts to
frame and fabricate circumstances to obtain the results that justified the
means for illicit self-serving interests. This very same conduct, committed by
public servants, elected and enlisted to enforce the law, to which Judge Dalzell
found so appalling. Conduct, which violated the very same rights their respective
offices are commissioned to protect. Conduct which strikes the meaning of We
The People from our nations very own Constitution.
Fortunately, this victims story is laced with a thread of faith, a faith in
God. And because of his faith, this victim will forever regard Lisa Michelle
Lambert3 and Laurie Show as his little Angels of Justice, a Godsend. An
answer to his many prayers, that for the first time in ten years provided a small
glimmer of hope, and a few moments of solitude that have materially justified his
own tragic experience. The realization that the truth is that much more believable
because of the trials and tribulations of Lisa Michelle Lambert. Unfortunately, this
3 The author admitted in an affidavit in 1998 that he did not know the criminal
prosecutorial misconduct and the erroneous handling of the crime scene that the
truth evaded both the prosecution and the defense as to who actually killed
Laurie Show.
Page 3 of 18
04.11.2007

Page 51 of 2301
Page 8 of 63

revelation came at the unfortunate and untimely death of Laurie. However, it just
may be Gods intentions of a Higher Purpose.
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 obstruct this victims rights for
justice. Its 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 Boys club of Lancaster County. A process obsessed with
keeping its disclosure from escaping beyond the confines of Pandoras Box. Its
a tenure of power that evolved from the days of this countrys 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!
AT ISSUE
The central issue in this story, is a cover up, a cover up of mass
proportions, and of perplexing design, with national consequences. The fact of
the matter is that this cover up has had ramifications throughout this world,
specifically the Middle East The cover up would be emphatically unbelievable
without the wealth of evidence, especially the recorded conversations with
Pennsylvania officials. A cover up that permeates from what will later emerge as
the 4th largest financial fraud (Billion Dollars) in the history of the United States
coupled with the covert sales of arms to Iraq. And five years after this cover up
began, these same munitions were used against our own troops in the Persian
Gulf War. And of course, there are admitted ties to the Central Intelligence
Agency (CIA) and the National Security Agency (NSA).. And this cover up and
story, which began in June of 1987, in Lancaster County, preceded criminal
indictments by the United States Attorney General, the Federal Bureau of
Page 4 of 18
04.11.2007

Page 52 of 2301
Page 9 of 63

Investigation (FBI), the Internal Revenue Service (IRS), the Department of

Justice and Commerce, and more. A vast array of criminal activities conspired
from the ultra conservative Lancaster County, where God is supposedly
supreme, and its hard line approach to crime is said to be preeminent. In June of
1987, Lancaster County was immersed in a dynamic twist of fate, with a host of
The irony of this story is how Lancaster County manages the disclosure of
the very same criminal activities that this story proves that it condoned, prior to
the intervention of federal authorities. It most dramatically will prove the nature of
its integrity, or lack thereof. International Signal & Control, (ISC) is the
controversial player in this web of conspiracy. In 1987, the third largest employer
in Lancaster County, a non-discrete defense contractor. In all due respect to our
beloved country, this report is in no way challenging the policies or the activities
of the Department of Defense, or the vast agencies of the Intelligence
Community, especially the CIA or the NSA (National Security Advisory). with
regards to ISCs foreign dealings. Trying to protect the world of malicious and evil
empires is a process which never ends, and whos players are constantly
changing. And our respective intelligence agencies are continually challenged
with the task of trying to make a difference, in accordance with protecting our
national security. Unfortunately, given the nature of their discrete activities, and
given the CIAs history of avoiding congressional approval in certain situations,
our current laws are void of effectively dealing with the peripheral catastrophes of
such activities that inherently transpire. The CIA remains immune, while
everyone outside suffers the consequences.
The fact that the CIA, or anyone of the other intelligence community, may
have been involved, does not grant a blanket of immunity over activities which
were not material to protecting our national security. If a company provides a
service to anyone in the intelligence community, our constitution, our laws, and
its respective commercial regulatory authorities, must still have the full sense of
their jurisdiction. The intelligence community may not have the right of
Page 5 of 18
04.11.2007

Page 53 of 2301
Page 10 of 63

intervention into the commercial enterprise, or organization, circumventing the

rights of its employees, shareholders, creditors, and customers. No United States
law or statute suggests that there is any involuntary mandate that requires any of
the preceding to compromise their interests in the respective enterprise for the
that.
This victim was a shareholder of record of International Signal & Control
(ISC) for the previous four years prior to when this tragic ordeal began. The
victim was to purchase the stock from now Republican Pennsylvania Senator
Gib Armstrong, who was in the brokerage business at the time and selling ISC
stock. The stock was sold over the London Securities Exchange, supposedly for
reasons to suppress information. The victim was interested in the stock because
of his appetite for technology, and was more curious about the business of ISC,
than anything. In fact, the victim had never made any inference to any of the
illicit dealings with Iraq. However, the perpetrators of this story, attempt to hide
behind a vale of national security," in an effort to find legal immunity from all
wrongdoing. In accordance, the record will prove that this is merely a smoke
screen used to intimidate and obstruct the victims access for due process of the
law.
The trials and tribulations of this victim are unprecedented in terms
of emotional and psychological duress, fortunately his indestructible faith in God,
and his enduring belief in himself and the truth, endures his life. There was one
attempt on the his life, days within the public disclosure of the CIAs involvement
with the local Lancaster County defense contractor (ISC), which Ted Kopel
Page 6 of 18
04.11.2007

Page 54 of 2301
Page 11 of 63

reported on ABC News Nightline, on May 23, 1991, 4 years after the initial cover
up began. This story will depict a series of systematic and strategic offensive
attacks upon this victim and his businesses that will result failed business
enterprises, and a Hollywood motion picture, deserted. An impeccable
professional reputation and a flawless credit rating purposely sabotaged.
Financial opportunities, that in 1987, were almost impossible to extrapolate, Vast
financial opportunities and aspirations forever a part of history. This horrendous
crime was perpetrated for the interest of a cover up, further protecting the corrupt
enterprises of Lancaster County's International Signal & Control (ISC). A quest
for justice that polarized every relationship the victim maintained, in Lancaster
County and beyond, including friends and family. This story demonstrates a
methodology of his perpetrators for keeping this victim quarantined from justice
and public disclosure, through a malicious means of credibility proponents, and
horrendously deceptive tactics. Financial motives prominently displayed in the
hands of all of the perpetrators, which absolves the burden for a traditional
conspiracy..
The emotional response to the truth of this story is compelling, to say
the least. Subsequently, the startling keen sense of perception that the victim
had demonstrated, is even more intriguing. It is this extraordinary quality that is
responsible for saving his life, while yet at the same time providing his
perpetrators with an alibi and a vehicle for discrediting his startling allegations
and his story. This story embellishes a dichotomy of perception that had
Hollywood producers from his film project call his work genius, while his
perpetrators from the Lancaster County Community conveniently and maliciously
labeling him as insane and emotionally disturbed."
THE LANDSCAPE
The perplexing question of the victims intelligence, or lack thereof, is
best analyzed as a question of perception. However it terms of the legal
consequences of the activities contained herein, they are of little if any relevancy.
Page 7 of 18
04.11.2007

Page 55 of 2301
Page 12 of 63

The fact of the matter is that the mental deficiencies have very little relevancy to
this story, other than serving as a means to discredit the victim, a vehicle to
facilitate the cover up, and a blanket of immunity for all of the perpetrators.
The heart of this victims legal dogma is best described as follows: If a
person, is perceived to have a mental deficiency; yet whose actions and
decisions are always proven to be instinctually and amazingly prudent, always
abiding within the law, and in the best interest of his affairs, what rights and
protection do the laws afford him from persons abusing that perception, in order
to yield political and financial rewards, as a direct consequence of his demise?
Furthermore, how does the law protect his rights, if any and all malicious acts
against this victim, are constantly and immediately disregarded because he is
perceived to not to be credible? As this story unfolds, these questions will
become even more troubling and appalling. Although the victim could never
describe the pain of his trauma, he would often say that the closest situation that
may compare is that of a woman being continuously raped, night after night,
helplessly praying for relief, struggling to free herself from her captor, all with no
avail. He would call it as being brain f------.
The victim, coming from the lower middle class of Lancaster City, was
only 29 years old when this tragedy began. Coming from a broken home, he was
the third of six boys. While at a very young age, he would help his mother run a
dry cleaning business, in an amazing similarity like Lisa Michelle Lambert, he had
also nursed his mother during bouts of depression. While in high school, he was
nursing his mothers depression, while at same time tending to his older brothers
bouts of schizophrenia. The victim had learned to listen to the obscenities of
mental illness since he was a child. He learned to fill the shoes of his absent
father in helping his mother raise his three younger brothers.. The victim was
often called the little old man because of his extraordinary maturity as a child.
The victim was determined to break the barrier of the Good Ole Boys club or
the power elite, and had always felt a sense of compassion for those less
fortunate, and those neglected by those of material means, the oppressed and
Page 8 of 18
04.11.2007

Page 56 of 2301
Page 13 of 63

impoverished. He had an undivided aspiration to someday make a difference to

those that could not help themselves, especially his older brother. Through his
ingenious, resourceful, and honest business approach, he was relentlessly
growing his business and their respective missions, in constant reminder of his
oppression. His in depth understanding of computer technology and his vision
were his most powerful allies. Always pushing the envelope for advanced
technologies and seeking solutions for the most efficient means of his
operations.. He knew that every break was going to be few and far between, he
dedication himself to his work, and married his business affairs, always
In 1986, after serving on the Board of Directors for the Central
Pennsylvania Chapter of International Association of Financial Planners (IAFP),
the victim had made a large contribution to increasing its membership and its
awareness among local professionals, as its vice president. In an effort to
promote the organization, the victim solicited a nationally recognized and
prominent financial planner from Washington, D.C., to be a headline speaker at a
dinner meeting. Ms. Alexandra Armstrong, one of the most nationally recognized
financial planners, often headlined in Money Magazine, attracted 100 industry
professionals to the Treadway Resort Inn. The attendance was unprecedented
for the local IAFP chapter. The IAFP is the authoring organization for certification
as a financial planner. It was through the direct conversations with Ms. Armstrong
regarding his ideas and her experience, that inspired the victim to pursue his
ambitions of growing his own financial firm, which he began in the following
months.
Disgruntled with the conflicts of interest and the lack of incentive for
various professionals to work together in managing ones wealth, a process
which lacked efficiency, this entrepreneur founded the firm Financial
Management Group, Ltd., or FMG as it was often called. The firm was to
incorporate a one-stop-shopping strategy and incorporate financial services,
legal, accounting, tax preparation, real estate, insurance, mortgage banking, and
Page 9 of 18
04.11.2007

Page 57 of 2301
Page 14 of 63

estate services all in one firm, all residing in one location, all taking advantage of
the synergistic approach toward managing wealth. And to provide the
professionals long term security and equity participation, all participants were
encouraged to purchase stock in the company. This was a new and innovative
approach that attracted a lot of attention from investors and clients, but also
came a lot of nervous twitches from competitors, especially in conservative
Lancaster County.
The victim began recruiting professionals from all of the other firms, with
great success. He had enlisted two partners whom he had worked with at
IDS/American Express, to carry out his mission, which he began after extensive
market studies and his early version of the company, Pro Financial Group, Ltd.,
His two partners had followed the victim to an independent broker dealer in
Atlanta, named Financial Services Corporation, where Ms. Alexandra Armstrong
was associated, and encouraged the victim to visit, during their discussion after
dinner. Within one year, by June of 1987, the firm had invested over $40 million
for respective clients.
The company had developed satellite offices throughout Pennsylvania and
in several other states, through his unique design. This firm was causing the
other financial services companies and the local banks in Lancaster County a run
for their money. The firm had built a new 20,000 square foot office building just a
few miles north of the city. The firm was attracting clients, associates, and
nervous attention from, well just about everybody. Considering the capabilities,
legal, real estate, insurance, financial services, accounting, FMG was making as
many enemies as it was making friends. And the victim always believed in the
premise that its always better to have people talking about you, regardless of the
matter, than to have no one notice you. And they were talking. The victim was
only in his late twenties when he started this organization,. He held several
positions, he was Executive Vice President and Secretary of Financial
Management Group Ltd, and President of FMG, Advisory, Inc., which was one of
the many subsidiaries parent company owned. The victim acted as the architect
Page 10 of 18
04.11.2007

Page 58 of 2301
Page 15 of 63

and legal administrator of the organization, in addition to building his own

financial planning clients. He filed all of the articles of incorporation in the
Commonwealth of Pennsylvania and submitted all of the tedious and rigorous
filings necessary for the Pennsylvania Securities Commission, which were very
demanding considering the victim was selling stock of his company to his
associates and investors. The victim and his associates had also attracted some
very prominent Lancastrianss to invest in his venture, coming from various
professional circles, all infatuated with this extraordinary and intriguing concept of
this young victim. All had seen its potential for success and financial reward.
Many of his friends were involved, and in Lancaster, everyone knows
everybody, so it seams.. And everyone talks, gossip is as common as jogging.
This exaggerated trait of Lancaster County, will later to come back to haunt this
victim, in a way that is most sickening. In a way that will parallel the attitudes
and sentiments in the Lisa Michelle Lambert story.
In 1987, his business affairs were reaching a point of incredible success.
In fact, most of his family and friends, have always questioned the merits of their
legitimacy. He always conducted his affairs with the presumption that time could
not afford the opportunity to complete his agenda, while at the same time
disclosing his business affairs to persons that were not directly involved..
Accomplishing his mission was first and foremost. But in Lancaster County, that
was difficult. Lancastrianss have a notion to fear what they dont know, and will
always believe what they think they know, regardless of its merits. In Lancaster
County new ideas are shunned unless coming from their own, and their own
ideas are often kept close at bay, inhibiting progress and stymieing learning. By
June of 1987, a majority of his business affairs were conducted out of the grasp
of Lancaster County, his unknown activities made others curious, especially in
Lancaster County, where the blessing of the power elite was essential for
success. But, deep down inside, he knew he could never be accepted, because
he did not descend from a family of social grace. This fueled his aspirations for
Page 11 of 18
04.11.2007

Page 59 of 2301
Page 16 of 63

success even further, committed to prove that intelligence was innate and
learned, not a direct correlation to material wealth or social grace.
One of his most cherished testimonials to his concept, his reputation, and
his mission, was provided by an elder attorney, Mr. Kenellm Shirk, a very
respected and prominent older Lancaster attorney, who was part of the status
quo. Mr. Shirk had petitioned the Pennsylvania Bar Association, after meeting
with the victim, to obtain their blessing and their knowledge of any laws which
would forbid his firm to provide a satellite office in the headquarters of Financial
Management Group, Ltd., (FMG) Mr. Shirks firm was to provide a partner, and
estate services to the clients of FMG. The Pennsylvania Bar provided a lengthy
recommendation that did not prohibit a relationship, although cautioned it to
proceed with careful review. The fact that the very young and unknown victim
could attract an elder, conservative Lancaster County attorney to associate with
his firm was an encouraging sign of respect. Ironically, Mr. Shirk is the father of
Roy Shirk Jr., Lisa Michelle Lamberts first attorney who represented her during
trial of 1992, the proceeding which was the center of Judge Dalzalls
controversial and appalling findings.
The victim prided himself on his
entrepreneurship , and after building the foundation for FMG, he set out to take
advantage of its resources and its synergism.
By June of 1987, the victim had developed a fairly substantial mortgage
banking relationship with a Houston, Texas banker. That operation was capable
of providing lending to potential developers and businesses in the range of $ 3
million to $100 million. And the lending packages were as competitive if not
more competitive than the local lending institutions of Lancaster County, capable
with even higher lending limits. In a matter of months of securing this
relationship, the victim and his partner were evaluating deals from Pennsylvania,
New Jersey, New York, Florida, and as far away as California.
There was a uniqueness to his capabilities that was very appealing to
potential borrowers. Because of the vast array of services of FMG, potential
Page 12 of 18
04.11.2007

Page 60 of 2301
Page 17 of 63

developers had the opportunity to obtain both debt and equity financing through
his companies. In plain terms, most shopping centers raised capital by raising
funds through investors coupled with a mortgage. This gave potential developers
one place to take down the deal rather than dealing with many other
professionals at the same time. It was a much more efficient process for all. The
victim was capable of providing a mortgage, while at the same time selling
shares in a shopping center through its vast client base of investors at FMG.
This also gave the victim a formidable presence into the venture capital markets,
by way of his strong ability to raise capital through his vast portfolio of clients of
FMG. And this was a rarity that developers and investors loved. Investors were
attracted because they could invest in equity type real estate projects with real
sense of knowing the developer, or kicking the bricks of the project. This was
far different than investing in a nationally syndicated project, with properties
scattered all over the country, and with developers that they did not know. The
synergistic approach to his organization began paying dividends by developing
other peripheral markets and businesses.
Given the complex nature of the victims design of FMG, internal
struggles within the organization readily became the challenge. Orchestrating the
relationships among all of the different professionals, and trying to adhere to the
interests of the clients, the professionals and of the firm, FMG, managing the
daily activities required immense thought and prudence on the part of the
principals. Of, course, the victim assumed honesty and integrity to be a given.
And for most it was. However there were times when the senior partner engaged
in tactical rights of power.
In the later part of 1986, after the victim had developed FMG to the point
where its future was on stable grounds, his two partners conveniently attempted
to circumvent his position and regain control of his stock and the firm. In fact,
after the victim refused to collaborate on a scheme to set up his other partner,
the remaining two partners began to attempt to regain the victims control.
Through intimidating techniques, the partners began to attack his presence. The
Page 13 of 18
04.11.2007

Page 61 of 2301
Page 18 of 63

victim became agitated, especially because he played the lead role and was
responsible for the formation of the company, methodically designing and
developing its foundation, with great success. And now after the company was
beyond its point of greatest risk, due to in large part the victims efforts, the
other two partners wanted to take advantage of his work, and take the cream of
the pie for their own financial gain. It was a difficult task to carry out because the
victim was the most respected of all three partners, consistently keeping their
respective policies in the best interest of the firm and of the other associates and
stockholders. In fact, most feared that the loss of control of the victim would
ultimately lead to adverse consequences. However the two partners trued
unsuccessfully to weaken his position, and when that didnt work, they focused
on weakening the victim, via intimidation and humiliation The coup and hostile
environment caused a state of depression for the victim, although he kept to his
daily duties and responsibilities, accordingly, he called a client and friend who
was a psychiatrist, whom he trusted and respected. It was easy access to a
professional, yet on a very informal basis. Because the victim had a family
history of mental deficiencies, he wanted to seek the proper help.
The psychiatrist had diagnosed the victim as having Bi Polar Mood
disorder. The psychiatrist had quickly discounted any correlation between the
current state of affairs, and his partners abuse. The psychiatrist rationale was
that because the startup of the company was so successful in such a short
period of time , and his demonstrated intelligence and creativity, the victim must
have been in a state of mania, and of course now, was subsiding in a state of
depression, the typical cycle for manic depressants. The victim complied with
the psychiatrist. And after refusing to sell out to his partners, vowed to regain his
business and rescind any efforts to give up his claim to his accomplishments.
The depression soon faded. The victim never disclosed the fact that he had
sought help to anyone other than family members. This coup lead to the victims
aggressive approach to grow the business, and to posture himself in projects that
would ultimately remain in his control, out of the influence of his partners.
Page 14 of 18
04.11.2007

Page 62 of 2301
Page 19 of 63

Particularly the mortgage banking activities and the digital movie, which he did
successfully, but apparently too successfully.
THE DIGITAL MOVIE
Through an act of fate, in February of 1987, the victim found himself in a
meeting with Tony Bongiovi at Power Station studios. Through one of his
partners, he reluctantly traveled to New York to consider financing a motion
picture. The victims own lack tolerance for the risk associated with film
investments was overshadowed by the opportunity to visit a recording studio.
Although his associate was a friend of Tonys, he was not familiar with his
accomplishments, or his work, so he thought. If nothing else, it was a weekend
away from Lancaster, and a chance to visit the Big Apple. Intriguingly, he found
more than he had ever imagined on that weekend excursion. Tony Bongiovi, a
musical genius, whos credits include one of the most recognized recording
studios in the country, Power Station Studios. Tony Bongiov produced the sound
track for Star Wars, and is responsible for the format of one of the most
successful recording artist of the 80s, Jon Bon Jovi, his cousin. Power Station
has recorded the albums for some of the most influential artists of all time,
including Diana Ross, Madonna, The Rolling Stones, Steve Winwood, Bruce
Springsteen, etc., Tony, an eccentric genius, of Italian decent, had many talents,
from music to aerospace engineering. The victims associates sister met Tony
while he flew his plane into Lancasters airport for repairs. They dated for some
time and the victims associate and Tony became friends, which led the victim
to Tonys Power Station Studios.
Tony was looking to finance his new project, which was to be the first
digital movie. And, given the victims extreme appetite for technologies,
coupled with his amazing sense of perception, he dramatically recognized the
future evolution for the technical merits of delivering digital video and digital audio
entertainment to the mass markets. By June of 1987, the victim was positioned
as the Executive Producer, collaborating with Flatbush Films of Hollywood
California, the movie producers, entrusted with the mission of finding investors to
Page 15 of 18
04.11.2007

Page 63 of 2301
Page 20 of 63

provide funding for the first digital movie, and to manage the ensuing business
The movie was to be shot on-location at the Jersey shore points, mostly
in Wildwood. Tony strategically envisioned making a movie in the horror genre.
There were several specific reasons that supported this strategy. First, he
determined that it was the least expensive format to produce, we all estimated a
budget of $4 million for the production and post production. Secondly, the horror
genre would compliment a very intense sound track. The sound track was
important to enhance the new digital format, and also provide the means to
introduce a new band that he had been grooming in his studio for the past
several years, French Lick, his predecessor to Bon Jovi. There had been bad
blood between Tony and his cousin Bon Jovi, which resulted in legal disputes
pertaining to Tonys financial interests in Jons success. It was an unfortunate
situation considering Tonys father and Jons father were brothers living in the
same area. It was a subject that Tony never wanted to discuss, except for his
contributions toward Jons career.
If by another act of fate, the victim had the privilege of meeting one of the
many superstars while working at Power Station studios. While growing up, at an
early age, the victim would sneak up into the bedroom of his oldest brother, and
start up his old General Electric stereo phonograph and listen to his favorite
album - Diana Ross and the Supremes. It was a passion and a ritual that
provided an early infatuation to music, and to Diana Ross. The victim was only
10 or 11 years old. And at this early age, he noticed and listened to the annoying
hiss, that conventional hiss that always seemed to overshadow the music,
And in a mystical twist of fate, while engrossed in a project dedicated to
delivering music without that hiss (digital) - the victim opened the door to the
recording suite to pack his bags for the journey back to Lancaster; - and there
she sat, with a glowing array of beauty, more beautiful than any picture could
Page 16 of 18
04.11.2007

Page 64 of 2301
Page 21 of 63

ever tell, Ms. Diana Ross. She was pregnant and in the middle of a recording
session, for a new album. Her assistant quickly demanded, in a stern and
protective voice, that we leave, and the victim and his associate replied this is
our makeshift bedroom, we are just gathering our belongings. The victim
walked toward Diana Ross, who was seated near his bag, and she asked and
who are you?, the victim calmly replied his name and absorbed as much of her
beauty as his eyes could behold before walking out the door. The room that was
his bedroom the nigh before, and suddenly transfixed into the recording suite of
Diana Ross, thinking back some twenty years earlier, one of the many gifts that
God would bestow upon him. A living memorial and reminder to his older brother,
who died on Christmas day of 1985, his best friend who taught him two of his
greater pleasures in life, Diana Ross, and listening to music. He prayed that his
And so, the digital movie project that the victim had embraced in 1987
had personal significance, and he never ever doubted his instincts regarding the
technical merits of the project. The victims perception that the entertainment
industry would deliver full length motion pictures in a truly digital medium will later
become a truly remarkable vision.
The technical merits of this project and at this particular time with respect
to the victims extreme sense of perception require analysis. To truly understand
this time perception, some of the attributes of digital technologies need to be fully
understood. In 1987, Compact DISC (CD) technology was only now being
introduced to the commercial markets. The victims own crafting of his joint
venture proposals, dominated by the term digital movie, is in itself some 4 or 5
years away. In 1987, there was very little use of the term digital, with the
exception of research and development engineers. The victim will, throughout the
documentation of this story, will have preceded a terminology that has literally
become the root of most technological advancements in the computer and
telecommunications industries of our present day, 10 years after the victims
Page 17 of 18
04.11.2007

Page 65 of 2301
Page 22 of 63

vision. Today, digital is found to be part of or referred to in just about every

During May of 1987, the victim had created a joint venture proposal for
SONY Entertainment, Inc., for the digital movie. After weeks of researching the
current state-of-affairs within SONY, and after his proposal was completed,
SONY publicly announced their desire to open the markets for new and emerging
technologies on the cover of TIME magazine, another demonstrated sense of
perception. It was this proposal, when delivered to one of the Hollywood
producers in Santa Monica, California, after reading a draft of the proposal she
said you are a genius. The proposal was introduced to Tony Bongiovi at the
Wildwood Boardwalk, where many of scenes were to be shot, and he approved
of the proposal and thought that it had great merits. Tony, who wanted very to do
with the business elements of his project, gave the victim complete authority to
secure the financing of the project, with a salary as Executive Producer, and a
percentage of the profits on the back end.
After review of the victims research and proposals, his vision and his
passion, unfortunately without his efforts, has come to be known as Direct
Satellite System, or DSS, which is Sonys satellite entertainment system (TV),
delivering digital audio and digital video entertainment. That technology is fast
eroding at the cable industry. The victim had his patent research center around
the PSDMS system, the Power Station Digital Movie System. And that was in
1987, some seven years before SONY delivered his dreams. Later the victim
would also accurately predict that the 90s would become the Information Age
because of the direct contributions and advancements of digital technologies,
which is directly responsible for the development of the INTERNET.
The victims obsession with his digital movie has proven to be one of his
Page 18 of 18
04.11.2007

Page 66 of 2301
Page 23 of 63

Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
The following is a letter to the editor which I wish to be published on your site.
January 22, 2016
Re: Good Old Boys Network and the Kathleen Kane Coup
I have been the victim of a widespread civil and criminal conspiracy that dates back to
1987, made up of the very same actors that Kathleen Kane is up against, the "good old boys". In
1987 I blew the whistle on a local company, International Signal & Control, or ISC, that was
indicted for selling arms and weapons to Iraq via South Africa with the aid and support of the CIA
and the NSA. It was the 3rd largest white collar crime at that time, valued at $1 Billion Dollars. I
was the victim of a widespread wholesale cover-up through an elaborate slander campaign that
included 29 false arrests, multiple false imprisonments, and a fabricated mental illness record that
to this day is still resonating.
Kathleen Kane must be commended for her courage and her determination for taking on
this culture of arrogance and total disregard for the U.S. Constitution and the rule of law that they
so emphatically espouse to uphold. They believe and conduct their affairs in a manner that
suggests they are above the law and we, the Pennsylvania taxpayers, are beneath the law. The
sad fact that it reaches into the judiciary and law enforcement agencies is undeniably the most
outrageous and deplorable truth to this scandal. Case in point, until yesterday I was the
APPELLANT in a case before the U.S. Third Circuit Court of Appeals that involves the Habeus
Corpus for convicted and imprisoned Lisa Michelle Lambert. A murder case in the early 1990's
that was made famous when in 1997 U.S. District Judge Stewart Dalzell found her actually
innocent due to "one of the worst cases of prosecutorial misconduct in the English speaking
language" and released her from prison. The case drew nationwide attention when then
Pennsylvania Attorney General, then Mike Fischer, enlisted the help of 9 other state attorney
generals to curtail the reach of the federal bench in state matters concerning Habeus Corpus
cases. To make matters worst, 38,000 Lancastrians signed petitions to remove the Honorable
Stewart Dalzell from the federal bench.
Mike Fisher and company won and Lisa Michelle Lambert was back in prison within 9
months while the case went back to the Lancaster County Court of Common Pleas. The Honorable
Judge Lawrence Stengel held a bench hearing where she was again found guilty and sentenced to
life in prison. The case was covered by the LA Times in a multi-part Sunday series, A&E producer
Bill Curtis did a 48 Hours special, and Lifetime Movies made it into a prime time movie.
This year, these "Good Old Boys" made it so difficult for me to litigate my efforts to free
Lisa Michelle Lambert, that I had to dismiss my appeal and effectively withdraw as her MOVANT
and Advocate. I was trying to persuade the courts that my own demise was the result of the same
type of wholesale prosecutorial misconduct by some of the very same principals that Lisa Michelle
Lambert fell victim to. My efforts were so distasteful to the powers to be that her court appointed
attorney threatened me with criminal prosecution for no other reason than I might actually be
successful in helping her win the Habeus Corpus she filed in May of 2014. I allege the U.S. District
Op Ed Letter re Kathleen Kane
Page
Page11ofof29
Monday,
Sunday, January 25,
24, 2016

Page 67 of 2301
Page 24 of 63

Judge was trying in vain to invalidate and derail my own federal court cases that seek to restore
me to whole from a life of ruin, misery, torture, and financial collapse.
For the record, I founded a financial firm in the 1980's that reached 5 states and raised
some 90 million dollars in a matter of 9 months. In the late 1980's and early 1990's I was one of
5 domestic companies that had the capabilities of manufacturing CDROM's that included a client
list that reached across the globe and included government agencies and fortune 500 companies.
And in 1987, myself and a genius recording engineer named Tony Bongiovi and his famous
recording studio, Power Station Studios of New York, were developing and producing the first
"digital movie". The intellectual property rights and the RICO statutes that apply to my legal
claims in federal courts were too much for the "Good Old Boys" to handle.
_____________/S/___________
ACTIVE COURT CASES
U.S.C.A. Third Circuit Court of Appeals Case No. 16-1149;15-3400; 16-1001; 07-4474
U.S. District Court Eastern District of PA Case No. 15-03984; 14-02559; 05-2288; 06-4650
Superior Court of Pennsylvania Case No. 1561 MDA 2015; 1519 MDA 2015
Lancaster County Court of Common Pleas Case No. 08-13373; 15-10167; 06-03349
Op Ed Letter re Kathleen Kane
Page
Page22ofof29
Monday,
Sunday, January 25,
24, 2016

Page 68 of 2301
Page 25 of 63

Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
November 12, 2015

Ms. Kathleen Kane
Pennsylvania Attorney General
16th Floor Strawberry Square
Harrisburg, Pennsylvania
Re: Old Boys Network filed in GENERAL OAG QUESTIONS November 11, 2015
November 11, 2015 7:42am
"Kane, the first woman and Democrat elected to the position of Pennsylvania's top
prosecutor, has dismissed the case as a backlash over her challenge to what she
calls the old-boys' network in Pennsylvania law enforcement." LNP, Attorney
General Kane faces trial on more charges, by the Associated Press on November 11,
2015.
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.
Stan J. Caterbone Advanced Media Group
717-669-2163
See the enclosed as well as U.S.C.A. 15-3400 LISA MICHELLE LAMBERT APPEAL,
APPELLANT, Stanley J. Caterbone, Pro Se
https://www.scribd.com/doc/284639091/Federal-Whistleblower-and-TargetedIndividual-of-U-S-Sponsored-Mind-Control-Executive-Summary-Updated-October12-2015
Stan J. Caterbone
Newslanc
Op
Ed Letter
Letter
re Kathleen
to the Editor
Kane
Page
Page
Page333of
of
of699
Wednesday,
Tuesday,
Monday,
December
January 25,
15, 2016
20,
2015

Page 69 of 2301
Page 26 of 63
Newslanc
Op
Ed Letter
Letter
re Kathleen
to the Editor
Kane
Page
Page
Page444of
of
of699

Wednesday,
Tuesday,
Monday,
December
January 25,
15, 2016
20,
2015

Page 70 of 2301
Page 27 of 63
Newslanc
Op
Ed Letter
Letter
re Kathleen
to the Editor
Kane
Page
Page
Page555of
of
of699

Wednesday,
Tuesday,
Monday,
December
January 25,
15, 2016
20,
2015
Case:22,
15-3400
Sunday January
2017
Document: 003112153497
Filed: 12/14/2015
Page 71 of 2301Page: 1 StanDate
J. Caterbone
LAMBERT CASE FILE
Page 28 of 63
scaterbone@live.com
717-669-2163
Stanley J. Caterbone, APPELLANT, Pro Se
1250 Fremont Street
Lancaster, PA 17603
IN THE UNITED STATES THIRD CIRCUIT COURT OF APPEALS
_______________________________________________________________________________
Lisa Michelle Lambert
:
PETITIONER
:
:
v.
:
CASE NO. 3400-2015
:
Lynn Bissonnette, et al.,
:
RESPONDANT
:
:
Stanley J. Caterbone
:
APPELLANT
:
MOTION TO DISMISS
_______________________________________________________________________
I hereby on this 14th day of December, 2015, I Stanley J. Caterbone, appearing pro se, as
the APPELLANT do hereby file a Motion to Dismiss the above captioned appeal for reasons previously
affirmed in previous filings.
/S/ Stanley J. Caterbone

Date: December 14, 2015
Stanley J. Caterbone, Pro Se Appellant

1250 Fremont Street
Lancaster, PA 17603
(717)-669-2163
http://www.amgglobalentertainmentgroup.com/__
Newslanc
Op Ed Letter
Letter
re Kathleen
to the Editor
Kane
Page
Page
Page666of
of
of699
Wednesday,
Tuesday,
Monday,
December
January 25,
15, 2016
20,
2015
KEISLING: Palace coup: what the Kathleen Kane prosecution is really ...
1 of 3

December 9, 2015
http://newslanc.com/2015/12/09/keisling-palace-coup-what-the-kathleen...
Page 72 of 2301
Page 29 of 63

Letters to the Editor, News and Commentary
Breaking: Kanes staff has approved one of two contracts needed to hire a special prosecutor to investigate the porno email
scandal
by Bill Keisling
Have Republicans in the top levels of Pennsylvania government and courts engineered a takeover of the Democraticcontrolled state attorney generals office?
Has this high-level palace coup taken place under everyones noses?
Are the criminal charges brought by Republican officials against AG Kane, her subsequent
law license suspension, and efforts by the state senate to remove her from office all simply
a ruse meant to distract voters from what is really going on: an attempt by Republicans to
control policy in the attorney generals office, and throughout state government, without
having won an election?
Recent developments in all three branches of Pennsylvania government make these
reasonable questions.
Several weeks ago, on November 18, four high-level staffers from the AGs office testified
before the state senate committee exploring AG Kanes removal from office that theyve
been running nearly all the offices legal functions since Kane could no longer practice law.
First Deputy Attorney General Bruce Beemer, and three executive deputy attorneys general
Robert Mulle, James Donahue, and Lawrence Cherba testified they have effectively
Kathleen Kane
taken control of the elective attorney generals office following Kanes unprecedented law
license suspension.
First Deputy AG Beemer is a holdover from the days when Republican Attorney General Tom Corbett ran the office, before
Kanes election in 2012.
When she came into office Kane probably thought Beemer was a nice guy, and a competent and experienced career
prosecutors, who should be kept around.
But did Attorney General Kane make a mistake not having her own loyalists in these top positions?
Several weeks back, Beemer and the other three made a splash at
the senate impeachment committee when they spoke about the
importance of the many criminal cases the office was responsible
for handling.
But criminal cases prosecuted by the AGs office are, from a public
policy perspective, small potatoes.
The state AGs office is a johnny-come-lately in criminal
prosecutions. Before the office became an elective one in 1980, the
AGs office seldom if ever prosecuted criminals. (Criminal
Four guys running the AG's office: who voted for them?
prosecutions, before 1980, were referred to local DAs.)
Newslanc
Op
Ed Letter
Letter
re Kathleen
to the Editor
Kane
Page
Page 77 of
of 99
Wednesday,
Monday, January 25,
20, 2016
1/20/2016 5:25 AM
2 of 3

Page 73 of 2301
Page 30 of 63
For centuries, the most important job of the Pennsylvania attorney general has been to issue opinions on the legality or
constitutionality of state actions or programs.
Opinions issued by the Attorney General can and do concern the nuts and bolts of how state agencies are run from the
legality of programs, to who is hired, to how paper clips are bought, to the treatment and execution of prisoners.
Legal opinions of the attorney general carry the full force of law, until and unless a court overturns them.
Beemer and his three associates, testifying before the state senate, played down these important constitutional
responsibilities. These days, Beemer said, the AGs office rarely if ever issues important opinions on government or interagency matters.
Two recent and important issues demanding high-level decisions in the AGs office clearly demonstrate this is not true.
The first issue is a constitutional matter: the state senate is set to vote on whether to hold a hearing to remove Kane from
office, bypassing the constitutional impeachment process. Its the historic role of the attorney generals office to intervene on
questions of the legality of removing an official from office.
The second issue is a personnel, or contract, matter: The contract for Kanes choice of the special prosecutor to investigate
the court pornography email scandal must be reviewed and approved by her office.
AG Kane selected Douglas Gansler, a former Maryland attorney general, and his Washington DC-based law firm, to review
the hundreds of thousands of emails Kane found on her office servers.
But contracts hiring Gansler and his firm must be approved and signed by the attorney generals office staff.
The responsibility to review and approve Ganslers contract fell to one of the four AG office employees who testified several
weeks ago before the state senate panel to remove Kane: Robert Mulle, the executive deputy attorney general of the civil
law division.
Two employment contracts, one involving Gansler and the other his firm, landed on Deputy AG Mulles desk last week. Mulle
evidentially at first objected to the form and content of the special prosecutor agreements.
Kanes spokesman, Chuck Ardo, tells me, (Deputy AG) Mulle was able to work with Kane to massage the first of the two
contracts, about the firm.
That first contract has been signed, Ardo says. But Ganslers personal contract has yet to be approved, or signed.
They are still working on Ganslers contract, Ardo says. But she certainly got the first part approved.
Needless to say, the last thing state Republicans want is an unfettered special prosecutor looking into hundreds of
thousands of correspondence found on the AGs email servers.
Likewise, the attorney generals office must soon respond to the senates demand for a hearing to remove Kane from office.
Those running Kanes office apparently dont seem to be in any hurry, or think its their job, to weigh in on the constitutionality
of the senates proposed action.
But, it should go without saying, if a Democrat-controlled senate were to try removing a Republican attorney general in this
matter, the court papers already would be flying.
Likewise, if the porno email scandal involved mostly Democrats, instead of mostly Republican prosecutors and judges, a
special prosecutor would likely already be on the job.
So Kane finds herself having difficulties directing her own staff to work on these two important matters.
Three million Pennsylvania voters elected Kane. Voters didnt elect her staff members.
Newslanc
Op
Ed Letter
Letter
re Kathleen
to the Editor
Kane
Page
Page 88 of
of 99
Wednesday,
Monday, January 25,
20, 2016
1/20/2016 5:25 AM
3 of 3

Newslanc
Op
Ed Letter
Letter
re Kathleen
to the Editor
Kane
Page 74 of 2301
Page 31 of 63
Page
Page 99 of
of 99

Wednesday,
Monday, January 25,
20, 2016
1/20/2016 5:25 AM
Woes across government branches tarnish Pa.'s image, experts say
1 of 3

http://triblive.com/state/pennsylvania/9844432-74/state-political-budget?...
Page 75 of 2301
Page 32 of 63

(https://twitter.com/BBumsted_Trib)
1/25/2016 5:22 AM
2 of 3

Page 76 of 2301
Page 33 of 63

1/25/2016 5:22 AM
3 of 3

Page 77 of 2301
Page 34 of 63

1/25/2016 5:22 AM

Page 78 of 2301
Page 35 of 63


Page 79 of 2301
Page 36 of 63


Page 80 of 2301
Page 37 of 63


Page 81 of 2301
Page 38 of 63


!
$% &
'
"
Page 82 of 2301
Page 39 of 63

( )!
*+ ,
!
"
'
0
( .
.
"
.
1
(.
'
2 34 5"678!8.47 !73 896 ):6 6:;!8.47 4& 896 8:589

&
!
>
(
4
<=* .
.
(.
-
(.
$ "#
%
&
"
"
"
#
(
"
"
&
"
"
"
'
"
? ?
2
7
'
(
(
"
(
8
'
B1
)
!
!
<( $
C
<
(
(
&
D

B.
Page 83 of 2301
Page 40 of 63
C
8
6/
7
1
!
E

" (
C
9!8:63
'
.G1!7
6;6:>476
8
.
"
( H8
(
'
&
"
"
(
>
(
!( (
%
) *+ ,
.
'
% "
*
' 0
%'
'
2
'
"'
,
*
*! 1'
%
#
( 2
' 3
4
"
5(
/
>
&
=( $
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 84 of 2301
Page 41 of 63

!
'
" #$ $ %
)'
&
%
%)
*++
!
$
'
"
"
'
8 '
(922
(
2'
"!
( )%
"% .
"
"## $"
-$
&
0
$
$
$
$"
$
$
%,11
/
$
1
2$
!%
!%$
!%+
!%$
%
$
1
1
$) ! !
$
$
$
1
&
%
-! ) * . *++
-! ) . *++
/0
'
'
2
*
5 #$ '
69
"
*
"# - /
0
*
1%
"
!%
Page 1 of 16
%&
&
, - .$
"
%' ( )*+*
'
'
%
',%
)' +
#
2
6
(34
0
Page 85 of 2301
Page 42 of 63

,
-$
%!
""
3
"
1-
""
! $
$.
&/. 6
! )
! )
"
) .
"
!
$
$.
"
%
""
"
).
$
.
%
?
.&
"
"
)<
<
<
"
4 ** )
"
%
"
"
$&
-$
2
+A $ @
%
%!
>
). %
/!
"
'@'
>
%!
<
-$
"
)<
"
A "
>
$
"
"
%!
@
D.+++
3"#
?
./%& 01%&2
% )
$
"%/
."
"
" %$" , 7
)
$
%$"# "34
#.. "
" 6
. B
%
.B
%!
""
#$ $ B
"
Page 2 of 16
&
"
'"%
&"%
&
! ) "6
6 "%%
/
"
*$
).
4%
!
%
)
"
;!%
"
*3.
:!
" ' "
-!
'
"
!
5
-$
"
!%
"
" !
%!
!%. 6
)$
"
' %
-$
&
2 !
"
/!
** )
"!
" "
,
'
"
Page 86 of 2301
Page 43 of 63

"#. "
) "' "
8"%
88'
'
"
. "
&"% , /$. "
#"4.
%% %
) "
@""
:!
!/
%
/!
!
"'
%
9
&
"
#$ $
*
=
!
%
)
;
%
)
) .
)
"
"
!
8 2.
"!
" /
"
1
)
"
8 >
!
"
<
'
"
9$
"
3 %
/3"#
%
<
":# )*6)*
9
% ;
) -
<
-! )
) <
! )
.
$
"
.
":#6 /
1
"
>
?
"
& # %/"#.
"
)
" = %
"
'
: !
"
B
. "
"
&
%& " 6 %& "

"
!
!
#$ $
" '
#$ $
&". "
8
)
"9
'
$
!
B
"
"
) !
/! "
$.
-$
&/. 6
"
$.
$
<+==*<**(> 6
%
"
-$
"%/
;
+;++ H 6
7 $ D
!
!
"%/
=
2.
$
!
)
A
!
;
"
" 6
G
% =
$
B
!
!
!
!
9 )
-$
.
""
"
F %%
)
9
=
"
.6
.
B
. 2. 6
)$
%
;
.%/# 4."%
*++D
%
**
#$ $ '
! )B
.
"%/
&"%./
#
!
$ $.
;
" :
+;++ H 6
. #
%
"
G 8 !
&
'
Page 3 of 16
" B
! )
!
2 .
%
% B
)
"
-
/!
' %
(=8@>( $ 6
$
+D;
Page 87 of 2301
Page 44 of 63

%
%
%
B
?%
"%/
) -
+;++ H 6
%
) !
"
%
6
"
.
) #$ $
B
-
*++
B
.
%
!
2$
<
>
""
!
.
<
)
<
< "
!
.
% $
)$
!%
<
<
". !% !
5! )
$
"
"
!%
"
"
"
;!%,
)
%
-$
"
) "
(4
7?
%
"
)%
!%
"
"
%
!
)
)
"
)
"
< %!
"
"
% %!
"
! <
"
<
"
; !
< "
!%
!
/!
"
"
$
.
$
!
!
). "
)
""
%
1 %
"
)
5!
#$ $
"
! $
) "
" 6
!)
"
$.
)
%! !
)
Page 4 of 16
$
.
Page 88 of 2301
Page 45 of 63

,
)
"
. "
5!
) .
>
"
"
% 4
"
)
>
" 5!
"
" %
!
.
"
"!
$ 8
= %!
! %
2 )! %
*++D
-$
".
'
" B
$
"%8
44"
#"
" /
5 "%
8"%
5 )**?
"4 "38"%
& ." !" #"
I. *++D
2
#
.
%%
2 !% )
&
) B
/ $ /
8# % ! /
2 !% )
."
8" !
5 @ # /!"
"
$.
$ +D;
8' 4
./%&
/%! /
"&
-$
"
B
%
." #"! %/ '
"
"
/55
& & " 4% !"##
-$
!
:/ .&% :
." ! #" :/
"
'
& . # 8""
& )
"
.
!
$ +D;*3+D $
"
!
5 )**?
'
# !!"##5
%%
"&
& &"#/#
(=8@>( $
# 0*(<>>(>2 /
./# ! #" /# # /
5 ";/&" !"
**
#$ $
" ' "
'
' %
-$
"!
) %
%
"
$ :
J 2
!%
"
"
) "
$ '!
"
*++D
"
) '
!
!
5!
" !
; @
"
?
%
2
)
7
@
$
!
"
?
"
%!
!
+A
-$
Page 5 of 16
" "
) %
.
Page 89 of 2301
Page 46 of 63

K
K$
"
. % 2
B
)%
#$ $
!
&
*++D$
"
6 !
. !
"
! !
! !
)<
) "
; !
!
"
9!
! .
(=8@>(
&
!
$.
"
+D;
;**
-$
3 )
#$ $
@""
)$
"
"
"!
)A
-$
#$ $
"
"
$ &
"
! $
-$
%%
*H1
"
) B
""
"
"
! )
$ 6
"
)
!
#$ $ '
)< )
) 2
*++D
%
. =
"
! !
% $
"
"!
8!
"
"
*++I
%
" *++
-$
)<
<
&F #6 =
! %
<
,
" ) !
B
"
"
"
3 "
"%8
"
%$.
"
" 6
-$
).
2
."%
"
)
2
!%
? %
"
!
8
?
!
)
&
!
Page 6 of 16
"
&
2
)
!
!
$
$ :
$
Page 90 of 2301
Page 47 of 63

."%
"
3 "
.
%
"%8
? %
."%
"
. 3 # 7
.
-$. 8 %
". !""
&
"
"
"
"
-$
"
%'
2 )
.
! %
"
!
.
. !
' =B
!
)
< ""
"
-$
<
$ :
-$
)
"
"%8
"
"
"
% %
<
" &F #6 =
"
:
%
"
#$ $
2
%
>
).
)
%
%
!
)
"
&
"
HI
$ :
H3
"
"
.
. %
$ 8)
) "
%
%
>
)1
!
),
$ :
)
"!
"
."%2
/!
"
"
"
3 "
" ' "
"
. - $.
"
" &F #6 = $
' %
"
4%
"
<
I+A
"
' %
"
6 '
) '
! %
"
" &F #6 =
"
' "
&
>
2 ) %
"
'
%
"
&
2 ) %
8%
2
)
3/ ' ,/#
%)%
."
- $.
'
"
"
)$
)
"
". !""
"%8
"
)2
"%8
!""
".
"
%
Page 7 of 16
B$
.
$
!""
$
+A $ :
B2 .
"
?
I+A .
. - $.
Page 91 of 2301
Page 48 of 63

"
$
2
%)$
#6 = $
(
)
"
!
$
. B
)
%
!%. 6
% $
" "
"
"
!
"
)
) B
"
. -!
) "
"
"
"
"
)-
"
" 0 %
."%2
!
2
"
"
"
).
@A8
)
!
" 6
!
"
. - $.
"
-!
" 6
"
"
* .
$. J !
"
/
. -$
K$
!
B$
) "
! !
) B
$.
&
. - $.
" &F
%%
"
" 6
$
.
@='(=
)
"
B$
"
&
7*++$++
-!
" 7 +$++$
! %
6
"
%) (4%
&
.
-
. - $.
" "
B$
2
' %
! .
"
)$ J !
"
3 "
.
-$
"
"%8
"
6 '
"
"
B!
/!
$
A @""
"
!
"
% )
*$
8)
K
" ! %
)
%
$
)
"!
"
"
"
Page 8 of 16
)
8
!%
2
"
>
"
6 'K
-$
) "
!
.
"6 '"
! 5
"
$
"
" " ! % )
.
:
H.
!
. B
*D.
2 )
!
"
H.
"
""
! "
-$
$
"'
"
%
)/
-
+$
&F #6 = $
) /
9!
"
"!
"
"
"
"
4%
*3.
" $
? %
$
Page 92 of 2301
Page 49 of 63

. 3 #
!
"%8
"
' %
8
8%
"
%
"
" B
-!
"
D$
(=8@>(
$ 6
"
) B
"
/!
"
9! )
$. +D;
' B
" 6
>
"
"!
2.
*3*3 >
-$
%
"
'
B2 .
"
% %
2 )
" #
)
.
-$B$ &
" B
"
"
2.
"
&
' B
;**
B$
.
"
B$
"
$ B
. B
%
$
$
-
&
I$
'
!
$ B )
!
B$
&
"!
"!
"!
'
"
#6 @> 8 >F
)
2 7 *.+++ "
'
2 )
"
??
"
!
! "
."%2
!
;;
" 0 %
"
"
&$ F
" 6
"%8
4
#$ $
" /#
%"3
"
!
!
)
"
"!
#
4
6
" !
$.
)
!
-$
%
) 8
$$
!%. 6
"
.
-$
&
)
"
.
"
$.
Page 9 of 16
K'
%
/
&
!%.
K<
?!
)
/
"
&
. "
.
&
4%
" ! )
+$
%
"
-$
%!
" B
!%. 6
).
"
-$
""
& B
&
.
8
$
$ 6
2 )
D.
!
!
-$
"
%
"
%%
*; %
!
).
"
L
"
-$
2$
"
!
"
"
%
!
" ;/":"%.
$
7*+.+++
"
I
Page 93 of 2301
Page 50 of 63

"
4
%%
"
"
." 3"
) 7 ++.+++
."
"
" <
";/":
"
9! )$
. ./#
%'
& ." !%/3/

!
%"! %&#
@ *
)"
%
9! 2 )
%!
&
"
K
." : %& D "

"
!
:
<
+ E .
";/":
." 1
!
)
."
%/3/
/!/&"
" 6
$
)
. B
" 6
) >
' %
"
"
-
E . *++D
. *++
:
! !
"
3+*
) -$
"
-$
%
) <
<
-! )
"
<
. B
"
" $
%
!
"$
& )
< "
%%
"
%%
' %
)
"! %&
) "
"
)$
"&
)B
#A " ! A
)
8%/!
#/
%
) (
"
""
8!
) F
A &"
"
K$
#/
#$ $ '
"
"
)
%%
"
*++
"
(=8@>(
'
"
,
B!
B
!
"
""
<
"
6
"
"
"
<
)
++
%
)
)
"
3.+++
<
-$
!
<
H+.+++
';=@&
"
-$
"
>
!
"
"
&
!%.
B
6
4
"
#$ $
#$ $
"" $
"
% )
@""
<
%
< 6
Page 10 of 16
<' %
(
"
< 6
< 6
"
"
!
:
Page 94 of 2301
Page 51 of 63

% < &
!
"
3 "
"%8
< 6
"
3' 8%
"
-$
% < &
<
3 "
"
"%8
" 3' 5
<
< 6
!
%
(
.
"
B!
>
$.
< 6
< =
!%$
%
$
"
<
. 6
< 6
1%
% <
' "
"
$
$
!%$
$
$
1
!%+
$"
2$
1
$
$
1
$
$
$
%,11
$) ! ! $
1
$ =(('@&
: $ @&
) /!
."%.
!
% <
@""
."%.
% %
% <
!%
Page 11 of 16
!
(
'
<
"
4
&
!
% %
<
Page 95 of 2301
Page 52 of 63

,
MM
8""
/# /34 %
! 33"%!/
#/ $
"3
5 "
"
"!%"
/E"& 8' ! %4 %
8%
% "&
'
"3
D "&/ 3D
&! #
# !
5 3 #
"94"%/3"
#"!%" /;" 5 % #
&% 3
" .
/":"%#
." ";
./#
7,
"
/":"%
, -! ) * . *++
-$
&
/ !%
0
$
$
$
!%$
$
$
1
!%+
$"
2$
1
$
$
1
$
$
$
%,11
$) ! ! $
1
"
3"%/!
& !"%
# 5 % %" &
'#/#
"!.
$/"# 8 %
5 ."
&
." %"#
/ $
' 8""
#" #
"!.
& "94"%
$ "#
"# /5/"&
!%$
%
$
1%
"
!%
Page 12 of 16
"
/":/ $ . # %"!"
" F** ! 34
"4 % 3"
$/!
&;
#
!"3"
%'
./# # 3"
"
./# /#
"5" #"
# !
."
5 ." " &/ $

/
%"
. & %"! %&"&

: #
'
/"#
& 3 % " 5 %"! # #
#"& /
' = )**?
# :/ .
"3
./# . # %"!"
#
5 ./# :%/ / $
'
" ";/#/
% &/
/;"
.'#/!/#
Page 96 of 2301
Page 53 of 63

"4 "38"% ( )**=
-$
&
!%
*D+
6
.B
'
I+3
2=
:
B$@$ 8 4
+**
.@
HD*+
B
; ++;D ;DI
4 ; II;H33;H +
, " 0"
"
"- #
;"%
'
2.
&) %
&
! $ '
:
) !
)$
) !
2
5
!"G
%;"/
'
! # "%
2.
) N
';=@&
."
)
"
. "
2
2
$
"
:
$
2
*++D
%
"
"
$K
?
6
2
$
%
+A
%
)1
&
/ !%
!"
!
&
';=@&
!%$
.
!
"
)$ 8
.
$
+A
G
"
9$
$
>
"
"
"
)
% )
"! "
! 6
"
2
"
ID
":
)$ >
!
4$
6
!
"
2
"
"
&
"
"
"
!"
:
>
%
)
/ $
" )
)
4%
/E"&
+D
%$
"
5 %
!
$
<
$'
1
'
6
%
& B"%
"
6
)
!%
"
) " ! "!
"! $
. 6
.
2
) !,
#' ;
"
) )
$ =
"
2. 5!
!
4% !
6
)$ K
% %
"
/ 6;
#$ $ ' %
>
8
" -!
Page 13 of 16
"@
3 .
#$ $
Page 97 of 2301
Page 54 of 63

"
'
7 8
! $
2
>
"
B
* "
). 6
/ 6;
!
"
.
"
) K
"
$
)
!
"
&
>
"
%
!
$6
%K$ /
)K
%
:$ 8!
K
"
!
'
9
)
>
! "
> $ *++I;
. =
A
)
9!
"
. %
%
"
;* I+ "
"
" ) ! "
"
&! 2
%%
2
'
,++,++ ) !
=
"
6
.
)$ :
>
>
. A
!
8
),
>
). "
#$ $
%
"
!
"
!
!
%
!
)
F
$
)
%
B
%
.
""
%
!
"
$ /
);
).
!
"
"
!
! ! $8
!
8 >
>
- !
!
) 3+.
! !
)A
2%
"
1>
. /
I
>
).
2
A
""
"" "
)
$O*3P
B
%
'
' %
.
%
" =
"
"
). " "
!
%$
H$
A
%
%
>
%
"/
2
"
$O**P
)
.
)
'
%.
% 5
$
!
: % $
$
)
!
C.
"
).
"
!
!
%
!
!
+A .
.
%%
"
%%
!
4%
)
4 !
!
%
$ K:
"
!
2
A
!%
>
/
4
%%
#$ $ "
.
")
!
"
%
"
>
).
% )
""
2
8!
. 8!
B
&
>
2
.
% )
! ; ! $ $$$ 8!
.
%%
"
!
!
B
$ 8!
!
"
$
)
%
$
.
)
).
%
$
)
4
H. "
).
""
$K J !
$
:$ 8!
! ) *+.
>
"
> !
&
& ) *3.
G
8 >
%
.
!
6
$ -
& ) 3. *++
"
) !
)
"
"
)
%%
9$ @"
)$ 6
$8!
' "
!
"
)
"
!
%
F %%
)$
"&
"
4
/
$ 6
.
%
"
#$ $
"
) = %!
"
/
"
"
).
& ) *3.
"
3D
"
) . "
.
%
!
;
O*HP
Page 14 of 16
.
!
"
.K
)
"
Page 98 of 2301
Page 55 of 63

>
"
8
"
'
)$
. "
%%
%
3
!
8
"
"
%)
8
I$
A "
4%
$
$
)
B
)
(=8@>( $ 6
! "
(
"
$
*++I
'
"
'
!
)
%
$
) >
*$ :
%
>
'
B
2$ :
4%
!
"
.
%
!
:
:
!
)
!
$
!
)
"
"
Page 15 of 16
)
"
/
B
"
"
!
""$
@%
' "
%
)
" ' "
%
)
!
#$ $ '
)
"
)
""
%
!
!
A
"
"
%
2 %
)
' "
2
"
)
)
!% "
)
"
%
/!
2
B
2
. )
%
)A
"
"
*. *++D "
' 2
2
B
"
%
%%
! .
$
$
" *++D
) *
"
&
) &! ! .
)
. '$ B
%
$
! !
*
"
' %
!
) :
@
)
)
)
$
)
!
2
!%
"
$
! ) B
. $ $.
> $ *++D; ;+*
'
" B
)
$
"
."
).
-! )
) = )
).
)
.
)
2
2 ) !
. )"
"
$
$K
%
"
"
-! )
)$
"
.
8
"
2%
/!
A
% $
2
=
. ( 9$. " 6
!
6
6
)A /
! ) !
$
>
H.
' "
)
K
$K )
.
%
)
"
&
) >
&
"
"
;
! )
"
) %
" '
. " B
%
$
?
>
!
% )
%%
)A$
.
.
"
.
"
> )%
,
:$ 8! . "
B
"
#
/!
.B
!
"
) = )
. "
'
"
>
G
.
$
&) "
.
! B$
.-$
: "
.
! -$
. $
/
>
). "
=
5!
/
$ 8!
"
> )$
$
> 4
). '
/
8
&
>
G
"
K $ $ $ $
A
"
8
) = )
) B
9!
% !
"
%%
>
) = )
/
"
"
2
2 8 )
$
Page 99 of 2301
Page 56 of 63

&) "
)
!
!% 5!
"
!
%
8
)"
+
B" !
2 !% )
"
.
.
3.
2
2; ;%
-$
$
$
$
$"
$
$
%,11
/
$
$
$
!%
!%$
!%+
1
2$
!%$
%
$
1
1
$) ! !
$
$
!
"
>
D$
"
&
0
$.
$
1
1%
"
!%
Page 16 of 16
.=
LETTER: LNP remains a lily-white newspaper | Newslanc.com
1 of 1

http://newslanc.com/2016/04/24/letter-lnp-remains-a-lily-white-newspaper/
Page 100 of 2301

Page 57 of 63

April 24, 2016
Featured, Letters to the Editor, News and Commentary
Comments
Re: LNP takes cheap shot at Hillary Clinton by publishing Lewistown Sentinel bogus editorial
NEWSLANCS editor responded to a comment: EDITOR: We believe there has ben a significant
improvement at LNP over the past year or two While we find fault with them from time to time, we also
have reason to be displeased at times with reports in the New York Times and other leading publications.
The following is a response by someone else to our comment.
Improvement? Really? LNP remains a lily-white newspaper which refuses to acknowledge or challenge
the governmental, judicial or business Power-Elite. They continue to self-promote themselves at every
and any opportunity, and go on witch-hunts after those who may have crossed their paths. They refuse to
provide any substantive details regarding the financial albatross that occupies the adjacent block of Penn
Square, and are content to only report on their perspective of vibrant, robust downtown, without
acknowledging the abysmal streets, on-going violence and ever-increasing tax burden that is driving
residents out of town.
Of course, I suspect most LNP reporters/editors dont call the city their home; so in the immortal words if
Hillary Clinton..What difference does it make?
Share
4/30/2016 1:40 PM

Page 101 of 2301

Page 58 of 63

Stan J. Caterbone

1250 Fremont Street

Lancaster, PA 17603
scaterbone@live.com
717-669-2163
April 20, 2016
Stan J. Caterbone/Advanced Media Group Biography

Present - Advanced Media Group, President, Owner, and Founder.
In 1987 I 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 I am connected 24/7 with
the same person who declares telepathically she is a known celebrity. Over the course of 10 years I
have 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.
I have 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 2015 I filed an amicus curie on behalf of Lisa Michelle Lambert who was convicted in 1992 of the
murder of Laurie Show, both of Lancaster, Pennsylvania. I currently am in litigation in the U.S. Third
Circuit Court of Appeals and in February of 2016 Lisa Michelle Lambert published her book titled
Corruption in Lancaster County My Story, which is available in bookstores and on Amazon.com. I
am in frequent contact with her co-author, Dave Brown of Philadelphia, Pennsylvania.
Stan J. Caterbone/Advanced Media Group Biography Page 1 of 6
Wednesday, April 20, 2016

Page 102 of 2301

Page 59 of 63

In 2009 I Proposed an ORGANIZED STALKING AND DIRECTED ENERGY WEAPONS HARASSMENT BILL
to Pennsylvania House of Representative Mike Sturla (Lancaster, Pennsylvania) and City of Lancaster
Mayor Richard Gray in 2009. The draft legislation is the work of Missouri House of Representative Jim
Guest, who has been working on helping victims of these horrendous crimes for years. The bill will
provide protections to individuals who are being harassed, stalked, harmed by surveillance, and
assaulted; as well as protections to keep individuals from becoming human research subjects, tortured,
and killed by electronic frequency devices, directed energy devices, implants, and directed energy
weapons. I again reintroduced the bill to the Pennsylvania General Assembly in 2015 and frequented
the Pennsylvania Capitol trying to find support and a sponsor; which I still do to this day.
In 2006 I began his role as an Activist Shareholder for Fulton Financial, which is listed as "FULT" on the
NASDAQ stock exchange. As a founder of Financial Management Group, Ltd., a full service financial firm,
Stan J. Caterbone has drawn upon the success in developing the strategic vision for his company and
the experience gained in directing the legal affairs and public offering efforts in dealing with Fulton
Financial. I have been in recent discussions with the Fulton Financial Board of Directors with regards to
various complaints dealing with such issues as the Resource Bank acquisition and the subprime failures.
I believe that Fulton Financial needs management to become more aggressive in it's strategic planning
and the performance it expects from it's management team in order to increase shareholder value.
Expanding the footprint of the regional bank has not yielded an increase to the bottom line that is
consistent with the expectations of shareholders. Lancaster County has seen several local banking
institutions acquired by larger regional banks, thus increasing the competition Fulton Financial will see in
it's local marketplace as well as in it's regional footprint.
In 2005 I, as a Pro Se Litigant filed several civil actions as Plaintiffs that are in current litigation in the
United States District Court for the Eastern District of Pennsylvania, the United States Third District
Court of Appeals, the Pennsylvania Supreme Court, The Pennsylvania Superior Court, the
Commonwealth Court of Pennsylvania, The Court of Common Pleas of Lancaster County, Pennsylvania.
These litigations include violations of intellectual property rights, anti-trust violations, and interference
of contracts relating to several business interests. Central to this litigation is the Digital Movie, Digital
Technologies, Financial Management Group, Ltd,/FMG Advisory, Ltd., and its affiliated businesses along
with a Federal False Claims Act or Federal Whistleblowers Act regarding the firm of International Signal
and Control, Plc., (ISC) the $1Billion Dollar Fraud and the Export violations of selling arms to South
Africa and Iraq. This litigation dates back to 1987. Stan J. Caterbone was a shareholder of ISC, and was
solicited by ISC executives for professional services. The Federal False Claims Act is currently part of
RICO Civil Complaint in the United States District Court for the Eastern District of Pennsylvania and the
Third Circuit Court of Appeals, as docket no. 05-2288.
In 2005 Advanced Media Group/Project Hope filed a Civil Action in the Court of Common Pleas of
Lancaster County against Drew Anthon and the Eden Resort Inn for their attempts to withhold the
Tourism Tax and Hotel Tax that supports the Downtown Lancaster Convention Center & Marriot. We also
proposed an alternative plan to move the Convention Center to the Hotel Brunswick and Lancaster
Square to all of the major stakeholders. The Lancaster County Convention Center is finally under
construction with a March 2009 Opening date.
In 2005 I was selected to attend the Clinton Global Initiative in New York City after submission of
an essay with and application. I received the invitation from Bruce R. Lindsey, Chief Executive Officer of
the William J. Clinton Foundation.
In 2005 I began our philanthropic endeavors by spending our energies and working with such
organizations as; ONE.org, Livestrong.org, WoundedWarriors.org, The Clinton Global Initiative,
Lancaster Convention Center Authority, Lancaster Chamber of Commerce, Toms Project Hope, People to
People International, GlobalWarming.org, Contact Lancaster/24 Hour Suicide Hotline, Schreiber Pediatric
Center, and numerous others.

Page 103 of 2301

Page 60 of 63

In 2004 I embarked on our past endeavors in the music and entertainment industries with an emphasis
on assisting for the fair and equitable distribution of artists rights and royalties in the fight against
electronic piracy. We have attempted to assist in developing new business models to address the
convergence of physical and electronic mediums; as it displaces royalties and revenues for those
creating, promoting, and delivering a range of entertainment content via wireless networks.
In 2000 to 2002 I developed an array of marketing and communication tools for wholesalers of the
AIM Investment Group and managed several communication programs for several of the company
wholesalers throughout the United States and Costa Rica. We also began a Day Trading project that
lasted until 2004 with success.
In 1999 I developed a comprehensive business plan to develop the former Sprecher Brewery, known as
the Excelsior Building on E. King Street, in Lancaster, Pennsylvania. This plan was developed in
conjunction with the Comprehensive Economic Development Plan for the Revitalization of Downtown
Lancaster and the Downtown Lancaster Convention Center for the former Watt & Shand building.
In 1999 I contributed to the debate, research, and implementation of strategies to counter the effects
of the global Y2K threat to the worlds computer technologies. I attended the U.S. Sponsored Y2K
symposium and Conference in Washington, D.C. hosted by the Senate Y2K Subcommittee and Senator
William Bennett.
In 1998 I had began to administer the charity giving of Toms Project Hope, a non-profit organization
promoting education and awareness for mental illness and suicide prevention. We had provided funding
for the Mental Health Alliance of Lancaster County, Contact Lancaster (The 24/7 Suicide Prevention
Hotline), The Schreiber Pediatric Center, and other charitable organizations and faith based charities.
The video "Numbers Don't Lie" have been distributed to schools, non profit organizations, faith based
initiatives, and municipalities to provide educational support for the prevention of suicide and to bring
awareness to mental illness problems.
In 1996 I had done consulting for companies under KAL, Inc., during the time that I was controller of
Pflumm Contractors, Inc., I was retained by Gallo Rosso Restaurant and Bar to computerized their
accounting and records management from top to bottom. I had also provided consulting for the
computerization of accounting and payroll for Lancaster Container, Inc., of Washington Boro. I was
retained to evaluate and develop an action plan to migrate the Informations Technologies of the Jay
Group, formally of Ronks, PA, now relocated to a new $26 Million Dollar headquarters located in West
Hempfield Township of Lancaster County. The Jay Group had been using IBM mainframe technologies
hosted by the AS 400 computer and server. I was consulting on the merits of migrating to a PC based
real time networking system throughout the entire organization. Currently the Jay Group employees
some 500 employees with revenues in excess of $50 Million Dollars per year.
In 1993 I was retained by Pflumm Contractors, Inc., as controller, and was responsible for saving the
company from a potential bankruptcy. At that time, due to several unpaid contracts, the company was
facing extreme pressure from lenders and the bonding insurance company. We were responsible for
implementing computerized accounting, accounting and contract policies and procedures, human
resource policies and procedures, marketing strategies, performance measurement reporting, and
negotiate for the payment of unpaid contracts. The bonding company was especially problematic, since
it was the lifeline to continue work and bidding for public contracts. The Bank of Lancaster County
demanded a complete accounting of the operations in order to stave off a default on the notes and loans
it was holding. We essentially revamped the entire operation. Within 3 years, the company realized an
increase in profits of 3 to 4 times its previous years, and record revenues.

Page 104 of 2301

Page 61 of 63

In 1991 I was elected to People to People International and the Citizen Ambassador Program, which
was founded by President Dwight D. Eisenhower in 1956. The program was founded to To give
specialists from throughout the world greater opportunities to work together and effectively
communicate with peers, The Citizen Ambassador program administers face-to-face scientific, technical,
and professional exchanges throughout the world. In 1961, under President John F. Kennedy, the State
Department established a non-profit private foundation to administer the program. We were scheduled
to tour the Soviet Union and Eastern Europe to discuss printing and publishing technologies with
scientists and technicians around the world.
In 1990 I had worked on developing voice recognition systems for the governments technology think
tank - NIST (National Institute for Standards & Technology). I co-authored the article Escaping the Unix
Tar Pit with a scientist from NIST that was published in the magazine DISC, then one of the leading
publications for the CD-ROM industry. Today, most all call centers deploy that technology whenever you
call an 800 number, and voice recognition is prevalent in all types of applications involving
telecommunications.
In 1989 I had founded Advanced Media Group, Ltd., and was one of only 5 or 6 U.S. domestic
companies that had the capability to manufacture CD-ROM's. We did business with commercial
companies, government agencies, educational institutions, and foreign companies. I performed services
and contracts for the Department of Defense, NASA, National Institution of Standards & Technology
(NIST), Department of Defense, The Defense Advanced Research Projects Agency (DARPA), and the
Defense Mapping Agency, Central Intelligence Agency, (CIA), IBM, Microsoft, AMP, Commodore
Computers, American Bankers Bond Buyers, and a host of others. I also was working with R.R,
Donnelly's Geo Systems, which was developing various interactive mapping technologies, which is now a
major asset of Map Quest. Map Quest is the premier provider of mapping software and applications for
the internet and is often used in delivering maps and directions for Fortune 500 companies. We had
arranged for High Industries to sell American Helix, the manufacturer of compact discs, to R.R. Donnelly.
We had brokered a deal and the executives from Donnellys Chicago headquarters flew to Lancaster to
discuss the deal and perform due diligence of the manufacturing facility located in the Greenfield
Industrial Park.
In 1987 Power Station Studios of New York and Tony Bongiovi retained me as executive producer
of a motion picture project. The theatrical and video release was to be delivered in a digital format; the
first of its kind. We had originated the marketing for the technology, and created the concept for the
Power Station Digital Movie System (PSDMS), which would follow the copyright and marketing formula
of the DOLBY technology trademark.
We had also created and developed marketing and patent research for the development and
commercialization of equipment that we intended to manufacture and market to the recording industry
featuring the digital technology. Sidel, Gonda, Goldhammer, and Abbot, P.C. of Philadelphia was the lead
patent law firm that We had retained for the project. Power Station Studios was the brainchild of Tony
Bongiovi, a leading engineering genius discovered by Motown when he was 15. Tony and Power Station
Studios was one of the leading recording studios in the country, and were responsible for developing Bon
Jovi, a cousin. Power Station Studios clients included; Bruce Springsteen, Diana Ross, Cyndi Lauper,
Talking Heads, Madonna, The Ramones, Steve Winwood, and many others. Tony and Power Station
Studios had produced the original Sound Track for the original Star Wars motion picture. It was
released for distribution and was the number one Sound Track recording of its time.
Tony Bongiovi was also active in working and researching different aerospace technologies. * We had
developed and authored a Joint Venture Proposal for SONY to partner with us in delivering the Digital
Movie and its related technologies to the marketplace. The venture was to include the commercialization
of technologies, which Tony Bongiovi had developed for the recording industry simultaneously with the
release of the Digital Movie.

Page 105 of 2301

Page 62 of 63

I also created the concept for the PSDMS trademark, which was to be the Trademark logo for the
technology, similar to the DOLBY sound systems trademark. The acronyms stand for the Power Station
Digital Movie System. Today, DVD is the mainstay for delivering digital movies on a portable medium, a
compact disc.
In 1987 I had a created and developed FMG Mortgage Banking, a company that was funded by a major
banking firm in Houston Texas. We had the capability to finance projects from $3 to $100 million dollars.
Our terms and rates were so attractive that we had quickly received solicitations from developers across
the country. We were also very attractive to companies that wanted to raise capital that include both
debt and equity. Through my company, FMG, we could raise equity funding through private placements,
and debt funding through FMG Mortgage Banking. We were retained by Gamillion Studios of Hollywood,
California to secure financing of their postproduction Film Studio that was looking to relocate to North
Carolina. We had secured refinancing packages for Norris Boyd of and the Olde Hickory and were in the
midst of replacing the current loan that was with Commonwealth National Bank. We had meetings and
discussions with Drew Anton of the Eden Resort, for refinancing a portion of his debt portfolio. We were
quickly seeking commitments for real estate deals from New York to California. We also had a number of
other prominent local developers seeking our competitive funding, including Owen Kugal, High
Industries, and the Marty Sponougle a partner of The Fisher Group (owner of the Rt. 30 Outlets). We
were constantly told that our financing packages were more competitive than local institutions.
In 1986 I had founded Financial Management Group, Ltd (FMG); a large financial services organization
comprised of a variety of professionals operating in one location. We had developed a stock purchase
program for where everyone had the opportunity for equity ownership in the new firm. FMG had
financial planners, investment managers, accountants, attorneys, realtors, liability insurance services,
tax preparers, and estate planners operating out of our corporate headquarters in Lancaster. In one
year, we had 24 people on staff, had approximately 12 offices in Pennsylvania, and
several satellite offices in other states. We had in excess of $50 million under management, and our
advisors were generating almost $4 million of commissions, which did not include the fees from the
other professionals. We had acquired our own Broker Dealer firm and were valued at about $3 to $4
million.
In 1985 I developed the Easter Regional Free Agent Camp, the first Free Agent Camp for the
Professional Football industry; which was videotaped for distribution to the teams scouting departments.
(See Washington Post page article of March 24, 1985) Current camps were dependant on the team
scouts to travel from state to state looking for recruits. We had developed a strategy of video taping the
camp and the distributing a copy, free of charge to the teams, to all of the scouting departments for
teams in all three leagues FL, CFL and WFL. My brother was signed at that camp by the Ottawa
Roughriders of the CFL, and went on to be a leading receiver while J.C. Watts was one of the leagues
most prominent quarterbacks. My brother also played 2 years with the Miami Dolphins while Dan Marino
was starting quarterback. We were a Certified Agent for the National Football League Players
Association. Gene Upshaw, the President of the NFLPA had given me some helpful hints for my camp,
while we were at a Conference for agents of the NFL. The Washington Post wrote a full-page article
about our camp and associated it with other camps that were questionable about their practices.
Actually, that was the very reason for our camp. We had attended many other camps around the
country that were not very well organized and attracted few if any scouts. We had about 60 participants,
with one player coming from as far away as Hawaii. We held the camp at Lancaster Catholic, with a
professional production company filming the entire camp, while I did the editing and produced the video.
The well respected and widely acclaimed professional football scout, Gil Brandt, of the Dallas Cowboys,
had given me support for my camp during some conversations We had with him and said he looked
forward to reviewing the tapes for any hopeful recruits.

Page 106 of 2301

Page 63 of 63

In 1985 I was elected Vice President of the Central Pennsylvania Chapter of the International
Association of Financial Planners, and helped build that chapter by increasing membership 3to 4 times.
We had personally retained the nationally acclaimed and nationally syndicated Financial Planner, Ms.
Alexandria Armstrong of Washington D.C.; to host a major fundraiser. More than 150 professionals
attended the dinner event that was held at the Eden Resort & Conference Center. Ms. Armstrong
discussed financial planning and how all of the professions needed to work together in order to be most
effective for their clients. We attracted a wide variety of professionals including; brokers, lawyers,
accountants, realtors, tax specialists, estate planners, bankers, and investment advisors. Today, it has
become evident that financial planning was the way of the future. In 1986 executives approached us
from Blue Ball National Bank to help them develop a Financial Planning department within their bank.
In 1984 I had helped to develop strategic planning for Sandy Weill, former President of Citi Group (the
largest banking entity in the U.S). We were one of several associates asked to help advise on the future
of Financial Planning and how it would impact the brokerage and the investment industry at large. Mr.
Weil was performing due diligence for the merger of American Express and IDS (Investors Diversified
Services). We were at that time a national leader in the company in delivering Fee Based Financial
Planning Services, which was a new concept in the investment community and mainstream investors.
That concept is now widely held by most investment advisers.
1250 Fremont Street

Lancaster, PA 17603
scaterbone@live.com
717-669-2163
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
Page 107 of 2301
[Advanced Media Group's Weblog] Comment: "City of Lancaster Aims At Cover-Up"

From:
Heather Johnston (donotreply@wordpress.com)
You may not know this sender.Mark as safe|Mark as unsafe
Sent:
Sun 7/20/08 9:44 AM
Reply-to: hjohnston12@yahoo.com (hjohnston12@yahoo.com)
To:
amgroup01@msn.com
New comment on your post #110 "City of Lancaster Aims At Cover-Up"
Author : Heather Johnston (IP: 76.173.82.205 , cpe-76-173-82-205.socal.res.rr.com)
E-mail : hjohnston12@yahoo.com
URL
: http://formerlyfreelisalambert.com
Whois : http://ws.arin.net/cgi-bin/whois.pl?queryinput=76.173.82.205
Comment:
I read about Lisa 10 years ago then started a website for her. I bought and posted
the Dalzell transcripts but they were stolen from me. Lancaster is the strangest
place I have ever lived. I spent 2 years there writing stories about people who
had been screwed, but it just got too hot for me there. Followed, mail stolen,
etc. etc. Thanks for your website and Good Luck!
You can see all comments on this post here:
http://advancedmediagroup.wordpress.com/2008/05/09/city-of-lancaster-aims-atcover-up/#comments
Delete it: http://advancedmediagroup.wordpress.com/wpadmin/comment.php?action=cdc&c=177
Spam it: http://advancedmediagroup.wordpress.com/wpadmin/comment.php?action=cdc&dt=spam&c=177
Page 108 of 2301
finally may get to meet you! I used to communicate with you back then re Lisa Michelle
Lambert.
From:
Stan Caterbone (amgroup01@msn.com)
Sent:
Sun 7/20/08 5:57 AM
To:
hjohnston12@yahoo.com
Cc:
amgauctions@comcast.net
July 20, 2008
Dear Heather,
So you are the mysterious Heather. I used to email you back then in 1997-98. I thought back
then you said you were from Los Angeles. I used to read all of your posts on the LancasterOnline
chat board. I actually filed an Affidavit for that case, which was really an Amicus Curiea.
I also tried to hire Christina Rainville for all of my federal civil complaints in 1997, but her firm,
Harrison Schneider barred her from taking on anymore Lancaster County clients after I had begun
to work with her.
Can I meet you? Would love to discuss your experience and mine sometime. You can visit my
website at:
Please email me.

Thank You for the comment on my blog at:
City of Lancaster Aims At Cover-Up

Heather Johnston Says:
July 20, 2008 at 2:44 am
edit
I read about Lisa 10 years ago then started a website for her. I bought and posted the
Dalzell transcripts but they were stolen from me. Lancaster is the strangest place I
have ever lived. I spent 2 years there writing stories about people who had been
screwed, but it just got too hot for me there. Followed, mail stolen, etc. etc. Thanks for
your website and Good Luck!
http://advancedmediagroup.wordpress.com/2008/05/09/city-of-lancaster-aims -at-coverup/#comments
View our latest Federal Court Filing in the U.S. Third Circuit Court of Appeals
Stan J. Caterbone
Against All Odds - And Always A Winner
Page 109 of 2301
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. Number 7.
1 of 6
Page 110 of 2301
8/8/2016 8:01 AM
2 of 6
Page 111 of 2301
8/8/2016 8:01 AM
3 of 6
Page 112 of 2301
8/8/2016 8:01 AM
4 of 6
Page 113 of 2301
8/8/2016 8:01 AM
5 of 6
Page 114 of 2301
8/8/2016 8:01 AM
6 of 6
Page 115 of 2301
8/8/2016 8:01 AM
1 of 9
Page 116 of 2301
8/8/2016 7:57 AM
2 of 9
Page 117 of 2301
3 Ways To Stop
Dementia
Learn the 3 simple habits that
can stop dementia dead in its
tracks
8/8/2016 7:57 AM
3 of 9
Page 118 of 2301
8/8/2016 7:57 AM
4 of 9
Page 119 of 2301
8/8/2016 7:57 AM
5 of 9
Page 120 of 2301
8/8/2016 7:57 AM
6 of 9
Page 121 of 2301
8/8/2016 7:57 AM
7 of 9
Page 122 of 2301
8/8/2016 7:57 AM
8 of 9
Page 123 of 2301
8/8/2016 7:57 AM
9 of 9
Page 124 of 2301
8/8/2016 7:57 AM
Case
Sunday January 22,
20175:14-cv-02559-PD
Document
Page 1 of
1
Page 125 of24
2301Filed 01/14/16
Stan J. Caterbone
LAMBERT
CASE FILE
Judge Paul S. Diamond, In The United States District Court For The
Eastern District of Pennsylvania
United States District Court
Philadelphia, PA 19106-9865
F'IL.E:.[)
Date: Wednesday, December 30th, 2015
JAN 1~ 2016
From: Lisa Lambert

T85884
MCI Framingham, Framingham, MA 01701
rLLKUNZ.~
RE: Brian Claypool, Esquire, and his petition before the Court to
grant his application to appear pro hac vice on my behalf, along
with Jeremy Gonzalez-Ibrahim
Dear
Judg~
Diamond:
As stated above, the purpose of this letter is to endorse Brian

Claypool's application for pro hac vice on my behalf. I would greatly
appreciate it if you would consider this application for approval,
so that Brian Claypool may be of assistance to Jeremy Gonzalez-Ibrahim
in the preparation of my second amended petition for habeas corpus. I
am very aware that the lengthy history of my case, as well as the vast
number of state and federal transcripts, will require a Herculean effort,
hence my request, so that Brian Claypool, Esquire, willl be able to assist
Jeremy Gonzalez-Ibrahim as co-counsel.
I will also be sending a letter of consent to Jeremy Gonzalez-Ibrahim,
in order to put my agreement to Brian Claypool's application in writing.
Thank you very much for your time and attention in this matter; I
greatly appreciate it.
~
i
MCI Framingham
P.O. Box 9007
Framingham, MA 01701
00
Page 126 of 2301
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
January 11, 2016

c/o David Brown, Esq.,
Pearson Koutcher Law
1650 Arch Street
Suite 1903
Philadelphia, PA 19103
(215) 391-4963
Dear Lisa,
It is with great pleasure to finally write to you. I tried to call you a few months
ago, but the Warden refused to connect me or leave a message. My efforts to free
you are sincere and I have been fighting since 1998 when I delivered documents to
the chambers of Judge Dalzall. We both suffered irreparable harm at the hands of
the same corrupt public officials, police, prosecutors, and Judges.
I'll keep this
short, and if you want to receive correspondence from me, give your contact
information to Dave.
Regards,

1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
Case
Sunday January 22,
20175:14-cv-02559-PD
Document
Page 1 of
7
Page 127 of23
2301Filed 12/29/15
Stan J. Caterbone
LAMBERT
CASE FILE
Case
Sunday January 22,
20175:14-cv-02559-PD
Document
Page 2 of
7
Page 128 of23
2301Filed 12/29/15
Stan J. Caterbone
LAMBERT
CASE FILE
Case
Sunday January 22,
20175:14-cv-02559-PD
Document
Page 3 of
7
Page 129 of23
2301Filed 12/29/15
Stan J. Caterbone
LAMBERT
CASE FILE
Case
Sunday January 22,
20175:14-cv-02559-PD
Document
Page 4 of
7
Page 130 of23
2301Filed 12/29/15
Stan J. Caterbone
LAMBERT
CASE FILE
Case
Sunday January 22,
20175:14-cv-02559-PD
Document
Page 5 of
7
Page 131 of23
2301Filed 12/29/15
Stan J. Caterbone
LAMBERT
CASE FILE
Case
Sunday January 22,
20175:14-cv-02559-PD
Document
Page 6 of
7
Page 132 of23
2301Filed 12/29/15
Stan J. Caterbone
LAMBERT
CASE FILE
Case
Sunday January 22,
20175:14-cv-02559-PD
Document
Page 7 of
7
Page 133 of23
2301Filed 12/29/15
Stan J. Caterbone
LAMBERT
CASE FILE
Page 134 of 2301
WORKING THEORY ON AMICUS AND HABEUS FOR

LISA MICHELLE LAMBERT AND TABITHA BUCK
by Stan J. Caterbone
1. Did Hazel and or John Show notify the police or any law enforcement regarding the harassment
the Laurie Show and the Show family endured before the murder took playce?
2. If so why did not the said law enforcement cite some kind of harassment or disorderly conduct
citation or arrest against Lambert, Buck, and or Yunkin before the murder took place?
3. If yes to the above, my working allegation is that the police were entrapping the three for a
more serious charge.
4. If 1 and 2 are true, maybe there is more to the rape allegations by Lambert; and maybe that is
another reason no harassment or disorderly conduct charges were filed. Remember, she was
awarded some $35,000 a few years ago because she was raped by a Correctional Officer.
5. Now, completely off the record, after my personal observation of Lambert at trial in the
Lancaster County Courthouse, the rape and sexual abuse, my experience and knowledge, Lisa
Michelle Lambert may be a Targeted Individual in the truest sense.
6. If the above is true, this would constitute a Wrongful Death Claim for the Show's.
Entrapment - From Wikipedia, the free encyclopedia

In criminal law, entrapment is a practice whereby a law enforcement agent induces a person to
commit a criminal offense that the person would have otherwise been unlikely to commit.[1] It
is a conduct that is generally discouraged and thus, in many jurisdictions, it is a possible defense
against criminal liability.
Depending on the law in the jurisdiction, the prosecution may be required to prove beyond a
reasonable doubt that the defendant was not entrapped or the defendant may be required to
prove that they were entrapped as an affirmative defense.
Sting operations are fraught with ethical concerns over whether they constitute entrapment.[2]
Lancaster Online.com: News : Top court wants more on Lambert appeal
Page 135 of 2301
Homes | Cars | Jobs | Customer Care Center

Home
Classifieds
Talk Back
Visit
Lancaster
Weather
Services
Apartments
Automotive
Wizard
Business
Directory
Realty Wizard
Shopping
Travel
Personals
Local News
Top Stories
Letters to the
Editor
Sports
Obituaries
Special
Sections
Special
Reports
Archive
National News
Top Stories
Pennsylvania
US/Nation
Washington
Elections
International
Sports
Business
Off Beat
Entertainment
Technology
Health
Science
Features
Site
Site Map
Keyword
Index
RSS Feeds
Need A
WebSite?
Contact Us
http://www.lancasteronline.com/pages/news/local/4/13713
LancasterOnline Keyword
Go
Top court wants more on Lambert appeal
At least one justice is seeking more information from prosecution about convicted killer's
case.
By Cindy Stauffer
Lancaster New Era
Published: Apr 21, 2005 12:56 PM EST
LANCASTER COUNTY, PA - Someone at the nations
highest court is curious about Lisa Michelle Lambert.
Subscribe to
Home Delivery
At least one U.S.
Supreme Court justice Article Tools
recently asked
Link to This
Article
prosecutors to spell out
exactly why the court
Printer Friendly
should not hear
Format
Lamberts appeal of her
Order a Reprint
conviction for the 1991
Email This Article
murder of 16-year-old
Most Emailed
Laurie Show.
Articles
Related Articles
Prosecutors did that
Wednesday, in a
More News
20-page petition that
argues that Lambert, now 32, is actually guilty of
Shows murder and is rightly serving a life sentence.
Prosecutors had been hoping to simply file a perfunctory
one-page form in response to Lamberts recent appeal
to the U.S. Supreme Court, her final appeal in an almost
15-year odyssey through the court system.
But after prosecutors filed that form that basically
said that Lamberts appeal did not meet the
requirements for an appeal someone at the Supreme
Court wanted to hear more.
Ads by Google
Advertisement
Wall Lantern 313

Olde Mill Lighting
$190.00
Minnetonka Sheepskin Pug

Boots #3571
Coyote Trails $99.00
Penn State Paw
Stermer Brothers $11.99
At least one justice wanted to know our view on why we believe they should
not hear the case, said Kevin Harley, spokesman for state Attorney General
Tom Corbett, whose office is prosecuting the case.
Thousands of people try to get the U.S. Supreme Court to hear their cases
each year.
1 of 3
4/21/2005 8:35 PM
Page 136 of 2301
Does this request for more information indicate that the court might be
interested in hearing Lamberts appeal?
Harley doesnt think so.
You cant really read anything into this, he said. If you look at the
percentage of cases the Supreme Court hears each year, its a minuscule
percentage, and we argue in our brief that...theres no reason why the nations
highest court should pick up her appeal.
Lamberts defense attorney, Peter Greenberg, declined to comment today on
the latest developments in the case.
In their petition, prosecutors argue that, Under Pennsylvania law, (Lambert) is
actually guilty of first-degree murder.
Prosecutors say Lambert stabbed Show to death in a jealous rage after Show
briefly dated Lamberts boyfriend, Lawrence Yunkin. Defense attorneys say it
was Yunkin and another friend, Tabitha Buck, who actually killed Show.
Buck, now 33, is serving a life sentence for her role in the killing. Yunkin, now
32, served nearly 12 years for his role, and was released from prison last year.
In a February filing, Greenberg, argued that prosecutors so mishandled her
case and that evidence was so dramatic that it led a federal judge to briefly
free Lambert in 1997. The fact that state courts reached a totally different
conclusion, upholding Lamberts original conviction, shows that they never
considered the relevant facts in her case, he said.
But prosecutors argued in their petition that the state courts did consider those
facts and still came to the conclusion that she was guilty of first-degree
murder.
Lambert cannot claim to be actually innocent, the petition says.
The petition notes the vivid testimony given by Buck during a past hearing, in
which Buck described watching Lambert cut Shows throat as though she were
cutting bread.
That testimony, taken into account with other evidence and Lamberts own
admission about going to Shows apartment on the day of the murder, prevent
her from demonstrating her innocence, the petition says.
Recent TalkBack comments about this article
Comment on this article
obie
the court should not hear michelles case as the pa courts have
04-21-2005 taken up
enough time on this murderer.
she is where she belongs and should stay there for life.
dimples
When will this ever end? Will Laurie Show ever get to rest in
04-21-2005 peace? Will her family ever get to sleep at night knowing Laurie's
killer is forever in Jail? Will Laurie's friends ever get the peace of
mind of knowing that their friend is finally at peace? Isn't enough
that the driver of the get away car is out on probation?
Give it up Lisa we all know you did it. Stop trying to blame other
people.
2 of 3
4/21/2005 8:35 PM
Page 137 of 2301
Kate
Just when you think the past will remain in the past it comes
04-21-2005 back to haunt you.
I hope the US Supreme's put this to rest FOREVER!!!
Comment on this article
2004 Lancaster Newspapers
PO Box 1328, Lancaster PA 17608, (717) 291-8811

Terms of Service Privacy Policy
3 of 3
4/21/2005 8:35 PM
Print
1 of 2
https://us-mg6.mail.yahoo.com/neo/launch?.rand=27j1k00gflnuc#81115...
Page 138 of 2301
Subject:
FW: Muslims Using My Situation to Fight Against USA
From:
Stan J. Caterbone (scaterbone@live.com)
To:
stan.caterbone@yahoo.com;
Date:
Sunday, August 16, 2015 5:18 PM
From: jeremyibrahim.esq@verizon.net
Subject: Re: Muslims Using My Situation to Fight Against USA
Date: Thu, 9 Jul 2015 08:45:01 -0400
To: scaterbone@live.com
Kindly remove my email address. Your emails are harassing and causing distress. This a cease and desist notice.
I refer you to 18 USC 2261 and
PA Code: http://www.legis.state.pa.us/WU01/LI/LI/CT/HTM/18/00.027.009.000..HTM
I will file a police report shortly in my township.
Jeremy H. Gonzalez Ibrahim, Esq.
USNA Blue & Gold Officer
On Jul 8, 2015, at 8:39 PM, Stan J. Caterbone <scaterbone@live.com> wrote:
No
Sent from my iPhone
On Jul 8, 2015, at 8:37 PM, Law Office <jeremyibrahim.esq@verizon.net> wrote:
Please remove me from this email

Jeremy H. Gonzalez Ibrahim, Esq.
USNA Blue & Gold Officer
On Jul 8, 2015, at 8:16 PM, Stan J. Caterbone <scaterbone@live.com> wrote:

ADVANCED MEDIA GROUP, LTD.,
&
STAN J. CATERBONE
Federal Whistleblower (Federal False Claims Act Violation in 1987 re ISC)
Targeted Individual of U.S. Sponsored Mind Control
and Directed Energy Devices and Weapons
EXECUTIVE SUMMARY
copyright 2009
Ya know what, I
difficulty understanding
Extreme Terrorism is to
seems to talk about that
the West?
am beginning to analyze this War on Terror and am having

it all. To me the most effective fundamental fight against
reduce the motive; or the Hatred Against America. No one
subject. How do we reduce that Hatred Towards America and
See, from my perspective, my situation is very disturbing. I mean we have the United States Torturing Me, a U.S. Citizen for no good or valid reason. I have warned EVERYONE about using my
situation to feed this HATRED towards America.
Low and behold a week or so ago I have had several Muslims sign up as Followers to my www.scribd.com/amgroup01 online webspace, which I use to post documents. The following being the most
prominent IKWAN Scope, "The Largest Muslim Brotherhood's Scope on the Web":
http://ikhwanscope.net/main/
There have also been several Muslim individuals who signed up as followers around the same time, a week or so ago. They have also signed up as followers on my www.twitter.com/StanCaterbone
8/16/2015 5:24 PM
Print
2 of 2
https://us-mg6.mail.yahoo.com/neo/launch?.rand=27j1k00gflnuc#81115...
Page 139 of 2301
webspace.
You must understand, I am a VERY Patriotic Person and live a very patriotic life - I believe in the U.S. Constitution and Our Founding Father's vision for America; I support Our Military and our Troops;
I believe in the Rule of Law; I am a Practicing Catholic, and have been my whole life; I Believe in the TRUTH; I believe in Right v. Wrong; Good v. Evil; and finally I believe in God.
What do you believe in?
Date Completed:
Date Initiated:
Fulton Bank Stock Message Board, January 7, 2010
July 28, 2009

July 8, 2009

Advanced Media Group,
Movant for the Petition for the Habeus Corpus of Lisa Michelle Lambert, US District Court of Pa Case No. 5:14-cv-02559-PD
Visit- https://www.scribd.com/stan5j.5caterbone for authentic documents pertaining the Lisa Michelle Lambert Amicus
and all related matters.
PRIVILEGED AND CONFIDENTIAL: Stan J. Caterbone, Pro Se Litigant, and the Advanced Media Group are victims of U.S. Sponsored Mind Control and has
been engaged in litigation in both Federal and State courts seeking financial remedies and a resolution of his Civil Liberties and his Constitutional Rights. In
1987 Stan J. Caterbone, while managing the financial firm the he founded, Financial Management Group, Ltd., Stan J. Caterbone became a Federal
Whistleblower when, as a shareholder, he claimed fraud and misconduct within the international arms dealer and local start-up International Signal &
Control, Plc., Some 4 years later ISC was indicted and plead guilty to the 3rd largest fraud in U.S. history, some $1 Billion and selling arms to Irag via South
Africa. In June of 2015 Stan J. Caterbone became the Movant in the U.S. District Court for the Eastern District of Pennsylvania case No. 5:14-cv-02559-PD
for the Habeus Corpus Petition of Lisa Michelle Lambert.
From: scaterbone@live.com
To: mtciidd@aol.com; sector9@police.co.lancaster.pa.us; broda@lnpnews.com; jlongeresq@aol.com; jwarner@lcswma.org;
john@spiziriassociates.com; righton01@bellsouth.net; inventor0207@yahoo.com; kenrhoades2008@yahoo.com; pwenger@fultonbank.com;
derrickcrobinson@gmail.com; clh@rkglaw.com; james_doran@msn.com; info@satweapons.com; dmoyer@teamemerald.com;
drodriguez@lnpnews.com; jeremyibrahim.esq@verizon.net
Subject: HACKERS WANTED - ASAP - FIGHT FIRE WITH FIRE
Date: Wed, 8 Jul 2015 19:50:31 -0400
July 8, 2015
<Stanley J Caterbone Signature.jpg>
Advanced Media Group,
Movant for the Petition for the Habeus Corpus of Lisa Michelle Lambert, US District Court of Pa Case No. 5:14-cv-02559-PD
Visit- https://www.scribd.com/stan5j.5caterbone for authentic documents pertaining the Lisa Michelle Lambert Amicus
and all related matters.
PRIVILEGED AND CONFIDENTIAL: Stan J. Caterbone, Pro Se Litigant, and the Advanced Media Group are victims of U.S. Sponsored Mind Control and has
been engaged in litigation in both Federal and State courts seeking financial remedies and a resolution of his Civil Liberties and his Constitutional Rights. In
1987 Stan J. Caterbone, while managing the financial firm the he founded, Financial Management Group, Ltd., Stan J. Caterbone became a Federal
Whistleblower when, as a shareholder, he claimed fraud and misconduct within the international arms dealer and local start-up International Signal &
Control, Plc., Some 4 years later ISC was indicted and plead guilty to the 3rd largest fraud in U.S. history, some $1 Billion and selling arms to Irag via South
Africa. In June of 2015 Stan J. Caterbone became the Movant in the U.S. District Court for the Eastern District of Pennsylvania case No. 5:14-cv-02559-PD
for the Habeus Corpus Petition of Lisa Michelle Lambert.
8/16/2015 5:24 PM
Page 140 of 2301
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
717-459-7588 Fax
August 11, 2015

Complaint No. SR1-2637592483
Epic Card
P.O. Box 245998
San Antonio, TX
78224
Re: Bonnie Lee and Polygraph Solutions, LLC.,

1. I had chosen a one issue test and Bonnie Lee kept changing the terminology
of my question - dealing with telepathy. Ms. Lee looked up the term on her
smart phone and gave me definitions that were not consistent with the
technology, I had to provide me own definition on the fly without any
documents and write it down for her on her tablet for the test. My polygraph
question was "Am I a Victim of U.S. Sponsored Mind Control?" - I have the
Social Security Disability Benefits to prove that I am.
2. As usual, there had to be some form of uninfluenced, typical of Targeted
Individuals and Federal Whistleblowers.
3. Ms. Miller failed to inform me yesterday that she only accepts cash the day of
the polygraph test; I luckily read it on her website. It was buried on a 3
long screen text message.
4. As usual my Apple I-phone GPS was again hacked and lead me in the wrong
direction to the middle of a development some miles away, fortunately I had
prepared for this and had Ms. Lee provide me with verbal instructions the day
before.
5. Again, as they did on my way to Carlisle, I was again given the
electromagnetic attacks that produce an intense need to sleep while driving.
6. When I arrived early in the pre-test interview she tried to talk me out of
continuing on with the test; I had to almost threaten legal action due to the
fact that I had paid a $300.00 credit card deposit the day before the test.
Page 141 of 2301
Maybe she does this to avoid taxes?

7. The entire process lasted from 1:50pm until 4:30pm and was exhausting. She
admitted that she performed more than the usual 3 chart test. I had actually
fallen asleep for a few seconds due to the electromagnetic sleep attack, and
fought myself during the entire process not to fall asleep. She gave me no
breaks; I finally had to request a bathroom break before the last chart.
8. I had to sit motionless for almost an hour and a half and she barked at me for
the slightest movement; which does not seem to be normal.
9. She had tailored the profile questions to include any hint of behavior for my
entire lifespan.
10. During the profile interview I had warned her that the only way that I would
fail would be due to either her machinery or her conduct.
11. SHE GUARANTEED ME THAT IF I TOLD THE TRUTH I WOULD PASS THE
TEST; SHE FLAT OUT LIED TO ME! I TOLD THE TRUTH DURING THE ENTIRE
PROCESS!
12. Bonnie Miller had 2 books in the corner of her office titled Brain Mapping
and one on Interrogation Techniques. These 2 books are directly related to
my victimization of electromagnetic weapons.
13. During the profile session regarding personal integrity she had asked do you
have any bad behavior within the past 55 years.
14. I had asked her if she would release the results to third parties and she said
that was alright however she said she would have to include all my answers
regarding the profile of my personal information. I kept questioning why she
would not just release the report she released to me and she would not budge
on her position.
Respectfully,
Stan J. Caterbone
Page 142 of 2301
Polygraph Solutions LLC

257 W. Uwchlan Ave
Downingtown, PA 19335
Date: 8-6-2015
Client: Mr. Stanley Caterbone
Dear Mr.Caterbone,
At your request, I conducted a Forensic Psycho Physiological Truth Verification
Examination on you Mr. Canterbone. This examination was conducted to determine your
truthfulness regarding the 3 relevant questions listed below re: mind control.
POLYGRAPH TEST CONSENT:
The examination was conducted in accordance with State and Federal laws concerning
the use of the polygraph. Prior to the examination you signed a consent form assuring all
concerned that you were aware of your rights concerning the polygraph, and that you were taking
the examination voluntarily. At the conclusion and same day of the examination you were given
the results of the test. During the polygraph pre-interview and test, you were well treated, and
remained of your own free will, knowing you could stop the procedure and leave at any time.
AGREEMENT TO COOPERATION:
You signed an Agreement of Cooperation form that stated any deliberate attempts to try
to alter your physiology for the assessment were counter-productive, a sign of deception, and
grounds for the examiner to report the results as same.
CONSENT TO SHARE INFORMATION:
You signed a consent form permitting me to give all information and the results of the
test with no one.
INTERVIEW INFORMATION:
You were properly identified, and you reported no disabilities or medical conditions that
would adversely affect your physiology or your ability to take the Polygraph Examination.
ADMISSIONS PRIOR TO TEST:
You believe the US government is conducting mind control including Synthetic Telepathy
your definition of Synthetic Telepathy is Technology developed by various government
agencies that target individuals with voice communications 1-way or 2-way by way of a
technological source
Page 143 of 2301
POLYGRAPH EVALUATION:
A Forensic examination, consisting of 3 charts of an Integrated Zone Comparison
Technique was administered and scored. (Single-Issue test.) The Relevant questions listed
below, were among all of the Polygraph Examination questions.
QUESTIONS:
R1. Are you a victim of US sponsored mind control?
ANSWER (YES)
RESULT: (DI) Deception Indicated
R2. RE: US sponsored mind control, are you a victim of it?
ANSWER (YES)
R3. Are you being truthful today that you are a victim of US mind control?
ANSWER (YES)
REMARKS:
The Lafayette Computerized LX-4000 Polygraph System was utilized for the
examination. This instrument indicates and records on a moving chart relative changes in
physiology, including blood pressure, pulse rate, respiratory changes, electro dermal responses,
and countermeasure indicators. This instrument has internal scoring algorism systems.
POLYSCORE SCORING SYSTEM:
The Polyscore Scoring algorithm 5.0 designed by Johns Hopkins University Applied
Physics Laboratory, indicated (DI) Deception Indicated, that the possibility that this data was
produced by a Deceptive Subject/Examinee is greater than 99%.
The Objective Scoring algorithm (OSS3) indicated (DI) Deception Indicated. Based on
the published research the likelihood that this polygraph data was produced by a Deceptive
Subject/Examinee is 99% or greater.
The Horizontal Scoring algorism, was used to manually score these charts. A passing test
requires a score of (plus) 13 or higher for truthfulness, a failing score requires a score of (minus)
-13 or lower. This Subject/Examinees score was minus -14, indicating (DI) Deception
Indicated.
CONCLUSION:
It is my professional opinion, after careful analysis of this Examinees Polygraph
charts/tests, based on the reactions to the formulated test questions, that this examinee is not
considered to be truthful.
This examination was performed by:
Bonnie (Barbara) Lee, President

Forensic Psycho-physiologist
polygraphsolutions.com
(610)324-1058
Page 144 of 2301
Page 145 of 2301
Page 146 of 2301
Page 147 of 2301
P
usps.com
Legal Flat Rt Env
Mailed from 17603

062S0000000314
Commercial Base Pricing
Click-N-Ship
1 lb 0 oz
9405 5036 9930 0120 3153 11 0052 5001 0077 8224

$5.25
US POSTAGE
08/12/15
0006
Expected Delivery Date: 08/14/15
B100
PRIORITY MAIL 2-DAY
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
Carrier -- Leave if No Response
SHIP
TO:
SAN ANTONIO TX 78224-5998
EPIC CARD
PO BOX 245998
USPS TRACKING #
9405 5036 9930 0120 3153 11
Electronic Rate Approved #038555749
Cut on dotted line.
Click-N-Ship Label Record
Instructions
1. Each Click-N-Ship label is unique. Labels are to be
USPS TRACKING # :
used as printed and used only once. DO NOT PHOTO

COPY OR ALTER LABEL.
2. Place your label so it does not wrap around the edge of

the package.
3. Adhere your label to the package. A self-adhesive label
is recommended. If tape or glue is used, DO NOT TAPE
OVER BARCODE. Be sure all edges are secure.
4. To mail your package with PC Postage, you
may schedule a Package Pickup online, hand to
your letter carrier, take to a Post Office, or
drop in a USPS collection box.
5. Mail your package on the "Ship Date" you
selected when creating this label.
9405 5036 9930 0120 3153 11

Trans. #:
Print Date:
Ship Date:
Expected
Delivery Date:
From:
To:
344928754
08/11/2015
08/12/2015
Priority Mail Postage:

Total
$5.25
$5.25
08/14/2015
STAN CATERBONE
AMG
1250 FREMONT ST
EPIC CARD
PO BOX 245998
SAN ANTONIO TX 78224-5998
* Commercial Base Pricing Priority Mail rates apply. There is no fee for USPS
Tracking service on Priority Mail service with use of this electronic rate shipping
label. Refunds for unused postage paid labels can be requested online 30 days from
the print date.
Thank you for shipping with the United States Postal Service!
Check the status of your shipment on the USPS Tracking page at usps.com
Page 148 of 2301
Page 149 of 2301
Page 150 of 2301
Page 151 of 2301
Page 152 of 2301
Page 153 of 2301
Page 154 of 2301
Page 155 of 2301
Page 156 of 2301
Page 157 of 2301
Page 158 of 2301
Page 159 of 2301
Page 160 of 2301
Page 161 of 2301
Page 162 of 2301
Page 163 of 2301
Page 164 of 2301
Page 165 of 2301
Page 166 of 2301
Page 167 of 2301
Page 168 of 2301
Page 169 of 2301
Page 170 of 2301
Page 171 of 2301
Page 172 of 2301
Page 173 of 2301
Page 174 of 2301
Page 175 of 2301
Page 176 of 2301
Page 177 of 2301
Page 178 of 2301
Page 179 of 2301
Page 180 of 2301
Page 181 of 2301
Page 182 of 2301
Page 183 of 2301
June 7, 2015
1250 Fremont Street
Lancaster, PA 17603
Social Security Administration

P.O. Box 4550
Wilkes Barre, PA 18767-4550
Claim No. XXX-XX-0959 A-
Re: Disability Update Report of June 5, 2015

To Whom It May Concern:
Attached are supporting documents for the above. The following is a list of the
attached items for your considerations and review:
1.
2.
3.
4.
5.
Fairmont Behaviorial Systems/Hospital Medical and 302 Report

Lancaster General Hospital Illegal No Trespass Notice
Targeted Individual Summary and Notarized Affidavit
Accumulated Illegal No Trespass Notices
24 Criminal Charges Dismissed 1987 to 2007
Thank you for your considerations.
cc: file
Page 184 of 2301
Page 185 of 2301
Page 186 of 2301
Page 187 of 2301
Page 188 of 2301
Page 189 of 2301
Page 190 of 2301
Page 191 of 2301
Page 192 of 2301
Page 193 of 2301
Page 194 of 2301
Page 195 of 2301
Page 196 of 2301
Page 197 of 2301

&
STAN J. CATERBONE
and Directed Energy Devices or Weapons With Organized Stalking
See Attached Affidavit of September 16, 2010
I have been a Targeted Individual, TI, and Victim since 1987. In 1987 I blew the whistle on
an international defense contractor, International Signal & Control, ISC, who was selling arms to
Iraq via South Africa and was convicted of a $1 Billion dollar Fraud. They were founded and
headquartered in my hometown of Lancaster, Pennsylvania. I was a shareholder and was solicited
to help finance some of their operations.
ISC was a Department of Defense (DOD) Contractor
and a partner with United States Intelligence Agencies since it's beginnings in the early 1970's.
One of it's first contracts was Project X with the National Security Agency or NSA of Ft. Meade,
Maryland.
My father was part of U.S. Navy experiments in the 1940's and experienced synthetic
telepathy in the 1970's and 1980's. My brother was in the U.S. Air Force and a victim of the LSD
experiments in the late 1960's.
Organized stalking and harassment began in 1987 following the public allegations of fraud
within ISC. As far back as the late 1980's I knew that my mind was being read, or "remotely
viewed".
In 2005 the U.S. sponsored mind control turned into an all-out assault of mental
telepathy; synthetic telepathy; and pain and torture through the use of directed energy devices
and electromagnetic weapons. This assault was no coincidence in that it began simultaneously
with the filing of the federal action in U.S. District Court, of CATERBONE v. Lancaster County
Prison, et. al., or 05-cv-2288.
Stan J. Caterbone
Page 198 of 2301
Freedom from Covert Harassment and Surveillance (FFCHS)

Post Office Box 9022
Cincinnati, Ohio 45209
October 10, 2010
Glenn A. Fine, Inspector General
Office of the Inspector General
U.S. Department of Justice
950 Pennsylvania Avenue, N.W.
Room 4706
Washington, D.C. 20530
Subject: A Demand for an Investigation of the FBI
Dear Mr. Fine:
Freedom from Covert Harassment and Surveillance (FFCHS) represents nearly one-thousand U. S.
citizens and residents, all of whom are victims of organized stalking, electronic stalking, or mind
manipulation carried out remotely by unseen assailants using unseen weapons. FFCHS is only one
of several organizations composed of those targeted individuals (TIs). Attached to this demand
letter are also affidavits of victims concerning their torture.
Most of the victims have recurred to the FBI and other law enforcement entities, sometimes
repeatedly, to file complaints concerning their assault; yet, the FBI has consistently refused to
properly investigate the victims claims. Refusal to look into those crimes makes the FBI guilty of
misconduct and dereliction of duty by not providing protection to American citizens on American
soil. Moreover, it makes the FBI accomplices of the assailants. The FBIs unwillingness to intervene
dangerously undermines the American citizenrys faith in the national government.
TIs suffer relentless attacks by high-tech directed energy weaponry that the U. S. military, the U.
S. intelligence community, and law enforcement are known to possess. Some of those targets
daily endure involuntary neurological intervention that includes synthetic telepathy and mind
reading. Many TIs believe that elements of the executive branch either commit those assaults or
aid and protect those who do so. Victims of those attacks experience mentally and physically
debilitating effects. Some of those effects follow.
-- Continual voice-to-skull (V2K) hearing and auditory torture with intense, loud,
electronic-sounding noise.
-- Visual distortions and blurred vision.
-- Manipulation of will, emotions, feelings, and perceptions.
-- Forced speech, involuntary body movements.
-- Mind reading, mining of memories, and neurological interrogations.
-- Induced multiple personalities, transmission of specific commands into the subconscious, and
compulsory execution of these commands.
-- Debilitation of mental acuity: inability to concentrate and disruption of ability to think rationally
and independently.
-- Loss of memory and knowledge.
-- Imposition of altered states that targeted individuals have never experienced before such as
narcotic intoxication and obsessive desires.
-- Manipulation of sleep patterns: sleep deprivation or uncontrollable sleep.
-- Cramps, seizures, and muscle spasms.
Page 199 of 2301
--Excruciating artificial pain in any part of the body.

-- Induced heart attacks, cancer, and other serious medical conditions.
Those electronic and neurological attacks are often accompanied by on-site organized stalking,
wiretapping, phone tampering, computer tampering, mail tampering, vehicle tampering,
workplace mobbing, vandalism, illegal entries, and break-ins.
The failure of the FBI, along with federal, state and local law enforcement, to protect victims of
electronic and neurological assault results in the following violations of those victims basic civil
and human rights.
Denial of victims of equal protection under the laws and the right of due processunder Section 1 of
the Fourteenth Amendment, also known as the Incorporation Doctrine. The Supreme Court has
found that each of these incorporated rights is "deeply rooted in the nation's history" and
"fundamental" to the concept of "ordered liberty" represented by the due process clause [Palko v.
Connecticut, 302 U.S. 319, 58 S. Ct. 149, 82 L. Ed. 288 [1937]. Subjection of victims to cruel and
unusual punishment and the tortuous invasion of privacy by the endless snooping" [See Galella v.
Onassis, 353 F. Supp. 196, 227-28, Page 2 (S.D.N.Y. 1972]. And subjection to organized stalking
and stealth technologies utilized to conduct myriad intrusions upon our person [See United States
of America v. Lawrence Maynard, (08-3030), p. 32 (U.S. Court of Appeals, D.C., August 6, 2010)
where the court found that U. S. Governments prolonged GPS tracking of Jones indeed violates
the intrusions every police practice the Supreme Court has deemed a search under
Katz].Deprivation of victims right to privacy, as well as the privacy of thought, as interpreted by
the U.S. Supreme Court through our Bill of Rights, the 1st Amendment (Privacy of Beliefs), 3rd
Amendment (Privacy of the Home), 14th Amendment, as well as our 4th Amendment (Right
Against Search and Seizure).
Please note that even the courts recognize that the stealth technologies exist and are in the
hands of law enforcements. In Kyllo v. United States [(99-8508) 533 U.S. 27 (2001) 190 F.3d
1041], the Supreme Court found that the use of an Agema Thermovision 210 thermal imager to
scan Kyllos home was a violation of the 4th Amendment and his privacy rights. The Court also
noted that: The ability to see through walls and other opaque barriers is a clear, and scientifically
feasible, goal of law enforcement research and development. The National Law Enforcement and
Corrections Technology Center, a program within the United States Department of Justice,
features on its Internet Website projects that include a Radar-Based Through-the-Wall
Surveillance System, Handheld Ultrasound Through the Wall Surveillance, and a Radar Flashlight
that will enable law officers to detect individuals through interior building walls
(nlectec.org/tech/proj, visited May 3, 2001).
Some devices may emit low levels of radiation that travel through-the-wall, but others, such as
more sophisticated thermal imaging devices, are entirely passive, or off-the-wall as the dissent
puts it [FN3].
By means of this correspondence, FFCHS petitions, and demands, that the Department of Justice
(1) conduct an investigation of the FBI to determine why it refuses to identify, locate, and arrest
the electronic assailants and (2) instruct the FBI to cooperate in investigating the cases regarding
victims of electronic stalking. Thank you for your attention to this urgent and distressing matter.
Sincerely yours,
Derrick C. Robinson President, FFCHS
And other board members
Page 200 of 2301
Page 201 of 2301
Page 202 of 2301
Page 203 of 2301
P.O. Box 9022

Cincinnati, OH 45209
Email: info@freedomfchs.com Voicemail: 1-800-571-5618
Fax: 1-866-433-4170 Website: www.freedomfchs.com
Pennsylvania Counseling Services - Lancaster City

40 Pearl Street
Lancaster, PA 17603
www.pacounseling.com
June 2, 2010
Dear Ms. Erin:
I am writing this letter to you on behalf of Stan Caterbone, who is a targeted individual, one of many
thousands in this country and worldwide who are victims of organized stalking and directed energy
weapons (DEW) assaults. DEW's are advanced surveillance, harassment and mind-invasive technologies
that provide access to the human mind and body for rogue elements of government, business, and
some individuals. Because the technologies are not widely known in society, people often believe that
when they hear voices in their mind that are not their own that they must be delusional. This is not
always the case. Because they are classified, most people do not realize that technologies exist today
that can remotely read and influence human thought, manipulate limbs and inner organs, cause
extreme pain, and/or influence human emotion. Because of congressional hearings in the 70s and
whistleblower accounts, weve learned that there has been secret, ongoing government research and
development of these technologies since the '50's, for almost 60 years.
However, this society remains mostly unaware that not only individual, but mind control on a mass scale
is occurring even as we speak. Therefore, many in this country are suffering greatly in ways they do not
understand, nor do those around them.
Freedom From Covert Harassment and Surveillance (FFCHS) is one of the few organizations that is trying
to bridge this gap and is in the process of helping those who have found that they are victims of
advanced technologies that are preying on the minds and bodies of innocent Americans across this
country and the globe.
Page 204 of 2301
I believe Stan is one of the fortunate ones to have realized the truth of his situation and now the
struggle for him and others becomes finding a means of protection and relief. We have been in
emotional support of him and many others who face this same struggle today; one that our entire
society will one day grapple with hopefully sooner, rather than later. As his therapist, we appreciate
whatever support and guidance you can provide for him at this time.
Feel free to contact me at anytime if you have any questions or comments about how you may be of
help to Stan in assuring his emotional and mental well-being.
Peace and Liberty,

Derrick Robinson, President
Freedom From Covert Harassment and Surveillance
www.freedomfchs.com
Phone: 513-344-4113
Email: derrickcrobinson@gmail.com
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mi...
1 of 11
Page 205 of 2301
http://www.globalresearch.ca/PrintArticle.php?articleId=7123
On the Need for New Criteria of Diagnosis of Psychosis in the Light of

Mind Invasive Technology
By Carole Smith
Global Research, October 18, 2007
Journal of Psycho-Social Studies, 2003.
"We have failed to comprehend that the result of the technology that originated in the years of the arms race
between the Soviet Union and the West, has resulted in using satellite technology not only for surveillance and
communication systems but also to lock on to human beings, manipulating brain frequencies by directing laser
beams, neural-particle beams, electro-magnetic radiation, sonar waves, radiofrequency radiation (RFR), soliton
waves, torsion fields and by use of these or other energy fields which form the areas of study for astro-physics.
Since the operations are characterised by secrecy, it seems inevitable that the methods that we do know about,
that is, the exploitation of the ionosphere, our natural shield, are already outdated as we begin to grasp the
implications of their use." [Excerpt]
For those of us who were trained in a psychoanalytical approach to the patient which was characterised as patient
centred, and which acknowledged that the effort to understand the world of the other person entailed an awareness
that the treatment was essentially one of mutuality and trust, the American Psychiatry Associations Diagnostic
Criteria for Schizotypal personality was always a cause for alarm. The Third Edition (1987) of Diagnostic and
Statistical Manual of Mental Disorders (DSM) required that there be at least four of the characteristics set out for a
diagnosis of schizophrenia, and an approved selection of four could be: magical thinking, telepathy or sixth sense;
limited social contact; odd speech; and over-sensitivity to criticism. By 1994, the required number of qualifying
characteristics were reduced to two or more, including, say, hallucinations and negative symptoms such as
affective flattening, or disorganised or incoherent speech or only one if the delusions were bizarre or the
hallucination consisted of a voice keeping up a running commentary on the persons behaviour or thoughts. The next
edition of the DSM is not due until the year 2010.
In place of a process of a labelling which brought alienation and often detention, sectioning, and mind altering
anti-psychotic medication, many psychoanalysts and psychotherapists felt that even in severe cases of schizoid
withdrawal we were not necessarily wasting our time in attempting to restore health by the difficult work of
unravelling experiences in order to make sense of an illness. In this way, psychoanalysis has been, in its most
radical form, a critic of a society, which failed to exercise imaginative empathy when passing judgement on people.
The work of Harry Stack Sullivan, Frieda Fromm-Reichmann, Harold Searles or R.D. Laing - all trained as
psychiatrists and all of them rebels against the standard procedures provided a way of working with people very
different from the psychiatric model, which seemed to encourage a society to repress its sickness by making a
clearly split off group the carriers of it. A psychiatrist in a mental hospital once joked to me, with some truth, when
I commented on the number of carrier bags carried by many of the medicated patients around the hospital grounds,
that they assessed the progress of the patient in terms of the reduction of the number of carrier bags. It is too often
difficult to believe, however, when hearing the history of a life, that the schizophrenic was not suffering the effects
of having been made, consciously and unconsciously, the carefully concealed carrier of the ills of the family.
For someone who felt his mind was going to pieces, to be put into the stressful situation of the psychiatric
examination, even when the psychiatrist acquitted himself with kindness, the situation of the assessment procedure
itself, can be an effective way to drive someone crazy, or more crazy. (Laing, 1985, p 17). But if the accounting of
bizarre experiences more or less guaranteed you a new label or a trip to the psychiatric ward, there is even more
reason for a new group of people to be outraged about how their symptoms are being diagnosed. A doubly cruel
sentence is being imposed on people who are the victims of the most appalling abuse by scientific-military
experiments, and a totally uncomprehending society is indifferent to their evidence. For the development of a new
class of weaponry now has the capability of entering the brain and mind and body of another person by
technological means.
Harnessing neuroscience to military capability, this technology is the result of decades of research and
experimentation, most particularly in the Soviet Union and the United States. (Welsh, 1997, 2000) We have failed
to comprehend that the result of the technology that originated in the years of the arms race between the Soviet
Union and the West, has resulted in using satellite technology not only for surveillance and communication systems
but also to lock on to human beings, manipulating brain frequencies by directing laser beams, neural-particle
beams, electro-magnetic radiation, sonar waves, radiofrequency radiation (RFR), soliton waves, torsion fields and
by use of these or other energy fields which form the areas of study for astro-physics. Since the operations are
characterised by secrecy, it seems inevitable that the methods that we do know about, that is, the exploitation of
the ionosphere, our natural shield, are already outdated as we begin to grasp the implications of their use. The
patents deriving from Bernard J. Eastlunds work provide the ability to put unprecedented amounts of power in the
9/24/2010 9:25 PM
2 of 11
Page 206 of 2301
Earths atmosphere at strategic locations and to maintain the power injection level, particularly if random pulsing is
employed, in a manner far more precise and better controlled than accomplished by the prior art, the detonation of
nuclear devices at various yields and various altitudes. (ref High Frequency Active Auroral Research Project,
HAARP).
Some patents, now owned by Raytheon, describe how to make nuclear sized explosions without radiation and
describe power beam systems, electromagnetic pulses and over-the-horizon detection systems. A more disturbing
use is the system developed for manipulating and disturbing the human mental process using pulsed radio
frequency radiation (RFR), and their use as a device for causing negative effects on human health and thinking. The
victim, the innocent civilian target is locked on to, and unable to evade the menace by moving around. The beam is
administered from space. The Haarp facility as military technology could be used to broadcast global mind-control,
as a system for manipulating and disturbing the human mental process using pulsed radio frequency (RFR). The
super-powerful radio waves are beamed to the ionosphere, heating those areas, thereby lifting them. The
electromagnetic waves bounce back to the earth and penetrate human tissue.
Dr Igor Smirnov, of the Institute of Psycho-Correction in Moscow, says: It is easily conceivable that some Russian
Satan, or lets say Iranian or any other Satan, as long as he owns the appropriate means and finances, can
inject himself into every conceivable computer network, into every conceivable radio or television broadcast, with
relative technological ease, even without disconnecting cablesand intercept the radio waves in the ether and
modulate every conceivable suggestion into it. This is why such technology is rightfully feared.(German TV
documentary, 1998).
If we were concerned before about diagnostic criteria being imposed according to the classification of recognizable
symptoms, we have reason now to submit them to even harsher scrutiny. The development over the last decades
since the Cold War arms race has included as a major strategic category, psycho-electronic weaponry, the ultimate
aim of which is to enter the brain and mind. Unannounced, undebated and largely unacknowledged by scientists or
by the governments who employ them technology to enter and control minds from a distance has been unleashed
upon us. The only witnesses who are speaking about this terrible technology with its appalling implications for the
future, are the victims themselves and those who are given the task of diagnosing mental illness are attempting to
silence them by classifying their evidence and accounts as the symptoms of schizophrenia, while the dispensers of
psychic mutilation and programmed pain continue with their work, aided and unopposed.
If it was always crucial, under the threat of psychiatric sectioning, to carefully screen out any sign of confused
speech, negativity, coldness, suspicion, bizarre thoughts, sixth sense, telepathy, premonitions, but above all the
sense that others can feel my feelings, and that someone seemed to be keeping up a running commentary on your
thoughts and behaviour, then reporting these to a psychiatrist, or anyone else for that matter who was not of a
mind to believe that such things as mind-control could exist, would be the end of your claim to sanity and probably
your freedom. For one of the salient characteristics of mind-control is the running commentary, which replicates so
exactly, and surely not without design, the symptoms of schizophrenia. Part of the effort is to remind the victim that
they are constantly under control or surveillance. Programmes vary, but common forms of reminders are electronic
prods and nudges, body noises, twinges and cramps to all parts of the body, increasing heart beats, applying
pressures to internal organs all with a personally codified system of comments on thoughts and events, designed
to create stress, panic and desperation. This is mind control at its most benign. There is reason to fear the use of
beamed energy to deliver lethal assaults on humans, including cardiac arrest, and bleeding in the brain.
It is the government system of secrecy, which has facilitated this appalling prospect. There have been warning
voices. the government secrecy system as a whole is among the most poisonous legacies of the Cold War the
Cold War secrecy (which) also mandate(s) Active Deceptiona security manual for special access programs
authorizing contractors to employ cover stories to disguise their activities. The only condition is that cover stories
must be believable. (Aftergood & Rosenberg, 1994; Bulletin of Atomic Scientist). Paranoia has been aided and
abetted by government intelligence agencies.
In the United Kingdom the fortifications against any disturbing glimmer of awareness of such actual or potential
outrages against human rights and social and political abuses seem to be cast in concrete. Complete with
crenellations, ramparts and parapets, the stronghold of nescience reigns supreme. To borrow Her Majesty the
Queens recent observation: There are forces at work of which we are not aware. One cannot say that there is no
British Intelligence on the matter, as it is quite unfeasible that the existence of the technology is not classified
information. Indeed it is a widely held belief that the women protesting against the presence of cruise missiles at
Greenham Common were victims of electro-magnetic radiation at gigahertz frequency by directed energy weapons,
and that their symptoms, including cancer, were consistent with such radiation effects as reported by Dr Robert
Becker who has been a constantly warning voice against the perils of electro-magnetic radiation. The work of Allen
Frey suggests that we should consider radiation effects as a grave hazard producing increased permeability of the
blood-brain barrier, and weakening crucial defenses of the central nervous system against toxins. (Becker, 1985, p.
286). Dr Becker has written about nuclear magnetic resonance as a familiar tool in medecine known as magnetic
resonance imaging or MRI. Calcium efflux is the result of cyclotronic resonance which latter can be explained thus:
If a charged particle or ion is exposed to a steady magnetic field in space, it will begin to go into a circular or orbital,
motion at right angles to the applied magnetic field.The speed with which it orbits will be determined by the ratio
between the charge and the mass of the particle and by the strength of the magnetic field. (Becker, 1990,p.235)
9/24/2010 9:25 PM
3 of 11
Page 207 of 2301
The implications of this for wide scale aggression by using a combination of radar based energy and the use of
nuclear resonating are beyond the scope of the writer, but appear to be worth the very serious consideration of
physicists in assessing how they might be used against human beings.
Amongst medical circles, however, it has so far not been possible for the writer to find a neuroscientist, neurologist
or a psychiatrist, nor for that matter, a general medical practitioner, who acknowledges even the potential for
technological manipulation of the nervous system as a problem requiring their professional interest. There has been
exactly this response from some of Englands most eminent practitioners of the legal profession, not surprisingly,
because the information about such technology is not made available to them. They would refer anyone attempting
to communicate mind- harassment as a psychiatric problem, ignoring the crime that is being committed.
The aim here is not to attempt a comprehensive history and development of the technology of mind control. These
very considerable tasks - which have to be done under circumstances of the most extreme difficulty - have been
addressed with clarity and courage by others, who live with constant harm and threats, not least of all
contemptuous labelling. Their work can be readily accessed on the internet references given at the end of this
paper. For a well-researched outline of the historical development of electro-magnetic technology the reader should
refer to the timeline of dates and electromagnetic weapon development by Cheryl Welsh, president of Citizens
against Human Rights Abuse. (Welsh 1997; 2001). There are at least one and a half thousand people worldwide who
state they are being targeted. Mojmir Babacek, now domiciled in his native Czech Republic, after eight years of
residence in the United States in the eighties, has made a painstakingly meticulous review of the technology, and
continues his research. (Babacek 1998, 2002)
We are concerned here with reinforcing in the strongest possible terms:
i) The need for such abuses to human rights and the threats to democracy to be called to consciousness, and without
further delay.
ii) To analyse the reasons why people might defend themselves from becoming conscious of the existence of such
threats.
iii) To address the urgent need for intelligence, imagination, and information - not to mention compassion - in
dealing with the victims of persecution from this technology, and
iv) To alert a sleeping society, to the imminent threats to their freedom from the threat from fascist and covert
operations who have in all probability gained control of potentially lethal weaponry of the type we are describing.
It is necessary to emphasise that at present there is not even the means for victims to gain medical attention for
the effects of radiation from this targeting. Denied the respect of credulity of being used as human guinea pigs,
driven to suicide by the breakdown of their lives, they are treated as insane at best regarded as sad cases.
Since the presence of a permanent other in ones mind and body is by definition an act of the most intolerable
cruelty, people who are forced to bear it but who refuse to be broken by it, have no other option than to turn
themselves into activists, their lives consumed by the battle against such atrocities, their energies directed to
alerting and informing the public of things they dont want to hear or understand about evil forces at work in their
society.
It is necessary, at this point, to briefly outline a few one might say the precious few attempts by public servants
to verify the existence and dangers inherent in this field:
In January 1998, an annual public meeting of the French National Bioethics Committee was held in Paris. Its
chairman, Jean-Pierre Changeux, a neuroscientist at the Institut Pasteur in Paris, told the meeting that
advances in cerebral imaging make the scope for invasion of privacy immense. Although the equipment
needed is still highly specialized, it will become commonplace and capable of being used at a distance. That
will open the way for abuses such as invasion of personal liberty, control of behaviour and brainwashing.
These are far from being science-fiction concernsand constitute a serious risk to society. (Nature. Vol
391, 1998.
In January 1999, the European Parliament passed a resolution where it calls for an international convention
introducing a global ban on all development and deployment of weapons which might enable any form of
manipulation of human beings. It is our conviction that this ban can not be implemented without the global
pressure of the informed general public on the governments. Our major objective is to get across to the
general public the real threat which these weapons represent for human rights and democracy and to apply
pressure on the governments and parliaments around the world to enact legislature which would prohibit the
use of these devices to both government and private organisations as well as individuals. (Plenary
sessions/Europarliament, 1999)
In October 2001, Congressman Dennis J. Kucinich introduced a bill to the House of Representatives which, it
was hoped would be extremely important in the fight to expose and stop psycho-electronic mind control
experimentation on involuntary, non-consensual citizens. The Bill was referred to the Committee on Science,
and in addition to the Committee on Armed Services and International Relations. In the original bill a ban
was sought on exotic weapons including electronic, psychotronic or information weapons, chemtrails,
9/24/2010 9:25 PM
4 of 11
Page 208 of 2301
particle beams, plasmas, electromagnetic radiation, extremely low frequency (ELF) or ultra low frequency
(ULF) energy radiation, or mind control technologies. Despite the inclusion of a prohibition of the basing of
weapons in space, and the use of weapons to destroy objects or damage objects in space, there is no
mention in the revised bill of any of the aforementioned mind-invasive weaponry, nor of the use of satellite
or radar or other energy based technology for deploying or developing technology designed for deployment
against the minds of human beings. (Space Preservation Act, 2002)
In reviewing the development of the art of mind-invasive technology there are a few outstanding achievements to
note:
In 1969 Dr Jose Delgado, a Yale psychologist, published a book: Physical Control of the Mind: Towards a
Psychocivilized Society. In essence, he displayed in practical demonstrations how, by means of electrical
stimulation of the brain which had been mapped out in its relations between different points and activities, functions
and sensations, - by means of electrical stimulation, how the rhythm of breathing and heartbeat could be
changed, as well as the function of most of the viscera, and gall bladder secretion. Frowning, opening and closing
of eyes and mouth, chewing, yawning, sleep, dizziness, epileptic seizures in healthy persons were induced. The
intensity of feelings could be controlled by turning the knob, which controlled the intensity of the electric current. He
states at the end of his book the hope that the new power will remain limited to scientists or some charitable elite
for the benefit of a psychocivilized society.
In the 1980s the neuromagnetometer was developed which functions as an antenna and could monitor the
patterns emerging from the brain. (In the seventies the scientists had discovered that electromagnetic pulses
enabled the brain to be stimulated through the skull and other tissues, so there was no more need to implant
electrodes in the brain). The antenna, combined with the computer, could localize the points in the brain where the
brain events occur. The whole product is called the magnetoencephalograph.
In January 2000 the Lockheed Martin neuroengineer Dr John D. Norseen, was quoted (US News and World Report,
2000) as hoping to turn the electrohypnomentalaphone, a mind reading machine, into science fact. Dr Norseen,
a former Navy pilot, claims his interest in the brain stemmed from reading a Soviet book in the 1980s claiming that
research on the mind would revolutionize the military and society at large. By a process of deciphering the brains
electrical activity, electromagnetic pulsations would trigger the release of the brains own transmitters to fight off
disease, enhance learning, or alter the minds visual images, creating a synthetic reality. By this process of
BioFusion, (Lockheed Martin, 2000) information is placed in a database, and a composite model of the brain is
created. By viewing a brain scan recorded by (functional) magnetic resonance imaging (fMRI) machine, scientists
can tell what the person was doing at the time of recording say reading or writing, or recognise emotions from
love to hate. If this research pans out, says Norseen, you can begin to manipulate what someone is thinking even
before they know it. But Norseen says he is agnostic on the moral ramifications, that hes not a mad scientist
just a dedicated one. The ethics dont concern me, he says, but they should concern someone else.
The next big thing looks like being something which we might refer to as a neurocomputer but it need not
resemble a laptop it may be reducible to whatever size is convenient for use, such as a small mobile phone.
Arising from a break-through and exploitation of PSI-phenomena, it may be modelled on the nervous-psychic
activity of the brain that is, as an unbalanced, unstable system of neurotransmitters and interacting neurones, the
work having been derived from the creation of a copy of a living brain accessed by chance, and ESP and worked
on by design.
On receiving a communication from the writer on the feasibility of a machine being on the horizon which, based on
the project of collecting electromagnetic waves emanating from the brain and transmitting them into another brain
that would read a persons thoughts, or using the same procedure in order to impose somebody elses thoughts on
another brain and in this way direct his actions there was an unequivocal answer from IBM at executive level that
there was no existing technology to create such a computer in the foreseeable future. This is at some variance with
the locating of a patent numbered 03951134 on the Internet pages of IBM Intellectual Property Network for a
device, described in the patent, as capable of picking up at a distance the brain waves of a person, process them by
computer and emit correcting waves which will change the original brain waves. Similar letters addressed to each of
the four top executives of Apple Inc., in four individual letters marked for their personal attention, produced
absolutely no response. This included the ex- Vice President of the United States, Mr Al Gore, newly elected to the
Board of Directors of Apple.
Enough people have been sufficiently concerned by the reports of victims of mind control abuse to organise The
Geneva Forum, in 2002, held as a joint initiative of the Quaker United Nations Office, Geneva; the United Nations
Institute for Disarmament Research; the International Committee of the Red cross, and the Human Rights Watch
(USA), and Citizens against Human Rights Abuses (CAHRA); and the Programme for Strategic and International
Security Studies, which was represented by the Professor and Senior Lecturer from the Department of Peace
Studies at the University of Bradford.
In England, on May 25, 1995, the Guardian newspaper in the U.K. carried an article based on a report by Nic Lewer,
the peace researcher from Bradford University, which listed more than 30 different lines of research into new age
weaponssome of the research sounds even less rational. There are, according to Lewer, plans for pulsed
9/24/2010 9:25 PM
5 of 11
Page 209 of 2301
microwave beams to destroy enemy electronics, and separate plans for very-low-frequency sound beams to induce
vomiting, bowel spasm, epileptic seizures and also crumble masonry. Further, the article states, There are plans
for mind control with the use of 'psycho-correction messages transmitted by subliminal audio and visual stimuli.
There is also a plan for psychotronic weapons apparently the projection of consciousness to other locations and
another to use holographic projection to disseminate propaganda and misinformation. (Welsh, Timeline). Apart
from this notable exception it is difficult to locate any public statement of the problem in the United Kingdom.
Unfortunately, the problem of credulity does not necessarily cease with frequent mention, as in the United States, in
spite of the number of reported cases, there is still not sufficient public will to make strenuous protest against what
is not only already happening, but against what will develop if left unchecked. It appears that the administration
believes that it is necessary and justifiable, in the interests of national security, to make experimental human
sacrifices, to have regrettable casualties, for there to be collateral damage, to suffer losses in place of strife or war.
This is, of course, totally incompatible with any claims to be a democratic nation which respects the values of human
life and democracy, and such an administration which tutors its servants in the ways of such barbaric tortures must
be completely condemned as uncivilised and hypocritical.
Disbelief as a Defence Mechanism
In the face of widespread disbelief about mind-control, it seems worth analysing the basis of the mechanisms
employed to maintain disbelief:
i) In the sixties, Soviet dissidents received a significant measure of sympathy and indignant protest from western
democracies on account of their treatment, most notedly the abuse of psychiatric methods of torture to which they
were subjected. It is noteworthy that we seem to be able to access credulity, express feelings of indignant support
when we can identify with victims, who share and support our own value system, and who, in this particular
historical case, reinforced our own values, since they were protesting against a political system which also
threatened us at that time. Psychologically, it is equally important to observe that support from a safe distance, and
the benefits to the psyche of attacking a split-off bad father, the soviet authorities in this case, presents no threat
to ones internal system; indeed it relieves internal pressures. On the other hand, recognizing and denouncing a
similar offence makes very much greater psychic demands of us when it brings us into conflict with our own
environment, our own security, our own reality. The defence against disillusion serves to suppress paranoia that
our father figure, the president, the prime minister, our governments - might not be what they would like to be
seen to be.
ii) The need to deposit destructive envy and bad feelings elsewhere, on account of the inability of the ego to
acknowledge ownership of them - reinforces the usefulness of persons or groups, which will serve to contain those,
disowned, projected feelings which arouse paranoid anxieties. The concepts of mind-invasion strike at the very
heart of paranoid anxiety, causing considerable efforts to dislodge them from the psyche. The unconscious
identification of madness with dirt or excrement is an important aspect of anal aggression, triggering projective
identification as a defence.
iii) To lay oneself open to believing that a person is undergoing the experience of being invaded mentally and
physically by an unseen manipulator requires very great efforts in the self to manage dread.
iv) The defence against the unknown finds expression in the split between theory and practice; between the scientist
as innovator and the society who can make the moral decisions about his inventions; between fact and science
fiction, the latter of which can present preposterous challenges to the imagination without undue threat, because it
serves to reinforce a separation from the real.
v) Identification with the aggressor. Sadistic fantasies, unconscious and conscious, being transferred on to the
aggressor and identified with, aid the repression of fear of passivity, or a dread of punishment. This mechanism acts
to deny credulity to the victim who represents weakness. This is a common feature of satanic sects.
vi) The liberal humanist tradition which denies the worst destructive capacities of man in the effort to sustain the
belief in the great continuity of cultural and scientific tradition; the fear, in ones own past development, of not being
ongoing, can produce the psychic effect of reversal into the opposite to shield against aggressive feelings. This
becomes then the exaggerated celebration of the new as the affirmation of human genius which will ultimately be
for the good of mankind, and which opposes warning voices about scientific advances as being pessimistic,
unenlightened, unprogressive and Luddite. Strict adherence to this liberal position can act as overcompensation for
a fear of envious spoiling of good possessions, i.e. cultural and intellectual goods.
vii) Denial by displacement is also employed to ignore the harmful aspects of technology. What may be harmful for
the freedom and good of society can be masked and concealed by the distribution of new and entertaining novelties.
The technology, which puts a camera down your gut for medical purposes, is also used to limit your freedom by
surveillance. The purveyors of innovative technology come up with all sorts of new gadgets, which divert, entertain
and feed the acquisitive needs of insatiable shoppers, and bolster the economy. The theme of Everythings up to
date in Kansas City only takes on a downside when individual experience exploding breast implants, say takes
9/24/2010 9:25 PM
6 of 11
Page 210 of 2301
the gilt off the gingerbread. Out of every innovation for evil (i.e. designed for harming and destroying) some good
(i.e. public diversion or entertainment) can be promoted for profit or crowd-pleasing.
viii) Nasa is sending a spacecraft to Mars, or so we are told. They plan to trundle across the Martian surface
searching for signs of water and life. We do not hear dissenting voices about its feasibility.
Why is it that, when a person accounts that their mind is being disrupted and they are being persecuted by an
unseen method of invasive technology, that we cannot bring ourselves to believe them? Could it be that the horror
involved in the empathic identification required brings the shutters down? Conversely, the shared experience of the
blasting of objects into space brings with it the possibilities of shared potency or the relief that resonates in the
unconscious of a massive projection or evacuation a shared experience which is blessed in the name of mans
scientific genius.
ix) The desire not to be taken in, not to be taken for a fool, provides one of the most powerful and common
defence mechanism against credulity.
Power, Paranoia and Unhealthy Governments
The ability to be the bearer and container of great power without succumbing to the pressures of latent narcissistic
psychoses is an important matter too little considered. The effect of holding power and the expectation and the need
to be seen as capable of sustaining it, if not exercising it, encourages omnipotence of thought. In the wake of this, a
narcissistic overevaluation of the subjects own mental processes may set in. In the effort to hold himself together
as the possessor, container and executor of power, he (or indeed, she) may also, undergo a process of splitting
which allows him, along with others, to bear enthralled witness of himself in this illustrious role. This may mean that
the seat of authority is vacated, at least at times. The splitting process between the experiencing ego and the
perceiving ego allows the powerful leader to alternate his perception of himself inside and outside, sometimes
beside, himself. With the reinforcement of himself from others as his own narcissistic object, reality testing is
constrained. In this last respect, he has much in common with the other powerful figure of the age, the movie star.
or by those, in Freuds words, who are ruined by success.
In a world, which is facing increasing disillusion about the gulf between the public platforms on which governments
are elected, and the contingencies and pragmatics of retaining defence strategies and economic investments, the
role of military and intelligence departments, with their respective tools of domination and covert infiltration, is
increasingly alarming. Unaccountable to the public, protected from exposure and prosecution by their immunity,
licensed to lie as well as to kill, it is in the hands of these agents that very grave threats to human rights and
freedom lies. Empowered to carry out aggression through classified weapon experimentation which is undetectable,
these men and women are also open to corruption from lucrative offers of financial reward from powerful and
sinister groups who can utilize their skills, privileged knowledge and expertise for frankly criminal and fascist
purposes.
Our information about the psychological profiles of those who are employed to practice surveillance on others is
limited, but it is not difficult to imagine the effects on the personality that would ensue with the persistent practice of
such an occupation, so constantly exposed to the perversions. One gains little snatches of insight here and there. In
his book on CIA mind control research (Marks, 1988), John Marks quotes a CIA colleagues joke (always revealing
for personality characteristics): If you could find the natural radio frequency of a persons sphincter, you could
make him run out of the room real fast. (One wonders if the same amusement is derived from the ability to apply,
say infra-sound above 130 decibels, which is said to cause stoppage of the heart, according to one victim/activist
from his readings of a report for the Russian Parliament.)
Left to themselves, these servants of the state may well feel exempt from the process of moral self-scrutiny, but
the work must be dehumanising for the predator as well as the prey. It is probably true that the need to control
their agents in the field was an incentive to develop the methods in use today. It is also an effectively brutalising
training for persecuting others. Meanwhile the object, the prey, in a bid for not only for survival but also in a
desperate effort to warn his or her fellows about what is going on, attempts to turn himself into a quantum
physicist, a political researcher, a legal sleuth, an activist, a neurologist, a psychologist, a physiologist his own
doctor, since he cannot know what effects this freakish treatment might have on his body, let alone his mind. There
are always new methods to try out which might prove useful in the search to find ways of disabling and destroying
opponents air injected into brains and lungs, lasers to strike down or blind, particle beams, sonar waves, or
whatever combination of energies to direct, or destabilise or control.
Science and Scepticism
Scientists can be bought, not just by governments, but also by sinister and secret societies. Universities can be
funded by governments to develop technology for unacceptably inhumane uses. The same people who deliver the
weapons - perhaps respected scientists and academics - may cite the acceptable side of scientific discoveries, which
have been developed by experimenting on unacknowledged, unfortunate people. In a cleaned up form, they are
then possibly celebrated as a break-through in the understanding of the natural laws of the universe. It is not
implausible that having delivered the technical means for destruction, the innovator and thinker goes on, wearing a
9/24/2010 9:25 PM
7 of 11
Page 211 of 2301
different hat, to receive his (or her) Nobel Prize. There are scientists who have refused to continue to do work when
they were approached by CIA and Soviet representatives. These are the real heroes of science.
In the power struggle, much lies at stake in being the first to gain control of ultimate mind-reading and
mind-controlling technology. Like the nuclear bomb, common ownership would seem by any sane calculations to
cancel out the advantage of possession, but there is always a race to be the first to possess the latest ultimate
means of mass destruction. The most desirable form is one that can be directed at others without contaminating
oneself in the process - one that can be undetected and neatly, economically and strategically delivered. We should
be foolish to rule out secret organisations, seeing threat only from undemocratic countries and known terrorist
groups.
As consumers in a world which is increasingly one in which shopping is the main leisure activity, we should concern
ourselves to becoming alert to the ways in which human welfare may have been sacrificed to produce an awesome
new gadget. It may be the cause for celebration for the innovator, but brought about as the result of plugging in or
dialling up the living neuronal processes of an enforced experimentee. If we are concerned not to eat boiled eggs
laid by battery hens, we might not regard it morally irrelevant to scrutinise the large corporations producing
electronically innovative software. We might also be wary about the origins of the sort of bland enticements of
dating agencies who propose finding your ideal partner by matching up brain frequencies and bio-rhythms.
We do not know enough about the background of such technology, nor how to evaluate it ethically. We do not know
about its effects on the future, because we are not properly informed. If governments persist in concealing the
extent of their weapon capability in the interests of defence, they are also leaving their citizens disempowered of
the right to protest against their deployment. More alarmingly, they are leaving their citizens exposed to their
deployment by ruthless organisations whose concerns are exactly the opposite of democracy and human rights.
Back in the United Kingdom
Meanwhile, back in England, the Director of the Oxford Centre for Cognitive Neuroscience, Professor Colin
Blakemore, also the elective Chief Executive of the Medical Research Council writes to the author that he ... knows
of no technology (not even in the wildest speculations of neuroscientists) for scanning and collecting neuronal data
at a distance. (Blakemore, 2003, ) This certitude is at distinct variance with the fears of other scientists in Russia
and the United States, and not least of all with the fears of the French neuroscientist, Jean-Pierre Changeux of the
French National Bioethics Committee already quoted (see page 5). It is also very much at odds with the writing of
Dr Michael Persinger from the Behavioural Neuroscience Laboratory at Laurentian University in Sudbury, Ontario,
Canada. His article On the Possibility of Directly Accessing Every Human Brain by Electromagnetic Induction of
Algorithms (1995), he describes the ways that individual differences among human brains can be overcome and
comes to a conclusion about the technological possibilities of influencing a major part of the approximately six billion
people on this planet without mediation through classical sensory modalities but by generating electromagnetic
induction of fundamental algorithms in the atmosphere. Dr Persingers work is referred to by Captain John Tyler
whose work for the American Air Force and Aerospace programmes likens the human nervous system to a radio
receiver. (1990)
Very recently the leading weekly cultural BBC radio review had as one of its guests, the eminent astro-physicist and
astronomer royal, Sir Martin Rees, who has recently published a book, Our Final Century, in which he makes a
sober and reasoned case for the fifty-fifty chance that millions of people, probably in a third-world country could be
wiped out in the near future through biotechnology and bio-terrorism by error or malign release. He spoke of
this devastation as possibly coming from small groups or cults, based in the United States. few individuals with
the right technology to cause absolute mayhem. He also said that in this century, human nature is no longer a
fixed commodity, that perhaps we should contemplate the possibility that humans would even have implants in the
brain.
The other guests on this programme were both concerned with Shakespeare, one a theatre producer and the other
a writer on Shakespeare, while his remaining guest was a young woman who had a website called Spiked, the
current theme of which was Panic Attack, that is to say, Attack on Panic. This guest vigorously opposed what she felt
was the pessimism of Sir Martin, regarding his ideas as essentially eroding trust, and inducing panic. This reaction
seems to typify one way of dealing with threat and anxiety, and demonstrates the difficulty that a warning voice,
even from a man of the academic distinction of Martin Rees, has in alerting people to that which they do not want
to hear. This flight reaction was reinforced by the presenter who summed up the mornings discussion at the end of
the programme with the words: We have a moral! Less panic, more Shakespeare!
The New Barbarism
Since access to a mind-reading machine will enable the operator to access the ideas of another person, we should
prepare ourselves for a new world order in which ideas will be, as it were, up for grabs. We need not doubt that the
contents of anothers mind will be scooped up, scooped out, sorted through as if the event was a jumble sale. The
legal profession would therefore be well advised to consider the laws on Intellectual Property very judiciously in
order to acquit themselves with any degree of authenticity. We should accustom ourselves to the prospect of
9/24/2010 9:25 PM
8 of 11
Page 212 of 2301
recognizing our work coming out of the mouth of another. The prospect of wide-scale fraud, and someone posturing
in your stolen clothes will not be a pretty sight. The term personal mind enhancement is slipping in through the
back door, to borrow a term used by the Co-Director of the Center for Cognitive Liberty and Ethics, and it is being
done through technologically-induced mental co-ercion mind raping and looting. In place of, or in addition to,
cocaine, we may expect to see mind-enhanced performances on live television.
The brave new science of neuropsychiatry and brain mapping hopes to find very soon, with the fMRI scanner - this
brand new toy that scientists have got their hands on - the blob for love and the blob for guilt, (BBC Radio 4:
All in the Mind, 5 March, 2003). Soon we will be able to order a brain scan for anyone whose behaviour strikes us as
odd or bizarre, and the vicissitudes of a life need no longer trouble us in our diagnostic assessments. In his recent
Reith Lectures for the BBC (2003), Professor Ramachandran, the celebrated neuroscientist from the La Hoya
Institute in San Diego, California, has demonstrated for us many fascinating things that the brain can do. He has
talked to us about personality disorders and shown that some patients, who have suffered brain damage from head
injury, do not have the capacity to recognise their mothers. Others feel that they are dead. And indeed he has found
brain lesions in these people. In what seems to be an enormous but effortless leap, the self-styled kid in a candy
store is now hoping to prove that all schizophrenics, have damage to the right hemisphere of the brain, which
results in the inability to distinguish between fantasy (sic) and reality. Since Professor Ramachandran speaks of
schizophrenia in the same breath as denial of illness, or agnosia, it is not clear, and it would be interesting to know,
whether the person with the head injury has been aware or unaware of the head injury. Also does the patient derive
comfort and a better chance at reality testing when he is told of the lesion? Does he feel better when he has
received the diagnosis? And what should the psychoanalysts and the psychiatrists, - feel about all those years of
treating people of whose head injuries they were absolutely unaware? Was this gross negligence? Were we
absolutely deluded in perceiving recovery in a sizeable number of them?
It is, however, lamentable that a neuroscientist with a professed interest in understanding schizophrenia should
seek to provide light relief to his audience by making jokes about schizophrenics being people who are convinced
that the CIA has implanted devices in their brain to control their thoughts and actions, or that aliens are controlling
them. (Reith Lecture, No 5, 2003).
There is a new desire for concretisation. The search for meaning has been replaced by the need for hard proof. If
it doesnt light up or add up it doesnt have validity. The physician of the mind has become a surgeon. He found a
lump as big as a grapefruit!
Facing up to the Dread and Fear of the Uncanny
Freud believed that an exploration of the uncanny would be a major direction of exploration of the mind in this
century. The fear of the uncanny has been with us for a very long time. The evil eye, or the terrifying double, or
intruder, is a familiar theme in literature, notably of Joseph Conrad in The Secret Sharer, and Maupassants short
story, Le Horla. Freuds analysis of the uncanny led him back to the old animistic conception of the universe: it
seems as if each one of us has been through a phase of individual development corresponding to the animistic phase
in primitive men, that none of us has passed through it without preserving certain residues and traces of it which
are still capable of manifesting themselves, and that everything which now strikes us as uncanny fulfils the
condition of touching those residues of animistic mental activity within us and bringing them to expression. (Freud:
1919. p.362)
The separation of birth, and the childhood fear of spooks in the night, also leave their traces in each and every one
of us. The individual experience of being alone in ones mind the solitary fate of man which has never been
questioned before, and upon which the whole history of civilised nurture is based - is now assaulted head-on. Since
growing up is largely synonymous with acceptance of ones aloneness, the effort to assuage it is the basis for
compassion and protection of others; it is the matrix for the greatest good, that of ordinary human kindness, and is
at the heart of the communicating power of great art. Even if we must all live and die alone, we can at least share
this knowledge in acts of tenderness which atone for our lonely state. In times of loss and mental breakdown, the
starkness of this aloneness is all too clear. The best of social and group constructiveness is an effort to allay the
psychotic anxieties that lie at the base of every one of us, and which may be provoked under extreme enough
conditions.
The calculated and technological entry into another persons mind is an act of monumental barbarism which
obliterates perhaps with the twiddling of a dial the history and civilisation of mans mental development. It is
more than an abuse of human rights, it is the destruction of meaning. For any one who is forced into the hell of
living with an unseen mental rapist, the effort to stay sane is beyond the scope of tolerable endurance. The
imaginative capacity of the ordinary mind cannot encompass the horror of it. We have attempted to come to terms
with the experiments of the Nazis in concentration camps. We now have the prospect of systematic control
authorised by men who issue instructions through satellite communications for the destruction of societies while
they are driving new Jaguars and Mercedes, and going to the opera.
This is essentially about humiliation, and disempowerment. It is a manifestation of rage acted out by those who fear
impotence with such dread, that their whole effort is directed into the emasculation and destruction of the terrifying
rival of their unconscious fantasies. In this apocalypse of the mind the punitive figure wells up as if out of the bowels
of the opera stage, and this phantasmagoria is acted out on a global scale. These men may be mad enough to
9/24/2010 9:25 PM
9 of 11
Page 213 of 2301
believe they are creating a psychocivilised world order. For anyone who has studied damaged children, it is more
resonant of the re-enactment from the unconscious, reinforced by a life devoid of the capacity for empathic
identification, of the obscenities of the abused and abusing child in the savage nursery. Other people -which were to
them like Action Man toys to be dismembered, or Barbie Dolls to be obscenely defiled - become as meaningless in
their humanity as pixillated dots on a screen.
Although forced entry into a mind is by definition obscene, an abbreviated assessment of the effects that
mind-invaded people describe testifies to the perverted nature of the experiments. Bizarre noises are emitted
from the body, a body known well enough by its owner to recognise the noises as extrinsic; air is pumped in and out
of orifices as if by a bicycle pump. Gradually the repertoire is augmented - twinges and spasms to the eyes, nose,
lips, strange tics, pains in the head, ringing in the ears, obstructions in the throat, pressure on the bowel and
bladder causing incontinence; tingling in the fingers, feet, pressures on the heart, on breathing, dizziness, eye
problems leading to cataracts; running eyes, running nose; speeding up of heart beats and the raising of pressure in
the heart and chest; breathing and chest complaints leading to bronchitis and deterioration of the lungs; agonizing
migraines; being woken up at night, sometimes with terrifying jolts ; insomnia; intolerable levels of stress from the
loss of ones privacy. This collection of assorted symptoms is a challenge to any medical practitioner to diagnose.
There are, more seriously, if the afore-going is characterised as non-lethal, the potential lethal effects since the
capability of ultrasound and infra-sound to cause cardiac arrest, and brain lesions, paralysis and blindness, as well
as blinding by laser beam, or inducing asphyxia by altering the frequencies which control breathing in the brain,
epileptic seizure all these and others may be at the fingertips of those who are developing them. And those who
do choose to use them may be sitting with the weapon, which resembles, say, a compact mobile telephone, on the
restaurant table next to the bottle of wine, or beside them at the swimming pool.
Finally if the victims at this point in the new history of this mind-control, cannot yet prove their abuse, it must be
asserted that, faced with the available information about technological development it is certainly not possible for
those seeking to evade such claims to disprove them. To wait until the effects become widespread will be too late.
For these and other reasons which this paper has attempted to address, we would call for an
acknowledgement of such technology at a national and international level. Politicians, scientists and
neurologists, neuroscientists, physicists and the legal profession should, without further delay, demand public
debate on the existence and deployment of psychotronic technology; and for the declassification of
information about such devices which abuse helpless people, and threaten democratic freedom.
Victims accounts of abuse should be admitted to public account, and the use of psycho-electronic weapons
should be made illegal and criminal,
The medical profession should be helped to recognise the symptoms of mind-control and psychotronic abuse,
and intelligence about their deployment should be declassified so that this abuse can be seen to be what it is,
and not interpreted automatically as an indication of mental illness.
If, in the present confusion and insecurity about the search for evidence of weapons of mass destruction, we
conclude that failure to locate them - whatever the truth of the matter encourages us to be generally complacent,
then we shall be colluding with very dark forces at work if we conclude that a course of extreme vigilance signifies
paranoia. For there may well be other weapons of mass destruction being developed and not so far from home;
weapons which, being even more difficult to locate, are developed invisibly, unobstructed, unheeded in our midst,
using human beings as test-beds. Like ESP, the methods being used on humans have not been detectable using
conventional detection equipment. It is likely that the signals being used are part of a physics not known to
scientists without the highest level of security clearance. To ignore the evidence of victims is to deny, perhaps with
catastrophic results, the only evidence which might otherwise lead the defenders of freedom to becoming alert to
the development of a fearful new methods of destruction. Manipulating terrorist groups and governments alike,
these sinister and covert forces may well be very thankful for the professional derision of the victims, and for public
ignorance.
References
Laing, R.D. (1985) : Wisdom, Madness and Folly: The Making of a Psychiatrist. Macmillan, 1985
Welsh, Cheryl (1997): Timeline of Important Dates in the History of Electromagnetic Technology and Mind Control,
at:
www.dcn.davis.ca.us/~welsh/timeline.htm
Welsh, Cheryl (2001):Electromagnetic Weapons: As powerful as the Atomic Bomb, President Citizens Against
Human Rights Abuse, CAHRA Home Page: U.S. Human Rights Abuse Report: www.dcn.davis.ca.us/~welsh
/emr13.htm
Begich, Dr N. and Manning, J.: 1995 Angels Dont Play this HAARP, Advances in Tesla Technology, Earthpulse Press.
9/24/2010 9:25 PM
10 of 11

ZDF TV:
Page 214 of 2301
Secret Russia: Moscow The Zombies of the Red Czars, Script to be published in Resonance, No. 35
Aftergood, Steven and Rosenberg, Barbara: The Soft Kill Fallacy, in The Bulletin of the Atomic Scientists, Sept/Oct
1994.
Becker, Dr Robert: 1985,The Body Electric: Electromagnetism and the Foundation of Life, William Morrow, N.Y.
Babacek, Mojmir: International Movement for the Ban of Manipulation of The Human Nervous System:
http://mindcontrolforums.com/babacek.htm and go to: Ban of Manipulation of Human Nervous System
Is it Feasible to Manipulate the Human Brain at a Distance?
www.aisjca-mft.org/braindist.htm
Psychoelectronic Threat to Democracy
http://mindcontrolforums.com/babacek.htm
Nature: Advances in Neuroscience May Threaten Human Rights, Vol, 391, Jan. 22, 1998, p. 316; (ref Jean- Pierre
Changeux)
Space Preservation Act: Bill H.R.2977 and HR 3616 IH in 107th Congress 2nd Session: see:
www.raven1.net/govptron.htm
Sessions European Parliament:
www.europarl.eu.int/home/default_en.htm?redirected=1
Click at Plenary Sessions, scroll down to Reports by A4 number, click, choose 1999 and fill in oo5 to A4
Delgado, Jose M.R: 1969. Physical Control of the Mind: Towards a Psychocivilized Society, Vol. 41, World
Perspectives, Harper Row, N.Y.
US News & World Report: Lockheed Martin Aeronautics/ Dr John Norseen; Report January 3/10 2000, P.67
Freud, Sigmund: 1919: Art and Literature: The Uncanny. Penguin,
Also Those Wrecked by Success.
Marks, John: 1988 :The CIA and Mind Control the Search for the Manchurian Candidate, ISBN 0-440-20137-3
Persinger, M.A. On the Possibility of Directly Accessing Every Human Brain by Electromagnetic Induction of
Fundamental Algorythms; In Perception and Motor Skills, June, 1995, vol. 80, p. 791 799
Tyler, J.Electromagnetic Spectrum in Low Intensity Conflict, in Low Intensity Conflict and Modern Technology,
ed. Lt. Col. J. Dean, USAF, Air University Press, Centre For Aerospace Doctrine, Research and Education, Maxwell
Air Force base, Alabama, June, 1986.
Rees, Martin Our Final Century: 2003, Heinemann.
Conrad, Joseph: The Secret Sharer, 1910. Signet Classic.
Maupassant, Guy de: Le Horla, 1886. Livre de Poche.
Carole Smith is a British psychoanalyst. In recent years she has been openly critical of government use of intrusive
technology on non-consenting citizens for the development of methods of state control. Carole Smith
E-mail: rockpool@dircon.co.uk
Disclaimer: The views expressed in this article are the sole responsibility of the author and do not necessarily reflect those of the Centre for
Research on Globalization. The contents of this article are of sole responsibility of the author(s). The Centre for Research on Globalization will
not be responsible or liable for any inaccurate or incorrect statements contained in this article.
To become a Member of Global Research
The CRG grants permission to cross-post original Global Research articles on community internet sites as long as the text & title are not
modified. The source and the author's copyright must be displayed. For publication of Global Research articles in print or other forms including
commercial internet sites, contact: crgeditor@yahoo.com
www.globalresearch.ca contains copyrighted material the use of which has not always been specifically authorized by the copyright owner. We
are making such material available to our readers under the provisions of "fair use" in an effort to advance a better understanding of political,
economic and social issues. The material on this site is distributed without profit to those who have expressed a prior interest in receiving it for
research and educational purposes. If you wish to use copyrighted material for purposes other than "fair use" you must request permission
from the copyright owner.
For media inquiries: crgeditor@yahoo.com
9/24/2010 9:25 PM
11 of 11
Page 215 of 2301
Copyright Carole Smith, Journal of Psycho-Social Studies, 2003., 2007

The url address of this article is: www.globalresearch.ca/PrintArticle.php?articleId=7123
Copyright 2005-2007 GlobalResearch.ca

Web site engine by Polygraphx Multimedia Copyright 2005-2007
9/24/2010 9:25 PM
Page 216 of 2301
scaterbone@live.com
www.advancedmediagroup.wordpress.com
www.scribd.com/amgroup01
www.facebook.com/scaterbone
www.twitter.com/StanCaterbone
www.mcvictimsworld.ning.com/profile/StanJCaterbone
http://www.youtube.com/advancedmediagroup
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
ILLEGAL NO TRESPASS NOTICES AGAINST

STAN J. CATERBONE AND ADVANCED MEDIA GROUP
Violations of Public Accommodations Law re Discrimination
and Anti-Trust Violations with False Statements to Authorities
March 14, 2010
Work-In-Progress
Community Stalking and Organized Libel/Slander Campaign Strategy Issue a few every
year to support false arrests; false imprisonment; fabricated mental illness history. In addition to
isolate by prohibiting entrance to major entertainment venues with good live music. Prohibit from
defending against the lies and slander in public to a minimum. Also, destroy history of strong
Christian values and church attendance on a weekly basis by keeping away from church. The
Millersville University Graduate Studies No Trespass Notice was accommodated by the denial of
entitled benefits of LETA Job Training Education Course of the Paralegal program at HACC during
the same time period.
1. David Pflumm Properties by David Pflumm Served by State Constable in June of

2005, original not signed by David Pflumm
2. Eden Resort Inn, by Drew Anthon, Owner Sent via 1st Class Mail in 2005.
3. Barley Snyder, LLC Lancaster Office, by Shawn Long, Esq., Attorney representing
Fulton Bank in 2006 Sent via 1st Class Mail
4. Lancaster Newspapers, Inc., by Steve Weaver, Manager in 2006, No Notice,
Corraborated by Jack Buckwalter, Chairman and CEO and George Warner, Atty with Barley
Snyder, LLC, No Formal Notice
5. Ruby Tuesday, Manor Shopping Center, Lancaster, by Manager and Lancaster City
Police in 2006, No Formal Notice
6. Alley Kat Restaurant and Bar, Lancaster by Bartender Ms. Santinello, Brett Stabley,
and Lancaster City Police, No formal Notice in 2006
7. Village Nightclub, Lancaster by George in 2008, No Formal Notice
8. Marion Court Restaurant, Lancaster, by Security Personnel, corroborated by Michael
Geesey, in 2008, No Formal Notice
9. Valentinos Cafe, Lancaster, by Jeanine, Bartender,in 2008, corroborated by John
Valentino, Owner, No Formal Notice
10. Brunswick Hotel, Lancaster, by Staff Employees, in 2008, No Formal Notice
11. Lancaster County Library and Duke Street Business Center, by Executive Director in
March of 2009, by 1st Class Mail
12. Anne Bailey's Restaurant and Bar, Lancaster, by Manager in 2009, No Formal Notice
13. Millersville University Graduate Studies and Millersville University, Millersville, by
Lori Austin, Judicial Affairs, via Certified Mail in June of 2009.
Page 217 of 2301
14. TGIF Friday's, Lancaster, by Manager, in January of 2010, No Formal Notice

15. Lucky Dog Restaurant and Bar, Lancaster, by Robert Donnelly, in January of 2010, No
Formal Notice
16. Saint Mary's Catholic Church, Lancaster, by Don Spica, Usher and Lancaster City Police
Department in Feb of 2010, No Formal Notice
17. O'Halloran's Bar, Lancaster, March 25, 2010 by Male Staff Employee. No Formal Notice.
18. Fulton Bank, Fulton Financial Corporation, March 26, 2010 by Susan Follmer, Security
Officer.
Dated: March 29, 2010
Page 218 of 2301
Page 219 of 2301

http://www.amgglobalentertainmentgroup.com/
mailto: amgroup01@msn.com
717.427-1621 Fax
Stan J. Caterbone, Pro Se Litigator

1250 Fremont Street
Lancaster, PA 17603
STANLEY J. CATERBONE, PRO SE LITIGATOR

24 CRIMINAL CHARGES DISMISS/WITHDRAWN/NOT-GUILTY
1987 TO 2007
1. 09/01/1987 Cc2706 Terroristic Threats - M1 Quashed / Dismis / Demur Sus
2. 09/03/1987 Cc2902-1 Unlawful Restraint - M1 Quashed / Dismis / Demur Sus
3. 09/03/1987 Cc3304a2 Criminal Mischief - F3 Nolle Prossed / Withdrawn
4. 09/03/1987 Cc3502 Burglary - F1 Quashed / Dismis / Demur Sus
5. 09/03/1987 Cc3701al Robbery - F1 Quashed /Dismis /Demur Sus
6. 09/03/1987 Cc3921a Theft By Unlwf Taking Or Dispo F3 Nolle Prossed / Withdrawn
6. 09/03/1987 Cc3933a1 Unlawful Use Of Computer - F3 Nolle Prossed /Withdrawn
7. 09/03/1987 Cc3933a2 Unlawful Use Of Computer - F3 Quashed / Disnis / Demur Sus
8. 12/05/2006 1 18 5503 A2 Disorderly Conduct-Unreasonable Noise - Withdrawn (Lower Court)
9. 12/05/2006 1 18 3926 A4 Theft Of Services-Acquisition Of Services Withdrawn (Lower Court)
10. 12/05/2006 1 18 2709 A7 Harassment - Comm. Repeatedly In Another Manner Withdrawn (Lower Court)
11. 01/23/2007 1 285-21d No Parking Or Stopping Permitted Withdrawn (Lower Court)
12. 01/23/2007 1 285-30a Meter Violation Withdrawn (Lower Court)
14. 01/23/2007 1 18 6501 A1 Scatter Rubbish Upon Land/Stream Etc Dismissed (Lower Court)
17. 01/18/2007 1 75 1543 A Driv While Oper Priv Susp Or Revoked Not Guilty
18. 01/18/2007 1 75 1786 F Oper Veh W/O Req'd Financ Resp Not Guilty
19. 04/30/2007 1 18 5503 A4/ Disorder Conduct Hazardous/Physi Off Not Guilty
20. 04/30/2007 2 18 5507 A / Obstruction Highways Not Guilty
21. 04/30/2007 3/ 18 2709 A3 Harassment - Course Of Conduct W/No Legitimate Purpose Nolle Prossed
22. 04/30/2007 1 75 3111 A / Disregard Traffic Control Device Not Guilty Nolle Prossed
23. 05/10/2007 M2 18 5104 Resist Arrest/Other Law Enforce 08/04/2006 K4775120
24. 05/10/2007 3 M1 18 908 A Make Repairs/Sell/Etc Offens Weap 08/04/2006 K4775120 Nolle Prossed
Page 220 of 2301
1250 Fremont Street
Lancaster, PA 17603
717-669-2163
scaterbone@live.com
Morayma Rivera, Disability Examiner

SOCIAL SECURITY ADMINISTRATION
Office of Medical and Vocational Expertise
Baltimore, Me 21235-7786
Case Number: 0514869
May IS, 2009
Dear Morayma:
Per our conversation yesterday, May 14, 2009 enclosed is the required form for my
above mentioned claim. As you will see I tried to provide you and the Social
Security Administration with as much documentation as possible. Attached are
several letters and research documents which prove my claim. You may also visit
my website for more information. You will also find attached an invoice for my
claim.
As we discussed, I will await the appointment date and time with the local
psychiatrist for m~ evaluation. As you stated, this should come within the next two
weeks via U.S. fj~t class mail.
I look forward to my evaluation.
(Jf). (ffi,.)
tan J. catJone
Stanley J. Caterbone Case No. 0514869

Page 1 of 55
Page 1 of 55
05.15.2009
05.18.2009
Page 221 of 2301

Office of Medical and
Vocational Expertise
DATE: May 7, 2009
STANLEY JOSEPH CATERBONE
1250 FREMONT STREET
LANCASTER PA 17603
Case Number:
0514869
We need to talk to you about your claim for Social Security disability
benefits.
Please call me as soon as possible, using my toll free number at:
1 800-582-6041 Extension: 57905.
You should call Monday through Friday between the hours of 6:30 AM to 03:00 PM.
Failure to call within 10 calendar days from the date of this letter may result
in a determination being made based on the evidence in file.
Thank you for your cooperation.
MORAYMA RIVERA
Disability Examiner
D2013/mrl16
Page 2 of 55
05.18.2009
Page 222 of 2301
RQID:L~~~~~C646~~~
DOCTYPE:~075
SSN:200460959
SITE:V4~
RF:D CS:7df4
DR:S
111111111111111111111111111111111111111111111111"" 111111111111111111111111 1111

1250 FREMONT STREET
LANCASTER PA 17603
20090507500039
DATE: May 7, 2009

Claimant: STANLEY JOSEPH
CATERBONE
SSN: XXX-XX-0959
SSA CLAIMANT INFORMATION COVER SHEET
INSERT THIS PAGE INTO THE W7NDOW ENVELOPE PROVIDED W7TH THE ADDRESS
BELOW SHOWING.
THIS PAGE MUST BE ON TOP OF YOUR REPORT.
V40 OMVE/FDDS
PO BOX 8744
LONDON KY 40742-9981
PLEASE NOTE:
You must complete and return the attached form(s) to the address shown
above.
If you would like, you may fax your completed form(s) to 1-866-560-4945.
BE SURE TO PUT THIS PAGE ON TOP OF THE DOCUMENT YOU ARE FAXING.
Page 3 of 55
05.18.2009
Page 223 of 2301
1111111 11111 111111111111111
dill
11111 1111111111111111111111111111111111111111111
20090507500039
Office of Medical and

Vocational Expertise
DATE: May 7, 2009
1250 FREMONT STREET
LANCASTER PA 17603
Case Number:
0514869
Your Social Security Disability case has been sent to the Office of Medical and
Vocational Expertise in Baltimore, Maryland for medical development and
evaluation. After reviewing your case, we find that we need more information
about your daily activities and/or your allegations of pain. Please attempt to
answer all the questions on the enclosed form(s) in as much detail as possible
and avoid single word answers. The information you provide will help our agency
evaluate how your medical condition affects your daily activities.
The form(s) should be returned within 10 calendar days from the date of this
letter, in the self-addressed, postage-paid envelope provided. Failure to do so
may result in a determination being made based on the evidence in file.
If you have any questions, please call me toll free at:
1-800-582-6041 on extension: 57905.
You should call Monday through Friday between the hours of 6:30 AM to 03:00 PM.
TO ENSURE PROMPT SERVICE, PLEASE RETURN THE COVER SHEET AND THIS LETTER WITH THE
ATTACHED FORM.
Thank you for your cooperation.

MORAYMA RIVERA
Disability Examiner
Enclosures:
Adult Function Report
Return Envelope
D2103/mr116
Page 4 of 55
05.18.2009
Page 224 of 2301
FUNCTION REPORT - ADULT - Form SSA-3373-BK

READ ALL OF THIS INFORMATION BEFORE
YOU BEGIN COMPLETING THIS FORM
IF YOU NEED HELP

If you need help with this fonn, complete as much of it as you can and call the phone number
provided on the letter sent with the fonn, or contact the'person who asked you to complete the
fonn. If you need the address or phone number for the office that provided the fonn, you can get it
by calling Social Security at 1-800-772-1213.
HOW TO COMPLETE THIS FORM

The infonnation that you give us on this fonn will be used by the office that makes the disability
decision on your disability claim. You can help them by completing as much of the fonn as you
can.
It is important that you tell us about your activities and abilities.
_=
=.
-=
~
::l
Print or type.
DO NOT LEAVE ANSWERS BLANK. If you do not know the answer or the answer -_
is "none" or "does not apply," please write "don't know" or "none" or "does not apply."
Do not ask a doctor or hospital to complete this fonn.
Be sure to explain an answer if the question asks for an explanation, or if you
think you need to explain an answer.
If more space is needed to answer any questions, use the "REMARKS" section on
Page 8, and show the number of the question being answered.
REMEMBER TO GIVE US THE NAME AND ADDRESS OF THE PERSON
COMPLETING TmS FORM ON PAGE 8
Page 5 of 55
05.18.2009
Page 225 of 2301
Privacy Act and Paperwork Reduction Act Statements
The Social Security Administration is authorized to collect the infonnation on this fonn under sections
205(a), 1631(d)(1) and 1631(e)(1) ofthe Social Security Act. The infonnation on this fonn is needed by
Social Security to make a decision on the named claimant's claim. While giving us the infonnation on this
fonn is voluntary, failure to provide all or part ofthe requested infonnation could prevent an accurate or
timely decision on the named claimant's claim. Although the infonnation you furnish is almost never used
. for any purpose other than making a determination-about the claimant's disability, such infonnation may
be disclosed by the Social Security Administration as follows: (1) to enable a third party or agency to
assist Social Security in establishing rights to Social Security benefits and/or coverage;(2) to comply with
Federal Laws requiring the release ofinformation from Social Security records (e.g., to the General
Accounting Office and the Department of Veterans Affairs); and (3) to facilitate statistical research and
such activities necCssary to assure the integrity and improvement ofthe Social Security programs (e.g., to
the Bureau ofthe Census and private concerns under contract to Social Security).
We may also use the infonnation you give us when we match records by computer. Matching programs
compare our records with those ofother Federal, State, or local government agencies. Many agencies
may use matching programs to find or prove that a person qualifies for benefits paid by the Federal
government. The law allows us to do this even ifyou do not agree to it. Explanations about these and
other reasons why infonnation you provide us may be used or given out are available in Social Security
offices.
Paperwork Reduction Act Statement - This infonnation collection meets the requirements of44 U.S.C.
3507, as amended by Section 2 of the Paperwork Reduction Act of 1995. You do not need to answer
these questions .un1ess we display a valid Office of Management and Budget control number. We estimate
that it will take about 30 minutes to read the instructions, gather the facts, and answer the questions.
SEND THE COMPLETED FORM TO THE OFFICE THAT REQUESTED IT. If you do not have
fhataddress, you maycaU Social Security at 1-800-772-1213. You may send comments on our time
estimate above to: SSA, 1338 Annex Building, Baltimore, MD 21235-0001. Send only comments
reliding to our time estimate to this iUId~ss, not the completed form.
PLEASE REMOVE THIS SHEET BEFORE RETURNING
THE COMPLETED FORM.
Page 6 of 55
05.18.2009
Page 226 of 2301
Fonn AIJproved
OMS No. 0960-0681
FUNcnoN REPORT .. ADULT

How your Hlnesses, injuries. or conditions limit your activities
~~--~----~~
~~==~~~~~
SECTION A - GENERAL INFORMATION

1. NAME OF DISABLED PERSON {FitSt,MiddIe. Last}
2. SOCIAL SECURITY NUMBER
4. YOUR DAY11IE TELEPHONE NUMBER {If there is no tBl6phontJ number where you can be reschBd,
pIBas8 give us s daytime number where ... can lesve s trl8SSSgs for you.}
.
o Your Number
AtaaCode
5. a. Where do you live? (Check 0fIIJ.)
I]Ii1OOse
o Shelter
0
0
Apartment
Grcq> Home
o Message Number
o Boarding House o Nursing Home
o OIher (Whst?} _ _ _-_,:_'.. '. _ _ _ _ _ __

'~_
b. With whom do you live? (Check one.)
"""'
0 WIth Family
YJith Frfends
o Other {Describe relationship.} _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

SECTION B -INFORMATION ABOUT DAILY ACTIVITIES
6. , Describe what you do from the time you wake up until going to bed.
SEe
.fA"e
11
Form S8A-3373-8K (9-2004) ef (09-2()04.) .

Page 1
Page 7 of 55
Page 7 of 55
05.1~.2Q09
.
!',.
,
.
05.18.2009
Page 227 of 2301
7. Do you take care of anyone else such as a wifelhusband, children, grandchildren,

parents, friend, other?
.
Dves
liNO
Dves
rz(No
If "VES," for whom do you care, and what do you do for them?
8. 00 you take care of pets or other animals?
If "VES," wh~t do you do for them? _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Dves
9. Does anyone help you care for other people or animals?

. If "VES," who helps, and what do they do to help?
j//l(t/~ 7J/z;1/&.#-rS e:-A-VS tI/I1,;,;..~

~wv liN ~ tn:..rl;,fz., /?G~/~ry /
..:::::-
a;v;4467Vr/~I'-~
~
11. Do the illnesses, injuries, or conditions affect our sleep?
I~m-M~b-:I~
-------------------------1
10. WPJat were you able to do before you~ illnesses, injuries, or condition~ that you Can't do now?
.lf71~~?
~o;
unr
D No
~C;1:::-;l. tJ AJ
tJ~CA-f /u-- ; e:-M;<" jI~t:I" c~
/AJ,(...(" /-ft..,lU :5~.4 ~~.
12. PERSONAL CARE (Check here .lSi if NO PROBLEM with personal care.)
a. Explain how your illnesses, injuries, or conditions affect your ability to:
Dress
---------------------------------------------1
Bathe _________________________________________
Care for hair

Shave
------------------------------------
------~-------------------------------
Feed self_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Use the toilet
-------------------------------------~
CXher?________________________________________________
Page 2
Form SSA-3373-BK (9-2004) af (09-2004)

Page 8 of 55
05.18.2009
Page 228 of 2301
b. Do you need any special reminders to take care of personal

needs and grooming?
If "YES." what type of help or reminders are needed?
,IZf No
--------------------------------
c. Do you need help or reminders taking medicine?

If "YES," what kind of help do you need?
Dyes
Dyes
E1No
------------------------------~--------
13. MEALS
IfYes
a. Do you prepare your own meals?
No
If "Yes," what kind of food do you prepare? (For example. sandwiches. frozen dinners, or complete
meals with several courses). ___________________________________________
An&nges
in cooking habits since the Hlness, injuries, or conditions began?
b. If "No; explain why you cannot or do not prepare meals. _________________--'-_
14. HOUSE AND YARD WORK

a. List household chores, both indoors and outdoors, that you are able~o. (For example,
cleaning. laundry, household repairs, ironing. mowing. etc.) ___....:~-s-._~___.,;;;L
___________
b. H~ much time
s it take you, and how ~en do YOU. do each of these things?
A. IJ V E
Ihv ~
lC~
,<1A-t,L./
E,r
{;;n;L
ttl'.(t::-
",,"';l1:t1Jt!.,
,f)0
I~-+t /~.
c. Do you need help or encouragement doing these things?

If "YES," what help is needed?
-------------------------------------~--Page 3
Fonn SSA-3373-BK {9-2004} af (09-2004)

Page 9 of 55
05.18.2009
.~.
Page 229 of 2301
d. If you don't do house or yard work, explain why not.
15. GETTING AROUND
-------------------------------
_....:!oo[)~(:.....::i:.....'1:.....t-~~tt:..---------------------------
-----------------------------------
a. How often do you go outside?

If you don't go out at all, explain why not.
b. When going out, how do you travel? (Check all that apply.)
o Walk
_use
g(Drive a car
public transportation
if Ride a bicycle
Ride in a car
Other (Explain) _ _ _ _ _ _ _ _ _ _ _ __
c. When going out, can you go out alone?

If "NO," explain why you can't go out alone.
.s
0 NO
---------------------------------11
Yes
iii Yes
d. Do you drive?
If you don't drive, explain why not.
ONo
---------------------------------~
16. SHOPPING
a. If you do any shopping. do you shop: (Check all that apply.)
&!lIn stores
By phone
b. Describe what you shop for.
N~s
By mail
..... 4 J
() IVL-
- d:=,-Jlkll~
~"- J3As/~
.d~ C"hl"; ~"
c. How often do you shop and how long does it take?
;;'tJ
o By computer
~A... '~of. . (~.
_-=/I;....-.;~;;..."'_~.:.._..___7/~----J,at---f;4-J---~"""./:.....--'r-~--r(.;...;;;:.....----l
17. MONEY
a. Are you able to:
Pay bills
Count change
ONo
DNo
Handle a savings account

Use a checkbook/money orders
DNo
No;
Explain all nNO" answers. __________________________________
Page 4
Form SSA3373-BK (9-2004) ef (09-2004)

Page 10 of 55
05.18.2009
Page 230 of 2301
b. Has your ability to handle money changed since the illnesses,

injuries, or conditions began?
If AVES," explain how the ability to handle money has changed. _ _
aYes
No
A~~_~__,_~
___e_r____
,,
18. HOBBIES AND INTERESTS

a. What are y ur ~bbies and i[lte~ests? (For e,xample, readinf/, watching TV, se~ing, play!ng sporJs,
etc.)
"" rio(
~~J
i) , Itt'
/l.<Jt:i"A:.I'''''''
h~/'
....,A-17..
~t/.
J.
b. How often and how well do you do these things?
c. Describe any cha'1ges in
/. trt-.t
se activities since the iIInes es, injuries, or conditions began.
77 #fA yo
k../i)
~N c-
"-
O~/
9--..+t1 AJC7J
19. SOCIAL ACTIVl1"IES

a. Do you spend time with others? (In person, on the phone, on the computer, etc.)
Ves
No
,t't;-.R'r /..i e /Vt//..coA/,e

O~ I~JMt::;:7vT/;.!ot../I-,'~ ~ fl:1':;TIVt:-.::... ., ~vb<-(./.
If "VES," describe the kinds ofthings you do with others.

J
How often do you do these things?
-------------------------------------
b. List the places you go on a reg.ular basis. (For example, church, community center, sports events,
(!J+r.,...(.(!.J../- C;l/~
S"v......
socia/groups, etc.)
""Ay
Do you need to be reminded to go places?

How often do you go and how much do you take part?
DVes
------------------------------
Do you need someone to accompany you?
Dves
/Sot..
DNo
~tJtA.J
Page 5
Fonn SSA-337a-BK (9-2004) af (09-2004)

Page 11 of 55
05.18.2009
Page 231 of 2301
c. Do you have any problems getting along with family, friends, neighbors,
or others?
If -;;;XPlain.
~&/-L J
AJabH
eYes
t!.J.v S 7>r--rZ:..
)!~/J.& I~(,
4iJ?."J(,
d. Describe any changes in social activities since the illnesses, injuries, or qpn9"tions began.
;tfp ~t:
L~o
(. /h7()~
FKT7l/;sMe'
[B1\Jo
~.......
-,
.-vA.",
___
p..f44,*.1 H/!b;A/1
SECTION C - INFORMATION ABOUT ABILITIES
20. a. Check any of the following items that your illnesses, injuries, or conditions affect:
o Ufting
o Squatting
o Bending
o Standing
o Reaching
o Walking
o Sitting
o Kneeling
o Talking
o Hearing
o Stair Climbing
o Seeing
o Understanding
o Following Instructions
D Memory
.If Completing Tasks
q Using Hands
iD"Getting Along With Others
II Concentration
Please explain how your illnesses, injuries, or conditions affect each of the items YQu checked. (For
example, you can only lift [hOW many pounds], or you can only walk [hOW far])
07tfzA..S .
II
b. Are you:
[l}AIght Handed?
0 Left Handed?
/
c. How far can you walk before needing to stop and rest? _A_.IJ_...v.;;....".t__---..:T:...~_.Iu"..t
_ __
(;: __'-Ltt"---JI...,;/;.....(.;:...rl",,---,,-_
If you have to rest, how long bef()re you can resume walking?
--------------------------
d. For how long can you pay attention?
,4
'"""'l
?tJA./(,
r; 4-a e-
[].:ftrs
0 No
e. Do you finish what you start? (For example, a conversation,
chores, reading, watching a movie)
1. How well do you follow written instructions? (For example, a recipe) _______________
t!~ U/t:1A
_~_---.~.----=w
___t::"l..-L_______________
g. How well do you follow spoken instructions? _-,0"",,'
Page 6
Form SSA-3373-BK (9-2004) at (09-2004)

Page 12 of 55
05.18.2009
1
!
Page 232 of 2301
h. How well do you get along with authority figures? (For example, police, bosses, landlords or
teachers)
~;(fit,t:::"A1 ~(
, ~4 ~/lc..r
~+I
tJCl..,l."
LC
,i ~-
zfh::;t
/C.uow
,;..;;c.kr- t,.t;:-r
dv("t;;,~ ~
r~ 6e-r
,+vl'~#" ~/~~r -W~'" ~r ~/~~/lktf

i. Have you ever been fired or laid off from a job because of problems getting
~es
D No
/'
..
(j)
~
Gll
along with other people?
If "VES," please explain.
h ;(. (!./.;r.4 ()v1 I
I 9 7 - I 'i 9/- 19'? J'
(!)~ (P
14;
L To . CZ>
&t~cA- /;z:::~~
iN
v"f1.,C64
dl'-ll'A
~v~
k. How well do you handle changes in routine?
Dves
I. Have you noticed any unusual behavior or fears?

If "VES," please explain. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
21. Do you use any of the following? (Check all that apply.)
[ ] Crutches
[]Walker
D Wheelchair
D Other (Explain)
[ ] Cane
D Hearing Aid
D Brace/Splint
D Artificial Limb
[ ] Glasses/Contact Lenses
D Artificial Voice Box
---------------------------------------------------
Which of these were prescribed by a doctor? _ _ _ _ _ _ _ _ _ _...;....._ _ _ _ _ _ __
When was it prescribed? _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
When do you need to use these aids? _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Page 7
Fonn SSA-3373-BK (9-2004) af (09-2004)

Page 13 of 55
05.18.2009
Page 233 of 2301
SEcnON D .. REMARKS
Use this secdon for any added Infonnation you did not ahow In earlier parts of this form. When ypu
are clone With this section (or If you dldn' have anything to add), be sunt to complet. the fields at 'the
bottom of this page.
----------------------------------~----------------------------~
Date {month, day, year)
Name of person completing this
-sr~Le-
Address (Hum
/ :; 57J
City
1'1-4- .
#l1l0?
and Street)
)(e'IIu 4/
f :5-r.
:1~~~
Form SSA-3373-BK (9-2004)

Stanley). Caterbone Case No. 0514869
Page 8
Page 14 of 55 _ _ _ __
Page 14 of 55
05.15.2009
05.18.2009
Page 234 of 2301
1250 Fremont Street
Lancaster, PA 17603
717-669-2163
scaterbone@live.com
Office of Medical and Vocational Expertise
Case Number: 0514869
Answer to Question No. 10; The following is an email that I sent to a friend to
describe the pain and torture:
Subject: WHO IS DOING THIS TO ME?
Date: Sun, 18 May 2008 03:19:47 -0400
On May 16, 2008, at 1:59 PM, Stan Caterbone wrote:
May 16, 2008
Tome,
I know that I am the victim of this technology that both Neurobotics claims and that
Carole Smith has researched regarding invasive mind control. I have some of my
research posted on my research blog
www.advancedmediagroupresearch.wordpress.com .
The peering into one's thoughts and ideas I can live with, however the pain and
torture of some of this technology is very hurtful and painful. I am trying
desperately to find the source and the means of how they deploy this on me. I try
to change my location when they use it, but that does not stop it. I was told that
the perps can isolate a person with radar and satellite, so it is hard or impossible for
me to avoid.
I know sometime tonight or tomorrow they will hit me again. They usually need to
alternate the pain and pleasure so that it reaches its full impact. You know, kind of
like making sure there is always a spectrum of highs and lows. I believe they use a
technique of using the telepathy (Sheryl Crow telepathically communicating with me
while she is physically with Brett Stabley and Dave Pflumm; which are always
predators toward me) to enga'ge me in hostile and harassing conversation along with
some sort or electromagnetic energy isolated on me.
Any help would be greatly appreciated. This is one of the main problems I have with
writing briefs and filing court documents. They will use this to interfere with my
focus and to confuse me while the hackers change my documents and briefs. It is
very challenging, but at least I am litigating, which is the important thing.
tanley J. Caterbone Case No. 0514869

Page 15 of 55
Page 15 of 55
05.15.2009
05.18.2009
Page 235 of 2301
Stan J. Caterbone
-----~---------
.. ~~~ ... -----.-----~-----
---
In addition they have used the technology of cuasing excrusiating pain, usally in my back
and my mouth. They seam to be able to either cuase the pain and amplify it or amplify
some existing discomfort and/or pain.
tanley J. Caterbone Case No. 0514869

Page 16 of 55
Page 16 of 55
05.15.2009
05.18.2009
Page 236 of 2301
/I. Ae~i /J1J"&lA4~r:r/;r,n ~<.
,;4".
,d"'y
.;<$. tt.J~ AI~J

(J.
,l)4i:/'A--4. e- ~"" ~
i3~b4'( hH r
p. ,AAt/IV"Y/ ;/0 (JJc u.-fo41r3

.
g; 17l-+vcz:.. TO 6?~ ~V#~. &teJA.-7/.
t,,/II ~IJ<.~ &.t. T7'1e,,;/e ." A... 77J /11'<-4 bt-Ivu .. c. - C/..." v?#<.~;,
,to l*'t
A- M/f.t../
>
/.
(?f th-.t.tr:M.
L,:"Ie.
U,u( (J~ jl;'(,-'f?- ~e"; &~~" ~
J. ~ "'lC..Joy~,; .4-IY~(;1:rfI/VI~,,;, ~~
It/b4ftfhr//5~IJ" /- ;tI;:Sc~~#//' V/./~r
/v/5t..IC (J/XG~ /le~' ~/t...-h:'r7~ ~/5t'-rC:.
,,-<. rt>
/It:7 ~J.,NJ
I-: E"tf"fT ~~AJc:....;/ A-7 &""M.vA/,e >7 #c-n <t!
Sr. ~~e ."....-<- ~ ~e
II., /I1.;if #J;i- V/.5 $~ 4<- a/'~
7.
~i:: ~ LVA-;eeW.
T~t y~~
'J.
/(. /Vrnwt /1/{;:7..;./
fit /114/ h
,/l.
j7
~~4. A/~
.
2?~ ~ /JI,u.-~I'v'#,i.t'-d'* ~,A~
~ ;~~.4c../c #cz,--j';"';;'~J CI~
,
.
~ t?i~v~/c.A'fl"..J
/.~" w~~.
I. .. '~R7f /.v
~
lAS't!hrt-A ~ 4.lt/~~~ /f,G'7n';""'-; ~rzvt4"~
u ..
A4.4-'.t~r;
Page 17 of 55
;-t...
0-
h-;~~/,.(.dVe-
05.18.2009
Page 237 of 2301
/II. ~~ Mt;-;v~/ ' ""Vi.;.TI_~J:."~" ~

~~(,
~'ht.+rCt:.;G3,4L
/. i
tz; "fl.
en I-~
~. ~I/;fIIv~ ~",:. ~J"?

3.
~ ;!,Ac.-/G
t>.
..
;t~.;""~,,, /II,JI!:J'/~/e;-,7
/I"''"L/N7.; .... 1
Ib
~~, .~~/~M'~
"'-MH"'- &.... 4.47-~ .
.~. '~""""r j./",..dA,;J~/~,.;,,~/

~,,~ ~/~ry
7.
IV!~(/S ~~~ff
1iA.- !3<Jd/C.
:'t.

Page 18 of 55
Page 18 of 55
'.
05.15.2009
05.18.2009
Page 238 of 2301
mailto: amgroupOl@msn.com
Blog: http://advancedmediagroup. wordpress.coml
Research Blog: www.advancedmediagroupresearch.wordpress.com
Video Biography at: http://www.youtube.com/profile?user=advancedmediagroup
1250 Fremont Street
Lancaster, PA 17603
December 3, 2007
R. Scott Smith
Chairman, President
And Chief Executive Officer
Fulton Financial Corporation
One Penn Square
P.O. Box 4887
Lancaster, Pennsylvania 17604
Re:
Black Budget Identities of the United States Government regarding Covert Activates & Mind Control
Rufus Fulton, Former Chairman and Chief Executive Officer & Department of Defense
Caterbone v. Fulton Bank litigation
Federal False Claims Act Complaint re International Signal & Control (ISe) of Lancaster, PA
Dear Mr. Smith:

I would like to bring to your attention a very dire matter that severely implicates Fulton Bank and
Fulton Financial Corporation. I would like to bring to your attention the Rufus Fulton interview of November
21, 2007 broadcast on WGAL TV 8 News at 6. This interview disclosed National Security information for the
first time regarding his work for the Department of Defense and the Kennedy Administration.
I am suggesting that his classified work with the Department of Defense and his present influence
concerning National Security matters is a dire conflict of interest concerning my litigation against Fulton Bank
that needs to be investigated by outside agencies and or authorities.
I have serious questions regarding the Defense Intelligence Agency and the possible collusion with
your institution. You have to understand that in July of 2005 while I was visiting a museum on a military
base in Austin Texas, I was detained by 2 agents for the Defense Intelligence Agency and questioned about
my Federal case 02-5588 Caterbone v. Lancaster County Prison, et aI., which Fulton Bank is a defendant,
and my whereabouts as well as my destination.
They required me to verify where I was staying, and called my brother Phil's Doctors office in Austin,
whom I was staying with, and caused his staff problems by getting them alarmed about the situation. They
were not very nice and I left them with the question "We are all on the same team, aren't we?
They left me be on my way after reviewing my documents and my Federal civil complaint, which
included information about ISC and my allegations and Federal False Claims Act; and demanding that I do
not visit any more military bases. To my knowledge I have had no physical contact since.
Page 1 of2
Page 19 of 55
December 3, 2007
05.18.2009
Page 239 of 2301
The problem is the involvement of the Department of Defense r Mr. Rufus Fulton's past affiliation and
possible influencer my allegations and civil complaints against Fulton Bank r and my telepathic abilities and
remote viewing 1
For some time I have been trying to identify groups and or agencies that may have remotely trained
me. I have written to and personally visited the office of Senator Arlen Specte~r the Federal Bureau of
Investigation 3 , the Senate Select Committee for Intelligence4 , and corresponded with the Defense Advanced
for Research Projects Agency5r and the Central Intelligence Agency6 with the hopes of finding some answers.
However they have proved fruitless.
See the attached research document dated ThursdaYr November 29, 2007, titled "THE SHADOW
GOVERNMENT; ITS IDENTIFICATION AND ANALYSIS", by Richard J. Boylan, Ph.D?; it is a report that
identifies organizations, agencies, and companies that are directly involved with mental telepathy and
remote viewing, most of which operate under the direction and funding of the Department of Defense. I
have just recently discovered this document on Friday, November 30, 2007 and found it most disturbing
after having to watch the Rufus Fulton interview the prior week. Pay particular attention to the items in
red highlight.
Your Board of Directors and the Securities and Exchange Commission should be and will be alerted to
this discovery. I wish you would reconsider your letter of November 14, 2007 and your position no to meet
with me personally to discuss some of these issues. I believe it will be in your best interest to stay ahead of
this information. A civil and criminal conspiracy allegation that involves this information will have dire
consequences to your major stakeholders and your shareholders.
As a courtesy I will promise to give you until the end of this week, December 7, 2007 to review this
material and perform any due diligence that you seem worthy; and communicate a response. After that
time, I will take it upon myself to disclose this information as it pertains to Fulton Bank and Fulton Financial
Corporation to the Securities and Exchange Commission, and others that will help protect my interests and
the interests of the Advanced Media Group and my litigation v. Fulton Bank.
Copy to file
Deliver to Stephanie Carfley, Barley Snyder, LLC
I See attached research document titled On the Need for New Criteria of DiagnOSis of Psychosis in the Light of Mind Invasive Technology
By Carole Smith Global Research, October 18, 2007; Journal of Psycho-Social Studies, 2003,
2 See attached letter dated July 12, 2007 from Stan J. Caterbone/Advanced Media Group to Senator Arlen Specter of the Senate judiciary
Committee. Senator Ar1en Specter was viSited on May 17, 2006.
3 See the attached letter dated July 16, 2007 from Stan J. Caterbone/Advanced Media Group to the Federal Bureau of Investigation (FBI),
The meeting at the FBI Philadelphia Field Office took place on October 24, 2007, and the FBI Harrisburg Field Office was visited on May
17,2006.
4 The Senate Select Intelligence Committee office was visited on May 17,2006
5 See attached email dated February 26, 2007 regarding mental telepathy and mind control to the Defense Advanced Research Projects
Agency (DARPA),
6 See the attached email confirmation from the Central Intelligence Agency (CIA),
7 See the attached research document dated Thursday, November 29, 2007, titled "THE SHADOW GOVERNMENT: ITS IDENTIFICATION
AND ANALYSIS", by Richard J. Boylan, Ph.D"
Page 2 of2
Page 20 of 55
December 3, 2007
05.18.2009
Page 240 of 2301
The calculated and technological entry into another person's mind is an act of monumental
barbarism which obliterates- perhaps with the twiddling of a dial - the history and civilisation
of man's mental development. It is more than an abuse of human rights,
it is the destruction of meaning.
For anyone who is forced into the hell of living with an unseen mental rapist, the effort to stay
sane is beyond the scope of tolerable endurance. The imaginative capacity of the ordinary
mind cannot encompass the horror of it.
We have attempted to come to terms with the experiments of the Nazis in concentration
camps. We now have the prospect of systematic control authorised by men who issue
instructions through satellite communications for the destruction of societies while they are
driving new Jaguars and Mercedes, and going to the opera.
By Carol Smith
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mind Invasive Technology
Global Research
October 18, 2007
On the Need for New Criteria of Diagnosis of Psychosis

in the Light of Mind Invasive Technology
By Carole Smith
Global Research, October 18, 2007
Journal of Psycho-Social Studies, 2003.
"We have failed to comprehend that the result of the technology that originated in the years of the arms
race between the Soviet Union and the West, has resulted in using satellite technology not only for
surveillance and communication systems but also to lock on to human beings, manipulating brain
frequencies by directing laser beams, neural-particle beams, electro-magnetic radiation, sonar waves,
radiofrequency radiation (RFR), soliton waves, torsion fields and by use of these or other energy fields
which form the areas of study for astro-physics. Since the operations are characterised by secrecy, it
seems inevitable that the methods that we do know about, that is, the exploitation of the ionosphere, our
natural shield, are already outdated as we begin to grasp the implications of their use." [Excerpt]
For those of us who were trained in a psychoanalytical approach to the patient which was characterised as
patient centred, and which acknowledged that the effort to understand the world of the other person
entailed an awareness that the treatment was essentially one of mutuality and trust, the American
Psychiatry Association's Diagnostic Criteria for Schizotypal personality was always a cause for alarm. The
Third Edition (1987) of Diagnostic and Statistical Manual of Mental Disorders (DSM) required that there be
at least four of the characteristics set out for a diagnosis of schizophrenia, and an approved selection of
four could be: magical thinking, telepathy or sixth sense; limited social contact; odd speech; and over
sensitivity to criticism. By 1994, the required number of qualifying characteristics were reduced to two or
more, including, say, hallucinations and 'negative' symptoms such as affective flattening, or disorganised
or incoherent speech - or only one if the delusions were bizarre or the hallucination consisted of a voice
keeping up a running commentary on the person's behaviour or thoughts. The next edition of the DSM is
not due until the year 2010.
In place of a process of a labelling which brought alienation and often detention, sectioning, and mind
altering anti-psychotic medication, many psychoanalysts and psychotherapists felt that even in severe
cases of schizoid withdrawal we were not necessarily wasting our time in attempting to restore health by
the difficult work of unravelling experiences in order to make sense of an illness. In this way,
psychoanalysis has been, in its most radical form, a critic of a society, which failed to exercise imaginative
empathy when passing judgement on people. The work of Harry Stack Sullivan, Frieda Fromm-Reichmann,
all trained as psychiatrists and all of them rebels against the standard
Harold Searles or R.D. Laing
procedures - provided a way of working with people very different from the psychiatric model, which
seemed to encourage a society to repress its sickness by making a clearly split off group the carriers of it.
A psychiatrist in a mental hospital once joked to me, with some truth, when I commented on the number
of carrier bags carried by many of the medicated patients around the hospital grounds, that they assessed
By Carole Smith of Global Research
Page 1 of 13
Page 21 of 55
October 18, 2007
05.18.2009
Page 241 of 2301
the progress of the patient in terms of the reduction of the number of carrier bags. It is too often difficult
to believe, however, when hearing the history of a life, that the "schizophrenic" was not suffering the
effects of having been made, consciously and unconsciously, the carefully concealed carrier of the ills of
the family.
For someone who felt his mind was going to pieces, to be put into the stressful situation of the psychiatric
examination, even when the psychiatrist acquitted himself with kindness, the situation of the assessment
procedure itself, can be 'an effective way to drive someone crazy, or more crazy.' (Laing, 1985, p 17).
But if the accounting of bizarre experiences more or less guaranteed you a new label or a trip to the
psychiatric ward, there is even more reason for a new group of people to be outraged about how their
symptoms are being diagnosed. A doubly cruel sentence is being imposed on people who are the victims
of the most appalling abuse by scientific-military experiments, and a totally uncomprehending society is
indifferent to their evidence. For the development of a new class of weaponry now has the capability of
entering the brain and mind and body of another person by technological means.
Harnessing neuroscience to military capability, this technology is the result of decades of research and
experimentation, most particularly in the Soviet Union and the United States. (Welsh, 1997, 2000) We
have failed to comprehend that the result of the technology that originated in the years of the arms race
between the Soviet Union and the West, has resulted in using satellite technology not only for surveillance
and communication systems but also to lock on to human beings, manipulating brain frequencies by
directing laser beams, neural-particle beams, electro-magnetiC radiation, sonar waves, radiofrequency
radiation (RFR), soliton waves, torsion fields and by use of these or other energy fields which form the
areas of study for astro-physics. Since the operations are characterised by secrecy, it seems inevitable
that the methods that we do know about, that is, the exploitation of the ionosphere, our natural shield,
are already outdated as we begin to grasp the implications of their use. The patents deriving from Bernard
J. Eastlund's work provide the ability to put unprecedented amounts of power in the Earth's atmosphere at
strategic locations and to maintain the power injection level, particularly if random pulsing is employed, in
a manner far more precise and better controlled than accomplished by the prior art, the detonation of
nuclear devices at various yields and various altitudes. (ref High Frequency Active Auroral Research
Project, HAARP).
Some patents, now owned by Raytheon, describe how to make "nuclear sized explosions without
radiation" and describe power beam systems, electromagnetic pulses and over-the-horizon detection
systems. A more disturbing use is the system developed for manipulating and disturbing the human
mental process using pulsed radio frequency radiation (RFR), and their use as a device for causing
negative effects on human health and thinking. The victim, the innocent civilian target is locked on to, and
unable to evade the menace by moving around. The beam is administered from space. The Haarp facility
as military technology could be used to broadcast global mind-control, as a system for manipulating and
disturbing the human mental process using pulsed radio frequency (RFR). The super-powerful radio waves
are beamed to the ionosphere, heating those areas, thereby lifting them. The electromagnetic waves
bounce back to the earth and penetrate human tissue.
Dr Igor Smirnov, of the Institute of Psycho-Correction in Moscow, says: "It is easily conceivable that some
Russian 'Satan', or let's say Iranian or any other 'Satan', as long as he owns the appropriate means and
finances, can inject himself into every conceivable computer network, into every conceivable radio or
television broadcast, with relative technological ease, even without disconnecting cables ...and intercept the
radio waves in the ether and modulate every conceivable suggestion into it. This is why such technology is
rightfully feared."(German TV documentary, 1998).
If we were concerned before about diagnostic criteria being imposed according to the classification of
recognizable symptoms, we have reason now to submit them to even harsher scrutiny. The development
over the last decades since the Cold War arms race has included as a major strategic category, psycho
electroniC weaponry, the ultimate aim of which is to enter the brain and mind. Unannounced, undebated
and largely unacknowledged by scientists or by the governments who employ them - technology to enter
and control minds from a distance has been unleashed upon us. The only witnesses who are speaking
about this terrible technology with its appalling implications for the future, are the victims themselves
and those who are given the task of diagnosing mental illness are attempting to silence them by
classifying their evidence and accounts as the symptoms of schizophrenia, while the dispensers of psychic
mutilation and programmed pain continue with their work, aided and unopposed.
Page 2 of 13
Page 22 of 55
Odober 18, 2007
05.18.2009
Page 242 of 2301
If it was always crucial, under the threat of psychiatric sectioning, to carefully screen out any sign of
confused speech, negativity, coldness, suspicion, bizarre thoughts, sixth sense, telepathy, premonitions,
but above all the sense that "others can feel my feelings, and that someone seemed to be keeping up a
running commentary on your thoughts and behaviour," then reporting these to a psychiatrist, or anyone
else for that matter who was not of a mind to believe that such things as mind-control could exist, would
be the end of your claim to sanity and probably your freedom. For one of the salient characteristics of
mind-control is the running commentary, which replicates so exactly, and surely not without design, the
symptoms of schizophrenia. Part of the effort is to remind the victim that they are constantly under
control or surveillance. Programmes vary, but common forms of reminders are electronic prods and
nudges, body noises, twinges and cramps to all parts of the body, increasing heart beats, applying
pressures to internal organs - all with a personally codified system of comments on thoughts and events,
designed to create stress, panic and desperation. This is mind control at its most benign. There is reason
to fear the use of beamed energy to deliver lethal assaults on humans, including cardiac arrest, and
bleeding in the brain.
It is the government system of secrecy, which has facilitated this appalling prospect. There have been
warning voices. " ...the government secrecy system as a whole is among the most poisonous legacies of
the Cold War ...the Cold War secrecy (which) also mandate(s) Active Deception ...a security manual for
special access programs authorizing contractors to employ 'cover stories to disguise their activities. The
only condition is that cover stories must be believable." (Aftergood & Rosenberg, 1994; Bulletin of Atomic
Scientist). Paranoia has been aided and abetted by government intelligence agencies.
In the United Kingdom the fortifications against any disturbing glimmer of awareness of such actual or
potential outrages against human rights and social and political abuses seem to be cast in concrete.
Complete with crenellations, ramparts and parapets, the stronghold of nescience reigns supreme. To
borrow Her Majesty the Queen's recent observation: "There are forces at work of which we are not
aware." One cannot say that there is no British Intelligence on the matter, as it is quite unfeasible that
the existence of the technology is not classified information. Indeed it is a widely held belief that the
women protesting against the presence of cruise missiles at Greenham Common were victims of electro
magnetic radiation at gigahertz frequency by directed energy weapons, and that their symptoms,
including cancer, were consistent with such radiation effects as reported by Dr Robert Becker who has
been a constantly warning voice against the perils of electro-magnetic radiation. The work of Allen Frey
suggests that we should consider radiation effects as a grave hazard producing increased permeability of
the blood-brain barrier, and weakening crucial defenses of the central nervous system against toxins.
(Becker, 1985, p. 286). Dr Becker has written about nuclear magnetic resonance as a familiar tool in
medecine known as magnetic resonance imaging or MRI. Calcium efflux is the result of cyclotronic
resonance which latter can be explained thus: If a charged particle or ion is exposed to a steady magnetic
field in space, it will begin to go into a circular or orbital, motion at right angles to the applied magnetic
field.The speed with which it orbits will be determined by the ratio between the charge and the mass of
the particle and by the strength of the magnetic field. (Becker, 1990,p.235) The implications of this for
wide scale aggression by using a combination of radar based energy and the use of nuclear resonating are
beyond the scope of the writer, but appear to be worth the very serious consideration of physicists in
assessing how they might be used against human beings.
Amongst medical circles, however, it has so far not been possible for the writer to find a neuroscientist,
neurologist or a psychiatrist, nor for that matter, a general medical practitioner, who acknowledges even
the potential for technological manipulation of the nervous system as a problem requiring their
professional interest. There has been exactly this response from some of England's most eminent
practitioners of the legal profession, not surprisingly, because the information about such technology is
not made available to them. They would refer anyone attempting to communicate mind- harassment as a
psychiatric problem, ignoring the crime that is being committed.
The aim here is not to attempt a comprehensive history and development of the technology of mind
control. These very considerable tasks - which have to be done under circumstances of the most extreme
difficulty - have been addressed with clarity and courage by others, who live with constant harm and
threats, not least of all contemptuous labelling. Their work can be readily accessed on the internet
references given at the end of this paper. For a well-researched outline of the historical development of
electro-magnetic technology the reader should refer to the timeline of dates and electromagnetic weapon
development by Cheryl Welsh, president of Citizens against Human Rights Abuse. (Welsh 1997; 2001).
Page 3 of 13
Page 23 of 55
October 18. 2007
05.18.2009
Page 243 of 2301
There are at least one and a half thousand people worldwide who state they are being targeted. Mojmir
Babacek, now domiciled in his native Czech Republic, after eight years of residence in the United States in
the eighties, has made a painstakingly meticulous review of the technology, and continues his research.
(Babacek 1998, 2002)
We are concerned here with reinforcing in the strongest possible terms:
i) The need for such abuses to human rights and the threats to democracy to be called to consciousness,
and without further delay.
ii) To analyse the reasons why people might defend themselves from becoming conscious of the existence
of such threats.
iii) To address the urgent need for intelligence, imagination, and information
compassion - in dealing with the victims of persecution from this technology, and
- not to mention
iv) To alert a sleeping society, to the imminent threats to their freedom from the threat from fascist and
covert operations who have in all probability gained control of potentially lethal weaponry of the type we
are
describing.
It is necessary to emphasise that at present there is not even the means for victims to gain medical
attention for the effects of radiation from this targeting. Denied the respect of credulity of being used as
human guinea pigs, driven to suicide by the breakdown of their lives, they are treated as insane - at best
regarded as 'sad cases'. Since the presence of a permanent 'other' in one's mind and body is by definition
an act of the most intolerable cruelty, people who are forced to bear it but who refuse to be broken by it,
have no other option than to turn themselves into activists, their lives consumed by the battle against
such atrocities, their energies directed to alerting and informing the public of things they don't want to
hear
or
understand
about
evil
forces
at
work
in
their
society.
It is necessary, at this pOint, to briefly outline a few - one might say the precious few - attempts by public
servants
to
verify
the
existence
and
dangers
inherent
in
this
field:
In January 1998, an annual public meeting of the French National Bioethics Committee was held in
Paris. Its chairman, Jean-Pierre Changeux, a neuroscientist at the Institut Pasteur in Paris, told the
meeting that "advances in cerebral imaging make the scope for invasion of privacy immense.
Although the equipment needed is still highly specialized, it will become commonplace and capable
of being used at a distance. That will open the way for abuses such as invasion of personal liberty,
control of behaviour and brainwashing. These are far from being science-fiction concerns...and
constitute "a serious risk to society." ("Nature." Vol 391, 1998.
In January 1999, the European Parliament passed a resolution where it calls" for an international
convention introdUcing a global ban on all development and deployment of weapons which might
enable any form of manipulation of human beings. It is our conviction that this ban can not be
implemented without the global pressure of the informed general public on the governments. Our
major objective is to get across to the general public the real threat which these weapons
represent for human rights and democracy and to apply pressure on the governments and
parliaments around the world to enact legislature which would prohibit the use of these devices to
both
government
and
private
organisations
as
well
as
individuals."
(Plenary
sessions/Europarliament, 1999)
In October 2001, Congressman Dennis J. Kucinich introduced a bill to the House of

Representatives which, it was hoped would be extremely important in the fight to expose and stop
psycho-electronic mind control experimentation on involuntary, non-consensual citizens. The Bill
was referred to the Committee on SCience, and in addition to the Committee on Armed Services
and International Relations. In the original bill a ban was sought on 'exotic weapons' including
electronic, psychotronic or information weapons, chemtrails, particle beams, plasmas,
electromagnetic radiation, extremely low frequency (ELF) or ultra low frequency (ULF) energy
radiation, or mind control technologies. Despite the inclusion of a prohibition of the basing of
weapons in space, and the use of weapons to destroy objects or damage objects in space, there is
Page 4 of13
Page 24 of 55
October 18.2007
05.18.2009
Page 244 of 2301
no mention in the revised bill of any of the aforementioned mind-invasive weaponry, nor of the use
of satellite or radar or other energy based technology for deploying or developing technology
designed for deployment against the minds of human beings. (Space Preservation Act, 2002)
In reviewing the development of the art of mind-invasive technology- there are a few outstanding
achievements to note:
In 1969 Dr Jose Delgado, a Yale psychologist, published a book: "Physical Control of the Mind: Towards a
Psychocivilized Society". In essence, he displayed in practical demonstrations how, by means of electrical
stimulation of the brain which had been mapped out in its relations between different points and activities,
functions and sensations,
by means of electrical stimulation, how the rhythm of breathing and
heartbeat could be changed, as well as the function of most of the viscera, and gall bladder secretion.
Frowning, opening and closing of eyes and mouth, chewing, yawning, sleep, dizziness, epileptic seizures in
healthy persons were induced. The intensity of feelings could be controlled by turning the knob, which
controlled the intensity of the electric current. He states at the end of his book the hope that the new
power will remain limited to scientists or some charitable elite for the benefit of a "psychocivilized SOCiety."
In the 1980's the neuromagnetometer was developed which functions as an antenna and could monitor
the patterns emerging from the brain. (In the seventies the scientists had discovered that electromagnetic
pulses enabled the brain to be stimulated through the skull and other tissues, so there was no more need
to implant electrodes in the brain). The antenna, combined with the computer, could localize the points in
the brain where the brain events occur. The whole product is called the magnetoencephalograph.
In January 2000 the Lockheed Martin neuroengineer Dr John D. Norseen, was quoted (US News and World
Report, 2000) as hoping to turn the electrohypnomentalaphone, a mind reading machine, into science
fact. Dr Norseen, a former Navy pilot, claims his interest in the brain stemmed from reading a Soviet book
in the 1980's claiming that research on the mind would revolutionize the military and society at large. By
a process of deciphering the brain's electrical activity, electromagnetic pulsations would trigger the release
of the brain's own transmitters to fight off disease, enhance learning, or alter the mind's visual images,
creating a 'synthetic reality'. By this process of BioFusion, (Lockheed Martin, 2000) information is placed
in a database, and a composite model of the brain is created. By viewing a brain scan recorded by
(functional) magnetiC resonance imaging (fMRI) machine, scientists can tell what the person was doing at
the time of recording - say reading or writing, or recognise emotions from love to hate. "If this research
pans out", says Norseen, "you can begin to manipulate what someone is thinking even before they know
it." But Norseen says he is 'agnostic' on the moral ramifications, that he's not a mad scientist - just a
dedicated one. "The ethics don't concern me," he says, "but they should concern someone else."
The next big thing looks like being something which we might refer to as a neurocomputer but it need
not resemble a laptop - it may be reducible to whatever size is convenient for use, such as a small mobile
phone. Arising from a break-through and exploitation of PSI-phenomena, it may be modelled on the
nervous-psychic activity of the brain - that is, as an unbalanced, unstable system of neurotransmitters
and interacting neurones, the work having been derived from the creation of a copy of a living brain
accessed by chance, and ESP and worked on by design.
On receiving a communication from the writer on the feasibility of a machine being on the horizon which,
based on the project of collecting electromagnetic waves emanating from the brain and transmitting them
into another brain that would read a person's thoughts, or using the same procedure in order to impose
somebody else's thoughts on another brain and in this way direct his actions - there was an unequivocal
answer from IBM at executive level that there was no existing technology to create such a computer in the
foreseeable future. This is at some variance with the locating of a patent numbered 03951134 on the
Internet pages of IBM Intellectual Property Network for a device, described in the patent, as capable of
picking up at a distance the brain waves of a person, process them by computer and emit correcting
waves which will change the original brain waves. Similar letters addressed to each of the four top
executives of Apple Inc., in four individual letters marked for their personal attention, produced absolutely
no response. This included the ex- Vice President of the United States, Mr AI Gore, newly elected to the
Board of Directors of Apple.
Page 5 of13
Page 25 of 55
October 18. 2007
05.18.2009
Page 245 of 2301
Enough people have been sufficiently concerned by the reports of victims of mind control abuse to
organise The Geneva Forum, in 2002, held as a joint initiative of the Quaker United Nations Office,
Geneva; the United Nations Institute for Disarmament Research; the International Committee of the Red
cross, and the Human Rights Watch (USA), and Citizens against Human Rights Abuses (CAHRA); and the
Programme for Strategic and International Security Studies, which was represented by the Professor and
Senior Lecturer from the Department of Peace Studies at the University of Bradford.
In England, on May 25, 1995, the Guardian newspaper in the U.K. carried an article based on a report by
Nic Lewer, the peace researcher from Bradford University, which listed "more than 30 different lines of
research into 'new age weapons'..."some of the research sounds even less rational. There are, according to
Lewer, plans for 'pulsed microwave beams' to destroy enemy electronics, and separate plans for very-Iow
frequency sound beams to induce vomiting, bowel spasm, epileptic seizures and also crumble masonry."
Further, the article states, "There are plans for 'mind control' with the use of 'psycho-correction messages'
transmitted by subliminal audio and visual stimuli. There is also a plan for 'psychotronic weapons'
apparently the projection of consciousness to other locations - and another to use holographic projection
to disseminate propaganda and misinformation." (Welsh, Timeline). Apart from this notable exception it is
difficult to locate any public statement of the problem in the United Kingdom.
Unfortunately, the problem of credulity does not necessarily cease with frequent mention, as in the United
States, in spite of the number of reported cases, there is still not sufficient public will to make strenuous
protest against what is not only already happening, but against what will develop if left unchecked. It
appears that the administration believes that it is necessary and justifiable, in the interests of national
security, to make experimental human sacrifices, to have regrettable casualties, for there to be collateral
damage, to suffer losses in place of strife or war. This is, of course, totally incompatible with any claims
to be a democratic nation which respects the values of human life and democracy, and such an
administration which tutors its servants in the ways of such barbaric tortures must be completely
condemned as uncivilised and hypocritical.
Disbelief as a Defence Mechanism
In the face of widespread disbelief about mind-control, it seems worth analysing the basis of the
mechanisms employed to maintain disbelief:
i) In the sixties, Soviet dissidents received a significant measure of sympathy and indignant protest from
western democracies on account of their treatment, most notedly the abuse of psychiatric methods of
torture to which they were SUbjected. It is noteworthy that we seem to be able to access credulity,
express feelings of indignant support when we can identify with victims, who share and support our own
value system, and who, in this particular historical case, reinforced our own values, since they were
protesting against a political system which also threatened us at that time. Psychologically, it is equally
important to observe that support from a safe distance, and the benefits to the psyche of attacking a split
off 'bad father', the soviet authorities in this case, presents no threat to one's internal system; indeed it
relieves internal pressures. On the other hand, recognizing and denouncing a similar offence makes very
much greater psychic demands of us when it brings us into conflict with our own environment, our own
security, our own reality. The defence against disillusion serves to suppress paranoia that our father
figure, the preSident, the prime minister, our governments - might not be what they would like to be seen
to be.
ii) The need to deposit destructive envy and bad feelings elsewhere, on account of the inability of the ego
to acknowledge ownership of them - reinforces the usefulness of persons or groups, which will serve to
contain those, disowned, projected feelings which arouse paranoid anxieties. The concepts of mind
invasion strike at the very heart of paranoid anxiety, causing considerable efforts to dislodge them from
the psyche. The unconscious identification of madness with dirt or excrement is an important aspect of
anal aggression, triggering projective identification as a defence.
iii) To lay oneself open to believing that a person is undergoing the experience of being invaded mentally
and physically by an unseen manipulator requires very great efforts in the self to manage dread.
Page6of13
Page 26 of 55
October 18. 2007
05.18.2009
Page 246 of 2301
iv) The defence against the unknown finds expression in the split between theory and practice; between
the scientist as innovator and the society who can make the moral decisions about his inventions;
between fact and science fiction, the latter of which can present preposterous challenges to the
imagination without undue threat, because it serves to reinforce a separation from the real.
v) Identification with the aggressor. Sadistic fantaSies, unconscious and conscious, being transferred on to
the aggressor and identified with, aid the repression of fear of passivity, or a dread of punishment. This
mechanism acts to deny credulity to the victim who represents weakness. This is a common feature of
satanic sects.
vi) The liberal humanist tradition which denies the worst destructive capacities of man in the effort to
sustain the belief in the great continuity of cultural and scientific tradition; the fear, in one's own past
development, of not being 'ongoing', can produce the psychic effect of reversal into the opposite to shield
against aggressive feelings. This becomes then the exaggerated celebration of the 'new' as the affirmation
of human genius which will ultimately be for the good of mankind, and which opposes warning voices
about scientific advances as being peSSimistic, unenlightened, unprogressive and Luddite. Strict
adherence to this liberal position can act as overcompensation for a fear of envious spOiling of good
posseSSions, i.e. cultural and intellectual goods.
vii) penial by displacement is also employed to ignore the harmful aspects of technology. What may be
harmful for the freedom and good of society can be masked and concealed by the distribution of new and
entertaining novelties. The technology, which puts a camera down your gut for medical purposes, is also
used to limit your freedom by surveillance. The purveyors of innovative technology come up with all sorts
of new gadgets, which divert, entertain and feed the acquisitive needs of insatiable shoppers, and bolster
the economy. The theme of "Everything's up to date in Kansas City" only takes on a downside when
individual experience - exploding breast implants, say - takes the gilt off the gingerbread. Out of every
innovation for evil (i.e. designed for harming and destroying) some 'good' (i.e. public diversion or
entertainment) can be promoted for profit or crowd-pleasing.
viii) Nasa is sending a spacecraft to Mars, or so we are told. They plan to trundle across the Martian
surface searching for signs of water and life. We do not hear dissenting voices about its feasibility.
Why is it that, when a person accounts that their mind is being disrupted and they are being persecuted
by an unseen method of invasive technology, that we cannot bring ourselves to believe them? Could it be
that the horror involved in the empathic identification required brings the shutters down? Conversely, the
shared experience of the blasting of objects into space brings with it the possibilities of shared potency or
the relief that resonates in the unconscious of a massive prOjection or evacuation - a shared experience
which is blessed in the name of man's scientific genius.
ix) The desire 'not to be taken in', not to be taken for a fool, provides one of the most powerful and
common defence mechanism against credulity.
Power, Paranoia and Unhealthy Governments

The ability to be the bearer and container of great power without succumbing to the pressures of latent
narcissistic psychoses is an important matter too little considered. The effect of holding power and the
expectation and the need to be seen as capable of sustaining it, if not exercising it, encourages
omnipotence of thought. In the wake of this, a narcissistic overevaluation of the subject's own mental
processes may set in. In the effort to hold himself together as the possessor, container and executor of
power, he (or indeed, she) may also, undergo a process of splitting which allows him, along with others,
to bear enthralled witness of himself in this illustrious role. This may mean that the seat of authority is
vacated, at least at times. The splitting process between the experiencing ego and the perceiving ego
allows the powerful leader to alternate his perception of himself inside and outSide, sometimes beside,
himself. With the reinforcement of himself from others as his own narcissistic object, reality testing is
constrained. In this last respect, he has much in common with the other powerful figure of the age, the
movie star. or by those, in Freud's words, who are "ruined by success."
Page 7 of 13
Page 27 of 55
October 18, 2007
05.18.2009
Page 247 of 2301
In a world, which is facing increasing disillusion about the gulf between the public platforms on which
governments are elected, and the contingencies and pragmatics of retaining defence strategies and
economic investments, the role of military and intelligence departments, with their respective tools of
domination and covert infiltration, is increasingly alarming. Unaccountable to the public, protected from
exposure and prosecution by their immunity, licensed to lie as well as to kill, it is in the hands of these
agents that very grave threats to human rights and freedom lies. Empowered to carry out aggression
through classified weapon experimentation which is undetectable, these men and women are also open to
corruption from lucrative offers of financial reward from powerful and sinister groups who can utilize their
skills, privileged knowledge and expertise for frankly criminal and fascist purposes.
Our information about the psychological profiles of those who are employed to practice surveillance on
others is limited, but it is not difficult to imagine the effects on the personality that would ensue with the
perSistent practice of such an occupation, so constantly exposed to the perversions. One gains little
snatches of insight here and there. In his book on CIA mind control research (Marks, 1988), John Marks
quotes a CIA colleague's joke (always revealing for personality characteristics): "If you could find the
natural radio frequency of a person's sphincter, you could make him run out of the room real fast." (One
wonders if the same amusement is derived from the ability to apply, say infra-sound above 130 decibels,
which is said to cause stoppage of the heart, according to one victim/activist from his readings of a report
for the Russian Parliament.)
left to themselves, these servants of the state may well feel exempt from the process of moral self
scrutiny, but the work must be dehumanising for the predator as well as the prey. It is probably true that
the need to control their agents in the field was an incentive to develop the methods in use today. It is
also an effectively brutalising training for persecuting others. Meanwhile the object, the prey, in a bid for
not only for survival but also in a desperate effort to warn his or her fellows about what is going on,
attempts to turn himself into a quantum phYSicist, a political researcher, a legal sleuth, an activist, a
neurologist, a psychologist, a physiologist
his own doctor, since he cannot know what effects this
freakish treatment might have on his body, let alone his mind. There are always new methods to try out
which might prove useful in the search to find ways of disabling and destroying opponents air injected
into brains and lungs, lasers to strike down or blind, particle beams, sonar waves, or whatever
combination of energies to direct, or destabilise or control.
Science and Scepticism
Scientists can be bought, not just by governments, but also by sinister and secret societies. Universities
can be funded by governments to develop technology for unacceptably inhumane uses. The same people
who deliver the weapons - perhaps respected scientists and academics - may cite the acceptable side of
scientific discoveries, which have been developed by experimenting on unacknowledged, unfortunate
people. In a cleaned up form, they are then possibly celebrated as a break-through in the understanding
of the natural laws of the universe. It is not implausible that having delivered the technical means for
destruction, the innovator and thinker goes on, wearing a different hat, to receive his (or her) Nobel Prize.
There are scientists who have refused to continue to do work when they were approached by CIA and
Soviet representatives. These are the real heroes of SCience.
In the power struggle, much lies at stake in being the first to gain control of ultimate mind-reading and
mind-controlling technology. Like the nuclear bomb, common ownership would seem by any sane
calculations to cancel out the advantage of possession, but there is always a race to be the first to possess
the latest ultimate means of mass destruction. The most desirable form is one that can be directed at
others without contaminating oneself in the process - one that can be undetected and neatly, economically
and strategically delivered. We should be foolish to rule out secret organisations, seeing threat only from
undemocratic countries and known terrorist groups.
As consumers in a world which is increasingly one in which shopping is the main leisure activity, we should
concern ourselves to becoming alert to the ways in which human welfare may have been sacrificed to
produce an awesome new gadget. It may be the cause for celebration for the 'innovator', but brought
about as the result of plugging in or dialling up the living neuronal processes of an enforced
experimentee. If we are concerned not to eat boiled eggs laid by battery hens, we might not regard it
morally irrelevant to scrutinise the large corporations producing electronically innovative 'software.' We
Page 8 of13
Page 28 of 55
October 18. 2007
05.18.2009
Page 248 of 2301
might also be wary about the origins of the sort of bland enticements of dating agencies who propose
finding your ideal partner by matching up brain frequencies and 'bio-rhythms'.
We do not know enough about the background of such technology, nor how to evaluate it ethically. We do
not know about its effects on the future, because we are not properly informed. If governments persist in
concealing the extent of their weapon capability in the interests of defence, they are also leaving their
citizens disempowered of the right to protest against their deployment. More alarmingly, they are leaving
their citizens exposed to their deployment by ruthless organisations whose concerns are exactly the
opposite of democracy and human rights.
Back in the United Kingdom

Meanwhile, back in England, the Director of the Oxford Centre for Cognitive Neuroscience, Professor Colin
Blakemore, also the elective Chief Executive of the Medical Research Council writes to the author that he
" ... knows of no technology (not even in the wildest speculations of neuroscientists) for scanning and
collecting 'neuronal data' at a distance." (Blakemore, 2003, ) This certitude is at distinct variance with the
fears of other scientists in Russia and the United States, and not least of all with the fears of the French
neuroscientist, Jean-Pierre Changeux of the French National Bioethics Committee already quoted (see
page 5). It is also very much at odds with the writing of Dr Michael Persinger from the Behavioural
Neuroscience Laboratory at Laurentian University in Sudbury, Ontario, Canada. His article "On the
Possibility of Directly Accessing Every Human Brain by Electromagnetic Induction of Algorithms" (1995),
he describes the ways that individual differences among human brains can be overcome and comes to a
conclusion about the technological possibilities of influencing a major part of the approximately six billion
people on this planet without mediation through classical sensory modalities but by generating
electromagnetic induction of fundamental algorithms in the atmosphere. Dr Persinger's work is referred to
by Captain John Tyler whose work for the American Air Force and Aerospace programmes likens the
human nervous system to a radio receiver. (1990)
Very recently the leading weekly cultural BBC radio review had as one of its guests, the eminent astro
physicist and astronomer royal, Sir Martin Rees, who has recently published a book, "Our Final Century",
in which he makes a sober and reasoned case for the fifty-fifty chance that millions of people, probably in
a 'third-world country' could be wiped out in the near future through biotechnology and bio-terrorism
"by error or malign release." He spoke of this devastation as possibly coming from small groups or cults,
based in the United States. " ...few individuals with the right technology to cause absolute mayhem." He
also said that in this century, human nature is no longer a fixed commodity, that perhaps we should
contemplate the possibility that humans would even have implants in the brain.
The other guests on this programme were both concerned with Shakespeare, one a theatre producer and
the other a writer on Shakespeare, while his remaining guest was a young woman who had a website
called "Spiked", the current theme of which was Panic Attack, that is to say, Attack on Panic. This guest
vigorously opposed what she felt was the pessimism of Sir Martin, regarding his ideas as essentially
eroding trust, and inducing panic. This reaction seems to typify one way of dealing with threat and
anxiety, and demonstrates the difficulty that a warning voice, even from a man of the academic
distinction of Martin Rees, has in alerting people to that which they do not want to hear. This flight
reaction was reinforced by the presenter who summed up the morning's discussion at the end of the
programme with the words: "We have a moral! Less panic, more Shakespeare!"
The New Barbarism

Since access to a mind-reading machine will enable the operator to access the ideas of another person, we
should prepare ourselves for a new world order in which ideas will be, as it were, up for grabs. We need
not doubt that the contents of anothers mind will be scooped up, scooped out, sorted through as if the
event was a jumble sale. The legal profession would therefore be well advised to consider the laws on
Intellectual Property very judiciously in order to acquit themselves with any degree of authenticity. We
should accustom ourselves to the prospect of recognizing our work coming out of the mouth of another.
The prospect of wide-scale fraud, and someone posturing in your stolen clothes will not be a pretty sight.
The term "personal mind enhancement" is slipping in through the back door, to borrow a term used by
the Co-Director of the Center for Cognitive Liberty and Ethics, and it is being done through
Page 9 of 13
Page 29 of 55
October 18. 2007
05.18.2009
Page 249 of 2301
technologically-induced mental co-ercion - mind raping and looting. In place of, or in addition to, cocaine,
we may expect to see 'mind-enhanced' performances on "live" television.
The brave new science of neuropsychiatry and brain mapping hopes to find very soon, with the fMRI
scanner - this "brand new toy that scientists have got their hands on" - "the blob for love" and "the blob
for guilt", (BBC Radio 4: All in the Mind,S March, 2003). Soon we will be able to order a brain scan for
anyone whose behaviour strikes us as odd or bizarre, and the vicissitudes of a life need no longer trouble
us in our diagnostic assessments. In his recent Reith Lectures for the BBC (2003), Professor
Ramachandran, the celebrated neuroscientist from the La Hoya Institute in San Diego, California, has
demonstrated for us many fascinating things that the brain can do. He has talked to us about personality
disorders and shown that some patients, who have suffered brain damage from head injury, do not have
the capacity to recognise their mothers. Others feel that they are dead. And indeed he has found brain
lesions in these people. In what seems to be an enormous but effortless leap, the self-styled "kid in a
candy store" is now hoping to prove that all schizophrenics, have damage to the right hemisphere of the
brain, which results in the inability to distinguish between fantasy (sic) and reality. Since Professor
Ramachandran speaks of schizophrenia in the same breath as denial of illness, or agnosia, it is not clear,
and it would be interesting to know, whether the person with the head injury has been aware or unaware
of the head injury. Also does the patient derive comfort and a better chance at reality testing when he is
told of the lesion? Does he feel better when he has received the diagnosis? And what should the
psychoanalysts - and the psychiatrists, - feel about all those years of treating people of whose head
injuries they were absolutely unaware? Was this gross negligence? Were we absolutely deluded in
perceiving recovery in a sizeable number of them?
It is, however, lamentable that a neuroscientist with a professed interest in understanding schizophrenia
should seek to provide light relief to his audience by making jokes about schizophrenics being people who
are "convinced that the CIA has implanted devices in their brain to control their thoughts and actions, or
that aliens are controlling them." (Reith Lecture, No 5, 2003).
There is a new desire for concretisation. The search for meaning has been replaced by the need for hard
proof. If it doesn't light up or add up it doesn't have validity. The physician of the mind has become a
surgeon. "He found a lump as big as a grapefruit!"
Facing up to the Dread and Fear of the Uncanny
Freud believed that an exploration of the uncanny would be a major direction of exploration of the mind in
this century. The fear of the uncanny has been with us for a very long time. The evil eye, or the terrifying
double, or intruder, is a familiar theme in literature, notably of Joseph Conrad in The Secret Sharer, and
Maupassant's short story, Le Horla. Freud's analysis of the uncanny led him back to the old animistic
conception of the universe: " ...it seems as if each one of us has been through a phase of individual
development corresponding to the animistic phase in primitive men, that none of us has passed through it
without preserving certain residues and traces of it which are still capable of manifesting themselves, and
that everything which now strikes us as 'uncanny' fulfils the condition of touching those residues of
animistic mental activity within us and bringing them to expression." (Freud: 1919. p.362)
The separation of birth, and the childhood fear of 'spooks in the night', also leave their traces in each and
every one of us. The individual experience of being alone in one's mind - the solitary fate of man which
has never been questioned before, and upon which the whole history of civilised nurture is based - is now
assaulted head-on. Since growing up is largely synonymous with acceptance of one's aloneness, the
effort to assuage it is the basis for compassion and protection of others; it is the matrix for the greatest
good, that of ordinary human kindness, and is at the heart of the communicating power of great art. Even
if we must all live and die alone, we can at least share this knowledge in acts of tenderness which atone
for our lonely state. In times of loss and mental breakdown, the starkness of this aloneness is all too
clear. The best of social and group constructiveness is an effort to allay the psychotic anxieties that lie at
the base of every one of us, and which may be provoked under extreme enough conditions.
The calculated and technological entry into another person's mind is an act of monumental barbarism
which obliterates- perhaps with the twiddling of a dial - the history and civilisation of man's mental
development. It is more than an abuse of human rights, it is the destruction of meaning. For anyone who
Page 10 of 13
Page 30 of 55
October 18, 2007
05.18.2009
Page 250 of 2301
is forced into the hell of living with an unseen mental rapist, the effort to stay sane is beyond the scope of
tolerable endurance. The imaginative capacity of the ordinary mind cannot encompass the horror of it.
We have attempted to come to terms with the experiments of the Nazis in concentration camps. We now
have the prospect of systematic control authorised by men who issue instructions through satellite
communications for the destruction of societies while they are driving new Jaguars and Mercedes, and
going to the opera.
This is essentially about humiliation, and disempowerment. It is a manifestation of rage acted out by
those who fear impotence with such dread, that their whole effort is directed into the emasculation and
destruction of the terrifying rival of their unconscious fantasies. In this apocalypse of the mind the punitive
figure wells up as if out of the bowels of the opera stage, and this phantasmagoria is acted out on a
global scale. These men may be mad enough to believe they are creating a 'psychocivilised world order".
For anyone who has studied damaged children, it is more resonant of the re-enactment from the
unconscious, reinforced by a life devoid of the capacity for empathic identification, of the obscenities of
the abused and abusing child in the savage nursery. Other people -which were to them like Action Man
toys to be dismembered, or Barbie Dolls to be obscenely defiled - become as meaningless in their
humanity as pixillated dots on a screen.
Although forced entry into a mind is by definition obscene, an abbreviated assessment of the effects that
mind-invaded people describe testifies to the perverted nature of the experiments. Bizarre noises are
emitted from the body, a body known well enough by its owner to recognise the noises as extrinsic; air is
pumped in and out of orifices as if by a bicycle pump. Gradually the repertoire is augmented - twinges and
spasms to the eyes, nose, lips, strange tics, pains in the head, ringing in the ears, obstructions in the
throat, pressure on the bowel and bladder causing incontinence; tingling in the fingers, feet, pressures on
the heart, on breathing, dizziness, eye problems leading to cataracts; running eyes, running nose;
speeding up of heart beats and the raising of pressure in the heart and chest; breathing and chest
complaints leading to bronchitis and deterioration of the lungs; agonizing migraines; being woken up at
night, sometimes with terrifying jolts; insomnia; intolerable levels of stress from the loss of one's privacy.
This collection of assorted symptoms is a challenge to any medical practitioner to diagnose.
There are, more seriously, if the afore-going is characterised as non-lethal, the potential lethal effects
since the capability of ultrasound and infra-sound to cause cardiac arrest, and brain lesions, paralysis and
blindness, as well as blinding by laser beam, or inducing asphyxia by altering the frequencies which
control breathing in the brain, epileptic seizure - all these and others may be at the fingertips of those
who are developing them. And those who do choose to use them may be sitting with the weapon, which
resembles, say, a compact mobile telephone, on the restaurant table next to the bottle of wine, or beside
them at the swimming pool.
Finally - if the victims at this point in the new history of this mind-control, cannot yet prove their abuse, it
must be asserted that, faced with the available information about technological development - it is
certainly not possible for those seeking to evade such claims to disprove them. To wait until the effects
become widespread will be too late.
For these and other reasons which this paper has attempted to address, we would call for an
acknowledgement of such technology at a national and international level. Politicians, scientists and
neurologists, neuroscientists, physicists and the legal profession should, without further delay,
demand public debate on the existence and deployment of psychotronic technology; and for the
declassification of information about such devices which abuse helpless people, and threaten
democratic freedom.
Victims' accounts of abuse should be admitted to public account, and the use of psycho-electronic
weapons should be made illegal and criminal,
The medical profeSSion should be helped to recognise the symptoms of mind-control and
psychotronic abuse, and intelligence about their deployment should be declassified so that this
abuse can be seen to be what it is, and not interpreted automatically as an indication of mental
illness.
If, in the present confusion and insecurity about the search for evidence of weapons of mass destruction,
we conclude that failure to locate them - whatever the truth of the matter -encourages us to be generally
Page 11 of13
Page 31 of 55
October 18, 2007
05.18.2009
Page 251 of 2301
complacent, then we shall be colluding with very dark forces at work if we conclude that a course of
extreme vigilance signifies paranoia. For there may well be other weapons of mass destruction being
developed and not so far from home; weapons which, being even more difficult to locate, are developed
invisibly, unobstructed, unheeded in our midst, using human beings as test-beds. Like ESP, the methods
being used on humans have not been detectable using conventional detection equipment. It is likely that
the signals being used are part of a physics not known to scientists without the highest level of security
clearance. To ignore the evidence of victims is to deny, perhaps with catastrophic results, the only
evidence which might otherwise lead the defenders of freedom to becoming alert to the development of a
fearful new methods of destruction. Manipulating terrorist groups and governments alike, these sinister
and covert forces may well be very thankful for the professional derision of the victims, and for public
ignorance.
References
Laing, R.D. (1985): Wisdom, Madness and Folly: The Making of a Psychiatrist. Macmillan, 1985
Welsh, Cheryl (1997): Timeline of Important Dates in the History of Electromagnetic Technology and Mind
Control, at: www.dcn.davis.ca.us/...welsh/timeline.htm
Welsh, Cheryl (2001):Electromagnetic Weapons: As powerful as the Atomic Bomb, President Citizens
Against Human Rights Abuse, CAHRA Home Page: U.S. Human Rights Abuse Report:
www.dcn.davis.ca.us/...welsh/emr13.htm
Begich, Dr N. and Manning, J.: 1995 Angels Don't Play this HAARP, Advances in Tesla Technology,
Earthpulse Press.
ZDF TV:
No. 35
"Secret Russia: Moscow - The Zombies of the Red Czars", Script to be published in Resonance,
Aftergood, Steven and Rosenberg, Barbara: "The Soft Kill Fallacy", in The Bulletin of the Atomic Scientists,
Sept/Oct 1994.
Becker, Dr Robert: 1985,The Body Electric: Electromagnetism and the Foundation of Life, William Morrow,
N.Y.
Babacek, Mojmir: International Movement for the Ban of Manipulation of The Human Nervous System:
http://mindcontrolforums.com/babacek.htm and go to: Ban of Manipulation of Human Nervous System
"Is
it
Feasible
to
Manipulate
www.aisjca-mft.org/braindist.htm
the
Human
"Psychoelectronic
Threat
http://mindcontrolforums.com/babacek.htm
Brain
at
to
Distance?"
Democracy"
Nature: "Advances in Neuroscience May Threaten Human Rights", Vol, 391, Jan. 22, 1998, p. 316; (ref
Jean- Pierre Changeux)
Space Preservation Act: Bill H.R.2977 and HR 3616 IH in 107th Congress
www.raven1.net/govptron.htm
Sessions
European
www.euroDarl.eu.intlhome/defaulten.htm?redirected=l
2nd Session: see:
Parliament:
Click at Plenary Sessions, scroll down to Reports by A4 number, click, choose 1999 and fill in 005 to A4
Delgado, Jose M.R: 1969. "Physical Control of the Mind: Towards a Psychocivilized Society", Vol. 41,
World Perspectives, Harper Row, N.Y.
Page 12 of 13
Page 32 of 55
October 18. 2007
05.18.2009

US News & World Report:
P.67
Page 252 of 2301
Lockheed Martin Aeronautics/ Dr John Norseen; Report January 3/10 2000,
1919:
Freud,
Sigmund:
Also "Those Wrecked by Success."
Marks, John:
20137-3
Art
and
Literature; "
The
Uncanny".
Penguin,
1988 : The CIA and Mind Control - the Search for the Manchurian Candidate, ISBN 0-440
Persinger, M.A. "On the Possibility of Directly Accessing Every Human Brain by Electromagnetic Induction
of Fundamental Algorythms"; In Perception and Motor Skills, June, 1995, vol. 80, p. 791 799
Tyler, J."Electromagnetic Spectrum in Low Intensity Conflict," in "Low Intensity Conflict and Modern
Technology",
ed. Lt. Col. J. Dean, USAF, Air University Press, Centre For Aerospace Doctrine, Research
and Education, Maxwell Air Force base, Alabama, June, 1986.
Rees, Martin Our Final Century: 2003, Heinemann.
Conrad, Joseph: The Secret Sharer, 1910. Signet Classic.
Maupassant, Guy de: Le Horla, 1886. Livre de Poche.
Carole Smith is a British psychoanalyst. In recent years she has been openly critical of government use of
intrusive technology on non-consenting citizens for the development of methods of state control. Carole
Smith
E-mail: rockpool@d;rcon.co.uk
Disclaimer: The views expressed in this article are the sole responsibility of the author and do not
necessarily reflect those of the Centre for Research on Globalization.
To become a Member of Global Research
The CRG grants permission to cross-post original Global Research articles on community internet sites as
long as the text & title are not modified. The source and the author's copyright must be displayed. For
publication of Global Research articles in print or other forms including commercial internet sites, contact:
crgeditor@yahoo.com
www.globalresearch.ca contains copyrighted material the use of which has not always been specifically
authorized by the copyright owner. We are making such material available to our readers under the
provisions of "fair use" in an effort to advance a better understanding of political, economic and social
issues. The material on this site is distributed without profit to those who have expressed a prior interest
in receiving it for research and educational purposes. If you wish to use copyrighted material for purposes
other
than
"fair
use"
you
must
request
permission
from
the
copyright
owner.
For media inquiries: crgeditor@yahoo.com
Copyright Carole Smith, Journal of Psycho-Social Studies, 2003., 2007

The uri address of this article is: www.globalresearch.ca/PrintArticle.php?articleId=7123
Copyright 2005-2007 GlobalResearch.ca

Web site engine by Polygraphx Multimedia Copyright 2005-2007
Page 13 of 13
Page 33 of 55
October 18. 2007
05.18.2009
Page 253 of 2301
Hotmail Email of December 1, 2007
Subject: Covert U.s. Government Parasychology Projects - Black Budget Programs"
From: Stan Caterbone (amgroupOl0msn.com)
Sent: Sat 12/01/0710:48.AM

To: john(!lsplziriassociates.com
Icc: SenatoOipecterOSpecter.Senate.gov (senatorJPe(terOspectet .senate.goy); sectDr9OpoIke.Q).lancaster.pa.us

(sectDr90poIk:e.Q).lancaster.pa.us); sec:tor8OpOIk:e.co.lancaster.pe.us (~Ice.CO.lancaster.peI.uS); Rodrtgues,
Tommye (rtghtonOlObellsouth.net); Resean::h (researchOgac).gov); Ralph (ralpttJnazzocchIOaol.com); Pftumm, faml
(pelmSUOaol.com); pbroganOcft;yoflancasterpa.com (pbroganOct.yoftancasterpa.com); OwIngs, Usa
Ilsa_owingsOJudldary...-ep.senate.gov); Hast, DIanne (nxfal1l!lStOrodanast.com)i Munton, Christine
(anunionOtravelers.com); Longer, janice (jIongeresqOaol.com): Kauft'man, Bob (robert.kauft'manOaxa-advlsors.com);
infoOjudidalwatdl.org (lnfoOjudidalwatch.org)i huggens, &til (stusongsOyahoo.com); Garofolo, John
(jOhn.garofoioOnl5t.gov); gannstrongOpasen.gov (gannstrongOpasen.gIOV); Bhtc5, Government
(contDetogeOoge.gov); FBI, f1eId omce (pbiladelphlaOfbl.gov); Ben (benOdaddyJustICe.com); ft1endsOfoxnews.com;
newsletterObllloreilly.com; samIornbIIrdoObenecon.com; webt'rIasterOIlve8live.chtah.com; dchkennettOdgw.net;
ckovalyOlaverylaw.com; tom.tlllettOmall.house.gov; jdmmfOaol.com; jbuckwelterOlnpnews.com;
mhalcOsupemet.com; pwengerOfuItonbitnk.com; scarfleyObBr1ey.comi nlkoIoITOeddancaster.com; tnfoOadupe.org;
InfoObioodhoundsinc.com; cvrOrkglaw.com: ssblrkOco.sante-blrbara.ca.us; bethgOtt;anywalker.com;
ureypOco./ancaster.peI.us; sheilywOkxxa.com; ndcaoIeyOhlgh.net; rpIotktnOmcgulrewcods.com;
matla..J)lakoudasOsp.senate.gov; Ibur1cholderOthewgnnel.com; beyyerddOaol.com;
wengerrOco.lancaster.peI.us; sunnewsOlnpnews.com; inteillettersOlnpnews.com; neweralettersOlnpnews.com
John,
Here IS the arttde I told you about last evening. Pay parttcular attention to the red highlights. These
are Items which I think have something to do with training me to be telepathic and remote viewing 'of.
my mind. You have to understand that In July of 2005 (July 27, 2005) while I was visiting a museum'
on a military base In Austin Texas, I was detained by 2 agents for the Defense Intelligence Agency and
questioned about my Federal case 02-5588 catemone v. Lancaster County Prison, et al., and my
whereabouts and my destlnatfon.
They required me to verify where I was staying, and called my brother Phil's Doctors offtce In Austin,
whom I was staying with, and caused his staff problems by getting them alanned about the situation.
They were not very nice and I left: them with the question "We are all on the same team, aren't we?
They left me be on my way after reviewing my documents and my Federal dvll complaint, which
Induded Infonnatlon about ISC and my allegations and Federal False Oalms M.
I have been trying to Identify these groups listed below for quite sometime and just happened to
locate this article yesterday, November 30, 2007. Now at least I know where to go to find some
answers. I suspect there have been quite amount of $dollars spent on my situation.
fnJ/t-v' dt#
-'~::wCvember 29. 2007

THE SHADOW GOVERNMENT: ITS IDENTIFICATION AND ANALYSIS
by
Richard J. Boylan, Ph.D.
This Is a summary report on those elements of that dandestine organizational network, (which we
shall label the s....w Goermnent), which serves as a kind Of "parallel government" to the offidal
Dacamber 1. 2007
Stanley], Caterbone Case No. 0514869

Page 34 of 55
Page 34 of 55
05.15.2009
05.18.2009

Page 254 of 2301
elected and appointed government of this country (USA). It includes t .....,se elements known to the
author with sufficient certainty that they can be positively identified, and their known or
reliably reported functions described. It is distinctly possible that there are other elements,
(particularly in the realms of the "Black Budget" and "Special Operations",) which have eluded our
study, and are not named here.
Just as with the official government, the Shadow Government has functional branches. However,
unlike the official government, the purpose of the none-executive branches of the Shadow Government
is simply to distribute various functions, but not to achieve a system of checks and balances, as was
supposed to happen constitutionally between the executive, legislative and judicial branches of the
U.S. Government. That is because the Shadow Government is a creature of a powerful elite, who need
not fear being dominated by an instrument of their own creation.
In the Shadow Government five branches may be identified. These branches are: the Executive
Branch, the Intelligence Branch, the War Department, the Weapons Industry Branch, and the FinanCial
Department.
The reporting lines of the Intelligence Branch and the War Department to the Executive Branch are
straightforward and obvious. Intelligence exists to provide the Executive Branch with suffiCient
necessary information to make adequately informed policy decisions. The War Department exists to
provide coercive force to carry out Executive policy decisions which could meet with public resistance.
The Special Operations units within the Intelligence Branch and War Department exist to carry out
policy directives requiring covert action and official denlablllty.
The Weapons Industry Branch reports to the Executive Branch most often indirectly, through the War
Department and/or the Intelligence Branch (for Black Budget weapons systems).
The Financial Department theoretically reports to the Executive Branch for fiscal policy
implementation, but de facto also reports directly to the international power brokers who have created
the Shadow Government. The Financial Department serves at times directly as their instrument of
fiscal pOlicy Implementation.
An analysis of the overall purposes of these five branches suggests that the overall purpose of the
Shadow Government is to exercise covert control by: 1) collecting comprehensive institutional and
personal Information, 2) by establishing national and International policy independently of the
established Government, 3) by developing high-tech arms and equipment, and, with these,
establishing small, specialized, highly-mobile, elite military units to effect these covert policies, when
need arises, without having to rely on the official (and "unreliable") Armed Services, (whose
subservience to the Shadow Government is reasonably suspect), 4) by developing an armed capability
to repel any threat to the status quo, (including the uncertain ontOlogical, social, and economic
Impacts of any revelation of the reality of UFO and extraterrestrial presence) through the development
of a Star Wars/BMOO ground and space-based surveillance and SOl weapons network,S) by denying
information compromising to the Shadow Government from all those outside "need-to-know"
policymaking levels, and 6) by exercising control on the money supply, availability of credit, and the
worth of money, through policy decisions made outside of the official Government.
All of these mechanisms of control serve to preserve or advance the agenda of an International group
of pivotal power and influence brokers. That agenda is, according to Senator Barry Goldwater, that
"national boundaries should be obliterated and one world rule established." [With No Apologies,
Berkley Books, New York [[date unknown]].]
These power brokers' most visible unifying instrumentality is the Council on Foreign
Relations (CFR), (which promotes the transition of Earth from a cluster of Nation-States to one
global government), [Chairman: Peter G. Peterson; headquarters: 58 E. 68th Street, New York, NY
10021]. [Ct. In Control, Kerrville, TX: Fund to Restore an Educated Electorate, 1993.] However, one
must not underestimate the influence of the Trilateral Commission (TC), (which coordinates economic
initiatives of the Group of Seven with other "developed countries" vis-a-vis the "underdeveloped
world",) [Chairman: Paul Volcker; headquarters: 345 E. 46th Street, New York, NY 10017]. Neither
should one misjudge the power of the secretive Bllderberg Group (BG), (which concentrates on the
Page 2 of9
Page 35 of 55
December 1, 2007
05.18.2009

Page 255 of 2301
military and strategic considerations of powerful West European and Nu, ch American power brokers),
[chair rotates, former Chair: Prince Bernhard of Holland; headquarters unknown: annual meetings
rotate, but originally were held at the Hotel de Bilderberg, Oosterbeck, Holland].
David Rockefeller is the Chairman Emeritus of both the CFR and the TC, and certainly
influences, through proxy representatives (such as Lloyd Bentsen), the Bilderberg Group. [Cf. Holly
Sklar, ed., Trllaterallsm: The Trilateral Commission and Elite Planning for World Management; Boston:
South End Press, 1981.]
What follows is a succinct identification and description of the constituent agencies in each of the five
branches of the Shadow Government.
EXECUTIVE BRANCH
(This branch contains the effective policymaking and controlling structures behind the veil of apparent,
democratic governmental structures):
a) Council on Foreign Relations (CFR) (includes George Bush, Bill Clinton, all modern CIA Directors,
most modem Joint Chiefs of Staff, most modem cabinet and top Executive Branch appointed
officeholders, etc.);
b) Tri-Lateral Commission (David Rockefeller, Henry Kissinger, John D. Rockefeller, Alan Greenspan,
Zbignew Brzezinski, Anthony Lake, John Glenn, David Packard, David Gergen, Diane Feinstein, Jimmy
Carter, Adm. William Crowe, etc.;
c) The Bilderberg Group (Prince Hans-Adam of Liechtenstein, Prince Bernhard of Netherlands, Bill
Clinton, Lloyd Bentsen, etc.);
d) National Security Council (NCS), (the military and intelligence policymaking and control group for
national and international security, which reports directly to the President), its secret 5412 Committee
(which directs black [covert] operations), and its PI-40 Subcommittee (aka MJ-12: which exercises
policy direction and control of the UFO Cover-Up);
e) Joint Chiefs of Staff (JCS)'s Spedal Operations compartment, (the operations directorate which
implements the orders of the NSC's 5412 Committee, utilizing the U.S. Special Forces Command);
f) National Program Office (NPO), (which operates the Continuity of Government Project (COG), an
ongoing secret project to maintain command, control, communication and intelligence executive
centers during an extreme National Emergency by operating dandestine, secure, underground cities
staffed by surrogates for above-ground national leaders]); and,
h) Federal Emergency Management Agency (FEMA)'s black projects compartment, (which operates
federal preventive-detention camps [often located on military bases or federal Bureau of Land
Management lands], secure underground shelters for the elite during cataclysms, etc.).
INTELLIGENCE BRANCH
(Serves functions of domestic and international surveillance and of secret police/enforcers):

a) National Security Agency (NSA), (monitors and screens all telephone, telegraph, computer modem,
radiO, televiSion, cellular, microwave, and satellite communications, and electromagnetic fields "of
interest" around the world, and orchestrates information-control and cover-up activities related to UFO
secrecy and surveillance of extraterrestrial operations), Fort Meade, MD;
b) National Reconnaissance Office (NRO), (controls and collects information from global spy satellites,
monitors UFO traffic entering and leaving Earth's atmosphere, coordinates firing of energy-beam
weapons from orbiting Star Wars satellites at selected human ground and airborne targets and
selectively at extraterrestrial craft), Pentagon basement and Dulles-Airport area, VA;
c) National Reconnaissance Organization (NRO) (aka MJ-TF), (the military/intelligence operations arm
Page 30f9
Page 36 of 55
December 1. 2007
05.18.2009

Page 256 of 2301
of the PI-40 Subcommittee, conducts surveillance, interdiction, capturE: dnd confiscation of UFOs and
their extraterrestrial occupants for intelligence and "International Security" purposes; surveilles and
"interacts" with close-encounter experiencers, including occasional physically and sexually assaultive
mind-control kidnappings disguised as "Alien abductions" for psychological warfare and
disinformational purposes), headquarters unknown, probably compartmented and dispersed among
various elite Delta Force Special Operations units, such as the USAF Blue light at Hurlburt Field, Mary
Esther, FL and Beale Air Force Base, Marysville, CA;
d) Central Intelligence Agency (CIA), (commands, often controls, and sometimes
coordinates, the gathering of secret overseas information gathered by spies (HUMINT),
electronic surveillance (SIGINT), and other means; carries out covert unconstitutional
paramilitary counterinsurgency operations and preemptive political pacification projects in
violation of international law, as well as counter-intelligence sting operations against
foreign agents; engages in domestic surveillance, and manipulation of the U.S. political
process, "in the National interest" in direct violation of its congressional charter; operates
proprietary "false-front" companies for profit; conducts a major share of international
transshipment of illegal drugs, using National Security cover and immunity; and cooperates
with NSA's UFO cover-up operations), Langley, VA, and worldwide branches;
e) Federal Bureau of Investigation, Counter-Intelligence Division, (the branch which investigates,

survellles and neutralizes foreign Intelligence agents operating within the U.S., and cooperates with
the National Reconnaissance Organization in the surveillance of those involved in close encounters with
UFOs and extraterrestrials);
f) Department of Energy Intelligence (DOE-INTEL), (which conducts internal security checks and
external security threat countermeasures, often through its contract civilian instrumentality, the
Wackenhut Corporation);
g) NSA's Central Security Service, and CIA's Special Security Office, (which respectively spy on the
spies, and conduct special operations which cannot be entrusted to line intelligence officers), Ft.
Meade, MD and Langley, VA;
h) U.S. Army Intelligence and Security Command (INSCOM) (whose assignments include
psychological and psychotronic warfare (PSYOPS), parapsychological intelligence (PSYINT),
and electromagnetic intelligence (ELMINT), Ft. Meade, MDi
i) U.S. Navy Office of Naval Intelligence (ONI), which gathers intelligence affecting naval operations,
and has a compartmented unit involved in UFO and USO [Unidentified Submerged Objects] information
gathering;
j) U.S. Air Force Office of Special Investigations (AFOSI), (which gathers intelligence affecting
aerospace operations, and has a compartmented unit involved in investigating UFO slghtings,
extraterrestrial contact reports, as well as lAC [Identified Alien Craft] surveillance, and coordination
with NRO interdiction operations), Bolling Air Force Base, MD;
k) Defense Intelligence Agency (DIA), (which coordinates the intelligence data gathered
from the various Armed Services intelligence branches (Army, Navy, Marines, Air Force,
Coast Guard and Special Forces), and provides counter-threat measures, which include
providing security at ultra-classified installations by the deployment of U.S. "Thought
Police", who conduct surveillance, by remote-viewing and other parapsychological
measures, against penetrations and scanning by foreign or civilian remote-viewers
[clairvoyants/out-of-body seers]), Pentagon, VA, Fort Meade, MD, and the entire astral
plane;
I) NASA Intelligence, (which gathers intelligence data relating to space flights, sabotage threats,
astronaut and reconnaissance satellite encounters with UFOs and Star ViSitors, and coordinates the
transfer of Star Visitor technology to U.S. and allies' aerospace operations);
m) Air Force Special Security Service (which is an NSA/USAF jOint intelligence operations unit dealing
Page4of9
Page 37 of 55
Oec:ember 1, 2007
05.18.2009

Page 257 of 2301
with possible threats to aerospace operations from foreign powel';), terrestrial or otherwise);
n) Defense Industry Security Command (DISCO), (which conducts Intelligence operations within and
on behalf of the civilian defense contractor corporations engaged In classified research, development,
and production);
0) Defense Investigative Service (DIS), (which conducts investigations into people and
situations deemed a possible threat to any operation of the Department of Defense);
p) Naval Investigative Service (NIS), (which conducts investigations against threats to Naval
operations);
q) Air Force Electronic Security Command, (which conducts surveillance and interdiction of threats to
the security of Air Force electronic transmissions and telemetry, and to the integrity of electronic
counter-measure (ECM) warfare equipment; r) Drug Enforcement Agency (DEA) Intelligence, (which
conducts surveillance and interdiction of drug smuggling operations, unless exempted under "National
Security" waivers);
s) Federal Police Agency Intelligence, (which coordinates Intelligence relating to threats against federal
property and personnel);
t) Defense Electronic Security Command, (which coordinates intelligence surveillance and
countermeasures against threats to the integrity of military electronic eqUipment and electronic
battlefield operations), Fort Worth, TX.
u) Project Deep Water (the ongoing effects of the compromised personnel, sources and methods
resulting from the secret importation of Hitler's own Nazi Intelligence chief, Gen. Reinhard Gehlen, to
redesign the U.S.'s Intelligence apparatus);
v) Project Paperclip (the ongoing results of the secret importation of Nazi weapons and aerospace/UFO
scientists into U.S. secret military research and development bases);
w) (Undoubtedly, more clandestine units exist, not Identified at this time.)
WAR DEPARTMENT
(High-Technology Weapons Development and Covert Special

Deployment) :
Forces/Special Operations Units
a) CIA's Directorate for Science and Technology, (which gathers information with promise
for scientific and technological developments which present a superiority advantage for, or
a threat against, the National Security, [also contains the "Weird Desk", which centrally
processes intelligence about UFOs and Star Visitors and their interaction with Earth],
current Deputy Director of Central Intelligence for Science and Technology is Ron Pandolfi);
b) StrategiC Defense Initiative OffIce (SDIO)/ Ballistic Missile [sic] Defense Organization (BMDO),
(which coordinates research, development and deployment of Star Wars electromagnetic-pulse, killer
laser, particle-beam, plasmoid, and other advanced-technology aerospace weapons;
c) Department of Energy (DOE) (which, besides its cover-story of researching cleaner-burning coal and
gasoline and more solar power, is principally Involved in research and development of: more
specialized nuclear weapons; plus compact, self-sustaining, fUSion-powered, particle and wave
weapons, including electromagnetiC pulse, gravltational/antlgravltational, laser, neutral particle-beam
and plasm old applied weapons research; high-energy invisibility "cloaking" technology, etc.);
d) Lawrence Uvermore National laboratOries (LLNL)/Sandia National laboratories-West (SNL-W),
(which are involved in nuclear warhead "refinements", development of new trans-uranic elements for
weapons and energy applications, development of anti-matter weapons (the Teller Bomb: 10,000
times the force of a hydrogen bomb), laser/maser technology applications, and, reportedly, successful
Page 5 of9
Page 38 of 55
December 1, 2007
05.18.2009

teleportatlon experiments,
Death"),Uvermore, CA;
among
Page 258 of 2301

other projects, at

this kussian-nicknamed "City of
e) Idaho National Engineering Laboratories (INEL), (which houses numerous underground facilities in
an immense desert installations complex larger than Rhode Island, has security provided by its own
secret Navy Base, is involved in nuclear, high-energy electromagnetic, and other research, and
includes Argonne National Laboratory, West), Arco, 10;
f) Sandia National Laboratories (SNL)/Phillips Air Force Laboratory, (which are sequestered on Kirtland
Air Force Base/Sandia Military Reservation, and conduct the translation of theoretical and experimental
nuclear and Star Wars weapons research done at Los Alamos and Lawrence Uvermore National
laboratories Into practical, working weapons), Albuquerque, NM;
g) Tonopah Test Range (SNL's DOE weapons-testing facility for operationally testing Star Wars
weapons in realistic target situations, and is adjacent to classified stealth and cloaked aerospace craft
and U.S.-UFO bases at the Groom Lake [USAF/DOE/CIA] Base [Area 51] and Papoose Lake Base [5
4]), Nevada Test Site/Nellis AFB Range, Tonopah, NV;
h) Haystack USAF Laboratory, Haystack Buttes, Edwards AFB, CA, (a 30-levels deep, extreme-security
facility reportedly engaged In Star Visitor technology retro-engineering;
i) Los Alamos National Laboratories (LANL), (which is the premiere research lab for nuclear, subatomic
particle, high magnetic field, exo-metallurglcal, exo-biologlcal and other back-engineered
extraterrestrial technologies research), Los Alamos County, NM;
j) Area 51 (Groom Lake [USAF/DOE/CIA] Base), and S[Site]-4 (Papoose Lake Base), ultra-secure
"nonexistent" deployment bases where extremely classified aerospace vehicles are tested and
operationally flown, Including the Aurora [Mach-S] spyplane, the Black Manta [TR-3A] stealthy fighter
follow-on to the F-U7A, the Pumpkinseed hyperspeed unmanned aerospace reconnaissance vehicle,
and several variants of antigravltatlonal craft (U.S.-UFOs), including the "Christmas Tree Ornament"
(glowing orange orb) and the "Firefly" (strobing, flitting, blUish-white lit airframe);
k) U.S. Special Forces Command, Hurlburt Field, Mary Esther, FI, along with its Western U.S.
Headquarters, Special Forces Command, Beale AFB, Marysville, CA, coordinating: 1) U.S. Army Delta
Forces (Green Berets); 2) U.S. Navy SEALS (Black Berets), Coronado, CA; and 3) USAF Blue Ught
(Red Berets) Strike Force;
I) Defense Advanced Research Projects Agency (DARPA), (which coordinates the application
of latest scientific findings to the development of new generations of weapons); (now called
ARPA);
m) the Jason Group (elite weapons-application scientists, developing cuttlng-edge-sclence weapons for
DARPA/ARPA, and operating under the cover of the Mitre Corporation);
0) Aquarius Group (UFO technology-application scientiSts, reportedly working under the guidance of
the Dolphin SOCiety, an elite group of scientists privy to extremely classified science and technology
findings);
p) Defense Science Board, (which serves as the Defense Department's intermediary between weapons
needs and the physical sciences);
q) Defense Nuclear Agency (DNA) (currently concentrating on fUSion-powered, high-energy particle
beam, X-ray laser, and EM forcefield weapons development and deployment);
r) U.S. Space Command, (Space War Headquarters for operating "the next war, which will be fought
and won in space"), jOintly coordinated through Peterson AFB, Schreiver AFB, Cheyenne Mountain AFS,
Colorado Springs, and Buckley AFB, Aurora, CO;
Page6of9
Page 39 of 55
December 1.2007
05.18.2009
Page 259 of 2301
s.l) North American Aerospace Defense Command (NORAD), (operating the nuclear-survivable space
surveillance and war command center deep inside Cheyenne Mountain), Colorado Springs, CO;
s.2) Naval Space Command, the secret lead agency in dealing with the mounting of and operating of
space-based warfare "assets" to deal with any perceived threat from space;
t) Air Force Office of Space Systems, (which coordinates the development of future technology for
operating and fighting in space);
u) National Aeronautics and Space Administration (NASA) (which operates covert space-defense,
research aabout extraterrestrial lifeforms, and space-weapons compartments, in addition to manned
Shuttle and unmanned scientific satellite launches);
v) NASA's Ames Research center, (which conducts the SEn (Search for Extraterrestrial Intelligence)
Project, Exobiology (Star Visitor life forms) Division, and "Human Factors" (PSY-Warfare) Division),
Sunnyvale, CA;
w) Project Cold Empire (SOl weapons research-classified);
x) Project Snowbird (creating pseudo-UFOs, used as disinformation);
y) Project Aquarius (UFO research-classified);
x) Project MIlSTAR (development and deployment of WW III [space war] command, control,
communication and intelligence satellites);
z) Project Tacit Rainbow (stealth drones/pseudo-UFO's);
aa) Project Timberwind (nuclear-powered spacecraft);
bb) Project Code EVA (space-walk-based technology);
ee) Project Cobra Mist (SOl energy-beam (plasmold?) weapon research); and
dd) Project Cold Witness (SOl weapons-classified), etc.
WEAPONS INDUSTRY BRANCH

("private" [black project] weapons and covert operations contractors):
a) AT&T (Sandia Labs, Bell Labs, etc. - Star Wars weapons research and NSA telephone/satellite
communications interception facilitation); (Sandia Weapons Lab has now reportedly being taken over
by Batelle Memorial Institute, a proprietary with reported Intelligence connections);
b) Stanford Research Institute, Inc. (SRI), (an Intelligence contractor involved in

psychotronic, parapsychological and PSY-WAR research);
c) RAND Corporation (CIA-front involved in Intelligence projects, weapons development, and
underground bases development);
d) Edgerton, Germhausen & Greer Corporation (EG&G), (NSNOOE-contractor Involved in Star Wars
weapons development, fUSion applications, and security for Area 51 (U.S. UFO-technology aerospace
vehicles base) and nuclear installations, etc.);
e) Wackenhut Corporation (NSNCINDOE cut-out contractor) involved in contract security operations
for Top Secret Ultra and Black Budget surface and underground military reservations, such as Area S-4
(U.S. UFO base), NV and Sandia National Labs, (Star Wars weapons testing facility), NM), and,
reportedly, "dirty jobs" for CIA and Defense Intelligence agencies;
Page 7 019
Page 40 of 55
December 1, 2007
05.18.2009
Page 260 of 2301
f) Bechtel Corporation (CIA's "ditch-digger" for covert projects and off-the-books underground bases);
g) United Nuclear Corporation (military nuclear applications);
h) Walsh Construction Company (on the CIA projects dole);
i) Aerojet (Genstar Corp.):{ makes DSP-l Star Wars battle satellites for the NRO);
j) Reynolds Electronics Engineering (on CWDoD dole);
k) Lear Aircraft Company (Black Budget technology);
I) Northrop Corporation (makes U.S. antigravity craft, back-engineered from Star Visitor technology,
ear lancaster, CA);
m) Hughes Aircraft (classified projects compartment);
n) Lockheed-Martin Corporation (Black Budget aerospace projects);
o} McDonnell-Douglas Corporation {Black Budget aerospace projects};
p) BDM Corporation (CIA contractor, involved in UFO back-engineering and psychotronic projects,
etc.);
q) General Electric Corporation (electronic warfare and weapons systems); and
r) PSI-TECH Corporation (involved in military/Intelligence-applications of research into
psychotronics,
parapsychology,
remote
viewing,
and
contacting
extraterrestrial
consciousness);
s) Science Applications International Corp. (SAle); "black projects" contractor, reportedly including
psychic warfare.
FINANCIAL DEPARTMENT
(Extra-Constitutional funding):
a) Federal Reserve System (cartel of private banks overseen by elite superwealthy finanCiers, such as
the Rockefellers, Mellons, DuPonts, Rothschilds, etc., which dictates to the Government the flow of
money, worth of money, and the interest rates the government and citizens must pay);
b) CIA self-financing {the operation and/or control of much of the international drug trade in heroin,
cocaine and marijuana, as well as "front" bUSiness enterprises, as a source of cash for off-the-books
covert operations, and the purchase of exotic munitions and strategic bribe funds};
c) Department of Justice self-financing (the use of confiscated cash and valuables from "targets of
investigation" to finance "special projects");
d) Special Forces self-finanCing (the self-use of confiscated "booty" from covert military operations to
fund other clandestine operations).
What conclusions can be drawn from this preliminary analysis of the structure, functions and
operations of the Shadow Government?
Foremost, the Shadow Government is a very large, well-organized, skillfully camouflaged, parallel
power structure. History suggests that it has served its masters well, and that its predilection for
operating out of sight and notoriety, if not in an outright clandestine fashion, is exactly how its
masters want it to function -- not drawing attention to itself, manipulating power behind the scenes,
Page 8 of9
Page 41 of 55
December 1, 2007
05.18.2009

Page 261 of 2301
and accomplishing by covert operations what cannot lawfully or politicallY be accomplished out in the
open.
What should be the attitude of the informed citizen to the Shadow Government?
Since it thrives in the dark, we should shine the light of full disclosure on it. Citizens can
demand: the end of the Congressional practice of allowing "Black Budget" items; the end of
unpublished secret Executive Orders and National Security Directives; the end of the
practice of indefinitely- sustained Presidential Declarations of National Emergency (as is
currently in place); the end of Federal Reserve Notes and the return to the gold standard to
back the dollar; the end to governmental domestic spying on its own citizens; and extremely
severe reduction (on the order of 90 oJb) in the number, staffing and scope of the endlessly
proliferating Intelligence agencies, which are an anachronism since the Cold War ended;
and an end to CIA and DEA collusion in allowing a continuing stream of drugs to pour into
this country.
We founded this Country (USA); it's time to take it back.
- Richard l. Boylan, Ph.D.
Dr. Richard Boylan is a behavioral scientist, university instructor, certified clinical hypnotherapist, and
researcher into extraterrestrial-human encounters.
Richard Boylan, Ph.D., LLC,
Post Office Box 1009, Diamond Springs California 95619, United States of America.
Phone: (530) 621-2674 (PDT)
E-mail: drboylan@sbcglobal.net
WEBSITE: htW:/lwww.drboylan.com
You are invited to join his UFOFacts internet reports-and-ET/UFO/Experiencers
chat list; moderated by Dr. Boylan: (subscribe at: http://Qroup;;.yahoo.com!aroup/ufofacts); or
join DrRichBoylanReports (his reports-only!) list at:
bltQ.;LI_9LQ\J~'l@h 00, comLg[ouQL9 rrich boyla n r~Qf:t;;
Posted by Stewart at
:/;'
;
.
,
'
a(i!i
,-
<'
Y'
nced
edia Group
terbone
Visit Our Blog For Journey of a Whistleblower
Visit Our Blog For Research Into ESP - Mental Telepathy & The U.s. Governments Activities
Visit Our Video Biography
Notice and Disclaimer: Stan J. Caterbone and the Advanced Media Group have been slandered, defamed, and publidy discredited Since
1987 due to going public (Whistle Blower) with allegations of misconduct and fraud within International Signal fit Control, Pic. 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 malidous 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
Ust. Number 7.
Page9of9
Page 42 of 55
Oecember 1. 2007
05.18.2009
Page 262 of 2301
amgrouD01@msn.com
Stan Caterbone, Pro Se Litigant

1250 Fremont Street
Lancaster, PA 17603
July 16, 2007

Federal Bureau of Investigations
J. Edger Hoover Building
935 Pennsylvania Avenue
Washington, D.C. 20535-0001
Philadelphia, PA
Re:
Important Matters
Dear Sir or Madam:

First of all, I received a personal letter from Senator Arlen Specter on July 11, 2007. It
was held in the mail system or was stolen for almost a full 30 days. I have had so many
complaints regarding the same that I filed a complaint with the United States Postal Inspector
(See Attached). They had written me but I never did receive the follow-up to the investigation
as the letter promise. I am attaching a copy of the letter with the hopes that you could follow
up and make certain that my complaint is not being subverted.
If you are not aware, I have a Federal Whistle-Blowing and Federal False Claims Act case
that I need to file against the United States Attorney General, as required by law. This case
involves the former Department of Defense contractor International Signal & Control, Pic, (ISC)
formerly of Lancaster, Pennsylvania. Unfortunately, I also have an unprecedented case of
obstruction of justice that surrounds that case, and I am evaluating the merits of waiting until
your subcommittee finds a resolution to U.S. Attorney General controversy before I file my
action in the United States District Court for the Eastern District of Pennsylvania. I am certain
that any filing before would only be subject to further misconduct. My cases now before the
United States District Courts and the various Courts of the Commonwealth have been subject to
an unprecedented array of judicial misconduct.
However, I realize that you do not have the
authority or the jurisdiction to intervene, so I am told.
I.
For approximately
'have"had th!e ,ability. to <communlcate
telepathically. .1IjaYE!spe
this' abllltythrQ~QhevarloustnfeIUgen~~
agendes dec/ass.
.... rnellts.
,
;g>.rinected2a pers,on (Sheryl
Crowl that Is co
when I am
litigating ciV11.andCfim
mproroised.
I. do notknow'flOwl
wledge ,and or
consent. lneed,:tos
elp in
that isconneGtedtome
subjects me to a brutal.arraYQfmen2
,'V~.betltt'letl1attheyare
being usedasa medlum;1f{)f" this purpose.
yJS$uesin a
urse.10svery
Court of Law, and thlsISr'l0ta},gQodtlme2for ....'sabl
suspect considering my FeOeraLFalseClaimsAetatieg
Unfortunatelw I have.had perSoRal\ld~aOI'l9s.II'A'jthtQe ,epartrnentt1fAdvaneed;Research
Projects (DARPAlthat dates backto;1.990~h~n~,had .......,.. .2 .......... with. the National Institute of
Standards and Technology and DAR.PA.. lkliow. thattheystl..ld,y and research paranormal
THE ADVANCED MEDIA GROUP
Page 1 of 36
Page 43 of 55
07/16/2007
05.18.2009
activities and
knowledge
Intelli",'~r~rl"""A(
ISC, a
agents
issues .......,... ".......,
type of com nUlllcc:ttlC)n..
foreignaff~i
possibility for
Page 263 of 2301
dropon~hjs
ue!;tloln()l'1fnat:ter"$retated to
and other
tnef'ft is always the
sornet)ne~td
In the past few weeks I have downloaded a declassified document dump from the Central
Intelligence Agency (CIA) that contained hundreds of bibliographies from the Soviet Union
dating as far back as the 1930's regarding this subject. It appears that they have more
knowledge and expertise than the United States. This brings me to a disclosure that mayor
may not be concerning. Over the past several months I have had two contacts and intimate
conversation with an 80-year-old Russian immigrant regarding my problem. She seemed to be
knowledgeable of the subject matter and made several disclosures, which mayor not be true.
She said that she was a Psychologist with a Doctorate degree and a former employee of the
Pennsylvania State University System.
She also disclosed that her former husband was
imprisoned and tortured by the KGB.
I look forward to your response.
, y, . ( )
tanJ.
ca~ne
cc:
Enclosures
()it'V
USPS Certified Mail

Letter of June 15, 2007
May 24, 2007 - Letter from United States Postal Inspection Service
February 26, 2007 - Email to DARPA
April 12, 2007 - Email Confirmation from CIA
2002 - CIA Declassified Document
July 10, 2007 - Email from The GAO
Page 2 of 36
Page 44 of 55
07/1612007
05.18.2009
Page 264 of 2301
amaI"QUoOl@msn.a>m
www.amgglobalentertainmentgroup.a>m

1250 Fremont Street
Lancaster, PA 17603
July 16, 2007

Federal Bureau of Investigations
J. Edger Hoover Building
935 Pennsylvania Avenue
Washington, D.C. 20535-0001
PlililL I
I.' '\
Re:
Important Matters
Dear Sir or Madam:

First of all, I received a personal letter from Senator Arlen Specter on July II, 2007. It
was held in the mail system or was stolen for almost a full 30 days. I have had so many
complaints regarding the same that I filed a complaint with the United States Postal Inspector
(See Attached). They had wlitten me but I never did receive the follow-up to the Investigation
as the letter promise. I am attaching a copy of the letter with the hopes that you could follow
up and make certain that my complaint is not being subverted.
If you are not aware, I have a Federal Whistle-Blowing and Federal False Claims Act case
that I need to file against the United States Attorney General, as required by law. This case
involves the former Department of Defense contractor International Signal &. Control, PIc, (ISC)
formerly of Lancaster, Pennsylvania. Unfortunately, I also have an unprecedented case of
obstruction of justice that surrounds that case, and I am evaluating the merits of waiting until
your subcommittee finds a resolution to U.S. Attorney General controversy before I file my
action in the United States Distlict Court for the Eastern District of Pennsylvania. I am certain
that any filing before would only be subject to further misconduct. My cases now before the
United States Distlict Courts and the various Courts of the Commonwealth have been subject to
an unprecedented array of judicial misconduct. However, I realize that you do not have the
authority or the jurisdiction to intervene, so I am told.
For
telepath1ca
agencies c:lel:ta~;Slfl
Crow) that -Is:
litigating
"
I,donot
UnfortunateiYiI"" h-ave,ha~~ ~t"'_flflg$";~Wlttl;'~Ji J"ep(),rttn~nt.Adval1Ce(:rReseinl:h

Projects (DARPA1Jhclt 'cfateS,back~i;~~~~ ~,.j)ifCI .-::.ctl$\Nlth the: National Institute of
Standards and:' Technology" and DARPA: lktltiw:,tli:at ~~<~',_80d'(esear-di,paranor:mal
THE ADVANCED MEOlA GROUP

Pagel 0'36
Page 45 of 55
Page 45 of 55
0711612007
05.15.2009
05.18.2009
Page 265 of 2301
July 12, 2007

Senator Arlen Specter
Page 2
trained without my knowledge and or consent. I need to seek help in trying to disconnect. The
person that is connected to me subjects me to a brutal array of mental and psychological abuse.
I firmly believe that they are being used as a medium for this purpose. I have waited 20 years
to resolve my issues in a Court of Law, and this is not a good time for this ability to assert itself,
and of course it is very suspect considering my Federal False Claims Act allegations.
Unfortunately, I have had personal "dealings" with the Department of Advanced Research
Projects (DARPA) that dates back to 1990 when I had contracts with the National Institute of
Standards and Technology and DARPA. I know that they study and research paranormal
activities and technologies, including remote channeling. My Whistle-Blowing activities and my
knowledge of the fraud within ISC back in 1987, has put me in direct scrutiny of the Central
Intelligence Agency (CIA) and the National Security Agency (NSA) due to their relationships with
ISC, and of course my very public condemnation of the fraud.
In the past few weeks I have downloaded a declassified document dump from the Central
Intelligence Agency (CIA) that contained hundreds of bibliographies from the Soviet Union
dating as far back as the 1930's regarding this subject. It appears that they have more
knowledge and expertise than the United States. This brings me to a disclosure that mayor
may not be concerning. Over the past several months I have had two contacts and intimate
conversation with an 80-year-old Russian immigrant regarding my problem. She seemed to be
knowledgeable of the subject matter and made several disclosures, which mayor not be true.
She said that she was a Psychologist with a Doctorate degree and a former employee of the
Pennsylvania State University System.
She also disclosed that her former husband was
imprisoned and tortured by the KGB.
I will copy Senator Diane Feinstein of California with this letter. The fact that she serves
on the Judiciary Committee with you and the fact that she is also on the Senate Select
Intelligence Committee might help me find a solution to this problem. I would hope that you
both might be able to help me find someone that can help me disconnect from this other
telepathic person, while at the same time taking any making certain there are no National
Security issues.
In another matter, I also will enclose a copy of an email from the Government Accounting
Office (GAO) pertaining a document that I am trying to locate that was sent to me in 1987 from
the GAO. I would appreCiate it if you could follow-up on this and make sure I am afforded the
FOIA for this document.
I look forward to your response.
cc:
.1/
Enclosures
USPS Certified Mail

Letter of June 15, 2007
May 24, 2007 - Letter from United States Postal Inspection Service
February 26, 2007 - Email to DARPA
April 12, 2007 - Email Confirmation from CIA
2002 - CIA Declassified Document
July 10, 2007 Email from The GAO
Page 4 of 36
Page 46 of 55
0711612007
05.18.2009
Page 266 of 2301
amgroup01@msn.com

1250 Fremont Street
Lancaster, PA 17603
July 13, 2007
Lorita O'Leary
Abuse Case Documenter
Citizens Commission for Human Rights International
6616 Sunset Blvd.,
Hollywood, CA 90028
Re:
email of July 10 2007
Dear Lorita:
I appreciate your response and the abuse case forms. I thought I would start
sending you documentation via United States Postal Service due to concerns of repeated
computer hacking and the lack of security on my email accounts. To get you started I thought I
should first deliver the original complaint that I sent you CCHR in 1992. If you will notice I
talked to an agent of CCHR at your headquarters on December 16, 1991 and followed up with
the enclosed abuse complaint form.
As you will notice, I am in litigation in United States District Court for the Eastern District
of Pennsylvania for a Federal False Claims Act or Whistle-Blowers complaint. The attached
complaint form will at least proved documentation for the first 4 years, as far as your
organization is concerned.
I will then continue to fill out the new form that will handle abuse from 1992 to today.
As you will learn, I have expertise in information technologies and I posses a large library of
documentation recorded on various mediums. I must to date have in excess of 20,000 pages
of documentation concerning these issues, so please do not hesitate to request explanations or
documentation in different formats.
I am also enclosing my resume, and suggest that you visit my website at:
www.amgglobalentertainmentgroup.com for additional information that may be helpful. As you
have already noticed, I will continue to copy my contacts in my email list of different
correspondence. This is a very strategic action that helps me to disseminate the truth in an
effort to defend myself against the broad array of libel and slander that continues. I use this
tactic to try to keep law enforcement honest against future false arrests. I now have 27 criminal
charges that I have had withdrawn or overturned on appeals. Of course my perpetrators have
no alternative than to try to discredit me. I'm sure with your experience with Whistle-Blower
cases, you can recognize this quite easily.
I will' also enclose a few headlines from the Lancaster Newspapers concerning
International Signal & Control (ISC), Pic. Please keep in mind that my current litigation is
Current and former
concerning to the current Bush Administration for several reasons.

Administration officials had direct ties to ISC. I will forward 3 ABC News Nightline episodes and
1 ABC News 20/20 episodes that investigated and reported on the ISC scandal. I will forward
these next week.
Page 20 of 36
Page 47 of 55
07/1612007
05.18.2009
Page 267 of 2301
I look forward to your help.
cc:
Enclosures
Page 21 of 36
Page 48 of 55
07/1612007
05.18.2009
Page 268 of 2301
IIJSIbf. Hotn"
Printed: Monday, February 26,200711:04 AM
amgroup01@Il1SI1.com
Fram :
Stan c:atmJone <amgroopOl@msn.com>
Sent:
Monday, February 26, 2007 11:03 AM
To :
webmaster-dso@darpa.mil
Subject:
Programs
'Attachment; WiredNews-ASpyMachineofDARPA_sOreams.pdf (0.03 MB)
I am looking for information of some of your programs regarding the Mind and Remote QlameIlng. See attad1ed.
I did some work on the "lIMIT' project with the National IsI:itute for Standards and Technologies. NIST back In 1990, as a
contractor (Advanced Media GroI4l). I was the Q)-ROM 111af'IUf'actln. I beIeve you were part of that rrojed.
Within the past 14 months I have bealme telepathiC, and I want to be assured your stalf has nothing to do with that activity.
I also have a Federal False Cairns Act complaint in the United States District Court for the Eastern District of PeMsytvnania
06-cv-39SS, It will be amended In due time and refiled.
In July of 2005, I was detained by 2 DIA Agents in Austin, Texas, and questioned about another Federal CDITlplaint 05-2288.
I would lite some ITansparency and some answers inVolving your involvement.
pOl@msn.CDITl
www.amggltertalnmentgroup.com
Fax: (717) 427-1621

220 Stone Hill Road
Conestoga, PA 17516
THE ADVANCED MEOlA GROUP

Page 7 of 36
Page 49 of 55
Page 49 of 55
07/1612007
05.15.2009
05.18.2009
Page 269 of 2301
CCHR Abuse Case Interview Form {ver. 1.0}, Jan, 1, 1992

No Proof or Edit
Citizens Commission on Human Rights

6362 Hollywood Boulevard,
Suite B Los Angeles, CA 90028
Phone: {213} 467-4242 Fax: {213} 467-3720
ABUSE CASE INTERVIEW FORM
NAME:
ADDRESS:
CITY:
WORK PHONE:
FAX:
DATE:
FORM FILLED
Stan J. Caterbone
615 Wyncroft Lane, Apt. 2
Lancaster
STATE: PA
{717} 392-3682 'HOME PHONE: Same
{717} 392-0532
January 1, 1991
OUT BY: Stan J. Caterbone
AGE: 33
ZIP: 17603
Brief summary of abuse {Drugs, Electric Shock Treatment, Psychiatric Rape, Confinement}:
Fabricated allegations of suicide, "going to the beach with a gun to kill himself", made by James Warner on August 12,
1987 to the Stone Harbor Police Department. Incarcerated and taken to the Burdette Tomlin Hospital in Stone Harbor,
New Jersey, on August 12, 1987 by Officer Steve O'Conner and Henry Stanford of the Stone Harbor Police Department,
and accompanied by Steve and Tom caterbone (brothers). Hospital officials refused to release me, and after several
hours, I was forced into signing a contract with the hospital that said "I, Stanley J. Caterbone will not take my life
tonight or anytime" as a requirement for my release. [SEE PAGES 40 TO 41 OF ROY GRIFFEN'S CHRONOLOGY OF
EVENTS, DATED DECEMBER 20, 1991]
On September 9th, 1987, I was denied bail for again fabricated criminal charges of September 3, 1987, (all charges
dropped in March of 1988) unless I admitted myself into the Psychiatric Unit of St. Joseph Hospital in Lancaster, PA.
Offidals of the Lancaster County Prison, attorney Robert Byers, Mary Lynn DiPaolo, Dr. AI Shulz, Yolanda Caterbone
(Mother), and Michael Caterbone (brother) all collaborated that the only way bail would be allowed to be posted is by
admitting myself, voluntarily, into the Hospital. After learning that the requirment (hospitalization), for posting bail was
not required, I released myself from the hospital. During the five days of hospitalization, I was made to take lithium
several times per day. I was also denied any opportunity to communicate with any attorneys or representatives
regarding any of my legal affairs. [SEE PAGES 45 TO 46 OF ROY GRIFFEN'S CHRONOLOGY OF EVENTS, DATED
DECEMBER 20, 1991]
On June 7, 1991, I was again incarcerated and arrested on fabricated charges, again by the Stone Harbor Police, again
by Officer Henry Stanford, for driving while under the influence. During a sobriety test on the Sidewalk, I again asked
Officer Stanford what the charges were and he replied "It doesn't matter, it is my word against yours, -and we know
who they will believe, remember '87. When I passed two breathalizer tests (.08), Officer Stanford refused to release me
and I was placed in a holding cell. After several hours, an Officer Mclaughlin arrived from the Avalon Police Department,
with a warrent for my arrest, for outstanding warrents (fabricated traffic violations of August 14, 1987), which attorney
Byers had since said were dropped, and again placed under arrest. The two officers, McClaughlin (Avalon, NJ) and
Stanford (Stone Harbor, NJ) requested $340.00 for bail. I requested to go to my car for the cash, which was one block
away, and Officer McGlaughlin refused stating "you may have a gun in the car". I was taken to the cape May County
Prison, fingerprinted and improsoned until the next day. I posted bail the following day. [SEE PAGES 74 TO 75 OF ROY
GRIFFEN'S CHRONOLOGY OF EVENTS, DATED DECEMBER 20, 1991]
On September 3, 1987, I was arrested for burglarizing my own leased property, charged with stealing my own
property, charged with destroying my own property, charged with terrorizing my own employee, who I kissed goodbye,
and awaited for her safe return into my building, and charged with making an alleged bomb threat to my own place of
bUSiness, by the Manhiem Township Police Department, the Lancaster District Attorney, District Justice Murray Horton,
and District Justice Richard Reeser. [SEE PAGES 44 TO 45 OF ROY GRIFFEN'S CHRONOLOGY OF EVENTS, DATED
DECEMBER 20, 1991]
Page 22 of 36
Page 50 of 55
07/1612007
05.18.2009
Page 270 of 2301
On December 4, 1987 at the annual shareholders meeting of Financial Management Group, Ltd., the company that I
had founded, Mr. Robert Kauffman conveniently arranged and hired armed security guards stand _at the entrance of the
meeting. This strategy was used for the sole purpose of purporting and supporting his fabricated allegations of criminal
misconduct and mental illness of myself, by suggesting that I was going to attend the meeting, which was perfectly
within my rights, as a 20% shareholder of Financial Management Group, Ud., the Executive Vice PreSident, and
Secretary, and President of FMG Advisory. Mr. Kauffman attempted to insinuate that I was contemplating attending the
meeting in order to cause violence. I did not attend the meeting, nor had any plans to do so. [SEE PAGES 53 OF ROY
GRIFFEN'S CHRONOLOGY OF EVENTS, DATED DECEMBER 20,1991]
In March of 1991, David D. Dering, the president of American Helix Technology Corporation, told all employees during a
special staff meeting, that I "was a runaway ex-convict that would end up in jail soon, and that I was "bad news". Mr.
Dering also spent approximately 20 minutes slandering my character, my reputation, and my bUSiness activities. Mr.
Dering was threatened by my disclosure of filing a civil Anti-Trust suit against American Helix and High Industries, its
parent company, for allegations of conspiracy to sabotage my bUSiness activities in 1987 with "Digital Technologies",
which resulted in the formation of American Helix, by persons which were involved in my business affairs in 1987, and
which was my business. (Scott Robertson, Robert Long, Norris Boyd, High Industries). [SEE PAGES 73 OF ROY
GRIFFEN'S CHRONOLOGY OF EVENTS, DATED DECEMBER 20,1991]
On July 6, 1987 in the first conversation with Dr. AI Shulz since 'November of 1986, Stan Caterbone learned that
numerous persons, including Mary Lynn DiPaolo and Jere Sullivan had personally called Dr. Shulz and fabricated
allegations of mental illness in the previous' days. Dr. AI Shulz also accused Stan Caterbone of suffering from "illusions
of grandure", and did not believe any of his extensive business dealings, specifically the "Digital" movie and its related
activities.
[SEE PAGES 34 TO PAGES 35 OF ROY GRIFFEN'S CHRONOLOGY OF EVENTS, DATED DECEMBER 20, 1991]
On or about July 30, 1987 Stan Caterbone retained the services of Dr. Marshall Levine, a psychiatrist from Northfield,
NJ, to conduct an objective review of his mental state of mind, soley to discredit the fabricated allegations of mental
illness. Dr. Levine conducted a 2 hour interview at his home in Stone Harbor, NJ and requird Stan Caterbone to
complete the MMPI test. Stan Caterbone also paid Dr. Marshall Levine a $600 fee for the services. After submitting the
MMPI test, and not hearing from Dr. Levine, Stan Caterbone finally called Dr. Levine for the results. Dr. Levine had
disclosed that he had conducted telephone interviews with family members, without the consent or knowledge of Stan
Caterbone, and specifically not adhering to the original agreement of a complete objective and impartial review. Dr.
Levine prescribed Lithium drugs, and would not send any written communications regarding his findings or conclusions.
Stan Caterbone requested for a refund of all monies paid, however Dr. Marshall leVine refused.
[SEE PAGES 39 TO
PAGES 40 OF ROY GRIFFEN'S CHRONOLOGY OF EVENTS, DATED DECEMBER 20, 1991]
It should be noted that I have never been convicted of any crime, before or after the above occurences. In fact, I have
never had any altercation with the law before the above inddents, except for a few speeding violations that dated back
to 1982.
Many other inddents described in detail in Roy Griffen's chronology of events of December 20, 1991.
When did the abuse occur?
See above.
List the names of the psychiatrists involved:
Name
Dr. AI Schulz
Dr. Marshall Levine
Office/Hospital
Phone
St. Joseph Hospital

Northfield, NJ
Page 23 of 36
Page 51 of 55
(717) 291-8083
forthcoming
07/16/2007
05.18.2009
Page 271 of 2301
List the names of any other people involved:
Name, Phone (All parties below have supported and or fabricated allegations of insanity, and or
psychiatric treatment)
Michael Hartlett, (717) 898-560-4499
Mary Lynn DiPaolo, (717) 569-0022
Michael DiPaolo, (717) 569-0022
Jere Sullivan, (703) 579-6143
James Warner, (717) 397-9968
Detective Sigler, (717) 569-6401
Robert Kauffman, (717) 569-560-8300
Detective Mathias, (717) 569-6401
Howard Eisler, (717) forthcoming
David Drubner, (203) 753-9292
Yolanda Caterbone, (717) 394-7710
Steven Caterbone, (305) 751-0352
Phillip Caterbone(717) forthcoming
Thomas Caterbone, (717) 299-5194
Robert Beyers, (717) 394-7204
David D. Dering, (717) 392-7840
Allon Lefever, (717) 293-4444
Scott Robertson, (717) 393-8082
Mr. & Mrs. Frank Roda, (717) 394-1160
Unda Murphy Berger, forthcoming
Karen Hickman, (717) forhtcoming
Michelle Hodge Miller, (213) 546-5124
Ronald Roda, (717) 299-5469
Wayne LandiS, (717) 843-9227
Art Kerst (717) 392-4797
Evelyn Sullivan, (717) 392-3221
Benjamin Roda, (717) 392-9999
Joseph Roda (717) 397-3791
Amy Hinterlighter, (215) 640-4852
Dan Moyer (717) 295-1200
Jack Mahn (609) 368-1551
Bob Walters forthcoming
Victor Makarowicz (717) 569-8296
Herb Fisher (717) 394-6463
Fred Martin (FBI) (717) 232-8686
Jeff Jamounou (717) 232-8000
Sen. Gib Armstrong forthcoming
Steven Hobday (717) 393-8637
Cristine Housner (717) 293-9293
District Justice Murray Horton forthcoming
District Justice Richard Reeser forthcoming
James Christian forthcoming
Lt. Madenspacher (717) 569-6401
Richard Hobday (717) 393-8637
Tim Hogentogler (717) 569-8057
John Baumgardner forthcoming
Daniel Berger (717) 872-1313
Alan Loss (717) 560-4499
Nancy Arment (717) 872-9355
Omar Landis (717) 859-5466
Peter Peneros (717)295-1200
John M. Wolf II 393-5601
Chuck Smith (717) 569-5341
Peter Wolfson (717) 299-6615, (717) 569-5341
Craig Russell (717) 293-9293
Page 24 of 36
Page 52 of 55
07/1612007
05.18.2009
Page 272 of 2301
Rich Braverman (717) 295-1200
Dr. William Umiker (717) 394-9936

William Kogler (404) 951-0600
Claude Pea (404) 951-0600
Thomas Flannery forthcoming
Jay Curtis forthcoming
Mike Kawahara forthcoming
Benjamin Phister forthcoming
Mike Hess (717) 299-7382
Bruce Kline forhtcoming
John DePatto forhtcoming
Michael McDonald forthcoming
Lewis Schweller (609) 645-1111
Michael Orstein forthcoming
Mr. Tottaro, Asst. District Attorney (Lancaster) forthcoming
Marc Finegold (717) 392-7840
Pete Richter (717) 394-0547
Farmers Rrst Bank (717) 394-0547
Jill Carson (Fulton Bank) forthcoming
Norris Boyd (717) 569-0484 Cliff Weaver forthcoming
Ric Fox (717) 774-5244 Detective Bodan,
PA Attorney Generals Office forthcoming
Give the sequence of the abuse in detail from the beginning to end, providing the dates for all
occurrences and the names of the people involved in each occurrence.
See Roy Griffen's Chronology of December 20, 1991, pages 1 to 88.
Date
Occurrence
See Roy Griffen's Chronology of December 20, 1991, pages 1 to 88

List out the specific harms resulting from the psychiatriC treatment which you are aware of:
Loss of professional and personal ruputation. Loss of income. Extreme sense of cuation when engaging in interpersonal
relationships. Extreme loss of respect among personal and professional peers. Complete and thourough mistrust for
psychiatric profession. Sense for the inadequate and abuse of psychiatric diagnosis, and familiarity and personal
experience of psychiatric abuse in order to support political, finandal, and or personal agendas and gains. Extreme loss
of dignity. Extreme loss of respect. Permanent psychological scares from experience. Extreme mental duress, stress,
and other related anxieties. Complete loss of faith of Psychiatric profession and related supporting systems, induding
law enforcement, judidal, and legislative, considering the pleas for help to resolve the criminal conspiracy in the early
stages of July, 1987.
Loss of Patent and intellectual property rights of Financial Management Group, Ltd., and Digital technologies, induding
the PSDMS (Power Station Digital Movie Sound).
Loss of Accumulated Business assets worth at least $2,500,000.

Do you have government connections personally or through family members? If so, what?
Page 6 of S
CCHR Abuse Case Interview Form (ver. 1.0), Jan, 1, 1992
-Federal contracts with the National Institute of Standards and Technology for CD-ROM manufacturing. Procurement for
same with the Defesnse Mapping Agency of the Department of Defense. Phillip Caterbone (brother), fellowship with
the National Institute of Health of Bethesda, Maryland (1990-1991). Samuel A. Caterbone (brother), military service,
USAF (1969-1971). Samuel Caterbone, Jr., (father), alleged assodation with the Central Intellegence Agency, CIA,
(disdosed by Dominic Roda, unde & Godfather, on November 17,1991, and by Midge Caterbone, aunt, on November
22, 1991. Both persons acknowledged the time period of 1974 to 1981 where the whereabouts of Sameul Caterbone
Jr. were unknown to all persons, induding all family members.
Page 25 of 36
Page 53 of 55
07116/2007
05.18.2009
Page 273 of 2301
Do you have family or friends who think you should undergo further psychiatric treatment?
See list.
All persons have advocated the use of medication. Reasons were never disclosed. The persons would
especially disclose the belief for psychiatric treatment when I persued legal recourse for activities of 1987.
In all of the events, activities, and incidents described herein, No one, has ever stated any particular event or incident
to support the many allegations of mental illness. Any allegations, the suicide, financial bankruptcy, and others, have
always been proven to be fabricated, and I have always had sufficient evidence that they were fabricated. However,
to this day, I, have never had any opportunity to discuss all related affairs, contained herein, with the exception of the
4 hour meeting on September 29,1987, with the Pennsylvania Securities Commission. However, after that meeting, I
have not heard from the investigator, Mr. Howard Eisler, or any representative of the Pennsylvania Securities
Commission, until 2 months later, when I recieved a notice to put my complaint into writing.
In addition, during the preliminary hearing of the Criminal charges of September 3, 1987, my alleged attorney, Robert
Byers, refused to discuss any of my defenses, including that I was legally never terminated from the FMG, Ltd., Board
of directors, that I was an indiviual leaseholder of the building I allegedly burglarized, that all of the files taken were my
property, as well as others.
How do you feel about what psychiatry did to you?
Ruined my life, my businesses, my opportunity for income, and Virtually all relationships encountered prior to 1987.
Loss of all personal assets, including homes, monies, and business accomplishments. It is the single most reason for
the lack of any type of quality of life, which I presently am deprived, which will soon result in becoming homeless.
Have you contemplated taking any action against the psychiatrist or do -you want to take action? If
so, what?
Yes, civil suits to recover financial damages, personal and professional reputation, and punative damages for extreme
emotional and mental duress.
Any other comments or information you would like to provide?
This case is directly involved with a "Cover-Up" (criminal conspiracy) to supress my knowledge and allegations of
misconduct of Intemational Signal & Control (ISC), which I made public in May of 1987, and to ISC executive Larry
Resch on June 23, 1987, during a meeting at my office. I was a shareholder of ISC stock during that time. In addition,
Jere Sullivan and James Warner, both of whom personally fabricated allegations of isanity, were directly involved with
ISC. Jere Sullivan worked for United Chem Con, (Guerin company), and has been a business partner of Mr. Larry
Resch since 1987. James Wamer (Lancaster Solid Waste Management Authority) was working with attorny Steve
Spinello, of the law firm of Hartman, Underhill, & Brubaker, on the $50 million incinerator. Steven Spinello was also
negotiating the ISC merger with Ferranti International, of London, during the time inwhcih I made allegations of
misconduct regarding Mr. James Guerin, ISC, and United Chem Con. During this same tirne, Mr. James Warner made
repeated allegations of insanity, and also offiCially reported a fabricated allegation of suicide to authorities of the Stone
Harbor Police Department, of New Jeresy. Ferranti and ISC finally merged the following November, of 1987. In
September of 1987, I made allegations of fruad within ISC to Howard Eisler, an investigator with the Pennsyvania
Securities CommiSSion, during a 4 hour meeting in my home, 'that was solicited by the Pennsylvania Securities
Commission.
All allegations of insanity (surfacing in July of 1987 and continuing to present), conveniently discredited all of my
allegaitons of misconduct within ISC, its executives, and its operations, as well as my allegations of criminal conspiracy
and fruad by Robert Kauffman, Michael Hartlett, FMG, Ltd., executives, Commonwealth National Bank, as well as all
other related parties.
In 1989, Ferranti disclosed allegaitons of the "Billion Dollar Fraud" by James Guerin and ISC, by inflating the value of
ISC related contracts.
On October 31, 1991, ISC founder James Guerin, Larry Resch, and 17 others were indicted by a Philadelphia Federal
Grand Jury on charges of a "$ 1.14 Billion Fraud (Ferranti/ISC Merger of November, 1987)" and the illegal sales of
Arms to South Africa and Iraq. Mr. Guerin and Mr. Resch have since pleaded guilty to aU charges.
Page 26 of 36
Page 54 of 55
07116/2007
05.18.2009
Page 274 of 2301
Thank you for filling out this survey. Please send it to us in the enclosed self addressed envelope.
As per my conversation with your representative on December 16, 1991, I would expect to receive a copy of your
findings, reports, and or conclusion of your investigation, for myself, as well as my legal representatives, and or their
agents.
Audio tapes of authentic recorded conversations of above inCidents, forthcoming. In addition, I possess the following
information assets, which, beyond a shadow of a doubt, collaborate, support, and prove all of the preceding:
Paper Documents
Audio Transcripts
Microfiche
VHS Video
CD-ROM
CD Audio
9- Track Tape
CD-ROM/CDTV Demo Discs
Full Color Photographs
News Articles
11,000
Appr. 18 Hours
9,079 Images
50 Hours
150 Megabytes (1 disc)
60 Minutes (1 disc)
2 Reels- P{v. 50400 Appr. 200
Page 27 of 36
Page 55 of 55
07/1612007
05.18.2009
JUDGING JUSTICE: A special report.; Federal Judge Overturns Murder ...
1 of 7
http://www.nytimes.com/1997/12/27/us/judging-justice-special-report-fe...
Page 275 of 2301
This copy is for your personal, noncommercial use only. You can order presentation-ready copies for distribution to
your colleagues, clients or customers, please click here or use the "Reprints" tool that appears next to any article.
Visit www.nytreprints.com for samples and additional information. Order a reprint of this article now.
December 27, 1997
JUDGING JUSTICE: A special report.; Federal Judge Overturns

Murder Verdict, Fueling Feud on Judicial Power
By JAN HOFFMAN
EAST LAMPETER TOWNSHIP, Pa. On a December morning six years ago, Hazel Show walked into her home to find
her 16-year-old daughter, Laurie, soaked with blood from a savage, gaping throat wound. As she frantically cradled Laurie in
her arms, Mrs. Show would later say, the dying girl rasped, ''Michelle. Michelle did it.''
Across the largely rural, huddled communities of Lancaster County here, those dying words have long represented an
unflinching, accusatory finger.
But last April, a Federal judge sitting 75 miles east in Philadelphia said the words should be erased from communal memory.
Because of her wounds, he wrote, Laurie Show could not possibly have uttered them. Then he freed ''Michelle'' -- Lisa Michelle
Lambert, who had been serving a life sentence for the murder.
Over the course of a 14-day hearing, he wrote, Ms. Lambert had proved not only that she was ''actually innocent,'' but also that
her state trial had been extravagantly corrupted by prosecutorial misconduct.
Then for that reason, in an unprecedented act, the Federal judge, Stewart B. Dalzell, barred the state from retrying her.
Judge Dalzell's decision vaulted the Lambert case into the contentious national debate over how active a role Federal judges
may take in state matters.
Supporters of the ruling say it is a rare, shining example of the Federal court exercising its traditional authority as a last
refuge against a rogue state prosecution. But detractors say it is a fat thumb in the eye of convention, Federal overreaching at
its most extreme. And they have mounted a campaign against Judge Dalzell that is extraordinary, even at a time of
widespread criticism of the Federal judiciary.
A conservative organization circulated a fund-raising tape featuring the Lambert decision as judicial activism at its most lurid.
Pennsylvania's senior Senator, Arlen Specter, and two of its Congressmen introduced legislation that would strip Federal
judges of the power to ban many state retrials. In a companion brief to a Federal appeals court, which is expected to rule in
the coming days, six state attorneys general warned that to uphold the Dalzell opinion would be to give Federal judges a free
hand to wrest cases from state prosecutors.
And in Lancaster County, 37,000 people made it personal: they signed a petition demanding that Judge Dalzell be impeached.
Conversely, the judge could be seen as having struck the first blow. He wrote that the rush to convict Ms. Lambert, who had
originally faced the death penalty, had been communal in nature.
In its haste, Judge Dalzell wrote, ''Lancaster County made a Faustian bargain.'' By trying to execute an innocent woman, ''it
lost its soul.''
How could Lancaster County and a Federal judge be so far apart?
The answer lies to some extent in the different images of the defendant. In 1997, Judge Dalzell freed an inmate who now
called herself Lisa, a 24-year-old woman with chestnut-colored eyes and light brown hair, whose witnesses included an expert
on domestic violence.
But in 1991, Lancastrians knew her as Michelle, a 19-year-old waitress with bleached white-blond hair, blue contact lenses,
heavy makeup, skimpy clothing, a rough mouth and a rougher reputation.
7/24/2015 5:30 AM
2 of 7
Page 276 of 2301
That year, Lancaster County was particularly uneasy about violent crime, especially violent teen-age crime. Juvenile offenses,
exacerbated by boredom and drugs from Philadelphia, were rising. Although murder was rare in this sedate, religious area
best known for its Amish farmers, a sensational family slaying had sent the murder rate to 14. Teen-agers were suspects in five
of the homicides.
Laurie's Death
A Butcher Knife, A Rope on Her Neck
The motive in Laurie Show's murder was jealousy, prosecutors argued at Michelle's 1992 trial. That summer, Laurie had dated
Michelle's live-in boyfriend, Lawrence (Butch) Yunkin. Throughout the autumn, Michelle spoke openly of her hatred and
jealousy of Laurie and even scuffled with her at a mall. Laurie was so frightened that her mother had their phone number
changed and tried, in vain, to have Michelle served with an order of protection.
At 6:45 A.M. on Dec. 20, 1991, Mrs. Show left the condominium where she and Laurie lived, in East Lampeter Township. The
night before, she had received a call to meet a school counselor about her daughter. After she drove off, Tabitha Buck, a
17-year-old friend of Lawrence and Michelle, arrived at the condominium, carrying a butcher knife and a rope. Michelle
followed.
Mrs. Show, unnerved when no counselor appeared, returned home and found Laurie bleeding from her hands, back and head.
She untied a rope from Laurie's neck. Then she saw the throat wound.
At the seven-day non-jury trial, Michelle testified that the three had only intended to cut off hanks of Laurie's hair, as a prank.
When Tabby Buck's attack turned brutal, Michelle said, she tried to drag Laurie away but then fled the apartment in terror,
meeting Lawrence, who was on his way in.
The county judge found Ms. Lambert guilty of first-degree murder. Because she had no prior record and, having been six
months pregnant at the time of the murder, was now a mother, he sentenced her to life in prison instead of death.
Tabby later received a life sentence for second-degree murder. Lawrence testified against both women -- saying he had only
dropped them off, gone to a McDonald's, and picked them up -- and received up to a year in prison in a plea bargain. That was
later changed to 10 to 20 years, after prosecutors realized he had committed perjury.
A Handwritten Appeal
A Petition Lands In Federal Court
In the years that followed, Ms. Lambert's situation became increasingly desperate. Her appeals were rejected by successive
Pennsylvania courts. When she accused a prison guard of repeatedly raping her, she was punished with solitary confinement.
The guard, however, was eventually tried and convicted; for her protection, she was transferred to a New Jersey prison. From
there, she sent a handwritten petition in 1996 to the Federal court in Philadelphia.
In recent years, the Supreme Court and Congress, angered by the Federal court backlog, have made it exceedingly difficult to
obtain a habeas corpus hearing, at which a Federal judge can decide if a state prisoner's imprisonment is unconstitutional. Of
the 10,000 or so petitions filed every year, a small percentage get hearings. Perhaps 1 percent earn relief.
Ms. Lambert's petition landed at random before Judge Dalzell, 54, an eloquent, erudite Bush appointee who is regarded as
even-handed, except, perhaps, some say, in matters of criminal law. When an appeals court overruled his sentence of a drug
dealer for being too harsh, for example, Judge Dalzell reduced the sentence to 35 years from 40.
The judge asked a Philadelphia firm, Schnader, Harrison, Segal & Lewis, to take the Lambert case. It was picked up by a
relentless 37-year-old litigator named Christina Rainville. Armed with broad Federal discovery powers, Ms. Rainville and
seven Schnader lawyers began combing through police and prosecution files.
Lisa's Story
Religion and Sex, Violence and Fear
When Ms. Lambert took the stand at her habeas hearing last April, her hair and eyes were their original brown, and she
7/24/2015 5:30 AM
3 of 7
Page 277 of 2301
identified herself by her first name, Lisa. In a hearing that was 14 days, twice as long as her trial, a fuller account of the events
leading up to the murder, as well as the investigation, emerged.
She had used her middle name, Michelle, to please her boyfriend. Lawrence. Her deeply religious parents -- accountant father,
homemaker mother -- had encouraged the match because Lawrence's uncle was an upstanding member of their church.
Her parents taught her that a woman marries the man who takes her virginity. On their fourth date, she said, when she was
16, Lawrence Yunkin, then 18, her blond Adonis, raped her in the back of his van. She became his.
Lawrence ordered her to dress like Barbie. So she wore itsy bits of leather and X-rated bikinis, bleached her hair, slathered on
makeup.
He knew the sight of blood nauseated her. To torment her, he would cut deep X's in his cheeks and stand over her, dripping.
One night, after she was living with him, her mother, responding to her shrieking phone call, went to their apartment and saw
blood-soaked sheets: he had sodomized her. To Lawrence, Lisa testified, sex without violence was not any fun.
The beatings escalated with a dull, terrifying regularity. Once he hacked her hair short with a butcher knife. A neighbor called
the police. She did not press charges -- he had promised to marry her.
Eventually they moved to a remote trailer; he had forbidden her to learn to drive, so she depended on him to get to work, to
the store, to visit a girlfriend.
At the hearing, Dr. Ann Burgess, an expert in domestic violence, explained that Lisa was incapable of leaving -- to do so would
be to fail her religion, her parents, Lawrence. Lisa believed that without makeup she was ugly, without Lawrence she was
nothing.
When Hazel Show learned that Lisa was pregnant, she halted her daughter's fledgling relationship with Lawrence. Laurie
seemed relieved, her mother later testified: Laurie said Lawrence date-raped her in his van.
Whenever Lisa screamed at the younger girl in front of their friends, Lawrence was in the background, smirking. Lisa testified
that as her pregnancy developed, she tried to prove her loyalty to Lawrence by insulting Laurie, hoping the beatings would
abate.
In the fall, Lawrence heard that Laurie had told the police about the date-rape. He feared prison, being raped himself. He told
Lisa and their friend Tabby that the three should beat up Laurie. Believing that Laurie herself was pregnant, Lisa testified, she
urged them just to cut her hair. Lawrence seemed to agree. But he told friends he was going to ''murder a bitch.''
Lisa's account of the murder was virtually identical to the one she told at trial five years before:
When she saw Tabby stabbing Laurie, she tried to separate the two. Blood. Panic. ''Don't leave me here,'' Laurie cried as Lisa
backed away. Lisa grabbed her by the wrists, but Tabby lunged. Lisa fled.
As Lawrence stormed into the condo, he ordered Lisa to wait at the bottom of the stairwell.
In Federal court she was asked why had she not screamed, gotten help? Why did she stay? She seemed nonplussed. ''Because,''
she replied, ''Lawrence put me there.''
A Judge's Ruling
Evidence Destroyed, Hidden, Fabricated
In his closing remarks, District Attorney Joseph Madenspacher of Lancaster County defended his chief assistant's prosecution.
''I still think the evidence indicates that perhaps this was just a very poor police job,'' Mr. Madenspacher told Judge Dalzell.
The judge found that thinking wishful at best. In his decision, he wrote that Ms. Lambert's new lawyers had proven that in 25
instances, prosecutors and the police had fabricated, hidden and destroyed evidence, tampered with witnesses and offered
perjured testimony. (He listed but did not elaborate on nine more, saying, ''We have surely by now beaten the life out of that
horse.'')
There was, for example, the videotape.
7/24/2015 5:30 AM
4 of 7
Page 278 of 2301
Before the trial, an eight-minute soundless videotape had been turned over to the defense, showing officers searching in vain
for a pink trash bag in which Ms. Lambert said she had placed Mr. Yunkin's bloody sneakers. Ms. Rainville's team demanded
the unedited, nearly 13-minute original, complete with sound. It reveals an officer standing by a pink trash bag, waving away
the camera. Someone yells, ''What do you got, a bag?''
And the absent crime-scene photographs.
At the Federal hearing, at least three witnesses described a pattern of blood spatters consistent with Lisa's story. So did
private insurance company photos, taken three days after the killing. But only about 20 of the nearly 500 police photographs
given to Ms. Rainville's team were of the crime scene: none detail those spatters, much less bloody footprints.
And the mysterious sweatpants.
At the trial, prosecutors offered a pair of men's extra large sweatpants that had traces of Ms. Show's blood. Mr. Yunkin
testified they were his, but that Ms. Lambert had borrowed them because of her pregnancy.
But Ms. Lambert, six months along, was so slim that arresting officers had not realized she was pregnant. At the hearing,
prosecutors again produced what they insisted were the sweatpants she wore. But these were smaller, a boy's size large.
The sweatpants were the only physical evidence linking Ms. Lambert to the murder. No fingerprints or hair strands were
recovered; unlike Tabby and Lawrence, she had no scratches or bruises.
There remained, however, the resounding echo of Laurie's dying words.
Before the trial, the prosecutor, although forbidden by Ms. Lambert's lawyer and in violation of legal ethics, telephoned the
defense's forensic pathologist, who would testify about whether Laurie could have spoken. At trial, the defense expert agreed
with the prosecution's view: yes, speech would have been possible. The defense lawyer was stunned. The next year, the
pathologist's income from testifying as an expert for the Lancaster County District Attorney's office quadrupled.
But at the hearing, Ms. Lambert's new lawyers presented a professor of speech mechanics and Philadelphia's chief medical
examiner. Both said Laurie's throat wounds were so severe that speech would have been impossible. Disputing a Lancaster
County autopsy report, the experts concluded that a carotid artery had been severed. At best, Laurie would have been
conscious five minutes after the attack, brain-dead after 10.
Certainly many people at the scene remembered Mrs. Show yelling, ''Michelle did it!'' But no one recalled her saying Laurie
had said so. The first reference appeared in a report taken by the chief detective of East Lampeter Township.
As the damning evidence accumulated, so did Judge Dalzell's anger: police officers were denying responsibility, pointing
fingers, suffering collective amnesia. By the third day, he warned the district attorney, Mr. Madenspacher, that officers were
committing perjury.
Freedom for Lisa
An Unusual Result For an Unusual Case
On the 12th day of the April hearing, a distressed Hazel Show told the judge that her memory had been jogged. She now
remembered telling a detective about a brownish car -- Lawrence Yunkin's -- leaving the condominium complex as she drove
in. Her account matched the testimony of another witness, placing Mr. Yunkin close to the crime scene and corroborating
parts of Ms. Lambert's account.
But the detective had told Mrs. Show that she must have been mistaken. Neither her report nor the fuller description given by
the other witness was disclosed to the defense. Under a powerful line of Supreme Court cases, the prosecution must hand over
any evidence favorable to the defense.
At that, Judge Dalzell asked Mr. Madenspacher if he did not now believe that Ms. Lambert was entitled to relief. Reluctantly,
Mr. Madenspacher agreed.
Then the judge released Ms. Lambert to her lawyers, pending his final ruling.
Three days after Mr. Madenspacher put on a day of tepid testimony defending the prosecution, the judge unleashed his
7/24/2015 5:30 AM
5 of 7
Page 279 of 2301
90-page opinion. Commending Ms. Lambert for her ''punctilious honesty,'' Judge Dalzell said she had established
prosecutorial misconduct, as well as her own ''actual innocence'' under a tough new habeas standard requiring that proof be
not just ''more likely than not,'' but ''clear and convincing.'' (This is still a notch below the criminal standard of beyond a
reasonable doubt.)
Usually, a Federal judge lets state prosecutors decide if they have enough evidence for a retrial. But, Judge Dalzell said,
unusual cases demand unusual results. To permit Pennsylvania to retry her, after it had so utterly deprived her of due process,
he wrote, would be constitutionally intolerable.
''Why did this happen?'' Judge Dalzell asked. ''How could a place idealized in Peter Weir's 'Witness' become like the world in
David Lynch's 'Blue Velvet?' ''
After Laurie Show's vicious murder, he theorized, Lancaster quickly pronounced judgment: Ms. Lambert, whom even friends
called ''trailer trash,'' he wrote, ''was as though delivered from Central Casting for the part of villainess.''
He added: ''In making a pact with this devil'' -- Mr. Yunkin, who he said had a direct role in the murder but cut an
extraordinary deal for his testimony -- ''Lancaster County made a Faustian bargain. It lost its soul, and it almost executed an
innocent, abused woman.''
In Lancaster County, the Amish values of work and church are closely held. Civility is important. So is respect for law
enforcement.
To the local way of thinking, Judge Dalzell had treated their officers with neither civility nor respect.
''People were hostile, upset, flabbergasted,'' said Ted Byrne, whose radio show was jammed with calls about the case.
The same theme was sounded: We trust our own to investigate our own. ''They knew that Lisa Lambert was a bad girl, a very
violent young woman,'' Mr. Byrne said. The judge had turned truth on its head. Somehow, Ms. Lambert had become the victim
while their prosecutor -- a well-respected man whom people knew from church -- had become the villain.
Molly O'Brien, a former county public defender who teaches law at Emory University in Atlanta, said that Lancaster's law
enforcement had traditionally enjoyed unchallenged authority.
''Whatever the prosecution wanted to give us was all that we would get,'' Ms. O'Brien said. ''The attitude in Lancaster toward
police misconduct has been, 'If they're getting the right people, I don't really care how they get them.' But I don't think that
Lancaster is much worse than other places.''
For Ms. O'Brien, what distinguished the case was neither the misconduct nor the public loyalty to law enforcement but ''the
kind of defense Lisa Lambert got on her habeas hearing. That's really unusual.''
Even last May, when the United States Attorney in Philadelphia started looking into the handling of the Lambert case,
Lancastrians stood by the prosecution. So the police had forgotten to cross T's and dot I's. After all, the Show case was only the
township's third homicide in 20 years.
Laurie's parents are the police and prosecutor's strongest boosters. ''I could put myself in their shoes,'' said John Show, Hazel's
ex-husband and a technician at a farm-machinery plant. Shaking his head sympathetically, he added, ''Those police officers
went through hell up there on the stand.''
A petition drive roared through the county. Started largely by Mr. Show, it demanded that Judge Dalzell be impeached.
Everyone clamored to sign, including tourists, drawn to posters of Laurie's apple-cheeked 10th-grade photo. Even the Amish,
who usually avoid affairs of the modern world, tied up their buggies at the hitching post outside Mr. Show's home, paid their
respects and offered their signatures.
That summer, the Shows also met with members of the Free Congress Foundation, an arch-conservative group that has
campaigned against many Clinton judicial nominees. A 15-minute fund-raising tape, featuring footage of John Show sobbing,
proffers Judge Dalzell as the epitome of ''liberal judicial activism.''
In September, the Shows and their friends took the 37,000 signatures to Washington. Senator Specter had explained that
Federal judges, who have lifetime appointments, cannot be impeached for unpopular decisions. But as a curative, the Senator
7/24/2015 5:30 AM
6 of 7
Page 280 of 2301
and Representatives George W. Gekas and Joseph R. Pitts, both Republicans like Senator Specter, had proposed the Victim
Protection Act, called the Laurie bill, to prevent Federal judges from barring many state retrials.
Given how rarely a Federal judge would consider so extreme a measure, the bill is more symbolic warning than substantive
curb on judicial authority. But that symbolism -- if we don't like a ruling, we will find a way to block it -- has great force,
especially in an era when the President criticizes a New York Federal judge's ruling in a drug case and a few members of
Congress have questioned the lifetime tenure of the judiciary and the limited conditions for removal from the bench.
Edward W. Madeira Jr., chairman of an American Bar Association commission on judicial independence, said Congress
indeed has the right to rein in the power of the Federal judiciary. But he and other legal scholars have criticized the bill as
inappropriate while the United States Court of Appeals for the Third Circuit, in Philadelphia, is weighing the case.
''Is this the right time?'' Mr. Madeira asked. ''One would think not, particularly when it could be seen as threatening to an
appellate court and judges generally.''
The appeals court may not even address whether Judge Dalzell should have barred a retrial. First, the judges must decide if
Ms. Lambert even had the right to be in Federal court.
The county argues that Ms. Lambert has not exhausted her state court remedies. Ms. Lambert's lawyers retort that the
Pennsylvania Supreme Court denied her appeal, and that state law barred her from bringing a fresh claim based on
innocence. Federal court, which has an eye-of-the-needle opening for such claims, they say, was her last chance.
In the county's appeal, handled by Alvin Lewis and Richard Sprague, private lawyers, Lancaster quarreled with each of Judge
Dalzell's misconduct findings. Investigatory mistakes were unintentional. Before the trial, the prosecutor disclosed that he had
contacted the defense's expert witness. And even if various tapes, notes and reports had been given to the defense, the county
argues, they were not persuasive enough to have changed the verdict.
The bottom line, the lawyers for the county wrote, was that Ms. Lambert lacked credibility. In her early statements to the
police, she had even exonerated Mr. Yunkin. But by her own testimony, they said, she had helped set in motion something
that could hardly be passed off as a ''prank.''
Contrary to Judge Dalzell's view of her role -- that, given her severe psychological limitations, Ms. Lambert had tried to play
down violence that spun horribly out of control -- prosecutors said she should be held responsible as an accomplice to murder.
Certainly in Lancaster, Ms. Lambert's guilt is almost an article of faith.
An Anxious Wait
Shy and Nervous, An Uncertain Woman
Recently in her lawyers' office in Philadelphia, Lisa Lambert talked about letting go of Michelle, and five and a half years of
prison. Indicative of her progress has been the wiping off of her old makeup, which a Schnader lawyer, Peter Greenberg,
described as ''Tammy Faye Bakker crossed with 'The Rocky Horror Picture Show.' ''
''I was so convinced I was ugly,'' Ms. Lambert said, '' that I had to cover every little bit of skin.''
At 25, Lisa Lambert looked like an 18-year-old trying to dress up. She wore a double-breasted black skirt suit and high heels.
Her makeup was moderate. A shy woman, she blushed easily, radiating a blend of sensuality and vulnerability. When she
walked through the building's lobby, nervously flipping her shoulder-length hair, men stared.
Her transformation is not complete. The suit jacket had a deep V-neck, and her many gold chains did not cover her bare skin.
The skirt, Ms. Rainville carped with a propriety tone, was too short.
Ms. Lambert was painfully reluctant to talk, but after much coaxing, she spoke briefly about life these days.
''I'm depressed a lot, and I'm always worried that people at work will find out about me,'' said Ms. Lambert, whose parents
have custody of her daughter. ''It's hard to talk to people. I don't have the communication skills of a normal 25-year-old.''
Small talk is difficult, silence more familiar. ''At restaurants, I don't like to order food, I like people to order for me. In prison,
you have to watch what you say. ''
7/24/2015 5:30 AM
7 of 7
Page 281 of 2301
She said she was terrified that she might have to face Lancaster prosecutors again and be imprisoned. After all the evidence
that tumbled out at the Federal hearing, she wondered, ''Why do they want to keep doing this to me?''
In Lancaster County, Hazel Show is confident that her daughter's killer will be punished -- and she does not mean Lawrence
Yunkin, who will be eligible for parole in about four years.
''When Michelle goes back to prison, it will be harder on her because she's enjoying life now,'' said Mrs. Show, who works as a
personal shopper at a high-end department store.
Hazel Show does not share Judge Dalzell's view that the ''headlong caricature of a prosecution'' had cruelly deprived the
Shows and the county of a resolution. Until last year, Mrs. Show had been rebuilding her life. The truth about the murder of
her only child was known, and justice had put the right people away for the appropriate sentences.
But then a Federal judge in Philadelphia reached in and ripped everything apart.
''She could have been mouthing something to me across the street and I'd know what she was saying,'' said Mrs. Show, who
still lives in the condominium where her daughter was murdered, surrounded by Laurie's stuffed animals. ''And you have the
audacity to tell me that I don't know the last words that came out of my daughter's mouth?''
Photos: Ms. Lambert at the Shows' apartment in a visit during her trial in July 1992. Hazel Show in the bedroom of her slain
daughter, Laurie, in July 1993 in Lancaster, Pa. Lawrence (Butch) Yunkin, the boyfriend of Lisa Michelle Lambert.
(Photographs by Associated Press)(pg. A8); MAIN CHARACTERS -- The major figures in the Lambert case are Judge Stewart
Dalzell of Federal Court in Philadelphia; Laurie Show, center, killed in 1991 (Photographs by Associated Press), and Lisa
Michelle Lambert, whose conviction was nullified by Judge Dalzell. (Laura Pedrick for The New York Times)(pg. A1)
Copyright 2015 The New York Times Company
Home
Privacy Policy
Search
Corrections
XML
Help
Contact Us
Back to Top
7/24/2015 5:30 AM
CourtSunday
Rejects January
Lisa Michelle
Lambert's Appeal
22, 2017
http://65.54.175.250/cgi-bin/getmsg/CourtRejectsLisaMichelleLam...
Page 282 of
2301
Welcome to About.com
What is About.com?
I'm Charles Montaldo, your Guide to Crime / Punishment. If this MSN search
is not what you were looking for, you may want to see our other popular
topics, such as Current Cases, Historical Crimes, or Death Penalty.
Related Topics
Issues / Controver...
Juvenile Crime
Law Enforcement
Missing Kids/Adult...
FREE Crime / Punishment Newsletter Enter email address

Crime / Punishment
Court Rejects Lisa Michelle Lambert's Appeal

Crime/Punishment Blog
Join the Crime & Punishment Discussion | Main | Michael Jackson Taken to Hospital
June 03, 2005

The U.S. Supreme Court has rejected the appeal of Lisa Michelle Lambert, who was convicted in 1991 of the stabbing of
a teenage rival in a case that became a USA Network TV movie, "The Stalking of Laurie Show."
The high court refused to hear the case, thereby upholding an earlier appeals court ruling that said that "Lambert's trial
was fair, amply supported and not infected by material error or injustice."
The court ruling apparently ends a long legal battle by Lambert to reverse her conviction. She had previously been freed
from prison in 1997 when a federal district judge ruled that Lambert was "actually innocent" and called the prosecutor's
behavior during her trial "the worst case of prosecutorial misconduct in English-speaking experience."
An appeals court later overturned the judge's ruling and she was returned to prison. She is serving a life sentence in
Clinton, N.J. Also convicted in the case were Lambert's boyfriend, Lawrence Yunkin, and friend Tabitha F. Buck. Yunkin
pleaded guilty to third-degree murder and was released to a halfway house in January pending his release. Buck is
serving a life sentence.
See Also:
Court Rejects Appeal in Stabbing Case
Earlier Article:
Court Upholds Lisa Michelle Lambert's Conviction
Topic Index | Email to a Friend | Print this Page

Our Story | Be a Guide | Advertising Info | Work at About | Site Map | Icons | Help
User Agreement | Ethics Policy | Patent Info. | Privacy Policy | Kids' Privacy Policy
2006 About, Inc., A part of The New York Times Company. All rights reserved.
1 of 1
4/26/2006 7:50 PM
Page 283 of 2301
Plaintiffs Findings Of Facts
Page 1 of 76
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF

PENNSYLVANIA
STANLEY J. CATERBONE,
County of Lancaster, Pennsylvania
V.
COMMONWEALTH OF PENNSYLVANIA,
ATTORNEY GENERAL of PENNSYLVANIA
PENNSYLVANIA SECURITIES COMMISSION
PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY
DISTRICT ATTORNEY of LANCASTER COUNTY
COUNTY OF LANCASTER, PENNSYLVANIA
LANCASTER COUNTY PRISON
MANHIEM TOWNSHIP POLICE DEPARTMENT,
STEINMAN ENTERPRISES, INC., OF
STONE HARBOR POLICE DEPARTMENT,
COUNTY OF CAPE MAY , NEW JERSEY
AVALON POLICE DEPARTMENT,
COUNTY OF CAPE MAY, NEW JERSEY
COMMONWEALTH NATIONAL BANK
(i.e. MELLON BANK)
COUNTY OF DAUPHIN, PENNSYLVANIA
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
CIVIL ACTION
NO.
AFFIDAVIT OF STANLEY J. CATERBONE
STATE OF PENNSYLVANIA
COUNTY OF LANCASTER
: ss
I, Stanley J. Caterbone being duly sworn according to law, make the following affidavit concerning the
years during which I was maliciously and purposefully mentally abused, subjected to a massive array of
prosecutorial misconduct, while enduring an exhaustive fight for the sovereignty of my constitutional rights,
shareholder rights, civil liberties, and right of due access to the law. I will detail a deliberate attempt on my
life, in 1991, exhibiting the dire consequences of this complaint.. These allegations are substantiated
Page 284 of 2301
Page 2 of 76
through a preponderance of evidence including but not limited to over 10,000 documents, over 50 hours of
recorded conversations, transcripts, and archived on several digital mediums. A Findings of Facts is
attached herewith providing merits and the facts pertaining to this affidavit. These issues and incidents
identified herein have attempted to conceal my disclosures of International Signal & Control, Pls.,.
However, the merits of the violations contained in this affidavit will be proven incidental to the existence of
any conspiracy.
The plaintiff protests the courts for all remedial actions mandated by law. Financial considerations would
exceed $1 million.
These violations began on June 23, 1987 while I was a resident and business owner in Lancaster County,
Pennsylvania., and have continued to the present. These issues are a direct consequence of my public
disclosure of fraud within International Signal & Control, Plc., of County of Lancaster, Pennsylvania, which
were in compliance with federal and state statutes governing my shareholder rights granted in 1983, when
I purchased my interests in International Signal & Control., Plc.. I will also prove intentional undoinfluence
against family and friends towards compromising the credibility of myself, with malicious and self serving
accusations of insanity. I conclude that the courts must provide me with fair access to the law, and most
certainly, the process must void any technical deficiencies found in this filing as being material to the
conclusions. Such arrogance by the Courts would only challenge the judicial integrity of our Constitution.
1. The activities contained herein may raise the argument of fair disclosure regarding the scope of law
pertaining to issues and activities compromising the National Security of the United States. The Plaintiff
will successfully argue that due to the criminal record of International Signal & Control, including the
illegal transfer of arms and technologies to an end user Iraq, the laws of disclosure must be forfeited by
virtue that said activities posed a direct compromise to the National Security of the United States.; the
plaintiff will argue that his public allegations of misconduct within the operations of International Signal &
Control, Plc., as early as June of 1987 ; demonstrated actions were proven to protect the National
Security of the United States..
The activities of International Signal & Control, Pls., placed
American troops in harms way. The plaintiffs actions should have taken the American troops out of
harms way causing the activities of the International Signal & Control, Plc., to cease and desist. .
All activities contained herein have greatly compromised the National Security of the United States, and
the laws of jurist prudence must apply towards the Plaintiffs intent and motive of protecting the rights of
his fellow citizens. Had the plaintiff been protected under the law, and subsequently had the law
enforcement community of the Commonwealth of Pennsylvania, and the County of Lancaster administer
justice, United States troops may have been taken out of harms way, as a direct result of ceasing the
operations of International Signal & Control, Plc., in as early as 1987.
2. The plaintiff will successfully prove that the following activities and the prosecutorial misconduct were
directed at intimidating the plaintiff from continuing his public disclosures regarding illegal activities within
International Signal & Control, Plc,. On June 23, 1998, International Signal & Control, Plc was
negotiating for the $ billion merger with Ferranti International, of England. Such disclosures threatened
the integrity of International Signal & Controls organization, and Mr. James Guerin himself, ,
consequently resulting in adverse financial considerations to all parties if such disclosures provided any
Page 285 of 2301
Page 3 of 76
reason to question the integrity of the transaction, which later became the central criminal activity in the in
The United States District Court For The Eastern District Of Pennsylvania
3. The plaintiff will prove that undoinfluence was also responsible for the adverse consequences and
fabricated demise of his business enterprises and personal holdings. The dire consequences of the
plaintiffs failed business dealings, will demonstrate and substantiate financial incentive and motive.
Defendants responsible for administering undoinfluence and interference in the plaintiffs business and
commercial enterprises had financial interests. The Commonwealth of Pennsylvania as a taxing
authority, Lancaster County had a great investment whos demise would facilitate grave consequences
to its economic development. . Commonwealth National Bank (Mellon) would have less competition in
the mortgage banking business and other financial services, violating the lender liability laws. The
Steinman Enterprises, Inc., would loose a pioneer in the information technologies industries, and would
protect the public domain from truthful disclosure. The plaintiff will also provide significant evidence of
said perpetrators violating common laws governing intellectual property rights.
4. Given the plaintiffs continued and obstructed right to due process of the law, beginning in June of 1987
and continuing to the present, the plaintiff must be given fair access to the law with the opportunity for
any and all remedial actions required under the federal and state statutes. The plaintiff will successfully
argue his rights to the courts to rightfully claim civil actions with regards to the totality of these activities,
so described in the following Findings of Facts, regardless of any statute of limitations. Given the
plaintiffs genuine efforts for due process have been inherently and maliciously obstructed, the courts
must provide the opportunity for any and all remedial actions deserving to the plaintiff.
5. Under current laws, The plaintiffs intellectual capacity has been exploited as means of discrediting the
plaintiffs disclosures and obstructing the plaintiffs right to due process of the law. The plaintiff has
always had the proper rights under federal and state laws to enter into contract. The logic and reason
towards the plaintiffs activities and actions are a matter of record, demonstrated in the Findings of
Facts, contained herein..
The plaintiff will argue and successfully prove that the inherent emotional consequences to all of the
activities contained herein, have resulted in Post Traumatic Stress Syndrome. The evidence of the stress
subjected to the plaintiff, will prove to be the direct result of the activities contained herein, rather than
the exhibited behavior of any mental deficiency the plaintiff may or may not have. The courts must
provide for the proper interpretations of all laws, irrespective of the plaintiffs alleged intellectual
capacity. The plaintiff successfully argue that his mental capacity is of very little legal consequence, if
any; other than in its malicious representations used to diminish the credibility of the plaintiff.
6. The plaintiff will demonstrate that the following incidents of illegal prosecutions were purposefully
directed at intimidating the plaintiff from further public disclosure into the activities of International
Signal & Control, Plc., consequently obstructing the plaintiffs access to due process of the law. Due
to the fact that these activities to which the plaintiffs perpetrators were protecting were illegal activities,
the RICO statutes would apply.
To this day, the plaintiff has never been convicted of any crime with the exception of 2 speeding
Page 286 of 2301
Page 4 of 76
tickets. The following report identifies 34 instances of prosecutorial misconduct during the prosecutions
and activities beginning on June 23, 1987 and continuing to today.
7) Given the preponderance of evidence associated with this affidavit, the courts must conclude that In The
United States District Court For The Eastern District of Pennsylvania, Federal Judge Stuart Dalzalls
findings of April 14, 1997, in the Lisa Lambert case identifying acts of Prosecutorial Misconduct, now,
by virtue of this affidavit, now discloses evidence of a bona fide pattern of prosecutorial misconduct, in
the Commonwealth of Pennsylvania and in the County of Lancaster. Criminal law must now determine if
these disclosures would warrant investigations of a possible criminal enterprise. This affidavit is of
material interest to the Lambert case, for the very fact that this affidavit compromises the very same
integrity of the court, which would tip the scales of justice even further from the peoples deserving rights..
In the truthfulness of this affidavit, The Commonwealth must concede Lisa Michelle Lambert to balance
the scales of justice, which no other act could accomplish. The Commonwealth must yield the criminal
culpability of Lisa Michelle Lambert to the superior matter of restoring the integrity to the courts; by its
own admission of wrongdoing, assuring the peoples of its commitment to administer equalities of justice,
not inequalities of justice. Balancing the scales of justice. Anything less, would take the full scope of
jurisdiction out of the boundaries of our laws, negating our democracy and impugning the Constitution
of the United States.. The plaintiff must be restored to whole to so that justice may be restored to the
Commonwealth of Pennsylvania and to the County of Lancaster.
A. August 11, 1987 Stone Harbor (New Jersey) Police Department (2) - The plaintiff had been literally chased
by family members when the plaintiff wanted to obtain a restraining order to keep his family members from
obstructing his access to the law, and invading his home. The Stone Harbor Police Department detained the
plaintiff against his will, and later transported the plaintiff to Burdette Tomlin Hospital, giving no explanation
to the plaintiff. The Burdette Tomlin later disclosed that someone from Lancaster called the Stone Harbor
Police Department and stated that the plaintiff had a gun and was going to the beach to kill himself. This
whole incident was fabricated in efforts to illegally detain the plaintiff, and further facilitate the alibi of
insanity. The plaintiff was detained for 4 hours in the Hospital, and was not released until he signed a
suicide agreement. The hospital report casts any doubt into the plaintiffs truths, and goes to insinuate
that plaintiff activities of the digital movie, are illusions. The plaintiff later found the phone numbers of
the Pennsylvania, Maryland, Delaware, and New Jersey State Police Departments in his home in Conestoga,
PA. The handwriting of the individual, matches an official of the Lancaster County Solid Waste Department,
who at the time was negotiated a bond issue for the Lancaster County Incinerator with an attorney named
Stephen Spinello, of Lancaster, the same attorney responsible for negotiating the ISC and Ferranti merger at
the very same time.
B. August 14, 1987 Avalon (New Jersey) Police Department (5) - Family member again invade the privacy of
the plaintiff at his residence in Stone Harbor. The plaintiff flees the house, and this time drives to the
Avalon Police Department, one mile north of the Stone Harbor Police Department. An Avalon Patrol car pull
Page 287 of 2301
Page 5 of 76
the plaintiff over while en route. The plaintiff tries to explain the circumstances, and his desire for a
restraining order. The Avalon Policeman commands the plaintiff from his car, proceeds to frisk the plaintiff,
and searches his entire vehicle, again not providing any explanation. The policeman confiscates an old dry
empty bear can and a vile of muscle relaxes (plaintiff had a stiff back) from the car, and handcuff the plaintiff
and take him to the Avalon Police Department. The plaintiff, without the opportunity for any explanation is
charged with the following offenses :
A) SPEEDING (F-1) B) OPEN ALCOHOLIC CONTAINER IN
VEHICLE C) UNREGISTERED VEHICLE (NEW JERSEY DEALER MAILED REGISTRATION MATERIALS

TO CONESTOGA, PA ADDRESS BY MISTAKE D) FAILURE TO EXHIBIT DRIVERS LICENSE. The
Avalon Police Department impounded the plaintiffs vehicle.
All of the Police Officers were verbally
abusive, laughing at the plaintiff trying to defend himself, and trying to get a restraining order.
C. July 14th, 1987 Pennsylvania Attorney Generals Office (1) The plaintiff phone the Pennsylvania Attorney
Generals Office and talked to Attorney General Bodan, and reported the crimes and requested intervention,
of which the plaintiff was told that nothing he said fall within the jurisdiction of the Pennsylvania Attorney
Generals Office, obstructing justice, and potentially facilitating and protecting the criminal enterprises of
Mr. James Guerin.
D. September 3, 1987 Manhiem Township (Pennsylvania) Police Department (3) - The plaintiff arranged for
a charter flight with Romar Aviation, to a destination of the Lancaster County Airport, for a scheduled
meeting with 2 Board of Directors from Financial Management Group, Ltd., the following morning, September
4, 1987. As the plaintiff was in flight, the Manhiem Township Detective, Detective Sigler, filed a charge of
TERRORISTIC THREATS (M1) against the plaintiff. The warrant for arrest will disclose that the
Terroristic Threats actually were reported two days later, with no recollection of time except with the time of
9:00 am and 12:pm. There was also no disturbance reported, and no one from FMG, Ltd., had admitted calling
the Manhiem Township Police Department. This arrest warrant was totally fabricated. obstructing justice,
and potentially facilitating and protecting the criminal enterprises of Mr. James Guerin
E. September 3, 1987 Manhiem Township (Pennsylvania Police Department (6) - The plaintiff was arrested for
A)
BURGLARY (F-1)
B) CRIMINAL MISCHIEF (F-3) C) UNLAWFUL RESTRAINT (H-1) D)
UNLAWFUL USE OF COMPUTER (F-3) E) THEFT BY UNLAWFUL TAKING (F-3) F) ROBBERY (F-1).
The plaintiff, unknowing of the arrest warrant for Terroristic Threats filed early that day, visited his office at
Financial Management Group, Ltd., (FMG) later that same day to try to find any remaining business files that
were missing since his plane was repossessed. . Upon being let into the building by a cleaning girl, the
Plaintiff quickly asserted his rights to the property, which he was a rightful leaseholder and Officer of FMG,
and proceeded to gather documents. The plaintiff kissed the girl goodbye and ensured her safe return into
the building. obstructing justice, and potentially facilitating and protecting the criminal enterprises of Mr.
Page 288 of 2301
Page 6 of 76
James Guerin The plaintiff was illegally arrested for stealing his own files from his own building.
F. September 3, 1987, Manhiem Township Police Department (3): At the precise time that the plaintiff was
released into custody from the Conestoga Township Police, The Manhiem Township Police immediately used
unnecessary physical abuse upon the plaintiff by first placing shackles around the plaintiffs hands and legs
together, then smashing his head into the car door, and further forcing and wrestling the plaintiff, made every
attempt to cooperate, especially consider that the Conestoga Policeman allowed the plaintiff to sit in the front
seat, without handcuffs. The Manhiem Township Police refused the plaintiff request to know what he was
being arrested for. The Manhiem Township Policeman refused, and intentionally threw papers on the floor
of the cruiser in front of the plaintiff, laughing that he would be unable to pick it up or read it because of the
plaintiffs shackles. After arriving at the Police Station, Detective Larry Mathias refused to take a statement
from the plaintiff or tell the plaintiff why he was arrested.
After several hours, the plaintiff was again
thrown into the police cruiser, where the driver intentionally drove at high rates of speed, and curving to
cause the plaintiff to be thrown around the back of the cruiser, again unable to protect himself because of
the shackles. The victim was given no rights to provide testimony that would have immediately resulted in
his release. The plaintiff was never afforded the opportunity to contribute to the record of his any of his
prosecutions. The prosecutorial misconduct was again obstructing justice, and potentially facilitating and
protecting the criminal enterprises of Mr. James Guerin
A.
F) September 4, 1987, Lancaster County Prison (1): The plaintiff was refused to make a phone
call, and when he was given a phone privilege, the phone would not connect to an outside
line. The plaintiff was verbally abused and generally mistreated.
G) September 5, 1987, The Lancaster County District Attorneys Office (2): Attorney Robert Byers appeared
at the Lancaster County Prison to offer his services to the plaintiff, however the plaintiff never called or
mention to anyone Mr. Robert Byers. The plaintiff questioned his sudden interest in his affairs, and who had
called Mr. Byers.
H) September 9, 1987, The Lancaster County District Attorneys Office (2): The plaintiffs bail was granted on
the illegal condition that the plaintiff admit himself into the St. Joseph Psychiatric unit until released by the
Hospital. After 7 days, the plaintiff learned that this condition was not legal, and immediately discharged
himself. St. Joseph Hospital would not release the plaintiff until he accepted full liability for the $3,029.00
charge. St. Joseph Hospital refused to accept the plaintiffs insurance information, stating that it was no
longer in force, which the plaintiff disputed. Another demonstrated act of inflicting financial hardship and
mental duress by providing false claims to the plaintiff that his bail was falsely protected on his entering St.
Joseph Hospital.
Page 289 of 2301
Page 7 of 76
I) September and October 1987, The Lancaster County District Attorneys Office (1): The Lancaster
District Attorney refused any and all attempts by the Plaintiff to discuss the dire issues of his pending
charges.
The plaintiff was extensively shut out of the Lancaster Attorneys Office despite the
overwhelming abundance of evidence that the plaintiff could provide proving his innocence, and the
illegalities of the arrests. obstructing justice, and potentially facilitating and protecting
the criminal
enterprises of Mr. James Guerin
J) September 29, 1987, The Pennsylvania Securities Commission (3): See the following Findings of Facts,
page 43.
A.
J) November , 1987, The Pennsylvania Attorney Generals Office (1): See the following Findings of
Facts, 46.
B.
K) November , 1987, The Pennsylvania Securities Commission (1): See the following Findings of
Facts,. Tape.
L) March 24, 1988, The Lancaster County District Attorneys Office (1): See the following Findings of
Facts, page 48.
A.
M) May 27, 1991, Stone Harbor (New Jersey) Police Department See the following Findings of Facts,
page 63).
Stanley J. Caterbone, Plaintiff

Sworn to and subscribed
Before me this
of
day
, 1998
Notary Public
Notary Public of :
My commission expires:
Page 290 of 2301
Page 8 of 76
This page intentionally left blank.
Page 291 of 2301
Finding of Facts Resulting in Chapter 11 Bankruptcy
Page
THE YEAR
1983
September
1983 -
Pa. State Senator Gib Armstrong, former stock broker of Individual Securities of Lancaster, solicits Stan
Caterbone. to purchase the offering of (ISC) International Signal & Control, Plc, stock.. Stan Caterbone
purchases 1,000 shares of ISC stock.
Page 292 of 2301
Page
THE YEAR
1984
APRIL 1984
Stan Caterbone is elected Executive vice President of the newly formed Central Pennsylvania Chapter of the
International Association of Financial Planners (IAFP), the largest and mast prestigious professional organization of the
financial planning industry.
NOTES:
Stan Caterbone assists John Herr in increasing the regional membership by more than 300% in the first year, while also
attracting members from the other complimentary professions including: attorneys; stock brokers; accountants; estate
planners; insurance professionals; trust officers; and tax specialists.
OCTOBER 1984
Stan Caterbone invites nationally accredited, and Washington, D.C. based Financial Planner, Alexandria Armstrong for
a speaking engagement and meeting of the IAFP held at the Treadway Resort Inn, of Lancaster. Ms. Armstrong was
one of the most prominent advocates of Financial Planning, featured on the cover of "Money" magazine, and often
quoted in the "USA Today" financial section.
NOTES:
The meeting was a huge success, attracting over 90 professionals for the Central Pa region, and making it the largest
meeting ever held, even today (1991).
Page 293 of 2301
Page
THE YEAR
1985
Jan 9, 1985 -
Stan Caterbone terminates his affiliation with Investors Diversified Services (IDS), of Minneapolis, MN and forms his
own independent financial advisory firm, S.J. Caterbone Associates, of Lancaster, PA.
NOTES:
At the advice and recommendation of Alexandria Armstrong, Stan Caterbone visited Financial Services Corporation
(FSC), of Atlanta, Ga, and affiliates with the broker dealer the previous November.
Stan Caterbone transfers his registered representative's license several days after his brother's death. IDS executive Jack
Campana telephoned Stan Caterbone after learning of his plans, and tried to intimidate him by threatening legal action,
in the event he continued to service his existing clients.
Stan Caterbone also introduced Robert Kauffman to the Atlanta-based firm, while leading a large IDS division in
Atlanta, and making in excess of $250,000 annually. FSC will eventually recruit Robert Kauffman as an executive,
promoting him to national sales manager at large, charged with recruiting representatives and offices throughout the
country.
After his leaving (IDS), and upon educating many other financial planners of the merits of an Independent Broker
Dealer, the following former associates of IDS will leave and eventually become affiliated with his firm of FMG, Ltd.,
over the next 2 years: Robert Kauffman; P. Alan Loss; Daniel Moyer; Harry Radcliffe; Jim Werst; Michael Hartlett;
Daniel Moyer; Rich Podlasceck; Tom Turner; Rick Volpe; Gail Turner; as well as others.
March 30, 1985 -
Stan Caterbone conducts the Eastern Regional Free Agent Camp (ERFAC), in Lancaster Pa. The first ever-video-taped
professional football free agent camp attracted players (45) from as far away as Hawaii and California. The camp was
organized to give players access to the scouts of all three professional football leagues, National Football League (NFL),
United States Football League (USFL), and the Canadian Football League (CFL). The ERFAC was a pioneer because of
its strategy of having players attend one camp, and submitting a video tape of the camp to all of the teams in the leagues
, with no charge to the individual teams.
The Washington Post wrote a full page story in it's Sunday edition, and tried to accuse Stan Caterbone of profiting off of
the dreams of young athletes. Actually, that was precisely why Stan Caterbone organized the camp, after being wasting
time and money on conventional camps in trying to secure a professional football contract for his brother, Mike
Caterbone. Free agent camps are considered successful if only one player lands a contract, and even extraordinary if the
player lands a career.
In the following months, Stan Caterbone will negotiate a contract for Mike Caterbone; who will go on to load the
Canadian Football League in scoring, and be named Player of the week by Lite Beer, and featured during the traditional
Sunday afternoon broadcast. Mike Caterbone played for three seasons before joining the Miami Dolphins of the NFL.
The Eastern Regional Free Agent Camp full filled its primary mission, despite loosing some $3,000.
Stan Caterbone's career in the film industry has officially began as writer, producer, director, and technician.
April 20, 1985 -
June
1985
Stan Caterbone incorporates Pro Financial Group, Ltd., a company composed of accountant Robert Long, attorney
Timothy Lanza, accountant Michael Smoker, broker dealer FSC, and others to provide financial services to professional
athletes in an organized and coordinated effort. This was Stan Caterbone's attempt at a concept which will later form the
foundation for Financial Management Group, Ltd., or FMG, Ltd.
-
Stan Caterbone conducts a marketing and feasibility survey with Marketing consultant Jeffrey Johnston, for the concept
of the business which later will evolve into Financial Management Group, Ltd., The study
was conducted by
interviewing several area local physicians of substantial income and wealth for their input and feedback of having one
firm manage and administer all of their respective financial, legal, accounting and related affairs.
Page 294 of 2301
Page
THE YEAR
1986
March
1986
Stan Caterbone requests a meeting with John Depatto, President of Parent Federal Savings and Loan (owned and
operated by James Guerin's Parent Industries holding company), for a residential real estate loan for the property at 2323
New Danville Pike, Conestoga, Pa.
NOTES:
Stan Caterbone also discusses the formation of Financial Management Group, Ltd., and any possible joint venture
activities that may exist between the two financial services organizations, with specifics to mortgage banking
opportunities.
June 12, 1986
Stan Caterbone & Mike Caterbone (Joint Title) settle on the real estate deal, with a $100,000 loan from Parent Federal.
June 19, 1986
Stan Caterbone incorporates Financial Management Group, Ltd., (FMG, Ltd.,) and 12 other subsidiary corporations to
form a multi-faceted financial services [inn. The firm would offer: securities brokerage; portfolio in management;
financial planning; insurance & risk management; tax planning; accounting S tax preparation; estate planning; financial
advisory; legal services; real estate services; mortgage brokerage; venture capital.
June 22, 1986
Stan Caterbone submits the first draft of the Offering Memorandum to securities attorney Jeff Jamoneau of the law firm
McNeese, Wallace & Nurick, or Harrisburg in preparation for riling the necessary regulatory requirements to secure
financing for FMG, Ltd., under a Regulation D, Rule 144 Offering Memorandum. The offering allowed approximately
$500,000 to capitalize FMG, Ltd.,
NOTES:
The three principals decide on the following offices: Robert Kauffman is elected President of FMG, Ltd.,; Michael
Hartlett the Executive Vice President and Treasurer; Stan Caterbone the Executive Vice President, Secretary, and also
form the Board of Directors Stan Caterbone is also President and Treasurer of FMG Advisory, Inc., the firm to be incorporated as the Registered
Investment Advisor with the Pennsylvania Securities Commission, which Stan Caterbone will also administer and
manage.
Augusts 1, 1986 -
Financial Management Group, Ltd., (FMG) occupies and formally opens its headquarters containing 20,000 sq. ft. of
office space in the Eden Park complex owned by the Fisher/Sponougle Group of Lancaster.
August 14, 1986 -
Stan Caterbone; and Michael Hartlett; and Robert Kauffman; as individuals; and Financial Management Group, Ltd.,
sign a five (5) year individual lease with personal guarantees for the office space with Fisher/Sponougle Group, Ltd.,
August 21, 1986 -
FMG, Ltd., holds its first official and formal shareholders meeting.
October 6, 1986 Robert Kauffman signs a demand note and borrows $10,000 from FMG, Ltd., Scott Robertson signs a demand note and
borrows $20,000 from FMG, Ltd.,.
November 1986 -
In late 1986, Stan Caterbone sustained a take-over attempt by partners Robert Kauffman and Michael Hartlett, in order
to take full control of FMG, Ltd.,. Several employees were innocently fired in order to weaken Stan Caterbones control
and respect within the corporation.
NOTES:
While in Baltimore, visiting a satellite office, Robert Kauffman and Michael Hartlett terminated Mary Lynn Dipaolo, a
close personal friend and assistant, which caused a serious problem in the trust of the principals, not to mention
emotional duress.
Stan Caterbone would later visit his client, Dr. Al Schulz, because of his emotional duress and stress caused by the illicit
takeover attempts of Robert Kauffman and Michael Hartlett. Stan Caterbone will discuss the behavior of his partners as
causing severe stress.
Mike and Marylynn Dipaolo will personally hold Stan Caterbone responsible for the firing, and continue to subject him
to persecution for allegedly not standing up to Robert Kauffman and Michael Hartlett, despite his efforts for
reinstatement, and Stan Caterbone's advise to seek legal counsel concerning the wrongful termination. The Dipaolo's
refused to seek legal counsel.
Page 295 of 2301
Page
Several FMG, Ltd., executives, including Alan Loss, Scott Robertson, and Bob Long, engaged in private meetings
concerning the mistrust of both Robert Kauffman and Michael Hartlett. Stan Caterbone, was the most trusted and
respected principal of the firm, and was constantly caught in the middle of the principal/associate confrontations.
November 1986
Abe Diffenbach, the acting manager of Lancaster's Shearson/American Express stock brokerage office, contacts Stan
Caterbone and asks him to consider hiring Peter Peneros, a very large producer, who was apparently having difficulties
with the NASD.
Peter Peneros met with Stan Caterbone and discussed his problems, and it was revealed that other firms did not want to
get involved. Robert Kauffman consented and hired Peter Peneros, who later joined and became FMG, Ltd's., largest
personal producer.
Page 296 of 2301
Page
THE YEAR
1987
January 20, 1987 -
Al Dannatt & Institutional Investors, of Houston, requests Stan Caterbone to market and develop a portfolio of real
estate projects in the East for mortgages, with an extraordinary lending criteria of $3 to $100 million authority, with
attractive and competitive terms and rates from Institutional Investors' lending authority.
Al Dannatt also discloses to Stan Caterbone that he is in the process of acquiring a bank, which will also be available for
business with him.
NOTES:
Stan Caterbone decides to fight and not accept any offers from Kauffman to give up his equity in FMG, Ltd., and
aggressively pursues the other peripheral businesses he established in the original business plan, with emphasis on the
mortgage banking activities. Stan Caterbone also agrees to include Scott Robertson and Robert Long in the mortgage
banking activities.
Stan Caterbone agrees to provide FMG, Ltd., with the normal profit splits of peripheral business, but limits the
involvement in order to minimize risk against undoinfluence of Kauffman and Hartlett.
January 26, 1987 -
The FMG, Ltd., shareholders elect Alan Loss and Robert Long to the Board of Directors, increasing the original Board
of Caterbone, Hartlett, and Kauffman to five directors. Stan Caterbone had campaigned for both Alan Loss and Robert
Long, while Robert Kauffman and Michael Hartlett cast votes to others.
February 5, 1987 -
Carolyn Royer writes a formal notice and complaint to FMG, Ltd., president Robert Kauffman and Michael Hartlett
regarding her recent fulfillment of passing her NASD examine for a Registered Principal, which was agreed by both
Kauffman and Hartlett, to give her a salaried position of managing and administering the stock broker's activities for
FMG, Ltd., whom both would later deny.
NOTES:
This would later load to the resignation of Carolyn Royer, despite the efforts of Stan Caterbone to keep both Kauffman
and Hartlett to their word and previous agreements.
February 3, 1987 -
Stan Caterbone offers his mortgage banking loan portfolio to High Industries Inc, and High Associates at the request of
Robert Long, FMG, Ltd., in-house accountant, who also a former employee and accountant of High Industries Inc.,
February 4, 1987 -
Stan Caterbone receives a letter from Owen Kugel, principal of OK Properties, to secure financing for several historical
rehabilitation properties, and offering and finders fee of $433, 592 upon financing.
February 11, 1987 -
The FMG, Ltd., Board of Directors agree at the request and advise of Robert Kauffman to loan $10,000 to Gail Turner
(daughter of Tom Turner) of Minneapolis, Mn, to capitalize an FMG, Ltd., satellite office in Minneapolis.
February 19, 1987 -
Scott Robertson solicits Stan Caterbone to visit Power Station Studios and Tony Bongiovi, of New York, for assistance
in securing financing for a movie. Stan Caterbone cites concern for the risk associated with motion picture investments,
however later decides to at least visit the studio. Discussions were also held in securing financing for New York real
estate deals for the mortgage banking activities which had recently begun.
Robert Kauffman finalizes joint venture deal and agreement with Hilibbard Brown & Company, the Broker Dealer from
Washington, D.C., All FMG, Ltd., Registered Representative's licenses are terminated from Financial Services
Corporation (FSC) of Atlanta, GA, Kauffman's former employer.
March 10, 1987 -
Investors Diversified Services (IDS), formally terminates Tom Turner, the largest Divisional Manager in the country,
earning in excess of $700,000 per year, for his religious overtones in his office.
NOTES:
Tom Turner is a close personal friend of Robert Kauffman's, and he and his daughter become affiliated with FMG, Ltd.,.
FMG, Ltd., will later loan $10,000 to Gail Turner facilitated by Robert Kauffman.
Stan Caterbone becomes concerned because of the religious ties between Robert Kauffman, Tom Turner, and Barry
Schuttler, all FMG, Ltd., affiliates.
March 24, 1987 -
In the FMG, Ltd., Newsletter, Robert Kauffman officially announces that Tom Turner, of Minneapolis, Mn, has
officially joined FMG, Ltd., and will begin building offices in the same.
March 26, 1987 -
The FMG, Ltd., Board of Directors, at the request and advise of Robert Kauffman, vote to approve a loan of $25,000 to
Page 297 of 2301
Page
Hibbard Brown & Company, of Washington, D.C.,

In addition the Board votes to have Stan Caterbone pursue the legal issues of restructuring FMG, Ltd., in order to pursue
the national franchising of the organization, and to provide a means to transfer the equity of FMG, Ltd., to the same.
March 26, 1987 -
John Keeble, President of Financial Services Corporation (FSC), officially cite Robert Kauffman for breaching their
current employment contract by transferring the licenses to Hibbard Brown & company. FSC sends all licensed
representatives of FMG, Ltd., a letter stating their position and these allegations against Robert Kauffman.
NOTES:
Stan Caterbone becomes infuriated at the recent events due to the fact that he has insisted as far back as the Spring of
1986 that Robert Kauffman disclose to all of the principals of FSC that Stan Caterbone and FMG, Ltd., are planning to
eventually apply for their own Broker Dealer License, or acquire an interest in another through a joint venture, both of
which would mean the termination in the relationship and agreement with FSC.
It has become apparent that Kauffman was not only receiving compensation from FSC, and FMG, Ltd., but was actually
conducting business that was in a conflict of interest to either FSC, or FMG, Ltd., either of which would ultimately add
risk to the value of FMG, Ltd., stock, and increase the potential liability for litigation to FMG, Ltd.,
April 1987 - Stan Caterbone directs and coordinates a joint venture deal with the Life Underwriters Group, of Harrisburg and FMG, Ltd., for the
insurance business of FMG Insurance, Inc., which Stan Caterbone presides. The joint venture was also to evaluate and
analyze of FMG, Ltd., to enter into the reinsurance business, another strategy to acquire equity.
April 9, 1987 -
Robert Kauffman receives a formal complaint from the president of Conestoga Fuels, Bradley S. Singer, with regards to
the services of accountant Robert Long in the preparation of his 1986 taxes. Mr. Singer cites the negligence of Mr.
Robert Long in not delivering the services as promised, and not responding to his calls. Mr. Singer also alleges that
FMG, Ltd., is not delivering the services that it promotes, and states that FMG, Ltd., is not able to provide financial
advise on both a personal and corporate level.
April 14, 1987 -
The FMG, Ltd., Newsletter announces that Stan Caterbone is offering his mortgage banking services to all FMG, Ltd.,
affiliates, and that loans in excess of $2 million are available for real estate ventures. Stan Caterbone also announces the
plans to develop an FMG, Ltd., satellite office in the York, Pa, area, through a joint venture with the Bennet Williams
real estate firm. It is also announced that the new Rennet Williams office complex will be the first private real estate
syndication for FMG, Ltd.,
April 16, 1987 -
The FMG, Ltd., Board of Directors meeting is held at the law offices of McNesse, Wallace and Nurick, of Harrisburg,
with corporate attorney Jeffrey Jaouneau present. The Board discussed the relationships of Tom Turner and Barry
Schuttler with specific regards of how to transfer equity of FMG, Ltd., to their interests through a restructure.
The reorganization and restructure of FMG, Ltd., was also discussed with the considerations to vote on the preceding
matters and a 5:1 stock split within the next 30 days.
April 18, 1987 -
Stan Caterbone personally visits the headquarters of Hibbard Brown & company, outside Washington, D.C., en route to
a tour day vacation in Captiva Island, 71. Mike Dipaolo was also present.
Stan Caterbone wanted to discuss the present problems encountered with the securities trading of his brokers,
specifically Peter Poneros, was an exceptionally large volume producer. Stan Caterbone also wanted to perform some
sort of due diligence on the firm, which he had previously scorned both Robert Kauffman and Michael Bartlett for not
personally visiting the offices prior to reaching the decision to sign and consummate the joint venture agreement.
NOTES:
Stan Caterbone became infuriated at the response by Pete Hibbard and his subordinates after learning that they did not
know a problem existed, while persons at FMG, Ltd., were under the impression that the staff at Hibbard Brown & Co.
were acting to rectify and resolve the problems.
Stan Caterbone also become disappointed to find that the firm was nothing more than empty offices, with little if any
staff.
Stan Caterbone transcribes an extensive diary of events of the formation, development and progress of Financial
Management Group, Ltd., in response to the recent problems caused by President Robert Kauffman, and in preparation
for any potential legal litigation that may arise in the future.
NOTES:
Stan Caterbone wanted to insure against Robert Kauffman misrepresenting the facts, as he has demonstrated in the past.
Page 298 of 2301
Page
In addition, Stan Caterbone wanted to protect and preserve all of his interests, which were instrumental in the success of
FMG, Ltd.,
It was known that Kauffman and Hartlett very much resented the accomplishments and respect of Stan Caterbone within
FMG, Ltd.,, despite their lack of commitment in the early development of FMG, Ltd.,. Stan Caterbone assumed more
risk, and contributed more efforts than either of the other two principals in the beginning days of the company.
May 5, 1987 -
"Expanded" FMG, Ltd., Board of Directors Meeting is held that includes additional FMG, Ltd., satellite office
principals: Richard Volpe (Phil.); Barry Schuttler (Siver Springs, Md.); Jerry Bavero (Camp Hill); and Ken flay (ISIS).
Stan Caterbone presents cover story of "Business Week", regarding growth of convenience industry, which is why he
conceived the full service strategy for FMG, Ltd., Stan Caterbone also explains the procedures for his mortgage
banking services and its related issues. Stan Caterbone discusses the "Digital" Movie venture and its progress and
financial considerations - Stan Caterbone also describes in detail the Bennett Williams real estate syndication, and the
current plans for a satellite office in a joint venture with Bennett Williams. In addition, Stan Caterbone discloses his
design for and plans for development of a fully integrated computer system, which would include automatic tax
preparation, financial planning, and other related technologies, which are now 3 different bastardized systems.
Negotiations for an additional satellite office in the Harrisburg area are also disclosed, as well as the status and progress
of already existing offices in Lewisburg, Baltimore, Reading, Minneapolis, and Florida.
May II, 1987 -
Stan Caterbone loans $2, 000 to Scott Robertson, until settlement of pending deals, and also pays $750 to Marcia Silen
of Flatbush Films, in advance for work done for the "Digital" Movie.
May 11, 1987 -
Al Dannatt of Institutional Investors, of Houston, visits with Stan Caterbone to inspect the Olde Hickory properties in
order to secure a refinancing package of $6 million for Noris Boyd (FMG Ltd., shareholder). A proposed financing
package is later proposed and offered, and Noris Boyd discloses to Stan Caterbone that the terms and conditions are
more favorable than the existing and proposed terms of the Commonwealth National Bank, which is in jeopardy of
loosing the loan to Stan Caterbone and Institutional Investors.
The deal would have resulted in at least a $25,000 fee to Stan Caterbone.
NOTES:
Stan Caterbone also holds additional meetings with local and regional real estate developers concerning his loan
portfolio and financing abilities, including Drew Anton, owner of the Treadway Resort Inn, and Fisher/Sponougle
Group, Ltd.,. Al Dannatt will later travel to Florida in order to inspect a commercial shopping center owned by the
Fisher Sponougle Group, Ltd., that was looking to secure some $so million in financing.
Art Kerst, a computer consultant, will also solicit Stan Caterbone to become involved in the mortgage banking activities,
and despite Stan Caterbone's already existing dealings with the Fisher Sponougle Group, Ltd., Art Kerst will begin to
conduct meetings with Herb Fisher.
May 13, 1987 -
Stan Caterbone attends an all expense paid conference to Palm Springs, CA, by Philadelphia Life Insurance Co., for his
personal life insurance business of the previous year.
FMG, Ltd, Board of Directors meet to vote on Stan Caterbone's request and demand to ratify the recent joint venture
agreement/contract with Hibbard Brown & Company, after Stan Caterbone learned of dire inefficiencies within Hibbard
Brown & company, and the "Born Again" relationships of Kauffman, that placed an unprecedented amount of risk to
FMG, Ltd.,. Stan Caterbone voted by telephone from the Chicago Airport, in the midst of his travel to Palm Springs and
Hollywood California. The Board also voted to negotiate and approve a deal with the Planners Securities Group, of
Atlanta, GA.
NOTES:
Stan Caterbone had won the votes of Alan Loss and Robert Long, overturning the decision of Robert Kauffman and
Michael Bartlett and officially terminating the agreement.
This vote, in and above itself, took control of the Board of Directors from Kauffman and Bartlett, and put the power of
the Board in the direction of Stan Caterbone. This will eventually lead to the Coup conspired by Kauffman and Hartlett
to find a way to get Stan Caterbone out of the corporation.
May 14, 1987 -
Robert Kauffman sends a formal letter of apology to Pete Hibbard, president of Hibbard Brown & Company, of
Washington, D.C. for the recent action of the FMG, Ltd., Board of Directors to ratify the previously accepted joint
venture agreement.
Page 299 of 2301
Page
Robert Kauffman acknowledges his efforts in trying to convince the FMG, Ltd., board to continue with the agreement,
and also states his position that this action will be regretted by all in the future.
May 15, 1987 -
Stan Caterbone travels to Hollywood, CA, directly from Palm springs, to meet with Marcia Silen, of Flatbush Films, the
film producer of "Mutant Mania", the "Digital Movie". Stan Caterbone discloses his outline and strategies for the SONY
proposal which Marcia Silen calls "genius and brilliant". Additional strategies are discussed for the project.
An additional meeting with Becky Austin, a known real estate professional in the Hollywood area, is held. Stan
Caterbone discusses a possible joint venture to develop a Hollywood office for the mortgage banking activities, and
Becky Austin indicates her interest to pursue the venture. Additional plans are made to meet with Al Dannatt of
Institutional Investors in Houston, Texas at a later date.
Stan Caterbone also contacts Ted Gamillion, owner and operator of Gamillion Studios (a successful "mini-major" film
studio), of Hollywood Studios, who has solicited his services through Becky Austin and Marcia Silen, for the
refinancing and a restructuring of his studios. Plans are made for a future visits to the Studios at a later time, due to
scheduling problems at that time.
May 16, 1987 -
Stan Caterbone directs his administrative assistant, Lynn Kreider, to confidentially transcribe his diary of May 2, 1987
into the word processor for future reference, without the knowledge of any persons.
May 18, 1987 -
Stan Caterbone completes the first draft of the SONY proposal and the "Digital Movie" in order to secure the financing
of the project.
FMG, Ltd., sponsors and conducts a seminar titled "Medical Malpractice Risks" at the St. Joseph Hospital for all
attending Physicians and hospital staff. Scott Robertson bad requested Stan Caterbone to coordinate the efforts because
of his relationship with Hospital Administrators, and his many clients that included many Hospital physicians. Stan
Caterbone bad also worked with the Hospital's Human Resource Department on other similar projects.
The seminar included an attorney from the local law firm of Barley, Snyder, & Cooper, that presented information
regarding legal and financial exposure in the event of medical malpractice suits, and an executive from Crown Life
Insurance describing new products that help alleviate some financial exposure. Robert Kauffman, presented information
about FMG, Ltd., its progress, and services, and Alan Loss acted as moderator.
NOTES:
In addition, Stan Caterbone directed the professional filming of the seminar, and also a marketing video, which
included demonstrations and talks by the head of various departments within FMG, Ltd., as well as demonstrations of
various computer technologies utilized and designed by FMG, Ltd. Stan Caterbone had intended to edit the video, and
use it for marketing and recruiting in the franchising of the company.
The seminar attracted approximately 50 persons, including Dr. William Umiker (FMG, Ltd., shareholder) and Dr. Albert
Schulz Psychiatrist), both Stan Caterbone's clients. The seminar was considered a success.
May 18, 1987 -
Robert Kauffman signs and notarizes the agreement for the stock option agreement and joint venture with the Planners
Securities Group, of Atlanta, Ga; as Robert Long again signed as the FMC, Ltd., Board of Directors, rather than Stan
Caterbone, Secretary of FMG, Ltd., as common practice, policy, and law.
NOTES:
Again, Stan Caterbone would not approve this contract, on the basis of a clause, conveniently included, that would have
provided that the 10 % stock option was only vested under the conditions that Robert Kauffman remain as president of
FMG, Ltd., Upon the termination, resignation, or any other departure, FMG, Ltd., would loose all interests in the
accumulated stock options earned over the next seven (7) years. Stan Caterbone would not approve such a contract
because of the conflict of interests with respect to the above clause, which yielded Robert Kauffman the power to hold
his position of Presidency, as a financial hostage, if his performance was not within the expectations of all shareholders,
or if he engaged in activities of misconduct or wrongdoing. The only way the stock option agreement was fully vested
upon the departure of Robert Kauffman before the seven year schedule, was if convicted of a felony, which yields the
potential for many abuses and conflicts of interests on his part that would still subject the FMG, Ltd., shareholders to the
loss of the stock options upon his departure.
May 20, 1987 - Attorney Ric Fox submits the legal "Letter of Intent for Joint Venture Participation and Contribution" for Power Productions I to Stan
Caterbone for securing investments and financing of "Mutant Mania", the "Digital" Movie. Stan Caterbone was the
General and Managing Partner responsible for managing the investment fund. The invoice was paid by FMG Advisory,
Page 300 of 2301
Page
10
Inc., in which Stan Caterbone was President and managed the daily operations.
NOTES:
Stan Caterbone had previously held a meeting with Noris Boyd and Robert Long, at FMG, Ltd., whereby Noris Boyd
had verbally committed to investing approximately $250,000 into the venture.
May 21, 1987 -
Again Robert Kauffman has Robert Long sign for his Employment Agreement with FMG,
Ltd. ,as representing
the Board of Directors, which should have been signed by the
Secretary of FMG, Ltd., Stan Caterbone.
NOTES:
Stan Caterbone also disputed this contract as proposed by Robert Kauffman, mainly due to the increased financial
incentives and salary increases to Robert Kauffman.
Stan Caterbone especially disputed a 3% profit incentive on all FMG, Ltd., businesses paid as a bonus to Robert
Kauffman. Stan Caterbone objected to Robert Kauffman being paid bonuses on businesses that Stan Caterbone had
personally developed, managed, and was responsible for managing the daily operations, including: the mortgage banking
activities; FMG Accounting; the insurance business; and FMG Advisory, which Stan Caterbone was elected and
remained President.
Stan Caterbone also disputed the increase in monthly salary of $5,000 to $7,000, as instituted by Robert Kauffman,
himself.
May 26, 1987 -
In the FMG, Ltd., Newsletter, Michael Hartlett officially announces the appointment of Jon Gruber and Craig Russell,
principals in the law firm of Russell, Kraft, Gruber and Huber to join FMG, Ltd., and occupy an office in the FMG, Ltd.,
headquarters.
NOTES:
The above announcement was done without prior notice or consent of Stan Caterbone, which was against present
company policy regarding important and sensitive matters of that nature. The same said law firm would later represent
FMG, Ltd., and take all legal action against Stan Caterbone in the following months.
May 27, 1987 -
Arlene Davidson, of Flatbush Films, finalizes and completes the first draft of the working budget 0 the "Digital" Movie
and mails it to Stan Caterbone in preparation for the meeting in Stone Harbor in the upcoming weeks.
May 29, 1987 -
Associate Producer Arlene Davidson encloses the first draft of the screenplay to Stan Caterbone in Stone Harbor, NJ.
Barry Schuttler's office manager, Audrey, discloses during a meeting with Stan Caterbone to educate her on how to
recruit and build the satellite office, that Fete Hibbard, president of Hibbard Brown & Company, is also (Kauffman,
Turner, Schuttler) ,a "Born Again" Christian, and that he is trying to convert her.
Mike Dipaolo submits a proposal to Stan Caterbone to join the FMG Accounting group with Robert Long.
June 6, 1987 -
Flatbush Film producers: Marcia Silen; Arlene Davidson; and Director Barbara Peters travel from Hollywood, CA, to
visit with Tony Bongiovi and other producers at Stan Caterbone's residence in Stone Harbor, NJ, for their first
production meeting. Flatbush Film personnel spent several days in New York at Power Station Studios, before traveling
to the New Jersey Shore, the location for the filming of the movie.
June 8, 1987 -
Stan Caterbone sells 1,000 shares of ISC stock.
June 9, 1987 -
Stan Caterbone submits an application for a loan in the financing of the aircraft to John Wolfe, Executive Vice President
of Commonwealth National Bank, and delivers it to him at Lancaster Aviation.
Stan Caterbone also submits a request for a $100,000 line of credit with the Farmers First Rank, where all FMG, Ltd.,
accounts are held. Stan Caterbone offers his FMG, Ltd., holding as collateral.
NOTES:
Stan Caterbone requested the financial records and statements from Michael Bartlett, the FMG, Ltd., Treasurer, who was
responsible for the accounting. However despite the legal entitlement, Michael Bartlett and Robert Kauffman refused to
allow access of all financial records to Stan Caterbone.
Ironically, even though Stan Caterbone's past efforts were known to be responsible for the success and the formation of
the organization, Stan Caterbone will never have or had, the privilege to review any financial records of the firm, even
as of the date of this report (1991).
June 10, 1987 -
Stan Caterbone prepares a financial capsule of Financial Management Group, Ltd., bases on his original projects
contained in his business plan of one year earlier.
Page 301 of 2301
Page
11
After gathering the analytical in formation based on capital raised, and production figures, Stan Caterbone reported that
FMG, Ltd., was at least two (2) years ahead of its original projections in almost every category, even though FMG, Ltd.,
was a month away from its 1st Birthday.
The following is a synopsis of that report which illustrates the highlights:
Capital Raised:
Professionals:
Staff:
Satellite Offices:
Stock Value:
$80 million
60
13
12
$13-$17 per share
(before the 5:1 stock split and not including the 10% interest in the Planners Securities Group, stock, recently acquired)
June 12, 1987 -
Lancaster Aviation arrange for the selected aircraft to be flown in from the Midwest to be inspected by Stan Caterbone.
Pete Wolfson of Lancaster Aviation conducts the meeting, as an official agent of Lancaster Aviation.
Commonwealth Bank has approved the financing of $97,000 for the purchase. The additional $25,000 required is not
yet available. Pete Wolfson insists that the plane must be purchased before being flown back to the Midwest. Pete
Wolfson requests a post-dated check from Stan Caterbone for the remaining balance. Stan Caterbone refuses, citing that
the remaining funds must be liquidated from the Keystone Mutual Fund, and the exact receipt of the moneys is not
guaranteed, and could take up to 10 days.
Pete Wclfson agrees not to deposit the check until Stan Caterbone confirms that the funds have been received and
deposited in order to cover the check for the remaining $25,000. Stan Caterbone makes sure that Pete Wolfson has the
authority to make the arrangement, and Pete Wolfson agrees. The purchase of the airplane was also subject to a prepurchase inspection by Lancaster Aviation. Lancaster Aviation also advises Stan Caterbone to have his airplane
included in their Fleet Insurance plan. Stan Caterbone also advises Lancaster Aviation that he would like to offer the
airplane to his business associates for use in order to subsidize the costs and maintenance.
The papers are signed and the settlement is made during the initial inspection.
June 15, 1987 -
Stan Caterbone receives the production schedule and itinerary for the "Digital" (Mutant Mania) Movie from Arlene
Davidson, Associate Producer (Flatbush Films), of Hollywood, CA.
NOTES:
Flatbush Films has begun to direct all communications and efforts to Stan Caterbone directly, and have begun to look to
him for direction, after lack of communication and several misunderstandings in dealing directly with Tony Bongiovi
and others at Power Station Studios.
Stan Caterbone suddenly finds himself in the middle of resentment by Scott Robertson and others because of the respect
from the Hollywood people concerning the directing of the movie.
June 17, 1987 -
Stan Caterbone receives materials from New York bases Real Estate developer, Susan Weinstein, for considerations in
securing financing for development of the fastest growing section of New Jersey, the "1-78 Corridor". This section of
New Jersey was attracting many professionals who worked in New York city, mainly due to it's 35 minute commute, and
it's rural setting.
June 18, 1987-
Stan Caterbone and Randy Grespin, corporate attorney for The Life Underwriters Group (TUG), fly to Atlanta, Ga, to
visit with executives of Planners Securities Group (PSG), a nationally known Broker Dealer. Stan Caterbone had
initially consulted with both Kauffman and Bartlett concerning the trip, however when both disagreed, Stan Caterbone
questioned why he was the only principal to personally visit the operations of Hibbard Brown & Company, which lead
to his decision to terminate the ill fated merger.
NOTES:
The company in Atlanta, was the regarded as the most successful Broker Dealers in the financial planning community,
and included several former presidents of the national board of the International Association of Financial Planners. The
company had previously been recruiting FMG, Ltd., and offering an attractive equity interest. Randy Grespin agreed to
reimburse $600 to Stan Caterbone for the expense and use of his aircraft.
NOTES:
Stan Caterbone had the following agenda for the trip and meeting:
Page 302 of 2301
1.
Page
12
Visit and discuss a possible joint venture and merger with FMG, Ltd., and evaluate the various departments
necessary to administer FMG, Ltd's., stock transactions and
private real estate offerings.
2. Discuss and evaluate the opportunities of utilizing insurance products from Randy Grespin's firm, and all matters
related to the structuring of business.
3.
Familiarize Greg Dune, a personal friend and recruitment of Stan Caterbones who was also visiting from Florida to
consider opening a Florida office for FMG, Ltd.,
4. Conduct an extensive and thorough due diligence investigation of the stability, efficiency, and security of the
operations, in order to prevent a similar situation that facilitated the previous termination of the recent Hibbard
Brown & Company deal. Stan Caterbone left the meetings with very optimistic and impressive findings, that only
left more questions as to the decision of Kauffman and Bartlett to affiliate with Hibbard Brown & Company,
knowing that the Atlanta group had been aggressively pursuing talks of a merger since the inception of FMG, Ltd.,
On the return flight home, Stan Caterbone confided to Randy Grespin, requesting legal advise, regarding the recent
problems and his allegations of misconduct by FMG, Ltd., President Robert Kauffman. Randy Grespin advised
Stan Caterbone to take some time and seek legal counsel.
Upon entering the offices of FMG, Ltd., after arriving in Lancaster, Robert Kauffman pulls Stan Caterbone into his
office and abruptly shouts "Who is running this corporation, me or you?". Stan Caterbone quickly answers "I don't give
a damn who runs this company. as long as it's run right, and for the right reasons!" Stan Caterbone immediately left the
office.
Later that evening, Robert Kauffman appears at the residence of Stan Caterbone, for the first time, unannounced and
completely out of character of Robert Kauffman.
Robert Kauffman and Stan Caterbone have a dispute over the renewal of their respective new contracts. Stan Caterbone
refuses to approve Robert auffman's new contract due to clauses that provide him with profits on businesses that tan
Caterbone has developed and will manage. Robert Kauffman also refuses to give Stan Caterbone an additional increase
of his salary of $3,000 per month, while wanting to increase his salary from $5,000 to $7,000 per month. Both salaries
did not include commissions from their respective clients.
June 22, 1987 -
Stan Caterbone hires Todd Deliinqer, a planner in FMG, Ltd., to help administrate the daily activities of his personal
clientele and to perform administrative duties
necessary due to the amount of time Stan Caterbone is conducting
business out at the office, allowing Stan Caterbone to focus attention on the Strategic Planning, and allowing him to
better manage his time.
Stan Caterbone sends a memo to client and shareholder Dr. William Umiker that introduces his new assistant, in
addition to information regarding his pension accounts.
June
1987 -
June 23, 1987 -
June 23, 1987

10:00 am
Guerins brother-in-law, Carl I. Jacobson, is targeted by a federal task force and grand jury investigating massive
Department of Defense contract fraud and corruption within United Chem Con and the York-based Wedteck
Corporation.
Carl Jacobean flees the U.S. in the early morning for Santiago, Chile, in what will ultimately be a failed attempt
to avoid a federal subpoena similar to those served to other United Chem Con associates. Romar Aviation
provided the flight.
Larry Resch visits Stan Caterbone at FMG, Ltd., headquarters in Lancaster, as scheduled. Larry Resch explains that "we
had to fly Carl Jacobson out of the country early this morning" as the reason for his not being able to attend the meeting
as planned.
Larry Resch discusses possible strategies to rescue Chem Cons Minority 8A Setaside contracts, and solicits financing
for new facility.
Stan Caterbone becomes annoyed the context of the conversation, especially the lack Of disclosure, and discusses
allegations of wrongdoing by Guerin and ISC, and the relationship to Chem Con. After evaluating the financial
statements, Stan Caterbone also suggests there is approximately $15 to $18 million in missing funds.
Page 303 of 2301
Page
13
2:00 pm
Stan Caterbone has his locks changed to his office by Russel Locksmith of Lititz, in order to secure confidential personal
and business tiles in light of the current internal power struggle between himself, Michael Hartlett and Robert Kauffman,
and given the conversation with Mr. Larry Resch a few hours earlier.
June 25, 1987 -
Robert Kaufman, President of FMG, Ltd., and other FMG, Ltd., executives burglarize Stan Caterbone's office removing
confidential personal and business tiles. Some of the mortgage banking and other business files have yet to be found.
Kauffman and Robert Long illegally issue FMG, Ltd., stock certificates to Peter Peneros and Scott Robertson. Robert
Long signs the stock certificates as Secretary of FMG, Ltd., when Stan Caterbone was acting Secretary, and was the only
person duly authorized to issue FMG, Ltd., stock certificates.
NOTES:
Stan Caterbone learned of the burglary by Robert Kauffman in a telephone conversation while at Stone Harbor, NJ;
Kauffman inadvertently mentioned that the stock certificates were issued, however, with all documents at risk of being
stolen, Stan Caterbone did not mention the incident, in hopes to first recover any potentially stolen business and
personal files.
June 27, 1987 -
Jim Bly of Virginia based Source Capital, is scheduled to use the aircraft of Stan Caterbone, for approximately 6 hours
of flight time at $300.00 per hour. However, Jim Bly is denied the flight by Lancaster Aviation, who repossess the
aircraft and refuses to allow the plane to leave the ground, without any knowledge by Stan Caterbone.
NOTES:
Chuck Smith, president of Lancaster Aviation, later discloses to Stan Caterbone that he had deposited Stan Caterbones
pre dated check for $25.000, without the confirmation by Stan Caterbone that the funds had been transferred from
accounts. Stan Caterbone had argued with Pete Wolfson, salesman, that he did not want to give them a post dated
check, however Chuck Wolfson insisted. Now, Chuck Smith had told Stan Caterbone that Pete Wolfson did not have
the authority to complete the transaction. However Stan Caterbone reminded Chuch Smith that he was acting as an
agent for Lancaster Aviation, and that was not material to this dispute.
June 29, 1987 -
Stan Caterbone receives patent research materials from patent attorney Joel S. Goldhammer, of the prominent
Philadelphia law firm Siedel, Gonda, Goldhammer & Abbot regarding the "Digital" Movie, and the national franchising
of Financial Management Group, Ltd.,. Stan Caterbone had retained the services of Siedel, Gonda, Goldhammer Abbot
in order to investigate all relevant matters concerning the technology, merchandising, and marketing of the "Mutant
Mania" project, and the use of the "Power Station" label. Research was required for the merchandising of consumer
electronics, professional audio/visual digital mixing consoles, and the "Power Station Digital Movie System
(PSDMS), as created by Stan Caterbone in the proposal for SONY Corporation of Japan.
In addition, Stan Caterbone had retained the law firm to research the private label of "Financial Management Group,
Ltd., in preparation of reorganizing and marketing the organization in the national marketplace. Stan Caterbone had
requested the patent research while President of FMG Advisory, Inc., and authorized payment from the companies
account, which Stan Caterbone had exclusive authority.
June 30, 1987 - Stan Caterbone visits with Dave Schaad, President of the York based real estate firm of Bennett Williams, Inc., Stan Caterbone was
finalizing plans to secure financing of a $2.5 million office complex for the new headquarters of Bennett Williams, as
well as 3 or 4 additional anchor tenants. Stan Caterbone had been working with Dave Schaad for the past 3 months,
along with Scott Robertson.
NOTES:
Stan Caterbone had previously discussed the deal with Dave Cook, and executive and former owner of the Turkey Hill
Convenience Stores. Dave Cook indicated a serious interest in providing the entire $2.5 million investment. The above
deal would have provided over $150,000 of fees upon settlement to Stan Caterbone upon settlement.
Prior to the meeting, Dave Schaad had indicated by telephone, that Robert Kauffman had invited himself to the meeting,
without prior consent or notice to Stan Caterbone, During the meeting, Stan Caterbone disclosed the current political
problems within the principals of FMG, Ltd., being facilitated by Robert Kauffman himself.
July 1, 1987 -
Stan Caterbone, assisted by James Warner, remove all personal and business files from the premises of FMG, Ltd., after
Stan Caterbone had learned of the burglary.
NOTES:
In an effort to conceal the incident to FMG, Ltd., personnel and shareholders to avoid a devastating and potential crisis,
the above attempt to restore the files was done at approximately 1:00 am. while the office was vacated. Stan Caterbone
had found several confidential business files (mortgage banking) in the offices of Robert Kauffman and Robert Long,
that were the exclusive property of Stan Caterbone. In an effort to document the theft, Stan Caterbone took photographs
of the files in the offices of the two executives, before he removed them.
Page 304 of 2301
Page
14
Stan Caterbone had prepared to take the files to the attorney office of Joe Roda on the following morning.
July 1, 1987 -
Stan Caterbone phones Joe Roda from the home of Mary Lynn Dipaolo to arrange for a meeting to discuss the recent
events and Coup attempt by Kauffman and Hartlett that
included several criminal and security violations.
Stan Caterbone visits with Joe Roda and describes the incidents in detail, including the "Digital Movie", ISC, and all
related activities. Joe Roda instructs Stan Caterbone to have all of the files copied and arranges for the return of all
FMG, Ltd., corporate files.
Stan Caterbone had questioned Joe Roda for a legal opinion as to his right of any moneys in FMG, Ltd., checking
accounts that he was authorized to sign for. Joe Roda advised that Stan Caterbone had no right to any funds. All checks
were returned to FMG, Ltd., along with all other documents.
Stan Caterbone advises Joe Roda that he is in fear that someone is deliberately orchestrating all of the recent incidents,
which were quite extraordinary and extremely criminal and have been coming from all directions. Stan Caterbone
advised Joe Roda that he would like to take all of his files to Stone Harbor, NJ for safekeeping while he pursued his
legal recourse. Stan Caterbone also explained that he would feel safer leaving Lancaster until these circumstances were
brought under control.
July 2, 1987
In an effort to continue all efforts and business activities, Stan Caterbone visits the Office Works, owned and operated
by High Industries, to purchase a printer while staying in Stone Harbor. FMG, Ltd., had an open account, which Stan
Caterbone authorized, as an officer of FMG, Ltd.,. The Office Works demands cash payment and refuses to put the
purchase on credit.
Stan Caterbone negotiates with Romar Aviation to provide pilot; storage; and insurance with his aircraft after many very
questionable occurrences at Lancaster Aviation, just a few hundred feet away. Stan Caterbone secures insurance and
pays $1,000 to Romar Aviation for the flight to Stone Harbor, which was conducted by Victor M. of Romar Aviation. In
addition, at the referral of Victor, Stan Caterbone calls Sam Goode, of Sam Goode Assoc., to bind insurance for the
aircraft. Sam Goode Binds the insurance and instruct Stan Caterbone to mail a payment of $750. The conversation took
place in Romar Aviation, at the time the $1,000 was paid to Victor. Stan Caterbone loads his aircraft with all of his
personal and business files to be transported to the Cape May County Airport, just a few miles outside of Stone Harbor,
in the morning of July 4.
NOTES:
Stan Caterbone was not aware of the relationship of Romar Aviation with Guerin and ISC, especially the previous flight
or Carl Jacobson to Chile by Romar Aviation just a few days before, the same day of his meeting with Larry Resch of
ISC.
July 4, 1987 - At approximately 12:00 am, Victor calls Stan Caterbone to notify him that his aircraft was reposed some hour earlier, and locked in
the hanger of Lancaster Aviation, with all of his personal and business files on board.
Victor only would say that Commonwealth Bank had taken part in the repossession, with no reasons given. The first
payment of the loan agreement with Commonwealth National Bank was not due until July 25, 1987. There was no
money due to Commonwealth National Bank.
Stan Caterbone also becomes quite suspicious, after learning a few weeks earlier that his efforts to provide a refinance of
some $6 million to Boyd Wilson Properties, was more favorable than the existing or proposed financing arrangements
now place with Commonwealth National Bank, which not only has a lender relationship with Stan Caterbone, but is also
a competitor for his mortgage banking activities.
It was also known that Stan Caterbone's lending authority was larger and more competitive than most of the local
banking community.
NOTES:
Stan Caterbone now becomes in fear for his life due to this incident, and all other unexplained incidents in the
preceding days and weeks.
July 4, 1987 -
At approximately 9:00 am in the morning, Stan Caterbone calls his attorney Joe Roda, under emotional duress from the
previous conversation with Victor and the repossession of his aircraft with all documents on board; Joe Roda responds
"Stan, you have to quit fabricating these allegations, it is July 4th, what do you want me to do. This conversation
reaffirms a conspiracy theory within Lancaster to ruin him, and supports his efforts to leave Lancaster with his files to
solicit aid and support from legal and law enforcement authorities to suppress the conspiracy.
Page 305 of 2301
NOTES:
Page
15
Stan Caterbone realizes that the documents were authentic proof and evidence of all of his allegations, and most
importantly all of his business activities for the past 5 or more years. The loss of the files would have devastating
consequences for his life.
At approximately 9:30 am, after the disturbing phone, Stan Caterbone drives to the Cape May County Airport to solicit
the services of a pilot to fly to Lancaster to retrieve his files. Brad Donahue accepts the job, and agrees to a $200 tee,
and an additional $200 it there are any difficulties in obtaining the files.
Stan Caterbone provides Brad Donahue with all documentation showing legal title to the aircraft in the event authorities
are notified. Stan Caterbone gives explicit instructions to notify the police in the event personnel will not return all of
the files.
Brad Donahue arrives a few hours later, with boxes of files. Brad Donahue briefly describes an encounter at Lancaster
Aviation, and demands payment of $400 as agreed. An invoice is signed by all parties as proof of payment and the
activity, and $400 in cash is paid to Brad Donahue. Pilot Dave Austin, of the Cape May County Airport witnesses the
transactions and the event.
NOTES:
In the following weeks, Dave Austin, would later disclose to Stan Caterbone that Brad Donahue was killed in a
mysterious "Air-Accident", while over water, with an unexplained and questionable flight chart.
July 5, 1987 - Stan Caterbone solicits the legal services of Ric Fox, a Harrisburg attorney that has prepared legal documents for the "Digital" Movie.
Rio Fox flies his aircraft to the Cape May County Airport, and arrives at Stan Caterbone's house accompanied with
another attorney Robert Chercicoff.
NOTES:
All of the recent activities were detailed and described concerning FMG, Ltd.,; the "Digital Movie"; and the illegal
repossession of the aircraft. Stan Caterbone questioned Mr. Fox and his associate of any relationship with
Commonwealth Bank, which headquarters were also in Harrisburg, and both gave a very ambiguous answer.
The meeting ended with both attorneys failing to recognize or admit to any wrongdoing by any and all related parties,
and further demanding a $2,000 retainer fee to look further into the matters.
Stan Caterbone suspects the conspiracy theory again, especially in light of the acknowledged relationship with
Commonwealth Bank, and an indirect relationship with Robert Kauffman, through Life Underwriters of Harrisburg, a
joint venture arranged by Stan Caterbone some months earlier.
By July 5, Stan Caterbone had already made two legitimate attempts to solicit legal aid for the unexplained events and
circumstances, both of which were maliciously sabotaged.
July 6, 1987 -
In an effort to document the conspiracy theory, Stan Caterbone requests Tom Caterbone to call Robert Kauffman to
inquire about the status of his affairs, and to tape the conversation. Tom Caterbone identifies himself as John Green, a
client of Stan Caterbone's and Robert Kauffman states the following:
"Stan Caterbone has moved his office to Stone Harbor, NJ.. he is not taking care of business, and I need to see to it that
his clients are taken care of for the time being.. he has been spending a lot of money, an airplane, a place at the shore,
and he seems to think that he is too important for his traditional clientele.. There is some history of mental disorders in
his family history.. I can't come right out and say that that is what's going on, .. I wish Stan would get some professional
help.. However for the time being, Stan is not taking care of business, and I need to be concerned for his clients.
July 6, 1987 -
Stan Caterbone telephones Dr. Al Schulz, psychiatrist at St. Joseph Hospital, and client of Stan Caterbone's in order to
thwart the allegations of insanity. Dr. Al Shulz had disclosed that several persons, including Mary Lynn Dipaolo and
Jere Sullivan had called him concerning Stan Caterbone's behavior and activities.
From the allegations, Dr. Shulz advised that Stan Caterbone was suffering from illusions of grandeur, and prescribed
Lithium treatment, and to return to Lancaster for consultation.
Stan Caterbone insisted that the allegations were purely fabricated, and that no one had any legal right to interfere with
his business and or legal affairs, let alone his confidential medical records.
July 6, 1987
Stan Caterbone contacts David Drubner, of Boston, Ma, a friend of Stan Caterbone's brothers Mike, and an attorney.
During the conversation, David Drutner questions Stan Caterbone about "taking some medication", and supports the
Page 306 of 2301
Page
16
allegations of insanity.
July 6, 1987
In the following days, Stan Caterbone had made numerous telephone calls to local, state, and federal authorities, for
intervention and help regarding all of the preceding events and circumstances. The following is a brief description of
each:
Manhiem Township Police Department, responded "what bank branch repossessed your aircraft"; Pennsylvania State
Senator Gib Armstrong, responded, "I will call the Pa Attorney General's Office and have them call you; the Federal
Bureau of Investigation (FBI), the Philadelphia-based field office; U.S. Representative Robert Walker (R-Pa), a
detailed and explicit conversation with Mrs. Robert Walker, who would only advise Stan Caterbone to put his situation
in writing and submit it to the Congressman in his Washington, D. C. office. In addition: David Wouls (Executive Vice
President of the Lancaster chamber of Commerce & Industry), Stan Caterbone talked at length, and in detail,
making allegations of misconduct with members of the same; National Association of securities Dealers (NASD), in
Washington, D.C., Stan Caterbone discussed the securities related violations. And also: the Securities & Exchange
Commission (SEC), also in Washington, D.C., and discussed securities laws violations; the Pennsylvania Securities
Commission, of Harrisburg, Pa, discussed the implications of Stan Caterbone's illegal lock-out, and his legal and formal
positions, including incorporating officer of FMG, Ltd., Stan Caterbone received no support or follow-up
communications concerning all of the above requests, despite his apparent emotional duress, and extreme situation.
July 7, 1987
Stan Caterbone contacts the law firm of Capello & Foley, of Santa Barbara, California. Stan Caterbone had conducted
research (American Bar Association Journal) in "Lender Liability", which was becoming very popular legal issue,
where banks participate in illegal activities resulting in the financial ruin of it's borrowers.
Stan
Caterbone
intended to file suit against Commonwealth National Bank for the illegal and unjustified repossession of his aircraft.
Stan Caterbone discussed the case briefly with Diane Campell that day, and Stan Caterbone made arrangements to
deliver supporting documents to the office in Santa Barbara the following week, while visiting with Gamillion Studios,
in Hollywood.
July 8, 1987
A formal notification of the termination of Stan Caterbone's Registered Representative Securities license with
the Planners Securities Group Inc., of Atlanta, GA is received, with a "cc: Robert Kauffman".
No explanation was provided, or any reasons for the termination. Stan Caterbones reprisal for disclosing
criminal activities to the proper authorities is that he will illegally loose his privilege to sell securities without any
merit.
July 8, 1987
July 9, 1987 -
Stan Caterbone's brothers, Steve, Phil, Mike, and Tom, arrive unexpectedly and uninvited at the residence of Stan
Caterbone's in Stone Harbor, NJ, and refuse to leave until Stan Caterbone agrees to take Lithium and return to
Lancaster to undergo treatment by Dr. Al Schulz, for mental illness.
Stan Caterbone receives a notice by regular 1st class mail from Commonwealth National Bank regarding the
repossession of 9 days prior. The following reasons are given for the repossession:
1. Failure to provide adequate insurance.
2. Removal of aircraft from Lancaster Aviation.
3. Intended plan to fly aircraft to Florida without prior written notice.
Jul 10, 1987 -
Stan Caterbone receives a formal notarized notification from Dr. and Mrs. William Umiker of FMG, Ltd.,; removing
Stan Caterbone as the former Trusee for their Estates.
Mr. Robert Kauffman also sends a personal letter to all of Stan Caterbones clients informing each and every one that
he has moved to Stone Harbor, NJ; that he may not handle investments at all; and that people close to Stan
Caterbone had requested that he, Robert Kauffman, personally service his clientele.
July 16, 1987 -
Stan Caterbone travels to New York, from Boston, MA, to visit with Bob Walters of Power Station Studios, to discuss
the allegations of Blackmail, and to find out who is involved, including Scott Robertson and Power Station Studios.
Stan Caterbone discusses the illegal repossession and other related matters, however during the conversation, becomes
suspicious when Bob Walters and Tony Bongiovi disclose that the "Digital" Movie project is suddenly suspended until a
later time.
Page 307 of 2301

July 17, 1987 -
Page
17
Stan Caterbone travels to Hollywood, California to meet and visit with Ted
Gamillion and Gamillion Studios (Film Studio), and Marcia Silen of Flatbush Films.
Ted Gamillion had previously solicited the consulting of Stan Caterbone in order to help reorganize the financing of the
film studio, after earlier arrangements in North Carolina had gone sour. Stan Caterbone had spent several days visiting
and touring the studio. Ted Gamillion agreed to allow Stan Caterbone to represent the studio in order to secure the
required financing. Ted Gamillion provided Stan Caterbone with substantial amounts of confidential financial, legal,
and tax documents for the project.
During the visit, Marcia Silen had disclosed to Stan Caterbone that Scott Robertson had made allegations of insanity
about him (Stan Caterbone) to persons at Power Station Studios and at Flatbush Films.
July 21, 1987 -
At 2:30 pm Stan Caterbone visits the law firm of Capello & Foley, in Santa Barbara, California, and delivers 3 large blue
binders for Diane Cambell and attorney Barry Capello to review, concerning his allegations of dire violations of lender
liability with specific
regards to the illegal repossession of his aircraft by commonwealth National Bank.
July 22, 1987 -
Attorney Joseph Roda invoices Stan Caterbone $527.00 for the time and services of July 1 & 2, 1987.
July 24, 1987 -
Michael M. Hartlett sends a letter to all creditors of FMG, Ltd., informing them that stated the following:
Stan Caterbone is no longer an officer of the corporation; he was removed from office on July 1, 1987; he had
been purchasing items under FMG, Ltd., and obtaining corporate discount and rates; and formally notifying
them that Stan Caterbone had never had the right to purchase items through FMG, Ltd., or make corporate
commitments on behalf of FMG, Ltd., or contract or in any way obligate FMG, Ltd.,.
July 24, 1987 -
Stan Caterbone conducts a three (3) hour meeting at his residence in Stone Harbor, NJ, with attorney Lew Schweller
regarding legal action concerning all events and activities of the prior days and months. Stan Caterbone also gives Lew
Schweller a $500.00 retainers fee, for his representation.
July 27, 1987 -
A Philadelphia-based grand jury begins a our year probe into illegal activities surrounding Chem-Con and its
executives, including Guerin.
July 30, 1987 -
Stan Caterbone had paid $600 to Dr. Levine, a Psychiatrist from North field, New Jersey, for an objective evaluation of
his mental state of mind, in order to prove the fabricated allegations of 'insanity".
Dr. Levine had conducted a 2 hour meeting in his residence in Stone Harbor, NJ, and required Stan Caterbone to
complete the Minneapolis Multiphase Personality Inventory (MMPI). Stan Caterbone completed the test, and
immediately returned it to Dr. Levine.
After several weeks without any communications from Dr. Levine, Stan Caterbone had called for the results.
Dr. Levine had explained that he had conducted telephone interviews with members of Stan Caterbone's family, without
notice or consent, in addition to the original request of Stan Caterbone to conduct an objective and confidential
examination.
In addition, Dr. Levine prescribed Lithium drug therapy, and disclosed a diagnosis of Bi-Polar Mood Disorder.
August 1987 -
Stan Caterbone will meet with a friend, and employee of Lancaster Newspapers, Inc., and request the employee to warn
Ms. Peggy Steinman, the direct supervisor of the employee, not to print my name in the newspapers. Stan Caterbone
sensed his perpetrators would resort to extremes and warned against libel and slander.
The Lancaster Newspapers did exactly that on September 4, 1987.
August 1, 1987 -
Stan Caterbone transcribes a memo to Diane Cambell, assistant to attorney Barry Capello, of Capello & Foley, of Santa
Barbara, Ca.
August 6, 1987 -
The legal firm of Appel, Yost & Sorentino, of Lancaster, Pa., send a formal notice to Stan Caterbone, demanding the
return of a facsimile machine leased from the ACM company of Lancaster, Pa. Attorney Appel advises Stan Caterbone
that it is the property of FMG, Ltd., and should be returned at once or legal action will follow.
Page 308 of 2301
Page
18
August 8, 1987 -
John M. Wolf, Executive Vice President of Commonwealth National Bank sends Stan Caterbone a formal letter advising
that the repossession of July 2, 1987 was both lawful and appropriate, and declines to accept a settlement of $5 million
for lender liability violations.
August 7, 1987 -
Stan Caterbone receives a Credit Report from the Credit Bureau of Lancaster County as requested. The credit report up
to the date of August 1, 1987 verifies and confirms that his credit report was excellent, without any blemishes. The
history of all accounts were "paid within 30 days, or as agreed".
August 10, 1987 -
Stan Caterbone receives a facsimile from the Board of Directors of FMG, Ltd., signed by Robert Long threatening to file
criminal charges for "embezzlement (we have checks to prove it), burglary, employee theft, corporate opportunity and
slander against our firm".
August 12, 19S7 -
Yolanda Caterbone, mother of Stan Caterbone, Steve, Phil, Mike, and Tom Caterbone, all brothers, arrive unexpectedly
and uninvited to the residence of Stan Caterbone in Stone Harbor. After several requests for the visitors to leave the
premises are denied, several brothers refuse to let Stan Caterbone leave the premises. Stan Caterbone flees, and the
brothers chase after him.
Stan Caterbone runs into a neighbors house to ask to use the telephone to phone the police. However, after realizing that
he is scaring the occupants, he flees to the Stone Harbor Police Department, a few blocks away, in an effort to obtain a
restraining order and to lawfully have the unwanted persons vacate his residence and personal property.
Officer Steve Conners and Officer Henry Stanford refuse the request, and hold Stan Caterbone in custody. After some
30 minutes, the officers, accompanied by Steve and Tom Caterbone, place Stan Caterbone into a Police Cruiser and
proceed to the Burdette Tomlin Hospital, in Stone Harbor.
Upon arriving, Stan Caterbone is interrogated and questioned extensively about a "gun". A hospital staffer then accuses
Stan Caterbone of an attempted suicide and keep him in custody for 4 or more hours. An extensive mental health
evaluation is performed by another hospital staffer.
Stan Caterbone is given an ultimatum of signing a contract in order to be released form the hospital, the contract stated:
"I Stanley J. Caterbone will not take my life tonight or at anytime".
August 13, 1987 -
At approximately 9:30 am, Stan Caterbone returns to the Burdette Tomlin Hospital to obtain a formal copy of the
incident the preceding night. After some arguments1 hospital officials provide explicit records of the event, including
the following summary:
"Stan was brought to the ER (emergency room) by two brothers and police. Police received a phone call from Jim
Warner, (8 72-9081, friend), who told them he believed Stan planned to take a gun, go to the beach & ki7J. himself.
Client denied any such statement, thoughts or plans. lie has legal difficult times, financial deals which have fallen
through; license to do financial planning (his business) revoked; repossessed material goods (airplane); being
blackmailed; and several major financial deals (in which he had invested personal funds) fall through --but NO
PROBLEMS! Denied any Depression.
August 14, 1987 -
The same family members again arrive unwanted at the residence of Stan Caterbone in Stone Harbor, NJ. After another
confrontation, similar to the incident of two evenings before, Stan Caterbone fleas to the Avalon Police Department for
another attempt to get a restraining order. However, en route, just a few blocks from the Avalon Police Station, an
Avalon Police cruiser pulls Stan Caterbone over and arrests him for the following violations:
1.
Driving Beyond the speed limit.
2.
Driving an unregistered vehicle (all required registration materials were in Lancaster, PA)
3. Containing an empty beer can in his vehicle (which was at .1 east three days old)
In addition, the Avalon Police Department repossessed his car and locked it in the Avalon Police Department compound,
which was his only means of transportation and communication by car phone.
August 24, 1987 -
Robert Kauffman sends a letter to Millard Johnson, Stan Caterbone's client, regarding his previous intentions of paying
the $25,000 demand note of Stan Caterbone to Millard Johnson. Robert Kauffman had previously promised to pay the
Page 309 of 2301
Page
19
debt to Millard Johnson during a meeting.

Robert Kauffman, told Millard Johnson to contact the FMG, LTD., attorney, Craig Russell in order to file legal claim,
and formally disclosed that he would:
no longer handle any discussions concerning Stanley J. Caterbone.
In the last paragraph, Robert Kauffman discloses that
"attorney Mr. Patterson, no longer represents the Caterbone family regarding his pending bankruptcy or
guardianship".
Notes: Stan Caterbone never gave any legal jurisdiction or rights to any family member, has never filed for
bankruptcy, was not bankrupt, or even knew of an attorney named Mr. Patterson.
August 28, 1987 -
In a desperate plead for help, and in total tear for his life, and completely confused as to who is facilitating and
orchestrating this atrocious conspiracy, Stan Caterbone Federal Expresses a letter to Diane Sawyer of CBS News/60
Minutes.
August 29, 1987 -
Diane Parker of CBS News signs for the Federal Express letter at 11:22 am.
September 1, 1987 -
In an attempt to resolve issues, Stan Caterbone calls FMG, Ltd. board member P. Alan Loss and requests a meeting with
Robert. long and Scott Robertson to explain allegations of misconduct of Robert Kauffman and Michael Hartlett and the
illegal lockout of Stan Caterbone.
P. Alan Loss agrees and a meeting is set for September 4, 1987 at 10:00 am in the aide Hickory Inn, a mile away from
FMG, Ltd., Stan Caterbone requests that the meeting be in the strictest of confidence.
September 2, 1987 -
Attorney Joseph Roda sends Stan Caterbone a letter requesting payment of $525.48 in outstanding legal tees for the
meetings of July 1 & 2 and copying charges.
Stan Caterbone calls Victor of Romar Aviation (no charge) to schedule a charter flight from Cape May County Airport
to the Lancaster Airport for September 3rd at approximately2:00 pm, the day before the meeting with FMG ,Ltd.,
executives.
September 3, 1987 -
Robert Kauffman calls detective Larry Sigler or the Manhiem Township Police Department to report an alleged
Terroristic threat made two days prior, on September 1, 1987, by Stan Caterbone between the hours of 9:00 and 1 pm
noontime.
Detective Larry Sigler issues a warrant for the arrest of Stan Caterbone with District Justice Murray Horton that was
issued at about the same time as the arrival of Stan Caterbone at Romar Aviation.
At approximately 3:00 pm Mary Lynn Dipaolo picks Stan Caterbone up at Romar Aviation for a scheduled visit and
dinner. After Stan Caterbone becomes annoyed at Mary Lynn Dipaolo's unjustified allegations, Stan Caterbone borrows
her car to go home to his residence in Conestoga and to go play basketball.
At approximately 7:00 pm, upon leaving the playground, he is approached by Nancy Arment, FMG, Ltd., secretary, who
is elaborated and crying, asking "why are you doing this?".
At approximately 9:00 pm, in an attempt to recover additional stolen personal and business tiles, Stan Caterbone
proceeds to the offices of FMG, Ltd., where he is greeted by employee Stacy Waters and allowed to enter the building.
Stan Caterbone insists that Stacy Walters accompany him throughout the building as he recovers files in the offices of
Robert Kauffman, Michael Bartlett, and Robert Long.
In addition retrieving a Back-Up (FMG, Ltd, records and communications) copy of the computer system which he
integrated.
Upon leaving, Stan Caterbone temporarily disconnect the systems which he had integrated and developed for FMG, Ltd.,
which fall under intellectual property rights.
Page 310 of 2301
Page
20
Stacy Walters assists Stan Caterbone in loading the tiles in his automobile, and Stan Caterbone kisses Stacy Walters
goodbye, and awaits for her safe return to the building until leaving.
Upon entering his residence later that night, Stan Caterbone is taken into custody by the Conestoga Police, and requests
that the files that he had taken out of the offices of FMG, Ltd., be taken along to prove his rights to the property, and his
position within the company. Stan Caterbone was then taken to the jurisdiction of Manhiem Township Police, where he
is arrested and taken into custody.
September 4, 1987 -
At approximately 2:00 am, Stan Caterbone is arraigned before District Justice Richard R. Reeser for the following
charges: Terroristic threats; burglary; unlawful restraint; unlawful use of computers; theft by unlawful taking; robbery;
and criminal mischief.
Bail is set at $20,000 and Stan Caterbone is placed. the Lancaster county prison. He was not permitted to post real
estate for bail.
September 5, 1987 -
The Lancaster New Era and the Lancaster Intelligencer Journal report the alleged crimes, reporting that Stan Caterbone
is an ax-employee; that FMG, Ltd., sustained $60,000 because of his actions; and that he threatened 2 female employees.
The entire arrests and reports fail to acknowledge that Stan Caterbone is an individual lessee of the property, and in
accordance with law, still holds all of his offices of PING, Ltd., and is the founder of the company.
The above incident further facilitates the ongoing conspiracy, and publicly discredits Stan Caterbone in every way,
financially, professionally, and most importantly conveniently supports the continued allegations of insanity.
September 6, 1987
All attempts to post bail are denied. Robert Beyer appears for visitation at the Lancaster county prison, completely
unexpectedly and unsolicited. Robert Beyer offers his services and representation with regards to only defending the
criminal charges.
September 9, 1987 -
Stan Caterbone is given an ultimatum by the Lancaster county prison authorities, Robert Bayer, Yolanda Caterbone, and
Mary Lynn Dipaolo of posting the required bail only if Stan Caterbone voluntarily admits himself into the Psychiatric
Unit of St. Joseph Hospital, or remain in the Lancaster County prison.
Stan Caterbone is released from Lancaster County prison, and immediately escorted to St. Joseph Hospital and admitted
into the Psychiatric Unit.
September 15, 1987 -
Stan Caterbone questions the legality of the ultimatum for posting tail, and upon learning that it is unlawful, arranges for
his discharge Upon his discharge, the St. Joseph Hospital administrators learn that FMG, Ltd., had terminated his health insurance,
and demand payment of $3, 064.60 for the six days of hospitalization.
Stan Caterbone is not able to pay, and leaves the hospital and returns to his residence of Conestoga, PA.
Stan Caterbone receives an invoice from St. Joseph Hospital for $3,064.00.
Stan Caterbone receives a call from Howard Eisler, an Investigator for the Pennsylvania Securities Commission who
requests a meeting with Stan Caterbone. A meeting is scheduled for September 29, and Stan Caterbone arranges for
Robert Beyer and Millard Johnson to attend.
September 21, 1987 -ISC and the British Ferranti firm agree in principal to merge, creating what appeared to be a $1.5 billion defense/electronics
conglomerate, after six months of negotiations.
September 22, 1987-Stan Caterbone and James Warner settle on the real estate deal, of 433 w. Marion Street, which Stan Caterbone had sold to James
Warner, at a distressed price, which still yielded a profit. The profits of the transaction were paid directly to Millard
Johnson, with Stan Caterbone getting none of the proceeds.
September 25, 1987-Art .Kerst visits Stan Caterbone at his residence and accuses hi-rn and his cousin of being connected with the Mafia, and
conspiring together, in order to provide the financing of the $50 million shopping center in Florida, that was originally
owned by the Fisher/Sponougle Group, and diverting the profits of the deal away from him (Art Kerst) and the Fisher
Sponougle Group.
Page 311 of 2301
Page
21
Stan Caterbone becomes infuriated, not only at the absurd allegation, but the timing, when in fact Stan Caterbone had
bean fighting for his life for the past 4 months, and to even consider such activities would be insane.
Howard Eisler conducts a meeting at the Residence of Stan Caterbone, with all parties consenting to have the meeting
recorded by Stan Caterbone.
Howard Eisler was not able to provide a believable explanation of what he was investigating or why he had contacted
Stan Caterbone.
Stan Caterbone explains all of the circumstances regarding his prior meeting with ISC/Chem Con executive Larry
Resch, and details his allegations of wrongdoing of James Guerin/ISC/Chem Con6 and the discussions of that meeting
on June 23, 1987, with ISC executive Larry Resch. Stan Caterbone also discloses his ISC stock holdings, and his
relationships with ISC and Chem Con associates.
Millard Johnson testifies to Howard Eisleer during the meeting regarding a previous meeting in August with Robert
Kauffman, where Robert Kauffman tried to persuade Millard
Johnson to fabricate a story that a legitimate
personal loan of $25,000 to Stan Caterbone in June of 1987, was instead intended for investment and embezzled by Stan
Caterbone. Robert Kauffman wanted Millard Johnson to support this story to authorities. Stan Caterbone spent more
than 4 hours explaining and detailing all of his allegations and business activities including how he founded and built
Financial Management Group, Ltd.,; his mortgage banking activities; the illegal repossession of his aircraft; all of the
fabricated arrests; and the chronology of events after the June 23 meeting with ISC executive Larry Resch.
Howard Eisler ended the meeting and requested copies of documents from Stan Caterbone.
September 1987 -
Scott Robertson, begins work with American Helix founder, David Dering, to secure financing for the venture and
manufacturing
facility to manufacture CD Audio & CD-ROM Compact Discs, an extension
of the "Digital" technologies activities of Stan Caterbone.
David Dering solicited FMG, Ltd., to provide help in securing the necessary $5 million of capital required .for the
venture. David Dering was referred to FMG, Ltd., by Norris Boyd (FMG, Ltd., shareholder) and Bob Fogarty, who had
previously been working with Stan Caterbone on various financing arrangements. It was Stan Caterbone that elected to
allow both Scott Robertson and Rob Long to participate in the venture capital markets. Scott Robertson would later
conduct negotiations with High Industries, Inc., to provide the entire $5 million financial package. Scott Robertson also
was named executive Vice President of American Helix Technology Corporation, and would resign from FMG, Ltd., in
order pursue the venture on a full time basis.
James Boyer, formerly the lead recording engineer for Billy Joel, was also recruited to form the principals of American
Helix, consisting of Dave Dering, Scott Robertson, and James Boyer In mid-December of 1990, David Dering will
confirm the above formation of American Helix to Stan Caterbone, after Stan Caterbone alleges violations at the 1934
Sherman Anti-Trust Act, concerning his activities in the digital technologies industries, and the undoinfluence by Scott
Robertson, Robert Long, and High Industries, as well as criminal conspiracy, of all parties concerned in the destruction
of his business affairs that began in June at 1987.
October 2, 1987 -
District Justice Murray Horton conducts a preliminary hearing for all criminal charges against Stan Caterbone. Attorney
Robert Beyer refuses to discuss any issues regarding his individual lease of the FMG, Ltd., offices, or any issues
resulting in the illegal activities of anyone other than Stan Caterbone District Justice Murray Horton orders Stan
Caterbone to defend all of the criminal charges in the next term of criminal court in Lancaster County. Stan Caterbone
ordered to be bound over for the next term of criminal court of Lancaster County.
October 4, 1987 -
Stan Caterbone meets with high school classmate and attorney Mike McDonald at Stan Caterbone's residence, to discuss
legal action and recourse against all involved.
Mike McDonald accepts the case, and Stan Caterbone provides all of the relevant information and documentation.
October 12, 1987 -
Stan Caterbone travels to New York city to the offices of Intercon Special Services (white collar crime detective
agency) in order to attempt to obtain assistance in all of the circumstances.
Intercon Special Services, which is staffed with ax FBI agents, estimates that the services would cost at least $25,000.
October t 16, 1987
Stan Caterbone survives a near death collision on the New Danville Pike, when a driver ran through a stop sign at the
Page 312 of 2301
Page
22
intersection of Long Lane, while traveling at a speed of 45 mph. The driver hit Stan Caterbone's Jeep Cherokee directly
in the passengers door, sending Stan Caterbone in a free tall, spinning a full 180 degrees and landing upside down in a
field, facing the opposite direction. Stan Caterbone was trapped in the car, while a passerby attempted to brake the
windshield to get him out. Stan Caterbone's car was completely demolished, and he sustained a whip lash. Stan
Caterbone was now without any means of transportation, in addition to all of his other mitigating circumstances.
October 18, 1987 -
The Unemployment Compensation Review Board formally and officially decides against a claim for benefits by Stan
Caterbone and cites misconduct and wrongdoing as the reasons.
October 27, 1987 -
Lancaster Aviation files a civil suit with District Justice Murray Horton for alleged unpaid bills of some $5,000.
NOTE:
In late October or early November, Stan Caterbone was driving in the Southern end of the County, in Conestoga, when
he noticed a vehicle following closely. It was about 9:00 pm in the evening, and the roads were deserted in this rural
area.
Stan Caterbone began turning, not going in any particular direction. The ensuing vehicle kept following, and Stan
Caterbone quickly found himself in a high-speed car chase, that lasted at least 30 minutes. Finally, Stan Caterbone
arrived near Millersville, and was able to loose the vehicle.
November 9, 1987 -
Stan Caterbone visits with Parent Federal Savings and Loan's president, John Depatto, to discuss him problems in
meeting his current mortgage payments.
John Depatto immediately disclosed to Stan Caterbone that foreclosure proceedings have officially begun, and that the
full loan of approximately $110,000 is immediately due.
Stan Caterbone stands up from the conference table and declares "You tell Mr. James Guerin he is in trouble", and
abruptly walks out of the offices.
November 11, 1987-
Stan Caterbone meets with representatives of Tabor Community Services, of Lancaster, Pa, in order to formally apply
for assistance to the Pennsylvania Homeowners Emergency Mortgage Fund, in order to subsidize his monthly mortgage
payments, in an effort to avoid becoming homeless.
Stan Caterbone supplies Tabor community services with financial data and supportive documents relating to his
circumstances, which must be found to be out of the applicants control in order for financial assistance.
November 18, 1987 -
ISC~Ferranti settlement takes place with Guerin becoming the deputy chairman of Ferranti and exchanges his is million
shares of ISC stock for over 32.2 million shares of Ferranti stock.
November 19, 1987 -
Stan Caterbone contacts attorney Jeff Jamounou of McNeese, Wallice, and Nurick, who Stan Caterbone retained as legal
counsel for the security law, and demanded a legal opinion as to the offices that Stan Caterbone formerly held, including
his FMG, Ltd., Board of Directors seat.
Jeff Jamounou disclosed that he no longer represented FMG, Ltd., in that capacity, and that Craig Russell was the
attorney now handling issues such as that.
November 23, 1987-A Referees Decision by the unemployment Compensation Review Board upholds a recent decision to deny Stan Caterbone from
collecting any benefits, again citing misconduct and wrongdoing. Stan Caterbone calls Howard Fisler, of the
Pennsylvania Securities Commission and demands an explanation for not returning to obtain any documents as promised
in the meeting of September 29th. The phone call was recorded.
November 25, 1987 -
Stan Caterbone receives a letter from the Pennsylvania Securities Commission, Howard Zisler, citing a
misunderstanding and lack of communication, and now requests that Stan Caterbone submit a written complaint of all
allegations discussed in the meeting of September 29, 1987.
November 30, 1987 -
Stan Caterbone fears that the conspiracy now involves local and state authorities, and delivers 9,079 documents to the
Good Sheppard Industrial Services, of Allentown, PA to be transferred to microfiche in order to preserve the authenticity
of the documents.
Stan Caterbone feared that an attempt would be made to destroy all incriminating evidence, and given the number of
documents, and the lack of money, their safekeeping was becoming at great risk.
Page 313 of 2301
Page
23
For security reasons, and to remain anonymous, Stan Caterbone uses the Global Entertainment Group, Ltd., company
for the transaction with the Good Sheppard Industrial Services company.
November 26, 1987 -
Stan Caterbone visits the Pennsylvania State Police barracks in Lancaster, to file a formal complaint to the White Collar
Crime Division.
Stan Caterbone was treated as if he was making the entire story up, and received no help.
December 1, 1987 -
In continuing the efforts of the intervention of authorities, Stan Caterbone visits the PA State Capitol building and
personally delivers documents to the offices of: Pennsylvania Governor Casey; the Pennsylvania Securities Commission;
and FMG, Ltd., attorney Jeffrey Jamounou of McNeese, Wallice, & Nurick, all of Harrisburg, PA. During the same day,
at a press conference being held by Mark Singleton, Stan Caterbone approaches State Senator Sib Armstrong and Sen.
Armstrong refused to talk and literally ran away in the middle of the State Capitol.
December 4, 1987 -
Financial Management Group, Ltd., holds its first annual shareholders meeting, for the year ended June 30, 1987, at the
Treadway Resort Inn.
In an effort to promote propaganda against Stan Caterbone, and to support the fabricated allegations of insanity, FMG,
Ltd., president hired armed security personnel to guard the doorways of the meeting, insinuating that the meeting was
under a threat of violence, and to collaborate his recent allegations of Terroristic threats, which Stan Caterbone was
previously arrested and awaiting trial.
December 12, 1987 -
Stan Caterbone received a resume from James Cross, who was allegedly seeking employment in the areas of microwave
technologies, and was specifically interested in Stan Caterbone's activities with the "Digital" movie. Stan Caterbone had
previously met Lynn Cross, while she was working in a video repair store, where Stan Caterbone had gone to inquire
about purchasing an R-DAT (digital audio device only sold in Japan) recording device.
December 17, 1987 -
The United States Postal Inspector acknowledges receipt of formal complaint from Stan Caterbone regarding executives
from FMG, Ltd., illegally changing or address; opening of confidential personal and business mail; and withholding and
possibly destroying confidential personal and business mail at Stan Caterbone's leased property of 1755 Oregon Pike,
Lancaster, PA, also the headquarters of FMG, Ltd.,.
Page 314 of 2301
Page
24
THE YEAR
1988
January 11, 1988 -
Stan Caterbone delivers 10 audio tapes to be transcribed, to Secritar-AIl, of Lancaster, Pa.
January 13, 1988 -
Stan Caterbone receives the transcripts and the original tapes from Secritar-AlI.
January 15, 1988 -
Stan Caterbone drives to San Diego, California, and meets with attorney Sandra Gray, and discusses his dire illegalities
and to find access to due process of the law.
Notes:
In an effort to avoid the political consequences of obtaining legal counsel, Stan Caterbone thought that it would be
easier to find adequate and effective counsel from out of state. In addition, Stan Caterbone needed
some time away from his persecutors.
January 26, 1988 -
The Pennsylvania Homeowners Emergency Mortgage Assistance Program formally and officially denies Stan Caterbone
of benefits citing the following:
" Applicant was terminated from job FMG, Ltd.,), therefore was not suffering from circumstances beyond his
control".
March 14, 1988 -
Stan Caterbone is served notice by Lancaster Constables regarding Parent Federal .Guerin' Bank) v. Stan Caterbone
Mortgage Foreclosure of his residence at 2323 New Danville Pike, Conestoga, PA.
May 1988 -
Stan Caterbone is forced to sell his residence, and subdues to the undoinfluence that he was responsible for all
circumstances, and moves to Florida with his brother.
Sep 15, 1988 - Seven Chem-Con executives, including Christian, are criminally indicted for the firms $15 million defense contracting fraud.
October 23, 1988
-Stan Caterbone, destitute, without a personal residence, automobile, or any income, and with accumulated debts of
more than $65,000 from all related incidents in the 1987 "Blackmail", sells his FMG, Ltd., holdings to Robert Kauffman
and is given $72,000 in proceeds at settlement. This by and of itself will be proven to be extortion.
Robert Kauffman was in fear of Stan Caterbone exercising his large voting
rights in the upcoming FMG, Ltd., annual shareholders meeting, which included the election off FMG, Ltd., Board of
Directors. Stan Caterbone had approximately 19% of the outstanding shares of FMG, Ltd., and had the potential to vote
someone of his selection to a Board seat.
Scott Robertson had solicited the deal for both parties, and acted as negotiator for both.
November 2, 1988 -
Christian pleads guilty.
December 2, 1988 -
The Wall Street Journal reports the FBI has opened an investigation into U.S. Representative Joseph McDades ties to
Chem-Con and Guerin.
December 1988 -
Guerin begins negotiating a leveraged buyout of the numerous ISC subsidiaries, subsidiaries Guerin knew were involved
in the numerous export law violations and the fictitious contracts used to facilitate the fraud, stemming from the Ferranti
scandal.
Guerin diverts approximately $2 million to other Swiss bank accounts.
December 24, 1988 -
Jacobson is linked to passing more than $200,000 in bribes to a civilian Navy official to secure no-bid contracts for
Chem-Con and Wedteck.
Page 315 of 2301
Page
25
THE YEAR
1989
January 4, 1989 -
Guerin transfers $1.8 million to Citicorp Investment Hank Account from a Parent Universal Agency Ltd. account in
Luxemburg.
January 21, 1989 -
McDade refuses the governments request to release records in the Chem Con investigation.
February 17, 1989 -
Christian confirms his cooperation into the federal investigations into Chem Con, Guerin, and Wedteck, since his
company's files were subpoenaed in 1987.
March 13, 1989 -
Scott Robertson, co-founder and executive vice president of American Helix Technology corporation, a wholly owned
subsidiary of High Industries, Inc., of Lancaster, Pa, recruits Stan Caterbone for marketing help.
Stan Caterbone accepts a weekly consulting contract, with no long-term commitment, in light of his efforts with Radio
Science Laboratories, Inc.,
Scott Robertson wanted Stan Caterbone to help develop the new and emerging CD-ROM business, which was
essentially "Digital" technologies. American Helix was one of 10 domestic manufacturing facilities located in the
continental U.S., for the production of CD-Audio discs (CD's or Compact Discs), and one of only a few CD-ROM
manufacturers.
April 13, 1989 -
Guerin transfers approximately $1 million from the Luxemburg account to Parent Industries Account at the Meridian
Bank, in Lancaster, Pa.
Guerin transfers $970,000 from the Parent Industries Meridian Account to the Bank of Delaware.
Guerin pays off a portion of the $2.75 million in alleged Blackmail money to William A. Clark, Guerin's top corporate
attorney for ISC, and also represented by attorney Joseph Roda (Stan Caterbone's attorney who questioned his
allegations on July 2, 1987)
April 17, 1989 -
Stan Caterbone incorporates Radio Science Laboratories, Inc., to further his interest in microwave technologies, and the
telecommunications industry. The company is a venture with James & Lynn Cross, both capable design engineers with
over 30 years experience.
NOTES:
The company was trying to secure financing for the development of a manufacturing enterprise for Low Noise
Amplifiers, or LNA's as they are commonly referred.
May 11, 1989 -
Carl Jacobson is indicted for passing bribes to Richard Ramirez, on behalf of defense contractor, Chem Con.
June 1, 1989
Jacobson is indicted, again this time for passing bribes to Ramirez on behalf
June 8, 1989
Christian names Guerin as the mastermind behind the Chem Con fraud, saying millions on dollars from Chem Con were
used to inflate the value of ISC prior to the Ferranti/ISC merger.
June
1989
Christian is sentenced to six years in prison for his role in Chem Con.
June 9, 1989
Guerin denies Christians claim that he is the target of any federal investigation.
June 25, 1989 -
Qf Wedtech.
Guerin is reported to be guilty resigning from numerous board positions in Lancaster, including his seat as Trustee at
Penn state Harrisburg, and Millersville Universities.
July 3, 1989
Guerin is linked to a second minority-owned company he started, then drained all of its assets. Once insolvent, former
Leola-based Application Technology Associates' uncompleted minority contracts were used by Guerin to set up Chem
Con as a minority- owned defense contractor with the U.S. Small Business Administration.
July 8, 1989
William A. Clark, Guerin's former top ISC attorney, sues Guerin for $2 million, the balance Clark claims is owed him in
a $2.75 million settlement (over an employment dispute) accepted by Guerin in March. Joe Roda is legal counsel for
William Clark.
Page 316 of 2301

NOTE:
July 1989
Page
26
Joe Roda was the first attorney that Stan Caterbone had gone to for help, who told Stan Caterbone to quit fabricating
things.
-
July 19, 1989
Clarks action freezes Guerins assets and temporarily blocks the transfer of Guerin's 1988 Christmas gift of Four
Seasons sports Complex to East Hempfield Township.
-
Stan Caterbone, Scott Robertson, and American Helix agree on a one year
employment contract, which American Helix will never fulfill in its entirety, and will be terminated in the following
April.
July 20, 1989 -
Guerin secretly plots to move his personal holding company, Parent Industries Inc., to Fort Myers, Fla., near his second
home in
Naples.
July 26, 1989 -
Citicorp forces Guerin to sell $38 million of his Ferranti stock to pay off a loan he took to fund what would be a failed
repurchase of attempt of several ISC divisions from Ferranti. These divisions held numerous inflated or non-existent
contracts used to overvalue ISCs prior to the Ferranti/ISC merger in 1987.
August 8, 1989
Guerin moves to Florida, but not before depositing $2 million with the Lancaster County Courts to free his assets,
regarding
the William Clark pay dispute.
Guerin blames inaccurate and malicious press coverage for forcing him out of Lancaster and is lauded and supported in
this claim by many of the county's most prominent citizen's apparently blinded by the seemingly genuine community
contributions.
August 14, 1989
McDade returns $20,000 in illegal Chem Con campaign contributions.

Despite documented, non-declared trips aboard Chem Con jets, trips to the Caribbean and a Delaware beach house and
clothing bought for him by Christian, McDade denies any wrongdoing, or that he is the target of any federal probe.
Jere Sullivan is implicated in the above investigation through his involvement of some of the above transactions.
August 23, 1989
Reports confirm McDade has already spent more than $22,000 in campaign funds to pay for legal fees associated with
the investigation into his ties to Chem Con.
September 12, 1989 -Ferranti halts trading of its stock, claiming it is the victim of a massive fraud.
September 15, 1989-Federal agents confirm Guerin is being targeted for illegal arms sales to Iraq, Iran, South Africa and other embargoed Third
World countries.
September 15, 1989-Ferranti halts trading of its stock and calls for a full investigation into a fraud federal prosecutors said exceeds $1
Billion.
September 20, 1989-Guerin issues a statement denying any wrongdoing with respect to Ferranti's claims, or any grand jury involvement.
September 21, 1989
-In a second prepared statement in as many days, Guerin reverses his position, now
confirming he is the target of
the grand jury probe into ISC and Chem Con and is cooperating with federal investigators.
October 3, 1989 -
Federal prosecutors confirm previous reports that the ISC probe includes illegal arms sales to South Africa.
Ferranti Stock plunges 24 percent as trading resumes in London.
October 6, 1989 -
Jacobson pleads guilty to passing bribes to Chem Con and Wedtech.
October 10, 1989 -
British Labor unions urge Ferranti to drop all ISC-related companies, claiming job loss in Scotland alone could exceed
8,000 workers.
October 16, 1989 -
A 1987 report commissioned by Sebastian de Ferranti surfaces showing that the company bearing his family's name was
cautioned not
to merge with ISC by Lazard Brothers.
Page 317 of 2301
Page
27
Ferranti chairman, Sir Derek-Alun Jones comes under tire by stockholders who demand his resignation during the
company's annual meeting in London.
October 24, 1989 -
Scotland Yard joins the U.S. in the Guerin probe. Federal agents will travel to London in January to coordinate the
investigation.
November 1989
Ferranti begins firing ISC executives still within the company.
December 1, 1989
Ferranti sues Guerin and three former ISC executives, including Larry Resch, for $198 million each, claiming all of ISC's
worth was a sham built on bogus contracts.
December 2, 1989
Federal agents confirm seizing shipments of military-grade electronics belonging to Guerin's son, James, at the Port of
Philadelphia destined for embargoed Third World countries in violation of U.S. export
laws.
Federal agents confirm using the threat of pending criminal charges against Guerin's son to force the elder Guerin's
ongoing cooperation with federal prosecutors.
Page 318 of 2301
Page
28
THE YEAR
1990
January 23, 1990
Christian sues Guerin for $93 million, claiming he, too, was a victim his former
Ferranti.
mentor's
plan
to
defraud
Guerin again captures the lead story in the Wall Street Journal, one that portrays him as a cold-blooded international
arms dealer and the mastermind behind the Ferranti Fraud.
The transcript of Guerin's Jan. 9th deposition in his dispute with Clark is released revealing that former Republican
presidential candidate and secretary of state Alexander Haig received $26,000 in illegal campaign contributions from
ISC.
Ferranti begins selling off ISC units abroad as it struggles to reorganize.
Keith Martin, WGAL-TV managing news editor and lead anchor, is named by Guerin as having worked for ISC while
also reporting on the company for Channel S TV.
Ferranti files a $664 million suit in British Courts against former ISC/Guerin auditors Peat Marwick for allegedly failing
to disclose the fraud within ISC prior to the ISC/Ferranti merger of 1987.
January 26, 1990 -
WGAL's Martin resigns under threat of termination for compromising his credibility
and violating his personal services contract.
February 2, 1990 -
Reports show former Guerin confidant and IBC executive R. Clyde Ivy, was ISC's lead missile developer in South
Africa during the Angolean War and the head and founder of Kentron, south Africas missile development arm of the
governments munitions firm, Armscor, while an employee of ISC.
February 23, 1990 -
Eugene Anderson, a Texas-born turnaround specialist, replaces Alun-Jones as

Guerins chairman.
Ferranti continues to sell off many of its subsidiaries and announces plans for massive debt write-offs.
March 19, 1990 -
Guerin and Clark appear to settle their dispute, with the escrowed cash to be dispersed on March 30.
March 30, 1990 -
Federal agents block the Guerin/Clark settlement by seizing the escrowed cash using pre-indictment provisions of the
Racketeer Influenced Corrupt Organization Act or RICO statutes.
April 13, 1990 -
Federal prosecutors claim Parent Industries Inc., and its resources were still controlled by Guerin, despite his giving the
company to his wife and her selling it to then Parent President Michael Peck for $1 and therefore is subject to seizure
under RICO statutes.
April 1990 -
The American Helix Board of Directors, lead by S. Dale High/High Industries, vote to terminate Scott Robertson of
American Helix, and to discontinue the financing of the CD-ROM business which Stan Caterbone was directly involved.
The joint venture agreement with Network Technologies, or Washington, D.C., had lost an estimated $450,000 in the
past 9 months, and the technologies which were to be deliver red, had proven to be worthless. Scott Robertson had
solicited, negotiated, and administer the deal, Stan Caterbone had raised serious concerns at to the capabilities of both
the technologies, the business, and Network Technologies, early in the project.
High Industries then conducted several meetings with Stan Caterbone to purchase the business, however, Stan Caterbone
had told the executive in a meeting on Good Friday, that he was solely responsible for any business that was left, and
any there was no real value.
High Industries agreed to pay Stan Caterbone his weekly consulting tee only until June 30, in hopes of negotiating an
agreement to keep American Helix in the CD-RON business, which was only feasible with Stan Caterbone, because of
his knowledge and expertise in "Digital" technologies.
May 5, 1990 -
Stan Caterbone is awarded his first government contract for CD-ROM technologies with the National Institute of
Standards and Technologies (NIST), of Gaithersburg, Maryland. NIST is the technology arm of the federal government,
similar to the National Institute of Health (NlH), of Bathesda, Maryland.
Page 319 of 2301
Page
29
Because of the technological complexities of the project surrounding the UNIX system environment, Phillips DuPont
(PSO) was the only other competitor in the U.S..
Computer Scientist, John Garofolo, will coordinate the project, which is responsible for the research and development of
speech recognition systems for the Defense Advanced Research Projects Agency Information Science and Technology
Office (DARPA-ISTO) The Automated Speech Recognition Group, will supervise the project for MIST. The group will
develop CD-ROM'S containing speech corpora for the scientific I community, including: Massachusetts institute of
Technology (MIT); Texas instruments (TI); SRI International; and other academic institutions.
May 10, 1990 - Raymond 8. "Tim" Wittig, the former counsel to McDade on the House Small Business Committee, is indicted on eight counts of
racketeering, bribery, conspiracy and filing false income tax returns for his role in Chew Con fraud.
The 12th person indicted in the Chem Con fraud, Wittig is alleged to have passed bribes to McDade to secure an
undisclosed portion of $72 million in no-bids, nail Business Administration contracts awarded to Chew Con.
An IRS agent testifies Guerin van deeply involved in illegal arms sales to South Africa, and an IRS agent names Guerin
as the mastermind behind the rerranti fraud estimated to exceed $1 billion.
Federal prosecutors announce in open court that Guerin's Parent Industries Inc., has pleaded guilty to a one-count
criminal bill of information for violation of the RICO statutes. Prosecutor. told U.S. District Judge Thomas N. Oneill
the company agreed to pay $4.4 million for the violation, including $2 million escrowed in the Clark
V. Guerin
dispute.
Jacobson is sentenced to two months in prison for his role in Wedteck and receives a three rear suspended sentence and
three year probation for the Ohm Con case.
May 31, 1990 -
Judge O'Neill grant. a 90-day freeze on Guerin's escrowed $2 million saying there is "substantial probability" the
government will prevail against him in its pending criminal RICO prosecution due to be filed by Aug 31. within a year.
ISC once boasted more than 3,000 local employees during its heyday; it will have less than 500 worker.. within a year.
Ferranti announces the layoff 022 ISCs workers in England; 200 in B. Wales; 150 in Manchester: and 115 each in the
Portsmouth and Bracknell plants. Ferranti files suit in Switzerland to recover the records of 20 front companies
allegedly used by Guerin in the fraud.
July 25, 1990 - Jacobsonsa flight to Chile is revealed to have been orchestrated by Chilean Arms dealer Carlos Cardoen, a Guerin associate and
cluster borib supplier to Iran and rraq.
It was disclosed Cardoen's operation also was used to fabricate more than $200 million by supporting phony inventory
for a bogus missile contract nc claimed it had with the United Emirates.
August 2, 1990 -
Stan Caterbone discovers that in July, Fulton Bank embezzled $5,000 from the checking account of Stan Caterbone due
to an error by Fulton Bank's accounting
Fulton Bank refused to credit the account for more than 60 days, without crediting the lost interest income.
August 11, 1990 -
Stuart N~ Pindall, a former ISC executive and Guerin confidant is sued for $189 million by Ferranti for his role in the
alleged fraud masterminded by Guerin.
In addition, six Panamanian and five U.S. front companies are sued for like amounts by Ferranti, which claimed the
firms were used to establish bogus business transactions needed to support the fraud. The pending civil suits, now
totaling 3.97 billion, include Guerin, former ISC executives, including Larry Resch and the international accounting
firm of Peat Warwick1 all who Perranti alleges were instrumental in the success of the fraud.
Guerins now-defunct personal holding company, Parent Industries Inc., through a corporate memorandum signed by
Guerin, pleads guilty to one count of violation of the RICO statutes and agrees to pay $4.4 million in fine. Characterized
by prosecutors as Quinn's "alter ego". Parent was one of the key companies Guerin used to mastermind the fraud against
Ferranti.
Page 320 of 2301
Page
30
October 11, 1990 - Florida land records show Guerin accepted a guilty plea agreement with federal prosecutors in July and will forfeit $600,000
from the proceeds of the sale of his $1.65 million bay front home in Naples, Florida.
October 11, 1990 -
Court records show Wittig, the former House aid to Mcdade and consultant to Ohm Con, is in the final stages of
reaching a negotiated guilty plea with federal prosecutors.
Department of Justice claims proceeds from the sale of his Naples home after paying the $600,000 outlined in his guilty
plea agreement to the Justice Department. Ferranti has asked the court to assist in collecting over $189 million from
Guerin, an amount awarded the firm by a British court when it said Guerin failed to convince the court he had nothing to
do with the 31 billion fraud.
Stan Caterbone begins to organize. all relevant documents, stored in some 30 boxes, regarding all circumstances
involving the "1987" blackmail and criminal conspiracy, in hopes of finally resolving all outstanding issues, by taking
action tar legal recourse.
In response from the effects of Post Traumatic Stress Syndrome, Stan Caterbone had rescinded efforts for due process
immediately after loosing his home and businesses.
In similar matter of being brainwashed, Stan Caterbone was fearful of pursuing due process of the law in fear of
continuing reprisal. However, upon the public disclosure of the Federal courts indictments into illegal ISC activities,
Stan Caterbone began to review his case, and find distinct and substantiated activities associated directly to his
disclosure of fraud within ISC.
November 19, 1990 -
Stan Caterbone's article, "Escaping the UNIX Tar Pit: Producing CD-ROM'S in the UNIX Environment" is submitted
and accepted for publication to the National Institute of Standards & Technology (MIST), by Co author John Garofolo,
computer scientist.
Linda Helgerson, editor of DISC magazine, as well as numerous other industry publications, requested Stan Caterbone
to write an article for the new magazine.
The article described in detail some of the problems encountered when producing CDROM's in the UNIX environment,
which was rarely done before. In addition, the "TIMIT" project, which Stan Caterbone and NIST had recently
completed, was one of the most aggressive CD-ROM projects in terms of pushing the envelope for the number of "Tar"
files and the sire of the data on one CD-ROM disc.
Phillips DuPont was the only other firm to accept any work involving the troublesome "Tar" tiles.
Dec 12, 1990 - Ferranti reports a near $40 million loss for the first half year, but says it hopes to begin showing a profit before year-end in March
1991a
Stan Caterbone receives a call from James Christian while in custody in the Loretto State prison. Stan Caterbone asked
Jim Christian if he had authorized or had knowledge about the June 23, 1987 meeting between himself and ISC
executive Larry Reach. James Christian answered the question as follows:
"I never knew of such a meeting, authorized a meeting with Larry and yourself. Larry (Reseb) was the courier for Jim
Guerin, that is how I and Chem Con got set up and used as the scapegoat to divert attention away from
~ You should
talk to Earnest Schriber of Lancaster Newspapers, you can trust him.. Guerin's attorney (Tate) called to offer me $1.00
to settle my $93 million law suit against Guerin".
Dec 14, 1990 -
At a Christmas party of Bradley DeForge's, Mike Dipaolo, during a conversation with Stan Caterbone, had stated that
"You (Stan Caterbone) had Guns and Knives in 1987" as the reason for the mental illness fabrications.
NOTES:
Stan Caterbone quickly left the party. In addition, during the same time, other such statements from friends, regarding
his present "mental condition", began to mysteriously resurface only after knowledge of his activities to take legal
recourse for the 1987 incidents, and to pursue his due access to the law.
Stan Caterbone, in order to get work accomplished on the project, traveled to Captitva Island, and continued his project,
the "AMG Legal Systems Prototype" disc.
The "AMO Legal Systems Prototype" project was a CD-ROM system, designed by Stan Caterbone, that would include
Page 321 of 2301
Page
31
all of his rlevent information concerning his alleged ISC Cover-Up, including audio conversations, and authentic
documents, all stored on one optical disc, or a CD-ROM.
The disc and system was finally completed on May 16, 1991.
December 20, 1990 -Stan Caterbone telephones his cousin Ron Roda, from Captiva Island, Florida, to inform him that he will arrive home in a few
days.
During the conversation, Ron Roda, disclosed to Stan Caterbone that both Jim Warner and Jere Sullivan had made
telephone call to his brothers, Phil and Tom, and made allegations of insanity about Stan Caterbone, and advised the
need for medication.
December 23, 1990 -Stan Caterbone forwards a letter to the Department of Defense Mapping Agency regarding his bid for the $2.5 million CD- ROM
contract (DMA 700-90-0011), then in negotiations.
Stan Caterbone alleges misconduct in the procurement and for the first time publicly discloses his allegations of
Blackmail immediately following his meeting with ISC executive Larry Resch on June 23, 1987..
December 28, 1990 -
A federal judge cuts Christians sentence by nearly four years, making him eligible for release in July 1991.
Page 322 of 2301
Page
32
THE YEAR
1991
January 9, 1991 -
Lt. Madenspacher of the Manhiem Township Police Department call Stan Caterbone at his lab/office in him home at
approximately 2:00 pm. Lt. Madenspacher explains that he had received a copy of the letter to the Department of
Defense, that Detective Larry Mathias had forwarded to him.
Lt. Madenspacher questioned his motives of the letter and stated:
"What are you going to do.. We (Manhiem Township Police Department) just don't want to see a multi-million dollar
law suit come down our way.."
Stan Caterbone responded, "You know that I was an individual leassee of that property, and in addition I had never
resigned any offices or my Board of Director's seat of FMG, Ltd., .. You also know that I had met with Larry Resch of
ISC on June 2S, 1987, and that I made allegations of misconduct.."
Lt. Madenspacher responded, "We were forced into that (the arrests of Stan Caterbone on Sept. 3, 1987), we were caught
between a rock and a hard place, we were forced into that".
Lt. Madenspacher then changed the subject to "Digital" technologies, and described the activities of the police
department of using the same in the telephone surveillance of criminal suspects.
Lt. Madenspacher then requested to meet with Stan Caterbone. Stan Caterbone agreed, however due to his current busy
schedule, confirmed he would contact him later to schedule a meeting.
January 10, 1991 -
Stan Caterbone sends a letter to Lt. Madenspacher of the Manhiem Township Police Department, to schedule a meeting
for Thursday, Jan. 17th at 3:00 pm, at his office at American Helix Technology Corporation, at the Green field
Corporate Park. Stan Caterbone requested a response only if the time was in conflict of his schedule.
January 17, 1991 -
Lt. Madenspacher fails to show up for the scheduled meeting with Stan Caterbone at Amen can Helix, and never
contacted him before that date to change the meeting, or
called to apologize for not being able to keep the prior commitment.
January 18, 1991
Stan Caterbone sends documents concerning the Blackmail" of 1987 to several reporters of the Lancaster Newspapers,:
Tim MeKeele; Earnest Schriber; and Thomas
Planner. Tim MeKeele also received a tape with some excerpts of the September 29, 1987 meeting with the PA
Securities Commission, where Stan Caterbone discusses allegations of misconduct against J. Guerin and ISC.
January 19, 1991
High Industries American Helix illegally and without notice locks Stan Caterbone out of his office and the facility of
American Helix, who was
currently under a joint venture agreement with Stan Caterbone and his Advanced Media
Group, Ltd., for his digital technologies business.
NOTES::
January 21, 1991
This "Lock-Out" was similar to that of FMG, Ltd., on July 1, 1987. Again conveniently when Stan Caterbone had raised
issues and allegations involving Guerin and ISC.
-
NOTES:
Jan 22, 1991
In fear and confused about his involvement, and in respect to the massive fraud of the ISC/Ferranti merger, Stan
Caterbone sends a package to Ferantt's legal counsel
in England by way of United Postal Service' Overnight
International Delivery Service (Tracking Number 1773 0619 670).
Stan Caterbone was in fear that a potential "Cover-Up" by U.S. authorities, and specifically the Lancaster community,
would place his life in danger, and wanted to insure that the information concerning his knowledge of ISC misconduct
before the lSC/Ferranti merger, and his disclosure to local, state, and federal authorities in the summer of 1987, at least
would be received by Ferranti, reducing the possibility of someone terminating his life in order so that these
circumstances would not be used as an asset in the present Ferranti Legal efforts.
In an effort to support his allegations of misconduct and the allegedly threatening

activities of Stan Caterbone, American Helix president Dave Dering has all of the
locks in the building changed by a professional locksmith, which is nothing
more than an act of propaganda.
Later that day, Stan Caterbone and David Dering meet. David Dering resolves to only allow Stan Caterbone in the
Page 323 of 2301
Page
33
building during normal business hours, and does not allow him to occupy his own office.
Stan Caterbone has never been given any reason why he was locked out in the first place.
February 1, 1991
Feb 17, 1991
ABC News 20/20 features the story "Weapons Sales to Iraq" about the ISC/Cardoen
how it got to Saddam Hussain.
-
cluster bomb technology and
Stan Caterbone receives a letter from Sandra K. Paul, of the Citizens Ambassador Program, a division of People to
People International, notifying him that he has been selected to participate in the upcoming Printing and Publishing
Delegation to the Soviet Union and Eastern Europe in the coming August.
People to People International is a nonprofit organization started by the late Dwitht D. Eisenhower to facilitate the
communications of experts from various professions throughout the world.
The objective of the delegation was to exchange ideas, information, and technologies of the printing and publishing
industries with American counterparts in the Soviet Union, and various Eastern European countries.
February 22, 1991
February 1991
Federal prosecutors seize $800,000 from Clark, claiming he was privy to information about ongoing criminal acts within
ISC that generated the tainted cash.
-In an American Helix staff meeting, with all employees present, but Stan Caterbone,
president David Dering had spent approximately 20 minutes alleging that Stan
Caterbone almost ruined his company, and that he "is a runaway ex-convict, that will
end up in jail very soon".
The above discussion was disclosed by engineer Al Thornburg, immediately following the meeting.
May 23, 1991 -
At approximately 2:00 pm, Jay Curtis, (appearing as a Department of Defense contractor, who had recently solicited the
services of Stan Caterbone and his Advanced Media Group, Ltd., to provide engineering in the development of "Digital"
simulation and training applications for various U.S. Military Logistics bases) had called Stan Caterbone. The following
is synopsis of the conversation:
"Because of your recent discussions concerning your knowledge and information about the ISC Scandal, and an alleged
"Cover-Up", I had to do a background check on you, to insure against any problems when including you in by proposal
to the U.S. Department of Defense... Everyone backs up your story, and is looking over your documents now, including
the CIA, IRS, SEC, FBI, Scotland Yard, Attorney General, the British M-4, and others.
They are all verifying and confirming your "cover-up" allegations.. They don't know what to tell the Press and Media "I
also know that you submitted documents to Mr. Thomas Flannery of the Lancaster Intelligencer Journal".
"How did you know about the CIA and its involvement with ISC, how did you know that, and what do you know?"
NOTES:
Jay Curtis kept pushing Stan Caterbone on the CIA issue, and what he had known and how he knew, Stan Caterbone
kept telling him that the whole situation was to emotional, and that he was afraid for his life. Stan Caterbone had to
eventually tell Mr. Curtis that he could not discuss this anymore. He abruptly changed the subject and hung up on Mr.
Curtis.
Stan Caterbone immediately went to a friends house, and disclosed that fact that he was in fear for his life. He quitly sat
on the steps with his friend, Abby. Later that night, his friend Dave Pflumm would take him to the corner bar for a few
drinks, while unknowing to Stan Caterbone, Ted Koppel was disclosing the story of the CIAs involvement with ISC.
Several hours later, Ted Koppel broke the story about the CIA and ISC's covert operations to sell arms to Iraq.
Immediately following the conversation with Mr. Jay Curtis regarding the CIA and ISC, Stan Caterbone packed a
suitcase and confidential information assets, in preparation to leave Lancaster, in total and legitimate fear for his life.
May 23, 1991 -
ABC News/Nightline and Ted Koppel feature the first in a series of stories, relating to CIA knowledge of a covert
operation to supply munitions to south Africa implemented by ISC and Carlos Cardoen.
Page 324 of 2301
Page
34
The story featured Lancaster and ISC. The report ties Guerin to the National Security Agency project in the 1970s.
The report was investigated by ABC News, the Financial Times of London, and the Lancaster Intelligencer News. Tom
Flannery of the Lancaster Intelligencer Journal, appeared on the program and was given credits on the show.
May 24, 1991 -
The Lancaster Intelligencer Journal reports on the above story.

At approximately 1:30 pm, Stan Caterbone drives out of Lancaster, en route to a safe haven, and stops at a convenience
store and reads the early edition of the Lancaster New Era, learning for the first time of ABC News/Nightline story about
ISC and the CIA the evening before, just hours after his conversation regarding the same to Jay Curtis.
June 7, 1991 - Stan Caterbone is again arrested by the Stone Harbor Police. After passing several sobriety tests, and two breathalyzer tests, Stan
Caterbone is placed in a jail cell, and refused to be released.
Several hours later, Stan Caterbone is cited for outstanding arrests warrants of Avalon, NJ, dated back to August 14,
1987, by an officer of the Avalon Police department who suddenly appeared.
Both arresting officers demanded $340.00 for the posting of bail. Stan Caterbone requested that the required cash be
retrieved from his car, located just a few blocks away.
The Avalon police officer responded by saying, "we can't let you go to your car, you may have a gun in there".
Stan Caterbone was immediately escorted to the cape May county Prison, fingerprinted and processed.
June 8, 1987 -
Stan Caterbone calls Mike Orstein, Lt. of the Stone Harbor police patrol, and
requests that he retrieve the required cash from his car, and post the required bail.
At approximately 2:30 pm, Stan Caterbone is released on bail.
June 11, 1991 -
Stan Caterbone left the Stone Harbor Marina at approximately 12:30 am en route to Lancaster, Pa, to retrieve some files
concerning the ISC cover-up.
Upon driving north on Route 47 (the normal route to Lancaster), approximately 10 miles outside the Cape May county
Courthouse, Stan Caterbone noticed a car following him closely. Suspicious, Stan Caterbone decreased his speed from
55 mph to 35 mph, in order for the car to pass him. However, the car remained directly behind, adjusting the speed
accordingly.
In an effort to elude the car, without raising suspicion, Stan Caterbone gradually increased his speed, while also
increasing the distance between the cars, resulting in the loss of his taillights to the ensuing vehicle - Because of the
winding road, Stan Caterbone looked for an abrupt turn-off, in hopes of dashing the eluding vehicle, by loosing sight of
his taillights.
There was little or no traffic on the route during the early morning hours, and Stan Caterbone stopped at an intersection,
and noticed that the headlights of the ensuing vehicle were not visible in his rear view mirror, meaning that his taillights
were also not visible to the ensuing vehicle.
Immediately upon pulling from the intersection, Stan Caterbone noticed a narrow dirt road that lead into a field of small
trees, the perfect place to sit for the ensuing auto to pass him, unnoticed.
The ensuing vehicle pulled to the intersection, and continued north on route 47, in the direction of Lancaster. Stan
Caterbone sat in his vehicle a few minutes, until continuing on his travel, north on Route 47.
Approximately five (5) minutes later, a car traveling in excess of SS mph, approached Stan Caterbone, traveling south
on the same road (2 lanes)
As the two cars approached each other, and approximately 30 yards from reaching each other, the approaching vehicle
drove directly into the lane of Stan Caterbone, with its high beams on, and continued straight for his vehicle, or what
appeared to be a head-on-collision. Stan Caterbone drove off of the berm of the road, missing a line of trees by less than
12 inches (eluding a life threatening disaster), and passed the vehicle that was still in the north bound lane, heading
south.
Page 325 of 2301
Page
35
Stan Caterbone, shaking and sweating furiously, noticed the cars brake lights go on, and the car apparently turned
around, and began pursuing Stan Caterbone again.
Stan Caterbone drove as fast as he could to Route 55, hoping to find traffic in order to hide and loose the pursuing car.
Stan Caterbone arrived in Lancaster, at approximately 3:00 am, and again noticed a car sitting in the parking lot of the
vacant "Sportsman's Den", at the intersection of the New Danville Pike and Prince Streets.
Upon driving west on Hershey Avenue, Stan Caterbone noticed the car following him. In an effort to identify the license
plate, Stan Caterbone made a few turns in the area of Hamilton Watch, and followed the car heading north on S. West
End Avenue. The car was a late model, gold or tan, Cougar or possibly a Buick Park Avenue.
Stan Caterbone watched the car increase his speed, and finally changed directions and proceeded to his residence, and
parked a few blocks away, and walked through the woods, to his apartment in the Hershey Heritage complex. Stan
Caterbone then used a flashlight, in order not to reveal his presence, and returned to his vehicle, sometime in the early
morning, during daylight.
June 10, 1991 -
Two independent U.S. courts uphold a $189 million award by Britian's High Court against ISC executives Shireman and
Reach for their role in the fraud.
Ferranti makes its first open statement against Guerin saying a similar decision is expected to uphold the High Court's
decision against him.
June 19, 1991 -
Stan Caterbone leaves Stone Harbor, in constant fear for his life, and remains in seclusion, in various parts of the Eastern
Seacoast, spanning from Captiva Island, Florida, to Boston, MA, in order to prepare an official request for a
Congressional Investigation of all related matters.
Jul 11, 1991 -
Stan Caterbone files an official request C300 pages) for a Congressional Investigation into all of the ISC and preceding
issues with U. S. Representative Robert Walker CR-Pennsylvania), and Speaker of the House, U. S. Representative
Thomas Foley.
Both requests were sent by Overnight Mail Service of the United States Post Office, outside of Baltimore, Maryland.
July 12, 1991 -
Stan Caterbone returns to his home, in Lancaster, PA, at approximately 1200 pm, after remaining in seclusion
immediately following the phone conversation of May 23, 1991 with Jay Curtis, regarding the CIA and ISC.
ABC News/NightLine features it's second story about Lancaster's ISC and Arms to South Africa and Iraq.
July 18, 1991 -
U.S. Representative Robert Walker sends a letter to Stan Caterbone relating to his request for a Congressional
Investigation into all of his allegations of misconduct and criminal wrongdoing regarding his alleged ISC/Fraud "coverup".
The letter said :
"Thank you for your recent letter and information on International Signal & Control corporation. I appreciate
your thinking of me; however, since this case is before the courts, it is unethical for me to interfere with the
judicial process. If you think I may be of assistance with other matters, please feel free to contact me".
July 25, 1991 -
Christian is released from prison after serving two years and a day for his role in the Chem Con fraud and toxic waste
dumping.
August 1, 1991 -
Stan Caterbone receives a notice of a warrant for his arrest by the Stone Harbor (NJ) Municipal Court, regarding
summons #081370.
Stan Caterbone called the Court Clerk, Pam Davidson, to explain the circumstances.
The Court Clerk refused to identify herself, and did not have time to listen to his explanation. She then questioned why
he (Stan Caterbone) wanted to write to the Judge to explain.
Stan Caterbone writes a formal letter to Judge Peter M. Tourson, of the Stone Harbor Municipal Court explaining his
allegations of misconduct, and the issues surrounding his recent arrest of June 7th, and all of the arrests dating back to
Page 326 of 2301
Page
36
August of 1987.
Stan Caterbone had described in detail his assertions and evidence that the arrests were conveniently orchestrated while
he was seeking legal recourse for the alleged ISC "Cover-Up'.
Stan Caterbone also explained his fear for not returning to the Stone Harbor Municipality, in light of the fabricated
arrests, and other questionable incidents.
Stan Caterbone requested another means of settling all outstanding frivolous traffic violations, other than appearing in
Stone Harbor Municipal Court.
August 8, 1991 -
Stone Harbor Municipal Court Judge, Peter M. Tourison, sends Stan Caterbone an official letter acknowledging receipt
of his previous letter and explanations.
Judge Tourison concluded his notice by demanding that Stan Caterbone appear in Court, as scheduled, "to have this
matter taken care of in the proper manner
August 13, 1991 -
Ferranti announces it has recovered $650,000 hidden by Guerin in a number of Swiss Hank accounts.
Ferranti also announces a fiscal 1991 loss of $282 million.
Stan Caterbone responds to Judge Tourison letter of August 8, and discloses the recent attempt on his life, the past June,
just outside or Stone Harbor, and states that because of the apparent criminal conspiracy within the same municipality,
Stan Caterbone formally notifies the Judge that he refuses to return to Court, as requested.
August 15, 1991 -
Guerin and Cardoen are shown to have been deeply involved in a failed $100 million arms procurement plot linked to
the infamous Iran-Contra scandal.
August 16, 1991 -
Stan Caterbone receives a formal notice and demand from American Helix President David D. Dering, for the return or
equipment, currently in the possession of Stan Caterbone, and notice of the termination of the business agreement, dated
October 1, 1990 between Stan J. Caterbone and American Helix Technology Corporation.
Stan Caterbone receives a facsimile from Mike Hess (former ISC engineer who frequented S. Africa and who solicited
Stan Caterbone in late 1989 for work), and refuses to sign a non-disclosure agreement with Stan Caterbone and the
Advanced Media Group, Ltd., as requested to continue a further relationship considering the recent activities from the
May 23rd phone call and the national media publicity regarding the ISC Scandal.
August 19, 1991 -
Stan Caterbone sends a letter to attorney Timothy Lanza via the Lancaster Bar Association, and asks for an explanation
as to his misrepresenting to Stan Caterbone for the past month that his order for Advanced Media Group, Ltd., stock
certificates were ordered, when in fact Stan Caterbone verified with authorized personnel of the H. Burr Kein company
that the order was never placed.
Timothy Lanza had personally disclosed to Stan Caterbone on several occasions that he was awaiting the delivery of the
certificate kit via UPS.
Stan Caterbone responds to the previous letter of David D. Dering, and his request for the return of American Helix
equipment, currently in the possession of Stan Caterbone.
Stan Caterbone formally notifies David Dering that the equipment will be held as collateral, according to statutes of the
Pa. Uniform Commercial Credit code, that the equipment will not he returned until the past due invoice {# 1018), of the
Advanced Media Group, Ltd., of July 12, 1991 for $4,914.00, which was due upon receipt according to their business
agreement, was paid in full.
August29, 1991 -
A federal judge dismisses Christian's $93 million suit against Guerin, but Christian vows to re file the suit.
ABC News/Nightline features another story about ISC, the CIA, and Arms Deals, in preparation for the beginning of
the-Confirmation Hearings of George Bush's nomination or the Director of the Central Intelligence Agency, Robert
Gates, which begins just three days away, by the Senate Intelligence Committee.
Ferranti and Clark reach an agreement to settle their legal battle, although details are not disclosed by either party.
Page 327 of 2301

Page
37
The first day of the Robert Gates' Confirmation Hearings brings questioning by
Senator Morkowski, of the Senate Intelligence Committee, about knowledge of the ISC operations by Robert Gates.
Gates, whose candor about Iran-Contra resulted in his 1987 withdraw when nominated for the same slot by then
President Reagen. In a less-than sincere line of questioning, Robert Gates denies any knowledge of ISC, Guerin, or
Carlos Cardoen, including any operations to sell munitions to Iraq or south Africa. In addition, he denies any knowledge
of any CIA involvement in the same.
September 19, 1991-
Stan Caterbone visits the office of Senator Bill Bradley (D-New Jersey), in the Hart Office Building, Washington, D.C., and
delivers documents, tapes, and a video, all relating to his allegations of an alleged "Cover-Up" regarding the ISC
Scandal.
The materials were taken by assistant Jackie Widrow, who signed a receipt.
September 21, 1991-
Stan Caterbone delivers a contract for the consulting services he has agreed to provide to J. Oman Landis, in order to insure
against any wrongdoing, and especially in light of Mr. Landis' assertion the previous Friday that "you (Stan Caterbone)
are taking a break (from business) to rest your mind".
This assertion conveniently supports the alibi of mental insanity, that has been made by numerous persons, including Mr.
Landis' friends, the High's, who wholly own American Helix Technology corporation.
Several hours after delivering the contract to Mr. Landis, and after beginning to work, as outlined in the contract, Mr.
Landis called Stan Caterbone into his office and said "there were some developments over the weekend, why don't you
continue on your normal duties of driving (limousines), this has nothing to do with the contract that you asked me to
sign".
September 25, 1991-
October 1, 1991 -
Stan Caterbone mails a cover letter and accompanying materials to attorney Howard Corny, of New York city, as previously
discussed, via UPS regular way service.
Stan Caterbone receives a facsimile from David Dering, President of American Helix, formally charging Stan Caterbone
with charges of 16,730.00.
David Dering also demands that the equipment be returned, and upon receipt, American Helix would forgive $11,816.00
($16,730 - $4914)(Caterbone's invoice) of unpaid charges to Stan Caterbone and or the Advanced Media Group, Ltd.,
Stan Caterbone sends by certified mail, a copy of a recent complaint (filed Sep. 6, 1991) to the New Jersey Department
of Motor Vehicles, and a demand for the title to his boat, and again allegations of criminal wrongdoing by the Stone
Harbor Marina, for not delivering title, given the bill of sale was satisfied on June 10, 1991, and a fee for the title was
paid as well.
Stan Caterbone personally meets with Ted Koppel, of ABC News/Nightline, at the Washington National Airport, at
approximately 5:30 pm.
Stan Caterbone questioned Ted Koppel if he knew a Mr. Jay Curtis, and why he was questioned about the CIA's
involvement with the ISC affairs, just hours before the broadcast.
Ted Koppel denied any knowledge of Mr. Jay Curtis, and stated that Thomas Flannery was involved in the broadcast by
the Financial Times of London. The letter of August 28, 1987 to Diane sawyer was also mentioned. Ted Koppel
requested the phone number of Stan Caterbone, and said that he would contact him later, due to his present time
constraints, and asked "what do you want, and what is the story line?"
Stan Caterbone responded, "Justice and protection, someone is trying to cover me up, and someone already made
attempts on my life... someone keeps getting information from me, while I'm left sitting in Lancaster like a sitting duck".
October 2, 1991 -
Stan Caterbone responds by facsimile, to the Oct. 1, correspondence, to David D. Dering.
NOTES:
Stan Caterbone requested supportive documentation regarding the suspicious charges of $16,730.00 as declared, in order
to consider the request for the return of the equipment.
David C. Dering responds by facsimile, demanding for Stan Caterbone to meet him at the Holiday Inn, in Lancaster on
Friday, Oct 4th, with the equipment in his possession, and states that he will deliver the required supportive
Page 328 of 2301
Page
38
documentation of the charges as requested.

October 2, 1991 -
Stan Caterbone responds by facsimile to Ted Koppel, as to his question concerning the "story line"
October 27, 1991 -
Stan Caterbone writes a letter to Sandra Woods, Associate Managing Editor, of the Philadelphia Inquirer, regarding the
recent feature story, "What went wrong in America" Stan Caterbone describes his experience and present situation regarding the ISC scandal, and cites corruption as the
cause of the present dire and destitute circumstances controlling his life.
October 31, 1991 -
Guerin and 19 others, including Larry Reach, are indicted on 75 criminal counts by the Philadelphia based grand jury.
Laura McQueen, administrator for the New Jersey Department of Motor Vehicles, called Stan Caterbone at
approximately 3:30 pm, to notify him that she was trying to sort out the problem with his complaint regarding title to his
boat.
Ms. McQueen acknowledged that the Stone Harbor Marina had submitted an application for a title, apparently dated on
or about June 10, however the identity of the boat did not match that of for Stan Caterbones. Ms. McQueen also
admitted that there seemed to be evidence of wrongdoing, but denied to state whether the matter was presently being
investigated.
Ms. McQueen also stated that the title in question was being microfiche, and that within a few days, they should be able
to trace the title, and resolve the problem.
Robert Clyde Ivy, Terrance Faulds, Wayne Radcliffe, Gerald schuler, and Thomas Jaslin enter a not guilty pleas to all
charges handed down by the Philadelphia grand jury.
November 24, 1987 -
Robert Shireman, ISC financial executive pleads his guilt in the ISC $billion fraud and scandal.
November 25, 1987 -
Anthony Stagq, ISC executive in charge of Singapore operations, pleads guilty in the Arms Export violations.
November 27, 1987-
ISC Executive Larry Resch pleads guilty to his role in the massive contract fraud in the Ferranti/ISC merger of
November, 1987.
December 3, 1991 -
Philadelphia grand jury hands down a "superseding indictment", clarifying the money laundering portion of the
charges. The indictment states that between November of 1986 and June of 1989, Guerin looped $450 million through
phony bank, vendor, -and customer accounts to give the appearance several of the bogus ISC contracts were real. The
preceding information also allows for the possibility of an indictment of William Clark, and possibly his attorney Joseph
Roda.
The largest of the fake contracts was the Pakistan Missile deal, in which Larry Resch was charged and indicted by the
grand jury for managing.
Stan Caterbone's best friend in the whole world, little "Abbey Pflumm", shouts his name, "Taan", for the first time.
December 3, 1991
-Mike Hess, a former ISC engineer that also has done work for Stan Caterbone, visits
Stan Caterbone to deliver all materials in his possession which is the property of the
Advanced Media Group, Ltd.,
Stan Caterbone and Mike Hess engage in an argument when Mike Hess becomes annoyed at Stan Caterbones continued
caution and suspicion of Mike Hess's real motives and agenda for the relationship.
Stan Caterbone had witnessed several incidents of inconsistencies with the attitude of Mike Hess, with specific respect
regarding Stan Caterbone's efforts for justice and legal recourse concerning the affairs of 1987.
Stan Caterbone admitted in several occasions that he will never trust anyone, especially given his former association
with ISC, and most importantly his activities and travel to South Africa-
December 4, 1991 -
Stan Caterbone calls the Citizens Commission of Human Rights, after seeing the organization featured on the Murray
Povich Show, and talks to Roy Griffen.
Page 329 of 2301
Page
39
The organization's mission is to investigate abuses within the mental illness profession. Roy Griffen requests
information, and agrees to investigate his allegations. Stan Caterbone states that he will Federal Express a copy of this
chronology.
December 5, 1991 -
At approximately 10:00 am, Stan Caterbone sent a package of information via Federal Express (tracking number
9734766S93) to:
Roy Griffen
Citizens Commission for Human Rights
6362 Hollywood Blvd.
Los An~elos, CA
90028
(800) 869-2247
The package was received at 9:56 am (PST) by L. Mezkerlsl, at the front desk.
December 5, 1991 -
At approximately 4:52 pm, James Guerin pleads guilty to eitht (B) grand jury indictments of October 31. The
indictments are as follows:
* Criminal Conspiracy
* Violation, Arms Export Control Act
* Violation, Comprehensive Anti-Apartheid act.
* Money Laundering
* Securities Fraud
* riling False Income Tax Return
* Aiding and Abetting the Commission of crime.
Sentencing is scheduled for February 25, 1992, with a minimum of 14 years, and a
maximum of Life in prison.
December 4, 1991
Stan Caterbone receives uninvited visitors at his residence, cousin Sam Miller
family, who in September left him stranded in Florida. They conveniently need a place to stay, while visiting in
Lancaster, and purposely cause distractions to his efforts for legal recourse.
December 11, 1991-
Stan Caterbone finally requests that his residence be vacated by Michelle and Jason Miller.
December 20, 1991-
Stan Caterbone receivers a notice from the Internal Revenue Service regarding a discrepancy in income reported on his 1989
Federal Income Tax Return. The items in question were his "disability income" from Monarch life insurance and
American Helix "non-employee income".
December 23, 1991-
Stan Caterbone responds to the IRS letter and submits a copy of the chronology of this conspiracy, along with the entire
audio transcript (2 - 90 minute cassettes) of his meeting of September 29, 198? with the Pennsylvania Securities
Commission and requests assistance in his ordeal. The correspondence was sent via 'Return Receipt Requested" in order
to insure proof of delivery.
Stan Caterbone sends an updated chronology to Roy Griffen of the Citizen's Commission for Human Rights.
December 28, 1991-
Stan Caterbone sends a formal notice to attorney Howard Cerny, 245 Park Avenue, New York, informing him to return the
previously submitted information and tapes
regarding this case, and also informing him that he no longer wishes to
discuss these issues with him or any member of his firm.
December 30, 1991-
Stan Caterbone travels to the U.S. 9:50 am courthouse in Philadelphia, PA, and personally delivers the chronology and a
copy of the "1987" Pennsylvania Securities Commission meeting to Chief Judge Bechtle, who is presiding over the ISC
court preceding.
10:00 am
Stan Caterbone visits the U.S. Attorney Generals office in the same building and files a formal complaint, "Criminal
Conspiracy to "cover-up" the International Signal a Control scandal. The proper form is filed with the clerk.
Assistant U. S. Attorney General Gray asks Stan Caterbone to briefly describe his complaint. Stan Caterbone gives Gray
the chronology along with the tapes.
Stan Caterbone briefly describes the meeting of June 23, 1987 with Larry Resch, the nay 23, 1991 phone call from Jay
Page 330 of 2301
Page
40
Curtis, the arrests by Manheim Township, and the attempts on his life. Agent Gray took notes, and said he is not
familiar with the case, but would personally see that the information is passed to the proper authorities involved in the
case.
During the conversation, Mr. Gray asked the exact same question that was asked by both Joe Roda and Investigator
Eisler of the Pennsylvania Securities Commission)
"But you did not work for them (ISC), you were not involved with them?"
Stan Caterbone gave this response to all questions by Mr. Gray:
It's all in there (the chronology), all of the information and events".
Page 331 of 2301
Page
41
THE YEAR
1992
January 6, 1992 -
Stan Caterbone sends a copy of the criminal conspiracy chronology and a complete audio transcript of the PA SEC
meeting of 1987 to the legal counsel of the Pennsylvania Securities Commission via Certified Mail Return Receipt
Requested: P825 695 935.
January 8, 1992 -
At a "Town Meeting" in Columbia, Pennsylvania held by U. S. Senator Arlen Spector, Stan Caterbone personally
delivers a copy of the criminal conspiracy chronology to Anon Spector after the meeting and asks Arlen Spector to read
the letter, Mr. Spector replied, " I will do that".
January 9, 1992 -
Stan Caterbone receives the Return Receipt from the Pennsylvania SEC, signed by Sharon F. Heinspach on January 8,
1992.
Page 332 of 2301
Page
42
THE YEAR
1997
November 8, 1997
Stan Caterbone solicits Attorney Matt Samley, of the law firm of Xelkallis, Reese and Pugh, to provide a legal opinion
as to the circumstances involved in the cover up. Mr. Samley quickly asks if anyone had called Stan Caterbone about
the issues. Mr. Samley agrees to review the documents and will provide a legal opinion of any criminal and
prosecutorial misconduct.
November 23, 1997 -
Stan Caterbone delivers materials to Mr. Samley and also sends via Federal Express the same materials to Christina
Rainville, of Shnader, Harris, Lewis, and . With a letter requesting a legal opinion from Ms. Rainville.
December, 8, 1997 -
Ms. Pam Pflumm call Dr. Albert Shultz regarding the behavior of Stan Caterbone.
December 15, 1997 -
Stan Caterbone telephones Jim Christian to again confirm that he did not have knowledge of his meeting with Mr. Larry
Resch. Jim Christian began threatening Stan Caterbone from public disclosure of these issues, he said
you have to forget about it. Your life will be worse off than it is now, you better just forget it
Page 333 of 2301
Page
43
THE YEAR
1998
January 14, 1998 -
Stan Caterbone visits with Fr. Edward Lavelle for advice and guidance concerning his situation. Stan Caterbone only
asked that Fr. Lavelle call Mr. David Pflumm, and ask he and is key employees refrain from inflicting any additional
mental duress upon his person
Fr. Lavelle refuses unless he is told to do so by Dr. Al Shulz. He offers no further assistance.
1:00 pm
A few hour later, Stan Caterbone visits Dr. Al Shulz for his quarterly appointment. Immediately upon entering the
appointment, and before the plaintiff will speak any words, Dr. Al Shuclz will contemporaneously accuse the plaintiff
and declare:
Stan, you are very sick. You are not well! You need to take additional medications.
The recorded transcript will prove the horrid implications of these conversations.
February 20, 1998
The plaintiff is forced to vacate his position of Controller of Pflumm

Contractors, Inc., due to the purposeful and intentional infliction of mental duress, perpetrated as a direct reprisal against
the Plaintiffs rightful pursuit of due process of the law concerning all issues contained herein.
April 21, 1998
The Pennsylvania Department of Labor and Industry will again illegally deny the Plaintiff of his legitimate claim for
Unemployment Compensation Benefits, which again is an act of reprisal against his rightful pursuit of fair access to the
law, and his disclosures of the incidents contained herein.
The Pennsylvania Department of Labor and Industrys 1987 rulings against the Plaintiff have been also proven to be in
err, which conveniently and intentionally subjects the Plaintiff to financial hardship and mental duress, all purposefully
hindering the Plaintiffs right to access the law. The record of the plaintiffs claim for Unemployment Compensation
Benefits is corrupted.
Page 334 of 2301
Page
44
THE YEAR 2004

Dec 16, 2004
Plaintiff sends a complaint to Agent Sarsfield of the Pennsylvania Attorney Generals Office in Pittsburg regarding
illicit telephone activities:
December 15, 2004
Stan Caterbone
220 Stone Hill Road
Conestoga, PA 17516
Commonwealth of Pennsylvania
Office of Attorney of General
Bureau of Consumer Protection
Pittsburgh Regional Office
6th Floor, Manor Building
Pittsburgh, PA 15129
Attn: Ms. Shannon J. Sarsfield
Ref: Verizon Customer Relations, C-006142-2004
Dear Ms. Sarsfield:
I appreciate your review of the aforementioned file. I was also in receipt of the November 19, 2004 response of the
complaint from Verizon. For the record, I have made several previous attempts prior to the July 28th request to be place
on their Do Not Call list. I had made several calls in the previous months, and the calls did not stop.
My telephone has been used as a means of harassment and intimidation, with my calls often being intercepted,
misdirected, or impersonated. And often calls from Out of Area made several times a day, with no answer. If you
were to do an audit of my calls (in/out) over the last several years, you would reveal the nature of these activities.
Thank you for your efforts.
Sincerely,
Stan Caterbone
Page 335 of 2301

THE YEAR 2005
Feb 17, 2005
Plaintiff sends the following letter to the Chief of Police of the Southern Regional Police Department:
February 17, 2005 3:30 am
Stan Caterbone
220 Stone Hill Road
Conestoga, PA 17516
Chief John A. Fiorill
Southern Regional Police Department
3284 Main Street
P.O. Box 254
Conestoga, PA 17516
Dear Chief Fiorill:
It is quite unfortunate that you would engage your department in these matters, but that
was your choice, so you will have to see these matters through to their resolve.
As I have explained to the officer that so rudely awakened me at 2:20 am this morning, I
was driving by the Pflumm residence when I noticed a 4-wheeler making donuts in their
pasture. I slowly drove up the driveway to make sure that it was not someone that did not
belong there. I asked if Abby was home, and they said yes, and I immediately went on
my way. You should read my complaint filed this past Sunday to better understand who
is telling the truth regarding these incidents. And after your officer boldly threatens me
with filing charges for harassment for contacting any member of the Pflumm family, Pam
calls me during my conversation with your officer. How ironic.
One issue that I do take seriously is the issue of my mental state of mind. And your
officer questioned that, so I will have to defend my opinions, actions, and the truth.
Accompanied you will find 2 documents that clearly explain my position and the issues at
hand. The document concerning Pflumm Contractors will clearly raise questions as to
why these allegations of my state of mind are again being challenged by the very same
people that did the same thing in 1998. The other document I provided to give you a
clear understanding of the issues that your officer questioned.
As to the involvement of Federal Law Enforcement agencies, you will have to draw your
own conclusions or make your own inquires. I will not say anymore regarding the same.
I am hereby demanding a full account of all complaints that I have filed while living at
this address. I dont care how you do it, or how long it takes. Do you understand?
I find it quite disturbing that after my home is constantly illegally entered on a consistent
basis, that you would send an officer to my door at 2:00 in the morning to threaten me
after I was just making sure that no one was on the Pflumm property that did not belong
there. This is just so unfortunate for your department.
I do appreciate you and your officers help regarding these matters.
Respectfully,
Stan Caterbone
Page
45
Page 336 of 2301

Approx 1:00 pm
Page
46
Plaintiff meets with Michael Landis, County Detective for Lancaster County, in his office at the Lancaster Courthouse to
discuss J. Karpathious and death threats and the Southern Regional Police Department. Plaintiff sends email to Michael
Landis and a copy of the 1998 Affidavit in the email. Supreme Court announces plans to review Lambert Appeal the
next day.
Dear Mr. Landis,
Thank you for taking the time to meet with me yesterday. I appreciate your time. I understand your frustration in trying
to understand the circumstances regarding my situation. I have enclosed a document which I authored in 1998 to help
you.
Also, if you could, maybe you could help to facilitate my application for food stamps with the County Assistance Office.
I would appreciate it.
Have a nice day.
Respectfully,
Stan J. Caterbone
Page 337 of 2301

Feb 18, 2005
Page
47
Plaintiff sends the following letter to the Chief of Police of the Southern Regional Police Department:
February 18, 2005
Stan Caterbone
220 Stone Hill Road
Conestoga, PA 17516
Chief John A. Fiorill
3284 Main Street
P.O. Box 254
Conestoga, PA 17516
Dear Chief Fiorill:
I am very disappointed in the way that our meeting had ended. I will be filing complaints
With the appropriate authorities concerning the threats and abuse by Officer Busser.
Remember you had requested that meeting. And as you stated, I do not believe anything
that you say, well Sir, that is certainly your choice, however I have never provided
anything but the truth to you or any member of your department.
The burden of proof to my allegations falls within your jurisdiction. If you are telling me
that I have to prove every allegation when I report a crime, I just dont know how that is
possible. But you are the Chief of the department, so I guess I will have to protect my
person and property in any manner that deems appropriate.
I apologize for becoming loud and frustrated, however when you tell me that I am lying
and I am most certainly telling the truth; and then you and Mr. Busser yell that I am nuts
and to get out of here; and that no one will respond to any of my calls to your office,
well we have a very serious problem.
You both have challenged my integrity, my truthfulness, credibility, and my sanity.
And Mr Busser pulling out his night stick and holding it up to hit me, that is more than
enough for me.
I get the picture loud and clear. I hope that you do as well.
Respectfully,
Stan J. Caterbone
Cc: Donald Totaro, Lancaster County District Attorney
Feb 19, 2005
Plaintiff files the following complaint with the The Internet Fraud Complaint Center (IFCC) after the incident of Kerry
Egan calling 911 to file a false report of plaintiff sending an email stating to kill himself.
Saturday, February 19, 2005
Stan Caterbone
220 Stone Hill Road
Conestoga, 17516
The Internet Fraud Complaint Center (IFCC) is a partnership between the Federal
Bureau of Investigation (FBI) and the National White Collar Crime Center (NW3C).
February 19, 2005 7:26 am
At approximately 5:00 am this morning the Conestoga Police entered my home and
accused me of sending an email to Kerry Egan threatening to kill myself. The officer
verbally and physically abused me because I did not know what he was talking about
and he kept interrogating me and handcuffed me because I said that I was not on
the internet after 10:00 pm on February 18, the evening before.
The officer told me that I sent an email to Kerry Egan and she called 911 at
approximately 5:00 am this morning. I told the officer that I did I fell asleep at
Page 338 of 2301
Page
48
approximately 1:00 am and did not awake until the officer arrived at my house.
The officer was quite abusive and tried to accuse me of lunging at him, when in fact
he was throwing me around. Pam Pflumm, who previously filed trespass charges against me, and whom I was to have
no contact with, illegally entered my home with the officer, via a key which I
had kept on the deck. Before they entered my home, I called 911 and requested that the Pennsylvania
State Police come to my aid because of the verbal and physical threats that I
received earlier in the day from Officer Busser and Chief of Police Fiorill of the
Southern Regional Police Department. After they had left, I took a shower and almost collapsed from exhaustion and
trauma. I got dressed and went to the emergency room of Regional Hospital, former
Saint Joseph Hospital. Dr. Laird attended to my concerns.
Feb 20, 2005
Plaintiff calls Southern Regional Police Department and Humane League to file formal complaint of Cruelty to Animals.
Both refused to investigate or file any reports. Complaint phoned in to the Humane League on Feb 20, 2005 As
described to a Letter To The Editor, Gil Smart
While I was away for a family emergency, I had someone let my two cats out after being inside for a few days, which I
have always done in the past. I returned after being in South Florida for one week. Upon driving toward my driveway,
my one cat was anxiously awaiting my arriveal. However, my second cat was not there. This was immediate cause for
concern, since being mother and son, they had always stuck together. After a few days I knew that my cat was either
abducted or was harmed. No way would he be around and not come home.
The other evening I went over to my suspect neighbors home, whom I know often has been mischevious toward my
property in the past, and asked him if he saw my cat. He went on to tell me how big my cat is and how he is the "king of
the neighborhood". I found this conversation to be typical bull.... He said "don't worry it will show up soon!"
Last evening I found my dead cat lying by my pond with a possom chewing on its ear. I examined the body and found
that it's neck had been broken with no other signs of any other wounds.
I called the Humane Shelter and talked to a Cruelty Officer who said" There is nothhing we can do if you did not see
anyone physically harm the animal"
Is this the way it is? You have to prove a crime before they will investigate? Sounds alittle backwards to me, but then
again I often forget where I am at.
Feb 21, 2005
Plaintiff sends letter to Fulton Bank regarding the death of Thomas Caterbone and the alleged indiscretions and
illegalities of the activities of Fulton Bank.
Monday, February 21, 2005
Project Hope
Mr. Stan Caterbone
220 Stone Hill Road
Conestoga, PA 17516
Mr. Scott Smith
Fulton Financial Corporation
One Penn Square
P.O. Box 4887
Lancaster, PA 17604
Dear Mr. Smith:
The reason I had called you on Friday morning was to discuss an outstanding issue with you. I am not threatening you
or coming to you as an adversary, but rather just trying to understand how your institution can be so cold and rude to
my family. On Thursday I visited the Manor Branch to discuss the account for Tom's Project Hope, our non-profit
foundation which advocates awareness for suicide prevention, with a focus for teenagers. Of course this foundation was
founded after the suicide of my youngest brother, Tom, in 1996.
Page 339 of 2301
Page
49
Well, I never had so much trouble trying to gain access to our account's statements than I did on that day. All that I
heard was how much I would have to pay to get copies of the statements. Which in itself is a little disheartening,
considering we are a non-profit giving something back to the community. We are a major donor for CONTACT
Lancaster. And it is this attitude that inspired me to address the very reason Tom's Project Hope was unfortunately
founded.
I had asked the Customer Service person what would happen if I made an attempt to deposit a check in an account that
did not have funds available at that time. She said "we have to give you the choice to deposit the check or wait until
there are funds". I said are you sure, she said "oh yes, you have the choice to make the deposit or not". I said that is
what I thought was the policy or rule.
In 1996 my brother, Tom, had his accounts with your bank. He was given a check in the amount of approximately
$60,000 by an account from Ms. John Depatto. Forgive me but I do not have the energy to retrieve all of the details at
this time. My brother went to the Manor Branch to deposit that check, and was refused on at least 3 occasions from
making that deposit. I know this because he was calling me asking for advise and help. I remember telling him to seek
legal counsel because this was not right. Your tellers refused to take the check for deposit because there were no funds
available. I kept telling him that this was wrong and that he should make the deposit incase funds became available the
check would be honored. But your tellers kept refusing to make that deposit.
I then went on to learn that funds did become available and were paid to other entities that had NSF checks waiting for
funds, which would have been behind my brothers check had your tellers accepted that deposit.
If you carefully review the financial problems my brother encountered prior to his death, you would see that this was the
one transaction that started a spiral of events that caused him a great amount of stress and duress. And I know this
because I was trying to help him. I eventually took him to the emergency room of St. Joseph Hospital just 4 days prior to
his death.
Now, Sir, you tell me how you would feel if you were in my position, and what would you want to happen. I have kept
this to myself for far too long, and since I have had my own problems with your institution in a similar way back in 1987.
I would like to understand why we are treated like this, and ask that these matters be addressed.
Put yourself in my position, would you want anything less?
This is for my brother, Tom, God rest his soul.
Respectfully,
Stan J. Caterbone
Project Hope
Page 340 of 2301

Feb 22, 2005
Page
50
Plaintiff sends email to Lancaster District Attorney Donald Totaro after Supreme Court announces Lambert Case is
being reviewed by the Supreme Court of the United States, one day after Plaintiff reviews affidavit for the first time in 7
years.
Dear Don:
Just so there are no misunderstandings, I have never had, nor do I have now, any information regarding the Lambert
proceedings. I have never spoken to anyone concerning the same. I am very suspect as to the timing of this
announcement and find it very disturbing given the document that I had innocently resurrected after 8 years. My only
intent in writing that document was to find resolve for my own tragic situation.
I believe a jury trial would have been the only fair way for an equitable resolution to this case. Had that occurred in the
beginning, I don't believe we would be confronting this issue today. I meant no disrespect toward your office or that of
the state. As far as the police, it is the same, except that I was very angered at the few that have treated me with such
malice, which is in no way a condemnation for the men in blue. I was literally fighting for my life, and still continue to
this day.
Respectfully,
Stan J. Caterbone
Feb 26, 2005
Plaintiff sends letter to President Bush and White House staff addressing concerns regarding National Security Issues
and this case and receives positive signal to proceed to court.
Iraq
National Security
To: President George W. Bush
From: Mr. Stan Caterbone <amgroup01@msn.com>
Subject: Write a Supporting Comment on National Security (Iraq)
Dear President Bush:
Dear President Bush:
I need to know if any information contained herein compromises the
security of the United States of America. I have been getting mixed
signals as to this question, and my life has been constantly
threatened because of this document. I would submit to a polygraph
to verify the credibility of any of the facts contained in this
document. I was the sole author of this writing back in 1998.
If you believe that this document does threaten our Nationa Security,
I would like to personally deliver the accompanying information
assets to yourself or the National Security Agency upon request.
If you believe that this document does not compromise the National
Security in any manner, then I would ask that you uphold my civil
liberties in continuing my efforts to adjucate these matters and find
an opportunity for remedy in the appropriate court of law.
I remain,
Stan J. Caterbone
Page 341 of 2301

Mar 14, 2005
Page
51
Plaintiff files complaint to the American Civil Liberties Union of Philadelphia, PA after the Intake Director directed
plaintiff in filing protocols.
March 14, 2005
Stan J. Caterbone
220 Stone Hill Road
Conestoga, PA 17516
American Civil Liberties Union Of Pennsylvania
Philadelphia, PA
intake@aclupa.org
Re: Complaint
I have had many persons levy attacks and harassment upon me with explicit statements defaming my character and
slandering me with such statements as calling me "insane, crazy and nuts". I have been abused, both emotionally and
physically, which are a matter of record, by the Southern Regional Police Department, formally the Conestoga Police
Department. I have had several fabrications and false reports concerning alleged suicide attempts, all of which have
been proved to be total lies. There has been total disregard for my civil liberties and numerous violations of my civil
rights. All of these incidents are intended to provoke and illicit the very same behavior they accuse me of; that of being
mentally unstable.
The reason for this is simple, to discredit my allegations and to prevent me from taking legal action and to block access
of due process against the private and public entities of the County of Lancaster, and the Commonwealth of
Pennsylvania. These attacks, harassment, and intimidation began in June of 1987 and continue today. In the last several
weeks, in the matter of 4 days, I was detained and abused by Police in the middle of the night on 2 different occasions.
At 4:00 am one morning a person called 911 and reported that I had emailed a message threatening to commit suicide,
proven to be a lie. I had a Police Officer raised his nightstick and threaten to hit me while he was in a violent rage, only
to have another officer take step in and disarm him. I have had the Police literally break into my home, because I would
not open the door, for fear of my safety after being abused the previous day. The officer handcuffed me and shoved me
around because I would not admit to wanting to kill myself. In the last several weeks I have had no less than 6 persons
attack my mental stability and in an effort to break me emotionally.
In 1987 I had made public allegations of fraud against a Defense Contractor, International Signal& Control (I was a
shareholder), after a meeting in which they wanted me to finance some questionable activities. From that meeting
forward, these illicit and malicious acts have been occurring quite frequently. It cost me money, financial opportunity,
friends, time; and everything imaginable except my life. And there was at least one attempt on that. In 1987 ISC was in
the midst of a multi-million dollar merger with the British Defense Contractor, Ferranti International. My allegations
caused grave consequences to that deal. Four years later executives of ISC were indicted for the "largest fraud in U.S.
history" $1 Billion dollars, and for exporting arms to Iraq by way of South Africa.
In 1987, when I made these allegations, I was making the first digital movie, ironically, I received the original patent
research materials days after that meeting with ISC, from a prominent patent law firm in Philadelphia. I have been
arrested at least on 6 occasions, and the most outlandish, for stealing my own files from my own office. I have spent 6
days in prison. I have been taken to the Hospital on 2 occasions, and have been detained by police on several other
occasions for persons making false claims that I threatened to commit suicide. I have never been convicted of any crime,
and all charges are conveniently discharged before any court proceedings. All charges of suicide have been proven to
be false allegations and fraudulent false reports. In the last week, I had obtained my medical records from the Regional
Medical Center, while I was maliciously and fraudulently admitted there after my arrest in 1987, and there are 3 reports
from 3 different psychiatrists which all reveal that there was never any attempt by anyone in the Hospital administration
or medical staff to validate any of my statements; which in and of themselves were used to indict me and support the
diagnosis of manic depression. Of, course, all of my statements were true, which all are methodically proven in the
following supporting documents.
I have had my airplane, loaded with all of my files, repossessed in the middle of the night by the Common National Bank
of Lancaster (Mellon), before any payments were due. This happened immediately after my meeting with International
Signal & Control, in 1987. I was trying to find safe haven in Stone Harbor, New Jersey, where we were making a movie.
Tony Bongiovi, of Power Station Studio in New York, had solicitedme to help him produce the 1st Digital Movie, again
in 1987.
I have been precluded from any seeking any kind of remedy in the courts due to the sensitive nature and involvement of
National Security issues. It has been reported that the CIA and National Security Agency were all involved in covert and
possibly rogue activities with ISC and the export of arms to Iraq (Cluster Bombs). This was one of the questions that
Robert Gates had to answer in his Confirmation Hearings for Director of the CIA in 1990 by the Chairman of the
Page 342 of 2301
Page
52
Committee (I have the CNN video). There was also a "Presidential Finding" that was said to be filed by then President
George H. Bush regarding the same.
The following are supporting documents and complaints that I filed and are forwarding to you:
Police letter of Feb. 17, 2005
Police Complaint of Feb. 18, 2005
IFCC FBI Complaint of Feb 19, 2005
1998 Affidavit of 1987 Complaints
I also have over 10,000 documents, several hours of taped conversations and videos to support the above matter.
Thank You For Your Assistance In Advance.
Stan J. Caterbone
Page 343 of 2301
Page
53
March 23, 2005

Email to Phillip Wenger
President of Fulton Bank
Lancaster, PA
Phil:
For the Record1. The Project Hope Account; Project Hope was founded in 1996 with it's mission stated in its non-profit organization charter to raise funds for the
intention of contributing to the education and awareness of mental illness and suicide prevention. Since it's inception, I was the sole administrator of
all monies that were dispersed and donated to various local organizations to further that cause. These relationships included; The Lancaster County
Mental Health Alliance, The Schreiber Pediatric Center, Contact Lancaster. I also was responsible for the local production of the video "Numbers
Don't Lie" (educational video for teenage suicide prevention) and distributing that video to a host of local schools, churches, and faith based
organizations. Since about 2001, Project Hope has not made any contributions from it's account, while at the same time continuing to raise funds from
the annual golf tournament. In excess of $9,000 was accumulated. Every year I questioned Phil and Mike about the contributions and what
organization they were going to give the money to. In December of 2004, Lois Gascho, Executive Director of Contact Lancaster, personally called me
asking if we could help her with some money. At that time, her affiliation with the League of Churches had been terminated and Contact Lancaster
was without funding, and the 24/7 Suicide Hotline for Lancaster was at risk of being shut down. I told her I would contact my brothers and get her
some help. There was an article in the Lancaster Newspapers about the funding problems and I emailed Mike, Phil, and Jimmy Karpathious the article
and message that Lois called me asking for help. Nothing was done.
I kept trying to tell them that they were not operating the Project within IRS guidlines, and their non-profit tax-exempt status was in jeopardy for not
distributing the monies accumulated, as required in the IRS regulations concerning the same.
When I was down at Mike's last month, I found the account statements for Project Hope and being that I am a Signatory on the account, took the entire
file with me and started to disperse the monies. I made one check out to Lancaster Contact for $2500. When I met with Lois Gascho of Contact
Lancaster to give her the check, she wanted to give me a tour of the facility where the suicide hotline operates. While visiting, she was saying how
difficult it is to find volunteers to staff the hotline. I suggested that I could design systems, with technology, that could allow volunteers to staff the
hotline while working from home. This would help Contact Lancaster a great deal in attracting more volunteers to help staff the hotline. Remember,
the hotline is located downtown, and volunteers must come and go during all hours of the night to staff the hotline. I designed a conceptual system
and called D&E Communications to provide a proposal to provide the required software and telecommunications technology to build the system. I
expect to receive that proposal on Friday.
I will be making a legal challenge to gain control of that account with the Internal Revenue Service and the Tax-Exempt status of the Project.
2.
Fulton Account When my Mom got sick while in Florida, it was determined, by her, that she could not live alone anymore. Our house at
1250 Fremont Street was in dire need of painting and other maintenance for sometime. I told my mother that I was going to do these tasks
now, incase we have to sell the house. They house is 2 stories, which is more difficult for my mother to live in. In January I decided that I
would make sure the house is ready to put on the market by springtime, and if we decide not to have to sell the house, it would be already
done and could be sold at anytime without any repairs needed. At the same time, I setup the Fulton Account with online banking so that I
could manage my mothers bills, and pay them from Lancaster without having her try to take care of this herself. My mother memory has
been a deteriorating problem since the fall of last year. To give you an example, while in Florida last month, I was taking my mother out for
breakfast, we were driving around looking for a restaurant, and she looked at me in the car and asked if we had eaten yet! She agreed that it
would be best that I manage her bills, hence the Power of Attorney for the Fulton Account and online banking.
The $2,000 transfer was for the renovations at 1250 Fremont that I am currently doing. I will now fund that project myself, because I do not want to
be bothered with this at a later time.
So, there you have the truth about the accounts. So be it.
Page 344 of 2301

Apr 26, 2005
Page
54
Plaintiff files complaint in the Court of Common Pleas, Lancaster, Pennsylvania against Drew Anthon and the
Eden Resort Inn.
IN THE PENNSYLVANIA COURT OF COMMON PLEAS, LANCASTER
COUNTY, PENNSYLVANIA
PROJECT HOPE/ADVANCED MEDIA GROUP
220 Stone Hill Road,
Conestoga, PA 17516
County of Lancaster, Pennsylvania :
:
V. :
:
Drew Anthon, Eden Resort Inn and Conference
222 Eden Road
Lancaster, PA 17601
: CIVIL ACTION
: NO. CI-05-03644 Apr 26 pm 4:55
:
STATE OF PENNSYLVANIA :
:
COUNTY OF LANCASTER : ss
I, Stan J. Caterbone, representing Project Hope and the Advanced Media make the following civil
complaint against the defendant, Drew Anthon and Eden Resort Inn and Conference Center:
Plaintiff alleges Drew Anthon and the Eden Resort Inn and Conference Center has colluded to
sabotage the Downtown Lancaster Convention Center project by organizing a formal request and
and soliciting support to certain Lancaster County Hoteliers to voluntarily withhold the payment of
the Lancaster County Hotel Room Tax, thereby placing the financial interests of the Business Plan
for the Excelsior Property of East King Street and the Rights to develop a UPS Store in or around
the Downtown Lancaster Convention Center at extreme risk.
Plaintiff will argue that such financial risk is causing mental stress and duress, that otherwise wouldnot be present, had
the defendant not engaged the above-mentioned activities.
Plaintiff seeks the Commonwealth of Pennsylvania to place a cease and desist order against the
defendants actions to withhold the Hotel tax until the defendants can prove to the Commonwealth thesaid actions are in
the best interests of the Plaintiffs interests and those of all major stakeholders of the proposed Downtown Lancaster
Convention Center, including the School District of Lancaster, the City of Lancaster, the County of Lancaster, Penn
Square Partners, as well as others. Thus the defendants must prove that the Downtown Lancaster Convention Center
will fail.
Plaintiff submits the following exhibits for considerations of the Courts:
The major pages of the website of Advanced Media Group
The Excelsior Place Business Plan
The Agreement Between Art Ward, Owner of the UPS Store and Stan Caterbone
Plaintiff seeks a jury trial with damages in excess of $10,000.
Stan J. Caterbone/Project Hope/Advanced Media Group
May 2, 2005
Plaintiff files a complaint with Capital Blue Cross

May 2, 2005
Stan Caterbone
220 Stone Hill Road
Conestoga, PA 17516
Capitol Blue Cross
Adult Basic Program
P.O. Box 777014
Harrisburg, PA 17177-7014
Page 345 of 2301
Page
55
Re: Policy H200460959 & Policy Laps

As per my meeting in with your customer service representative on Friday, April 29th, at your home office in
Harrisburg, this is a letter of appeal for the lapsed policy and also a letter containing the complaints concerning the
charges from the Lancaster Regional Medical Center and Dr. Laird, the attending emergency room physician, on
February 19th, 2005, as per the request of the customer service representative.
1)
As per the lapse in policy, I was told by Kay Richmond, of Cash Processing Services (717-541-7262) on
several phone calls that there was a 30 day grace period. She had told me that although it is not stated, there
is a 30 day grace period for your policy. I had called because my mail has been tampered with, and I
questioned the rule of no grace period, and the policy being dependant on Blue Cross receiving my payments
via the mail. If this person who misrepresented herself to me as a representative of your company was not who
she said she was, this would certainly not be the first time. Enclosed you will find a complaint that I filed with
the Agent Shannon J. Sarsfield, of the Pittsburg Regional Office of the PA Attorney General. In that complaint
I stated, My telephone has been used as a means of harassment and intimidation, with my calls often being
intercepted, misdirected, or impersonated. See the enclosed copy of the complaint.
2)
As per my reason to visit your home office on April 29th, to discuss the charges from the emergency room visit
on February 19th, I have enclosed all relevant documents for your use in determining the validity of the
charges from both Regional Medical Hospital and the emergency room physician, Dr. Laird.
Please direct any and all communications to me at the above address or amgroup01@msn.com, or phone 717-380-5903.
Respectfully,
Stan J. Caterbone
Page 346 of 2301

May 6, 2005
Page
56
Lancaster New Era and Intelligencer Journal Report on Project Hope/Advanced Media Group v. Drew Anton.
Businessman, irked by hotelier action, files suit
By Justin Quinn
Intelligencer Journal
Published: May 06, 2005 9:47 AM EST
LANCASTER COUNTY, PA - A local businessman filed a $100,000 lawsuit last month against Drew Anthon, owner of
Eden Resort Inn and Conference Center, claiming Anthon "colluded to sabotage" the proposed Lancaster County
Convention Center by announcing his intention to withhold the county hotel room tax.
Conestoga resident Stan J. Caterbone is asking that a local judge place a "sees (sic) and desist order" on Anthon and
the hotel to prevent them from withholding the room tax.
The suit was filed April 26, the day the Intelligencer Journal reported Anthon and several other hoteliers were
threatening to withhold payment of the room tax, most of which goes toward a hotel and convention center proposed for
Penn Square. The next room tax payment is due May 26.
Caterbone is founder of Advanced Media Group, 1857 Colonial Village Lane, an information technologies company
specializing in optical publishing. He claims in the lawsuit that Anthon's actions place "at extreme risk" Caterbone's
plans to develop a UPS store and an office complex called "Excelsior Place" across from the proposed convention
center.
"Plaintiff will argue that such financial risk is causing mental stress and duress that otherwise would not be present, had
the defendant not engaged (in) the above-mentioned activities," Caterbone says in the suit.
The suit asks for a court order to force the hoteliers to pay the tax "until the defendants can prove to the commonwealth
the said actions are in the best interests of the (plaintiff) and those of all major stakeholders of the proposed downtown
Lancaster convention center, including School District of Lancaster, the City of Lancaster, the County of Lancaster,
Penn Square Partners, as well as others. Thus, the defendants must prove that the downtown Lancaster convention
center will fail."
A person who answered the phone at the number listed in the lawsuit as Caterbone's did not identify himself.
"All the information is public," the man said when asked about the suit. "You can go there."
As exhibits, the lawsuit includes Web pages from Caterbone's company and a bound volume titled "The Excelsior Place
Business Plan." The suit also includes a handwritten agreement between Caterbone and Art Ward, owner of the UPS
Store.
Anthon did not return a reporter's phone calls.
A judge has not been assigned to the case.
In another legal front, the owner of Mulberry Art Studios filed a petition with the state demanding it not release funds to
project developers.
Planners have applied for tens of millions of state dollars. They project the state's contribution to be $46 million if all of
their applications are approved.
Earlier this week, studio owner April Koppenhaver asked state officials to consider that two lawsuits related to the
project are undecided and could upend project construction.
Page 347 of 2301
Page
57
Koppenhaver brought one of the suits against the redevelopment authority. Another pits Mayor Charlie Smithgall
against City Controller R.B. Campbell.
"It is imprudent in my judgment for the state to release money to this project," Koppenhaver said. "I want (the state) to
be very, very aware and responsive to residents' concerns."
Penn Square Partners is composed of general partner Penn Square General Corp., a High Associates affiliate, and
limited partners Fulton Bank and Lancaster Newspapers Inc., publisher of the Intelligencer Journal, Lancaster New Era
and Sunday News.
Staff writer Dave Pidgeon contributed to this story.
Justin Quinn's e-mail address is jquinnlnpnews.com.
Page 348 of 2301
Page
58
June 2, 2005
220 Stone Hill Road
Conestoga, PA 17516
Judicial Conduct Board
RE: Commonwealth of Pennsylvania v. Stanley J. Caterbone
District Court 02-2-06
Docket Number NT: 0000132-05
Commonwealth Court of Common Please
Appeal Docket No. CP-36-SA-00000141-2005
Explanation of Complaint
1.
2.
3.
4.
5.
6.
7.
Previous to hearing, I entered the offices of the District Magistrate and requested a meeting with him to review the rules for procedure for
his courtroom. He belligerently yelled at me and told me that I will determine who is guilty in this case and threw me out of his office.
I immediately contracted the Lancaster County Court Reporters (LCCR)service to record the hearing.
I requested and paid a service fee to have 4 witnesses subpoenaed for my defense. Prior to the start of the hearing, the District Magistrate
never gave me an opportunity to explain the reason for calling my witnesses, and collectively dismissed all of my witness without an
opportunity for me to explain how they were involved with this case. During the brief discussion that was on the record, the District
Magistrate intimidated and threatened me with court sanctions when I tried to explain how the witnesses did have personal knowledge
regarding the case. Two of the witnesses were officers of Lancaster County and were called by me to investigate a crime, in which both
refused.
At the conclusion of the hearing the District Magistrate threatened me with offensive language again with court sanctions for merely trying
to understand why he was violating the rules of conduct and the rules of procedure for the Commonwealth of Pennsylvania.
A few days after the conclusion of the hearing, I entered the offices of the District Magistrate to pay for the fines and penalties sanctioned by
the court. I first, asked whether I would have to pay before I entered my appeal to the verdict. They refused to provide any explanation,
other than you will have to get an attorney, we cannot answer that question. I immediately paid the fines knowing that I would appeal the
case.
After receiving the transcript for the LCCR, I found a blatant lie in the transcript. When asked whether a witness had personal knowledge
about the case, the transcript reads NO. Now before I subpoenaed my witnesses, I reviewed the rules of procedure and was
knowledgeable of the rules for personal knowledge of a witness, and would not have answered no to that question because they did have
personal knowledge.
The District Magistrate was intimidating me and obstructing justice by trying to deter me from filing CIVIL ACTION NO. 05-2288 IN THE
UNITED STATES COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA, which I filed on May 16, 2005.
The case
was filed with a Motion to Seal on the same day.
Page 349 of 2301
Page
59
PRIVATE
COMMONWEALTH OF PENNSYLVANIA COUNTY OF:
CRIMINAL COMPLAINT
Magisterial District Number:
02-2-06
. Leo Eckert, Jr.
MDJ Name: Hon
COMMONWEALTH OF PENNSYLVANIA
VS.
831 Stehman Road
DEFENDANT:
Address:
NAME and ADDRESS
Millersville, PA 17551
()
Telephone:
Thomas D. Grassel
Docket No.:
91 Hilltop Drive
06/13/05
Conestoga, PA 17516
Date Filed:
OTN:
(Above to be completed by court personnel)
(Fill in defendant's name and address)
Notice: Under Pa.R.Crim.P. 506, your complaint may require approval by the attorney for the Commonwealth before it can
beaccepted by the magisterial district court. If the attorney for the Commonwealth disapproves your complaint, you may
petition the court of common pleas for review of the decision of the attorney for the Commonwealth.Fill in as much information as
you have.
Defendant's Race/Ethnicity
Defendant's Sex
Defendant's Social Security Number
Page 350 of 2301
Defendant's SID (State Identification Number)

Defendant's D.O.B.
White
Black
Female
Male
Native American
Asian
Unknown
Hispanic
Defendant's Driver's License Number
Defendant's A.K.A. (also known as)
Defendant's Vehicle Information
State
Registration Sticker (MM/YY)
State
Plate Number
I,
(Name of Complainant-Please Print or Type)
do hereby state: (check appropriate box)
I accuse the above named defendant who lives at the address set forth above
1.
I accuse the defendant whose name is unknown to me but who is described as
I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I have
therefore designated as John Doe
Wagon Wheel Restuarant, Main St., Conestoga, PA
with violating the penal laws of the Commonwealth of Pennsylvania at
(Place-Political Subdivision) Millersville
in
County on or about
Page
60
Page 351 of 2301
Lancaster
June 10, 2005 0800 GMT
Participants were: (if there were participants, place their names here, repeating the name of the above defendant)
Thomas D. Grassel
AOPC 411A-05
1-2
Page
61

Page 352 of 2301
Findings Of Facts Resulting In Chapter 11 Bankruptcy

Page 62 of 67
of
(Continuation
No. 2)
Defendant's Name: Thomas D. Grassel
PRIVATE
CRIMINAL COMPLAINT
Docket Number:
The acts committed by the accused were: (Set forth a summary of the facts sufficient to advise the defendant of the nature of the offense
charged. Acitation to the statute allegedly violated, without more, is not sufficient. In a summary case, you must cite the specific section
and subsection of the statute orordinance allegedly violated.)
2.
Defendant did knowingly and willingly block plaintiffs access to the door to exit storein an attempt to intimidate and harrass, and after
plaitiff tried to avoid the defendant andexit the doorway, defendant did engage in an illegal sexual act by grabbing and squeezingthe
defendants buttocks with an inappropriate gesture with the defendants finger whilesqueezing. This lude act was in the strictest violation of
Pennsylvania statutesconcerning sexual harrasment. Witnesses were present both behind the checkoutcounter and waiting in line at the
checkout counter.Plaintiff requests the Commonwealth of Pennsylvania to prosecute the defendant to thefullest extent of the law.
All of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act ofAssembly, or in violation
of
and
(Subsection)
(Section)
of the
(PA Statute)
I ask that process be issued and that the defendant be required to answer the charges I have made.
3.
I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information andbelief. This verification
is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa.C.S. 4904)relating to unsworn falsification to authorities.
4.
June 11, 2005
Date
Signature of Complainant
Office of the Attorney for the Commonwealth
Disapproved because:
Approved
(Name of Attorney for Commonwealth-Please Print or Type)

Page 353 of 2301
(Signature of Attorney for Commonwealth)

(Date)
AND NOW, on this date
, I certify that the complaint has been properly completed and verified.
SEAL
(Magisterial District)
(Issuing Authority)
AOPC 411B-05
2-2

Page 63 of 67

Page 354 of 2301

Page 64 of 67
COMMONWEALTH OF PENNSYLVANIACOUNTY OF:

CIVIL COMPLAINT
PLAINTIFF:
Magisterial District Number:
02-2-06
NAME and ADDRESS
. Leo Eckert, Jr.
MDJ Name: Hon
220 Stone Hill Road
831 Stehman Road
Address:
Conestoga, PA 17516
Millersville, PA 17551
VS
DEFENDANT:
NAME and ADDRESS
Thomas D. Grassel
91 Hilltop Drive
Conestoga, PA 17516
Docket No.:
June 13, 2005
Date Filed:
DATE PAID
AMOUNT
Pa.R.C.P.D.J. No. 206 sets forth those costs recoverable by the prevailing party.TO THE DEFENDANT: The above named plaintiff(s)
asks judgment against you for $
together with costs
upon the following claim (Civil fines must include citation of the statute or ordinance violated):
Defendant did knowingly and willingly block plaintiffs access to the door to exit store in an attempt to intimidate and harrass, and after
plaintiff tried to avoid the defendant andexit the doorway, defendant did engage in an illegal sexual act by grabbing and squeezing the

Page 355 of 2301

Page 65 of 67
defendants buttocks with an inappropriate gesture with the defendants finger while squeezing. This lude act was in the strictest violation of
Pennsylvania statutes concerning sexual harassment. Witnesses were present both behind the check*out counter and waiting in line at
the checkout counter. Plaintiff requests the Commonwealth of Pennsylvania to prosecute the defendant to the fullest extent of the law.
Verify that the facts set forth in this complaint are true and correct to the
I,
Best of my knowledge, information, and belief. This statement is made subject to the penalties of Section 4904 of the
CrimesCode (18 PA. C.S. 4904) related to unsworn falsification to authorities.
(Signature of Plaintiff or Authorized Agent)
Plaintiff's
Address:
Attorney:
Telephone: ( )
IF YOU INTEND TO ENTER A DEFENSE TO THIS COMPLAINT, YOU SHOULD SO NOTIFY THIS OFFICE IMMEDIATELY AT
THEABOVE TELEPHONE NUMBER. YOU MUST APPEAR AT THE HEARING AND PRESENT YOUR DEFENSE. UNLESS YOU DO,
JUDGMENT MAY BE ENTERED AGAINST YOU BY DEFAULT.
If you have a claim against the plaintiff which is within magisterial district judge jurisdiction and which you intend to assert at the hearing,
you must file it on a complaint form at this office at least five (5) days before the date set for the hearing.
If you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services,
please contact the Magisterial District Court at the above addressor telephone number. We are unable to provide transportation.
AOPC 308A-05

Page 356 of 2301

Page 66 of 67
June 13, 2005

Stan J. Caterbone
220 Stone Hill Road
Conestoga, PA 17516
FiorillJ@police.co.lancaster.pa.us
Chief J. Fiorill
Main Street
Conestoga, PA 17516
Re: Recent Police Reports & Status of Ongoing Investigations
1.
2.
3.
Break-In reported on June 12, 2005: As reported to the officer, Adams? who came to take my report, I left my home at approximately
2:30pm, with all doors locked. At approximately 9:15pm, I entered through my garage door and found my back door wide open. I also
reported a Honda file missing, which I have since located.
I am requesting the status of the complaint that I reported to Officer Berger on June 10 concerning the sexual harassment by Mr. Thomas
Grasssel on the same date.
During my visit by the officer on June 12, I again asked if anyone in the department had questioned Mr. David Pflumm regarding access to
my home. As I have stated in just about every complaint about a break-in over the past six months, On Thanksgiving day, 2004, Mr. David
Pflumm, his son Keagen, and daughter Lizzy, approached my home. I wanted NO personal contact with them, and made sure my doors were
closed and locked. After several minutes of knocking on my back door, I went down to the basement hoping they would leave. They instead
went to my front door and basement door and kept knocking. I was located in the rear of my basement, waiting for them to leave. Suddenly,
Lizzy and Keagan appeared in my basement asking why I did not answer the door. I quickly asked them how they got into my house. First
they said the door was opened, then they said Keagan used a credit card to open my back door. They said Dave was upstairs in my kitchen.
We walked upstairs and I quickly asked Dave how they got into my house, he responded We have lots of keys.
Now with all of the reports of people breaking into my house, and the fact that I first reported the above event to Officer Berger in December
with the report of my missing remote control, I will again ask you why your department refused to question the Pflumms regarding keys to
my house?
4.
During my interview last evening I showed the officer the letter from Mr. David Pflumm dated June 2, 2005, which was served to me by a
Pennsylvania Constable from District Justice Leo Eckerts office at approximately 9:30 am on June 10th on Stone Hill road infront of my
mailbox. The officer said we have a copy of that letter, and are aware of that. I requested the officer to take the letter and my response,
sent via facsimile to Pflumm Contractors on June 10th, to you. The officer refused to take the letter. I asked him to take my statement
regarding the same, and he refused. I asked him why he would not take my statement, if you have a copy of the complaint from Mr. David
Pflumm? He said I am going home. I called him corrupt and said that the whole department was corrupt.
I attest to the above statements as the truth and request a copy of all of my complaints, reports, and calls to your department, as defined and authorized
under the Freedom Of Information Act, and according to the laws governing the same by the Commonwealth of Pennsylvania and the federal rules
governing the same.
Attest,

Page 357 of 2301

Page 67 of 67
Convicted killer Lisa Michelle Lambert claims prosecutor believed her '...
1 of 2
http://lancasteronline.com/news/local/convicted-killer-lisa-michelle-lamb...
Page 358 of 2301
Convicted killer Lisa Michelle Lambert claims

prosecutor believed her 'wrongfully convicted'
By BRETT HAMBRIGHT | Staff Writer | Posted: Friday, May 16, 2014 9:50 am
Convicted killer Lisa Michelle Lambert is asking a federal
court to review her conviction, claiming newlydiscovered evidence warrants reconsideration of her
case.
Lambert is serving a life sentence for the Dec. 21, 1991
murder of 16-year-old Laurie Show.
Lambert, a 40-year-old inmate at a Massachusetts state
prison, claims in her filing that Lancaster Countys court
system is corrupt and that the man who prosecuted her
believed her innocent.
The appeal, filed by Lambert herself to Pennsylvania
Eastern District federal court, seeks relief from her July
1992 wrongful conviction of murder.
Convicted killer Lisa Michelle

Lambert claims prosecutor
believed her wrongfully
convicted
(Its filed as a civil-action suit, not a criminal appeal,

because she wasnt convicted in a federal court.)
The suit mentions new findings, although the evidence

has been mentioned before in prior appeals.
The parties mentioned in the suit are: Lancaster County District Attorney Craig Stedman, state
Attorney General Kathleen Kane and the warden of the prison where Lambert is housed.
Stedman, on Friday morning, rejected the latest filing.
"There is nothing new here," he said. "These are the same absurdities she claimed in state court. They
were litigated, dismissed, and sustained on appeal."
The suit leans heavily on a letter written by a convicted felon that includes a statement allegedly made
by the late prosecutor Jack Kenneff.
Kenneff, after becoming a defense lawyer, allegedly made a statement in 2007 to Warren
Raffensberger Jr. that Lancaster Countys judicial system is corrupt, according to the filing. The 5-page
note includes statements allegedly made by Kenneff about Lamberts innocence.
6/28/2015 9:34 PM
Convicted killer Lisa Michelle Lambert claims prosecutor believed her '...
2 of 2
http://lancasteronline.com/news/local/convicted-killer-lisa-michelle-lamb...
Page 359 of 2301
Kenneff stated that the Lisa Michelle Lambert case has been weighing very heavily upon him, as he
had wrongfully convicted her, Raffensbergers letter states.
The letter has been introduced in at least three prior appeals, in 2012 and 2013, to Lancaster County
Court and the state's Supreme and Superior Courts.
All were denied.
"Jack Kenneff most certainly did not believe Lambert was innocent as she claims," said Stedman, who
worked with Kenneff for years. "This is just another desperate attempt to avoid being held
accountable."
Lambert, along with convicted accomplice Tabatha Buck, killed Show at the Conestoga Valley
sophomores East Lampeter home as she prepared for school.
Lambert, who viewed Show as a romantic rival, was convicted of slashing Shows throat. Buck was
convicted of assisting in the murder: in particular, holding Show inside the condominium at The Oaks.
Both women are serving life terms with no chance for parole.
Stedman said he is aware of the filing, although his office hasnt been formally served with the suit.
6/28/2015 9:34 PM
Page 360 of 2301
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Filed December 29, 1997

UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
Nos. 97-1281, 97-1283 and 97-1287
LISA MICHELLE LAMBERT
v.
CHARLOTTE BLACKWELL, MRS., SUPERINTENDENT;
THE ATTORNEY GENERAL OF THE
STATE OF PENNSYLVANIA,
Appellants
Appeal from the United States District Court
for the Eastern District of Pennsylvania
(D.C. Civ. No. 96-cv-06244)
Argued
October 21, 1997
Before: MANSMANN and GREENBERG, Circuit Judges ,
and ALARCON, Circuit Judge.*
(Filed December 29, 1997)
_________________________________________________________________
*Honorable Arthur L. Alarcon of the United States Court of Appeals for
the Ninth Circuit, sitting by designation.
Peter S. Greenberg, Esquire
(ARGUED)
Christina Rainville, Esquire
Jeannette M. Brian, Esquire
Diane L. Lisowski, Esquire
Schnader, Harrison, Segal & Lewis
1600 Market Street
Suite 3600
COUNSEL FOR APPELLEE
Richard A. Sprague, Esquire
(ARGUED)
Geoffrey R. Johnson, Esquire
Theodore J. Chylack, Esquire
Joseph R. Podraza, Jr., Esquire
T. Truxtun Hare, Esquire
David S. Lubin, Esquire
Deborah B. Miller, Esquire
Sprague & Sprague
Suite 400, Wellington Bldg.
135 South 19th Street
Richard A. Sprague, Esquire
Alvin B. Lewis, Jr., Esquire
Edward R. Kennett, Esquire
1 of 26
6/1/2006 3:04 AM
Page 361 of 2301
Sprague & Lewis

The Christopher DeMuth Bldg.
116 East King Street
Lancaster, PA 17602
COUNSEL FOR APPELLEES
2
D. Michael Fisher
Attorney General of Pennsylvania
Jerome T. Foerster
Senior Deputy Attorney General
Appeals and Legal Services Section
Robert A. Graci
Assistant Executive Deputy
Attorney General
Office of Attorney General of
Pennsylvania
Law and Appeals
16th Floor, Strawberry Square
Harrisburg, PA 17120
Daniel E. Lungren
Attorney General of California
1300 I Street, Suite 125
Sacramento, CA 95814
M. Jane Brady
Attorney General of Delaware
820 North French Street
Wilmington, DE 19801
Richard P. Ieyoub
Attorney General of Louisiana
P.O. Box 94095
Baton Rouge, LA 70804-9095
W.A. Drew Edmondson
Attorney General of Oklahoma
2300 North Lincoln Boulevard,
Suite 112
Oklahoma City, OK 73105-4894
3
Charles M. Condon
Attorney General of South Carolina
P.O. Box 11549
Rembert C. Dennis Building
Columbia, SC 29211-1549
COUNSEL FOR AMICUS
APPELLANTS: COMMONWEALTH
OF PENNSYLVANIA, STATE OF
CALIFORNIA, STATE OF
DELAWARE, STATE OF
LOUISIANA, STATE OF
OKLAHOMA, STATE OF
SOUTH CAROLINA
Donna G. Zucker
2 of 26
6/1/2006 3:04 AM
Page 362 of 2301
Assistant District Attorney

Ted McKnight
President, Pennsylvania District
Attorneys Association
1421 Arch Street
Philadelphia, PA 19102-1582
COUNSEL FOR AMICUS CURIAE
PENNSYLVANIA DISTRICT
ATTORNEYS ASSOCIATION
OPINION OF THE COURT
MANSMANN, Circuit Judge.
In this appeal we are faced with the onerous task of
determining whether the district court, upon petition for
writ of habeas corpus, erred in granting the unconditional
release of one convicted of first degree murder by a state
trial judge. Under Rose v. Lundy, 455 U.S. 509, 522 (1982),
the district court is required to dismiss a federal habeas
petition filed pursuant to 28 U.S.C. S 2254 which contains
both unexhausted and exhausted claims. Because wefind
the petitioner has not yet pursued her remedies under the
Pennsylvania Post Conviction Relief Act, 42 Pa. Cons. Stat.
Ann. S 9542 et seq. (West 1997 Supp.), her federal habeas
4
petition includes unexhausted claims and, hence, the result
here is dictated by Rose v. Lundy, supra . Thus, we will
remand this case to the district court with an order to
dismiss the petition without prejudice so that the petitioner
can first present her unexhausted claims to the appropriate
Pennsylvania state court.
I.1
Laurie Show became romantically involved with Lisa
Lambert's boyfriend, Lawrence "Butch" Yunkin, for a brief
period in June of 1991. Thereafter, Show incurred the
wrath of Lambert, who accosted Show on several occasions.
On the morning of December 20, 1991, Show was brutally
murdered. Lambert and an accomplice, Tabitha Buck, were
subsequently charged with criminal homicide for the
murder of Show.2 Buck was convicted of second degree
murder by a jury of her peers; Yunkin, in exchange for his
truthful testimony against Lambert, pled guilty to hindering
apprehension.3
_________________________________________________________________
1. We note, as a preliminary matter, that Lambertfiled a motion to
dismiss this appeal on the basis that since the district court found she
was actually innocent of first degree murder, the Double Jeopardy
Clause of the Fifth Amendment bars the Commonwealth's appeal. By
separate order, we will deny this motion. As we make clear in this
opinion, the district court erred in reaching the issue of Lambert's actual
innocence. Accordingly, we do not give weight to the district court's
factual findings in this appeal. Moreover, we are plainly authorized to
review the final order of the district court in a habeas case pursuant to
28 U.S.C. S 2253(a). Furthermore, a finding of actual innocence, as that
term has come to be used in federal habeas corpus jurisprudence, is not
the equivalent of a finding of not guilty by a jury or by a court at a
3 of 26
6/1/2006 3:04 AM
Page 363 of 2301
bench trial. We find, therefore, that the Double Jeopardy Clause does
not bar the Commonwealth's appeal.
2. At the time of her arrest, Lambert was six months pregnant with
Yunkin's child.
3. Several weeks after Lambert's murder trial was concluded; the
Commonwealth determined that Yunkin had perjured himself at
Lambert's trial. Consequently, Yunkin breached the plea agreement and
the Commonwealth charged him with third degree murder to which he
pled nolo contendere.
5
On July 20, 1992, after a seven-day bench trial in the
Court of Common Pleas of Lancaster County, Pennsylvania,
Lambert was convicted of first degree murder and criminal
conspiracy. Subsequently, Lambert was sentenced to life
imprisonment by the trial court. Lambert, through her trial
counsel, Roy Shirk, Esq., filed a Motion in Arrest of
Judgment and for New Trial, and Additional Reasons for
Post-Trial Motions, raising various allegations of trial error
and prosecutorial misconduct.4 On July 19, 1994, the trial
court issued an Opinion and Order denying Lambert's posttrial motions. No appeal was taken from this order.
_________________________________________________________________
4. The issues raised in the first set of post-verdict motions filed by Roy
Shirk, Esq., included:
Error to deny defendant's motion for change of venue;
Error to deny defendant's motion for sanctions;
Error to allow Tabitha Buck's statement into evidence;
Error to allow the trier of fact to take notes during trial and
potentially to use them during deliberation;
Error to affirm and read the Commonwealth's points of charge Nos.
3 and 4;
Error not to grant a mistrial when the request for supplemental
discovery of Laura Thomas was not granted;
discovery of Hazel Show was not granted;
discovery of Richard Kleinhans was not granted;
Error not to grant a mistrial when the prosecution withheld evidence
that a jergo was discarded and that they were aware of its location;
Error to qualify Dr. Penades as an expert in forensic pathology since
he was not board certified;
Error not to grant a mistrial when the prosecution withheld from
discovery a portion of Yunkin's statement of February 4, 1992;
Error not to grant a mistrial when the Assistant District Attorney
asked witness Samuel J. Golub two questions beyond his area of
expertise; and
4 of 26
6/1/2006 3:04 AM
Page 364 of 2301
Insufficient evidence existed to sustain the verdict.

6
Subsequently, Lambert, through new counsel, Jules
Epstein, Esq., filed a Motion for a New Trial based on
allegations of after-discovered evidence5 and ineffective
assistance of trial counsel.6 An evidentiary hearing on the
new motion was conducted over a two-day period in
November of 1994. On March 14, 1995, the state trial court
denied Lambert's motion for post-verdict relief. In June of
1995, Lambert appealed the judgment of sentence imposed
by the state trial court to the Superior Court of
Pennsylvania, raising essentially the same claims regarding
ineffective assistance of trial counsel and after-discovered
evidence.7 A three-judge panel of the Superior Court of
Pennsylvania affirmed the judgment of sentence on January
4, 1996. In her direct appeal to the Pennsylvania Supreme
Court filed on February 2, 1996, Lambert again raised the
same claims.8 Lambert's petition for allowance of appeal
_________________________________________________________________
5. The after-discovered evidence consisted of the testimony of Yunkin in
a court proceeding subsequent to Lambert's trial in which he stated he
was aware of the plans to harm Laurie Show; and, Yunkin's admission
of his involvement in the murder during the plea colloquy, which also
took place subsequent to Lambert's trial, resulting in a plea of nolo
contendere to third degree murder.
6. Lambert alleged trial counsel was ineffective in failing to present
evidence of good character/reputation; failing to present evidence and
witnesses to substantiate her testimony that she had been physically
and psychologically abused by Yunkin; failing to produce evidence that
Commonwealth witness Laura Thomas was on juvenile probation which
was crucial to the credibility determination; presenting a witness who
testified that Laurie Show's claim of date rape against Yunkin was false;
failing to present evidence of bad reputation for the veracity of witness
Laura Thomas; failing to move to suppress Lambert's inculpatory
statement to the police; failing to seek a new trial based upon new
evidence of Yunkin's nolo contendere plea to third degree murder; and,
in failing to impeach Yunkin with his statements to the police that he
knew of the plan to harm the victim before he dropped Lambert and
Buck off at Show's condominium.
7. In her appeal to the Pennsylvania Superior Court, Lambert argued her
counsel was ineffective for failing to introduce evidence of her good
character and of the abuse inflicted upon her by Yunkin; Lambert also
raised the after-discovered evidence of Yunkin's breach of his plea
agreement and perjury.
8. See note 7, supra.
7
was subsequently denied on July 2, 1996. Lambert did not
seek collateral review of any of her claims through the
Pennsylvania Post-Conviction Relief Act.
Lambert instituted the present federal habeas corpus
action by filing a pro se writ of habeas corpus on
September 12, 1996. The district court subsequently
5 of 26
6/1/2006 3:04 AM
Page 365 of 2301
appointed counsel to represent Lambert and directed

counsel to file an amended petition, which they did on
January 3, 1997. Lambert's first amended petition for writ
of habeas corpus incorporated the claims previously
presented to the state courts, but went further, advancing
the following grounds for relief: (1) Lambert was actually
innocent and no credible evidence supported the
prosecution's theory of her guilt or the findings of the state
trial court; (2) the misconduct9 of the prosecution and the
police created a situation of manifest injustice; (3) afterdiscovered evidence10 created manifest injustice; and, (4)
trial counsel was ineffective in over 35 separate ways. In its
Answer to the First Amended Petition, the Commonwealth
responded that Lambert was not entitled to federal review
at this time since she had failed to exhaust her state court
remedies and had committed insurmountable procedural
default. In the alternative, the Commonwealth argued that
Lambert's petition should be denied on the merits. Further,
_________________________________________________________________
9. The alleged misconduct includes altering Lambert's statement to the
police; creating a false crime scene photograph to discredit her;
knowingly presenting perjured testimony and failing to take remedial
measures after the perjury was confirmed; knowingly presenting "expert"
testimony that was scientifically incredible while tampering with the
defense's expert; altering evidence and witness statements; failing to
disclose Brady and Giglio evidence; and "losing" other exculpatory
evidence.
10. The after-discovered evidence allegedly consists of alterations of
Lambert's statement; alteration of crime scene evidence; scientific testing
of clothing worn by Yunkin; photographs of the crime scene which
revealed additional writing in blood by the victim that exculpates
Lambert; autopsy report notes revealing the time of the victim's death;
injuries incurred by the "real" killers, Yunkin and Buck; testing of blood
found on the victim's ring; statements made by Yunkin and Buck to
their friends; and, the subsequent admission by the prosecution that the
primary witness against Lambert--and one of the"real" killers--had
committed perjury at Lambert's trial.
8
the Commonwealth expressly stated in its Answer that it
was not waiving the exhaustion requirement in any manner.11
Despite the Commonwealth's objections to Lambert's
petition on the grounds of exhaustion and procedural
default, the district court determined that it would allow
broad discovery and would conduct an evidentiary hearing
on Lambert's claims of actual innocence and prosecutorial
misconduct while, at the same time, considering the
Commonwealth's procedural claims of exhaustion and
procedural default. The district court denied the
Commonwealth's objection that the evidentiary hearing was
prohibited by the Anti-Terrorism and Effective Death
Penalty Act of 1996 ("AEDPA"), codified at 28 U.S.C. S 2241
et seq., citing the highly unusual circumstances of this
case. The evidentiary hearing commenced on March 31,
1997, and, after fourteen days of testimony, the district
court entered an order granting the writ, releasing Lambert
from custody, and barring the Commonwealth from
conducting a retrial of Lambert.
6 of 26
6/1/2006 3:04 AM
Page 366 of 2301
The district court issued its Order and Memorandum

Opinion on April 21, 1997.12 Lambert v. Blackwell, 962
F.Supp. 1521 (E.D. Pa. 1997). The court found that the
1995 amendment to the Pennsylvania Post Conviction
Relief Act ("PCRA"), 42 Pa. Cons. Stat. Ann.S 9543, which
eliminated the waiver exception for actual innocence or
procedural default (former sections 9543(a)(3)(ii) and (iii)),
left Lambert without a state forum in which to raise her
claims of error. The district court interpreted the
Pennsylvania legislature's elimination of the actual
_________________________________________________________________
11. The district court found, however, that the Commonwealth waived its
exhaustion and procedural default arguments at the evidentiary hearing
when counsel stated that relief was "warranted" in this case. N.T. at
2703, April 16, 1997. In so holding, the district court did not recognize
that the Commonwealth withdrew this concession the very next day. In
any event, the Commonwealth maintains that any acquiescence it may
have made regarding relief did not result in an express waiver of the
exhaustion issue. See also note 28, infra.
12. In finding that Lambert was actually innocent of the murder of
Laurie Show, the district court did not address the third and fourth
grounds raised in Lambert's habeas petition regarding after-discovered
evidence and ineffective assistance of counsel.
9
innocence and procedural default exceptions to waiver "as
an advertent decision after the Supreme Court's decision in
Schlup [v. Delo, 513 U.S. 298 (1995),] to place those issues
squarely into the federal forum." Lambert, 962 F.Supp. at
1553. Thus, the district court concluded that Lambert
exhausted all of the claims presented in her federal habeas
proceeding, with the exception of the after-discovered
evidence which "expand[ed] the degree of the violations"
brought to the attention of the state trial judge or confirmed
Lambert's contention that she is actually innocent. Id.
The court further opined that to the extent there may be
claims which a Pennsylvania court might view as not being
waived, the state proceedings would be ineffective to protect
Lambert's rights if the district court dismissed the petition.
Id. at 1554. Moreover, the court found that if it were to
dismiss this case as a mixed petition pursuant to Rose v.
Lundy, supra, "on the suspicion that perhaps its reading of
the PCRA was wrong," then Lambert would be deemed to
have taken her one bite of the apple under the AEDPA. Id.
Consequently, in order for Lambert to return to federal
court, the district court opined, she would need the
approval of the court of appeals and denial of such
application was unreviewable by the Supreme Court. The
district court felt that under these extraordinary
circumstances, such a result was constitutionally
intolerable.13 Id.
Finally, the district court explained that in such an
extraordinary case, the principles of comity allowed it to
excuse total exhaustion or procedural default in the face of
a manifestly unjust incarceration.14 Id. In any event, the
_________________________________________________________________
13. Subsequent to the issuance of the district court's opinion, we decided
7 of 26
6/1/2006 3:04 AM
Page 367 of 2301
Christy v. Horn, 115 F.3d 201, 208 (3d Cir. 1997), holding that "when a
prior petition has been dismissed without prejudice for failure to exhaust
state remedies, [authorization from the court] is [not] necessary and the
petitioner may file his petition in the district court as if it were the first
such filing."
14. At a status conference held on February 13, 1997, prior to the
evidentiary hearing, the court, after articulating its concerns with the
exhaustion issue, opined that the better approach was to analyze the
petitioner's claims under the doctrines of actual innocence and manifest
10
court found that the Commonwealth's concession at the
evidentiary hearing that Lambert was entitled to some relief
effected a waiver of the exhaustion objection.
The Commonwealth filed a timely notice of appeal on
April 22, 1997. We have jurisdiction over this appeal
pursuant to 28 U.S.C. SS 1291 and 2253.15 In a federal
habeas corpus proceeding, we exercise plenary review of the
district court's legal conclusions and apply a clearly
erroneous standard to the court's factual findings. Caswell
v. Ryan, 953 F.2d 853, 857 (3d Cir. 1992) (citing Bond v.
Fulcomer, 864 F.2d 306, 309 (3d Cir. 1989)).
II.
We note at the outset that the parties do not dispute that
Lambert's petition includes claims which were not
presented to the state court.16 Unlike the district court,
however, we cannot dispense with consideration of the
exhaustion and procedural default claims in favor of
reaching the merits of Lambert's claim of actual innocence.17
_________________________________________________________________
injustice based upon prosecutorial misconduct, which are derived from
the Due Process Clause and not from any statute (such as the PCRA).
The district court thus intimated that it was avoiding the exhaustion
issue by proceeding to a due process analysis. The court further stated
that while it agreed with the general requirements of the AEDPA
regarding evidentiary hearings and unexhausted claims, this case
involved highly unusual circumstances and, thus, those provisions did
not apply.
15. Because the Commonwealth has taken the appeal in this proceeding,
a certificate of appealability is not required as a prerequisite to our
exercising appellate jurisdiction. Fed. R. App. P. 22(b).
16. Lambert argues in her brief, however, that since she has waived the
non-exhausted claims in state court, she has thus exhausted her state
remedies. As explained below, we do not agree with Lambert that the
non-exhausted claims were necessarily waived in state court.
17. We recognize that a panel of this court, on a motion by the
respondents for a stay of Lambert's release pending the appeal,
concluded that the respondents failed to show that they were likely to
succeed in their argument that the petition should be denied because of
Lambert's failure to exhaust her state court remedies. Of course, that
11
8 of 26
6/1/2006 3:04 AM
Page 368 of 2301
Rather, we find that Supreme Court precedent and the

AEDPA mandate that prior to determining the merits of her
petition, we must consider whether Lambert is required to
present her unexhausted claims to the Pennsylvania courts.
We turn, therefore, to a discussion of exhaustion of state
claims under the AEDPA.
A.
It is axiomatic that a federal habeas court may not grant
a petition for a writ of habeas corpus filed by a person
incarcerated from a judgment of a state court unless the
petitioner has first exhausted the remedies available in the
state courts. 28 U.S.C. S 2254(b)(1)(A); Toulson v. Beyer,
987 F.2d 984 (3d Cir. 1993). The exhaustion requirement is
excused, however, where no available state corrective
process exists or the particular circumstances of the case
render the state process ineffective to protect the
petitioner's rights. 28 U.S.C. SS 2254(b)(1)(B)(I) and (ii). A
petitioner will not be deemed to have exhausted the
available state court remedies so long as she has the right
under state law to raise, by any available procedure, the
question presented. 28 U.S.C. S 2254(c). A petitioner who
has raised an issue on direct appeal, however, is not
required to raise it again in a state post-conviction
proceeding. Evans v. Court of Common Pleas, Delaware
County, Pennsylvania, 959 F.2d 1227, 1230 (3d Cir. 1992)
(citing Swanger v. Zimmermann, 750 F.2d 291, 295 (3d Cir.
1984)). Thus, the federal habeas claim must have been
"fairly presented" to the state courts, i.e., it must be the
substantial equivalent of that presented to the state courts.
Id. at 1231 (citations omitted). In addition, the state court
_________________________________________________________________
inherently tentative conclusion, based on a record less complete than
that before us and not reached after the opportunity for the intensive
study available to a merits panel, is not binding on this panel. See Third
Circuit I.O.P. 9.1 (only the holding of a panel in a published opinion is
binding on subsequent panels). See also United States v. Houser, 804
F.2d 565, 568 (9th Cir. 1986). In any event, the motions panel did not
preclude the respondents from raising the exhaustion issue. Rather, it
merely opined that they were not likely to succeed on it. In fact, upon
fuller presentation and consideration, they have succeeded.
12
must have available to it the same method of legal analysis
as that to be employed in federal court. Id. The habeas
petitioner carries the burden of proving exhaustion of all
available state remedies. Toulson, 987 F.2d at 987. The
exhaustion requirement does not foreclose federal relief, but
merely postpones it. Id. at 986.
The Supreme Court has made clear that a section 2254
petition which includes unexhausted as well as exhausted
claims, i.e., a mixed petition, must be dismissed without
prejudice. Rose v. Lundy, 455 U.S. 509, 522 (1982). In
reaching this conclusion, the Court analyzed the policies
underlying section 2254 since it found that Congress's
intent was unclear from the statute or legislative history. Id.
at 516-17. In endorsing rigorous enforcement of the total
exhaustion rule, the Court acknowledged the preference
among federal jurists to allow state courts the initial
9 of 26
6/1/2006 3:04 AM
Page 369 of 2301
opportunity to review and correct alleged violations of

federal constitutional rights. This preference is derived from
principles of comity.18 Id. at 518. The Court further noted
that adoption of a total exhaustion rule causes a reduction
in piecemeal litigation, thereby increasing the likelihood
that all claims will be reviewed in a single proceeding. Id. at
520. Finally, the Court observed that the prisoner's interest
in obtaining speedy relief in federal court on his claims
would not be unreasonably impaired by requiring total
exhaustion. Id. at 520-22. Thus, Lundy teaches that if the
petitioner fails to satisfy the exhaustion requirement prior
to filing a federal habeas petition and none of the
exceptions apply, the federal court is precluded from
granting habeas relief to the petitioner.
_________________________________________________________________
18. The doctrine of comity " `teaches that one court should defer action
on causes properly within its jurisdiction until the courts of another
sovereignty with concurrent powers, and already cognizant of the
litigation, have had an opportunity to pass upon the matter.' " Rose v.
Lundy, 455 U.S. 509, 518 (1982) (quoting Darr v. Burford, 339 U.S. 200,
204 (1950)). Indeed, we opined in Toulson v. Beyer, 987 F.2d 984, 986
(3d Cir. 1993), that requiring exhaustion of state remedies "addresses
federalism and comity concerns by àfford[ing] the state courts a
meaningful opportunity to consider allegations of legal error without
interference from the federal judiciary.' " (Citations omitted.)
13
Five years later, the Supreme Court handed down its
decision in Granberry v. Greer, 481 U.S. 129 (1987). In
Granberry, the district court had dismissed the federal
habeas petition upon the state's motion to dismiss under
Rule 12(b)(6) of the Federal Rules of Civil Procedure. When
the petitioner appealed, the state for the first time
interposed the defense that the petitioner had not
exhausted his state remedies. The petitioner responded by
arguing that the state waived this defense by failing to raise
it in the district court. The Supreme Court granted
certiorari to consider whether the state's failure to raise the
exhaustion defense in the district court constituted a
waiver of that claim in the court of appeals. 481 U.S. at
130.
The Court held in Granberry that where the state has
failed to raise, in the district court, an arguably meritorious
nonexhaustion defense, through inadvertence or otherwise,
the court of appeals may appropriately examine the
nonexhaustion issue anew. Id. at 134. In determining
whether the interests of comity and federalism were better
served by addressing the merits despite non-exhaustion,
the Supreme Court delineated the following standard:
If, for example, the case presents an issue on which an
unresolved question of fact or of state law might have
an important bearing, both comity and judicial
efficiency may make it appropriate for the court to
insist on complete exhaustion to make sure that it may
ultimately review the issue on a fully informed basis.
On the other hand, if it is perfectly clear that the
applicant does not raise even a colorable federal claim,
the interests of the petitioner, the warden, the state
attorney general, the state courts, and the federal
10 of 26
6/1/2006 3:04 AM
Page 370 of 2301
courts will be well served even if the State fails to raise

the exhaustion defense, the district court denies the
habeas petition, and the court of appeals affirms the
judgment of the district court . . . .
Granberry v. Greer, 481 U.S. at 134-35. Thus, we learn
from Granberry that where a state fails to raise a
nonexhaustion defense in the district court, courts of
appeals should consider whether, under the particular facts
and circumstances presented, the interests of justice would
14
be served by addressing the merits of the habeas petition if
it is clear the petitioner has failed to state a colorable
federal claim, or by requiring exhaustion. Id. at 136. We
emphasize, however, our previous holding that Granberry
applies to "any claim before the court of appeals for which
the state neglected to raise non-exhaustion in the district
court." Keller v. Petsock, 853 F.2d 1122, 1128 n.6 (3d Cir.
1988). Clearly that is not the case before us. The
Commonwealth has aggressively asserted the
nonexhaustion defense first in the district court and now
on appeal. Indeed, in our most recent decisions applying
Granberry, the state had failed to raise the nonexhaustion
defense in the district court. See, e.g. , Smith v. Horn, 120
F.3d 400 (3d Cir. 1997); Evans v. Court of Common Pleas,
Delaware County, 959 F.2d 1227 (3d Cir. 1992); Keller v.
Petsock, supra.
Significantly, two changes in the federal habeas statute
are derived from the Supreme Court's decision in
Granberry. First, under the AEDPA, a district court may no
longer infer that a state has waived the nonexhaustion
defense from its failure to invoke the defense expressly.
Gaylor v. Harrelson, 962 F.Supp. 1498, 1499 & n.2 (N.D.
Ga. 1997). The revised statute now requires an express
waiver through counsel in order for the state to have waived
the nonexhaustion defense. 28 U.S.C. S 2544(b)(3). Second,
the AEDPA, in 28 U.S.C. S 2544(b)(2), codifies the holding
in Granberry by conferring upon the district court the
authority to deny a habeas petition on the merits despite
the petitioner's failure to exhaust state remedies. Hoxsie v.
Kerby, 108 F.3d 1239, 1243 (10th Cir.), cert. denied, ___
U.S. ___, 118 S.Ct. 126 (1997) (emphasis added). Standing
alone, section 2544(b)(2) does not provide a standard for
determining when a court should dismiss a petition on the
merits rather than requiring complete exhaustion. Id. Thus,
the court of appeals in Hoxsie read section 2544(b)(2) in
conjunction with Granberry. We read the Granberry test as
whether "it is perfectly clear that the applicant does not
raise even a colorable federal claim." 481 U.S. at 135.
We cannot say that it is perfectly clear that Lambert has
not raised a colorable federal claim. The district court
obviously found substantial merit to Lambert's claims of
15
actual innocence and prosecutorial misconduct. These
claims present unresolved questions of fact and of state law
and, thus, the interests of comity and justice are better
11 of 26
6/1/2006 3:04 AM
Page 371 of 2301
served by requiring complete exhaustion.

We note that section 2544(b)(2) does not provide the
district court with the authority to grant relief on the merits
where the petitioner fails to exhaust state remedies. Thus,
a strict reading of the statute compels us to conclude that
if a question exists as to whether the petitioner has stated
a colorable federal claim, the district court may not
consider the merits of the claim if the petitioner has failed
to exhaust state remedies and none of the exceptions set
forth in sections 2544(b)(1)(B)(I) and (ii) applies. Lambert
argues, in contrast, that Granberry establishes that where
the district court has held a full trial and found a
miscarriage of justice, a failure to exhaust is excused. We
disagree. The particular language in Granberry to which
Lambert refers states:
[I]f a full trial has been held in the district court and it
is evident that a miscarriage of justice has occurred, it
may also be appropriate for the court of appeals to hold
that the nonexhaustion defense has been waived in
order to avoid unnecessary delay in granting relief that
is plainly warranted.
481 U.S. at 135. We note that, unlike in Granberry, the
state has not waived the nonexhaustion defense. Second,
the AEDPA now explicitly requires an express waiver by the
state before waiver will be deemed to have occurred.
Moreover, to accept Lambert's argument would require that
we view Granberry as authorizing a district court to waive
the nonexhaustion defense even though the state has
aggressively asserted that defense at all stages of the
proceedings. This conclusion is irreconcilable, not only with
the express waiver provision in section 2544(b)(3), but also
with common sense. The quoted passage from Granberry
only has meaning when placed in the context of a case in
which the state failed to raise the nonexhaustion defense
before the district court. Given the new express waiver
requirement of the AEDPA, it is doubtful that Granberry
continues to have any import in a situation other than
where the state has expressly waived the nonexhaustion
16
defense. We need not answer this question, however, as the
resolution of the case before us does not require it.
For these reasons, we also reject Lambert's contention
that exhaustion is excused based on the "special
circumstances rule" derived from Supreme Court
jurisprudence, specifically Granberry v. Greer , supra, and
Frisbie v. Collins, 342 U.S. 519 (1952).19 We agree with the
Commonwealth that Granberry relates only to the special
circumstance of the prosecution never having raised the
exhaustion defense prior to appeal so that the Supreme
Court permitted the court of appeals to rule on the merits
of the petition. After enactment of the AEDPA in 1996, 28
U.S.C. S 2254 imposes a duty on the courts to examine the
exhaustion issue and to reject a petition if it raises
unexhausted claims.
Lambert's reliance on Frisbie v. Collins, supra, is likewise
misplaced, as that decision does not support a finding of
12 of 26
6/1/2006 3:04 AM
Page 372 of 2301
exceptional circumstances here.20 In Frisbie, the Supreme

Court reiterated the general rule that the presence of
special circumstances will excuse non-exhaustion. 324 U.S.
at 520-21. Whether such circumstances exist is to be
determined by the district court conducting a factual
appraisal in each particular case. Id. at 521. The Court
refused to discuss the special circumstances found by the
_________________________________________________________________
19. Lambert maintains before us that since she has either raised or
waived all of her claims in state court, she did exhaust her state
remedies. Lambert is equating exhaustion with waiver, however, in that
she argues that since the unexhausted claims have been waived under
Pennsylvania law, after the 1995 amendments to the PCRA, she is
without a mechanism for post-conviction relief. This argument cannot
form the basis of a "special circumstance" excusing her failure to
exhaust since, as we find infra, that review of her unexhausted claims is
not clearly foreclosed under Pennsylvania law.
20. The Commonwealth submits that the so-called "special
circumstances" exception of Frisbie v. Collins, supra, upon which
Lambert relies to excuse nonexhaustion, "is so ill-defined that it must be
considered sui generis" and, in any event, did not survive the AEDPA
amendments to the federal habeas corpus statute. The Commonwealth
describes Frisbie as "a case notably lacking in guidance on the
parameters of the [special circumstances] exception." We agree with the
Commonwealth's analysis of Frisbie.
17
court of appeals for the reason that the circumstances were
so peculiar to the case that "a discussion of them could not
give precision to the `special circumstances' rule."21 Id. at
522.
Recently, we considered the section 2544 exhaustion
requirement with regard to a mixed petition where, as here,
the state asserted the nonexhaustion defense in the district
court. Christy v. Horn, 115 F.3d 201, 206 (3d Cir. 1997).
Acknowledging the Supreme Court's strong presumption in
favor of exhaustion, we also recognized that "in rare cases
exceptional circumstances of peculiar urgency may exist
which permit a federal court to entertain an unexhausted
claim." Id. at 206-07 (citations omitted). We explained that
such circumstances exist where "state remedies are
inadequate or fail to afford a full and fair adjudication of
the federal contentions raised, or where exhaustion in state
court would be `futile.' " Id. at 207 (citations omitted).
Applying this principle in Christy, we declined to find an
exceptional circumstance which would excuse
nonexhaustion. We found the mere risk that the state
courts would not stay the petitioner's execution while his
federal constitutional claims are being litigated did not
amount to an "unusual circumstance." The more
appropriate inquiry, we found, was to focus on the actuality
that state courts will refuse to stay an execution while
federal claims are pending. Id.
Applying our holding in Christy to Lambert's petition, we
turn our attention to the actuality that the state courts
would refuse to entertain Lambert's claims. As we discuss
below, we cannot say with certainty that state review of
Lambert's claims is precluded. Absent clear preclusion, we
13 of 26
6/1/2006 3:04 AM
Page 373 of 2301
do not find any exceptional circumstances which would

warrant consideration of Lambert's unexhausted claims in
federal court.
_________________________________________________________________
21. The petitioner in Frisbie v. Collins alleged that the complaint in the
state court action was defective and, consequently, a faulty warrant was
issued for his arrest. He further contends that he was subsequently
kidnaped by Michigan police in Chicago and brought back to Michigan
for trial in violation of federal constitutional and statutory law. 324 U.S.
at 521 n. 5.
18
Our conclusion is further buttressed by the holding of
our sister court of appeals in O'Guinn v. Dutton , 88 F.3d
1409 (6th Cir. 1996), cert. denied, #6D6D 6D# U.S. ___, 117 S.Ct.
742 (1997). There the unexhausted claim involved
allegations of prosecutorial misconduct stemming from
Brady violations. The court of appeals found that the state
courts had an important interest in reviewing a serious
constitutional claim involving the conduct of a state
prosecutor in withholding evidence in a state trial in which
the defendant was prosecuted for a violation of state law.
Id. at 1412. Accordingly, the court held that the "interests
of justice and comity [did] not weigh in favor of having [the
federal court] decide the question." Id. at 1413. Having
found that the case did not present any unusual or
exceptional circumstances, the court concluded that the
state courts should address the prosecutorial misconduct
claim in the first instance. Id.
In contrast, we find that the cases cited by Lambert,
Evans v. Court of Common Pleas, supra, and Moore v.
DeYoung, 515 F.2d 437 (3d Cir. 1975), do not support her
argument that special circumstances exist which would
excuse exhaustion. It is true that in Evans we held that
"[e]xhaustion is not a jurisdictional requirement, but rather
a rule of comity, and a federal court may in certain
circumstances decide the merits of a claim despite nonexhaustion." 959 F.2d at 1231. We elaborated on the
circumstances which would support non-exhaustion: where
the petitioner has no opportunity to obtain relief in a state
court, or where the state corrective process is so deficient
as to render any effort to obtain relief futile. Id. (citing
Gibson v. Scheidemantel, 805 F.2d 135, 138 (3d Cir. 1986)).
Citing Granberry v. Greer, supra, we noted further that
non-exhaustion notwithstanding, a district court may deny
a habeas claim on its merits if it appears unequivocally that
the petitioner has not raised even a colorable federal claim.
Id. We thus proceeded to consider the merits of Evans'
claims based on our conclusion that Evans' federal due
process claim was "the substantial equivalent of that
presented to the state courts" and, thus, had been
adequately exhausted. Even though the state failed to raise
the exhaustion defense in state court, we relied on
Granberry for the authority to reach the merits of Evans'
19
claims. We subsequently affirmed the district court's denial
of federal habeas relief. 959 F.2d at 1237.
14 of 26
6/1/2006 3:04 AM
Page 374 of 2301
Unlike Evans, Lambert presents numerous claims which

are not the substantial equivalent of those presented to the
state court in the direct appeal of her murder conviction.
Her petition is more factually analogous to Gibson v.
Scheidemantel, supra. There the petitioner alleged an
ineffective assistance of counsel claim in state court, but he
asserted a different basis for this claim in the state
proceeding than that presented in his federal habeas claim.
Consequently, we held that the petitioner had not
exhausted his claim since the state courts could not be
expected to consider a claim that was never made. 805 F.2d
at 139.
Nor do we find that Lambert's position is supported, as
she contends, by our decision in Moore v. DeYoung, 515
F.2d 437 (3d Cir. 1975). There we acknowledged the
possibility that federal habeas review to enjoin a state
criminal proceeding prior to trial was possible despite nonexhaustion if "extraordinary circumstances are present." Id.
at 443. In finding that Moore failed to present an
" èxtraordinary circumstance' which would warrant pretrial, pre-exhaustion habeas corpus relief," we declined to
define the parameters of the "extraordinary circumstances"
exception, holding only that whatever the boundaries may
be, Moore's petition fell outside those limits. 22 Id. at 447.
We noted, however, that manifest shortcomings by the
prosecutor's office and negligence in conducting Moore's
prosecution did not "reveal that quality of delay,
harassment, bad faith or other intentional activity which, in
an appropriate situation, might constitute an èxtraordinary
circumstance', justifying pre-exhaustion federal habeas
relief." Id. at 447 n. 12.
_________________________________________________________________
22. In his petition, Moore alleged that the constitutional right to a
speedy trial was so unique that it should bar not only a conviction but
trial as well. This unique quality, Moore contended, constituted an
"extraordinary circumstance." 515 F.2d at 446.
20
B.
Although we discount Lambert's reliance on Granberry,
Frisbie, Evans, and Moore to support a finding of
exceptional circumstances sufficient to excuse
nonexhaustion, our inquiry does not end there. As we
stated earlier, one of the exceptional circumstances in
which courts have dispensed with the exhaustion
requirement is if further state litigation would be futile.
Christy, 115 F.3d at 207. See also Twenty-Sixth Annual
Review of Criminal Procedure, 85 Geo. L. J. 775, 1521 & n.
2755 (1997). In making this determination, courts have
examined the totality of the circumstances surrounding
each petition. Id. at 1521 n. 2755. For example, the Court
of Appeals for the First Circuit found the exhaustion
requirement excused when a recent independent decision
by the highest state court clearly rendered appellate review
futile. Id. (citing Allen v. Attorney General of Maine, 80 F.3d
569, 573 (1st Cir. 1996)). Another court of appeals excused
the exhaustion requirement when it was clear that the
petitioner's claims would be deemed procedurally barred if
15 of 26
6/1/2006 3:04 AM
Page 375 of 2301
presented in the state court. Id. (citing Grey v. Hoke, 933

F.2d 117, 120 (2d Cir. 1991)). Some courts have been
reluctant to apply the futility exception, however, because
it has been criticized for potentially bypassing the state
courts. Id. at 1522 n. 2755 (citations omitted). Most
importantly, we recently applied our jurisprudence to hold
that unless a state court decision exists indicating that a
habeas petitioner is clearly precluded from state court
relief, the federal habeas claim should be dismissed for
nonexhaustion, even if it appears unlikely that the state
will address the merits of the petitioner's claim. Banks v.
Horn, 126 F.3d 206, 211 (3d Cir. 1997) (citing Doctor v.
Walters, 96 F.3d 675, 683 (3d Cir. 1996); Toulson, 987 F.2d
at 988-89; Peoples v. Fulcomer, 882 F.2d 828, 831-32 (3d
Cir. 1989)).
In Banks, we were faced with whether the Pennsylvania
Supreme Court, in death penalty cases, consistently or
regularly bars second or subsequent PCRA petitions which
may not meet the court's criteria for such petitions,
"includ[ing] the existence of à strong prima facie showing
. . . that a miscarriage of justice may have occurred.' "
21
Banks v. Horn, 126 F.3d at 211 (citing Commonwealth v.
Beasley, 678 A.2d 773, 771 (Pa. 1996), cert. denied, ___
U.S. ___, 117 S.Ct. 1257 (1997)). We concluded, based on
our review of Pennsylvania case law, that the Pennsylvania
Supreme Court had established a practice of reaching the
merits of claims in PCRA petitions in capital cases
notwithstanding the failure of the petitioner to meet the
appropriate procedural requirements. Id. at 212-13.
Because we were not sure that the supreme court would
change this practice after the 1995 amendments to the
PCRA, we found that state review of Bank's unexhausted
claims was not foreclosed. Id. at 214.
In deciding Banks, we relied on Doctor v. Walters, supra,
which involved a defendant who fled during the lunch
recess of his criminal bench trial on the charge of
aggravated assault following the presentation of the
Commonwealth's case. When the defendant failed to return,
the trial court, without informing the defendant, his
counsel, or the Commonwealth, entered a guilty verdict
against Doctor. Upon his capture five years later, Doctor
was sentenced to a term of 49 to 98 months in prison. He
filed a timely direct appeal to the Pennsylvania Superior
Court which quashed the appeal without reaching the
merits based on the fugitive forfeiture rule.23 Both the
Pennsylvania Supreme Court and the United States
Supreme Court also declined to hear his appeals. In his
federal habeas petition, Doctor raised a Sixth Amendment
claim which had not been presented to any Pennsylvania
court. We found that although the Pennsylvania courts
would hold, on collateral review, that Doctor waived the
right to assert his Sixth Amendment claim on procedural
grounds, PCRA review was not clearly foreclosed since
Doctor may be able to show that a " `miscarriage of justice'
warranting `departure from the PCRA's stringent eligibility
requirements' " has occurred. 96 F.3d at 681-82 (citation
omitted).
_________________________________________________________________
16 of 26
6/1/2006 3:04 AM
Page 376 of 2301
23. Rule 1972(6) of the Pennsylvania Rules of Appellate Procedure

permits a Pennsylvania appellate court to quash an appeal because the
appellant is a fugitive. Doctor v. Walters, 96 F.3d 675, 678 (3d Cir.
1996).
22
Likewise, in Toulson v. Beyer, we considered whether it
would be futile to require the petitioner to exhaust his state
remedies first. 987 F.2d at 986. There the defendant was
convicted in a New Jersey court of various non-capital
offenses. After a series of unsuccessful direct appeals to the
New Jersey courts and the denial of his motion for postconviction relief by the state trial court, Toulsonfiled a
federal habeas petition containing unexhausted but
procedurally barred claims in addition to exhausted claims.
In examining pertinent New Jersey law, we found that it
was possible that a New Jersey court may allow state
review of otherwise procedurally barred claims based on
one of two statutory exceptions to the procedural bar rule.
987 F.2d at 988. Accordingly, we held that "[b]ecause no
state court has concluded that petitioner is procedurally
barred from raising his unexhausted claims and state law
does not clearly require a finding of default, . .. the district
court should have dismissed the petition without prejudice
for failure to exhaust state remedies." Id. at 989. Thus, our
precedent makes clear that Lambert must exhaust her state
remedies before she can seek federal habeas relief unless
such an attempt would be futile. Doctor, 96 F.3d at 681
(citing Toulson, 987 F.2d at 987).
Futility may be encountered where exhaustion is
impossible due to procedural default, i.e., the state court
refuses to hear the merits of the claim because either (1)
the defendant waived a PCRA claim she could have raised
in an earlier proceeding but failed to do so; or (2) some
other procedural bar exists, such as a statute of
limitations. Doctor, 96 F.3d at 681. Moreover, a federal
habeas court may excuse exhaustion because of a
procedurally barred claim in state court "only when state
law `clearly foreclose[s] state court review of [the]
unexhausted claims.' Toulson, 987 F.2d at 987." Doctor, 96
F.3d at 681. We further explained:
If the federal court is uncertain how a state court
would resolve a procedural default issue, it should
dismiss the petition for failure to exhaust state
remedies even if it is unlikely that the state court
would consider the merits to ensure that, in the
interests of comity and federalism, state courts are
23
given every opportunity to address claims arising from
state proceedings. See Vasquez v. Hillery, 474 U.S.
254, 257, 106 S.Ct. 617, 620, 88 L.Ed.2d 598 (1986);
Toulson, 987 F.2d at 987.
Id. We must determine, therefore, whether, in the case
before us, Pennsylvania collateral review is "clearly
foreclosed" such that further state proceedings are futile.
17 of 26
6/1/2006 3:04 AM
Page 377 of 2301
C.
In Pennsylvania, collateral review of a criminal conviction
is available under the Post Conviction Relief Act ("PCRA") of
1995, 42 Pa. Con. Stat. Ann. SS 9541-46 (West 1997 Supp.).24
The scope of the relief provided under the PCRA is limited
to "persons convicted of crimes they did not commit and
persons serving illegal sentences . . .".25 42 Pa. Con. Stat.
Ann. S 9542. Section 9542 further provides that the PCRA
"shall be the sole means of obtaining collateral relief and
encompasses all other common law and statutory remedies
for the same purpose that exist when [the PCRA] takes
effect, including habeas corpus and coram nobis." The
PCRA also imposes several eligibility criteria for relief. First,
the petitioner must plead and prove by a preponderance of
the evidence that she is, at the time relief is granted,
currently serving a sentence of imprisonment, or is on
probation or parole, or is awaiting execution of a death
sentence. 42 Pa. Con. Stat. Ann. S 9543(a)(1). Second, the
petitioner must prove by a preponderance of the evidence
that her conviction or sentence resulted from one or more
of seven categories of claims, only three of which are
relevant. We paraphrase them here:
(1) The petitioner's rights under the Pennsylvania
_________________________________________________________________
24. The PCRA of 1995 became effective on January 16, 1996, and
applies to postconviction petitions filed on or after that date. The PCRA
was subsequently amended by Act No. 1997-33 (H.B. 87), effective June
25, 1997, but the changes are irrelevant to the dispute before us.
25. Because it provides a limited scope of relief, the PCRA of 1995 has
been described as "one of the most restrictive and narrow of all the
modern state postconviction remedies." Donald E. Wilkes, Jr., State
Postconviction Remedies and Relief, App. A, p. 760 (1996 Ed.).
24
Constitution or the Constitution or laws of the United
States were violated which, under the circumstances,
so undermined the truth-determining process that no
reliable adjudication of guilt or innocence could have
taken place.
(2) The petitioner received ineffective assistance of
counsel which, under the circumstances, so
undermined the truth-determining process that no
reliable adjudication of guilt or innocence could have
taken place.
(3) Exculpatory evidence, which was unavailable at
the time of trial, was subsequently discovered and
would have changed the outcome of the trial if it had
been introduced.
42 Pa. Con. Stat. Ann. S 9543(a)(2)(i), (ii), and (vi).
Next, the petitioner must show by a preponderance of the
evidence that the alleged error has not been previously
litigated or waived. 42 Pa. Con. Stat. Ann. S 9543(a)(3). "An
issue will be deemed previously litigated when `the highest
18 of 26
6/1/2006 3:04 AM
Page 378 of 2301
appellate court in which the petitioner could have had

review as a matter of right has ruled on the merits of the
issue,' " Commonwealth v. Morales, 701 A.2d 516, 1997 WL
578289, *1 (Pa. Sept. 17, 1997) (quoting 42 Pa. Con. Stat.
Ann. S 9544(a)(2)), or "it has been raised and decided in a
proceeding collaterally attacking the conviction or
sentence." 42 Pa. Con. Stat. Ann. S 9544(a)(3). In her
federal habeas petition, Lambert advances three claims
which were previously litigated in the direct appeal of her
conviction and sentence. Accordingly, Lambert is not
entitled to postconviction relief on those claims under the
PCRA and has thus exhausted her state remedies as to
these three claims.
Finally, by a preponderance of the evidence, the
petitioner must demonstrate that the failure to litigate an
issue previously was not the result of any rational, strategic
or tactical decision by counsel. 42 Pa. Con. Stat. Ann.
S 9544(a)(4). Neither the contentions of the parties nor the
evidence of record suggests that Lambert's trial counsel
strategically planned to exclude in her direct appeal some
of the claims now raised.
25
Particularly significant to this appeal is the PCRA
provision on waiver, which states, "an issue is waived if the
petitioner could have raised it but failed to do so before
trial, at trial, during unitary review, on appeal or in a prior
state postconviction proceeding." 42 Pa. Con. Stat. Ann.
S 9544(b). In this regard, the Pennsylvania courts have held
"that nearly all claims are waived under the PCRA since
nearly all claims potentially could have been raised on
direct appeal. This applies even if the first-time petitioner
never has obtained appellate review of his conviction."
Commonwealth v. Eaddy, 614 A.2d 1203, 1207-08
(Pa.Super. 1992), appeal denied, 626 A.2d 1155 (Pa. 1993).
Prior to 1995, the PCRA also provided two exceptions to the
waiver rule. If the alleged error either (1) resulted in the
conviction of an innocent person, or (2) did not constitute
a state procedural default barring federal habeas relief,
then the waiver was excused. 42 Pa. Con. Stat. Ann.
SS 9543(a)(3)(ii) and (iii) (West 1988). Neither of these two
exceptions, however, is available to Lambert since her
direct appeal was not final until after the effective date
of the 1995 amendment to the PCRA. While Lambert
maintains and the district court held that elimination of
these two exceptions in the 1995 amendment effectively
bars relief under the PCRA on all claims, we are not
convinced that this is necessarily the case.
In the past, the Pennsylvania Supreme Court has allowed
the petitioner, in limited circumstances, to overcome the
waiver provisions where he has made a strong prima facie
showing that a "miscarriage of justice" may have occurred.
Commonwealth v. Lawson, 549 A.2d 107, 112 (Pa. 1988). In
order to prevail under this theory, the petitioner must show
either: "(a) that the proceedings resulting in[the] conviction
were so unfair that a miscarriage of justice occurred which
no civilized society can tolerate, or (b) that [the petitioner]
is innocent of the crimes charged." Commonwealth v.
Szuchon, 633 A.2d 1098, 1100 (Pa. 1993) (citing Lawson,
549 A.2d at 112). In a concurring opinion, Justice
19 of 26
6/1/2006 3:04 AM
Page 379 of 2301
Papadakos provided the following edification on

"miscarriage of justice":
A miscarriage of justice, like prejudice, can only occur
where it is demonstrated that a particular omission or
26
commission was so serious that it undermined the
reliability of the outcome of the proceeding. Where a
conviction can be shown to result from a breakdown in
the adversary process, the conviction rendered is
unreliable. Such a conviction is obviously prejudicial to
the defendant and, if allowed to stand, is a miscarriage
of justice.
Lawson, 549 A.2d at 112 (Papadakos, J., concurring).
Moreover, we noted in Doctor that allegations of a
miscarriage of justice have been permitted to override the
waiver provisions of the PCRA in the context of successive
PCRA petitions, which was the situation in Lawson, supra.
96 F.3d at 682 n. 6. We further noted that the
Pennsylvania courts, however, have not addressed whether
a showing of miscarriage of justice can be applied to
overcome the waiver provisions in an initial PCRA petition.
Id. In Doctor, we refused to find that collateral review was
foreclosed since we concluded that Pennsylvania case law
left open the possibility that a showing of miscarriage of
justice can overcome the waiver provisions in an initial
PCRA petition. Id. We thus concluded that a return to state
court would not be futile. Id. at 683.
In Banks, we reiterated our policy regarding review of
waived or procedurally defaulted claims, which we originally
stated in Toulson and applied in Doctor :
[I]n the absence of a state court decision indicating
that a habeas corpus petitioner is clearly precluded
from state court relief, the district court should dismiss
the claim for failure to exhaust even if it is not likely
that the state court will consider petitioner's claim on
the merits.
126 F.3d at 211. We have applied this policy to all habeas
corpus cases involving state convictions regardless of the
sentence imposed. Whether, in fact, state case law exists
which establishes unequivocally that state relief is
precluded would depend on the particular facts of the case.
Although factually Banks is distinguishable from Lambert's
situation, the general rule of Banks governs our resolution
of this dispute.26 Neither Lambert nor the district court
_________________________________________________________________
26. Lambert argues our decisions in Banks and Doctor are
distinguishable and, therefore, inapposite. Lambert attempts to
27
cites any authority to the contrary. The Commonwealth, on
the other hand, cites several decisions in which
Pennsylvania courts have expressed a willingness to depart
20 of 26
6/1/2006 3:04 AM
Page 380 of 2301
from the PCRA's stringent waiver standards for non-capital,

as well as capital cases, where actual innocence or manifest
injustice is alleged. See Commonwealth v. Moss , 689 A.2d
259, 262 (Pa.Super. 1997) (where there is a strong prima
facie showing that a miscarriage of justice may have
occurred in a rape conviction, court will consider the merits
of a fifth PCRA petition); Commonwealth v. Williams, 660
A.2d 614, 618-19 (Pa.Super. 1995), appeal denied , 674
A.2d 1071 (Pa. 1996) (although the court denied PCRA
_________________________________________________________________
distinguish Doctor on the basis that the petitioner failed to raise in the
state court the legal theory and facts supporting his habeas claim, and
that we were referring to the pre-amendment PCRA when we noted the
availability of a "miscarriage of justice" exception to the waiver rule. Our
holding in Doctor is clear: Pennsylvania case law leaves "open the
possibility that a showing of miscarriage of justice can overcome the
waiver provisions in an initial PCRA petition." 96 F.3d at 682 n.6. In
reaching this conclusion, we were construing the PCRA as amended in
1995, as evidenced by our citation to the 1996 supplement and the
language of the statute as amended in 1995.
Lambert distinguishes Banks on the basis that it is a death penalty
case with a clearly existing avenue for state court review. In a letter brief
to the court dated September 30, 1997, Lambert states:
In other words, Banks, Toulson, and Doctor hold only that a
petitioner should be returned to state court to pursue an avenue of
review that clearly exists. The present case presents precisely the
opposite situation. Here, the avenue of state review-- indeed, the
very review opportunity that was available in Toulson and Doctor -has been permanently blockaded by an explicit act of the
Pennsylvania legislature eliminating the waiver excuses and
advertently sending the cases at issue, including Lambert, to federal
court where waiver excuses still exist; and the practice in death
sentence cases of ignoring waivers that was available in Banks is
inapplicable.
Further, Lambert states that "where the legislature has advertently
channeled the case at issue to federal court--the district court should
proceed to the cause and prejudice/miscarriage of justice inquiry under
Schlup [v. Delo, 513 U.S. 298 (1995)]." (Citing Carter v. Vaughn, 62 F.3d
591, 595 (3d Cir. 1995)).
28
relief to a defendant who pled nolo contendere to robbery, it
acknowledged that Pennsylvania courts will address the
merits of waived claims upon a showing of manifest
injustice); Commonwealth v. Fiore, 665 A.2d 1185, 1194
(Pa.Super. 1995), appeal denied, 675 A.2d 1243 (Pa. 1996)
(Hoffman, J., concurring, wrote separately "to emphasize
that there are circumstances where a departure from the
PCRA's stringent eligibility requirements is appropriate,
such as where there are extraordinary circumstances or a
miscarriage of justice.").
A showing of ineffective assistance of counsel may also
excuse waiver. Morales, 701 A.2d 516, 1997 WL 578289, *2
(citing Commonwealth v. Christy, 656 A.2d 877, 881 (Pa.),
cert. denied, ___ U.S. ___, 116 S.Ct. 194 (1995)) (ineffective
assistance of counsel could be a basis for post-conviction
relief only if the defendant had a constitutional right to
21 of 26
6/1/2006 3:04 AM
Page 381 of 2301
counsel in the proceeding in which he claimed

ineffectiveness); see also Commonwealth v. Buehl , 658 A.2d
771, 777 (Pa. 1995) (three members of a divided court
interpreted the PCRA to require a defendant claiming
ineffectiveness of counsel to meet a more demanding
standard of prejudice than if he had raised this issue on
direct appeal); Thomas M. Place, Ineffective Assistance of
Counsel Under the Pennsylvania Post Conviction Relief Act,
69 Temple L. Rev. 1389 (1996). Waiver of errors under the
PCRA will be excused for ineffective assistance of counsel if
the defendant had a constitutional right to counsel at the
stage in the proceedings where counsel's ineffectiveness
brought about the waiver. Place, supra, at 1410 (citing
Christy, 656 A.2d at 881) (additional citation omitted).
"Consequently, ineffectiveness of counsel will only excuse
waiver of errors for claims where counsel is ineffective at
trial and on direct appeal." Id. (citing Christy, supra). If the
underlying claim was previously litigated on appeal, postconviction relief is not available based on a claim of
ineffective assistance of counsel. Id. (citations omitted).
Moreover, an ineffectiveness claim " `must be raised at the
earliest stage in the proceedings at which the allegedly
ineffective counsel is no longer representing the
[defendant].' " Id. (citing Commonwealth v. Griffin, 644 A.2d
1167, 1170 (Pa. 1994)). Finally, it should be noted that
"[c]ounsel's performance in terms of waiver becomes an
29
issue only in those cases where new counsel represents the
defendant at post-trial motions. If the new counsel does not
preserve the issue of the trial counsel's ineffectiveness in
post-trial motions, the new counsel waives the issue unless
a court determines that post-trial counsel provided
ineffective representation." Id. (footnote omitted).27
Our review of Pennsylvania decisional law leads us to
conclude that it is unclear after the 1995 amendments to
the PCRA whether the Pennsylvania courts would allow a
showing of miscarriage of justice to overcome the waiver
provisions in a non-capital case upon an initial PCRA
petition. Indeed, we have not discovered cases addressing
this issue after the passage of the 1995 amendments.
Accordingly, we cannot say that requiring Lambert to seek
review of her claims in the state courts is futile. 28
_________________________________________________________________
27. Although neither party has addressed the issue of whether
ineffectiveness of counsel excused waiver, the Commonwealth
acknowledged in its letter brief dated September 30, 1997, Pennsylvania
decisional law holding that "PCRA courts will consider claims which
otherwise would be deemed waived when raised under the rubric of
ineffective assistance of counsel." Commonwealth v. K.M., 680 A.2d 1168,
1171 n. 8 (Pa.Super. 1996) (citing Commonwealth v. Griffin, 644 A.2d
1167 (Pa. 1994)). Moreover, it is possible that Lambert could argue in a
PCRA petition that second post-trial counsel provided ineffective
representation in not raising the unexhausted claims in her direct
appeal. Since Lambert is now represented by different counsel, arguably
she would be raising the unexhausted claims at the earliest stage in the
proceedings at which previous counsel provided allegedly ineffective
representation. The uncertainty surrounding the availability of this
exception to the waiver rule further supports dismissal of the habeas
petition to allow the state court the opportunity to rule in the first
22 of 26
6/1/2006 3:04 AM
Page 382 of 2301
instance.
28. We find the district court erred in concluding that the
Commonwealth waived the exhaustion defense when it temporarily
conceded during the evidentiary hearing that Lambert was entitled to
some relief. Considering the circumstances under which the concession
was made, i.e., the Commonwealth was forced to defend the petition on
the merits without the benefit of a ruling on its exhaustion defense prior
to the evidentiary hearing, the fact that the Commonwealth continuously
maintained that Lambert had failed to exhaust her state remedies at all
stages of the proceedings, and the requirement that the waiver be
expressly given, we cannot say the Commonwealth waived the
exhaustion defense.
30
III.
In seeking state collateral review of her nonexhausted
claims, Lambert has several options. It is possible that
under 42 Pa. Con. Stat. Ann. S 5103, Lambert may transfer
her federal proceeding to the appropriate Pennsylvania
court. In addition, Lambert may institute a PCRA action
utilizing one or more of the three exceptions to the PCRA
statute of limitations, which allows for the filing of a PCRA
petition at the present time. We discuss these options
briefly.
A.
The Pennsylvania Transfer Statute provides in pertinent
part:
(a) General rule.--If an appeal or other matter is taken
to or brought in a court . . . of this Commonwealth
which does not have jurisdiction of the appeal or other
matter, the court . . . shall not quash such appeal or
dismiss the matter, but shall transfer the record
thereof to the proper tribunal of this Commonwealth,
where the appeal or other matter shall be treated as if
originally filed in the transferee tribunal on the date
when the appeal or other matter was first filed in a
court . . . of this Commonwealth.
42 Pa. Con. Stat. Ann. S 5103(a) (West 1997 Supp.) In the
case of actions originally filed in any United States court,
the statute further provides:
[Section 5103(a)] shall also apply to any matter
transferred or remanded by any United States court for
a district embracing any part of this Commonwealth. In
order to preserve a claim under Chapter 55 (relating to
limitation of time), a litigant who timely commences an
action or proceeding in any United States court for a
district embracing any part of this Commonwealth is
not required to commence a protective action in a court
. . . of this Commonwealth. Where a matter is filed in
any United States court for a district embracing any
part of this Commonwealth and the matter is
dismissed by the United States court for lack of
31
23 of 26
6/1/2006 3:04 AM
Page 383 of 2301
jurisdiction, any litigant in the matter filed may

transfer the matter to a court . . . of this
Commonwealth by complying with the transfer
provisions set forth in [section 5103(b)(2)].
42 Pa. Con. Stat. Ann. S 5103(b)(1) (West 1997 Supp.).
Although the transfer act clearly applies when the
original court lacks jurisdiction over the appeal or other
matter, we believe it may also apply here where the district
court dismisses a federal habeas petition for failure to
exhaust state remedies.29 The language of section 5103(b)(1)
indicates that a purpose of the statute is to prevent the
barring of claims and other matters under the statute of
limitations when the original court lacked jurisdiction over
a matter which was timely filed. Applying the transfer act
under the facts here would be entirely consistent with the
purpose of the statute.
We hasten to add, however, that we are not endorsing the
application of the transfer statute in all federal habeas
actions dismissed for nonexhaustion. Rather, we suggest
that transfer may be appropriate where, as here, the
district court did not originally dismiss the petition for
failure to exhaust state remedies. Instead, the court
prematurely proceeded to adjudicate the merits of the claim
during which the one-year statute of limitations expired.
Under these unique circumstances, the Pennsylvania
transfer statute may apply and any action commenced by
Lambert under the PCRA would be treated as filed on
September 12, 1996, the date on which she filed her
petition for writ of habeas corpus in the district court.
B.
Lambert has yet another option. The 1995 amendment to
the PCRA enacted for the first time a one-year statute of
limitations.30 Since the effective date of the 1995 Act is
_________________________________________________________________
29. When a district court dismisses a federal habeas petition for
nonexhaustion, it nevertheless has jurisdiction. The dismissal is based
on principles of comity afforded state courts.
30. Prior to the 1995 amendment, the PCRA did not contain a
limitations provision for filing a PCRA petition.
32
January 16, 1996, and Lambert's direct appeal wasfinal on
July 2, 1996, under 42 Pa. Con. Stat. Ann. S 9545(b)(1),
she had until July 1, 1997 to file a PCRA petition.31 A literal
reading of section 9545 indicates that by failing tofile a
PCRA petition on or before July 1, 1997, Lambert may now
be barred from filing a PCRA petition on her unexhausted
claims. Section 9545 also contains three exceptions to the
one-year filing requirement. Essentially, the limitations
period will be excused where (1) the petitioner failed to raise
the claim previously due to interference by government
officials with the presentation of the claim in violation of
the constitutions and laws of the United States and
Pennsylvania; (2) the facts upon which the claim is based
24 of 26
6/1/2006 3:04 AM
Page 384 of 2301
were unknown to the petitioner and could not have been

discovered through due diligence; or (3) the claim involves
a constitutional right recognized by the Supreme Court of
the United States or of Pennsylvania subsequent to the
expiration of the statute of limitations and held to apply
retroactively. 42 Pa. Con. Stat. Ann. S 9545(b)(1)(i), (ii), and
(iii). Interestingly, the original version of the bill proposing
the 1995 amendments to the PCRA contained a fourth
exception to the one-year time limit which was eliminated
before final passage. That exception would have allowed a
waiver of the statute of limitations where "[t]here is a
compelling need to address the claim because of a
fundamentally unfair trial, illegal sentence or some other
manifest injustice." H.R. 179-66, 1st Spec. Sess., at 510
(Pa. 1995).32
_________________________________________________________________
31. Section 9545(b) states in relevant part:
(1) Any petition under [the PCRA], including a second or
subsequent petition, shall be filed within one year of the date the
judgment becomes final. . . .
(3) [A] judgment becomes final at the conclusion of direct review,
including discretionary review in the Supreme Court of the United
States and the Supreme Court of Pennsylvania, or at the expiration
of time for seeking the review.
32. The debate on this amendment centered on the concerns of certain
representatives that by providing a "manifest injustice" exception, they
would be opening a Pandora's box for the Pennsylvania appellate courts.
H.R. 179-66, 1st Spec. Sess., at 510 (Pa. 1995). Mr. Piccola argued that
33
The possibility exists that Lambert may be able to plead
and prove one or more of the excuses to the statute of
limitations. For example, Lambert has alleged in her federal
habeas petition that she discovered certain exculpatory
evidence after her conviction for first degree murder.
Moreover, she cites numerous instances of alleged
prosecutorial misconduct which, if proven, may be
sufficient to fall within the first exception of
unconstitutional interference by government officials. We
note that to date, no Pennsylvania court has been asked to
decide under what circumstances it would excuse an
untimely PCRA petition under the new statute of limitations
provision.33 Thus, Lambert may be able to proceed under
the PCRA.
_________________________________________________________________
Pennsylvania case law does not provide guidance on what constitutes
"manifest injustice" and cautioned against passing these words into the
statute without defining them. Id. At 511. He further commented that
the current bill (S.B. 81) contained adequate protection for the criminal
defendant who finds new evidence after trial, as well as in many other
circumstances. Id. The "manifest injustice" amendment was eventually
defeated. Id. at 512. On the other hand, Mr. Thomas, who introduced the
amendment, argued that "the amendment provide[d] a protective
mechanism in situations where there is conduct that does not arise until
way beyond the statutory period," . . . . Id. at 510. He further
commented that "fairness would require that we provide an . . . avenue
of relief, in situations where individuals do not come face to face with
25 of 26
6/1/2006 3:04 AM
Page 385 of 2301
conduct that has resulted in either their incarceration or their harm

beyond that . . . statutory year that is provided for in this particular bill."
Id. at 510-11. He opined that passage of the bill without the avenue of
review provided in the amendment would cause a disservice to the whole
judicial system. Id. at 511.
33. Under the prior statute which did not contain a statute of
limitations provision, the Pennsylvania courts were lenient in allowing
collateral review after long delays, especially in situations involving
ineffective assistance of counsel. See, e.g., Commonwealth v. Johnson,
532 A.2d 796 (Pa. 1987) (mere delay, standing alone, may not be
sufficient reason to reject PCRA petition summarily); Commonwealth v.
McCabe, 519 A.2d 497 (Pa.Super. 1986) (a PCRA petition filed six years
after the supreme court affirmed denial of his petition to set aside an
illegal sentence was not untimely); Commonwealth v. Taylor, 502 A.2d
195 (Pa.Super. 1985), appeal denied (1986) (unexplained delay in filing
first PCRA petition is a factor to be considered in assessing the merits of
the claims raised in the petition, but is not a basis for refusing to
consider the claims by reason of laches and waiver).
34
IV.
One final matter bears mention. Each side has brought to
our attention serious factual issues concerning the district
court's finding that Lambert was actually innocent of first
degree murder. In light of our resolution of Lambert's
petition, we need not comment on Lambert's actual
innocence. Indeed, to do so would be to "deprive the state
courts of an òpportunity to correct their own errors, if
any,' " Doctor, 96 F.3d at 683 (citing Toulson, 987 F.2d at
989), by engaging in a premature examination of the verdict
prohibited by Congress under the AEDPA.
We do not, however, diminish the obvious sense of
outrage expressed by the prosecution nor that of the able
district judge who heard and evaluated the evidence
Lambert proffered. Resolution of these difficult questions
must nonetheless await the appropriate forum for the
constitutional balance our forefathers created to remain in
equipoise. Accordingly, we will vacate the order of the
district court granting the petition for writ of habeas corpus
and remand to the district court with the direction to
dismiss the petition without prejudice.
A True Copy:
Teste:
Clerk of the United States Court of Appeals
for the Third Circuit
35
26 of 26
6/1/2006 3:04 AM
LancasterOnline.com:
News
Lambert sex case back in court Page 386 of 2301
Sunday January
22, :2017
http://local.lancasteronline.com/6/206525
Stan J. Caterbone
LAMBERT CASE FILE
LancasterOnline.com
Lambert sex case back in court
Convicted killers 1996 civil suit against Pa. prison officials advances.
By CINDY STAUFFER, Staff
Lancaster New Era
Published: Jul 06, 2007 1:13 PM EST
LANCASTER COUNTY, PA Lisa Michelle Lambert has returned to the court
system, a place where she spent years
appealing her conviction in the 1991 murder of
16-year-old Laurie Show.
But this time Lambert will be in civil court,
pursuing again a lawsuit against
Pennsylvania prison officials, who, she says,
allowed two guards to sexually attack, fondle
and photograph her naked at a prison in
Cambridge Springs 13 years ago.
A judge recently ruled the case, originally filed in 1996, can now go
forward. It had been put on hold while Lambert pursued her criminal
appeals, which went all the way to the U.S. Supreme Court. The
nation's highest court declined to hear Lambert's case in 2005.
Much has happened in the 11 years since Lambert first filed her civil
suit.
Two of the six people she's suing in her civil case have since died.
Lambert has moved around to prisons in Delaware and then New
Jersey. About a year and a half ago, she was moved to a
Massachusetts prison for "security reasons."
Lambert is now 34. The daughter she had while in prison turned 15
this past spring.
If Lambert wins any money from the civil case, it first will go to pay
off court costs and restitution, her attorney said. If any money is
left, it likely would go to her parents, who are raising her daughter,
he said.
Lambert's suit alleges a prison guard, James Eicher, attacked her six
times in 1994. Another official, John Raun, fondled her, her suit
alleges.
Eicher was later fired and then convicted of aggravated indecent
assault and indecent assault in the case. He served two years in
prison, and was paroled in December 1999.
Lambert's civil suit also alleges that prison officials ignored her
complaints and later videotaped and photographed her without
clothing on.
Lambert's attorney, Angus Love of the Pennsylvania Institutional
Law Project, also said that two similar civil suits brought against
Cambridge Springs officials by other female inmates were settled
immediately.
1 of 3
7/6/2007 3:38 PM
News
Sunday January
22, :2017
Stan J. Caterbone
LAMBERT CASE FILE
He does not know what will happen in this case.

"I don't know if Lisa will want to settle, whether the state will want
to settle," said Love, whose office is in Philadelphia.
The state attorney general's office plans to vigorously defend the
case, a spokesman said today.
Kevin Harley said that Lambert's allegations about Raun and about
being photographed and videotaped naked are both false.
With regard to Eicher, Harley said Lambert willingly engaged in
sexual contact with him. However, the law prohibits prison officials
from engaging in sexual relations with inmates, even if consensual,
which resulted in Eicher's conviction, Harley said.
"Eicher was fired, charged, convicted and sent to state prison," he
said. "He's out. ... He broke the the law but it does not mean the
entire system was broken down."
However, U.S. District Judge Sean McLaughlin had a different view of
Lambert's allegations.
"Plaintiff paints a disturbing picture," McLaughlin wrote, saying
Lambert alleged Cambridge Springs was a "virtual haven of sexual
activity between Department of Corrections employees and
inmates."
The judge also found that a former prison superintendent and
official "fostered an attitude of acquiescence toward such pervasive
misconduct."
In a handwritten response to Lambert's lawsuit, Eicher denied the
allegations and said he was convicted due to a poorly conducted
investigation, false police statements and false testimony by
Lambert.
Love said he will not ask for a specific settlement amount, but leave
that up to a jury, if the case proceeds to court.
Lambert now is serving her life sentence at a state prison in
Framingham, Mass. She was moved there in January 2006 from a
New Jersey prison.
Matt Schuman, a New Jersey corrections department spokesman,
said only that Lambert was moved for "security reasons," which
officials do not elaborate on.
This is the fifth prison for Lambert, who also was held in Lancaster
County Prison, Cambridge Springs and prisons in Delaware and then
New Jersey.
Love said Lambert had "a little problem" with some inmates in New
Jersey.
He said she was held in isolation during her time in New Jersey and
now is happy to be out in the general prison population.
She is taking college courses, taught by Boston University
professors, and earning good grades, he said.
She regularly sees her daughter and parents, who have moved out
of Pennsylvania. Love declined to say where they are living.
2 of 3
7/6/2007 3:38 PM
News
Sunday January
22, :2017
Stan J. Caterbone
LAMBERT CASE FILE
Lambert was convicted and sentenced to life in prison in 1992 for

stabbing Show to death in Show's East Lampeter Township home.
Lambert allegedly killed Show in a jealous rage over the younger
girl's relationship with Lambert's then-boyfriend, Lawrence Yunkin.
Yunkin, now 36, pleaded guilty to third-degree murder in the case
and was released to a halfway house in 2005.
Lambert's accomplice, Tabitha Buck, now 33, was convicted of
second-degree murder and is serving a life sentence.
CONTACT US: cstauffer@LNPnews.com or 481-6024
2004-2007 Lancaster Newspapers

3 of 3
7/6/2007 3:38 PM
Page 389 of 2301
Welcome to the Lancaster County Courts Web Site

Lambert
IN THE COURT OF COMMON PLEAS

OF LANCASTER COUNTY, PENNSYLVANIA
CRIMINAL
COMMONWEALTH OF
PENNSYLVANIA
v.
No. 0423 - 1992

:
Relief Act
:
:
Post Conviction
OPINION
BY: STENGEL, J., AUGUST 24, 1998
Click here to download self-extracting zipped file - Word Perfect format
Click here to download self-extracting zipped file - MS Word format
TABLE OF CONTENTS
I. INTRODUCTION
II. BACKGROUND
A. The Trial
B. Post Verdict Motions
C. State Court Appeals
D. The Petition for Writ of Habeas Corpus in the District Court
III. THE POST CONVICTION RELIEF ACT PETITION
A. Procedural History: Motions, Petitions, Conferences, Orders
B. Legal Issues Pertaining to this Petition and Hearing
1. Eligibility for PCRA relief
Page 390 of 2301
a. Constitutional violations: prosecutorial misconduct and Brady

b. Ineffective assistance of counsel
c. After-discovered evidence: subsequent availability of exculpatory
evidence
2. "Finally litigated" and waiver under the PCRA
3. This court's role
4. To lead or not to lead: adverse and hostile witnesses
IV. THE 1992 VERDICT: FINDINGS OF FACT AND CONCLUSIONS OF LAW
V. STATE COURT AND FEDERAL COURT
A. A Comity of Errors
B. What Does "Actual Innocence" Actually Mean?
VI. PETITIONER'S STORY LINE: A CONTEXT
VII. LISA MICHELLE LAMBERT'S CASE: ISSUES AND DISCUSSION
A. Laurie Show's Dying Declaration
B. The "29 Questions"
C. The Abuse Issue
1. Relationship with Lawrence Yunkin
2. Allegation of gang rape
3. Cambridge Springs
D. Tabitha Buck's Involvement
1. The scratch on Tabitha Buck's face
2. Tabitha Buck's animus
3. Scent of a co-defendant
4. Tabitha Buck's story
E. Lawrence Yunkin's Involvement
Page 391 of 2301
F. Kathleen Bayan's Observation

1. Credibility
2. Discovery obligation
3. Truth-determining process
G. Hazel Show's Recollection of Mr. Yunkin's Car
H. The Mihalakis Issue
I. Credibility of Laura Thomas
J. The Black Sweatpants
K. The River Search Video
L. Ms. Lambert's Statement
M. Crime Scene Photographs
1. The telephone cord around the leg
2 . Footprints in the hallway and bedroom
3 . The white sweatshirt
4. "Missing" or "destroyed" photographs
N. The Pearl Earring
O. Robert Reed's Testimony
P. Proposed Admissions from the Federal Record
Q. Ineffective Assistance of Counsel of Roy D. Shirk, Esquire
R. Ineffective Assistance of Counsel of Jules Epstein, Esquire
S. Mr. Madenspacher's "Concession"
T. Brady/Giglio Violations
U. The Commonwealth v. Smith Issue
VIII. CONCLUSION: THE QUE STION OF INNOCENCE
Page 392 of 2301
ORDER
ADDENDUM TO OPINION
I. INTRODUCTION
Lisa Michelle Lambert's petition under the Post Conviction Relief Act ("PCRA"), 42
Pa. C.S.A. Section 9541 et seq. (1998 Supp.),(1) is now before this court. Ms.
Lambert was convicted of first degree murder for the death of Laurie Show and
sentenced to life in prison. The guilty verdict was entered on July 20, 1992, after a
non-jury trial.
Ms. Lambert's petition contends that her conviction and sentence are wrongful,
illegal and unconstitutional on the basis of after-discovered evidence. She believes
that this after-discovered evidence proves her innocence and credibility, and
establishes a fundamental miscarriage of justice. She also argues that intentional
acts of prosecutorial misconduct, deliberate falsification of evidence, witness
tampering, violations of discovery obligations, presentation of perjured testimony
and ineffective assistance of both trial and appellate counsel formed the basis for
her conviction. Ms. Lambert contends that she cannot be retried because the
prosecution intended to deny her a fair trial.
The 257 claims stated in the amended petition present various facets of certain
major issues. In this opinion, we address these issues. This court has had an
opportunity to consider Ms. Lambert's claims in light of the testimony at her 1992
trial, the testimony at her eight week 1998 PCRA hearing and the legal issues and
arguments presented by her counsel and by the Commonwealth. On the basis of
this fully developed record, we are in a position to make factual findings, credibility
rulings and legal decisions in the interest of a full resolution of all claims raised by
Ms. Lambert.
We find that Hazel Show's testimony regarding her daughter's dying declaration
was credible in 1992 and remains credible today. We find that the expert analysis
so ably presented by both sides of this case does not constitute such "afterdiscovered evidence" as would cause this court to make any change in the
credibility determination which formed an important basis for the 1992 verdict.
We find that the so-called "29 questions" did not and could not raise a reasonable
doubt as to petitioner's guilt and does not form the basis for any contention that
the Commonwealth presented perjured testimony.
While sympathetic to the evidence of past abuse presented by Ms. Lambert, we do
not find, under the law, that her diagnosis as a "battered person" has any legal
impact on the issues before us.
We find petitioner's evidence regarding the involvement of Tabitha Buck and
Lawrence Yunkin to be fraught with concerns over Ms. Lambert's credibility. Should
we resolve many of those credibility questions in petitioner's favor, we still do not
believe the testimony about the involvement of others is exculpatory of Ms.
Lambert and it certainly does not establish her innocence.
Page 393 of 2301
We are concerned regarding the discovery issues arising out of the information
made available to the police in 1992 by Kathleen Bayan and by Hazel Show. After
careful analysis of the legal obligations of the Commonwealth and the credibility of
all the witnesses involved in these two issues, we do not believe the issues provide
a basis for relief under the PCRA.
In 1992 we resolved the issue regarding the contact by First Assistant District
Attorney John A. Kenneff with defense expert witness Isidore Mihalakis, M.D., in
advance of trial. Nothing about the hearing in 1998 changes our view of that issue.
We find the issues regarding Laura Thomas's credibility, Lawrence Yunkin's black
sweatpants, the video of the river search, the statement taken of Ms. Lambert, the
photographs of the crime scene and the pearl earring to have more sensational
appeal than legal merit. The issues have generated more heat than light in this
case.
We have analyzed the many allegations of constitutional or discovery violations and
find that the Commonwealth's compliance with the Pennsylvania Rules of Criminal
Procedure regarding discovery and the requirements of Brady v. Maryland(2) has
been well established by the facts and the law.
Finally, we find no basis in law or in fact to hold either trial counsel or appellate
counsel ineffective.
On the basis of our consideration of these issues, our study of the law and our
careful consideration of the now fully developed record, we find that Ms. Lambert
has not established a basis for relief under the Post Conviction Relief Act. Our
findings on the individual issues raised by the petition will be set forth in the
sections to follow.
II. BACKGROUND
Lisa Michelle Lambert, in addition to another woman, Tabitha Faith Buck, was
charged with criminal homicide for the death of Laurie Show. The homicide took
place on December 20, 1991, in the condominium occupied by Ms. Show and her
mother, Hazel Show. Ms. Lambert was 19 years old at the time; Ms. Show was 15
years old. A third person, Lawrence Stewart Yunkin, was charged with hindering
apprehension. Ms. Lambert was Mr. Yunkin's girlfriend; she was, at the time,
pregnant to him.
A. The Trial
After waiving her right to a trial by jury, Ms. Lambert proceeded to trial and was
found guilty of first degree murder and criminal conspiracy to commit murder on
July 20, 1992. The Commonwealth elected to seek the death penalty in the
Lambert case. Following a hearing on the penalty phase, the court declined to
impose the death penalty and sentenced Ms. Lambert to a term of life in prison
without the possibility of parole.
Page 394 of 2301
Ms. Lambert's post verdict motions were filed on July 28, 1992. In essence, Ms.
Lambert argued that her conviction was against the weight of the evidence. She
raised a dozen claims of error essentially challenging evidentiary or procedural
rulings,(3) but her primary thrust was that there was insufficient evidence to
support a conclusion that she was the killer of Laurie Show. The court denied Ms.
Lambert's post verdict motions in an opinion dated July 19,
1994. (4) No appeal was taken from that order.
Ms. Lambert's family then hired a new attorney who filed a request with this court
for a new trial on the basis of after-discovered evidence and the alleged
ineffectiveness of her court-appointed attorney. At the joint request of the assistant
district attorney and her privately-retained attorney, an evidentiary hearing was
conducted over a two-day period in November 1994. (5) Counsel indicated a desire
to take all issues up on appeal at that time.(6)
The post verdict evidentiary hearing addressed the issues of ineffective assistance
of counsel and after-discovered evidence. Ms. Lambert attacked only the assistance
of counsel rendered to her by Roy D. Shirk, Esquire.(7) Specifically, she claimed he
was ineffective for the following reasons: (1) failing to call character witnesses in
her defense; (2) failing to introduce evidence of abuse by Mr. Yunkin; (3) calling a
witness to contradict her testimony; (4) failing to seek suppression of statements
she made to the police; (5) failing to present evidence of bad reputation for the
veracity of witness Laura Thomas; (6) failing to seek a new trial based upon new
evidence of Mr. Yunkin's nolo contendere plea to third degree murder; and (7)
failing to impeach Mr. Yunkin with his statements to the police that he knew prior
to the death of Laurie Show of plans to physically harm her.
The after-discovered evidence was that Mr. Yunkin "lied" about his involvement in
the crime, thereby violating the terms of his plea agreement with
the District Attorney's Office.(8) Ms. Lambert argued that if she had known at trial
that Mr. Yunkin was going to violate his plea agreement and that he would admit to
third degree murder, her defense at trial would have been enhanced. New counsel
argued that "this Court was deprived of critical information--evidence that Yunkin
was not merely an accessory after the fact, but that he had deliberately lied, that
he was in breach of a plea agreement, and that he pled nolo contendere to
involvement in the killing of Laurie Show." (Defendant's Memorandum of Law in
Support of Post Verdict Motion for a New Trial at 14) The question was whether this
court, or any finder of fact, c ould reasonably have been swayed by an admission
that Mr. Yunkin had lied in his testimony at trial. A review of the record and a
consideration of the totality of the record showed that Mr. Yunkin's credibility was
dubious at best.
The court found that the "after-discovered" evidence was not really new evidence
at all. It was simply the same story introduced at the Lambert trial with a slightly
different "spin." The court denied Ms. Lambert's post verdict motion for a new trial
in an order and opinion dated March 14, 1995.
Page 395 of 2301
Ms. Lambert appealed this court's findings to the Superior Court of Pennsylvania,
raising essentially the same claims regarding ineffective assistance of trial counsel
and after-discovered evidence. Specifically, Ms. Lambert claimed that her trial
counsel was ineffective for failing to introduce evidence of her good character and
of the abuse inflicted upon her by Mr. Yunkin. Ms. Lambert also argued the afterdiscovered evidence of Mr. Yunkin's plea agreement and perjury. The Superior
Court affirmed the judgment of sentence without opinion on January 4, 1996.
Commonwealth v. Lambert, 450 Pa. Super. 714, 676 A.2d 283 (1996) (table).
In her appeal to the Pennsylvania Supreme Court filed on February 2, 1996, Ms.
Lambert raised the same claims. The petition for allowance of appeal to the
Supreme Court of Pennsylvania was subsequently denied without comment on July
2, 1996. Commonwealth v. Lambert, 545 Pa. 650, 680 A.2d 1160 (1996).

Ms. Lambert never filed a petition under the Pennsylvania Post Conviction Relief
Act. Instead, she sent a handwritten pro se petition for writ of habeas corpus to the
United States District Court for the Eastern District of Pennsylvania on September
12, 1996. Counsel was appointed by the district court to represent her on a pro
bono basis and an amended petition for writ of habeas corpus was filed on January
3, 1997. The petition included the claims previously presented in state court, but
also introduced new claims asserting that (1) Ms. Lambert was "actually innocent,"
(2) that there was massive misconduct by the prosecution and the police, (3) that
after-discovered evidence created manifest injustice, and (4) that trial counsel had
been ineffective in a multitude of ways.
In its answer to the amended petition, the Commonwealth maintained that Ms.
Lambert was not entitled to federal review because she had not exhausted her
state court remedies as to all of the claims in her pleading and had committed
procedural default. In the alternative, the Commonwealth claimed that the habeas
petition should be denied on its merits. The Commonwealth explicitly stated in its
pleading that it was not waiving the exhaustion requirement in any way.
Simultaneously with the first amended petition, counsel filed a motion for
permission to take discovery, which the Commonwealth opposed. The district court
granted the motion on January 16, 1997, citing unspecified unusual circumstances,
and ordered broad, expedited discovery in the federal habeas corpus proceeding.(9)
Despite the Commonwealth's objections to the petition on the grounds of
exhaustion, the matter proceeded to an evidentiary hearing(10) on Ms. Lambert's
claims of actual innocence and prosecutorial misconduct.(11) The hearing
commenced on March 31, 1997. (12) After 14 days of testimony, the district court
granted the writ, declared Ms. Lambert to be "actually innocent," barred the
Commonwealth from conducting a retrial for the murder of Laurie Show, and
permanently released Ms. Lambert from prison.
In its 90-page memorandum opinion of April 21, 1997, the district court found
numerous instances of prosecutorial misconduct and offered its opinion that some
Page 396 of 2301
of this conduct might involve criminal activity on the part of members of the
Lancaster County District Attorney's staff. The court also ruled that Ms. Lambert
had exhausted all her state claims with the exception of those based on afterdiscovered evidence. To the extent that there were claims which a Pennsylvania
court might view as not having been waived, the district court found that the state
proceedings would be ineffective to protect Ms. Lambert's rights. Lambert v.
Blackwell, 962 F. Supp. 1521, 1553-55 (E.D. Pa. 1997).
The district court referred First Assistant District Attorney Kenneff to the United
States Attorney for the Eastern District of Pennsylvania for investigation of
allegations of criminal activity in the prosecution of the Lambert homicide case. The
district court also (1) demanded that District Justice Ronald W. Savage, a former
county detective involved in the investigation of the Lambert case, be investigated
by the Judicial Conduct Board of the Pennsylvania Supreme Court, and (2) offered
its opinion that another assistant district attorney and two county detectives, one
now retired, were guilty of prosecutorial misconduct.
The district court's ruling was appealed to the Court of Appeals for the Third Circuit
on April 22, 1997. (13) On December 29, 1997, a three-judge panel of the Third
Circuit vacated the decision of the district court and remanded this case to the
district court with the direction to dismiss the federal habeas petition without
prejudice. Lambert v. Blackwell, 134 F.3d 506 (3d Cir. 1997). The Third Circuit
found that the district court was without jurisdiction to hear the case because Ms.
Lambert had not yet exhausted her state remedies. Ms. Lambert's application for
rehearing en banc was denied, with four judges dissenting.
While her application for rehearing was pending, Ms. Lambert moved for a stay of
the Third Circuit's order and also filed an emergency application seeking the same
relief from the United States Supreme Court. On February 2, 1998, the Third Circuit
refused to stay its order, as did Justice David H. Souter, as Circuit Judge, the same
day. Thereafter, petitioner surrendered to prison officials on February 4, 1998. (14)
A petition for writ of certiorari, seeking review of the Third Circuit's opinion, was
filed by petitioner on April 23, 1998, and is pending in the United States Supreme
Court, where it is docketed at No. 97-8812. On April 24, 1998, petitioner filed with
the Third Circuit an application, pursuant to Rule 23 of the Federal Rules of
Appellate Procedure, for release from custody pending the Supreme Court's
consideration of her petition for writ of certiorari. (15) This petition for release from
custody was denied by the Third Circuit in an order and opinion filed on August 3,
1998.
An unverified Post Conviction Relief Act petition was filed on behalf of Ms. Lambert
in the Court of Common Pleas of Lancaster County on February 2, 1998. (16)
Contemporaneously with the filing of the PCRA petition, Ms. Lambert's counsel filed
a petition with the Supreme Court of Pennsylvania requesting that the Supreme
Court assume King's Bench jurisdiction over this case, remove the PCRA petition
from the Court of Common Pleas of Lancaster County, render a decision based
upon the record established in the habeas corpus proceeding in district court, and
Page 397 of 2301
stay the reincarceration of Ms. Lambert pending her appeal.

On February 2, 1998, the district attorney requested the Commonwealth of
Pennsylvania Office of Attorney General to assume prosecution of this case. The
Attorney General granted that request under the Commonwealth Attorneys Act,
pursuant to 71 P.S. Section 732-205(a)(3) and (c) (1990). On February 9, 1998,
the Attorney General entered an appearance and filed pleadings in the Supreme
Court. On February 10, 1998, Ms. Lambert's attorneys asked the Supreme Court of
Pennsylvania to remove the Attorney General as counsel for the Commonwealth.
The Supreme Court denied petitioner's request for King's Bench jurisdiction and
issued an order dated February 25, 1998, remanding the PCRA petition to the Court
of Common Pleas of Lancaster County with a directive that the petition be disposed
of within 120 days.(17) The Court also dismissed the motion to compel removal of
the Attorney General without prejudice to petitioner's right to refile that motion in
the Court of Common Pleas. Lastly, the emergency motion for writ of prohibition to
prevent the reincarceration of petitioner was dismissed as moot, petitioner having
returned to prison on February 4, 1998.
This court obtained a copy of the order of the Supreme Court on March 2, 1998. (18)
The PCRA petition also was received in chambers on March 2, 1998. A copy of
petitioner's motion to disqualify the Attorney General was forwarded to the court on
March 4, 1998. A response was sent by the Attorney General on March 5, 1998,
and a hearing was held on this matter on March 6, 1998. (19)
Ms. Lambert's motion to compel removal of the Attorney General as counsel was
denied in an opinion and order dated March 11, 1998, the court having held that
the Attorney General had the power to prosecute the PCRA petition pursuant to 71
P.S. Section 732-205. Upon motion of counsel for petitioner, an additional order
was entered on March 11, 1998, directing the Commonwealth to file an answer to
the PCRA petition. The Attorney General subsequently filed a response to Ms.
Lambert's PCRA petition on behalf of the Commonwealth on March 31, 1998.
The original PCRA petition contained some 57 claims of after-discovered evidence,
117 claims of prosecutorial misconduct, including 45 claims of Brady/Giglio
violations, and 21 claims of ineffective assistance of counsel. For this reason, the
court did not impose an expedited deadline on the filing of an answer, but chose to
require an answer within the 20 days which would normally be required under the
Pennsylvania Rules of Civil Procedure for an answer to a complaint or a petition.
The Commonwealth's filing of an answer in 20 days in no way delayed the
proceeding, due to the plethora of motions filed by petitioner, which are chronicled
below.
On March 6, 1998, the court issued an "Order Limiting Publicity" which contained
the text of Rule 3.6 of the Rules of Professional Conduct.(20) This was the subject of
collateral litigation in this court which took place in March 1998 and which resulted
in a modification of the original order. (21) For a discussion, see Commonwealth v.
Lambert, 76 Lanc. L. Rev. 184 (1998), now pending in the Superior Court.
In addition to the motion to remove the attorney general, petitioner filed an
additional 17 prehearing motions or petitions for the court's consideration over an
eight-week period. Most of these matters were briefed by the parties; all were
Page 398 of 2301
argued orally before the court at petitioner's request. Petitioner's additional filings
will be set forth seriatim in chronological order.
On March 11, 1998, petitioner filed a motion to file the record of the habeas corpus
hearing before the federal district court with this PCRA court and to deny a hearing
on the issues covered therein. Received with this approximately 50-page motion
were 30 volumes of the Federal Court of Appeals' Appendix. After the issues were
briefed by the parties and argued by counsel, the court denied petitioner's motion
to enter the federal record as the record in this PCRA proceeding in an opinion and
order entered on April 6, 1998. (22) See Commonwealth v. Lambert, 76 Lanc. L.
Rev. 169 (1998).
Because Ms. Lambert's petition and the Commonwealth's response thereto raised
material issues of fact, the court, on April 6, 1998, entered an order scheduling a
hearing on the petition pursuant to Pa. R. Crim. P. 1508. A prehearing conference
was scheduled for April 9, 1998.
Ms. Lambert's counsel made oral motions at the prehearing conference on April 9,
1998, to have themselves and their law firm appointed as counsel for petitioner. In
the alternative, counsel requested that petitioner be permitted to proceed in forma
pauperis so that they could be reimbursed all costs incurred on petitioner's behalf.
Written motions regarding the appointment of counsel, the in forma pauperis status
of petitioner, and the reimbursement of costs were subsequently filed with the
Clerk of Courts on April 15, 1998.
Included in petitioner's prehearing memorandum of April 21, 1998, was a written
request to incorporate admissions of the Commo nwealth "actors" from prior
proceedings, as well as all of the police reports, police notes, and other documents
turned over by the Commonwealth during the federal proceeding. The
Commonwealth responded on April 20, 1998, with a motion in limine directed to
Ms. Lambert's proposed introduction of prior federal testimony as "admissions." On
April 23, 1998, after hearing argument from counsel, the court denied petitioner's
request to incorporate certain portions of the testimony from the federal habeas
proceeding as admissions against the Commonwealth in the PCRA proceeding.(23)
Petitioner next presented to the court on March 13, 1998, a 119-page motion for
bail and release on her own recognizance pending disposition of her PCRA petition
by this court. The parties filed legal memoranda and presented oral argument. An
opinion and order were entered on April 3, 1998, denying petitioner's motion for
bail. (24) See Commonwealth v. Lambert, No. 0423-1992, slip op. (Lanc. Co. C.P.
April 3, 1998).
Petitioner's first motion for discovery was received by the court on April 3, 1998,
and argued before the court at the first prehearing conference on April 9, 1998. At
the conclusion of the argument, the court issued a ruling from the bench regarding
the various discovery matters raised in petitioner's first discovery motion.(25)
Specifically, the court denied petitioner's request to (1) depose inmates at SCIDallas relative to statements allegedly made by Mr. Yunkin, (2) depose "Smokey"
Roberts regarding the existence of a report or log of his diving shoots, (3) obtain
discovery of the Commonwealth's "discriminate use of PCRA rules," (4) obtain
discovery of the Commonwealth's "purpose" in pursuing Ms. Lambert's PCRA, and
Page 399 of 2301
(5) obtain discovery of the Commonwealth's efforts to "intimidate" the judiciary

over the Lambert case. The court did grant petitioner's request for any logs
maintained by the police of all photographs taken by police in the murder
investigation, directing the Commonwealth to determine if they existed and, if so,
to produce them to petitioner.
On April 6, 1998, petitioner served a change of venue motion on the court. This
was followed on April 8, 1998, with a motion for definite pleading by the
Commonwealth on the issues of waiver and other procedural requirements under
the PCRA and for a determination by the court whether it would raise such issues
sua sponte. On April 15, 1998, petitioner filed a motion for sanctions against John
Show, the victim's father, and Justice Ronald Savage, a former officer with the East
Lampeter Police Department, for violation of the original "Order Limiting Publicity."
These three outstanding motions were argued via a speaker phone in the
courtroom at the second prehearing conference on April 21, 1998. (26)
Petitioner's counsel began the April 21, 1998, conference by requesting the
disqualification of this court pursuant to Rule 3(C)(1)(a) of the Rules of Professional
Responsibility. Counsel argued that because the court viewed a piece of evidence at
the 1992 trial in this matter, the court could be a fact witness at the PCRA
proceeding as to the physical nature of that evidence. Specific ally, Ms. Lambert
argued that the sweatpants introduced into evidence at the 1992 trial were not the
same sweatpants introduced at the federal habeas hearing in 1997. Counsel for
petitioner asserted that this court had personal knowledge of a disputed evidentiary
matter which required recusal. This court's findings regarding the size of the
clothing and its significance at trial were clearly stated in our July 19, 1994,
opinion. See Section IV, infra. Ms. Lambert's request was denied on the record
after the court considered the arguments of counsel.
The parties thereafter addressed the change of venue issue, the motion for definite
pleading by the Commonwealth, the motion for sanctions for violation of the "gag"
order, the motion for appointment of counsel, and the motion for reimbursement of
costs. At the conclusion of this first prehearing, the court issued oral rulings from
the bench denying the motion for a more definite pleading and denying the motion
for sanctions.(27) The court reserved its ruling on the other matters.
On April 23, 1998, the court held a third prehearing conference via a speaker
phone in the courtroom. Counsel discussed Ms. Lambert's petition to proceed in
forma pauperis, the request for reimbursement of costs, the motion for
appointment of counsel, and the change of venue motion. Immediately following
this conference on April 23, 1998, the court entered a written order confirming
rulings made from the bench and disposing of several other of petitioner's motions.
Specifically, (1) the court denied the motion for more definite pleading, (2) the
court denied as moot the motion for sanctions for violations of the gag order, (3)
the court denied the motion to sit outside Lancaster County, (4) the court denied
petitioner's request to incorporate certain admissions from the federal habeas
hearing, (5) the court granted the motion to proceed in forma pauperis and to have
all costs necessary for the PCRA proceeding reimbursed by the County, and (6) the
court denied the motion for court appointment of defense counsel. (28)
A second motion for discovery was filed by Ms. Lambert on April 28, 1998. In this
motion, petitioner requested (1) all evidence favorable to her which had not
Page 400 of 2301
previously been disclosed, (2) a summary of the anticipated testimony of each

witness the Commonwealth intended to call, (3) the addresses and telephone
numbers of all Commonwealth witnesses, (4) all evidence of any prior statements
that were inconsistent with testimony that the Commonwealth intended to offer in
the PCRA proceeding, (5) all documents that related to or embodied agreements or
proposed or prospective agreements between Commonwealth witnesses and/or
their counsel in exchange for testimony in the PCRA proceeding, (6) a copy of all
exhibits that the Commonwealth intended to use, and (7) the Commonwealth's
impressio ns as to why Tabitha Buck may have been untruthful in her federal
deposition.(29) The court granted petitioner's request for all Brady/Giglio (30)
materials, the addresses and telephone numbers of Commonwealth witnesses, and
copies of all Commonwealth exhibits. The remaining discovery requests were
denied.
On April 30, 1998, the first day the court heard testimony in this PCRA proceeding,
petitioner moved for leave to amend the PCRA petition. This motion was granted
the same day. In addition, petitioner filed three motions on April 30, 1998, all of
which were argued in open court.
The first was a motion to admit the federal court testimony of Haresh G.
Mirchandani, M.D., the chief medical examiner for Philadelphia. Dr. Mirchandani had
recently declined to appear as an expert witness for petitioner in her PCRA
proceeding in Lancaster. An order was entered on April 30, 1998, denying the
motion to admit the prior federal court testimony of Dr. Mirchandani as he was not
an "unavailable witness" as that term is defined in 42 Pa. C.S.A. Section 5917.
The second motion requested transcripts and corresponding ASCII disks of all
prehearing matters, as well as the PCRA proceeding. The court ordered that
transcripts be given to petitioner but declined to order the court reporters to
produce ASCII disks.
Lastly, on April 30, 1998, Ms. Lambert petitioned the court to retain an investigator
to assist in her case. An order was entered on May 13, 1998, granting this motion
and authorizing an investigator to be compensated by the court at the rate of
$40.00 per hour with a maximum allowable expense of $1,000.00 for the
investigation.(31) Petitioner subsequently filed a second motion for appointment of
an investigator to assist in her rebuttal case, which this court approved on June 16,
1998.
During the course of the PCRA hearing, petitioner presented seven additional
motions to the court. On May 28, 1998, petitioner filed a motion to subpoena the
bank statements, canceled checks, and church wedding records of Officer John
Bowman and his wife. This motion was granted on June 16, 1998, after an inchambers conference with counsel for the Bowmans.
Petitioner also filed motions in limine to preclude the expert testimony of three
Commonwealth witnesses: (1) Roger J. Levin, M.D., an otolaryngologist; (2) Wayne
K. Ross, M.D., a forensic pathologist; and (3) Joseph L. Burton, M.D., a forensic
pathologist.(32) Additionally, counsel for petitioner filed a motion in limine to
preclude all evidence not introduced at the 1992 trial and to limit the
Commonwealth's witnesses. Following oral argument by counsel, these motions in
Page 401 of 2301
limine were denied by the court on June 16, 1998.

The last two motions were filed by petitioner on June 10, 1998, at the close of her
case. Petitioner submitted a list of admissions to be offered into evidence. Those
proposed admissions will be addressed in this opinion in Section VII.P, infra. She
also filed a second motion for leave to amend the petition, which was granted on
June 16, 1998.
The Commonwealth filed two prehearing motions. As discussed previously, the
Commonwealth filed a motion in limine objecting to the proposed use of federal
testimony as admissions in the PCRA proceeding. The court denied petitioner's
request to incorporate the testimony of Commonwealth "actors" as admissions and,
in effect, granted the Commonwealth's first motion in limine.
On April 27, 1998, the Commonwealth filed a second motion in limine to preclude
the testimony of Ann W. Burgess, Ph.D., on the issue of "battered person
syndrome." After briefing and argument by the parties, the court denied the
Commonwealth's motion in limine on May 18, 1998, and permitted the testimony of
Dr. Burgess in this proceeding.(33)
The Commonwealth's last motion in limine was filed on May 12, 1998, during the
course of the proceeding. This motion sought to preclude the testimony of
Professor Charles W. Wolfram on legal ethics and the propriety of lawyers' conduct.
After reviewing the parties' briefs and hearing oral argument on the issue, the court
granted this motion in limine on May 18, 1998. (34) The hearing commenced on April
30, 1998. (35) Petitioner presented 73 witnesses and offered the admission of 478
exhibits. She rested her case on June 11, 1998.
The Commonwealth presented 39 witnesses and offered the admission of 123
exhibits. The Commonwealth rested its case June 22, 1998. Closing arguments
were held on June 24, 1998, lasting a full day.
The record includes 36 volumes of notes of testimony (more than 8,000 pages) and
601 exhibits. The court addressed 28 motions, wrote four opinions, and issued 28
orders. It heard oral argument on outstanding legal matters on at least three
occasions prior to the hearing and additionally held three prehearing conferences.
The PCRA hearing itself covered 38 days in court over an eight- week period.
At the conclusion of the hearing, the court was asked to decide petitioner's claims
of 157 allegations of prosecutorial misconduct, including 66 allegations of
Brady/Giglio violations, 72 allegations of after-discovered evidence, and 28
allegations of ineffective assistance of c ounsel.
The petitioner must establish that an error or defect in her case resulted in a
"fundamentally unfair conviction." Commonwealth v. Carbone, --- Pa. ---, 707
A.2d 1145, 1148 (1998) (quoting Commonwealth v. Weinder, 395 Pa. Super.
608, 626-27, 577 A.2d 1364, 1374 (1990)). The purpose of the PCRA is to provide
Page 402 of 2301
a means of obtaining collateral relief for those persons who did not commit the
crimes for which they have been convicted, or who are serving sentences longer
than the legal maximum. 42 Pa. C.S.A. Section 9542. It is not a means of relitigating issues that have already been addressed on direct appeal, or which could
have been raised earlier. Commonwealth v. Buehl, 540 Pa. 493, 500, 658 A.2d
771, 775 (1995).
To obtain relief under the PCRA, the petitioner must prove, by a fair preponderance
of the evidence, that her conviction was the result of:
(1) a violation of the Constitution of Pennsylvania or the Constitution or laws of the
United States, which, under the circumstances, so undermined the truthdetermining process that no reliable adjudication of guilt or innocence could have
taken place, 42 Pa. C.S.A. Section 9543(a)(2)(I); or
(2) the ineffective assistance of counsel, at trial or on appeal, which, under the
circumstances, so undermined the truth-determining process that no reliable
adjudication of guilt or innocence could have taken place, 42 Pa. C.S.A. Section
9543(a)(2)(ii); or
(3) the unavailability at the time of trial of exculpatory evidence that has
subsequently become available and which would have changed the outcome of the
trial if it had been introduced, 42 Pa. C.S.A. Section 9543(a)(2)(vi).
These elements under a PCRA claim provide general categories for consideration of
the many claims asserted by Ms. Lambert. To further explain the process by which
this court must evaluate Ms. Lambert's claims for relief, we discuss the elements of
a PCRA case in the subsections to follow.
The question of prosecutorial misconduct is by far the most troubling in this case.
This is the area where concerns about the integrity of the system, the corruption of
the criminal trial process, and alleged unethical conduct by the prosecuting
attorney and the investigating detectives come under sharp scrutiny. This is an
area rife with emotion and a distracting level of hyperbole. The history of this case
teaches that reasoned analysis of the prosecutorial misconduct issues can easily
give way to rhetorical flourish and personal outrage. Yet, no issue is well resolved
through the barometer of personal feelings of advocates or a ground swell of
community opinion or media coverage. It is necessary to look at the law to
determine what might constitute prosecutorial misconduct and then to look directly
to the facts of this case to analyze what happened, what did not, and what it might
mean.
The issue of prosecutorial misconduct is subject to an analysis under the PCRA
statute and under the Pennsylvania Supreme Court decision in Commonwealth v.
Smith, 532 Pa. 177, 615 A.2d 321 (1992).
There is no specific provision for prosecutorial misconduct under the PCRA.
However, the Act provides that a petitioner, to be eligible for relief, must plead and
Page 403 of 2301
prove by a preponderance of the evidence that her conviction resulted from:

A violation of the Constitution of this Commonwealth or the Constitution or laws of
the United States which, in the circumstances of the particular case, so undermined
the truth-determining process that no reliable adjudication of guilt or innocence
could have taken place.
42 Pa. C.S.A. Section 9543(a)(2)(i). Ms. Lambert claims that police and
prosecutors' misconduct deprived her of due process. She further contends that the
Commonwealth's failure to disclose certain information to her trial counsel was a
constitutional violation.
A second focus in the prosecutorial misconduct area is Smith. The Pennsylvania
Supreme Court in Smith held that the double jeopardy clause of the Pennsylvania
constitution prohibits the retrial of a defendant (1) when prosecutorial misconduct
is intended to provoke the defendant into moving for a mistrial, or (2) when the
conduct of the prosecutor is intentionally undertaken to prejudice the defendant to
the point of the denial of a fair trial. 532 Pa. at 186, 615 A.2d at 325.
In Smith, there were two incidents of intentional prosecutorial misconduct. The
first concerned adhesive lifters. Certain adhesive lifters were used at the autopsy to
remove granular particles which looked like sand from between the victim's toes.
These adhesive lifters were discovered by the Commonwealth during the Smith trial
but were not disclosed to Smith's defense counsel. The prosecutor wrote a memo
saying, "It is obvious from [defense counsel's] tactics thus far that he will attempt
to establish that Mrs. Reinert was killed at the shore in Cape May, New Jersey by
William Bradfield, Chris Pappas, and Susan Myers. The sand, therefore, is
extremely materia l to the defense case." 532 Pa. at 182, 615 A.2d at 323. The
Commonwealth's theory in Smith was that the victim was murdered in
Pennsylvania. The defense theory was that she was murdered in Cape May, New
Jersey, and the sand in her toes would have supported the defense position. Yet
the Commonwealth did not disclose the existence of the sand between the toes of
the victim.
The second incident involved denial of an agreement with a witness. The Court
found that the Commonwealth deliberately denied the existence of an agreement
under which its witness, Mr. Martray, received lenient treatment at sentencing in
return for testimony against Smith. 532 Pa. at 181, 615 A.2d at 322-23.
For purposes of this opinion, the alleged prosecutorial misconduct will be
considered to determine whether it was intended to provoke Ms. Lambert into
moving for a mistrial or whether it was intentionally undertaken to prejudice
defendant to the point of the denial of a fair trial. 532 Pa. at 186, 615 A.2d at 325.
Ms. Lambert also argues that failure to turn over exculpatory evidence violated her
constitutional rights as set forth in Brady. In Brady, the United States Supreme
Court held that "the suppression by the prosecutor of evidence favorable to an
accused upon request violates due process where the evidence is material either to
guilt or to punishment, irrespective of the good faith or bad faith of the
prosecutor." 373 U.S. at 104. Pennsylvania promulgated Criminal Rule of Procedure
305(B)(1) in response to Brady, requiring Commonwealth disclosure to defense
counsel, upon request, of "any evidence favorable to the accused which is material
Page 404 of 2301
either to guilt or to punishment, and which is within the possession of the attorney
for the Commonwealth." Pa. R. Crim. P. 305(B)(1)(a).
When the reliability of a witness may be determinative of the guilt or innocence of
an accused, nondisclosure of evidence affecting the credibility of witnesses falls
within the general rule as pronounced by Brady. Giglio, 405 U.S. at 154.
Undisclosed evidence is "material" under Brady, however, only "if there is a
reasonable probability that, had the evidence been disclosed to the defense, the
result of the proceeding would have been different." United States v. Bagley, 473
U.S. 667, 682 (1985). The prosecution in Bagley failed to disclose impeachment
material about its two key witnesses: the witnesses had contracts with the
government to pay them money commensurate with information furnished. This
violated respondent's due process rights under Brady. Bagley, 473 U.S. at 671.
The Supreme Court shed yet more light on the materiality issue by pronouncing
that "a showing of materiality does not require demonstration by a preponderance
that disclosure of the suppressed evidence would have resulted ultimately in the
defendant's acquittal," and that Brady is violated "by showing that the favorable
evidence could reasonably be taken to put the whole case in such a different light
as to undermine confidence in the verdict." Kyles v. Whitley, 514 U.S. 419, 435
(1995). Kyles also adds to the materiality test that suppressed evidence must be
considered collectively, rather than just item by item. Id. at 507.
However, a defendant is not entitled to the benefit of the Brady doctrine "[w]here
the exculpatory information is not only available to the defendant but also lies in a
source where a reasonable defendant would have looked." Barnes v. Thompson,
58 F.3d 971, 975 (4th Cir. 1995) (citations omitted). See Commonwealth v.
McElroy, 445 Pa. Super. 336, 352, 665 A.2d 813, 820 (1995) (citing Gelormo,
327 Pa. Super. at 231, 475 A.2d at 771, indicating that Rule 305(B)(1) is not
intended to apply where defense counsel has equal access to evidence it seeks to
compel).
Most recently, the Supreme Court of Pennsylvania held that "the Brady rule is not
an all-encompassing directive to the prosecution to disclose all evidence in its
possession to a criminal defendant." Commonwealth v. Appel, 547 Pa. 171, 203,
689 A.2d 891, 907 (1997). The evidence that was the subject of Appel's alleged
Brady violation was statements made by people who knew the appellant which
were descriptive of his strange behavior and unusual ideas. Appellant maintained
that the Commonwealth had a duty to disclose this information to the defense or
the trial court to be considered in determining his competency. The court held that
the statements were not relevant to Appel's guilt or innocence, but merely to his
competency, and as such did not violate the rule as pronounced in Brady. Appel,
547 Pa. at 203, 689 A.2d at 907.
The PCRA requires a petitioner to plead and prove ineffective assistance of counsel
which so undermined the truth-determining process that no reliable adjudication of
guilt or innocence could have taken place. 42 Pa. C.S.A. Section 9543(a)(2)(ii);
Appel, 547 Pa. at 199-201, 689 A.2d at 905. Petitioner must prove: (1) there is
merit to the underlying claim; (2) counsel had no reasonable basis for his course of
conduct; and (3) there is a reasonable probability that but for the act or omission in
Page 405 of 2301
question the outcome of the proceeding would have been different.

Commonwealth v. Douglas, 537 Pa. 588, 597, 645 A.2d 226, 230 (1994) (citing
Commonwealth v. Pierce, 515 Pa. 153, 527 A.2d 973 (1987)) (referred to
hereafter as the "Douglas/Pierce" test). "Prejudice in the context of a claim of
ineffective assistance of counsel is determined by an evaluation of whether 'but for
the arguably ineffective act or omission there is a reasonable probability that the
result would have been different.'" Commonwealth v. Sneeringer, 447 Pa.
Super. 241, 248, 668 A.2d 1167, 1170 (1995) (quoting Commonwealth v.
Donahue, 428 Pa. Super. 259, 282, 630 A.2d 1238, 1249-50 (1993)).
A petitioner cannot obtain post-conviction review of claims previously litigated on
appeal by alleging ineffective assistance of prior counsel and presenting new
theories of relief to support previously litigated claims. Commonwealth v.
Peterkin, 538 Pa. 455, 460-61, 649 A.2d 121, 123 (1994), cert. denied, 515 U.S.
137 (1995). Further, counsel cannot be considered ineffective for failing to assert a
meritless claim and is presumed to have been effective. Id.; Commonwealth v.
Marshall, 534 Pa. 488, 633 A.2d 1100 (1993). See Commonwealth v. Henry, --Pa. ---, 706 A.2d 313, 323 (1997); Commonwealth v. Baker, 531 Pa. 541, 562,
614 A.2d 663, 673 (1992).
When the three prongs of the Douglas/Pierce standard are met, the petitioner is
then required to demonstrate that the ineffectiveness rendered the truthdetermining process inherently unreliable. 42 Pa. C.S.A. Section 9543(a)(2)(ii). In
Buehl, a plurality decision, the Supreme Court was divided on the issue of whether
this statutory requirement is merely a restatement of the prejudice standard set
forth in Douglas/Pierce, which requires a "reasonable probability" that but for the
ineffectiveness the outcome of the proceeding would have been different, or
whether it constitutes a higher burden for the petitioner in a PCRA proceeding. The
lead opinion in Buehl held that the PCRA requires a more stringent showing of
prejudice than that required on direct appeal. Buehl, 540 Pa. at 505, 658 A.2d at
777. In Buehl, the plurality found that counsel was ineffective for failing to request
a cautionary instruction regarding the use of other crimes evidence but concluded
that "while we are able to say that due to the prejudicial nature of the evidence in
question the outcome of Appellant's trial may have been different . . . we are
unable to say that due to the omission the adjudication of guilt is unreliable." Id. at
508, 658 A.2d at 779. This conclusion was based on the court's finding that all the
evidence in the case "created overwhelming evidence of Appellant's guilt." Id.
In Buehl, Chief Justice Nix, concurring, and Justices Cappy and Flaherty, in
dissent, concluded that there is no distinction between the prejudice prong of the
test in Pierce and the language of the PCRA requiring proof that counsel's
ineffectiveness "so undermined the truth-determining process that no reliable
adjudication of guilt or innocence could have taken place." Justices Cappy and
Flaherty expressed the view that a determination that counsel's ineffectiveness
may have resulted in a different outcome necessarily renders the truth-determining
process unreliable. Buehl, 540 Pa. at 515, 658 A.2d at 786 (Cappy, J., dissenting).
The Superior Court subsequently held that there is no substantive distinction
between the prejudice standard applicable on direct appeal and the prejudice
standard applicable under the PCRA. Commonwealth v. Kimball, 453 Pa. Super.
193, 199-200, 683 A.2d 666, 669 (1996) (en banc), allocatur granted, 548 Pa.
615, 693 A.2d 587 (1997). See Carbone, --- Pa. at ---, 707 A.2d at 1153. This
Page 406 of 2301
position would seem to be supported by recent cases of the Supreme Court in

which the Court has stated that to prevail on an ineffectiveness claim raised under
the PCRA, the defendant must demonstrate the three elements of the
Douglas/Pierce test only. See, e.g., Commonwealth v. Henry, --- Pa. at ---,
706 A.2d at 323; Appel, 547 Pa. at 199-200, 689 A.2d at 905.
evidence
After-discovered evidence can provide the basis for a remedy on a collateral appeal
, under the PCRA. The petitioner must prove: (1) the evidence must have been
unavailable at the time of trial; (2) the evidence must be exculpatory; and (3) the
evidence must be of such a quality that it would change the outcome of the trial.
Commonwealth v. Bonaccurso, 425 Pa. Super. 479, 484, 625 A.2d 1197, 1199
(1993); 42 Pa. C.S.A. Section 9543(a)(2)(vi). To grant such relief the court must
be satisfied that the evidence "could not have been obtained at trial by reasonable
diligence, that it is not cumulative or of such a nature that it merely impeaches
credibility, and that it would be likely to compel a different result."
Commonwealth v. Reese, 444 Pa. Super. 38, 44-45, 663 A.2d 206, 209 (1995).
See Commonwealth v. Schuck, 401 Pa. 222, 229, 164 A.2d 13, 17 (1960), cert.
denied, 368 U.S. 884 (1961).
Unlike the test for ineffective assistance of counsel which focuses on the reliability
of the truth-determining process, after-discovered evidence claims focus on
whether that evidence "would have changed the outcome of the trial if it had been
introduced." 42 Pa. C.S.A. Section 9543(a)(2)(vi) (amended November 1995,
effective January 16, 1996).(36) In granting a new trial in Bonaccurso, the PCRA
court made two crucial credibility determinations: that the after-discovered
witness's testimony was reliable and that the defendant did not have the
opportunity to tell his story to the court at the original trial because of counsel's
ineffectiveness for presenting the wrong defense.
In a concurring opinion in Bonaccurso, Judge Beck of the Superior Court noted
that the after-discovered evidence must independently and reliably corroborate the
defense theory presented at trial. She noted her concern that the majority opinion
in Bonaccurso could lead to "hindsight justice." 425 Pa. Super. at 489, 625 A.2d
at 1202. Judge Beck noted that generally defendants will not likely succeed in
obtaining collateral relief based upon new theories inconsistent with their trial
defense.
The standard for after-discovered evidence is more strict than for a Brady/Giglio
disclosure violation and the reason for this difference has been explained by the
United States Supreme Court:
[T]he fact that such evidence was available to the prosecutor and not submitted to
the defense places it in a different category than if it had simply been discovered
from a neutral source after trial. For that reason the defendant should not have to
satisfy the severe burden of demonstrating that newly discovered evidence
probably would have resulted in acquittal. If the standard applied to the usual
motion for a new trial based on newly discovered evidence were the same when the
evidence was in the State's possession as when it was found in a neutral source,
there would be no special significance to the prosecutor's obligation to serve the
Page 407 of 2301
cause of justice.
United States v. Agurs, 427 U.S. 97, 111 (1976). This explains why a petitioner
may prevail upon her Brady claims where her after-discovered evidence claims
provide no relief. Commonwealth v. Galloway, 433 Pa. Super. 222, 227 n.5, 640
A.2d 454, 457 n.5 (1994).
An issue is deemed finally litigated if (1) the highest appellate court in , which a
petitioner could have had review as a matter of right has ruled on the merits of the
issue, Commonwealth v. Szuchon, 548 Pa. 37, 41, 693 A.2d 959, 961 (1997), or
(2) the issue has been raised and decided in a proceeding collaterally attacking the
conviction or sentence. 42 Pa. C.S.A. Section 9544(a); Appel,, 547 Pa. at 186, 689
A.2d , a, t 898. Allegations of ineffectiveness of counsel may not be used to obtain
subsequent review of an issue that has previously been found to be without merit.
Commonwealth v. DeHart, 539 Pa. 5, 17, 650 A.2d 38, 44 (1994). The PCRA
petitioner must plead and prove that the failure to litigate the issue prior to trial,
during trial, or on direct appeal could not have been the result of any "rational,
strategic or tactical decision by counsel." 42 Pa. C.S.A. Section 9543(a)(4).
If the allegations of error have not been fully litigated, the PCRA also requires that
a petitioner demonstrate that these allegations of error have not been waived. An
issue is deemed waived if the petitioner could have raised it but failed to do so
before trial, at trial, during unitary review, on appeal, or in a prior state post
conviction proceeding. 42 Pa. C.S.A. Section 9544(b). To obtain review of such an
issue, the petitioner must show that his failure to appeal a ruling or raise an issue
was not knowing and intentional. Commonwealth v. Craddock, 370 Pa. Super.
139, 142-43, 535 A.2d 1189, 1191 (1988), aff'd, 522 Pa. 491, 564 A.2d 151
(1989).
Finally, the PCRA requires that all petitions be filed within one year of the date the
judgment becomes final, which is either at the conclusion of direct review, or at the
expiration of the deadline for seeking review. 42 Pa. C.S.A. Section 9545(b)(3).
The PCRA statute and the case law provide certain elements which the petitioner
must establish by a preponderance of the evidence in each of the several areas she
asserts. Each section requires the judge to determine what impact the evidence in
question would have had at trial. The after-discovered evidence must have been
unavailable, exculpatory and would have changed the outcome of the trial if it had
been introduced. The prosecutorial misconduct charges require the court to
determine whether the constitutional violations so undermined the truthdetermining process that no reliable adjudication of guilt or innocence could have
taken place. Similarly, the PCRA requires a petitioner to establish ineffective
assistance of counsel which rendered the truth-determining process unreliable.
For there to be a Brady violation, the petitioner must prove that the
Commonwealth failed to disclose exculpatory evidence or favorable evidence which
Page 408 of 2301
was "material." Brady, 373 U.S. at 87-88. "Material" has been defined as follows:
The evidence is material only if there is a reasonable probability that, had the
evidence been disclosed to the defense, the result of the proceeding would have
been
different. A 'reasonable probability' is a probability sufficient to undermine
confidence in the outcome.
Galloway, 433 Pa. Super. at 229, 640 A.2d at 457 (quoting Bagley, 473 U.S. at
682). The Brady claims then require the court to find that the result of the
proceeding would have been different had the material evidence been disclosed.
In each of these four major areas, there is an element for the trial court to
determine whether the alleged misconduct, Brady violations, after-discovered
evidence or ineffective assistance of counsel would have made a difference to the
outcome of the trial. Would the after-discovered evidence have "changed the
outcome of the trial?" Did the prosecutorial misconduct "so undermine the truthdetermining process that no reliable adjudication of guilt or innocence could have
taken place?" Did the Brady violations involve "material" evidence, i.e., would the
evidence have changed the outcome of the trial? Did the ineffective assistance of
counsel render the truth-determining process unreliable?
In this case, the judge sitting in review of the PCRA claims also sat without a jury in
the 1992 trial. In a typical case, a PCRA court would consider claims of afterdiscovered evidence, prosecutorial misconduct, ineffective assistance or Brady
violations and make its best judgment as to what would have influenced the jury.
In the case of a constitutional violation, the truth-determining process would have
been the jury's analysis and deliberations on the verdict. The court could speculate
about what would have mattered to the jury and what would not have mattered.
And so it goes for the after-discovered evidence, the Brady violations and the
ineffective assistance claims.
In this case, however, there was no jury and there is no need for this court to
project what might have mattered and what might have affected the jury's analysis
of the case. Here, the court listened to the evidence in 1992, considered the
arguments of counsel and determined a verdict. This court is in a unique position to
say what would have made a difference in the truth-determining process in 1992.
This court knows what affected the outcome of the case, knows what was
important in the truth-determining process and knows what was material.
Our research has disclosed no appellate case law on the standard to be applied to a
PCRA petition to a court who heard the initial case non-jury. It seems to make
sense that the court in the unique position of hearing a case non-jury would have
insight into the basis for the verdict that would not be available to a judge in a jury
trial. To speculate about the impact of certain evidence on a jury when in reality
the court itself heard the evidence and made the decision would seem both
unproductive and unnecessary. For example, how could this court in good
conscience find that after-discovered evidence would have changed the outcome of
the trial were a jury to hear the new evidence when, in reality, this court knows
Page 409 of 2301
that it would not have changed the outcome?

This is one practical consequence of petitioner's decision to waive her right to a jury
trial in 1992. In all the appeals, motions and petitions which followed since the
verdict in 1992, never once has petitioner contended that her decision to proceed
non-jury was improper. Never once has she contended that Attorney Shirk was
ineffective for advising her to proceed non-jury, never once has she argued that
her waiver was something other than knowing and voluntary, and never once has
she challenged the colloquy which led to the court approval of her waiver of a jury
trial. In fact, it is likely that petitioner views that decision as a successful decision.
In any event, by her choice to proceed non-jury, petitioner has afforded this court
an insight into the PCRA issues which would not otherwise have been available had
the case been tried with a jury.
Early in petitioner's case, she called Lieutenant Renee L. Schuler(37) as a witness.
Petitioner's counsel requested permission to cross-examine this witness because
she was "hostile" or "adverse." This request was denied. On May 4, 1998, petitioner
called retired Pennsylvania State Police Officer Carl S. Harnish. The request to treat
the witness as hostile or adverse was renewed. We asked for case authority and
each side presented legal argument.
Petitioner cited Commonwealth v. Butler, 529 Pa. 7, 601 A.2d 268 (1991), in
support of her request that she be allowed to cross-examine police witnesses on
direct. Mr. Greenberg argued on behalf of petitioner that these proceedings went
directly to the workings of the criminal justice system, that the police witnesses in
this proceeding were hostile and adverse, as those terms are used in the law, and
that justice required that petitioner be allowed to cross-examine each witness and
to proceed with leading questions rather than standard direct examination. This
court considered Butler and found it to provide no support for petitioner's
contention.(38) We indicated at that time that the question of a police witness being
hostile or adverse could not be addressed in a blanket ruling. The court promised to
consider the situation as to each witness and make a determination before, or
during, that witness's testimony about whether the witness would be treated as a
hostile or adverse witness.
We advised counsel that "hostility" required a showing of surprise during the
witness's testimony or an obvious lack of cooperation, reluctance or evasiveness in
answering questions. As to whether a witness is "adverse," the court informed
counsel that such a declaration required a showing that the witness had a direct
personal interest in the outcome of the litigation.
This same analysis was applied when former Detective Ronald C. Barley testified.
On May 5, 1998, at the beginning of the afternoon session and during the time Mr.
Barley was on the stand, Mr. Greenberg asked if he might "put a position on the
record." He was given permission and made the following statement:
Your Honor, I feel obligated to put this position on the record to establish what our
position is going forward in this proceeding so there's no subsequent question. And
Page 410 of 2301
I want to assure the court that I'm not taking this position lightly.
The situation that I predicted yesterday is exactly as I then suggested. By
immunizing the police and the prosecutor witnesses from cross examination and in
addition by allowing the Commonwealth to lead them, the court has made it
impossible for the petitioner to properly put on her case.
Crucial points of witness testimony made explicitly in federal court that could be
established by a single cross examination question that never will be asked in this
proceeding now are removed from the record before this court by witnesses'
convenient losses of memory and recollection.
The result is that the record being made in our view, and our position is, is
completely corrupted. We will go forward as we must to exhaust the alleged state
remedies that are allegedly available to this petitioner, but it's our position that this
proceeding is without integrity in terms of finding fact and seeking truth and it's our
position that any findings made herein against petitioner are entitled to absolutely
no deference as a result in any subsequent court.
(N.T., PCRA at 783-784.)(39)

A reading of the text of Mr. Greenberg's diatribe does little to capture the disdainful
tone of these remarks. When given an opportunity to present case law in support of
his request to cross-examination police witnesses, he produced nothing. Faced with
a ruling adverse to his position, he chose to stand in open court and assault the
integrity of this court.
The issue of leading questions came up with every police or prosecution witness. In
addition to Lieutenant Renee Schuler and former Detective Barley, petitioner
sought to ask leading questions of First Assistant District Attorney Kenneff,
Detective Raymond E. Solt,(40) and District Justice Ronald W. Savage,(41) among
others. Because this issue featured so prominently throughout the hearing, we
have included a discussion of the law on this point.
The general rule is that the party calling a witness is not permitted to examine him
or her by means of leading questions. Wargo v. Pittsburgh Railways Co., 376
Pa. 168, 101 A.2d 638 (1954); Buckman v. Philadelphia & Reading Railway
Co., 227 Pa. 277, 75 A. 1069 (1910). "A leading question is one which puts the
desired answer in the mouth of the witness." Commonwealth v. Chambers, 528
Pa. 558, 579, 599 A.2d 630, 640 (1992) (citing Commonwealth v. Dreibelbis,
493 Pa. 466, 476, 426 A.2d 1111, 1116 (1981)).
One may, however, cross-examine his own witness where the witness proves to be
hostile and unwilling, or where the party calling the witness is surprised by
testimony of the witness inconsistent with prior statements. Gantt v. Cox & Sons
Co., 199 Pa. 208, 48 A. 992 (1901). A thorough examination of the Pennsylvania
case law associated with this exception reveals an abundance of cases which define
"hostility" by way of the definition of "surprise," but an absence of any cases which
offer a definition of the discrete term "hostile witness."(42)
Page 411 of 2301
The term "hostile" has been considered by a number of courts. Where a party is
surprised in the testimony of a witness by his unexpectedly turning hostile, counsel
may exercise the right of cross-examination of the witness, or impeach his
testimony by other witnesses. Commonwealth v. Turza, 340 Pa. 128, 16 A.2d
401(1940). The party requesting leave to declare its witness hostile bears the
burden of proving that statements by the witness were unexpected, contradictory
to earlier statements, harmful to the party calling the witness, and would result in
injustice should the movant's request be denied. Tiburzio-Kelly v. Montgomery,
452 Pa. Super. 158, 186, 681 A.2d 757, 771 (1996). When one's witness turns
hostile by telling a different version on the witness stand than he told the calling
party prior thereto, the latter may plead surprise and request leave to crossexamine the witness and impeach him by his prior inconsistent statement.
Commonwealth v. Duffy, 238 Pa. Super. 161, 167, 353 A.2d 50, 54 (1975).
Clearly, the term "hostile" has been treated by Pennsylvania courts as involving an
element of "surprise."
It is within the sound discretion of the trial court to decide whether counsel may
exercise the right to cross-examine his own witness on a plea of surprise.
Commonwealth v. Barber, 275 Pa. Super. 144, 151, 418 A.2d 653, 657 (1980);
Duffy, 238 Pa. Super. at 167, 353 A.2d at 54. In exercising its discretion, the trial
court must apply a four-part test. First, the testimony given by the witness must be
unexpected; second, the testimony must be contradictory to the witness's earlier
statements; third, the testimony must be hurtful or injurious to the party calling
the witness and beneficial to the opposing side; and fourth, the scope of the crossexamination may not be excessive. Id. at 151-52, 418 A.2d at 657; Duffy, 238 Pa.
Super. at 167-68, 353 A.2d at 54.
Since the purpose of the cross-examination and impeachment is to induce the fact
finder to disbelieve the testimony of the witness, there must be something in the
witness's testimony, which, if believed by the fact finder, will be hurtful or injurious
to the party calling him. Commonwealth v. Thomas, 459 Pa. 371, 379, 329 A.2d
277, 281 (1974). Therefore, if there is no testimony which needs to be neutralized,
or which if accepted unchallenged will not aid the opposite party, or which was not
hurtful to the side calling him, there is no excuse for cross-examination to impeach
or discredit. Seldon v. Metropolitan Life Ins. Co., 157 Pa. Super. 500, 509, 43
A.2d 571, 577 (1945).
Even without a plea of surprise, where the witness is identified with an adverse
party and reluctant to testify against that party, leading questions may be used in
direct examination within the discretion of the trial court. Duffy, 238 Pa. Super. at
167-68, 353 A.2d at 54. Since the issue depends heavily upon evaluating the
witness's in-court demeanor, aspects of which may not even be reflected in the
record, it is recognized that trial courts must be given discretion to determine
whether a witness is hostile or unwilling to testify.
It is well settled that a witness who has an interest adverse to the party calling him
may be called as on cross-examination. Whether a witness's interest is adverse to
the party calling him to testify, for purposes of determining whether he could be
called as if under cross-examination, is a factual determination within the court's
discretion. American States Ins. Co. v. Maryland Casualty Co., 427 Pa. Super.
170, 192, 628 A.2d 880, 891 (1993) (citing Gaul v. Consolidated Rail Corp., 383
Pa. Super. 250, 556 A.2d 892 (1989)). This interest must be a direct interest in the
Page 412 of 2301
outcome of the suit in which he is called. An agent-principal relationship alone is

not sufficient. Indirect, contingent and supplementary interests will not suffice.
Brown v. Popky, 413 Pa. 236, 196 A.2d 638, 645-46 (1964). Nor are employees
of an adverse party ordinarily themselves "adverse" for purposes of permitting a
party to call them as on cross. Commonwealth, Department of Health v.
Brownsville Golden Age Nursing Home, Inc., 103 Pa. Cmwlth. 449, 470 n.7,
520 A.2d 926, 936 n.7 (1987).
In this case, we considered whether any of these police or prosecution witnesses
had any legal rights or liabilities which would be affected by this court's decision on
the PCRA issues. We approached this issue at the outset of the hearing by
contemplating three possible remedies or outcomes in this case which could
arguably affect these witnesses: (1) a new trial for Ms. Lambert; (2) a declaration
that there has been prosecutorial misconduct and that she cannot be retried under
Smith; and (3) a finding of prosecutorial misconduct which may be used to further
a federal investigation that might be taking place.(43)
If this court would award a new trial to Ms. Lambert, there would be no direct effect
on any personal rights or liabilities of any of the police witnesses. New trials are
granted by appellate courts in regular course. A declaration that because of
intentional prosecutorial misconduct Ms. Lambert cannot be retried under Smith
does not affect the personal rights or liabilities of any of these police or prosecution
witnesses. To say that one or all of them might be disappointed with such a result
is not to say that it would have a direct effect on the personal rights or liabilities of
these individuals. The possible impact of this court's decisions in this case on the
federal investigation demanded by the district court is contingent and remote.
There is simply no basis to find that this court's decision in favor of Ms. Lambert
would somehow prejudice the investigation against the police or that the converse
is true. Even if the federal investigative authorities will look to this court's findings
for additional information about the conduct of the police, that does not rise to the
level of a direct personal interest in the outcome of this litigation. The fact that
there may be some instructive or persuasive value in a collateral proceeding does
not establish this kind of interest.
There simply was no basis to consider the police and prosecution witnesses adverse
under Pennsylvania law. Nor was there any basis to find any of them hostile, with
the exception of Officer Robert S. Reed, who was declared hostile and whose
testimony will be dealt with below. All, except Officer Reed, demonstrated a
willingness to answer questions.
The federal rules depart from Pennsylvania practice on this issue. Ru le 611(c) of
the Federal Rules of Evidence permits the use of leading questions on direct
examination of a hostile witness, an adverse party, or a witness identified with an
adverse party, without any requirement of a showing of hostility or adversity. Rule
611(c) suggests that witnesses who are adverse parties or identified with one may
be presumed predisposed against the direct examiner without requiring a
demonstration of that fact.
Prior to the adoption of F.R.E. Rule 611(c), before a party could lead a witness on
direct examination, it had to be shown that the witness was actually hostile or was
an adverse party, officer, director, or managing agent of such adverse party. Ellis
v. City of Chicago, 667 F.2d 606, 612 (7th Cir. 1981); United States v. Bryant,
Page 413 of 2301
461 F.2d 912, 918-19 (6th Cir. 1972). Rule 611(c), however, significantly enlarged
the class of witnesses presumed hostile, "and therefore subject to interrogation by
leading questions without further showing of actual hostility." Ellis, 667 F.2d at 613
(citing F.R.E. 611 advisory committee note); see also Perkins v. Volkswagen of
America, Inc., 596 F.2d 681, 682 (5th Cir. 1979) (error for trial court to rule that
employee of defendant would be plaintiff's witness if plaintiff called him).
The federal courts, in applying Rule 611(c), have allowed the use of leading
questions in direct examination of law enforcement officials (regardless of whether
he or she is a local, state or federal officer) because they are "identified" with an
adverse party, i.e., the prosecution, in actions by the Government against criminal
defendants. United States v. Duncun, 712 F. Supp. 124 (S.D. Ohio 1988)
(granting the defendant's motion to invoke Rule 611(c) in direct examination of
police officers and government agents). In such cases, the burden is on the
Government to make a positive showing that the witness is not hostile, biased or so
identified with the adverse party that "the presumption of hostility which is the
cornerstone of Fed. R. Evid. 611(c) should not be indulged." Id. at 126.
Some commentators and courts have cautioned against such unwarranted
generalizations about the type of relationship sufficiently close to a party to permit
a presumption of bias and suggest that Rule 611(c) be applied with caution. See
Charles A. Wright & Victor J. Gold, Federal Practice and Procedure: Evidence
Section 6168 at 426 (1993 & 1998 Supp.). See also Suarez Matos v. Ashford
Presbyterian Community Hosp., 4 F.3d 47, 50 (1st Cir. 1993) (trial court erred
in permitting plaintiff to ask leading questions of witness as he could not be
deemed a hostile witness simply by virtue of the fact he was expected to give
testimony favorable to defendant). One federal court has recognized that Rule
611(c) is subject to the overriding command of Ru le 611(a) that the court "shall
exercise reasonable control over the mode . . . of interrogating witnesses" to elicit
truth, avoid delay and protect against harassment. F.R.E. 611(a). The court noted
that a district judge would certainly not allow leading questions of an adverse party
where this mode of interrogation was distorting the testimony of the witness.
Rodriquez v. Banco Central Corp., 990 F.2d at 13.
None of the police and prosecution witnesses listed above were parties in this case;
their interests were adverse to petitioner's only in a collateral sense. The simple
fact is that petitioner had previously been involved in a federal habeas corpus
proceeding where allegations of misconduct were made against these witnesses.
That does not create a personal interest or stake in the outcome of this PCRA
litigation.
Petitioner's counsel demonstrated hostility toward each of these witnesses by the
tone and manner of their questioning, if nothing else. Their demonstrated hostility
to these witnesses does not make the witnesses themselves adverse or hostile.
This court had every opportunity to observe these witnesses on the stand. Each
appeared willingly, some in response to a subpoena. There was no need for
petitioner or the court to coerce their attendance at the hearing nor did their
answers to any questions appear to be evasive. In fact, each appeared willing to
answer questions. Each was cooperative and responsive. There was nothing about
the testimony of any of these witnesses which would even suggest that any was
hostile.
Page 414 of 2301
Leading questions are useful to exact truthful statements from a witness who has a
clear and demonstrated tendency to give evasive, unresponsive or argumentative
answers. Leading questions should not be used to exact admissions, in the manner
of an inquisition, from a witness who is attempting to provide responsive answers
to direct questions. Nor should leading questions be used to cut off a witness's
opportunity to provide an explanation. In short, leading questions are not meant to
be loaded questions. And when an affirmative answer is exacted from a witness to
a line of questioning loaded with assumptions favoring only the inquisitor, the
leading question becomes not a tool of truth but of advocacy and intimidation. Our
decision to require direct questioning of witnesses called by petitioner is supported
by the law and was a sound exercise in discretion. The fact that the federal district
court permitted leading questions of police witnesses in the habeas corpus
proceeding does not dic tate how this court should apply Pennsylvania law.
The record indicates that these witnesses were extensively examined and
repeatedly impeached by petitioner. Under these circumstances, there was no
abuse of the PCRA court's discretion.
IV. THE 1992 VERDIC T: FINDINGS OF FACT AND CONCLUSIONS OF LAW
Ms. Lambert was found guilty of first degree murder on July 20, 1992. She filed
post verdict motions in which she claimed that her conviction was against the
weight of the evidence. In a July 19, 1994, opinion filed in response to the issues
raised in the post verdict motions, this court discussed its factual findings leading to
the conviction and whether the verdict was against the weight of the evidence. We
found that the verdict was well supported by the evidence.
Because so much of the analysis of the PCRA claims has a direct bearing on the
integrity of the truth-determining process or whether any new information would
have changed the outcome of the case, we include our findings of fact from the
1994 opinion:
The arguments raised by defendant are best considered in a factual context. The
facts, as found by the trial court, may be summarized as follows. Lisa Michelle
Lambert was romantically involved with Lawrence Yunkin. During an interlude in
their relationship, Mr. Yunkin dated Laurie Show. They apparently dated on one or
two occasions during the summer of 1991. The evidence at trial made clear that
Ms. Lambert reacted strongly to this development and that she expressed her
anger at Laurie Show to a number of her friends. In fact, a plan was developed in
the summer of 1991 that included kidnaping, harassing and terrorizing Laurie
Show. Apparently, Ms. Lambert was the author of this plan and she enlisted several
of her friends to execute the plan. The 'kidnaping' did not happen when several of
the group warned Laurie Show.
This 'bad blood' continued. Ms. Lambert confronted Laurie Show at the East Towne
Mall and struck her. According to the victim's mother, Hazel Show, the victim was
afraid of Ms. Lambert. It appears that Ms. Lambert was stalking Laurie Show during
the summer and into the fall of 1991.
On December 20, 1991, Hazel Show received a call from a person who claimed to
be her daughter's guidance counselor. The caller requested a conference with Hazel
Show before school the next morning. The following morning Hazel Show left the
Page 415 of 2301
condominium to keep this 'appointment.' While she was gone, two persons knocked
on the door of the Show condominium and entered when Laurie Show answered. A
commotion followed and these two figures then left the second floor condominium,
walked across a field, cut through a parking lot by some adjoining condominiums in
the same complex and got into an automobile. Hazel Show waited at the Conestoga
Valley High School for the guidance counselor and when the guidance counselor did
not appear at the time for the appointment, Hazel Show returned by automobile to
her condominium. She found her daughter laying on the floor of her bedroom,
bleeding profusely from a large slash wound across her neck. Laurie whispered to
her mother the words, 'Michelle... Michelle did it.' Laurie Show then died in her
mother's arms.
All this happened on the morning of December 20, 1991. During the evening of that
same day, East Lampeter Township Police, assisted by the Pennsylvania State
Police, arrested Lisa Michelle Lambert, Lawrence Yunkin and Tabitha Faith Buck in a
bowling alley. During questioning by police, Ms. Lambert admitted to being in the
condominium that morning but said Ms. Buck did the stabbing. Mr. Yunkin admitted
to driving the two women to the location and waiting in the car until they returned.
Ms. Buck made no statement to the police.
The evidence at trial clearly established a pattern and history of ill will directed by
Ms. Lambert to Laurie Show. Various witnesses documented an assault by Ms.
Lambert on Laurie Show at the East Towne Mall in November, 1991. There was no
evidence to controvert this. Ms. Lambert threatened Laurie Show with harm if she
went to the police regarding the assault in November, 1991. Ms. Lambert
encountered a friend of hers in December, 1991 at the Park City Mall and indicated
that she was aware that the police were looking for her on a simple assault charge.
In addition, Hazel Show had confronted Ms. Lambert on at least one prior occasion
and had called the East Lampeter Township Police in the summer of 1991. In
December, 1991, Hazel Show went to the East Lampeter Township Police to discuss
the simple assault charge. There was credible testimony at the trial to show that
Laurie Show was afraid of Ms. Lambert.
All of this evidence was relevant as to whether Laurie Show would have willingly
admitted Ms. Lambert and Ms. Buck to her condominium on the morning of
December 20, 1991. Given this history of ill will, it is comp letely credible that Laurie
Show would have admitted Ms. Lambert or anyone in the company of Ms. Lambert
to her home at any time.
Numerous facts developed at trial provided both direct and circumstantial evidence
linking Ms. Lambert to the homicide. On December 19, 1991, defendant bought a
50 foot length of rope and two ski hats at the K-Mart in the East Towne Mall. This
was established by credible testimony from Mr. Yunkin and through a K-Mart
receipt. Defendant took the rope with her on December 20, 1991. Defendant, by
her own admission, took a knife from her kitchen at home to the Show
condominium on December 20, 1991. Mr. Yunkin and Ms. Lambert picked Ms. Buck
up at her home at approximately 6:30 a.m. and Mr. Yunkin dropped the two
women off near the Show condominium at approximately 6:45 a.m. Mr. Yunkin was
seen by the manager of a McDonald's at approximately 7:00 a.m. on December 20,
1991. This McDonald's is very close to the Show home.
Page 416 of 2301
It is very safe to conclude from the evidence that Mr. Yunkin was aware of Ms.
Lambert's feelings about Laurie Show. Mr. Yunkin had dated Laurie Show for a brief
period and then was part of two kidnapping plots in July of 1991 and August of
1991. Mr. Yunkin was aware that Ms. Lambert and Ms. Buck were going to the
Show condominium on December 20, 1991. He was also aware that Ms. Lambert
had a rope and a knife with her.
The Show condominium is on the second floor of a two story structure containing a
number of condominiums. Access to the Show home is gained by ascending a flight
of steps which are on the exterior of the building. The steps are made of metal and
they are partially enclosed. A sidewalk runs in front of the building. A person going
up or down the steps can easily be heard by someone standing out on the sidewalk.
A person walking normally on the deck outside the Show condominium can be
plainly heard by someone inside the condominium or someone outside the
condominium. The construction of the condominium is such that sound travels
through the walls. These facts were clearly established by testimony from Hazel
Show, from the neighbors who lived in the condominium under the Show
condominium and by the court's own view conducted at the premises during the
trial.
Mr. and Mrs. Richard Kleinhans, the neighbors who lived in the condominium
beneath Laurie and Hazel Show, testified that they could hear Laurie Show getting
ready for school in the morning.
A physical inspection of the Show condominium reveals that at least half of Laurie
Show's bedroom can be seen from the main hallway of the condominium. From the
small hallway outside her bedroom, most of her bedroom can be seen. It should be
noted that the layout and construction of the condominium is such that any
commotion in Laurie Show's bedroom could easily have been heard from any
location in the front part of the Show condominium.
The structure of the condominium and the testimony of Mr. Kleinhans with respect
to his ability to hear what was going on in the Show condominium are very
important in this case. Ms. Lambert indicated, in one version of the events, that she
was outside Laurie Show's bedroom and that Ms. Buck was inside the bedroom
struggling with the victim. This version of the story would suggest that Ms. Lambert
was not in the bedroom at the time of the killing. The defendant offered this
version of the facts to support her story that Ms. Buck did the killing and that she
was a horror-struck bystander. A visit to the Show condominium taken by the court
in the company of counsel and an examination of the layout of the condominium
severely undermines Ms. Lambert's position under this version of the facts. Simply
stated, any person standing in the dining room area, kitchen area or bathroom area
of the Show condominium would be well aware of any struggle, commotion or
disturbance going on in Laurie Show's bedroom. The condominium is simply not
that big. A person standing in the hallway or in the dining area would have an easy
view into the bedroom and would certainly be able to hear almost anything taking
place in the bedroom.
From the physical layout of the condominium alone, Ms. Lambert's position that she
was helpless and unaware of what Ms. Buck might have been doing in Laurie
Show's bedroom is patently unbelievable.
Page 417 of 2301
The secondary significance of a description of the layout of the Show condominium

is to buttress and support the testimony of Mr. Kleinhans, who lives with his wife
below the Show condominium. He testified as to his ability to hear any commotion
or unusual noise from the condominium above his. An inspection of the premises
wholly and absolutely supports Mr. Kleinhans. The construction is such that any
commotion, noise or disturbance can be heard in the condominium below. In fact,
the court observed during a visit to the condominium that a person walking
normally up the steps and across the small balcony to the front door of the Show
condominium can easily be heard from the area below the condominium.
The physical findings at the crime scene, the testimony at trial of the defendant,
the trial testimony of Hazel Show, the history of ill will between defendant and the
victim and the circumstantial evidence developed at trial all lead to the conclusion
that defendant was guilty of the murder of Laurie Show.
Commonwealth v. Lambert, No. 0423-1992, slip op. at 3-10 (Lanc. Co. C.P. July
19, 1994).(44)
In 1994, we specifically considered Ms. Lambert's version of the events of
December 20, 1991, as she presented them at trial. We summarized her story as
follows:
Defendant's story, as presented at trial, was that she and Ms. Buck initially went to
the condominium. She and Ms. Buck then went inside and began to struggle with
Laurie Show. Somehow, somewhere, a knife 'appeared.' According to Ms. Lambert,
she was initially holding down Laurie Show's legs so that Ms. Buck could cut her
hair. When Ms. Buck began to stab Laurie Show, Ms. Lambert began to pull Laurie
from the apartment but Laurie 'slipped' from her hands. According to Ms. Lambert,
she ran out of the condominium, in horror, and sat on the staircase down at the
ground area. At this point, Mr. Yunkin appeared, uttered an expletive and jumped
over Ms. Lambert and went into the apartment. In Ms. Lambert's view of the case,
whatever happened when Mr. Yunkin and Ms. Buck were in the apartment resulted
in Laurie Show's death.
Commonwealth v. Lambert, July 19, 1994, slip op. at 12.
Putting aside the issue of credibility and considering only the legal significance of
Ms. Lambert's version of the facts, we concluded:
. . . Even if Ms. Lambert's story at trial was completely credible, she would still be
an accomplice to the crime of murder. She freely admits to going to the
condominium in possession of a rope and a knife. She admits to going into the
condominium and participating in the attack. The only variation is that she
contends that Ms. Buck was the aggressor and that Mr. Yunkin ultimately assisted.
Her presence and her participation, by her own admission, would support a finding
of criminal responsibility for the death of Laurie Show on an accomplice basis.
Commonwealth v. Lambert, July 19, 1994, slip op. at 12-13.
At trial, Ms. Lambert's testimony, her statement to Corporal Solt, Mr. Yunkin's
testimony and the questionnaire (45) created a number of factual inconsistencies.
Page 418 of 2301
The court found the questionnaire to be inconclusive and not sufficient to raise a
reasonable doubt about defendant's guilt. We were aware that either Ms. Lambert's
testimony at trial or Ms. Lambert's statement to Corporal Solt was at least partially
untruthful and we viewed Mr. Yunkin's testimony with a large measure of
skepticism. Much of this controversy was created by the self-serving statements of
the participants in the crime. To resolve these factual inconsistencies, we carefully
considered the observations of witnesses who had no interest in the proceeding and
who observed pieces of this drama as it unfolded on the morning of December 20,
1991. This discussion is found in the 1994 opinion:
The observations of disinterested third parties established several very important
facts. Mr. Kleinhans, who lived in the condominium below the Shows, heard
footsteps up the outdoor steps, heard Laurie Show's door open, heard a scream
followed by a thud. After several minutes passed, he heard the door slam and
heard people descending the steps. He looked out the window and saw two figures
of roughly the same height and build with hoods pulled over their heads. Ms. Buck
and Ms. Lambert are of roughly the same height and, given winter clothing and
hoods over their heads, could have appeared to be of roughly the same build. Ms.
Lambert wanted the court to believe that one of those figures was Mr. Yunkin and
the other Ms. Buck. Mr. Yunkin is significantly taller than either of the two women.
Mr. Kleinhans gave very credible testimony that the two figures he observed were
of roughly the same stature.
Another disinterested witness observed two figures with hoods over their heads
coming across a lawn adjacent to the parking lot at the Show condominium. They
were coming from the vicinity of the Show condominium down across another
parking area toward a road. The timing of this sighting of the two figures coincides
with the time at which Hazel Show was returning from Conestoga Valley High
School and was shortly after Mr. Kleinhans made his observation of the two figures.
A third fact established by a disinterested witness was that Mr. Yunkin was at the
nearby McDonald's restaurant at 7:00 a.m. The manager testified that she
observed Mr. Yunkin and that she later recognized his picture on the newscast
following the arrest of the three. This coincides with Mr. Yunkin's story that he went
to the McDonald's, ordered an orange juice and home fries, waited for a period of
time and then went to pick up the women along the road.
Mr. Kleinhans's testimony completely undermines the story told by Ms. Lambert. To
hear Ms. Lambert's version, there must have been a great deal of shouting,
bumping, sweating, crying, screaming and general commotion in the condominium.
This was followed by, according to Ms. Lambert, her 'escape' from the mayhem
inflicted by Ms. Buck. As part of this 'escape,' Ms. Lambert related that she went
half way down the staircase and sat. Then, supposedly, Mr. Yunkin ascended the
steps, swore out loud when Ms. Lambert told him that Ms. Buck was in the
condominium and went in after Ms. Buck.
Mr. Kleinhans testified that he heard no such commotion. Nor did Mr. Kleinhans
observe three individuals. Nor did Mr. Kleinhans observe anyone the size of Mr.
Yunkin. Nor did Mr. Kleinhans hear any screaming, fighting or doors slamming,
other than the initial entrance and exit.
Given the court's view of the condominium and Mr. Kleinhans's description of the
Page 419 of 2301
layout of his condominium in relation to the Show condominium, his testimony is

very important. By his clear factual statements, the likelihood that such a
commotion, as described by Ms. Lambert, took place is extremely slight at best. Mr.
Kleinhans testified as to what he heard and as to what he did not hear. He offered
no opinion and offered no interpretation of the events he related. He was found to
be extremely credible by the court sitting as fact finder in this case. His testimony
was in direct conflict with Ms. Lambert's version of the story at trial. Her version
would have involved a kind of 'noiseless mayhem' and this simply is not a credible
story. Mr. Kleinhans was directly below, was paying attention to what was going on
and remembered very clearly what he heard and what he did not hear. The lack of
any commotion, crashing, shouting, stomping, yelling or other related noises
renders Ms. Lambert's already incredible story completely incredible.
The testimony of Mr. Kleinhans, of Mr. and Mrs. Fry who saw the two hooded
figures coming from the direction of the Show condominium toward their own
condominium, and of the manager of the McDonald's restaurant established facts
which were entirely consistent with the Commonwealth's theory of the case and
which were largely uncontradicted. The testimony of these witnesses established
circumstantial evidence which was very important in this court's reasoning process
in 1992. (46)
Ms. Lambert claimed that her conviction was against the weight of the evidence.
This court denied post verdict motions on that basis and Ms. Lambert did not
appeal. Although petitioner filed a direct appeal in the Superior Court, she failed to
include a challenge to the weight of the evidence. This issue, therefore, was waived
and cannot be renewed in a collateral proceeding under the PCRA. 42 Pa. C.S.A.
Section 9544. See also, Appel, 547 Pa. at 186, 689 A.2d at 898; Commonwealth
v. Williams, 389 Pa. Super. 489, 492, 567 A.2d 709 (1989). An issue has been
waived "if the petitioner could have raised it but failed to do so. . .on appeal." 42
Pa. C.S.A. Section 9544(b).
In the July 19, 1994, opinion, we did consider whether the verdict was supported
by or was against the weight of the evidence. In so many words, petitioner has
challenged the sufficiency of the 1992 evidence in this PCRA proceeding. Much of
Ms. Lambert's PCRA case calls into question the evidence introduced in the 1992
trial. Rather than rule that she has waived any possible challenge to the 1992
evidence by not raising the issue of "sufficiency" in the Superior Court, we allowed
her to present her evidence and her arguments which called the 1992 evidence into
question. We did this in the interest of full litigation of all of petitioner's claims.
After Ms. Lambert's challenge to the weight of the evidence in her initial post
verdict motions filed by Mr. Shirk, she then was given an opportunity to challenge
the effectiveness of her trial attorney and to raise certain claims of after-discovered
evidence and prosecutorial misconduct in a post verdict hearing on November 18,
1994. This court made certain findings in response to those claims. See
Commonwealth v. Lambert, No. 0423-1992, slip op. (Lanc. Co. C.P. March 14,
1995).
In consideration of those post verdict issues raised by the new attorney retained by
Ms. Lambert's family, we again considered the record of the 1992 trial. We noted
Page 420 of 2301
that Ms. Lambert's counsel, Jules Epstein, Esquire, raised a number of issues and
appeared to ask this court to consider those issues out of the context of the entire
record. For example, Mr. Epstein challenged trial counsel's failure to call character
witnesses in a first degree murder case. A superficial consideration of that issue
might suggest that the failure to call character witnesses for the defendant in an
important case would be problematic. However, considering this issue against the
backdrop of the entire record, the decision not to call character witnesses seemed
more than prudent. As to the request that we ignore the record in favor of certain
discreet issues, we noted:
Ms. Lambert's new attorney invites this court, and any reviewing court, to view the
transcript of this trial as if it were a cold specimen in a laboratory, to be studied,
dissected and analyzed in a sterile environment. The court is invited to excise
certain portions of the transcript with the cold scalpel of cynicism and to carefully
study those portions of the record which, under a certain light or a different lens,
could be viewed as error. While interesting as pure, detached legal analysis, this
method of analysis of a trial record yields only part of the whole picture.
This case is not a law school research project or an examination question. This case
involves a consideration of the record of a murder trial. And as with all trials, it is
necessary to look at the record in totality. This trial was conducted in a context, as
is every trial. This trial was more than a recording of words, more than the
emotionless, cold series of questions and answers reflected in a transcript. A trial
involves human beings, thinking, speaking, pausing, listening, telling the truth,
shading the truth, avoiding the truth. It involves people speaking loudly, speaking
softly, crying, reacting to others who are speaking or crying. Counsel, the parties
and the fact finder observe facial expressions, tone of voice, body position,
inflection, statements and reactions to statements.
This court will not reevaluate the evidence from the trial nor is it required to do so.
This court can, however, recall and consider the entire record of the trial in
evaluating the performance of trial counsel. The court must consider the whole
record to determine whether any alleged errors by trial counsel were so serious as
to deprive the defendant of a fair trial, i.e., a trial whose result is reliable.
Commonwealth v. Carter, supra. Considering the various alleged errors of trial
counsel in the light of the entire record, this court can find no error which, in any
way, deprived defendant of a fair trial.
Commonwealth v. Lambert, March 14, 1995, slip op. at 38-40.
If nothing else, this case will give pause to anyone who considers the relationship
between the federal and the state courts. A brief consideration of the principle of
comity is necessary in this opinion for several reasons. First, it will help to explain
why this court conducted an eight-week hearing on a PCRA petition. Second, a view
of the comity question from our vantage point may possibly help in understanding
this court's decision as the case progresses through an appellate court. Third, the
context of this case has been instrumental in framing the issues. A complete
discussion of the context of this case would be greatly lacking without a
Page 421 of 2301
consideration of the treatment afforded the issues and the participants by the
federal district court in 1997.
What do we mean by "comity?" The Third Circuit, in considering this case in 1997,
gave a succinct and clear answer:
The doctrine of comity '"teaches that one court should defer action on causes
properly within its jurisdiction until the courts of another sovereignty with
concurrent powers, and already cognizant of the litigation, have had an opportunity
to pass upon the matter."' Rose v. Lundy, 455 U.S. 509, 518, 102 S.Ct. 1198,
1203, 71 L.Ed.2d 379 (1982) (quoting Darr v. Burford, 339 U.S.200, 204, 70 S.Ct.
587, 590, 94 L.Ed. 761 (1950)). Indeed, we opined in Toulson v. Beyer, 987 F.2d
984, 986 (3d Cir. 1993), that requiring exhaustion of state remedies 'addresses
federalism and comity concerns by "afford[ing] the state courts a meaningful
opportunity to consider allegations of legal error without interference from the
federal judiciary."'
Lambert v. Blackwell, 134 F.3d at 513 n.18 (citations omitted).
Comity appears to require deference. Comity appears to require understanding
and, perhaps, even respect for the treatment given the issues in state court. The
federal district court took significant liberties with state court criminal practice. The
federal district court did this in a number of ways. First, it allowed for an
unprecedented and unbounded level of discovery. In a three- month period of time,
some 55 depositions were taken.(47) The document production ordered by the
federal district court was at odds with any concept of attorney work product under
even the most liberal standards. In effect, the most permissive approach to civil
discovery was applied to a criminal case.
Second, the federal district court substituted its own fact finding on critical issues
from the 1992 trial. Something other than "comity" is at work when fundamental
findings of fact in a state court homicide case are "dismissed" by the federal district
court.
Third, the federal district court substituted its legal judgment for the state court's
analysis. For example, this court made a ruling on the discussion between First
Assistant District Attorney Kenneff and Dr. Mihalakis in response to Ms. Lambert's
counsel's motion for a mistrial at the 1992 murder trial. In making that finding, this
court held a conference in chambers, on the record, in the presence of all counsel
and the expert witness. This issue will be treated in more detail in Section VII.H,
infra. Suffice it to say, for purposes of our discussion of comity, that substitution of
the federal judge's legal analysis for the state court judge's legal analysis was an
"overruling" by a court which, at the moment, possessed a stronger and more
immediate power. It was not "comity" befitting a constitutional democracy.
Finally, by employing a creative and aggressive approach to exhaustion, the federal
district court deprived this court of the opportunity to revisit the legitimate issues
raised by petitioner in a proper context. Aggressive may be a good adjective for
investment strategy or athletic performance, but not for legal analysis.
Is this what the Anti-Terrorism and Effective Death Penalty Act of 1996 ("AEDPA"),
Page 422 of 2301
28 U.S.C. Section 2254, contemplated? If so, then federal legislation defining the
role of federal habeas corpus in the criminal justice universe has made this a very
strange place. This approach to "comity" will cause the state court murder trial
simply to become a rest stop on the way to federal justice. Will we have state court
homicide convictions ultimately decided in a forum under a lighter burden of proof
and where state court criminal convictions will come under the often misleading
microscope of civil discovery? Will we now as a matter of federal due process and
equal protection put every state court murder conviction under the scrutiny of
boundless discovery, creative advocacy and a court willing to reach conclusions
based upon a partly developed record?(48)
In federal habeas corpus litigation, factual determinations made by the state courts
are correct unless the petitioner can rebut the presumption of correctness by clear
and convincing evidence. See 28 U.S.C. 2254(e)(1). With respect to legal
conclusions, the federal courts are required to give deference to legal conclusions
made on the claims for relief by the state courts. See 28 U.S.C. Section 2254(b).
In Commonwealth v. Traviglia, 541 Pa. 108, 661 A.2d 352 (1995), the Supreme
Court reiterated that it is the responsibility of the state--not federal--courts to
make factual determinations in the first instance and that the latter must give
deference to the former. Specifically, both the Post Conviction Hearing Act court
and the federal district court resolved a factual dispute: whether a non-use
agreement had been struck in Indiana County. The PCHA court concluded that a
non-use agreement was not in existence; the district court came to the opposite
conclusion. In this regard, the Supreme Court stated:
Similar, nearly identical, records can legitimately support two different holdings;
that two different holdings may result from similar records does not mean that one
determination is somehow invalid. . . . A factual determination by a federal district
court in no way 'overturns' the factual determination made by, and subsequently
affirmed by, the courts of our commonwealth.
541 Pa. at 108, 661 A.2d at 362-63 (footnote omitted).
In this case, the federal district judge failed to give the state court record due
consideration and the deference to which it is entitled under law. For our purposes,
the "findings" of the district court in the habeas case in no way "overturned" the
factual findings made by this court.
As the Court of Appeals appropriately noted, "a finding of actual innocence, as that
term has come to be used in federal habeas corpus jurisprudence, is not the
equivalent of a finding of not guilty by a jury or by a court at a bench trial."
Lambert v. Blackwell, 134 F.3d at 509. See Bousley v. United States, --- U.S.
---, 118 S.Ct. 1604, 1607, 140 L.Ed.2d 828, 840-41 (1998) ("'actual innocence'
means factual innocence, not mere legal insufficiency") (citing Sawyer v. Whitley,
505 U.S. at 339).
Ms. Lambert maintains in this PCRA that she is actually innocent of Laurie Show's
murder. In the heading to the first section of her list of claims, she states: "After-
Page 423 of 2301
Discovered Evidence Proves Lambert's Innocence . . . ." (See Exhibit A, Section

A.(49)) Pennsylvania law, unlike its federal counterpart, does not specifically
recognize "actual innocence" as a basis for relief.(50) Consequently, there is no body
of state law specifically defining the parameters of proof of such a claim. But, in
federal decisional law, it is well established that when a petitioner makes a claim of
this sort, the government is not limited to the existing record to rebut any showing
that petitioner might make. It may present "any admissible evidence of [a]
petitioner's guilt. . . ." Bousley, --- U.S.at ---, 118 S.Ct. at 1607, 140 L.Ed.2d at
841. While a finding of "actual innocence" is not within the purview of the PCRA,
Ms. Lambert's case is centered on her belief that she is an innocent person,
wrongly convicted.
A two-judge motions panel of the Third Circuit in reviewing this case stated:
"Although the district court could not of course make a determination that Lambert
was not guilty of an offense tried in a state court proceeding, a finding of
'innocence' by the district court would appear to be a conclusion that prosecutorial
misconduct was a determinative factor in unjustly bringing about a guilty verdict."
See, 962 F. Supp. at 1528." Lambert v. Blackwell, Nos. 97-1281, 97-1283 and
97-1287, slip op. at 7 (3d Cir. May 6, 1998).
The finding of "actual innocence" could not have been a declaration that Ms.
Lambert did not commit this crime. "Actual innocence" does not actually mean
"innocent." It is, rather, a commentary on the weight of the evidence of
prosecutoria l misconduct and the application of a remedy under federal law. Ms.
Lambert has not been proven innocent and she does not stand before this court as
an innocent woman forced to prove her conviction was unfair. She has been
convicted of first degree murder and the federal finding of "actual innocence" is no
more than a footnote to that verdict.
This case presents a complex narrative of police corruption, heartless, dishonest
prosecutors, ineffective defense lawyers, an unwitting trial judge, rubber stamp
appellate courts and a fast breaking series of "shocking" revelations and "explosive"
disclosures. The petition raises well over two hundred allegations of prosecutorial
misconduct, new evidence, ineffective assistance of counsel, and discovery
violations. To accept petitioner's theory of this case, it is necessary to understand
her entire story. Each allegation has a place along a story line which must be true if
Ms. Lambert's case is to have any merit. Before delving into a discussion of the
merits of this case, we offer, as context, the following synopsis of the story,
according to Ms. Lambert.
We caution that this section does not present this court's findings of fact.
Rather, these "facts" represent petitioner's vers ion of this story.
On Friday morning, December 20, 1991, a 15 year old girl was murdered in her
condo in East Lampeter Township. Her mother returned home from a brief errand,
found her and held her in her arms until she died. Hearing the mother's cries for
help, a neighbor called 911. A dispatch was broadcast to East Lampeter Township
Police. Officer Robin Weaver, a Township police officer, was on patrol in that area
and heard the broadcast over his radio. He recognized the location and the name
Page 424 of 2301
and he responded without being dispatched.

Weaver was the first officer on the scene. He realized the victim was Laurie Show
and recalled Laurie Show had been harassed in a loc, al mall by Michelle Lambert, a
19 year old local resident. Weaver knew that Ms. Lambert and her boyfriend,
Lawrence Yunkin, had a disagreement of some sort with Laurie Show. Weaver also
knew that three officers from his department gang raped Ms. Lambert in her
apartment on June 17, 1991.
As he stood in the Show condo that morning, while Laurie Show died in the arms of
her grieving mother, Weaver's response was not to summon help, not to comfort
Mrs. Show, not to render aid to the victim, and not to search the condo premises
for suspects. Rather, Weaver's response was to plan, then and there, a conspiracy
which would implicate Michelle Lambert in the murder of Laurie Show, thereby
relieving his cohorts of any further worries about the gang rape of Ms. Lambert that
prior June.
This is the essential truth of this case as presented by petitioner: that the murder
of Laurie Show was a fortuitous moment for the East Lampeter Township police.
Further "truths" follow as the story unravels. Detective Savage, the crime
investigator for East Lampeter Township, responded to the scene. Savage knew
about the gang rape. Savage and Weaver heard Mrs. Show tell neighbors and
family that she believed the murder was "a set up" and that she believed Michelle
did it. They took her aside that morning and as they questioned her about the case,
they suggested to her that her daughter told her that Michelle did it. Because she
was vulnerable, because she was in shock, and because she hated Michelle
Lambert, Mrs. Show was willing to believe, then and there, what the police told
her: that her daughter made a dying declaration identifying Michelle as her killer.
Later, based solely on the subliminal suggestion of a cunning detective made just
outside her daughter's blood-soaked bedroom, Mrs. Show would testify about this
dying declaration under oath in two preliminary hearings and two first degree
murder trials.
The police suggested this dying declaration even though they had proof that
morning that Laurie Show couldn't speak. This proof was in the form of an
observation by Ken Zeyak, an EMT with no training in anatomy, no medic al
education and no experience in observing wounds such as those suffered by Laurie
Show. Yet, Mr. Zeyak, the first ambulance person on the scene, immediately noted
that the victim had a severed left carotid artery. Zeyak, Weaver and Savage knew
that a severed left carotid artery means you can't speak. Yet, knowing she couldn't
speak, the police suggested to the mother that the dying declaration pointed the
finger squarely at the woman they had gang raped six months before.
A team from the police department descended on the condo and began to gather
evidence. They took pictures all over the condo. Some of these pictures showed
blood in the front hallway, including bloody footprints all over the tile floor. The
victim's body was taken from the scene and transported to the county morgue
located in the basement of the county nursing home. An autopsy was scheduled for
9 o'clock the following morning.
The police conspiracy to frame Ms. Lambert, hatched that morning in the midst of
an emotional and confusing murder scene before an investigation even began,
Page 425 of 2301
forever changed the "true" facts of this case. Ms. Lambert has now presented her
view of what really happened.
Lisa Michelle Lambert and Lawrence Yunkin began dating in 1989. He was abusive
to her, sodomized her, and struck her whenever he disagreed with her. She came
from a strong Christian, middle class, suburban family and she had lost her
virginity to him. This meant that she was going to marry him, despite the abuse.
She left home at the age of 16 and began to live with Lawrence at his parents'
home. Later they moved into their own apartment and in the late summer, early
fall of 1991, they moved to a trailer in Pequea, a rural township "across town" from
East Lampeter.
Lawrence turned her from a brown haired, brown eyed, shy, Christian, suburban
teenager into a lynx. He told her to dye her hair blond, which she did. He told her
to make her brown eyes blue, which she did with, tinted contact lenses. He told her
to ditch the frumpy suburban teenage wardrobe and get something tight and short,
which she did. She became Rural Barbie, with an attitude. This 19 year old
lumberyard laborer, with the Adonis looks and the Svengali mind, dominated and
controlled her every move. They had a sexual relationship, but she didn't like it
much because he was cruel and rough. In fact, she didn't like it much for over two
years.
In the early summer of 1991, Lisa Michelle, known now only as "Michelle," began to
look for a way out of the relationship. She was tired of being a blond haired, blue
eyed wearer of tight clothes just to please this galoot. She broke up with Lawrence,
b, ut they continued, to , live together and to sleep in the same bed. She even saw
another man, but this was when Lawrence was sleeping, exhausted from a day of
boorish behavior. While Lawrence slept, Michelle crept out of the bedroom to the
outside where she encountered Allen Rudolph, her new friend. She and Allen played
midnight basketball. Then Allen would pull her in the window of his house where
they would sit on the floor in his bedroom, listen to rock and roll, laugh and, of
course, have sex. Then she would, by the light of the early dawn, creep back into
Lawrence's bed.
Lawrence found out about this and came to the swimming pool where she was
sunning herself in a bikini, although she really didn't like wearing small tight
clothes. Lawrence threw all of her clothes out of the van, all over the swimming
pool and screamed at her for four or five hours. This caught the attention, and the
affection, of Michael Pawlikowski, a life guard at the pool. He became romantically,
but not sexually, involved with Michelle through the rest of the summer.
On June 17, 1991, around the time when Michelle had broken up with Lawrence but
was still sleeping with him, was sleeping with Allen but not dating him, and was
inadvertently catching the eye of Mike the life guard, she was gang raped by three
police officers. As she lounged at twilight in her living room in her bikini after a day
of sunbathing, three police officers came to her door. They were able to open the
door because Lawrence had broken the window pane one day. The three officers
raped her. She heard each of them speak but she couldn't see them. She could
only see their police badges reflecting light off the street lights coming in through
the window.
Michelle's first response to this rape was to call Mrs. Show, the mother of Laurie
Page 426 of 2301
Show. She called Mrs. Show because Lawrence was, at that time and for a period of
one week, dating Laurie Show. She called Mrs. Show to find out where Lawrence
was. Mrs. Show didn't quite understand the question because it was hidden among
a screaming barrage of obscenities, profanities and threats against her daughter.
Michelle then called a number of other people looking for Lawrence. She didn't call
her parents, she didn't go to the hospital, she didn't go to a rape crisis center and
she didn't go to any police officer in any other department anywhere.
She called Mrs. Show a lot that summer. She would call her to find out where
Lawrence was and to tell Mrs. Show to keep her daughter away from Lawrence.
Sometimes, when Mrs. Show would hang up after being called every day for several
weeks, Michelle would continue to call and the phone would ring in the Show
residence all evening. Mrs. Show changed her number to an unlisted one and the
telephone calls stopped.
Michelle didn't think the phone calls were getting through to Laurie so she got some
friends to help her with a plan to "embarrass" Laurie, to keep her away from
Lawrence. They were going to go to Laurie's home, kidnap her and take her down
to "the ward."(51) They were going to cut off her hair, take off her clothes, blindfold
her, and tie her to a post. They were going to hang a sign around her indicating
that she was available for sex for any of the locals. One evening, they got so far as
to get in two cars and to head over to the Show residence. It was at this point that
two of the teenagers decided that this sounded like a little more than a "prank" and
decided to warn Laurie not to answer the door if anyone should come. They turned
around and didn't go to the Show residence that evening.(52)
Time passed and Michelle discovered that she was pregnant to Lawrence, she
believed with twins. Even though she lived with Lawrence miles from East
Lampeter, even though Lawrence no longer saw Laurie, even though they were
living worlds apart, Michelle wanted to make sure Laurie never took her man from
her again. So, she asked her new friend, Tabby, to go to the Show residence with
her to really scare Laurie. She told Tabby that she had arranged for Mrs. Show to
be out of the home that morning.(53)
Michelle bought a 50 foot length of rope and two ski masks from K-Mart. She took
a large butcher knife from her kitchen. She told Tabby to wear sunglasses, put her
hair up and leave the makeup in the bathroom.
Michelle and Tabby went to the condo a few days before Christmas. Michelle
wanted to talk to Laurie. They knocked on the door and when Laurie answere d,
they pushed their way in and began to struggle. Michelle just wanted to talk, but
Tabby wanted to cut Laurie's hair off. Tabby pulled out a knife that came from
Michelle's kitchen, even though Tabby hadn't been in Michelle's kitchen that
morning, and Tabby stabbed Laurie. Michelle realized that this was a bad scene.
She told Tabby to stop it and she tried to pull Laurie by her wrists out of her
bedroom and down the hall. This left blood all over the floor and the walls. But
Tabby pulled Laurie back in the bedroom and Michelle went outside. Michelle sat on
the steps and cried because she was afraid of Tabby and worried about Laurie.
Lawrence arrived and asked what had happened. Michelle told Lawrence about
Tabby and Laurie. Lawrence swore at Michelle and went inside. Then Lawrence and
Tabby came out and all three ran to Lawrence's car and drove home.
Page 427 of 2301
Michelle knew something bad happened to Laurie but she couldn't get help. She
couldn't call any friends, she couldn't call the police, she couldn't tell her parents.
This was because Lawrence watched her "like a hawk" and she knew he would hit
her if she made a false move. So they drove home, took showers and drove Tabby
to school. They ate lunch at home and Michelle watched Matlock, which would come
in handy later when she was questioned by the police because she would already
know about her rights. Then they went Christmas shopping. Then they went to cut
down a Christmas tree at Lawrence's grandmother's house. This explains why they
had ski masks, a knife and a rope. On the package of the rope, there is a picture of
a man dragging a Christmas tree, which is why Michelle bought that particular
rope--to pull the Christmas tree.
Last year when they were cutting down a Christmas tree with a knife at
grandmom's, Michelle got wood chips in her eyes and in her hair. She got "pink
eye" from the wood chips. So this year she took sunglasses and a ski mask and
gloves so that she would be protected.
Then they went to Tabby's house. Tabby was watching the news and heard that the
girl was dead. So they decided not to arouse any suspicion and to go about their
normal Friday night business, which means they went to the bowling alley. The
police came to the bowling alley and asked Tabby why she had a big scratch on her
cheek. Michelle, who was afraid of Tabby and who didn't make one false move
because Lawrence was watching her "like a hawk," stepped up and told the police
that Tabby got the scratch in a fight with some Puerto Ricans girls who had made a
pass at Lawrence that morning.
The police then took them to the station. Michelle told the police about the Puerto
Rican girls and the scratch and about cutting the Christmas tree. When the police
told her Laurie Show was dead, she started to cry, but not because she had
anything to do with it. Then Corporal Raymond Solt, a Pennsylvania State Police
polygraph examiner, gave Michelle a lie detector test. He strapped Velcro straps all
over her arms. Then he took out a needle and told her he was going to inject her
with something. Probably it was truth serum. She thought this was part of the test
so she let him do it. Then he asked her some questions. She began to tell him
about going to the Show condo that morning. She told him that she and Tabby
went inside and that all three struggled. She said that Tabby pulled a knife and that
she, Michelle, held Laurie's feet so Laurie wouldn't kick her. She then told Solt that
she and Tabby left, pulled their hoods up and ran across a parking lot, across a
field, down a hill, across a stream, through some woods and out onto a road, where
Lawrence was waiting. She told Solt that she didn't plan to kill Laurie, that Tabby
went crazy and that she held Laurie down while Tabby went crazy.
Solt typed up her statement and she read it. She signed her name across each
page of the statement. Then Solt gave her some blank papers to sign her name.
She didn't understand this but she signed her name across these papers, too.
Meanwhile, the police reviewed four rolls of photographs of the crime scene.
Michelle told them she tried to help Laurie escape. Michelle also told them that
Tabby threw the phone across the room. When they looked at the crime scene
photographs, sometime after five or six in the morning when Michelle told them
this information, they realized that the photographs were wrong. If the telephone
was across the room, this would mean that Michelle was telling the truth and Tabby
Page 428 of 2301
was the killer. But the police needed to prove that Michelle was the killer, because
they had gang raped her and wanted her to go to prison forever or maybe get the
death penalty. There was only one thing to do: take Laurie's body back to the
condo and take the pictures again.
Sometime after 6 o'clock in the morning, when Michelle's statement was finished,
the police went to the county morgue, in the basement of a public building, took
the body out of the morgue and put it in a police car. Then they drove to the condo
where they were met by a state police officer, who agreed to take the pictures
again because he got it wrong earlier that day. First, they cleaned up all the blood
in the hallway. They missed one or two footprints but most of the blood was
cleaned up so the new pictures would show that Michelle was lying about helping
Laurie get out of the condo.(54)
They took new pictures of the body with the telephone cord wrapped around the
leg. This would show that Michelle was lying about Tabby throwing the telephone
across the room. The telephone cord around the leg would show that Michelle was
the killer.
Then they got the body back in the police car, back down the highway and into the
morgue. They had to do this by 9 o'clock because the autopsy was scheduled at 9
o'clock and they had to have the body back for the autopsy.
The autopsy was very important because Weaver and Savage knew they had to tell
the doctors that Laurie spoke and that her carotid artery couldn't have been
severed, even though they knew from Ken Zeyak, the ambulance person who had
never seen a carotid artery, that the carotid was "definitely cut." So they called
First Assistant District Attorney Kenneff, who prosecutes these cases. They told him
what the problem was. Mr. Kenneff went to the autopsy that morning and told Dr.
Penades, the pathologist, all about the carotid. Even though Dr. Penades was board
certified in anatomical pathology, the prosecutors had to tell him how the carotid
artery worked and that it was cut. They got Dr. Annese, a throat surgeon, to attend
the autopsy. He was a good choice because he was a friend of the Show family.
Together with Dr. Penades, he would say that the carotid artery was intact. They
would all agree that Laurie Show could have spoken to her mother.
This seems like a lot to happen inside one day. But the next day, police officers go
to the river. Lawrence and Michelle told the police that they had put Lawrence's
sneakers and a shirt in a pink trash bag and cast it into the river. They also threw
the knife in the river but it was not in a bag. The police go to the river two days
before Christmas when the water temperature is in the thirties, and they try to
figure out how they can use the river to really frame Michelle Lambert. They are
looking for a pink trash bag with sneakers in it. They find the pink trash bag and
they notice that one of the divers has a video camera and is filming them. So they
wave at him to turn the camera off. They take Lawrence's sneakers and other items
out of the bag and throw them away. Then they take the pink bag and they put it
in ice. They think of a way to make it look like it was stuck in frozen ice, even
though when they took the sneakers out it was not stuck in ice. Then they take a
picture of the pink bag stuck in frozen ice to make it look like they never found a
bag in the first place.
The next day a diver finds a sneaker which is full of mud and has black rot all
Page 429 of 2301
around the canvas where it touches the sole. Even though the murder was three
days before and it looks like the sneaker has been in the river for two years, they
figure it is probably the sneaker of the murderer and they throw it away, too.
A month later, the police record the statement of Lawrence Yunkin. They have been
rehearsing his statement with him for a month to make sure that he says exactly
what they want him to say so they can frame Michelle. He is represented by a
lawyer, who is an officer of the court and enjoys a good reputation in his
community. They take a recorded statement of Lawrence but he can't seem to get
the wrong story right so they have to keep stopping the tape to tell him what to
say.
In the meantime, Michelle decided to cover up for Lawrence even though she knew
Lawrence and Tabby killed Laurie and even though she was sorry about this and
even though she didn't know what really happened. So she wrote some questions
on paper and left them in a book in the prison library. Lawrence got the questions
and wrote in answers. A lot of the questions looked strange because words are
squeezed in, words are inserted and some of the words are written over very
heavily. The answers, which Lawrence wrote on the paper, did not make sense but
they could be interpreted to say that Lawrence at least knew something about the
murder. Even though Michelle was covering up for Lawrence, she thought it was
necessary to send him a questionnaire to find out what he did. So that she could
cover up. She got the questionnaire some time in February. Her baby was born in
March. She wouldn't tell her attorney about the questions until closer to trial. Her
attorney told her she might get the death penalty and that evidence linking anyone
else to the crime, especially Lawrence, might help her. Still, she stuck to her guns.
It was only when her attorney offered to give her a bottle of hair bleach that she
came up with the questions. It was important for Michelle to bleach her hair
because Lawrence wanted her to be a blond. Her need to dye her hair blond for
Lawrence, even though she had been in prison for four months, was facing a
murder charge and knew that Lawrence was going to testify against her, was
important. It was important because she was a battered woman and Lawrence had
control over her.
At her trial in July 1992, Michelle decided not to cover for Lawrence anymore. She
told the judge that she went to the condo that morning to talk to Laurie. When they
got inside, Tabby went crazy and Michelle tried to help her. All she did was sit on
Laurie's legs while Tabby attacked her. Then she ran outside to the steps and that
is when Lawrence came in.
She was interviewed before trial by Dr. Carey, a psychiatrist. She told Dr. Carey
about the gang rape but asked him not to mention it. Dr. Cary testified about his
evaluation of Michelle. He felt she was abused and controlled by Lawrence and that
she had been extremely upset about Lawrence's attentions to Laurie. He found it
significant that Michelle had only ever been with one man and that she was true
and faithful to Lawrence. Six years later in a post conviction hearing, Michelle was
asked about Allen Rudolph and why she didn't tell Dr. Carey about sneaking out at
night with Allen. Michelle testified that she did tell this to Dr. Carey but he had a
hearing aid and didn't hear her.
Michelle was convicted of first degree murder and given a sentence of life in prison.
While in a women's prison in Cambridge Springs, Pennsylvania, she was brutally
Page 430 of 2301
raped, beaten and kept in isolation for 18 months. Because of the mistreatment she
received at this prison, she was unable to help the lawyer whom her parents hired
to file her appeal. She couldn't tell him the true story. That is why her conviction
was affirmed by the Superior Court of Pennsylvania and that is why the
Pennsylvania Supreme Court denied the request for review.
She was eventually transferred to a prison in Delaware; then transferred again to a
prison in New Jersey. At the prison in New Jersey, she wrote in her own hand a
federal habeas corpus petition. Attorneys were appointed for her from a large
Philadelphia law firm and she went to court in April 1997 before a federal judge in
Philadelphia. He understood the truth of this case. He knew that the police were
corrupt and that they changed the evidence. He knew that the statements she gave
to Solt were really made up by the police. He knew that all they were doing that
morning at the condo, with a knife and a rope, was a "teenage prank." He knew
that the dying declaration was phony because an EMT saw the severed carotid
artery and a speech professor, who did not, said there is no way Laurie could have
spoken. He saw through to the truth that police officers, in response to a horrifying
murder scene, saw the fortuitous opportunity to frame a teenage girl because they
had gang raped her. He knew that she was telling the truth because she was a
battered woman and any inconsistencies in her story were because she had been
battered. He knew that the "29 questions" really was nothing more than a
confession by Lawrence and that it was a reliable document. He knew that a state
court trial judge had found the dying declaration to be credible and had ruled that
the "29 questions" was unreliable and inconclusive. He didn't know that the police
carried the body back into the condo and he didn't know that the police injected
Michelle with truth serum before they took her statement. He didn't know this
because Michelle's lawyers didn't learn about this until later, after the habeas
proceeding.
So, even though Michelle was in the condo that morning and even though Michelle
had a demonstrated history of hatred and animus toward Laurie, and even though
two versions of Michelle's story not only put her in the condo that morning but had
her involved in the struggle leading to Laurie's death, he found her to be "innocent"
and declared her a victim.
This is the story line which flows logically from the individual allegations of
misconduct and "new evidence." Item by item, the allegations of prosecutorial
misconduct taken out of the context of Ms. Lambert's entire story make this look
like a corrupt and unreliable prosecution. But in order to accept them and find them
true, it is also necessary to accept their place along this story line.
The above scenario is an understatement. It is a bare boned description of what
must have happened in 1991 and through the progress of this case, according to
petitioner. This is the context as seen by Ms. Lambert for the claims she has
presented to this court.
The "dying declaration" is in this case simply because a federal judge disagreed
with this court's assessment of the facts at trial. At the core of this issue is the
Page 431 of 2301
credibility of Hazel Show. The expert testimony is relevant to support or question

her veracity on this point.
With an attitude that does not even suggest deference to the state court's fact
finding, the federal district court dismissed the "keystone" of the 1992 verdict at
the start of his analysis:
It became clear during the hearing that this keystone of the Commonwealth's case
must be removed, and by that fact alone the arch of guilt collapses.
Lambert v. Blackwell, 962 F. Supp. at 1528.
That choice, to reach back five years into a state court record which had been
reviewed and affirmed on appeal and to change this court's finding of a crucial fact,
has become another keystone. That choice, which was a keystone of the district
court's decision, now supports petitioner's case.
Mrs. Show testified in the 1992 trial that her daughter Laurie made a dying
declaration to her in which she identified Michelle Lambert as the killer. Mrs. Show
testified in 1992 that she came upon her daughter in her bedroom, that she took
her head and shoulders into her arms and she cradled her, after cutting the rope
that had been tightened around Laurie's throat. (N.T., Trial at 792-93.) As she
cradled Laurie's head in her arms, Laurie uttered the words, "Michelle did it. .
.Michelle. . .Michelle. . .I love you. . .I love you. . .I love you. . .I love you." (N.T.,
Trial at 793, 795, 818.)
Whether this dying declaration ever occurred was a central issue in the 1992 trial.
It was a central issue in the federal habeas proceeding in 1997 and was perhaps
the central issue in the PCRA hearing. No less than six expert witnesses testified at
the PCRA hearing regarding the medical and physiological issues presented by the
dying declaration.
This court found Mrs. Show to be a credible witness on this and other topics in the
1992 trial. See Commonwealth v. Lambert, July 19, 1994, slip op. at 17-18. We
found her to be credible by observing her testimony in the courtroom on the
witness stand as she related her recollection from the morning of December 20,
1991. We further considered her conversations with medical personnel and others
at the scene of the murder on the morning of December 20, 1991. We knew in
1992 that she related almost immediately that "Michelle" committed the murder
and that it was a "set up." Her recollection from that morning and the information
in the police reports show that she, at some point, told investigating police officers
that her daughter spoke those words to her.
At the 1992 trial, we also had the benefit of the testimony of Dr. Penades, the
pathologist who performed the autopsy on Laurie Show, and Dr. Annese, an
otolaryngologist who attended the autopsy specifically to observe the structures of
the neck and to offer an opinion of the possibility of speech. The defense called Dr.
Mihalakis, who ruled out the possibility of clear and normal speech but who
acknowledged that Laurie Show was capable of "somewhat slurred and less
intelligible" communication consistent with the dying statement. (N.T., Trial at 344-
Page 432 of 2301
45, 357.)
With the benefit of this evidence, the court made a decision in 1992 that the dying
declaration took place, that Mrs. Show was credible on this point, and that the
dying declaration linked Ms. Lambert to the murder.
The PCRA petition raises a number of counts of after-discovered evidence which
petitioner contends cast doubt on the dying declaration. Specifically, petitioner
contends that Laurie Show's left carotid artery was severed, (Exhibit A, Section A at
para. 1), that Laurie Show could not have been conscious at the time she made the
dying declaration, (Exhibit A, Section A at para. 2), and that speech was medically
impossible, according to Charles R. Larson, Ph.D., (Exhibit A, Section A at para.
59). Further, petitioner cites as after-discovered evidence certain credibility
questions which impact on the 1992 testimony supporting the dying declaration:
that Dr. Mihalakis was paid more by Lancaster County after the 1992 trial, (Exhibit
A, Section A at para. 17); that Dr. Mihalakis changed his testimony, (Exhibit A,
Section A at para. 18); that Dr. Annese compromised his testimony because of his
familiarity with the Show family, (Exhibit A, Section A at para. 60); and that Mrs.
Show did not tell anyone that Laurie said "Michelle did it" until nearly two hours
after the murder, (Exhibit A, Section A at para. 61).
The federal district court found that Ms. Lambert proved to him "at least by clear
and convincing evidence that Laurie Show could not have said 'Michelle did it'."
Lambert v. Blackwell, 962 F. Supp. at 1529. In so doing, the federal district court
ruled that Mrs. Show was not credible on this point, despite the fact that he did not
have an opportunity to hear and observe her testimony in 1992. Further, the
federal district court based its finding on "evidence" that Laurie Show's carotid
artery was cut, thereby rendering speech impossible. He based this finding on the
testimony of an EMT, who admittedly had minimal, if any, training in anatomy, and
on the testimony of a speech professor from Northwestern University, Dr. Larson,
who never observed Laurie Show's body, who did not attend her autopsy, who is
not a medical doctor, whose sole surgical experience is limited to monkeys, and
who was willing to offer opinions far outside his area of expertise.(55) The federal
district court was able, somehow, to overlook the testimony of Dr. Penades from
the 1992 trial, as well as the testimony of Dr. Annese from the 1992 trial. Each of
these witnesses had, literally, hands-on contact with the structures of the neck of
Laurie Show during the course of the autopsy.(56)
At the PCRA hearing, petitioner produced Dr. Larson to testify about the
mechanisms of speech. He made a thorough and interesting presentation on how
the various structures of the neck and mouth and respiratory system work together
to produce speech. He offered this as a prelude to his expert opinion that it was not
possible for Laurie Show to articulate intelligible speech. Dr. Larson contends it was
not possible for Laurie Show to say "Michelle did it." (N.T., PCRA at 2414-15.) He
offered this opinion without ever having had the opportunity to observe the
structures in Laurie Show's neck and relied exclusively on crime scene and autopsy
photographs, the autopsy report and testimony at the various prior hearings. (N.T.,
PCRA at 2442.)
Dr. Larson also offered an opinion that the left carotid artery on Laurie Show was
severed. (N.T., PCRA at 2381.) Dr. Larson, whose knowledge of human anatomy,
albeit well articulated and detailed, is limited to charts, diagrams, photographs,
Page 433 of 2301
transparencies, past experience performing experimental surgeries on live monkeys

and, apparently, the occasional experiment with a cadaver, was called to offer an
opinion as to the integrity of the anatomy of a crime victim whom he never
observed. Would that this were not enough, he never offered an opinion as to the
significance of the cut carotid. Petitioner's counsel apparently chose to leave these
conclusions to the medical witnesses who, indeed, did address the significance of
"the cut carotid."(57)
Dr. Larson testified that the cut on Laurie Show's neck was between the thyroid
cartilage and the hyoid bone. He gave his opinion that this injury would cause the
tongue to, essentially, lose its anchor, resulting in movement of the tongue up into
the pharynx. Dr. Larson testified that the trauma to the neck would have caused
the tongue to change its position and occlude the air passage necessary to create
speech. (N.T., PCRA at 2418.) Dr. Larson appeared to this court to be
knowledgeable about the speech process. He could say what would happen if a
certain portion of the vocal tract is impaired or destroyed. He could not, however,
testify with any expertise about what actually might happen to the structures
effecting the vocal tract given certain physical injuries. His knowledge in this area is
only theoretical. He must make certain assumptions about the impact of certain
trauma on the vocal tract. With these assumptions, he can then conclude what the
possible effect on the victim's ability to form words, syllables or sounds might be.
Perhaps if Dr. Larson's analysis of the mechanisms of speech had been supported
by credible and persuasive medical testimony, his opinion and explanation might
have been more helpful to the court. The medical witnesses offered by petitioner
did not provide the necessary medical support for Dr. Larson's theoretical
explanations of the process of human speech.
Michael M. Baden, M.D., was the first medical expert called by petitioner. He is a
forensic pathologist from New York City and has extremely impressive credentials.
He was originally contacted by the Commonwealth, who decided not to call him as
a witness after receiving his report. (See Report of Dr. Baden, Petitioner's Exhibit
3011.) They disclosed the report to petitioner and petitioner's counsel called Dr.
Baden.
His opinion, in essence, was that Laurie Show would have died within a few minutes
of receiving her wounds. He felt she would have had to lose consciousness within
three minutes and suffer brain death within two minutes after that. (N.T., PCRA at
3165-66.) If her left carotid was severed, she would have lost consciousness within
a minute or so. (N.T., PCRA at 3169.)
There were several troubling aspects to Dr. Baden's evaluation. His report referred
to the victim of this case as Lisa Michelle Lambert.(58) Dr. Baden also opined from
his review of the autopsy report and testimony relating to the autopsy that there
was no dissection of the neck. (N.T., PCRA at 3175.) He believes there was an
obligation to dissect the neck. (Id.) In fact, the testimony of the physicians who
performed the autopsy, and the physicians who took the time to review the autopsy
report, was that the larynx and trachea were dissected from the neck and the
carotid examined. (N.T., PCRA at 6845.) While it does not appear that the carotid
artery was taken apart, piece by piece, while it lay inside the neck of the victim, it
was dissected and tied off. It was Dr. Penades who noted upon examination of the
carotid artery after the neck had been dissected that the carotid was not cut and
that it was intact. (N.T., Trial at 96.) How Dr. Baden could offer an opinion as to
Page 434 of 2301
the autopsy procedure and the integrity of the carotid artery in light of this clear
testimony and statement in the report defies belief. He created the impression for
this court that his analysis may well have been hurried in the midst of other
pressing matters.
Dr. Baden focused more on the cause of death and the time of death in relation to
the time of the infliction of the injuries. He gave a range of time within which Laurie
Show would have lived given certain assumptions as to the nature and extent of
the injuries to her neck. He specifically noted that he could not tell from the
autopsy photographs whether the carotid artery was severed. He made the
statement that an EMT would be in a better position to give an opinion as to the
carotid artery given the EMT's opportunity to observe the injury at the scene.(59)
(N.T., PCRA at 3197.) He offered no support for this belief. Dr. Baden appeared to
this court to beg the issue of whether the carotid artery was, in fact, cut by
deferring to the observations of the EMT, Ken Zeyak, who testified earlier in the
hearing. With the opportunity to observe Dr. Baden on the witness stand and to
attempt to reconcile his testimony with other evidence in the case, we found this
statement to be patently unbelievable. Later in the hearing, Dr. Levin, a throat
surgeon, testified that medical students and medical residents who observe neck
surgery are often unable to pick out structures in the neck and throat area without
guidance from a more experienced physician. (N.T., PCRA at 6244.)
We believe it is likely that Dr. Baden was attempting to be respectful of other
witnesses in this proceeding and that his choice to "defer" to the EMT testimony
was, in reality, a way of saying that he, himself, could not tell whether the carotid
artery was cut. Dr. Baden did not offer an in-depth discussion of the impact of the
neck wounds of Laurie Show on her mechanisms of speech. This would have been
the medical testimony necessary to give support and credence to Dr. Larson's
explanation of the speech processes. Dr. Baden provided no significant medical
support for Dr. Larson's opinion regarding the mechanisms of speech involved in
this case.
Petitioner's next dying declaration expert was John E. Smialek, M.D., chief medical
examiner for the State of Maryland. Dr. Smialek offered an opinion that was
interesting but implausible given other evidence in the case. According to Dr.
Smialek, Laurie Show did not die from the horrific lacerations to her neck. Rather,
she bled to death from the stab wound to her back. (N.T., PCRA at 3276-77.) In
fact, she bled to death so quickly from the stab wound that she was dead when her
throat was cut, according to Dr. Smialek. We know that the throat was cut before
Ms. Buck and Ms. Lambert left the condominium and we know that Laurie Show
demonstrated signs of life to a number of personnel, medical and otherwise, that
morning. Thomas Chapman felt a pulse and observed Laurie move her leg, (N.T.,
PCRA at 914), Charles Robert May noted faint ventricular fibrillation, goose bumps
and lip movement, (N.T., PCRA at 1430-32, 1434), Lisa Hinkle Billiter observed
ventricular fibrillation some time after Mr. May, (N.T., PCRA at 1018), and Mrs.
Show observed Laurie communicating the identity of her killer, (N.T., PCRA at
5658). For Dr. Smialek to be believed, all these other witnesses would have to be
completely disbelieved.
Dr. Smialek offered an interesting medical view of an alternative scenario. He did,
however, note that it was impossible to tell from the autopsy photographs whether
the carotid artery was severed. (N.T., PCRA at 3282-84.) Dr. Baden also found it
Page 435 of 2301
difficult to tell from the photographs if the carotid was severed. (N.T., PCRA at
3197.) These two experts, called by petitioner, cast serious doubt on the witness
who appeared to provide the most convincing testimony to the federal district
court: Ken Zeyak.
Mr. Zeyak was at the time a volunteer EMT and was the first of the medical
personnel to arrive in the condominium that morning. Mr. Zeyak had EMT training
for five months, eight hours per week. He believes he learned the location of the
carotid artery in basic anatomy. He admitted that the training he received as a
registered nurse, subsequent to this incident, provided him with much more
anatomy training. He recalled a clear observation of the left carotid and noted that
it was severed, it was spasming and no blood was coming from the artery. (N.T.,
PCRA at 706.) He has never in his life seen an autopsy nor seen an exposed carotid
artery. (N.T., PCRA at 718.) He has no good idea of the basic anatomy of the neck
as was evidenced by his answers on cross-examination. (N.T., PCRA at 719-723.)
In his EMT training he never observed an autopsy, never observed surgery, never
looked at a cadaver, never viewed a model of the neck structures, though he
believes there may have been diagrams of the carotid in one of his anatomy texts.
(N.T., PCRA at 718, 746-47.) It was interesting and instructive as to Mr. Zeyak's
credibility that he was able to identify the carotid artery on photographs,
(Petitioner's Exhibit 1514A; N.T., PCRA at 743), which were of no help to two world
famous forensic pathologists, Drs. Baden and Smialek. (60)
Dr. Levin, a professor of otolaryngology at the Penn State College of Medicine in
Hershey, Pennsylvania, testified in the Commonwealth's case. Dr. Levin also
testified at the federal habeas proceeding in 1997. Dr. Levin performs surgery on
the neck at least three times per week. Much of his experience is in the oncology
field and he has some experience in traumatic injuries to the neck and throat.
Dr. Levin testified that it was "very unlikely" that Laurie Show's carotid artery was
cut. (N.T., PCRA at 6172.) He based this on the autopsy report and autopsy and
crime scene photographs. In direct contradiction of Mr. Zeyak, Dr. Levin testified
that he could not see the carotid artery, much less a cut carotid artery, on any of
the autopsy photographs. He opined that the carotid artery lies deep to the
sternocleidomastoid muscle and offered his opinion from the photographs that the
sternocleidomastoid muscle was intact on Laurie Show. (N.T., PCRA at 6175.)
According to Dr. Levin, several of the "strap muscles" anterior to the
sternocleidomastoid muscle were severed and a portion of the sternocleidomastoid
muscle was cut but the muscle itself was intact. This suggested to Dr. Levin that
the carotid was intact as well. Further, Dr. Levin noted that in Dr. Penades's
autopsy report the carotid was observed and found to be uncut and intact.
Dr. Levin opined that Laurie Show could have been alive and that medically
speaking, she had the capacity to utter weak, breathy sounds such as her mother
described. (N.T., PCRA at 6185-86, 6188.) Dr. Levin also testified that with the
head cradled in the fashion described by Mrs. Show, the internal airways could
have been sufficiently closed to allow air passage through the larynx such as to
create some speech. He believes it would not have been a complete closure and
that air would have been escaping through the holes in the neck, but that some
closure sufficient for speech could have been achieved.(61) (N.T., PCRA at 6186-87.)
Dr. Burton, a forensic pathologist from the Atlanta area, testified on behalf of the
Page 436 of 2301
Commonwealth as well. Dr. Burton was the only medical witness who
acknowledged that medicine has its limits. He testified as to the physiology and the
anatomy involved in speech, particularly in the victim of this crime. (N.T., PCRA at
6873-74.) He also testified that frequently events occur which appear to be
impossible from a medical standpoint. (N.T., PCRA at 6886-88.) Dr. Burton, in
addition to providing thorough and interesting medical testimony, articulated the
central issue for the analysis of all these expert opinions: the experts are talking
about that which is possible or impossible strictly from a medical or scientific
perspective. Dr. Burton was the only medical expert who assessed the situation
taking into account the medical facts and the clinical picture. (N.T., PCRA at 6875,
6955-56.) Dr. Burton testified that the presence of Mrs. Show may have stimulated
and aro used Laurie. (N.T., PCRA at 6875.) Dr. Baden and Dr. Smialek were
impressive with their knowledge and their background, but neither acknowledged
the need to consider the clinical picture in the context of the medical possibilities.
The clinical picture in this case is what Mrs. Show saw and heard and did.
Dr. Burton offered the following expert opinions: (1) there was no anatomic
evidence that Laurie Show could not speak, (N.T., PCRA at 6873, 6884-88); (2)
there was no forensic or medical evidence that the carotid artery was severed,
(N.T., PCRA at 6840, 6844, 6865, 6981); (3) he could not identify the carotid
artery in the autopsy photographs, (N.T., PCRA at 6841, 6988-89); (4) Laurie could
have been conscious when her mother returned to the condominium, (N.T., PCRA
at 6884, 6884-88); and (5) the carotid had been dissected by Dr. Penades, (N.T.,
PCRA at 6927, 6981-82).
Dr. Ross, the forensic pathologist for Lancaster County, was the last medical expert
to testify on behalf of the Commonwealth. Dr. Ross took exception to most, if not
all, of the expert opinions offered by Drs. Baden and Smialek. Unlike his colleagues,
Dr. Ross believes that (1) Laurie was conscious when her mother came home,
(N.T., PCRA at 7329-30, 7332-33, 7354, 7400-01, 7404-07), (2) cradling Laurie's
neck could reestablish her airway and make speech possible, (N.T., PCRA at 736162, 7388-89), (3) Laurie was capable of speech, (N.T., PCRA at 7363, 7401-02,
7403), (4) Laurie was alive when the neck wound was inflicted, (N.T., PCRA at
7310), (5) the carotid artery was not severed, (N.T., PCRA at 7302, 7378), and (6)
Dr. Penades did dissect out the neck, (N.T., PCRA at 7366). Dr. Ross, however, did
agree with the defense experts on one thing: one cannot identify the carotid artery
on the autopsy or crime scene photographs. (N.T., PCRA at 7369.)
This collection of expert opinions all goes to whether the testimony of Mrs. Show in
July 1992 was credible. Experience teaches that expert opinion is sometimes
helpful, sometimes not. Experts once thought the world was flat. Dr. Burton's
admonition that we must look at the clinical picture in conjunction with the medical
evidence is most helpful. Drs. Levin, Ross, Penades, Annese and Burton all testified
that what Mrs. Show perceived was possible. They did not say it happened, they
did not say it did not happen. They only said that what Mrs. Show observed was
medically and physiologically possible.
For purposes of our PCRA hearing, all this testimony comes under the heading of
"after-discovered evidence." The court must inquire as to whether this evidence
was unavailable at trial, is exculpatory and whether it would have changed the
outcome of the trial. Reese, 444 Pa. Super. at 44, 663 A.2d at 209. On the first
issue, all of this evidence was available at trial. The essential facts, the autopsy
Page 437 of 2301
photographs, the autopsy report and the essence of the dying declaration, were all
well known in 1991 and 1992. Had petitioner chosen to do so, she could have
called expert witnesses to testify as to what Drs. Baden, Smialek and Larson said at
the PCRA hearing. Nothing about the essential facts as to the dying declaration has
changed. The only after-discovered evidence is the expert analysis of those facts.
This court does not believe that an expert's opinion is after-discovered evidence.
Expert opinion may well be a subsequent interpretation of the available evidence
and might be "after-discovered" in the sense that no one inquired as to these
opinions at the time of the trial. But the essential facts, the evidence on which the
opinions are based, are the same today as they were in 1991 and 1992.
Is the after-discovered evidence exculpatory? The opinions are mixed and there is a
disagreement among the experts as to whether Laurie Show could have spoken.
Certainly the opinions of experts who testified favorably as to petitioner would be
exculpatory as to her position. Yet these are only exculpatory opinions, not
exculpatory facts or evidence.
Finally, would the new "opinions" have changed the outcome of the trial? This court
has considered the expert opinions in 1992 and the expert opinions in 1998 and
finds nothing that would have changed the verdict in this case. The testimony of
Dr. Larson, a speech professor, was informative but largely in a theoretical sense.
He "pic ked out" the carotid artery on the autopsy photographs and offered an
opinion that it was severed. But Drs. Baden, Smialek, Levin, Burton and Ross, all
medical doctors, said that they could not determine whether the carotid artery was
severed from a review of the same photographs. Dr. Larson's opinion as to the
impact of the neck wounds on the movement of Laurie Show's tongue was disputed
by Drs. Levin, Burton, and Ross. No medical witness called by petitioner was able
to give credible supporting medical testimony for Dr. Larson's explanation. Dr.
Larson's understanding is based largely on charts, diagrams and photographs. In
the face of the overwhelming medical evidence presented by the Commonwealth,
both at trial and at the PCRA hearing, his expert opinion fell short.
In an analysis of whether the new "opinions" would have changed the outcome of
the trial, we begin with the testimony of Mrs. Show. We found her to be credible in
the 1992 trial. At that time, the court had the benefit of the testimony of Dr.
Penades and Dr. Annese, both of whom carefully observed the structures in Laurie
Show's neck during the autopsy. We found them to be credible. Based on their
examination of the neck wound, the vocal tract, and the structures of Laurie Show's
neck during the autopsy, they offered opinions which have yet to be contradicted in
any credible way.
Petitioner's case, led principally by Dr. Larson, assumes that Laurie Show's carotid
artery was cut. The court is asked to conclude on this basis that there was no
possibility of speech and that death followed the infliction of the wounds in a very
short period of time. We find that there is conclusive evidence that the carotid
artery was not cut. Petitioner would have this court ignore the autopsy report and
the testimony of Drs. Penades and Annese. In the alternative, petitioner would
have us believe that the autopsy report was falsified and that these two physicians
lied under oath about findings in the autopsy. We simply find no support anywhere
in the record of this case for that argument. We observed Drs. Penades and Annese
testify, we considered their testimony and find no basis to conclude that they were
Page 438 of 2301
lying.
The testimony of the EMTs carries no weight on this issue. Only Mr. Zeyak is sure
that the carotid artery was cut but he did not, and does not, have the medical
expertise to make this finding. Dr. Baden's and Dr. Smialek's testimony that Laurie
Show would have died, or would have been without brain function, before Mrs.
Show arrived is contradicted by witnesses at the scene who observed signs of life.
The medical personnel and neighbors arrived well after Mrs. Show came back into
her home and found her daughter. The more credible and persuasive expert
testimony was that of Drs. Levin, Burton, and Ross.
This "battle of the experts" has not shaken the credibility of Mrs. Show on this
issue. Petitioner contends that Mrs. Show did not tell anyone that Laurie said
"Michelle did it" until nearly two hours after the murder. (Exhibit A, Section A at
para. 61.) Lisa Hinkle Billiter, the registered nurse on Community Hospital's life
support unit which responded to the scene, testified that after attending to Laurie,
she and the other medics left the bedroom and approached Mrs. Show in the living
room to inform her that they were unable to do anything further for her daughter.
At that time, Mrs. Show "explained that she felt that Laurie had -- that she'd been
setup, that she had been made to go to the school for a guidance counselor
appointment that was never to occur, and that Lisa had -- or excuse me -- that
Laurie had said to her Michelle did it." (N.T., PCRA at 1025-26.) This statement (62)
by Mrs. Show occurred well before her police interviews and reveals that
petitioner's contention that the dying declaration was "suggested" to her by the
police is baseless.(63)
No expert has established that it would have been impossible for Laurie Show to
speak. In fact, competent and credible expert testimony proves in a clear and
convincing way that the dying declaration was possible. No evidence was presented
in 1992 or has been presented in the PCRA hearing which would cause this court to
change its finding that Mrs. Show was credible in 1992 when she testified as to her
daughter's dying declaration. The expert opinions in 1998, had they been presented
in 1992, would not have changed the outcome of the case.
The "29 questions" is a document which was passed between Ms. Lambert and Mr.
Yunkin at the Lancaster County Prison between the time of their arrest and Ms.
Lambert's trial. (64) How can a document which was of no consequence to the fact
finder in 1992 take on significance six years after the trial? Petitioner contends that
certain after-discovered evidence regarding this document gives it added weight
and points toward the culpability of Mr. Yunkin and away from the culpability of Ms.
Lambert. The after-discovered evidence is the fact that Lawrence Yunkin was
probably not truthful and forthcoming in his testimony about the "29 questions" in
the 1992 trial.
That would have, perhaps, some significance to this court as the fact finder in the
PCRA context had the court given any weight to Mr. Yunkin's testimony in the first
instance. This court made clear in its opinion on the post verdict motions that it did
not find Mr. Yunkin credible and had many reservations about the veracity and
reliability of the "29 questions." See Commonwealth v. Lambert, July 19, 1994,
Page 439 of 2301
slip op. at 11-12.

All Mr. Yunkin really said about those questions and answers is that he
remembered a similar document, that he recalled the questions being written in
pencil and that he wrote answers in pen. (N.T., Trial at 274-79.) He believed that
the document marked Petitioner's Exhibit 1119 at the PCRA hearing and
Defendant's Exhibit 5 at the 1992 trial was not the document on which he actually
wrote. (N.T., Trial at 276.)
At the 1992 trial, the defense produced John C. Gencavage, a handwriting expert
who examined the document. He offered his opinion that the document contained
no erasures and no graphite, indicating that there had been no pencil writing on the
document. (N.T., Trial at 869.) Mr. Kenneff stipulated to this testimony on the basis
that he had the document examined by a Pennsylvania State Police document
examiner as well. (N.T., Trial at 888-89.) There was never any effort by the
Commonwealth to hide what Mr. Yunkin said or to somehow bolster what Mr.
Yunkin said with expert testimony. Mr. Kenneff freely and openly acknowledged
that his expert's analysis of the document was consistent with the defense expert
and these expert opinions were both inconsistent with Mr. Yunkin's testimony.
Mr. Kenneff made the appropriate argument that these facts went to the veracity of
Mr. Yunkin and the reliability of the document. Mr. Kenneff further argued that the
court was free to accept all, part, or none of the document and the testimony
regarding the document.(65) (N.T., Trial at 1231-32.)
In 1992 and today, this court assessed the "29 questions" as inherently suspicious
and of very little help to the fact finder. (A copy of this document is attached to this
opinion in the "Addendum to Opinion.") To say this document is a "confession" by
Mr. Yunkin(66) is simply wrong. This is a document which contains answers which
are barely responsive to the questions. The questions contain words which are
crammed in the spaces and the questions are, if nothing else, entirely self-serving.
A number of possibilities exist. One is that Mr. Yunkin did, in fact, answer a
questionnaire which was written in pencil and that Ms. Lambert then traced his
answers onto another document all in pen. This would alleviate the erasures and
the traces of graphite. Another possibility is that there were several such
documents circulated between Ms. Lambert and Mr. Yunkin. At the PCRA hearing,
Petitioner's Exhibit 1474 was offered into evidence. This was a copy of another
questionnaire which appears to be in the same or similar handwriting as appears on
Petitioner's Exhibit 1119.
The "29 questions" does not take on the stature of after-discovered evidence
simply because a federal judge disagreed with a state judge's analysis of the
document's importance. Perhaps the "29 questions" would have raised a reasonable
doubt to the federal judge and perhaps, standing alone, this inherently unreliable
document would have served as the basis for his conviction of Mr. Yunkin.
The reality of this case is that the "29 questions" was fully and well considered in
the 1992 trial. Mr. Shirk made every possible use of this document, pointing out to
the court that Mr. Yunkin appeared to have made admissions as to his involvement
in the murder, that Ms. Lambert's story that she was covering for Mr. Yunkin is
buttressed by the "29 questions" and that, if nothing else, the "29 questions"
created a reasonable doubt as to who was actually in the condominium and who
Page 440 of 2301
actually killed Laurie Show. Subsequent discussions of that document have not
changed this court's mind as to its importance in 1992 or today.
Mr. Kenneff never hid his belief that Mr. Yunkin was not being forthright about that
document. In truth, no one involved in the 1992 trial could quite figure out who
wrote what on that document and what it meant. Had the Commonwealth been
able to use that document in a way to implicate Mr. Yunkin, this court believes the
Commonwealth would have done so. At no time in 1992 did the Commonwealth
evidence any interest in removing Mr. Yunkin from the case. In fact, in Mr.
Kenneff's closing, he noted that "his heart, his mind, and his stomach" told him
that Mr. Yunkin participated in the murder of Laurie Show. (N.T., Trial at 1272.)
To say that Mr. Yunkin's testimony that he wrote answers in pencil was perjury is
interesting. Under this world view, any testimony that differs from any other
testimony might well be "perjury" in the eye of the person who disagrees. In this
case, that would mean that at least one or more of the experts who testified are
perjurers. Certainly they did not agree and they gave diametrically opposed
testimony on certain basic facts, i.e., whether the carotid artery was severed.
With respect to the "29 questions," all petitioner can say is that Mr. Yunkin testified
in a way that was disputed by expert testimony. That argument goes to the weight
of Mr. Yunkin's testimony and the court gave little weight to Mr. Yunkin's
testimony.
Subsequent developments, i.e., the appearance of Petitioner's Exhibit 1474, (67)
would suggest that Mr. Yunkin may well have not perjured himself with respect to
the "29 questions." It is now clear that there was more than one document passed
between Ms. Lambert and Mr. Yunkin. Could Petitioner's Exhibit 1474, which is a
copy, have been originally written partly in pen and partly in pencil and used in
some fashion by Ms. Lambert to create a document written entirely in pen? Did she
include words and omit words so as to compose questions suited to the answers?
These are all questions that are unanswered and unanswerable.
For the purposes of analysis of the evidence in this case, the "29 questions" was
and remains an unreliable, inconclusive document. At best, it would have
established a reasonable doubt. This court found that it did not and that finding has
not been assailed by anything other than sound and fury, signifying nothing.
C. The Abuse Issue
Dr. Ann W. Burgess testified for a full day on "battered person syndrome" and its
application to this case. Dr. Burgess holds a doctorate in psychiatric nursing and is
a professor at the University of Pennsylvania. She was described by petitioner's
counsel as the world's leading expert on the psychology of battered women.
"Battered person syndrome" testimony is generally admissible under Pennsylvania
law for the very limited purpose of showing a defendant's state of mind as it relates
to self-defense in murder prosecutions.
In Commonwealth v. Gallagher, 519 Pa. 291, 547 A.2d 355 (1988), the
Supreme Court ruled that an expert witness's testimony regarding a victim's
affliction with "rape trauma syndrome" took the issue of the victim's credibility from
Page 441 of 2301
the jury and was, therefore, improper. In Gallagher, the expert witness was Dr.
Ann Burgess, who testified that aspects of the syndrome could affect a rape
victim's ability to identify the rapist. In commenting on Dr. Burgess's testimony,
the Pennsylvania Supreme Court stated: "It is clear that the only purpose of the
expert testimony was to enhance the credibility of the victim." 519 Pa. at 297, 546
A.2d at 358 (emphasis in original). The Court went on to note:
The question of whether a particular witness is testifying in a truthful manner is one
that must be answered in reliance upon inferences drawn from the ordinary
experiences of life and common knowledge as to the natural tendencies of human
nature, as well as upon observations of the demeanor and character of the witness.
. . . [T]he question of a witness' credibility has routinely been reserved exclusively
for the jury.
Gallagher, 519 Pa. at 297, 546 A.2d at 358 (quoting Commonwealth v. Seese,
512 Pa. 439, 443, 517 A.2d 920, 922 (1986) (citations omitted; emphasis added)).
The Court added that "[s]uch testimony would invest the opinions of experts with
an unwarranted appearance of authority on the subject of credibility, which is
within the facility of the ordinary juror to assess." 519 Pa. at 297, 547 A.2d at 358
(footnote omitted).
In 1997, the federal district court accepted Dr. Burgess's testimony to bolster Ms.
Lambert's credibility. The testimony was used almost exclusively for that purpose.
The federal district court noted that Dr. Burgess's testimony "explain[s] why for so
long [Ms. Lambert] covered for. . .Yunkin." Lambert v. Blackwell, 962 F. Supp. at
1535. (68)
The most recent development in the use of battered person syndrome is seen in
Commonwealth v. Miller, 430 Pa. Super. 297, 634 A.2d 614 (1993), appeal
denied 538 Pa. 622, 646 A.2d 1177 (1994). In Miller, battered person syndrome
expert testimony was admissible on the question of the reasonable belief
requirement of self defense in a case which involved a history of abuse between the
victim and the defendant. The Superior Court confirmed earlier jurisprudence in this
area by stating that such evidence is not admissible "to improperly bolster the
credibility of the defendant. . . ." Id. at 313, 634 A.2d at 622. The use of expert
testimony to exp, lain the statements made by the defendant after the killing
improperly invades the providence of the jury. Id. at 311 n. 3, 634 A.2d at 622
n.3. Under Miller, battered person syndrome might be relevant if the victim of the
killing had been the abuser.
But that is not the way it was offered in this case. The battered person syndrome
was offered for the following purposes:
(1) to explain why Ms. Lambert "covered up" for Lawrence Yunkin;
(2) to explain why Ms. Lambert refused to give Mr. Shirk the "29 questions" until
several months after the murder;
(3) to explain why Ms. Lambert told one story to Detective Solt, another story to
the court in 1992, and another story in her deposition, the federal habeas hearing,
Page 442 of 2301
and the PCRA hearing;

(4) to explain why Ms. Lambert was of little help to Mr. Shirk and Mr. Epstein
during the litigation of the post verdict motions; and
(5) to explain why Ms. Lambert finally told the "real story" in her hand written
federal habeas petition, composed on the floor of her cell in New Jersey by the light
streaming in under her cell door.
The Commonwealth moved to exclude the testimony of Dr. Burgess on the basis
that it was "bolstering" testimony which went only to enhance the credibility of Ms.
Lambert. The Commonwealth cited to the Gallagher and Miller decisions, and
other Pennsylvania appellate decisions in support of this argument.(69) This court
agreed with the Commonwealth's position that the testimony of Dr. Burgess insofar
as it explains why Ms. Lambert told one story, changed her story, covered up for
another person, took the blame for the murder or protected her paramour, is not
relevant under any reading of Pennsylvania law.
We allowed Dr. Burgess's testimony on the narrow issue of waiver. That is,
petitioner asserted a concern that the Commonwealth might ask this court to
dismiss the petition because it was not filed within the applicable statute of
limitations, i.e., one year from the date the judgment became final. See 42 Pa.
C.S.A. Section 9595(b)(1).
At the PCRA hearing, counsel for the Commonwealth did not take a position on
whether the petition was barred by the statute of limitations. It was determined
that this argument would be made at the conclusion of the hearing after all the
evidence was in and the parties were given an opportunity to assert legal
argument. It seemed appropriate to consider Ms. Lambert's state of mind during
the 1992 through 1997 time frame to the extent it explained why she did not file a
PCRA in a timely fashion.
At this point, the Commonwealth has made no motion to dismiss the petition for
failure to file within the required time. In fact, it appears there was no issue
regarding the limitation period. The narrow issue, therefore, on which Dr. Burgess's
testimony was permitted is not, in fact, an issue in this case.
Yet, consistent with the history of this case, we are required to discuss an issue
which has great emotional and public appeal while having little or no legal
importance. The issue of abuse in this case has taken on a life of its own. The issue
of abuse is central to Ms. Lambert's emotional case. Because Ms. Lambert's status
as a victim is central to almost every claim she raises, a full analysis of the truth of
her case requires an analysis of the expert testimony offered to secure her place in
that sad galaxy. Further, because it is clear to this court that petitioner will litigate
the issue of battered person syndrome in the appellate courts, this discussion is
included to explain our analysis and decision.
Petitioner makes much of the impact on her life of the abusive relationship she
shared with Lawrence Yunkin. Mr. Yunkin's abusive conduct toward Ms. Lambert
Page 443 of 2301
was a central issue in the 1992 trial, the post verdict motions and the appeals to
the Superior and Supreme Courts of Pennsylvania. Mr. Yunkin's conduct was
described in vivid and detailed testimony by Ms. Lambert. Mr. Yunkin, himself,
acknowledged certain bizarre and arguably abusive behaviors when he testified. It
appeared likely to this court in 1992 that Mr. Yunkin and Ms. Lambert shared an
abusive relationship which, sadly, was not unlike many we see in the criminal
system, domestic violence system and family court. Asked to describe his
relationship with Ms. Lambert in 1992, Mr. Yunkin gave the ironic response,
"Constantly at each other's throats." (N.T., Trial at 250.) Certain witnesses ch,
aracterized the relationship as more one-sided and others pointed out that each did
a share of the arguing and the confronting.
Petitioner asserts that Mr. Yunkin's abusive, domineering and controlling persona
directed every aspect of her existence. According to Ms. Lambert, her blond hair
and blue eyes were a function of Mr. Yunkin's obsession that she look like a
"Barbie." In fact, we now know that she was bleaching her own hair blond as early
as age 13 or 14 and that she discussed with her hairdresser the damage that was
being done to her hair by the dye. (N.T., PCRA at 6373-74.) Further, during the
eight-day 1992 trial, Ms. Lambert appeared in the courtroom every day with blond
hair and blue eyes. We have learned through testimony at this hearing that the
blue eyes were created by the wearing of tinted contact lenses. We note, however,
that the trial took place eight months after her last contact with Mr. Yunkin, eight
months after her incarceration, and with no rea, son for her t, o conti, nue a
behavior pattern that was "dictated" entirely by Mr. Yunkin. In short, the assertions
about her appearance simply are not credible.
According to Ms. Lambert, Mr. Yunkin dominated her every move. Yet, the tone of
correspondence exchanged between Mr. Yunkin and Ms. Lambert after each had
been arrested would suggest otherwise. A fair reading of the letters offered into
evidence in this proceeding(70) would show that Ms. Lambert was anything but
demure and unassertive. Ms. Lambert apparently learned that Mr. Yunkin sent a
handwritten postcard to Mrs. Show from prison on December 23, 1991. The
postcard states:
I don't know what to say for what happened but I'm sorry. I know this doesn't
bring Laurie back. If I could die & take her place & let her come back, I swear to
you I would. Laurie was a nice person, and she cared about you & her father a lot
[sic]. When Michelle saw her somewhere I would try to keep her from Laurie and
that's the truth. I had nothing against Laurie. For that week we went out she was
so nice to me. I feel it was my fault for going out with her & none of this would of
happened. All I can say is I'm sorry & I didn't know. Sincerliy [sic] Lawrence
(Petitioner's Exhibit 1018.)
In a letter postmarked January 25, 1992, from Ms. Lambert to Mr. Yunkin, while
both were in prison, Ms. Lambert wrote the following:
Dear Sweet Pea,
Lawrence, where is your head? Why on earth did you write to Laurie's mother?
WHAT in the world did you say? You should know better than that! All her mother
has ever done, is harrass [sic] us! Just leave her alone! That post-card could end
Page 444 of 2301
up in the paper! Are you crazy? What are you trying to pull? Her mother is telling
lies about us, trying to get us in real bad trouble, and you go and try to be buddies
with her!. . .
(Commonwealth Exhibit 10 (emphasis in original).)
It is difficult to pinpoint a moment in the PCRA hearing as the most bizarre. One
likely contender, however, was the testimony by Dr. Burgess as to the sexually
explicit poem dated January 16, 1992, written by Ms. Lambert for Mr. Yunkin. Dr.
Burgess focused on one line at the end of the poem to suggest that the sexual
relationship between Ms. Lambert and Mr. Yunkin was violent, abusive and "not
pleasurable for the female." We print the poem in its entirety only to illustrate that
the author, Lisa Michelle Lambert, may well have been contemplating another kind
of relationship:
Hick-o-ry, Dick-o-ry - Dock,
I'll lick you stiff as a rock,
When the clock strikes four,
I'll shove you onto the floor,
And ride your fat hard cock.
You'll feel me fast and tight,
And make me scream all thru the night,
I'll beg for more and more,
As you pull my hair, and call me a whore,
And you ram me harder and harder,
Until the morning light.
And when you fall asleep,
I'll still make you do me deep,
And when you tiredly moan,
I'll match you with a groan,
As you hurt me 'till I weep.
(Petitioner's Exhibit 422 (emphasis in original).)
The image that Ms. Lambert now tries to market, that she was a demure,
Page 445 of 2301
dominated, controlled victim, is contrary to so much evidence. From her verbal and
physical assaults on Laurie Show, to her planning the abduction in the summer of
1991, from planning the attack on Laurie Show on the morning of December 20,
1991, to her strongly worded letter to Mr. Yunkin in the prison, Ms. Lambert
demonstrated a character that is anything but demure and controlled.
The first reference to the alleged gang rape of Ms. Lambert came in the testimony
of Gene L. Carey, M.D., a psychiatrist from Hershey Medical Center, at the death
penalty phase of the trial of 1992. Dr. Carey volunteered that Ms. Lambert had
shared with him a description of this incident and had asked him not to mention it
in his testimony. (N.T., Penalty Phase at 58.) If, in fact, this rape occurred, it is
inexcusable and wrong. On the assumption that it did happen on June 17, 1991,
the impact of that incident on petitioner's claims for relief must be addressed. The
gang rape may be relevant for three reasons: (1) it may explain why the East
Lampeter Township police officers "framed" Ms. Lambert for the murder; (2) it may
explain why Ms. Lambert did not go to the police immediately on the morning of
December 20, 1991; and (3) it serves to buttress Dr. Burgess's characterization of
Ms. Lambert as a victim.
There is no proof that the gang rape occurred other than Ms. Lambert's own
statement. She chose not to seek medical help, she chose not to contact any
authorities, she chose not to tell her parents and she chose not to share the
experience with her boyfriend or any friend. She drew a picture of one of the
"rapists" and that picture was later "identified" in testimony by Mr. Shirk as Officer
John Bowman of East Lampeter Township Police. (N.T., PCRA at 3428-29.) On the
basis of this irresponsible "identification," serious allegations were made against
Officer Bowman at the outset of this proceeding and in the prelude to this
proceeding.(71)
Officer Robin Weaver of the East Lampeter Township Police Department was named
by Ms. Lambert as one of the rapists. Yet, no proof of this very serious allegation
was established. Rather, Ms. Lambert testified to being terrified upon seeing an
East Lampeter Township police officer at the Lancaster Catholic High Carnival within
a week of the alleged rape (or three, depending on the witness) to the extent that
she rushed to avoid any eye contact with this police officer. Her description of
terror in seeing him, buttressed by the testimony of Michael Pawlikowski, who
accompanied her to the carnival, suggested that she lived in fear of the officers
who did this to her. Yet, on August 1, 1991, in response to a harassment and
assault complaint, the very same Officer Robin Weaver spoke with Mr. Yunkin and
Ms. Lambert at the East Towne Mall for a period of 20 minutes or more. He spoke
to them about their contacts with Laurie Show and about the charge of assault and
harassment. He attempted to talk to them about their behavior. (Commonwealth's
Exhibit 51.) According to Officer Weaver's uncontradicted and credible testimony,
Ms. Lambert and Mr. Yunkin participated in this discussion with him. (N.T., PCRA at
6359-63.) This would appear to belie Ms. Lambert's position that she lived in fear of
the police offic ers, especially Officer Weaver.
Ms. Rainville, co-counselor for petitioner, went so far as to suggest throughout the
hearing that Ms. Lambert's child, born in March 1992, was the product of this gang
rape. (N.T., PCRA at 32.) Yet, we know better. In one of Ms. Lambert's letters to
Page 446 of 2301
Mr. Yunkin while in prison, she refers specifically to the baby and to Lawrence as
the father. She wrote:
Listen to me. Yes, I told my parents they can have the baby! They are going to
take care of him until I get out. I can not give the baby to your parents, Lawrence!
Look at what your parents did to you! Your mom "babied" you so much, you can't
even think for yourself!
(Commonwealth Exhibit 10 (emphasis in original).) Ms. Lambert then wrote in the
same letter:
Another thing, you weren't even happy when I told you I was pregnant! You hit me,
and went out and slept with that tramp! And then, for 4 months after that, you
didn't even believe I was pregnant! As far as I'm concerned, this baby doesn't have
a father!
Lawrence, I love you, but because of how horrible you've treated me , I love the
baby more. I love the baby more, because he is the good part of you.
We know as a matter of public record here in Lancaster County that the custody of
her daughter has been the subject of several court proceedings. We know that Mr.
Yunkin has acknowledged paternity and we know that DNA testing was conducted.
Judge Wayne G. Hummer of this court wrote: "DNA testing has been completed and
found that Lawrence Yunkin was not excluded as the biological father of the said
child and calculated that the probability of paternity was 99.98 %. Defendants
[Leonard M. Lambert, Judy L. Lambert and Lisa Michelle Lambert] have not
objected to these results." Yunkin v. Lambert, No. 102 -1993, slip op. at 2 (Lanc.
Co. C.P. June 29, 1994) (court held that the Yunkins, as paternal grandparents,
had standing to request custody of Ms. Lambert's and Mr. Yunkin's daughter). Does
it appear curious to anyone beside this court that Ms. Lambert will allow her
attorney to assert that one of the rapists was the father of her daughter while
choosing not to contest DNA evidence that Lawrence Yunkin was the father of the
child by a probability of 99.98 percent?
The fact of the gang rape has little, if any, legal significance in the analysis of the
issues raised by the PCRA petition. It has enormous significance in creating a level
of emotional intensity and sympathy, which drives much of petitioner's case.
It would be a tragic and inexcusable event if, indeed, it took place. The level of
sorrow one might feel for petitioner having undergone such terrible treatment has
no bearing, however, on the legal significance of that event to her case. Whatever
occurred on June 17, 1991, has no place in the analysis of petitioner's claims.
The gang rape is in this case only to give the police a motive to frame Ms. Lambert
for the murder of Laurie Show. To believe this, the court must believe that Officer
Weaver, upon entering the Show condominium on December 20, 1991, observed a
dying teenage girl and thought first to use the event to frame Ms. Lambert. To
believe this, the court must accept that Detective Savage took a grieving mother
Page 447 of 2301
aside within an hour of her daughter's death and planted in her mind the
suggestion that her daughter made a dying declaration. To believe this, the court
would have to accept that these police officers were acting first and foremost in an
effort to use the murder of Laurie Show to frame a woman who was gang raped six
months earlier by them or by members of their department. This is just not
believable.
Nor does the gang rape explain why Ms. Lambert failed to go to the police on the
morning of December 20, 1991. In fact, given every opportunity to explain to the
police and at trial why she did not report the murder after she fled from the
condominium complex, she never mentioned fear of the police because of a "gang
rape." She talked about Mr. Yunkin watching her "like a hawk," she talked about
being afraid of Ms. Buck, and she talked about not having access to a telephone.
Yet, she went to collect her paycheck, she went to the local mall, she went to Mr.
Yunkin's grandmother's home, she went back to Ms. Buck's residence and then
ultimately to the bowling alley. It strikes this court as unbelievable that Ms.
Lambert failed to report this incident to anyone because of fear of the police arising
out of the "gang rape."
Except as support for Dr. Burgess's characterization of Ms. Lambert as a victim, the
gang rape has no legal significance in this case. As we discussed earlier in this
section, Dr. Burgess's evaluation of Ms. Lambert would not be admissible under
Pennsylvania law to explain her conduct, her statements, or her choice to "cover
up" for Mr. Yunkin. The expert opinion that Ms. Lambert is a victim of abuse and
that she, therefore, acts in certain ways because of this status, has no bearing on
any legal issue in this case.
The gang rape would neither explain nor would it justify the well documented
course of physic al and verbal assaults by Ms. Lambert on Laurie Show, a history of
stalking Laurie Show and the plot to kidnap and do serious physical harm to Laurie
Show. Nor would it excuse the plan to go to her condominium on December 20,
1991, to cut off her hair, an incident which has been irresponsibly referred to as a
"prank." For these reasons, we find that the gang rape has no legal significance in
this case. There is no factual support in the record. It certainly would not explain
any of petitioner's actions nor would it explain or call into question the conduct of
the police during the course of the investigation of this case.
Petitioner contends that she was subjected to brutal, degrading and long lasting
mistreatment while at the State Correctional Institution at Cambridge Springs. It is
true that a corrections officer was convicted of sexual offenses having to do with his
conduct with Ms. Lambert. She contends this was a repeated and prolonged course
of prison rape. The facts suggest otherwise.
The perpetrator of these incidents with Ms. Lambert was convicted of aggravated
indecent assault, indecent assault and official oppression. He was not charged with
nor was he convicted of rape or any of the other sex offenses involving force or lack
of consent.(72) It appears from the evidence at the PCRA hearing that Ms. Lambert
and this corrections officer had a voluntary sexual relationship and that he was
convicted because he was a corrections officer and she was an inmate. In fact, in
Page 448 of 2301
her conversations with her counselor in prison, Ms. Lambert referred to the
perpetrator as "her buddy." (N.T., PCRA at 7564.) She also justified her
relationship with this man by telling her counselor: "[M]y hormones are up to here
[the counselor gestured by raising her hand above her head]. . . . All the other
women have everybody else out there, outside the fence, and I have what's in
here." (Id.)
To suggest that the incidents involving Ms. Lambert were not "rape" is not to
diminish them or to excuse them. They should never have happened and the state
corrections system and the authorities in Crawford County took action in response
to this conduct. Interestingly, it was not Ms. Lambert who reported the conduct.
Rather, she was contacted by investigating authorities. In fact, she denied having
any relationship with the perpetrator in the initial interviews. (N.T., PCRA at 7578.)
The significance of the conduct at Cambridge Springs is high in emotion and low in
legal relevance. No prison inmate should be subjected to official oppression nor
should any inmate be subjected to indecent assault. Yet, these incidents do not
excuse murder, they do not excuse a period of intense harassment or stalking of
the victim which occurred in 1991, and they do not call for a new trial. The
Cambridge Springs incidents enhance petitioner's victim status which, once
established and enhanced, goes nowhere. It appears that the narrow legal
significance would be to explain how little Ms. Lambert was able to offer in assisting
Mr. Epstein in litigating her post verdict motions.(73) That may well be true. Yet,
there was no prejudice because Mr. Epstein did a credible and thorough job
representing Ms. Lambert. She has been given every opportunity to litigate every
meritorious claim, and many other claims, in the federal proceeding and in this
PCRA.
Tabitha Buck received a severe scratch on her face on December 20, 1991. There is
no question that she received that scratch either in the Show condominium or
during her flight across the field and through the trees to Mr. Yunkin's car. Ms.
Buck has no explanation for when she got the scratch, but does not deny she
sustained the injury during or immediately after the murder.
Petitioner's counsel devote substantial energy to this issue and to the suggestion
that the police somehow "overlooked" this scratch. Petitioner's counsel suggest that
because Ms. Buck had a scratch and Ms. Lambert had no scratches or bruises, that
Ms. Buck must have been the murderer.
In fact, Ms. Buck is a convicted murderer. She was found guilty by a jury of second
degree murder arising out of the events of December 20, 1991. The prosecuting
attorney and police officers in this case never wavered from their position that Ms.
Buck was fully involved in the murder. The fact that the victim may well have
injured Ms. Buck and did not injure Ms. Lambert does not prove that Ms. Lambert is
innocent. At best, it proves that Ms. Buck was, in fact, involved and this issue has
already been proven beyond a reasonable doubt to a jury.
Page 449 of 2301

The same holds true with evidence of Ms. Buck's animus toward Laurie Show. There
was testimony at the PCRA hearing from Rick Lentz that he was in Laurie Show's
company when she was verbally assaulted and "smacked around" by Ms. Buck in
the fall of 1991. (N.T., PCRA at 2945-46.) This testimony would only go to support
Ms. Buck's involvement in the murder. Ms. Buck has been convicted of murder.
Proof of her actions toward Laurie Show or her animus does not disprove
petitioner's actions or animus. The evidence of Ms. Buck's animus is of no relevance
to this PCRA proceeding.
The police used a bloodhound to search for evidence along the Susquehanna River.
See Section VII.K, infra. Mr. Shirk testified that he did not know that Ms. Buck's
sweater was used to scent the bloodhound. (N.T., PCRA at 3364.) However, he also
stated that he had received and reviewed Officer Reed's river search report which
clearly states: "A white sweater worn by def. Tabatha Buck was brought to the
scene by myself for use of the blood hound [sic]." (Petitioner's Exhibit 1295.)
Ms. Lambert admitted buying the rope, (N.T., Trial 991-92), admitted agreeing with
Ms. Buck and Mr. Yunkin to use the rope to tie up Laurie Show, (N.T., Trial at 100001), and admitted watching as Ms. Buck cut off a portion of the rope, (N.T., Trial at
1000). Of course, Ms. Buck's scent was on the rope. However, just because Ms.
Buck's scent was on the rope does not mean that Ms. Lambert's was not. There was
no testimony that the dog attempted to trace Ms. Lambert's scent and failed. This
"evidence" that Ms. Buck's scent was on the rope does not exculpate Ms. Lambert.
Tabitha Buck's testimony in this hearing marked the first time she has testified
under oath in a courtroom about the events of December 20, 1991. Previously she
testified in a deposition as part of the federal proceeding but was not called as a
witness. We discuss Ms. Buck's testimony in this section because it is relevant to
Ms. Lambert's involvement in the killing of Laurie Show, it is relevant to the extent
it corroborates or disputes essential facts which have been called into question by
petitioner, and it is relevant to the core issue of Ms. Lambert's petition: that she is
an innocent woman wrongly convicted.
Ms. Buck first met Ms. Lambert and Mr. Yunkin in September 1991 while riding "the
loop" in Lancaster. (74) (N.T., PCRA at 6617-18.) Ms. Buck was 17 years old at the
time and was attending Penn Manor High School. She, Michelle and Lawrence "hung
out" through the fall of 1991. (N.T., PCRA at 6618.) In the fall of 1991, she became
aware of difficulties between Michelle and Laurie Show. She recalled Michelle saying
that she did not like Laurie and referring to her several times as a "bitch." (N.T.,
PCRA at 6619.)
On the evening of December 19, 1991, around 10:30 p.m., Michelle came to visit
her at the apartment she shared with her mother. Lawrence was outside in the car.
Michelle was "very upset" and "went on and on about wanting to get Laurie back. .
. ." (N.T., PCRA at 6620.) Ms. Buck described her as "crying and ranting, raving,
Page 450 of 2301
she was upset." (Id.) Ms. Buck testified, "I asked her what she was going to do.
She said, I'll kill her." (N.T., PCRA at 6620-21.) Michelle told Ms. Buck that she
wanted her (Buck) to go with her to see Laurie the next morning. Ms. Buck was
also told to "wear [her] hair up, to not wear any make-up and not to wear any
fingernail polish." (N.T., PCRA at 6622.) Ms. Buck testified that she knew Laurie
Show "by sight" because they rode the same school bus when Ms. Buck attended
Conestoga Valley High School. (N.T., PCRA at 6623.)
Ms. Buck testified that Michelle and Lawrence picked her up on the morning of
December 20, 1991. (N.T., PCRA at 6623.) Michelle appeared to give Lawrence
directions from the intersection by the McDonald's on Lincoln Highway. (N.T., PCRA
at 6625-26.) Lawrence dropped them off on Oak View Road by a field. (N.T., PCRA
at 6626-27.) Ms. Buck understood that Lawrence was going to go to McDonald's.
(N.T., PCRA at 6628.) Michelle told him to pick them up in 15 minutes. (Id.) They
then walked across the field toward the condominium complex. (N.T., PCRA at
6628-29.) Michelle was looking for the condominium and was not sure of the
correct number. She then located the condominium. (N.T., PCRA at 6629-30.) They
went to the bottom of the steps and Michelle told Ms. Buck to go upstairs, knock on
the door and ask for Hazel Show. She did so and Laurie answered the door. Ms.
Buck asked if Hazel was home and Laurie said, "No." (N.T., PCRA at 6630-31.)
Michelle told Ms. Buck the night before that Hazel should not be there because she
had called and arranged for Mrs. Show to be at a counselor's appointment. (N.T.,
PCRA at 6631-32.)
At that point, Michelle made her way inside. Ms. Buck then described:
Michelle apparently pushed Laurie back some distance. They were, like, in front of
the kitchen area or the living room area. And they were holding each other's arms
wrestling, like, arguing, yelling. At one point, Laurie, I guess, broke away from
Michelle and came toward me and I remember Michelle saying something about
don't go, stop or something and -- oh, I did have sunglasses on. I failed to mention
that. And Laurie grabbed my face, pushed me somehow and knocked the
sunglasses off and Michelle was behind her and she had a knife and they were in
the corner there where the door meets the wall, the hinges of the door, I guess.
(N.T., PCRA at 6633-34.)
Ms. Buck then went on to describe Laurie's attempts to escape:
A. . . . Laurie coming at me, moving me. I was right there inside the doorway.
Q. Okay. Do you know what Laurie was trying to do when she came toward you?
A. My guess is she was probably trying to leave.
Q. Okay. And could she leave?
A. She didn't have a chance.
Q. And why not?
Page 451 of 2301
A. Michelle was on her.

(N.T., PCRA at 6636.)
Ms. Buck described the knife as a "large kitchen knife" and described how Michelle
ended up huddled with Laurie in the corner near the front door. (N.T., PCRA at
6637-38.) Laurie had grabbed the blade of the knife and Michelle pulled it out of
her hand. As a result, Laurie's hands were cut. (N.T., PCRA at 6638.) According to
Ms. Buck, Laurie then got away and went into her bedroom. Michelle then "grabbed
her by the back of her hair when she walked through the door and she cut her
hair." (N.T., PCRA at 6637-39.) Ms. Buck recalls seeing Laurie with a phone in her
hand and was uncertain about what happened to the phone. (N.T., PCRA at 6640.)
Ms. Buck then went on to describe more of a struggle in the bedroom. When Laurie
was on her knees facing the bed, Michelle hit her in the back of the head with the
butt of the knife. She hit her more than twice in this way. (N.T., PCRA at 6641-42.)
Michelle then handed Ms. Buck the knife and attempted to put a rope over Laurie's
head. (N.T., PCRA at 6642.) Apparently, Michelle told Laurie to stop struggling and
to cooperate because "it would be a lot easier this way" and then she put the rope
over her head. (Id.) Laurie then began to struggle and reached for a pair of
scissors. Ms. Buck moved the scissors out of Laurie's reach. (N.T., PCRA at 664344.)
Ms. Buck testified:
Q. What happened after you moved the scissors out of Laurie's reach?
A. Michelle told me to cut her throat.
Q. Michelle told you to cut Laurie's throat?
A. Uh-huh.
Q. What did you say to Michelle?
A. I said, no.
Q. Okay. Did you still have the knife in your hand at that point?
A. Yes.
Q. What did you do with the knife?
A. Michelle took it back.
Q. What happened after that?
A. She cut her leg and told her to stop struggling.
Page 452 of 2301
(N.T., PCRA at 6644.)

Ms. Buck then went on to describe Laurie kicking and fighting with Michelle. She
testified:
A. Michelle told me to grab her feet, make her stop kicking and I did.
Q. You did that?
A. Yes.
(N.T., PCRA at 6645.)
Ms. Buck described sitting on Laurie's feet and facing away from her. As she sat on
Laurie's feet, Laurie was struggling and at some point her feet stopped moving.
Then Ms. Buck got off her feet and looked at Laurie. When asked what she saw, she
said, "I saw her throat cut." (N.T., PCRA at 6647-48.) She noted that Michelle was
sitting next to Laurie, on Laurie's right side. She said that the throat was cut deeply
enough that she (Ms. Buck) could see into Laurie's throat and could hear a "hissing,
whooshing sound." (N.T., PCRA at 6648.) She then testified:
Q. After you turned around and saw that Laurie's throat was cut and you saw that
Michelle was still next to Laurie, did you see that the knife was still in Michelle's
hand?
A. Yes.
Q. What did you see Michelle do then?
A. When I looked at Laurie I said, is she dead? Did you kill her? And Michelle said, I
don't know and proceeded to further cut Laurie's throat.
Q. Can you describe what she did when she further cut Laurie's throat?
A. She held her chin back with her left hand and cut her throat as though she were
cutting bread.
Q. Okay. Did you see how many times that cut went across Laurie's throat?
A. Several times.
(N.T., PCRA at 6649.)
Ms. Buck related that Michelle had the tip of the knife and handed it to her. Ms.
Buck put it in her coat pocket, picked up her sunglasses and they left the
condominium. Michelle told her to put her hood up and they went back across the
complex area. (N.T., PCRA at 6650-51.) She testified that they went down the
staircase and headed in the direction toward the wooded area. They walked behind
or in a line of trees behind the Frys' condominium, went across a field and toward
the road. They ended up along the road in some bushes. Ms. Buck indicated on an
Page 453 of 2301
aerial photograph of the condominium complex, (Commonwealth's Exhibit 5), that

she and Michelle ended up on Oak View Road north of the condominium entrance.
She testified that Lawrence was there and picked them up. (N.T., PCRA at 665155.) All she recalls about the conversation in the car was Lawrence looking over at
Michelle and saying, "Blood?" (N.T., PCRA at 6655-56.)
They then went back to Michelle's and Lawrence's trailer. Michelle and Ms. Buck
took showers. She recalls that she took the tip of the knife out of her pocket and
tossed it somewhere in a room in the trailer. She borrowed a pair of black stretch
legging pants, put on her white sweatshirt and Michelle and Lawrence took her to
school. (N.T., PCRA at 6657-58.)
Ms. Buck testified about the cut on her cheek and she believes that she got the cut
sometime during the events that occurred in the morning of December 20. (75) (N.T.,
PCRA at 6658-59.) She recalls that she took her jeans off and borrowed pants
because there was blood on her jeans. She left her Miami Dolphins jacket with
Michelle and Lawrence because they said they would wash it. (N.T., PCRA at 665960.)
On cross-examination, Ms. Buck acknowledged that she lied in her April 1997
federal deposition in that she was not complete in her answers. She also indicated
that she was not truthful when speaking to Detective Joseph Geesey when he came
to visit her at Muncy in 1997. (N.T., PCRA at 6726.) Ms. Buck testified that there
were certain significant issues which she "left out" in her deposition testimony.
These were:
(1) she did not talk about Michelle placing the rope around Laurie Show's neck;
(2) she did not talk about Michelle's feelings about Laurie Show;
(3) she did not talk about her sunglasses;
(4) she did not talk about Michelle making the last cut on Laurie Show's throat;
(5) she did not talk about Michelle telling her about the phone call to Mrs. Show the
night before. Rather, she suggested that she learned that Mrs. Show would not be
in the condominium that morning as they approached the front door;
(6) she left out the testimony about Michelle telling her not to wear make-up and
nail polish and to put her "hair up";
(7) she left out the testimony about Michelle handing the knife to her during the
attack;
(8) she left out the testimony about Michelle telling her to "cut Laurie's throat"; and
(9) she lied about wearing black stretch pants because she knew that her jeans had
blood on them and did not want to admit that. (N.T., PCRA at 6732; 6773; 6732;
6733; 6729-30; 6731-32;6732; 6733; 6732-33.)
When questioned as to why she did not tell the whole truth in her deposition, Ms.
Page 454 of 2301
Buck testified:
A. Several reasons. One, I was very scared. I had been told for a very long time -A. I was told not to say anything to anybody for a very long time and I was left
under the impression that the more I knew of anything the worse off it would be for
me. And aside from that, I was extremely intimidated that day. And I don't expect
many people will understand this other reason. But being a lifer and having been
incarcerated a lifer for as long as I have now, I would like to see women doing a life
sentence go home, get out of jail, and I just couldn't see saying certain things,
even against Michelle, if this were going to be a chance for her to go home.
(N.T., PCRA at 6673-74.)
At Ms. Buck's deposition during the federal proceeding, she was represented by R.
Russell Pugh, Esquire, of Lancaster. Immediately following the deposition, she
wrote a letter to Mr. Pugh explaining that she had been less than completely
truthful in her deposition testimony. We reprint the entire letter in the text of this
opinion because it sheds light on the extent of Ms. Buck's untruthfulness in her
deposition and her state of mind at that time, and it contains an explanation as to
her actions. It is also significant to this court that she c hose to acknowledge her
lack of complete candor in a letter to her attorney without any prompting and
before she was ever confronted with any inconsistencies. The deposition was April
4, 1997. The letter bears the date of April 8, 1997:
Mr. Pugh,
I have not been completely honest about what happened. Most of what I've told
you is the truth but I've purposely left some things out. Some very important
things. I knew how Michelle felt about Laurie. She talked about it all the time. She
always said how she wanted to kill her. She would think of different ways to do it
and would ask me my opinion. would tell her that her plans would work and she'd
laugh. She never followed through with any of them so I truly didn't take her
seriously. At first I didn't know who she was talking about when she said 'Laurie'
but when she told me her name was Laurie Show and she went to C.V., I made a
point to find out who it was. Laurie rode my bus and I avoided her. I never spoke
to her. I doubt if she even knew my name.
When Michelle came to the apartment on the 19th, she was upset and wanted to
talk. She said she was going to get Laurie because the police were after her for an
assault against Laurie. She told me she had called Ms. Show and pretended to be a
counselor from school. She said that Ms. Show wouldn't be at home in the morning
and she wanted me to go with her. I asked her what she was going to do and she
said she was going to kill her. I didn't believe her and I told her so. Then she said
she was just going to get her back for dating Lawrence and for calling the police on
her. I had never seen Michelle fight anyone--she was all talk so I guess I just
figured she was just talking and wasn't really going to hurt Laurie. I told her I
would go with her. She said for me not to wear any nail polish or make-up and to
put my hair up. She said that way, if anything did happen --there would be no
Page 455 of 2301
evidence of who was there. Again, I didn't take her seriously.

The next day, I wore an old pair of blue jeans that were a favorite of mine and my
white sweatshirt. When Michelle came she asked if I had any sunglasses and I said
yes. She told me to bring them. I did wear make-up and my hair was down. She
didn't say anything about it so I knew she wasn't serious about what she had said.
When we got to the apartment Michelle told me to put the sunglasses on so that
Laurie wouldn't recognize me. I told her she didn't know me anyway but she
insisted I wear them. Once we were inside the apartment, all hell broke loose.
When Laurie tried to run to the door, she grabbed my glasses and threw them in
the corner. She may have scratched me then.
In the bedroom when Laurie was kneeling over the bed, Michelle handed me the
knife after hitting Laurie with it. Then she pulled out the rope from under her shirt
(jergo) and tried to put it around Laurie's neck. She told Laurie it would look like a
suicide and if Laurie didn't give in, then she (Michelle) would get a group of pagans
to sacrifice her. Laurie stopped struggling and allowed Michelle to put the rope
completely over her head. Then she went for the scissors. When I pushed them
away Michelle told me to cut Laurie's throat. I looked at her like she was crazy and
I said 'no!' She told me to give her the knife and I did. Laurie was struggling again
and Michelle cut her leg. She told her it would be a lot worse if she didn't
cooperate. That's when Laurie started kicking again and Michelle told me to grab
her feet. In the process of getting her feet down, she kicked me in my mouth.
When I got off of Laurie's feet, I saw the neck wound and heard the air escaping. In
my mind I knew that she must be dead but I asked anyway. I asked Michelle, 'Is
she dead? Did you kill her?' She said, 'I don't know.' Then she cut Laurie's neck
even deeper. I saw her do it. That's when she said, 'Come on. Let's go.' On my way
out I picked up my sunglasses and we left.
At the trailer we took showers and Michelle gave me a pair of black stretch pants to
wear. My jeans had ripped open on one of the legs and there was blood on them.
Everything else I told you was true. I didn't think she would actually do it and once
she did--I was scared half to death. I don't know why I didn't tell you about her
calling Ms. Show. I don't know why I didn't tell you about the rope. All I know is
that I'm telling you the whole truth now. This is very hard for me to do but I figure-what do I have to lose? I'm already doing Life. I know that I lied under oath at the
deposition and I don't know what that will mean now. When I testify in court, I
want to tell the truth. I hope that it isn't too late.
I know I've disappointed you. You believed me and I lied to you. I apologize to you
for deceiving you. If you want to wash you hands of my case--I won't blame you.
Maybe I'll end up dying in prison but at least my conscience will be clear. I know
that I had no intentions of harming Laurie and I didn't believe Michelle would,
either. But maybe I do deserve this life sentence. If I'm meant to go home --God
will let me go and it won't happen without Him.
Again, I am so sorry for lying to you. I'm sorry for lying to everybody including
Detective Geesey. I hope that you won't hate me because of it. I feel like the world
Page 456 of 2301
has been lifted from my shoulders but I know it will be hard for me to face you
now. I am so sorry.
Sincerely, Tabitha F. Buck
(Commonwealth's Exhibit 65 (emphasis in original); N.T., PCRA 6678-82.)
The court is faced with an unusual and interesting credibility assessment with this
witness. She has acknowledged that she was less than completely truthful under
oath. It appears that on several points she told the truth but not the whole truth.
On other points, she made statements contrary to the truth. Yet, almost
immediately, she confessed these lies to her lawyer. (76) Ms. Buck was never called
as a witness in the federal proceeding, so it is likely that she may never have been
"caught" in her lies. Her lack of truthfulness did not help or hurt her own situation,
given that she is serving a life sentence for murder. To this end, it is unlikely that
fear of perjury charges would have motivated her to confess her lack of honesty to
her attorney. She is serving a life sentence without the possibility of parole, which
in Pennsylvania means exactly that. Possible perjury penalties would have little, if
any, real impact on her life.
Further, her decision not to tell the whole truth did not hurt Ms. Lambert. In fact,
Ms. Buck soft-pedaled certain facts regarding Ms. Lambert's involvement. Had
these "lies" been for a malicious purpose, i.e., to prejudice Ms. Lambert's petition in
federal court, they might carry greater weight. It appears that the "lies" were an
effort, however ignoble, to help her former co-defendant. She explained this as a
feeling of sympathy not so much for a former co-defendant but for a fellow "lifer."
Petitioner's counsel did a good and thorough job of exposing these various lies in
cross-examination of Ms. Buck. Petitioner would have us completely disregard Ms.
Buck's testimony on that basis. This is not the law, however. We frequently include
in our instructions to a jury in a criminal case the maxim "falsus in uno, falsus in
omnibus" which means "false in one, false in all." Essentially, this means that if a
witness deliberately testified falsely about a material point, the fact finder may
choose to disbelieve the rest of his or her testimony. But the fact finder is not
required to do so. The fact finder should consider all other factors bearing on the
witness's credibility in deciding whether to believe other parts of his or her
testimony. Commonwealth v. Parente, 184 Pa. Super. 125, 130-32, 133 A.2d
561, 563-64 (1957), aff'd, 392 Pa. 38, 139 A.2d 924 (1958). See Commonwealth
v. Tyler, 305 Pa. Super. 15, 23, 451 A.2d 218, 222 (1982); Commonwealth v.
Joyce, 202 Pa. Super. 350, 353 n.1, 197 A.2d 226, 228 n.1 (1963).
In evaluating credibility, the court looks to how the witness testifies, what the
witness says, what interest the witness has in the outcome of the proceeding and
the relationship of the witness to the petitioner/defendant or others involved in the
case. The court considers whether, in general, the witness's testimony makes
sense. We look not only at the witness herself, and her background and history in
the case, but also to extrinsic factors which impact on credibility. For example, it is
proper for the court to consider whether other evidence in the case supports the
testimony of the witness. If other evidence, including the testimony of other
witnesses and items of physical evidence, shows that the witness's testimony is
less than accurate, then these other items of evidence would have a negative
Page 457 of 2301
impact on credibility.
One very important factor is whether the witness is willing to falsify testimony so as
to further her own interests. This does not seem to be the case with Tabitha Buck.
At the PCRA hearing, we had the benefit of an exchange of letters between
petitioner's counsel and Ms. Buck regarding petitioner's intentions in the federal
habeas proceeding. Ms. Buck received a "solicitation" of sorts from petitioner's
counsel, Ms. Rainville. Ms. Rainville was writing to Ms. Buck with a request for
cooperation and a suggestion that she may wish to follow Ms. Lambert's path
through federal court with a federal habeas petition of her own. Ms. Buck replied,
also in writing, with certain statements that provide insight to her credibility and
which confirm certain statements she made in her testimony at the PCRA hearing.
For completeness sake, we include the text of each letter as it was read into the
record at the hearing. The letter from Ms. Rainville to Ms. Buck is dated November
15, 1996, and was admitted as Commonwealth's Exhibit 64. The letter reads:
Dear Ms. Buck,
My law firm has been appointed by the federal court in Philadelphia to represent
Lisa Lambert in the preparation of her federal habeas petition. I am writing to you
because I believe that we have discovered new evidence that may help you as well
as Lisa. We believe that the new evidence may prove that Butch Yunkin was
present, and participated in the murder. Since Mr. Yunkin was a key prosecution
witness against both you and Lisa, this new evidence may meet the standard set
forth in a relatively new Supreme Court case, Kyles v. Whitley, 115 S. Ct. 1555
(1995), which held that a retrial was warranted due to the prosecution's failure to
disclose evidence favorable to the defense regarding a key informant and
prosecution witness. Simply stated, while you will need your own lawyer to give
you guidance, our new evidence might be enough to get you a new trial.
You and Lisa are no longer friends, and I understand that there is a great deal of
bitterness between the two of you. Indeed, the two of you have many legal
interests that are in conflic t. However, we have information which may help you get
a new trial, and you have information which might help prove that Yunkin was
there. 1991 was a long time ago, and you and Lisa are now in a unique situation of
being able to help each other by telling the truth about Yunkin's real role in the
killing.
If you are currently represented by a lawyer, you should forward my letter to your
lawyer, and have your lawyer call me. If you are not represented by a lawyer, you
may call me collect at 215-751-2374. I hope that I will be hearing from you or your
lawyer soon.
Sincerely, Christina Rainville
(Commonwealth's Exhibit 64; N.T., PCRA at 6668-69.)
Ms. Buck's response is undated, but was written in response to Ms. Rainville's
letter. It was admitted into the record at the PCRA hearing as Commonwealth's
Exhibit 63. It reads as follows:
Page 458 of 2301
Dear Ms. Rainville:

In response to your letter dated November 15, 1996, I must say that whatever
'new evidence' you claim to have discovered is, in fact, untrue. I realize that your
law firm was appointed to Miss Lambert's case and you will do whatever you can in
defense of her. You would even place Mr. Yunkin at the scene of the crime and try
to pin the blame, so to speak, on him in an effort to help Michelle (Lisa). The truth
is, however, Mr. Yunkin was not there and he did not participate in the crime.
Michelle knows that fact as well as I do. I will not fabricate lies and corroborate
with Michelle just to get myself off easy. You see, contrary to popular belief, I do
not take other people's lives into my own hands. I don't know if Mr. Yunkin knew
what Michelle was planning to do but I do know he was not there and he did not kill
Laurie. I will not lie and cause him to have a life sentence for something he didn't
even do. I know exactly what being in that situation feels like. I have no
information that would help Michelle nor do I have any that would hurt Lawrence.
Ms. Rainville, if I'm to be granted a re-trial, it will not be based on circumstantial
evidence which I know to be untrue. I resent the assumption that I would
jeopardize someone else's life just to make my own a little easier. That is a
character flaw of your client, Ms. Lambert, and I am nothing like her. There is only
one truth. I know it. Michelle knows it. God knows it.
I will be of no assistance to you and Lisa Michelle Lambert.
Cordially, Tabitha F. Buck
(Commonwealth's Exhibit 63 (emphasis in original); N.T., PCRA at 6670-72.)
While we believe that Ms. Buck's decision to withhold portions of the truth in her
deposition testimony and in her discussions with Detective Geesey was
unfortunate, we do not think that this choice establishes that she is a wholly
untruthful person who is not worthy of belief in any way in this proceeding. In fact,
she relates aspects of the story which are consistent with other testimony in
evidence and which are consistent in general terms with her letter to Ms. Rainville
written prior to the deposition. There cannot be a justification for lying under oath
but there certainly can be explanations which bear on the overall credibility of the
person shown to be untruthful on certain points.
From Ms. Buck's testimony, we can conclude with certainty that Ms. Lambert is
anything but innocent of the charge of murder. Ms. Buck's testimony is consistent
with the observations made by Mr. Kleinhans, Mr. and Mrs. Fry, and with the
history of hatred and animus demonstrated by Ms. Lambert during the summer and
fall of 1991. The evidence as to Ms. Lambert's planning of the assault, Ms.
Lambert's and Ms. Buck's approach to the condominium, their escape, and their
activities the remainder of the day of December 20, 1991, is consistent with much
of the evidence both at trial and the PCRA.
In assessing Ms. Buck's credibility in the PCRA hearing, we carefully considered her
testimony in light of its inconsistency with her deposition. We have carefully
considered the fact that she was untruthful at points in her deposition and in her
discussions with Detective Geesey. We observed her as she testified and we noted
Page 459 of 2301
the substance of her responses and the manner in which she considered and
responded to questions. Unlike Ms. Lambert, Ms. Buck does not have an answer for
everything. She has acknowledged that there are certain facts which she cannot
reconcile, and she is candid about that which she does not remember. She was
forthcoming about her untruthful answers in her deposition and in her discussion
with Detective Geesey.
We firmly believe that Ms. Buck found herself in the middle of a vengeful
conspiracy. We do not doubt for a minute that she was aware that Ms. Lambert
intended to do harm to Laurie Show and that she went along for reasons that only
she knows. She is not an innocent. But to her credit, she acknowledges that fact.
Ms. Buck has nothing to gain by lying about Ms. Lambert's involvement in the
death of Laurie Show. In her testimony at the PCRA, she had the candor and the
decency to accept responsibility for her own role in the killing. She knows that she
blocked Laurie Show's path as Laurie tried to escape. She knows that she held
Laurie's legs down while Ms. Lambert cut her throat. In our close observation of Ms.
Buck as she testified and in our subsequent consideration of her testimony, we find
her to be credible in her description of the murder. She has acknowledged that she
deserves her sentence because of her actions on December 20, 1991. She has
acknowledged her guilt under oath in a courtroom in the same courthouse in which
her own PCRA petition is pending. What possible impact will this admission have on
her own PCRA claim that her trial resulted in a "fundamentally unfair" conviction?
Ms. Buck knows full well that, when she took the stand to acknowledge, under oath
in a courtroom, that she actively participated in the killing of Laurie Show, she
severely compromised any chance she has that a state or federal court will be
inclined to find that she has been wrongly convicted. Her testimony will not take a
day off her life sentence and will not change the events of December 20, 1991. We
find her credible in her description of what happened that morning.
In his statement to the police and in his testimony at trial, Lawrence Yunkin denied
involvement in the murder of Laurie Show. Ms. Lambert denied Mr. Yunkin's
involvement in her statement to Corporal Solt. In four months' of letters from
prison, she denied his involvement. At trial, Ms. Lambert implicated Mr. Yunkin in
the murder of Laurie Show. Much of petitioner's case in the PCRA hearing involves
evidence pointing to Mr. Yunkin's involvement, evidence as to his credibility,
evidence as to why Ms. Lambert might have "covered" for Mr. Yunkin, and an
attempt to discredit those facts which show that Mr. Yunkin was not involved.
In separate sections of this opinion we consider some of those issues. The "29
questions" go directly to Mr. Yunkin's involvement and this is discussed in Section
VII.B., supra. Kathleen Bayan's testimony would implicate Mr. Yunkin and is
discussed in Section VII.F, infra. Similarly, Hazel Show's testimony concerns Mr.
Yunkin's involvement and is considered in Section VII.G, infra. The issue of the
pearl earring contains allegations of after-discovered evidence and prosecutorial
misconduct and is considered in a separate section of this opinion, Section VII. N,
infra.
In this section, we address the remaining allegations pointing to Mr. Yunkin's
Page 460 of 2301
involvement. The first of these is the license plate found in the search of Mr.
Yunkin's car after his arrest. The license plate bears the number YHM-028. Two
characters of this license plate were identified by Kathleen Bayan to Detective
Savage in his interview of her in July 1992. Petitioner points to this evidence as
conclusive proof that Mr. Yunkin drove in the condominium complex that morning
with the YHM-028 license plate and later changed the license plate to evade the
authorities.
There is a problem with this line of reasoning. The police investigation at the time
the license plate was found in the Yunkin car revealed that YHM-028 was a plate
registered to Lawrence Yunkin. It was apparently a license plate which was on a
van previously owned by Mr. Yunkin. In any event, the police concluded at that
time that the license plate was of no evidentiary value. This court finds it unlikely
that Lawrence Yunkin would have "disguised" his vehicle by using another license
plate which was registered to him. We do not believe that the license plate found in
the Yunkin vehicle implicates Mr. Yunkin in the murder.
A second issue concerns 158 seconds of the audiotape of Mr. Yunkin's statement.
At the beginning of one side of the tape of a cassette used to record Mr. Yunkin's
statement is 158 seconds of narrative in a female voice. The narrative has nothing
to do with this case and appears to be an academic lecture of some kind. Did the
police mask an incriminating portion of Mr. Yunkin's statement by taking the
cassette to an academic lecture? That seems unlikely. More likely is that the
cassette used to record Mr. Yunkin's statement had been used by someone on a
prior occasion to record a speech. It seems likely that the police simply did not
rewind the tape completely. This lack of attention to detail on the part of Detective
Savage in preparing the tape recorder to record Mr. Yunkin's statement does not
prove anything.
The third issue is related to the tape recording of Mr. Yunkin's statement. Listening
to the tape, one can hear several "clicks," indicating that the tape was stopped, or
paused, and started again. District Justice Savage recalls that the taping was
interrupted so that Mr. Yunkin could confer with his attorney, Douglas Cody,
Esquire. This is confirmed by Mr. Cody. (N.T., PCRA at 6465.) There is a break near
the end, after Mr. Yunkin had been given an opportunity to review his typed
statement. At that point, he included several corrections. Petitioner contends that
the "breaks" or "clicks" indicate occasions when Mr. Yunkin was coached by the
police to state certain facts which would incriminate Ms. Lambert or to remove
certain statements exculpatory to Ms. Lambert.
This court found Mr. Cody's testimony on this subject to be credible and convincing.
Mr. Cody testified that the police did nothing improper in taking the statement and
that the recorder was not turned off for any improper reason. (N.T., PCRA at 6466.)
When asked whether the police officers did anything to coach his client, Mr. Cody
responded: "Absolutely not." (Id.) When asked if the police did anything to suggest
how Mr. Yunkin should answer or should not answer, Mr. Cody replied: "Not on one
question." (Id.) Mr. Cody also confirmed that he did not observe the police erase
anything on the tape. (N.T., PCRA at 6467.) Finally, Mr. Cody confirmed that the
transcript of the statement accurately reflected the statement given by Mr. Yunkin.
(Id.)
Based on the record from the PCRA hearing, we find beyond any doubt that there
Page 461 of 2301
was no misconduct in the taking or recording of Mr. Yunkin's statement.

A fourth issue regarding Mr. Yunkin's involvement concerns the alleged date rape of
Laurie Show. We should note that the only "proof" of the date rape came from
police reports of discussions with Hazel Show regarding her daughter's brief
relationship with Mr. Yunkin. Mr. Yunkin never acknowledged a "date rape," no
police report was filed and no investigation conducted. In fact, it appears that Ms.
Lambert is convinced that there was never any "date rape." A review of her many
letters to Mr. Yunkin from prison in which she characterized Laurie Show as a
"tramp," "slut," and "whore" would suggest that Ms. Lambert believed the brief
relationship between Mr. Yunkin and Laurie Show, if any, was consensual and not
the product of any force by Mr. Yunkin. The only possible relevance of this "date
rape" charge was Mr. Yunkin's purported fear that the incident would be
investigated by the police and that he would go to jail for rape. There appears to be
nothing more than speculation and surmise in support of this argument.
At best, it would support some animus by Mr. Yunkin or some motivation by Mr.
Yunkin to murder Laurie Show. We already know that Mr. Yunkin drove Ms.
Lambert and Ms. Buck to the condominium that morning, that he was aware they
had certain items with them which could be used in an assault on Laurie Show and
that he picked them up after this was over. We believe Mr. Yunkin was aware of
their plans. There is no doubt that Mr. Yunkin was involved in this conspiracy.
Could his fear of a date rape charge have motivated his participation in this
murderous conspiracy? Certainly. Does it establish that he was in the condominium
that morning committing the murder? It certainly does not.
The prosecution's failure to disclose the information supplied by Ms. Bayan in no
way violated the due process rights afforded by Brady and Pa. R. Crim. P. 305.
Kathleen Bayan contends that she spoke to Detective Savage in early July 1992. As
a result of that conversation, Ms. Bayan prepared a handwritten statement for
Detective Savage detailing the events of the morning of the murder. (Petitioner's
Exhibit 2008 at DA3037- DA3042.) According to her statement, she was pulling out
of her driveway in the Oak Condominium complex when she saw a late model
brown car speeding by. The driver was male and appeared to have light hair. The
front and back passengers were of an indeterminate sex and had dark clothing on.
Ms. Bayan stated that she could not see their faces clearly because of the distance
between the cars, because of the dirty car windows and because of a perceptual
disability that limits her span of focus. She did, however, note that the occupants of
the car were between the ages of 16 and 22.
Ms. Bayan told this to Detective Savage when he came to her condominium in July
1992 to inquire about the whereabouts of her son, Elliott, on the morning of the
murder. (N.T., PCRA at 4759-60, 4761.) Apparently, witnesses had observed a
number of young people at or around the school bus stop near the condominium
entrance and Elliott was one of those students who occasionally waited for the bus.
Kathleen Bayan related this story to Detective Savage after approximately one-half
hour of a discussion regarding herself, her son and her son's educational and
medical problems.
Page 462 of 2301
At the PCRA hearing, Ms. Bayan related t, hat on the morning of the murder, she
left her home between 7:10 and 7:15 a.m. for an appointment in Harrisburg. (N.T.,
PCRA at 4752.) As she started to pull out of her driveway, she saw a brown car
driving in an erratic manner on Black Oak Drive. She recalls seeing a man with long
curly blond hair wearing a baseball cap driving with a front female passenger and a
back female passenger. (N.T., PCRA at 4757.) He was driving very fast and was
swerving. (N.T., PCRA at 4758.) It appeared to her there was an argument going
on inside the car and that the driver was attempting to push down the heads of the
passengers. (N.T., PCRA at 4757-58.) Ms. Bayan clearly recalled seeing the face of
the girl in the backseat and identified her as Tabitha Buck. (N.T., PCRA at 4757,
4796-97.) She saw all this in a matter of seconds as they drove past her going 30
to 35 m.p.h. (N.T., PCRA at 4803.) She then followed them out of the condominium
complex, following several car lengths behind. (N.T., PCRA at 4802.)
1. Credibility
Kathleen Bayan observed a great deal of detail from her vantage point in her own
car while the car in question flashed past her. She indicated that there was an
argument going on and recalls the color of the car, the color of the driver's hair and
a description of the passengers. She offered no explanation for not coming forward
with that information between December 1991 and July 1992. This fact in and of
itself would not be fatal to her credibility but it does raise a question. She had
ample opportunity to read newspapers, become acquainted with the facts of the
case and come to know the details of the description of the participants long before
July 1992.
In addition, she did not immediately tell Detective Savage of her observations. Only
after she had a lengthy discussion of other personal issues, did she offer her
observation of what she had seen.
It is appropriate for the PCRA court to consider the credibility of a witness to
determine if the after-discovered witness's testimony is reliable. Bonaccurso, 425
Pa. Super. at 490, 625 A.2d at 1202 (Beck, J., concurring). Ms. Bayan's credibility
was somewhat diminished in her testimony in the PCRA proceeding by her
responses to questions on cross-examination. She acknowledged that she has a
visual handicap. This handicap affects her ability to perceive objects other than that
specific object on which she focuses. That is, as Ms. Bayan explained, if she looks
at one object, she cannot see the details of anything else surrounding that finite
discreet item. This suggests that perhaps if Ms. Bayan was looking at the long curly
hair of the driver of the brown car, perhaps she was unable to see the occupants.
Or, if she was observing the make and color of the car, perhaps she was unable,
due to her handicap, to see the occupants.
Ms. Bayan testified in this proceeding by way of teleconference from Pensacola,
Florida. She had represented to the court and counsel in a telephone conference at
the beginning of the proceeding that she was unable to travel to Pennsylvania
because she is the sole support and transportation for a handicapped fianc.
Because of this sympathetic concern, the court made arrangements for Ms. Bayan
to testify by way of video conference. She testified from a public broadcasting
studio in Pensacola and her testimony was observed and questions posed to her
from the WGAL television studio in Lancaster, Pennsylvania. These arrangements
were made because the credibility of Ms. Bayan is a crucial part of this hearing and
Page 463 of 2301
because credibility can best be assessed by a face-to-face observation of a witness

as the witness is telling her story and responding to questions.
There are two important credibility points regarding Ms. Bayan's testimony. First,
by the court's observation of her as she testified, she appeared less than
completely credible as she answered the questions. The court is not surprised that
Detective Savage, upon his interview with her in July 1992, found there to be
problems with her credibility.
The second and more important issue as to Ms. Bayan's credibility has to do with
the contention that she was unable to travel to Pennsylvania. As we learned later in
the hearing, Ms. Bayan has an active warrant for her arrest in the offices of District
Justice Savage, formerly Detective Savage.(77) This warrant arises out of her failure
to pay certain county tax obligations while she was a resident of Lancaster County.
(N.T., PCRA at 6327-28.) We also note that she was the defendant in a lawsuit by
her condominium association and the judgment was satisfied by a sheriff's
execution sale of her furniture, presumably left behind at the condominium. (N.T.,
PCRA at 6329-30.) Ms. Bayan was sued twice before, by the taxing authority,
permitted the obligations to go to judgment, and satisfied the prior two obligations
upon the issuance of warrants. (N.T., PCRA at 6325-26, 6329-30.)
It is reasonable to infer that she was aware that a warrant had issued or would
issue for her given her past history with the local taxing authority. One is left to
wonder whether Ms. Bayan's reluctance to come to the jurisdiction was truly the
result of her life situation or rather whether the existence of an active warrant in
Lancaster County played some role. Even giving Ms. Bayan the benefit of the
doubt, this fact does impugn her credibility.
In Pennsylvania, it is mandatory for the Commonwealth to disclose evidence which
is favorable to the accused and which is material to either guilt or punishment. Pa.
R. Crim. P., Rule 305 (B)(1), 42 Pa. C.S.A. The comment to Rule 305 indicates that
the rule is intended to apply the constitutional guarantees which Brady commands.
Absent a specific request by the defendant for exculpatory evidence, a prosecutor
has a duty to make evidence available to the defense that is truly exculpatory
rather than merely favorable.(78)
The Supreme Court of Pennsylvania has defined Brady violations as: (1) the failure
to disclose , an agreement between the C, ommonwealt, h and a witness,
Commonwealth v. Moose, 529 Pa. 218, 602 A.2d 1265 (1992); (2) the failure to
disclose out-of-court statements by an accomplice claiming responsibility for the
murder, Commonwealth v. Green, 536 Pa. 599, 640 A.2d 1242 (1994); and (3)
the pretrial failure of the Commonwealth to disclose evidence proving bias of a
defense witness, Commonwealth v. Ulen, 539 Pa. 51, 650 A.2d 416 (1994).
In contrast, the Pennsylvania Supreme Court has held that where the prosecution
did not reveal statements by its witness that he saw someone other than the
defendant in possession of the murder weapon several weeks after the murders,
such evidence was not exculpatory and, thus, lacked materiality. Buehl, 540 Pa. at
Page 464 of 2301
504, 658 A.2d at 776. Likewise, a prosecution's failure to disclose an alleged

agreement with one guilt-phase witness was not a Brady violation entitling the
defendant to a new trial. Commonwealth v. Morales, 549 Pa. 400, 701 A.2d 516
(1997).
A central issue in this case is whether Kathleen Bayan's disclosure to Detective
Savage in July 1992 should have been disclosed to Attorney Shirk. Mr. Kenneff was
aware of the Bayan disclosure and was aware that Detective Savage had obtained
this information from her just prior to the start of the trial. At that time, Ms.
Lambert had related her story to Corporal Solt. Her story, as set forth in the "Solt
Statement," was that she and Ms. Buck left the Show condominium, proceeded
across the condominium complex, across a lawn, down a gully, through some
bushes and across a field to Oak View Road. (See Section VII.L, infra.) There, on
Oak View Road, they were picked up by Lawrence Yunkin. As of early July 1992,
the only "story" the Commonwealth knew from Ms. Lambert was that she fled on
foot from the Show condominium to Oak View Road. She was not contending that
Mr. Yunkin was in the complex, that the two young women entered the car in the
condominium complex, or that they entered the condominium complex and drove
around for any purpose.
The district attorney's discovery obligation under Rule 305 and under Brady was to
disclose information to the defense which would be material and exculpatory. As of
the start of trial, the disclosure by Kathleen Bayan was neither material nor
exculpatory to defendant. In fact, all Ms. Bayan's disclosure accomplished was to
place Mr. Yunkin in the condominium complex. This may have been inculpatory for
Mr. Yunkin, but not exculpatory for Ms. Lambert.
Mr. Kenneff evaluated his discovery obligation and chose to communicate with Mr.
Shirk regarding Ms. Lambert's position. He did so in a letter asking simply whether
Ms. Lambert still asserted that Mr. Yunkin picked her up on Oak View Road.
(Petitioner's Exhibit 1764.) Mr. Shirk responded to Mr. Kenneff that this was her
contention.
Under these facts and under Rule 305 and Brady, Mr. Kenneff had no obligation to
disclose the Bayan statement to Mr. Shirk. Examine for a moment what possible
basis there would be for the disclosure. Given Ms. Lambert's statement to Corporal
Solt, providing the Bayan disclosure to Ms. Lambert would give her a reason to
change or modify her story. Giving a criminal defendant an opportunity to revise
her story is not a basis for requiring disclosure in discovery.
Should the Commonwealth have anticipated that Ms. Lambert would dramatically
change her story during the course of the trial? Discovery under either Rule 305 or
Brady does not require that the prosecution employ a crystal ball. Now, in
hindsight, we know that Ms. Lambert changed her story at trial and placed Mr.
Yunkin in the condominium complex. This story was told after the Commonwealth
rested its case and during the defense case-in-chief.
The question then became whether Mr. Kenneff had an affirmative obligation to
provide information about the Bayan statement to the defense once Ms. Lambert
told a new version of her story during trial. The Commonwealth's contention was
that Ms. Lambert was lying at trial. Her statement of December 21, 1991, was the
most credible version of the facts because she gave that statement before she
Page 465 of 2301
understood the legal ramifications to her of placing herself in the condominium. She
had every reason to change her story at trial and the Commonwealth's argument
that the story at trial was a fabrication had considerable merit.
Mr. Kenneff did the responsible thing by confirming with Mr. Shirk what Ms.
Lambert's story was going to be. Mr. Shirk replied that Ms. Lambert contended that
she was picked up on Oak View Road. There is nothing unusual about one party
weighing its obligations under the rules and making choices under those rules as to
what must be disclosed. This is the essence of the adversarial process and Mr.
Kenneff did nothing more than evaluate his own obligations under the rules of
discovery. His choice, upon confirmation of the story by Mr. Shirk, to not disclose
the Bayan statement was proper.
When Ms. Lambert changed her story at trial, Mr. Kenneff's obligation was the
same: to disclose evidence that was exculpatory. Ms. Bayan's statement was not
exculpatory merely because Ms. Lambert calls it exculpatory. It is true that Ms.
Bayan's statement, if credible, would support some part of Ms. Lambert's trial
testimony. Ms. Bayan's statement would support only Ms. Lambert's description of
how she fled that morning. Yet, Ms. Lambert's own testimony put her in flight from
the condominium after participating in an assault which led to a murder. Her trial
testimony established that she was deeply involved in the conspiracy and the
murder. Ms. Bayan's statement might have been inculpatory to Mr. Yunkin but not
exculpatory to Ms. Lambert.
Exculpatory evidence is evidence which extrinsically tends to establish a
defendant's innocence. Hudgens, 400 Pa. Super. at 97-98, 582 A.2d at 1361. Ms.
Bayan's story does nothing to establish Ms. Lambert's innocence. Evidence that Ms.
Lambert was seen fleeing the scene of a murder in the company of two people
whom she identified at trial as the murderers would not "extrinsically tend to
establish" her innocence. The Kathleen Bayan story is, simply stated, not
exculpatory as to Ms. Lambert. At best, Ms. Bayan's story would tend to support
the version Ms. Lambert told at trial and would thereby "shade" her level of
culpability for the murder. Yet, by her own admission of going with Ms. Buck to the
condominium that morning, of planning an assault on Laurie Show and of
participating at some level in the assault which led to Laurie Show's death, she
would still be guilty of first degree murder. The information would, therefore, not
be "material" for Brady/Giglio purposes or for compliance with Pa. R. Crim. P. 305
in that the information would not have changed the outcome of the trial.
The ultimate question is whether the failure to disclose the Bayan statement so
undermined the truth-determining process that no reliable verdict was possible.
This court finds that even if Ms. Bayan had testified at trial, even if Ms. Lambert
had the support of Ms. Bayan for her revised story that Mr. Yunkin was in the
complex, the verdict would have been the same.
We did not find Kathleen Bayan credible at the PCRA hearing. We find that Ms.
Lambert's statement to Corporal Solt of how she fled, Ms. Buck's testimony about
how they fled together, Mr. Kleinhans's testimony about seeing two hooded figures
of about the same size heading away from the condominium, and the observations
Page 466 of 2301
of Mr. and Mrs. Fry, to be convincing and credible on this point. Because it is
contrary to overwhelming credible evidence, her story would have had no impact.
Even if we were to find that the failure to disclose Ms. Bayan's statement was a
constitutional violation, it did not so undermine the truth-determining process that
no reliable adjudication of guilt or innocence could have taken place.
In fact, petitioner's contention that Ms. Bayan saw Ms. Lambert, Ms. Buck and Mr.
Yunkin in the complex that morning cannot be reconciled with petitioner's
contention that Mrs. Show saw them as well. Ms. Lambert would have this court
believe that Mrs. Show left the school at 7:25 a.m., per Ms. Berry. Testimony has
shown that the trip from the school to the complex takes approximately ten
minutes. If Mrs. Show saw the three that morning, it would have been around 7:35
a.m. Yet, Ms. Bayan testified that she saw them as she left for Harrisburg between
7:10 a.m. and 7:15 a.m. This internal inconsistency in petitioner's case lends
further support to our finding that Ms. Bayan's testimony would not have changed
the outcome of the trial. Nor does it have any impact on the reliability of the
verdict.

Mrs. Show testified at the PCRA hearing that she saw a car on the morning of
December 20, 1991, that she now believes may have been Mr. Yunkin's car. She
testified in response to questions by petitioner's counsel:
Q. Mrs. Show, on the morning of December 20th, 1991, when you drove back into
the condominium complex, what, if anything, did you see driving out of the
condominium complex?
A. Remembering in 1991, I did not remember anything. Until 1997 I had a memory
of seeing Yunkin in a car.
Q. Can you tell us what you remember today of seeing Yunkin in the car?
A. I remember coming in the entrance. I don't know approximately where. But it
had to be in a break between the trees and the shrubbery, looking over to my left,
and seeing Lawrence's face. At that time not even realizing who it was, that it was
just a man with blond hair. But he's looking at me with a startled, surprised look on
his face, seeing him push someone down in the front seat with blond hair and
seeing someone with dark hair in the back seat. But I don't recall seeing the car.
Q. Do you recall what color the car is?
A. It's just a brownish color.
(N.T., PCRA at 5635-36.)
Mrs. Show was then asked if she had ever discussed the possibility that she saw
this car with Detective Savage:
Page 467 of 2301
Q. Okay. Back in 1991, 1992, did you have any discussions with anyone about it?
A. No.
Q. Did you discuss with Detective Savage at all the fact that you'd seen a brown
car?
A. What I told Detective Savage, he had told me a neighbor lady mentioned that
she had seen a brown car leaving our complex.
When he said that, I saw a flash of a brownish color and I said to him, a brownish
color? And then we went over this, had I seen a car? I wasn't sure. Where was it? I
wasn't sure. What type of car? Was anyone in it? And I had nothing in my memory
except when he said this brown color, I just saw a flash of a brown car. Not even
knowing that it was a car or anything and I tried to jog my memory to get more
information but there wasn't anything there.
And I started to become upset about this because it was important because this
neighbor lady was saying there were three people in the car. But nothing was
there. I couldn't remember anything and he told me that I was getting upset and
he told me not to worry about it, if something came back, we'd go from that point.
But nothing ever came back and I was to testify in a couple of days and I just
forget [sic] all about it.
Q. When did you have this discussion with Detective Savage?
A. It was probably a couple days before the trial.
Q. Before Ms. Lambert's trial?
A. Yes.
(N.T., PCRA at 5642-43.)(79)
Her chief recollection is that the car was coming toward her and there was nothing
impeding her view of the car. She recalls that she had to drive a distance after she
saw the car. It is possible that she saw the car out on Oak View Road. (N.T., PCRA
at 5648.) She thinks it was around 7:20 a.m. when she was coming back from the
school. (N.T., PCRA at 5649.)
Mrs. Show testified at the PCRA hearing that Detective Savage told her "not to
worry about it." Petitioner's counsel referred Mrs. Show to her federal testimony
and asked the following questions:
Q. Do you remember testifying in federal court that Detective Savage told you not
to dwell on it?
Q. Do you remember testifying to that?
A. I think I've said that here. That he said, you know, not to worry about it, not to
Page 468 of 2301
get upset about it or dwell on it because as far as what I had to testify to, I was
saying what I remembered and something that I had no memory about there
wasn't much I could do about it. So don't get upset about it.
(N.T., PCRA at 5644-45.)
This revelation by Mrs. Show, long after the 1992 trial, presents several issues.
First, does this testimony establish that she saw the Yunkin car? Second, was
Detective Savage's instruction to her "not to worry about it" a form of misconduct?
Third, is the information about the car after-discovered evidence entitling Ms.
Lambert to relief?
First, Mrs. Show did not say at the PCRA hearing that she remembered a car in
1992. She recalled a brownish flash and was not sure it was a car. She did not
recall a car until she was sitting in a federal courtroom in 1997 listening to District
Justice Savage. At most, this testimony, had it been presented in 1992, would
buttress the testimony of Ms. Bayan that a brown car was seen leaving the
condominium complex. The problem is that Mrs. Show cannot conclusively put the
car inside the condominium complex. She cannot rule out the possibility that she
saw the car out on Oak View Road.
Second, as to the misconduct question, it appears from Mrs. Show's testimony that
she was not reasonably certain of any detail in 1992. From her own description, she
was becoming very upset because she thought she was failing to recall important
information which would help the police. It was in this context that Detective
Savage told her not to worry. At that time, the police had the testimony of the
Kleinhanses and the Frys who put Ms. Lambert and Ms. Buck fleeing together
across the fields toward Oak View Road. Ms. Lambert and Mr. Yunkin had both told
the police in their statements that the pick up was on Oak View Road. The only
information to disclose is that Mrs. Show had an "image" of a brownish flash as she
approached or entered the complex that morning. It does not seem that there was
really anything to disclose. Detective Savage's comment "not to worry about it" in
the circumstances does not appear to be a directive to "bury" exculpatory evidence.
Third, is this after-discovered evidence? It certainly was unavailable at the trial, so
the first prong is met. We turn then to the question of whether the information is
"exculpatory." At best, it corroborates the story told by Ms. Lambert at trial and
undermines the story told by Ms. Lambert to Corporal Solt. It would tend to show
that Ms. Lambert was being untruthful with the police when she gave her
statement. Given the paucity of detail in the story, it is entirely likely that the
recollection would have been given little weight. It was certainly not exculpatory in
the sense that it established that Ms. Lambert was fleeing the scene of a murder.
Given the fact that she planned the activities of that morning, given the fact that
she participated in the assault on Laurie Show that morning and given the fact that,
at trial, she was placing responsibility for the murder on Mr. Yunkin and Ms. Buck,
the fact that she was seen in a car in their company fleeing the complex does not
sound too exculpatory. The only significance of this "recollection" of Mr. Yunkin's
car would be to place Mr. Yunkin at the scene. But evidence inculpatory to Mr.
Yunkin is not exculpatory to Ms. Lambert. If Mr. Yunkin and Ms. Lambert are fleeing
the scene of a murder arising out of an assault which Ms. Lambert "started" and
Page 469 of 2301
Mr. Yunkin "finished," the fact that she is seen in his car is hardly exculpatory.
It is unlikely that this information would have changed the outcome of the trial.
Even if entirely believed and even if it was found to support Ms. Lambert's story
that Mr. Yunkin was inside the condominium complex and that she was in the car
with him, this does not exculpate Ms. Lambert. It might lend more support to an
argument that Mr. Yunkin was somehow involved, which does not exclude Ms.
Lambert's involvement. Under the best story put forth by Ms. Lambert, she was in
the condominium and participated in the acts which led to the death of Laurie
Show. She claims she left and Mr. Yunkin went in. We never believed that story.
The fact that Mrs. Show remembered something that may buttress one fact of a
story we found to be incredible does not suggest that the story became any more
credible. It would not have made a difference in the outcome of the trial.

Shortly before trial, Mr. Shirk informed Mr. Kenneff that Dr. Mihalakis, a forensic
pathologist, would be testifying for the defense. In April 1992, Dr. Mihalakis had
entered into a contract with the County of Lancaster to perform forensic pathology
services in criminal cases. Over the weekend before trial, Mr. Kenneff placed a
telephone call to Dr. Mihalakis to express his concern about the doctor's choice to
testify for the defense.
The issues regarding the involvement of Dr. Mihalakis were raised at trial and in
post verdict motions, and considered by this court in its opinion of July 19, 1994.
Nevertheless, petitioner has included this issue in her case. The Commonwealth
argues that this issue has been previously litigated and, therefore, waived. Because
petitioner raised a claim of after-discovered evidence and "witness tampering" with
respect to Dr. Mihalakis, we will address the issue in this opinion. We note further
that the federal district court featured this issue in its discussion of the federal
habeas petition.(80)
The issues raised in the PCRA petition are:
(1) Dr. Mihalakis's income from Lancaster County increased 400 percent the year
after the Lambert trial (1993) and then dropped to nothing, (Exhibit A, Section A at
para. 17);
(2) Mr. Kenneff discussed with Dr. Mihalakis his proposed testimony and crossexamination questions and that Dr. Mihalakis did not want Mr. Kenneff to be upset
with him and offered to withdraw, thus Dr. Mihalakis changed his testimony to help
the prosecution, (Exhibit A, Section A at para. 18); and
(3) Mr. Kenneff's unauthorized, pretrial ex parte contact with a defense expert, Dr.
Mihalakis, (Exhibit A, Section B(4) at para. 30).
In 1994, in response to Ms. Lambert's long delayed post verdict motions and briefs,
we considered this issue in an opinion. At that time, we stated:
During the trial, a lengthy conference was held in chambers regarding the possible
Page 470 of 2301
testimony of Dr. Isidore Mihalakis. Dr. Mihalakis is a forensic pathologist who was
called by the defense to testify as to the wounds inflic ted on the neck of the victim.
This expert was going to explain the difficulty, or impossibility, of a person
speaking with these wounds. The point of this testimony was to rebut the
Commonwealth's evidence that the victim identified her killer just before she died.
Prior to the testimony of Dr. Mihalakis, counsel for the defense submitted a motion
for sanctions to the court on the basis that the assistant district attorney had
contacted Dr. Mihalakis in advance of his testimony. Defendant argued that the
assistant district attorney attempted to intimidate or coerce Dr. Mihalakis.
The court held a hearing on this motion in chambers with the assistant district
attorney, the district attorney, defense counsel, defendant's private investigator
and Dr. Mihalakis all present. . . .
Essentially, Dr. Mihalakis was under a consulting contract with the Lancaster
County District Attorney's Office. The assistant district attorney, Mr. Kenneff,
indicated his surprise and concern when it was learned that Dr. Mihalakis would
appear as a defense witness. Mr. Kenneff was concerned as to his ability to crossexamine a witness whom he has retained for testimony in other cases. He placed a
call to Dr. Mihalakis and raised this concern and also discussed with him, in general
terms, his anticipated trial testimony.
The court specifically addressed Dr. Mihalakis at the hearing in chambers. The court
questioned Dr. Mihalakis on whether he felt intimidated, coerced or in any way
threatened by Mr. Kenneff's call. Dr. Mihalakis emphatically stated he did not. In
fact, Dr. Mihalakis had issued a report and indicated, in chambers, that it was his
intention to testify consistent with that report.
Nothing about the testimony of Dr. Mihalakis in the hearing in chambers nor
anything about Dr. Mihalakis's testimony during the trial indicates that there were
any threats, intimidation or coercion. The court found defendant's motion for
sanctions to be without any basis in law or in fact and properly denied the motion.
At trial in 1992, Dr. Mihalakis testified as to the cause of death. He agreed with Dr.
Penades that, essentially, Laurie Show bled to death. He stated that asphyxiation
due to breathing in blood was a contributing factor. His first opinion was as to
cause of death and the length of time it would have taken the victim to die. He
testified:
A. To bleed to death, it would take multiple minutes. There are a lot of variables;
however, I think it would definitely be considerably less than a half hour.
Q. Somewhere between multiple minutes and considerably less than a half hour?
A. Right.
(N.T., Trial at 341.) He was asked how long it would take for Laurie Show to lose
consciousness. He stated: "Unconsciousness would have to be minutes. It would
Page 471 of 2301
not have to be a huge number of minutes but it wouldn't be that terribly quickly
also." (N.T., Trial at 342.)
Dr. Mihalakis was then asked by defense counsel about Laurie Show's ability to
speak. He noted damage to the tongue muscle and to the structures in the neck.
He gave the following testimony:
Q. What would be the effect of that loss of dexterity to the central portions of the
tongue?
A. The loss of the dexterity would be those words that have a tongue related
sound; may be somewhat slurred and less intelligible.
Q. And a tongue related sound as you described it would be, for the record and for
the Court, what kind of a sound might that be?
A. A sa, da, ja, ka, yul.
(N.T., Trial at 344.) Dr. Mihalakis further testified:
Q. There may be testimony presented at a later date in this trial that the decedent
might've possibly said, Michelle did it. Are the sounds in that phrase, would they be
affected by the damage to the muscles in the center of the tongue, affecting the
tongue and speech, would that have affected the ability to speak that phrase?
A. It would have to be affected in part. Ma is predominately a lip sound, and the

tongue and lips are controlled by a different set of nerves so the ma sound should
not've been affected. If it was affected it was to a minor degree.
The chael may have been somewhat less clear and the da may have been
somewhat less clear.
(N.T., Trial at 344-45.)
On cross-examination at trial, Dr. Mihalakis affirmed this testimony:
Q. Moving on to the issue to the injuries to the neck and the effect on the ability to
speak. As I understand your testimony, you feel that the ability of Laurie Show to
speak as a result of the injuries that she suffered would be compromised but not
eliminated.
A. That is correct.
(N.T., Trial at 357.)
There was absolutely nothing about this testimony which was in any way
inconsistent with Dr. Mihalakis's report to defense counsel of June 29, 1992. This
report was prepared before Mr. Shirk informed Mr. Kenneff that Dr. Mihalakis would
be testifying and before Mr. Kenneff had any contact with Dr. Mihalakis. In the
Page 472 of 2301
report of June 29, 1992, Dr. Mihalakis addresses a question put to him by defense
counsel's investigator:
Question 3: Could Laurie Show say anything afterward; could she have said,
'Michelle did it'?
Answer: The wound track of the neck wounds described by Dr. Penades involves
cutting of a major portion of the base of the tongue except for possibly the pillars
on each side. Such a cut would certainly limit but not totally eliminate phonation
especially words and letters that involve the tongue. M is a letter that is primarily
phonated by the lips. If the head is down and air can pass from the windpipe to the
mouth M could certainly be enunciated. 'Chelle' are somewhat more difficult to
enunciate and 'did' it very much tongue dependent so that would be very difficult to
enunciate but not totally impossible depending on how much tongue muscle was
left. We are told by Dr. Penades that literally one could look at her throat and see
the vertebral column. However, we are not told about the sides of the tongue.
The other factors that must be taken into consideration are the recurrent laryngeal
nerves. If one such nerve is cut, it causes a hoarse voice, and if both are cut, the
cords assume a midline neutral position, and at best, the only sound that can be
made is a 'breathy' type sound but hardly any intelligible speech. Neither Dr.
Penades nor his consulting otolaryngologist, Dr. Joseph S. Annese, address the
status of the recurrent laryngeal nerves. In spite of this shortcoming I believe that
these nerves were not cut because they are tucked in such a location that to
selectively injure them without cutting the carotids and deep jugular vessels is
essentially impossible. Thus, for all intents and purposes, you have to consider
phonation based on the injury to the tongue.
At the colloquy in chambers on July 10, 1992, Dr. Mihalakis acknowledged that he
had been contacted by Mr. Kenneff. He testified that he did not feel intimidated or
coerced by Mr. Kenneff. He stated clearly, unequivocally, and emphatically that he
would testify at trial consistent with his June 29, 1992, report. Dr. Mihalakis is a
medical professional of considerable stature in his field and in his community. When
he said that he would testify to the opinions expressed in his letter, he was
completely credible. And, in fact, his testimony at trial bore out this representation.
During the colloquy in chambers on Friday, July 10, 1992, Mr. Kenneff asked Mr.
Shirk to "address what chilling effect the phone call has had on his ability to
present his defense." Mr. Shirk's response demonstrates that, upon talking further
with Dr. Mihalakis, he did not believe the phone call would make any difference in
Dr. Mihalakis's testimony:
I asked Doctor Mihalakis, I indicated to him I never met him. I never met him, I
don't know him, and I asked him quite frankly if this would affect his testimony in
any way, shape or form. I think the exact word I used was whether he would pull
his punches. He indicated to me he would not.
I indicated, you know, it was very important because, you know, I don't want to
find out on the stand Friday and he indicated that in no way, in any way would it
Page 473 of 2301
affect his testimony Friday. I can honestly say to you at this point there is no way it
has a chilling effect. He hadn't been on the stand. I think he's an honorable enough
man that it will not have a chilling effect.
TH E COURT: What's the problem?
MR. SHIRK: I think there is a problem in the call being made in the first place. Your
Honor, I'm going to say right here on the record, I think Mr. Kenneff's phone call
was probably the result of blowing off some steam. I'm not going to accuse him of
having any ulterior motive.
(N.T., Trial at 323-24.)
Mr. Shirk and Mr. Kenneff had a discussion about coming in to see the judge on
Monday, the first day of trial to address the Mihalakis issue. It was going to be Mr.
Kenneff's intention to ask the court to direct Mr. Shirk away from questions about
Dr. Mihalakis's contract with the County. Mr. Kenneff alluded to this fact, among
others, in responding to Mr. Shirk.
With regard to what would happen on Monday, I did frankly discuss with Doctor
Mihalakis the problem that I saw of the defense being able to put him up on the
stand and say to him, isn't it true you are testifying for Mr. Kenneff a couple
months down the road? I could not possibly, once that type of question was asked
in front of a jury, do anything with his testimony no matter how damaging it was.
And about a contract. I said I was going to address the matter with the Court. What
my thinking on it was, those questions, even though they are time and again asked
of expert witnesses, are irrelevant. I was going to come in here and tell the Court
that we would not object as long as the Court rules that questions of that nature
were irrelevant.
We came in here Monday and found there was no need for that because there
wasn't a jury. A particular judge with a background such as yours knows exactly
what the story is with these guys and for that reason I didn't pursue the matter any
further, and for that reason I'm not concerned whatsoever about Doctor Mihalakis
testifying in this case.
Finally, it would be stupid for me to threaten the doctor when I have to use him a
few months down the line in a case just as important as this case.
(N.T., Trial at 326-27.)
The court then had an opportunity to question Dr. Mihalakis:
THE COURT: All right. No one made a request of you that you withdraw, did they?
DR. MIHALAKI S: No, no, they did not. In fact we kind of -- actually it was more
joking than anything with Mr. Kenneff. What do we do with you now that you are a
consultant? And then in fact I offered, I said look, I won't mention it when it comes
to mentioning my credentials.
Page 474 of 2301
THE COURT: You are a forensic pathologist by training and background?

DR. MIHALAKIS: That's correct.
THE COURT: And probably today is not the first time you've testified in a criminal
case.
DR. MIHALAKIS: No, it is not.
THE COURT: And you've done your examination and you have your opinions that
you are going to state as part of this case, I take it.
DR. MIHALAKIS: Yes. I have a consultative letter.
THE COURT: What is the date of that letter? About when was it written to him?
DR. MIHALAKIS: (Looking at a document ..) June 29.
THE COURT: All right. And I take it that your testimony would be consistent with
that consultative letter.
DR. MIHALAKIS: I would hope so, yes.
THE COURT: Okay. Is there anything about the discussion you had with Mr. Kenneff
that causes you to not say what was in that letter?
DR. MIHALAKIS: No, I don't believe so.
THE COURT: Did you feel threatened or intimidated or coerced by that discussion
you had with Mr. Kenneff?
DR. MIHALAKIS: No, sir, I did not.
THE COURT: Okay.
Mr. Shirk, are you aware of any rule of professional conduct that prevents an
attorney in a criminal case from contacting an expert of a witness who would testify
for the other side?
MR. SHIRK: No, I'm not.
(N.T., Trial at 328-30.)
The problem was that Dr. Mihalakis did not give the testimony that Mr. Shirk had in
mind. Mr. Shirk testified in this PCRA hearing that he was aware of the report and
did not think the report was very helpful. In fact, Mr. Shirk testified that he told Dr.
Mihalakis that the report wasn't going to "help us a lot." (N.T., PCRA at 3440.) After
a discussion with Dr. Mihalakis about the report, Mr. Shirk seemed to think that Dr.
Mihalakis could be possibly more helpful in court than he was in his letter.
However, Mr. Shirk testified that Dr. Mihalakis "indicated to me at all times that he
Page 475 of 2301
would not be able to say, to a degree of medical certainty, that Laurie Show could
not talk." (Id.) Mr. Shirk was aware that Dr. Mihalakis believed she did not speak
and Dr. Mihalakis gave Mr. Shirk his reasons. (N.T., PCRA at 3440-41.) Mr. Shirk
believes that Dr. Mihalakis "modified" his opinion in a telephone conversation.
(N.T., PCRA at 3441.)
In fact, Messrs. Shirk, Goldberg and Mihalakis had a meeting at a local restaurant
just prior to Dr. Mihalakis's testimony. There is no doubt that they knew what Dr.
Mihalakis was going to say on the witness stand. In fact, in this PCRA hearing, Dr.
Mihalakis testified that there was "no doubt in my mind that Mr. Shirk knew very
much what I was going to say." (N.T, PCRA at 2542.)
The only "new" evidence presented at the PCRA hearing had to do with Dr.
Mihalakis's income from the county. Dr. Mihalakis testified that his income from
Lancaster County increased because there was an increase in murder cases in
Lancaster County. He performed a number of autopsies in 1992 and these cases
came to trial in 1993. He did 16 autopsies for Lancaster County in 1993. It is clear
that his compensation increased because there was an increase in homicide cases
in Lancaster County in 1992 and 1993.
To take the fact of increased compensation out of context and attach some sinister
significance to this is misleading.(81) As testimony established, Lancaster County
was in a period of transition in 1992 in terms of handling murder cases. Dr.
Penades, who had been the county pathologist for years, was in the process of
retiring. The district attorney entered into a contract with Dr. Mihalakis dated April
8, 1992, for consulting services involving forensic pathological examinations,
assistance in criminal investigation, training, and expert testimony at preliminary
hearings and trials. (Petitioner's Exhibit 2087.) Pursuant to this agreement, Dr.
Mihala kis performed autopsies in 1992 and 1993. He also testified in several major
cases in 1993. His income began to trail off after 1993 because of the involvement
of Dr. Ross, a forensic pathologist who took over these responsibilities in Lancaster
County on a full-time basis in 1994.
According to the testimony of Mr. Kenneff and Mr. Madenspacher, both of whom
were uncontradicted on this point, there was a significant increase in homicide
cases in their office in 1992 and 1993. Unlike the major metropolitan centers, the
number of homicide cases in Lancaster County each year is relatively low. In a year
where there is a significant increase, there is a significant strain on the system and
a significant increase in the need for, among other things, expert testimony from a
forensic pathologist. When given more than superficial consideration, the increase
in compensation does not even come close to the kind of "payola" pronounced by
petitioner's counsel. (82)
The second allegation of after-discovered evidence by Ms. Lambert basically
involves Mr. Kenneff's conversation with Dr. Mihalakis and this has been fully
considered in the 1994 opinion and in the discussion above.
The third allegation of wrongdoing involving Dr. Mihalakis is a claim of "witness
tampering or retaliation." In essence, the federal district court disagreed with this
court's finding that there was no prejudice to defendant by the conversation
between Mr. Kenneff and Dr. Mihalakis. The federal district court attached greater
significance to this issue than did the state court without the benefit of any
Page 476 of 2301
additional relevant evidence.

In 1992 during a colloquy in chambers, and again in considering post verdict
motions in 1994, we carefully considered whether the behavior of Mr. Kenneff was
unethical under the Rules of Professional Responsibility. Clearly, Mr. Kenneff should
not have contacted Dr. Mihalakis and, in hindsight, all would agree with this. Did it
violate any stated canon of professional responsibility? The answer to that is no. In
fact, counsel for the defense was asked that specific question during the colloquy
and was unable to point to any violation of the Rules of Professional
Responsibility.(83)
This was more than simply an advocate contacting his opponent's expert witness.
In fact, Mr. Kenneff and Dr. Mihalakis were involved in a contractual relationship
that was in existence for only three months at the time of the trial. This expert was
"sprung" on the Commonwealth just before trial in that Mr. Shirk informed Mr.
Kenneff that Dr. Mihalakis would be testifying in a conversation on Thursday, July
2, 1992. Trial was set to begin the following Monday. These extenuating
circumstances explain Mr. Kenneff's displeasure at Mr. Shirk's retaining of Dr.
Mihalakis and at Dr. Mihalakis's willingness to assist the defense. His call to Dr.
Mihalakis was the result of this displeasure.
Mr. Kenneff testified at the PCRA hearing that he was going to ask the court for
cautionary instructions about the relationship between Dr. Mihalakis and the
County. When the case turned into a non-jury trial, this concern was alleviated.
The court does not make evidentiary rulings based upon allegations of unethical
conduct. The court can sanction counsel, can warn counsel and can suggest
appropriate disciplinary action.(84) The remedy for a violation of the Rules of
Professional Conduct is disciplinary action. While the contact between Mr. Kenneff
and Dr. Mihalakis created an issue in the 1992 trial, this court saw no reason for a
mistrial based on a demonstrated lack of prejudice to petitioner. This court saw no
basis on which to refer Mr. Kenneff to the Disciplinary Board. This court also notes
that in the ensuing years, neither Mr. Shirk, nor Mr. Goldberg, nor Mr. Epstein, nor
Ms. Lambert, nor Ms. Lambert's family saw fit to refer this issue to the disciplinary
authorities. It was arguably improper conduct with some justification under the
circumstances. The bottom line is that it did not affect the witness's testimony at
trial. He testified consistent with his report and his testimony was no surprise to
petitioner's counsel.
The question remains why did Mr. Shirk and Mr. Goldberg call Dr. Mihalakis under
these circumstances? Possibly, it was to cast doubt about Laurie Show's ability to
speak. Dr. Mihalakis certainly established that any speech would have been faint.
Keep in mind that the Commonwealth witnesses said that speech was possible and
Dr. Mihalakis qualified this and said it would have been very difficult for her to
enunciate.
A second reason to call Dr. Mihalakis would have been to cast doubt on the fact
that Laurie Show was alive for a full half hour. He helped the defense in this area
by providing a strong basis on which a fact finder could doubt that Laurie Show
lived long enough to speak to her mother. The fact that this court did not find a
reasonable doubt about guilt based upon this testimony does not mean it was a
Page 477 of 2301
mistake to put Dr. Mihalakis on the stand.

A third possibility, that defense counsel put Dr. Mihalakis on the stand knowing he
would not help them but with the belief that the Kenneff conversation would create
a strong appeal issue, is not considered by this court. This court is aware of the
professional integrity, skill and judgment of the defense attorneys involved in this
case and rules out any untoward use of Dr. Mihalakis's testimony under these
circumstances. It is likely that Dr. Mihalakis was put on the stand because of his
strong testimony on the time of death, the time for loss of consciousness, and the
difficulty in phonation or enunciation. The fact that he could not rule out speech
does not mean he was useless to the defense.

Petitioner contends that she now has after-discovered evidence relevant to the
credibility of Laura Thomas. Ms. Thomas was a witness at trial as to Ms. Lambert's
animus against Laurie Show. Specifically, Ms. Lambert contends that after the
murder, Ms. Thomas was caught lying to the East Lampeter Township police about
being "kidnaped." Petitioner contends that after Ms. Thomas agreed to say Ms.
Lambert planned to "slit Laurie's throat" in her trial testimony, her charges were
reduced to disorderly conduct and she was only made to pay a small fine. (Exhibit
A, Section A, para. 41.) Further, petitioner claims that neither Laura Thomas nor
her father, Floyd Thomas, said anything about Ms. Lambert's plans to "slit
[Laurie's] throat" in their initial interviews with the police. (Exhibit A, Section A,
para. 42.) Ms. Lambert lists those same allegations under the heading of
Brady/Giglio violations. (Exhibit A, Section B(5), paras. 66 and 68.) Finally, Ms.
Lambert refers to Ms. Thomas's testimony as "false and/or perjured" to the extent
that Ms. Thomas related that Ms. Lambert wanted to "slit Laurie Show's throat."
(Exhibit A, Section B(6), paras. 109 and 110.)
To understand this issue, it is important to look first at Laura Thomas's testimony in
1992. Ms. Thomas was a friend of Ms. Lambert's in 1991. She was one of a group
of teenagers enlisted by Ms. Lambert to abduct Laurie Show. She testified at trial
about discussions of a plan to do harm to Laurie Show:
Q. Who participated in the discussions leading to this plan to do something bad?
A. It was myself, Kimona Warner, Vince Orsi, Rachel Winesickle, Lawrence and
Michelle.
Q. Who told you what the plan was to be?
A. Michelle.
Q. What did Michelle tell you the plan was to be?
A. Okay. We were supposed to go over to Laurie's house and, myself and Kimona,
and we were supposed to go and knock on her door and say that we were going to
a fraternity party and there was like three college guys we were supposed to meet
there, supposedly. We were supposed to get her out of the house and then we
Page 478 of 2301
were supposed to go take her downtown on Green Street, tie her to a telephone
pole, or some kind of a pole, and Michelle was going to cut her hair and slit her
throat, beat her up, spray paint a sign, black pussy, on her.
Q. All of this was told to you by Michelle?
A. Yes.
(N.T., Trial at 668-69.)
This plan never came to fruition because Laura Thomas and Kimona Warner went
to Laurie Show's house and warned her. Ms. Thomas went on to describe another
discussion regarding harm to Laurie Show:
Q. Now did Michelle ever try to obtain your assistance again in a similar plan or
another plan to hurt Laurie?
A. Yeah. She always wanted me to go and pick her up, get her out of the house
because she knew that I was friends with Laurie.
Q. Where did the conversation regarding this occur?
A. Right outside my house on my picnic table that we all sat at.
Q. At any time did Michelle say to you what she intended to do once you got Laurie
out of the house?
A. Well, this time it wasn't getting her out of the house; I don't know what it was.
But she just said I swear to God I'm going to kill her. She said I'm going to slit her
throat.
Now, six years later, Ms. Lambert claims to have after-discovered evidence that
proves Ms. Thomas was lying. Ms. Lambert centers this issue on the absence of any
reference to slitting Laurie Show's throat in Ms. Thomas's interviews with the police
at the time of the murder. Ms. Thomas spoke to Officer Flory on December 20,
1991, to Officer Bowman on January 2, 1992, and to Officer Renee Schuler on
January 5, 1992. Only the January 14, 1992, report of Officer Bowman's interview
with Laura Thomas on January 2, 1992, contains any reference to Ms. Thomas's
recollection of a statement by Ms. Lambert that she was going to slit Laurie Show's
throat. (Commonwealth's Exhibit 4; Commonwealth's Exhibit 41.)
Ms. Lambert suggests that Ms. Thomas included the language "slit her throat" at
trial in exchange for favorable treatment by the East Lampeter Township Police
Department on a "false reports" charge against her. This is absurd given the fact
that Ms. Thomas's January 2, 1992, statement very clearly includes the "slit her
throat" language. This statement was taken six weeks before the "false reports"
charge was made against Ms. Thomas.
Moreover, this is a misleading argument based upon a contrived and superficial
Page 479 of 2301
understanding of the "false reports" incident. The incident involved a call by Linda
Thomas, Laura's mother, to the East Lampeter Township police regarding her
daughter's story about a "kidnaping." Officer Robert Reed of East Lampeter
Township interviewed Laura Thomas and prepared a report dated February 18,
1992. In short, Laura Thomas had "staged" her own kidnaping to attract the
attention of her apparently disinterested boyfriend. Her report was intended to get
back to the boyfriend and to draw his sympathies. It was not intended to get back
to Mrs. Thomas or to the police. Because the police did become involved and
because her deception led to a police investigation, albeit prompted by her mother,
Officer Reed charged Laura Thomas with disorderly conduct.
Petitioner makes much of the fact that this was a "false reports" charge which was
"reduced" to disorderly conduct by the East Lampeter Township police. First of all,
this was not a "false reports" charge in any way, shape or form. A "False Reports to
Law Enforcement Authorities" charge under 18 Pa. C.S.A. 4906(b), would have
involved conduct by Laura Thomas in making a false report to the police about an
incident knowing it did not occur. Laura Thomas did not do this. The elements of
"false reports" could not have been established under these facts.
In any event, a "false reports" charge would be a misdemeanor of the third degree.
The difference between a misdemeanor of the third degree and a summary offense
to a juvenile offender, to the police or to the Juvenile Court, is legally and factually
insignificant. Only a lack of understanding of the elements of a crime under
Pennsylvania law, a lack of understanding of the different treatment afforded
juvenile offenders and adult offenders under Pennsylvania law, and a tendency to
proclaim dramatic findings based upon a partially informed analysis could lead
anyone to attach significance to Officer Reed's decision to charge Ms. Thomas with
summary disorderly conduct. In fact, it is likely that neither a misdemeanor false
reports nor a summary disorderly conduct would have placed Ms. Thomas in the
formal juvenile justice system. It is more likely that either charge would have been
handled in the same or in a similar way: with a fine at the district justice level or
through informal probation with the Juvenile Probation Office involving no more
than a fine.
The second issue with respect to Laura Thomas is whether the report about her
"kidnaping" should have been disclosed to Mr. Shirk. (85) At the PCRA hearing, Mr.
Shirk testified that he would have liked to have been able to cross-examine Ms.
Thomas about this kidnaping report. (N.T., PCRA at 3392.) When questioned about
what use he could have made of the report at trial, he was less emphatic. In fact,
he acknowledged that it could be put to no legal use at trial but that he certainly
would have "attempted to use it and let the other side stop me." (N.T., PCRA at
3526.) Is it a Brady/Giglio violation to withhold information that could never be
put to a legal use or purpose at trial? Does the Commonwealth have an obligation
to provide the defendant with information which would create error if used? We
suggest that Mr. Shirk knows the answers to these questions and Mr. Shirk candidly
acknowledged that he would have tried to use the kidnaping incident, hoping the
Commonwealth would fail to object.
To argue that this report would have generated admissible impeachment material
as to Laura Thomas is just plain wrong. There is no other way to describe it. Under
the Juvenile Act, Ms. Thomas's juvenile record would have been inadmissible for
Page 480 of 2301
impeachment purposes in 1992. See, 42 Pa. C.S.A. Section 6354. (86)

The "slit her throat" issue has no merit. Mr. Shirk had available to him the report of
Officer Bowman which described Laura Thomas's description of Ms. Lambert's plan
to "slit" Laurie's throat. (Commonwealth's Exhibit 4; Commonwealth's Exhibit 41.)
He also had reports of Officers Flory and Schuler which did not mention the "slit her
throat" language. (See, Commonwealth's Exhibit 4.) He had every opportunity to
c ross-examine Ms. Thomas on this inconsistency and to argue that she fabricated
this aspect of her story. The real question is whether this would have made any
difference at all. Given the violent, premeditated, degrading plot to kidnap Laurie
Show, remove her clothing, physically assault her, and leave her tied up and
vulnerable to predators, the expression "slit her throat" is mere icing on the cake.
Without that language, Ms. Thomas was still describing a series of felonies which
spoke loudly and clearly to Ms. Lambert's hatred toward Laurie Show. When and
where and why she included language about slitting Ms. Show's throat is but one
fact in an otherwise unshakeable body of evidence demonstrating this prolonged
and hostile attitude exhibited by Ms. Lambert against Ms. Show.
Whether there was any discovery or Brady violation is addressed by Mr. Shirk's
cross-examination of Ms. Thomas at trial. In his cross-examination, he refers to a
police report of an interview of January 10, 1992. (N.T., Trial at 677.) Not only did
Mr. Shirk have the police reports available to him regarding the initial interviews of
Ms. Thomas, he also met with Ms. Thomas on June 18, 1992, in his office in
preparation for trial. The thrust of Mr. Shirk's cross-examination was to establish
that there was no mention of slitting a throat in the meeting of June 18, 1992. In
fact, this was a major thrust of Mr. Shirk's cross-examination of Ms. Thomas in
general. Ms. Thomas would not agree with Mr. Shirk's characterization of their
meeting. Mr. Shirk, in reference to the meeting in his office on June 18, 1992, with
Ms. Thomas and friends, asked the following of Laura Thomas:
Q. And didn't everyone pretty much agree that there was nothing said that night
about slitting Laurie's throat; it was simply to - not simply - but to take her to
town, tie her to a pole, cut her hair and put a sign, write on her, free black pussy?
A. No, we did say we were going to slit her throat.
Q. Who said that?
A. Me and Kim and Rachel. She wouldn't Q. That night in my office?
A. Yes.
The clear testimony was that in the June 18, 1992, meeting with Mr. Shirk, Ms.
Thomas related that Michelle said she was going to slit Laurie's throat. Whether Mr.
Shirk wanted to use the December 1991 and January 1992 interviews of Ms.
Thomas to impeach her on this point, he certainly could not claim surprise at trial
Page 481 of 2301
about this aspect of Ms. Thomas's testimony. She clearly told Mr. Shirk from the
witness stand that she had informed him prior to trial that the "slit the throat"
concept had been discussed by Ms. Lambert in the summer of 1991.

The black sweatpants were of relatively little value to this court as the fact finder in
1992. Today, they play a leading role in Ms. Lambert's post conviction drama. In
1992, the issue of the black sweatpants was simple. Mr. Yunkin testified that Ms.
Lambert wore them on the morning of the murder, but that they were his
sweatpants. Ms. Lambert told Corporal Solt that she was wearing black sweatpants
at the time of the murder. The only real question was whether she could have worn
sweatpants owned by the larger Lawrence. This was resolved by the court's
observations of the sweatpants, of Mr. Yunkin, of Ms. Lambert, and the conclusion
that Ms. Lambert could certainly have worn the garment.
Today petitioner contends that Mr. Yunkin's testimony about Ms. Lambert wearing
his clothing was false and perjured testimony. Further, petitioner contends that
some time between the 1992 trial and the 1997 federal habeas hearing, the
Commonwealth "switched" a pair of lady's (or boy's extra large) sweatpants for the
men's extra large sweatpants admitted into evidence in 1992 as Commonwealth's
Exhibit 9. Specifically, petitioner contends that the bloody sweatpants, sized men's
extra large, were destroyed by the Commonwealth and a smaller pair substituted.
The analysis can begin, and should end, with the observation that there was no
charge of misconduct regarding the black sweatpants in the 1992 trial. Petitioner
can point to no fabrication, alteration, modification or destruction of any evidence
regarding any item of clothing at or before the 1992 trial. Petitioner's only
contention with respect to the 1992 trial is that Mr. Yunkin's testimony about Ms.
Lambert wearing his clothing must have been false and, therefore, the
Commonwealth offered perjured testimony in support of the conviction.(87)
References to clothing are easily ascertained from the 1992 record. Ms. Lambert's
first description to the police about her attire was given in her statement dated
December 21, 1991. She told the police that she "had on a jergo. It's a strawy
thing, with a hood on it. I have it in my closet. I also had on a Bart Simpson TShirt, stretch pants, and these white shoes and socks." (Petitioner's Exhibit 1016-A,
Pennsylvania State Police Investigative Report of December 22, 1991, at 10.)
Toward the end of her interview with Corporal Solt, she changed her story:
The reason I was so scared, when I walked out I had different shoes, (sneakers),
socks, a red flannel shirt & white socks on, & black sweat pants. When Tabby came
out, she had blood on her hands & she grabbed my arm & got blood all over the
arm of my flannel shirt. I don't know if Lawrence saw that or not. I put it in a
dumpster, behind K-Mart or something.
(Petitioner's Exhibit 1023 at 7.)
In fact, the clothing described by Ms. Lambert was recovered by the police from a
truck that had picked up the trash from behind the K-Mart dumpster. (N.T., Trial at
Page 482 of 2301
132-34.)(88)
At trial, Ms. Lambert admitted that while she changed her statement regarding the
clothes she wore, that changed statement was a lie designed to cover up Mr.
Yunkin's participation. (N.T., Trial at 1035-36, 1172-73.) At trial she gave yet
another version of her apparel at the crime scene. She stated: "I had on black
pants. They were like black slush pants and a black Harley Davidson shirt, my black
MTV sweatshirt and gray and white jergo." (N.T., Trial at 1076.) This testimony
contradicted both versions given to Corporal Solt.
Mr. Yunkin testified at trial about Ms. Lambert's apparel on the morning of the
murder. On direct questioning by Mr. Shirk, Mr. Yunkin testified:
Q. Now when you dropped Michelle and Tabby off, do you recall what they were
wearing?
A. Yes. Michelle had on a flannel shirt, sweatpants and a jergo.
(N.T., Trial at 203.) Mr. Kenneff then held up the black sweatpants marked as
Commonwealth's Exhibit 9 and questioned Mr. Yunkin about these:
A. Sweatpants that I owned.
Q. Do you recall seeing those on December 20, 1991?
A. Yes, I do; on Michelle.
Q. Were those sweatpants on Michelle when she left your car on the morning of
December 20, 1991 at approximately 6:45 a.m.?
A. Yes.
Q. Was it unusual for Michelle to wear your clothing?
A. No it was not.
Q. Was t, here anything in particular at that time to cause Michelle to wear your
clothing?
A. She was pregnant at the time.
Q. How many months pregnant was she?
A. About seven months.
Mr. Shirk cross-examined Mr. Yunkin and Mr. Yunkin confirmed that Ms. Lambert
Page 483 of 2301
was wearing "black sweatpants." He also confirmed that those sweatpants were his.
(N.T., Trial at 225-26.)
Donald Bloser testified at trial that Commonwealth's Exhibit 9, the black
sweatpants, tested positive for the presence of blood. (N.T., Trial at 613-14.)
Vincent M. Orsi was called as a defense witness at trial and was shown the black
sweatpants by Mr. Shirk. Mr. Shirk first questioned him as to whether he had ever
seen Mr. Yunkin in black sweatpants:
Q. When had you seen Mr. Yunkin wearing black sweatpants?
A. I had slept over a few times and he wore them to bed, or if he was bumming
around the apartment he would wear them.
Q. I'm going to show you what's been marked Commonwealth's exhibit 9. Do you
recognize those sweatpants?
A. (Looking at the exhibit) Yeah. He would wear them to bed, bumming around the
house.
Q. They look familiar and similar to the ones he would wear?
A. (Nodding head affirmatively) Yeah.
(N.T., Trial at 904-05.)
None of this testimony appeared particularly pivotal at the 1992 trial. The black
sweatpants were never mentioned in Mr. Kenneff's opening statement or in Mr.
Shirk's opening statement. The sweatpants were not mentioned in Mr. Kenneff's
closing argument where certain items of evidence material to the Commonwealth's
theory of the case were discussed. Mr. Shirk argued that the sweatpants were worn
by Mr. Yunkin in his closing. (N.T., Trial at 1243-44.) Mr. Shirk argued that the
more likely wearer of the sweatpants was Mr. Yunkin and that this suggested that
Mr. Yunkin was in the condominium that morning and participated in the murder.
This court carefully considered that argument at trial and rejected it as proof that
Mr. Yunkin was present in the condominium. This issue was addressed in this
court's opinion on post verdict motions. See Commonwealth v. Lambert, July 19,
1994, slip op.
There is absolutely no merit to the contention that Mr. Yunkin's testimony about
Ms. Lambert wearing his clothes was false or perjured. We found this to be
believable in 1992 and nothing we have learned or heard since that time changes
that opinion.
Further, there is no proof that the sweatpants admitted into evidence as
Commonwealth's Exhibit 9 in 1992 have ever been altered, changed, or
substituted. Petitioner suggests that the sweatpants in 1992 were so large that Ms.
Lambert would be "swimming in them." There is simply no testimony or even any
Page 484 of 2301
argument to this effect.(89)

The controversy over the black sweatpants arose at the federal habeas hearing. In
petitioner's amended habeas petition she refers to "Yunkin's grossly oversized
clothing, that would have severely impeded her movements. . . ." See Lambert v.
Blackwell, 962 F. Supp. at 1531. Petitioner's characterization of the black
sweatpants as "grossly oversized clothing" appeared to be at odds with the size of
the sweatpants which were produced to petitioner by the Commonwealth. These
sweatpants, according to the Commonwealth, were the same sweatpants as were
admitted into the 1992 trial as Commonwealth's Exhibit 9. Armed with the
assumption that Commonwealth's Exhibit 9 was, in fact, a grossly oversized pair of
baggy black sweatpants and faced with a pair of black sweatpants which do not
appear to be "grossly oversized," petitioner's counsel leaped to the conclusion that
the sweatpants were "switched." For petitioner to argue that the sweatpants were
"switched" is somewhat tame.(90) But the evidence does not support this dramatic
and "shocking" possibility.
In the PCRA hearing, Mr. Shirk was shown Petitioner's Exhibit 1004, the black
sweatpants in question. He testified that to the best of his recollection, they are
smaller than the sweatpants used at trial. (N.T., PCRA at 3301.) He offered his
opinion that these sweatpants would not fit Mr. Yunkin. (N.T., PCRA at 3302.) Julius
Hyman, a textile expert, offered his opinion that the black sweatpants, Petitioner's
Exhibit 1004, were actually sized boy's extra large, not men's extra large. (N.T.,
PCRA at 358.) He was shown a photograph of the sweatpants which was taken in
1992 by Mr. Shirk, (Petitioner's Exhibit 3833), and compared that with the
sweatpants introduced into evidence at the PCRA as Petitioner's Exhibit 1004. He
offered his opinion that the sweatpants are different. (N.T., PCRA at 371-72.)
Yet, the Commonwealth's investigator, James Gallagher, testified that he conducted
an experiment where he obtained the same cardboard box lids, (Commonwealth's
Exhibits 56 and 57), on which the sweatpants rested in Mr. Shirk's 1992
photograph. (N.T., PCRA at 6568-69.) He took the sweatpants in question, laid
them out over the same box lids, and took a photograph that was substantially the
same as Mr. Shirk's photograph. (N.T., PCRA at 6569-75.)
Lieutenant Renee Schuler testified to Petitioner's Exhibit 1158, which is an evidence
log, listing the content, s of a trash bag found at the incinerator on Saturday
morning, December 21, 1991. (N.T., PCRA at 3835.) Officer Renee Schuler found a
pair of "ladies dress 'black' sweatpants (appears small size)" and listed these on the
evidence log. (Id.) Mr. Kenneff testified that these sweatpants eventually became
Commonwealth's Exhibit 9 at the 1992 trial. (N.T., PCRA at 1900.) Donald Bloser,
who performed blood testing on the sweatpants in 1992, identified his markings on
the exhibit in question at the PCRA hearing. (N.T., PCRA at 218.) He noted that the
markings are faded. (N.T., PCRA at 217.)
This court had the opportunity to view the sweatpants during the hearing. Certainly
they would have been baggy on Ms. Lambert. Certainly they appear to be more
consistent with a "ladies' large" or a "boy's extra large" size than with a "men's
ext ra large." We are left only to speculate as to whether the pants fit Mr. Yunkin.(91)
We found no evidence to suggest that the sweatpants were "switched." There
appears to be some disagreement as to whether Mr. Yunkin could have worn these
Page 485 of 2301
pants, whether they were "baggy" sweatpants as recalled by Mr. Shirk, and
whether by the size alone of the sweatpants they could have been worn by either
Ms. Lambert or Mr. Yunkin. We are left with the reliable and uncontradicted
evidence log which catalogs these as ladies' dress black sweatpants. We are left
with a comparison of the photographs from Mr. Shirk's office in 1992 and from the
evidence room in the PCRA hearing in 1998. These photographs are substantially
similar. We note Mr. Hyman's conclusion that the sweatpants in evidence contain
an elastic waistband and the sweatpants in Mr. Shirk's photograph do not appear to
have an elastic waistband. However, upon careful examination, the photograph
taken by Mr. Shirk is out of focus and it appears that, there could possibly h, ave
been an e, lastic waistband, although blurred by the photograph.
All this discussion about "switched" sweatpants is misleading. It would have been
silly to switch these sweatpants. They were considered at trial, they were identified
as having been owned by Mr. Yunkin and worn by Ms. Lambert. The court issued an
opinion in 1994 confirming that "title" to the sweatpants had nothing to do with the
verdict. The most we could conclude in 1992 was that Ms. Lambert could possibly
have worn the sweatpants and the fact they were owned by Mr. Yunkin did not
prove Mr. Yunkin's involvement in the murder.
Even if we assume the sweatpants were "switched" during the habeas corpus
hearing, that does nothing to establish after-discovered evidence, prosecutorial
misconduct or ineffective assistance of counsel under the PCRA. Even if the
sweatpants had been "switched" in 1997, this is is not a fact that would have
changed the outcome of the 1992 trial nor did it so undermine the truthdetermining process in 1992 that no reliable verdict was possible. Petitioner's
counsel would simply disagree with this court's conclusion that Ms. Lambert could
have worn the sweatpants offered into the record in 1992. They were not present
at the trial. This court was present and concluded on the record that it was possible
for her to have worn these sweatpants.
In the July 19, 1994, opinion, we noted: "The court listened to the testimo ny
regarding the clothing, observed the size of the garments and the size of the
people involved, i.e., Ms. Lambert, Ms. Buck and Mr. Yunkin, and found there to be
no question raised by the fact that the clothing appeared to be Mr. Yunkin's."
Commonwealth v. Lambert, July 19, 1994, slip op. at 14. That factual finding
was within the province of this court and was not attacked in any way by counsel in
the appellate process. If the federal district court found that the sweatpants were
"switched" during the proceeding, then it had every right to be concerned. But the
concern would have been for the Commonwealth's conduct during the habeas
hearing, not for the effect switching the sweatpants in 1997 would have had on the
1992 verdict. We simply do not have any conclusive evidence in this record which
would establish that the sweatpants were switched. We further find that argument
is of no legal significance to this PCRA case even if it would have factual support.
We looked at what was available to this court in 1992 and whether after-discovered
evidence regarding the integrity of the evidence in 1992 is now available to this
court. We considered whether presentation of the sweatpants as evidence in 1992
was the result of prosecutorial misconduct. We find neither to be the case.
Therefore, we find that the issue of the black sweatpants has no bearing on
petitioner's post conviction claim.
Page 486 of 2301

On December 22, 1991, two days after the murder of Laurie Show, the police
conducted a search of the Susquehanna River near the Pequea Creek inlet.
(Petitioner's Exhibit 1295.) Two critical pieces of evidence were found: a large
butcher knife and a rope. (N.T., PCRA at 800, 805.) This search was conducted by
the East Lampeter Township Police Department with the assistance of local scuba
divers. The search was filmed by William "Smokey" Roberts, a professional scuba
diver and videographer. (Petitioner's Exhibit 1040.) Mr. Roberts reviewed, edited
and copied the tape made of the search for the police and the district attorney's
office.(92) (Petitioner's Exhibit 1695; N.T., PCRA at 1107-1110.) Only this edited
version was turned over to Ms. Lambert's defense attorney. Mr. Shirk testified to
seeing the river search tape at the East Lampeter Township Police Department.
(N.T., PCRA at 3360, 3363.) He also stated that he received a copy of Officer
Reed's report that stated the videotape was edited by Smokey Roberts "to cut
down on time span and to eliminate unnecessary background noise." (N.T., PCRA at
3358; Petitioner's Exhibit 1295.) At no time, however, did Mr. Shirk request a copy
of the unedited tape.
Ms. Lambert contends that the police and/or prosecution edited the videotape to
delete allegedly exculpatory evidence of the police finding a pink bag at the river.
(Exhibit A, Section B(4) at para. 48.) The edited tape, however, showed an empty
pink bag embedded in ice. (N.T., PCRA at 1110, 3498-99; Petitioner's Exhibit
1695.) This pink bag was determined by the police to be immaterial to the case and
so was not recovered. (N.T., PCRA at 801-03.)
The edited tape also showed another empty bag of indeterminate color which was
found by the police along the river bank. (N.T., PCRA at 3498; Petitioner's Exhibit
1695.) However, this too was found to be irrelevant to the investigation and was
not seized as evidence.
At trial, Detective Barley was questioned by defense counsel as to whether during
the river search he found a trash bag containing sneakers. He stated he did not.
(N.T, Trial at 144.) Mr. Shirk explained in his PCRA testimony that he did not
impeach Detective Barley with the video, which clearly shows the discovery of a
pink bag, because he assumed it was one of many things found at the river that
simply was not relevant to the investigation. (N.T., PCRA at 3363.) As Mr. Shirk's
testimony reveals, it is reasonable to interpret Detective Barley's answer as a
denial that a trash bag with evidence in it, i.e., Mr. Yunkin's sneakers, the rope, the
knife, two pairs of sunglasses and the hats, was found during the search. The
evidence before this court, testimonial and video, showed that the plastic bags
were empty.(93)
Detective Barley's denial that he found a pink trash bag was immaterial to the case,
especially in light of the fact that the disposal of a trash bag by Ms. Lambert was
not an issue at trial. Ms. Lambert testified at trial that she disposed of a red bag(94)
containing the rope, the knife, two pairs of sunglasses, the hats, Yunkin's sneakers
and some rocks by throwing it into the Susquehanna River. (N.T., Trial at 1025-27,
1056.) Although Mr. Kenneff questioned Ms. Lambert about the color and size of
the bag and whether Mr. Yunkin threw anything in the river separate from the bag,
he did not question that Ms. Lambert threw the bag in the river. (N.T., Trial at
1154-55.) At trial, the Commonwealth never contended that Ms. Lambert did not
Page 487 of 2301
throw a bag into the river. To the contrary, the Commonwealth introduced Mr.
Yunkin's testimony that Ms. Lambert did throw a bag into the river. (N.T., Trial at
219.) This testimony had no effect on the outcome of the trial.
A second river search was organized for December 23, 1991. (Petitioner's Exhibit
1295.) At that time a diver discovered a sneaker in the Pequea Creek. (N.T., PCRA
at 823-24.) Detective Barley determined that it had no evidentiary value because it
was old, stained brown, decaying, packed with mud, had black rot, had rotted
threads, and had clearly been in the water more than three days. (N.T., PCRA at
823-24, 828-30.) It was found not in the river, like the rope and knife, but in the
Pequea Creek inlet which empties into the river and, therefore, could not have been
the sneaker the police were looking for. (N.T., PCRA at 824, 825.) For these
reasons, the sneaker was not seized as evidence.
Ms. Lambert contends that the undisclosed sneaker was exculpatory and, thus,
kept from the defense. At the time of the search, the police knew only that: (1) Mr.
Yunkin said that Ms. Lambert threw a trash bag containing shoes and rocks into the
river, (Commonwealth's Exhibit 4, West Lampeter Township Police Supplemental
Report by Officer Jere Schuler), and (2) Ms. Lambert said she had tossed sneakers
into the river, (Petitioner's Exhibit 2079). Thus, at the time of the search, the police
would have believed that anything found in the river relating to the murder would
incriminate Ms. Lambert because Ms. Lambert was the person who disposed of the
evidence. Clearly, so early in the investigation, the police would not ignore
evidence that might assist them in solving the murder, whether it incriminated only
Ms. Lambert (if the sneaker was Ms. Lambert's), or both Ms. Lambert and Mr.
Yunkin (if the sneaker was Mr. Yunkin's, but discarded by Ms. Lambert). Thus, it is
certainly plausible that an empty pink bag, embedded in ice, would be insignificant
to the searching officers, as would a black, rotted sneaker that had been in the
Pequea Creek for an extended period of time. The prosecutors and police officers in
this case could not then have known that Ms. Lambert would later disavow her presearch statements and later implicate Mr. Yunkin. The investigation must be viewed
in the light of what they knew when they acted.

Early in the morning of December 21, 1991, Ms. Lambert gave a statement to
Corporal Raymond Solt of the Pennsylvania State Police. This has been referred to
as the "Solt Statement' and has the designation of Petitioner's Exhibit 1023.
Corporal Solt was originally called in to administer a polygraph examination, to
which Ms. Lambert had consented.
Ms. Lambert actually gave to the police two statements on December 21, 1991. (95)
The first, given to Corporal Solt prior to the polygraph, was a handwritten
statement containing what has become known as "the alibi story."(96) She gave this
handwritten statement in response to Corporal Solt's request to tell him what
happened. He was going to use her story to compose questions for the polygraph
examination.
During the polygraph, Corporal Solt advised Ms. Lambert of his opinion that she
was not being truthful about what happened in the Show condominium. Ms.
Page 488 of 2301
Lambert then departed from the "alibi story."(97)

She told Corporal Solt that she and Ms. Buck were dropped off by Mr. Yunkin and,
in fact, they went into the Show condominium. She told Corporal Solt that it was
her idea to go because "I wanted to talk to Laurie." (Petitioner's Exhibit 1016-A,
PSP Report at 7.) She described how Ms. Buck went to the door, how Laurie
answered the door and how both went into the condominium: "I went upstairs and
went in and shut the door." (Id.)
Ms. Lambert described an attack, largely conducted by Ms. Buck and largely
witnessed by Ms. Lambert. On the second page of the "Solt Statement," Ms.
Lambert related:
Laurie tried to grab a scissors, and Tabby took them away and I don't know what
she did with them. I saw she had a knife and I saw her bring it down. It looked like
it bounced off. It didn't look real. Whenver [sic] she pulled it, Laurie jerked and fell
on the floor and rolled away and I heard that sound (indicating a 'woosh') and
Laurie coughing and kept saying that she was sorry. She was sorry, and saying:
'You're not going to leave me here?' and I saw Tabby take the knife and hitting and
I saw the knife come down, in her hair. Seh [sic] couldn't breathe right and was
making that sound ('woosh') and coughing and laying there and saying: 'Don't
leave me.'. She said she was sorry. She coughed, her body was jerking and stuff. I
couldn't look anymore and I turned away.
From her statement, it is clear that she was aware that Laurie had been stabbed.
She described a sound consistent with the back injury which punctured a lung and
she described how Ms. Buck's action made her sick. She went on to describe the
path she took when she left the apartment. In Corporal Solt's report, he relates
what Ms. Lambert told him:
. . . .I started to run, I'm not sure which way. Tabby told me to slow down. I ran
like up through the buildings and came out in somebody's back yard. I came out at
the cream house with shutters, I think they were blue. Tabby ran a different way. I
met up with her then right by the bushes at the woods.
(Petitioner's Exhibit 1016-A, PSP Report at 8.)
Later, at page 5 of the "Solt Statement," when asked where she went when she left
the apartment, she stated:
I got confused and I had no idea where I was and I ended up in someone's back
yard. I was in two fields while I was running and a patch of woods. I steped [sic] in
a creek and tripped over a barbed wire fence and fell. The creek was like a little run
off, not like a creek. I fell and landed in the briars. I ended up in those people's
back yard. I stood still and I saw Tabby walking down, through the woods, and she
was calm about it, and I ran.
Page 489 of 2301

Ms. Lambert also described what she was wearing:
When we walked up, I had on a jergo. It's a strawy thing, with a hood on it. I have
it in my closet. I also had on a Bart Simpson T- shirt, stretch pants, and these
white shoes and socks. I didn't have my hood up. We just walked around. Tabby
had her hood up. That is my jacket that I had on, over there. (pointing to a black
leather jacket in the interview room.)
The typewritten statement taken by Corporal Solt, i.e., the "Solt Statement,"
covers five and one-half typed pages. Each of these pages was signed by petitioner
in red felt-tipped pen upon completion of the statement. At the bottom of page six
and extending to page seven, there is hand printed lettering and then cursive
writing which contains an addition to the statement. This information was obtained
by Corporal Solt from Ms. Lambert in response to his question to her about whether
she had anything further to add to the statement. The pages containing the hand
printed and hand written portions are also signed by Ms. Lambert.
Ms. Lambert contends that the hand printed, handwritten portion on the last one
and one-half pages of her original statement are phony. She contends that she
signed blank papers at the time of her interview but that she did not understand
why she was doing that. She contends that Corporal Solt "filled in" these signed
papers with a "statement" which he created.
Petitioner presented expert witness testimony from William J. Ries, a forensic
document examiner. He testified that the recording of a statement from Ms.
Lambert on "plain paper" as opposed to "statement paper" is "unusual and odd."
(N.T., PCRA at 3621.) He opined that a statement should be taken on "formal
statement paper." (Id.) He also opined that the signature of Lisa Michelle Lambert
across the statement is "highly unusual." (N.T., PCRA at 3622-23.) When asked
whether he could tell if Ms. Lambert's signature was placed on the document after
the statement itself, he stated that "the red ink appears to be on top of the black
ballpoint pen writing on page 7 of Miss Lambert's statement." (N.T., PCRA at 3635.)
Mr. Ries is a retired Philadelphia polic e officer with experience in examining
documents. He testified as to the standard practice in Philadelphia, that is, the
taking of a statement on "official statement paper." He could not give any reason
for that practice other than compliance with departme nt procedure and certainly
could offer no opinion as to how the lack of "official statement paper" might affect
the integrity of the contents of the statement. (N.T., PCRA at 3644-45.) Mr. Ries
gave his commentary on Corporal Solt's methods and disapproved of the use of
plain paper in favor of "official statement paper." He disapproved of the practice of
having Ms. Lambert sign the statement across the page and noted that he has
never seen this done.(98) (N.T., PCRA at 3622-23.) Taken to its logical conclusion,
Mr. Ries's opinion would suggest that Corporal Solt should not have taken the
statement because he did not have "official statement paper" available to him. The
fact is that Mr. Ries really had very little to offer this court by way of criticism of the
"Solt Statement." His opinion failed to take into account that Corporal Solt was
taking a statement in the middle of night in a local police station using materials
Page 490 of 2301
available to him. Mr. Ries's tone of disapproval and his inconsequential criticism of
Corporal Solt's methods were of no help to this court and appeared to be little more
than advocacy dressed in expert's clothing.
Detective Solt testified that he used the paper available to him in the East
Lampeter Township Police Department. The first section of the statement, that is
the five and one-half typed pages, is on bond paper, which he obtained from a
secretary's desk by the typewriter he was using to type her statement. (N.T., PCRA
at 3099, 3122.) Ms. Lambert was then transported to another room of the station
and, at that point, she began to give him additional information. He took the only
available paper, from another desk, which was a different grading of paper, and
began to record what she was saying, first in hand printed lettering and then in
cursive writing. (N.T., PCRA at 3105-06, 3111-12, 3122.) He testified that he
switched from hand printing to cursive because he was writing quickly. (N.T., PCRA
at 3111-12, 3130.) Detective Solt testified at the PCRA hearing that he saw her
sign each page with a red pen after each paper was reviewed. (N.T., PCRA at 3114,
3129-30.)
The Commonwealth presented expert testimony from Lieutenant Joseph
Bonenberger, a document examiner with the Pennsylvania State Police. He offered
his opinion that the signature of Lisa Michelle Lambert is on top of the written and
printed material on the last two pages of her statement. Under microscopic
examination, he determined that wherever the red fibers crossed the other
printing, there was a slight smearing. His conclusion was that the statement was
signed by Ms. Lambert after the writing was placed on the paper. (N.T., PCRA at
7170-71.)
The time at which Ms. Lambert signed the statement also presents an issue in this
case. In Corporal Solt's report, he notes that the statement was completed at 7:51
a.m. and that Ms. Lambert signed the original of the "typed notes of the interview"
at 8:07 a.m. (Petitioner's Exhibit 1016, Corporal Solt's report of December 22,
1991.) These times are confirmed in Corporal Solt's testimony. (N.T., PCRA at
3101, 3118.)
Ms. Lambert points the court to the testimony of Detective Clarence L. Flory, who
transported Ms. Lambert to Community Hospital to have blood drawn. He testified:
Q. What time did you transport Ms. Lambert to Community Hospital?
A. 8:00 a.m. Roughly, 8:00 a.m.
Q. And what time was her blood drawn?
A. Approximately right away, around 8:00 a.m. I just have an approximate time.
(N.T., PCRA at 3715.)
In Detective Flory's report, he notes on the last page: "At approx. 0800 hrs., 21
December 91, this officer transported Lambert to Community Hospital of Lancaster
to obtain a sample of blood. Blood being drawn by Kimberly Felger, R.N. at approx.
Page 491 of 2301
0800 hrs., 21 December 91." (Petitioner's Exhibit 2065.)

Ms. Lambert's argument is that Corporal Solt presented false testimony about the
time she signed the statement, noting that she was at Community Hospital at the
time Corporal Solt contends the statement was signed.
It appears that the sequence of events here might be more reliable than the
precise times. Corporal Solt testified that the statement was completed at 7:51
a.m. and signed at 8:07 a.m. From his overall testimony and from his practice of
recording specific times, we believe his recollection of the times to be reliable. It
appears that Detective Flory was giving an approximate time, not an exact time. In
fact, every time Detective Flory referred to the time of transport to Community
Hospital, he used the word "approximate." This appears in his testimony and in his
report. He testified that he transported Ms. Lambert at "roughly 8:00 a.m." and
that her blood was drawn "around 8:00 a.m." (N.T., PCRA at 3715.) We know that
one or the other of those events did not take place at exactly 8:00 a.m. The East
Lampeter Township Police Department office is located east of the City of
Lancaster; Community Hospital is located just east of the city line. The time of
transport would be approximately 10 to 15 minutes. Allowing for time to place Ms.
Lambert in a police car, to drive to Community Hospital, to remove her from the
police car and to escort her to the blood lab, it is reasonable to expect that the
process took anywhere from 15 to 20 minutes.
When asked about the sequence of events that morning, without respect to exact
times, Detective Flory testified that he transported Ms. Lambert to Community
Hospital when Ms. Lambert's questioning was finished. (N.T., PCRA at 3715.)
From this testimony, we can conclude that Detective Flory took custody of Ms.
Lambert after her questioning was finished. Could Detective Flory's testimony that
he took her to the hospital at "approximately 8:00 a.m.," "roughly 8:00 a.m.," or
"around 8:00" have meant that he took her after she signed her statement at 8:07
a.m.? That certainly seems reasonable and we believe it is fair to conclude that that
is how this took place. To point to Detective Flory's testimony as precise on the
question of time and to, therefore, leap to the conclusion that Corporal Solt was
falsifying his report is a leap unsupported by the facts or by common sense. It is
clear that the sequence of events that morning had Ms. Lambert finish her
statement, review the statement, sign the statement and then to go to Community
Hospital in the company of Detective Flory.
Petitioner's final claim regarding her "fake statement" is that Corporal Solt
"injected" her in the arm before administering the polygraph examination. This
bizarre and wholly unsupported allegation surfaced at the PCRA hearing. The
"factual basis" for this charge is that Ms. Lambert had a slight bruise on the inside
of her arm upon inspection at the time of her arrest. (N.T., PCRA at 3784-85;
Petitioner's Exhibit 1609.) This slight, unexplained bruise became the marking of a
truth serum injection. Ms. Lambert was quick to adjust her story to accommodate
the "injection." She described how she was hooked up to the polygraph machine
with a number of Velcro straps and that Corporal Solt then injected her with a
needle. (N.T., PCRA at 5297, 5372.)
There is absolutely no support in the record for the allegation that Ms. Lambert was
injected with truth serum. In fact, if she was really injected with "truth serum," why
Page 492 of 2301
should she complain about what she said under its influence? We dismiss that
charge as incredible.
With respect to the substance of the statement, we note that Ms. Lambert
expressed familiarity with its contents at the 1992 trial. At the PCRA hearing, Ms.
Lambert was reluctant to say that she had even read the statement in 1992.
However, Mr. Shirk noted that he went over the statement with her in detail. (N.T.,
PCRA at 3447-49, 3527-28.) This would be consistent with basic, good practice for
a criminal defense lawyer and Mr. Shirk has demonstrated a high level of skill,
dedication and expertise at a very high level. It would be unbelievable to this court
that Mr. Shirk would not have gone over Ms. Lambert's statement with her in great
detail in preparation for trial. Mr. Shirk is uncertain whether he actually showed her
the statement or whether he had it in front of him and read portions of the
statement to her in preparing her for trial. (Id.) There really would be no significant
difference between these two approaches. The fact is that she was familiar with the
contents of her entire statement before trial. Her own trial counsel established this
fact.
In fact, in 1992, Ms. Lambert was asked about what she told Corporal Solt. This
question was in specific reference to her statement. She was asked, "Everything
Trooper Solt said you said was the truth[?]." And she responded, "Yes." (N.T., Trial
at 1035.)
Further, in a letter written from Ms. Lambert to Mr. Yunkin in the prison on
December 23, 1991, she adopted the information she gave to Corporal Solt in the
statement. (Commonwealth's Exhibit 16.) That is, her letter to Mr. Yunkin sets forth
the same information with respect to her apparel on the day of the murder.
In the handwritten portion of the "Solt Statement," Ms. Lambert states she was
wearing ". . . a red flannel shirt & white socks [ ] & black sweat pants." (Petitioner's
Exhibit 1023 at 7.) She makes further reference to Ms. Buck getting "blood all over
the arm of my flannel shirt." (Id.)
In the December 23, 1991, letter, she uses the same reference to how Ms. Buck
grabbed her arm and "got blood all over my red flannel." (Commonwealth's Exhibit
16 at 2.) Also in the letter, she refers to fleeing with Ms. Buck and meeting up with
her "down at the woods." (Commonwealth's Exhibit 16 at 3.)
Any contention that the handwritten (or printed) portion of the statement was
made up by Corporal Solt after Ms. Lambert signed the statement is clearly
contradicted by her own testimony at trial and her own handwritten letter to Mr.
Yunkin of December 23, 1991.
For PCRA analysis purposes, this issue of the "altered statement" involves neither
prosecutorial misconduct nor after-discovered evidence. There simply is no proof of
either under the elements required by the Act.
To establish prosecutorial misconduct, Ms. Lambert must prove by a preponderance
of the evidence that Detective Solt had her sign blank pages and then completed,
in his own handwriting, a false statement which he then attributed to Ms. Lambert.
On this issue we have Detective Solt's sworn testimony against Ms. Lambert's
Page 493 of 2301
sworn testimony. Having listened carefully to the testimony of each witness, this
court finds that Detective Solt is far more credible than Ms. Lambert on this issue.
We consider their statements at the PCRA hearing together with all other evidence
in this case both from the 1992 trial and from the balance of the testimony at the
PCRA hearing. For one thing, Ms. Lambert was well aware in 1992 of the contents
of her statement and never in her own testimony or through her lawyers'
arguments made an issue of or raised a question about her statement. Her bald
assertion that the statement was phony against Detective Solt's testimony as to the
steps he took to obtain the statement carries no weight whatsoever. Petitioner's
expert, Mr. Ries, does nothing to establish that the statement was the result of any
prosecutorial misconduct. The Commonwealth's expert, Lieutenant Bonenberger,
offers a reasonable opinion that the signature of Ms. Lambert was placed on the
document after the typed, printed or written portions. This court really does not
require the assistance of the experts on this issue. Given Ms. Lambert's testimony,
Detective Solt's testimony, Ms. Lambert's letter of December 23, 1991, to Mr.
Yunkin, and Ms. Lambert's testimony at trial, we find there to be no basis for a
finding of prosecutorial misconduct on this issue.
With respect to after-discovered evidence, the simple truth is that if the statement
had been altered, the alteration was plainly available to Ms. Lambert at the 1992
trial. She is unable to meet the first prong of the after-discovered test, i.e., that the
evidence was unavailable at trial. The contention that this was an "altered
statement" is without merit under any analysis.
Petitioner contends that Detective Solt is guilty of perjury in his testimony about
the statement. There is certainly no basis for a finding that Detective Solt perjured
himself in testifying about the statement. At best, his testimony is at
odds with Ms. Lambert's testimony.(99) We have already acknowledged that
Detective Solt's testimony is at odds with Ms. Lambert's testimony regarding the
statement. We resolved in 1992, and we resolve again, this credibility issue in favor
of Detective Solt and against Ms. Lambert. This inconsistency between these
witnesses is not perjury as to either Detective Solt or Ms. Lambert.

Ms. Lambert contends that the police altered or fabricated photographs of the crime
scene to (1) show a telephone cord wrapped around the victim's leg, thereby
proving that Ms. Lambert's version of the story of what happened in the
condominium that morning is false, (2) hide bloody footprints in the front hallway
and in Laurie Show's bedroom, and (3) include Tabitha Buck's white sweatshirt in
the crime scene.
A second level of alleged police misconduct regarding the crime scene photographs
concerns the nature of the photographs and the number of photographs taken. Ms.
Lambert contends that photographs of important parts of the crime scene, such as,
fingerprints, blood spatters and the like, were not taken. In the alternative, she
argues that such photographs were taken but were destroyed.
Page 494 of 2301

A series of crime scene photographs show a telephone cord wrapped around the leg
of Laurie Show. Laurie's body was positioned in her bedroom and a number of
photographs show the cord connecting a handset to the base of the telephone
wrapped once around her leg down near the ankle. Why is this of significance?
First, because the diagrams prepared by Officer Weaver do not show the telephone
cord wrapped around the leg of the victim. In fact, they show the telephone close
to her leg but not touching it. Second, Ms. Lambert testified at trial that Ms. Buck
grabbed the telephone from Laurie Show's hand and threw it across the room. If
Ms. Lambert was telling the truth, then the telephone would be somewhere away
from Laurie Show's body. If Ms. Lambert was not telling the truth, then the
telephone might, presumably, be near Laurie Show's body. In essence, petitioner
believes that the police wrapped the telephone cord around the leg of the victim in
an intentional act to discredit her story. Ms. Lambert attempts to discredit the
crime scene photographs by pointing to the crime scene diagram prepared by
Officer Weaver.
Officer Weaver testified that he did not prepare the diagram to scale, that there
were literally hundreds of items in the bedroom and that he did not record the
location or the description of each and every item. (N.T., PCRA at 1710.) The
telephone was placed in the diagram after the body was removed from the
bedroom. (N.T., PCRA at 1783.) In fact, he was preparing these diagrams
essentially to show the position of the body and the major articles of furniture in
the bedroom. (N.T., PCRA at 1710.) This was the first homicide investigation in
which he had been involved and the first crime scene he had drawn. (N.T., PCRA at
1777.) In his testimony he did not seem to attach much, if any, significance to the
precise location of these various objects. (N.T., Trial at 34; N.T., PCRA at 1784-86.)
Petitioner questioned almost every witness who was present in the crime scene that
morning as to the location of the telephone cord. No one was able to specifically
recall whether the telephone cord was, in fact, wrapped around the leg of Laurie
Show. Petitioner takes this wholesale lack of recollection about a detail of
questionable relevance and parlays it into an affirmative statement that the
telephone cord was not wrapped around the leg of the victim.
This analysis requires two substantial leaps: (1) a leap from the failure of any
witness to recall the telephone cord around the leg to the c onclusion that the cord
was not around the leg; and (2) a leap from that conclusion to the conclusion that
the police found it necessary to go back into the condominium, lay the body out on
the floor, wrap the telephone cord around the leg and then take a series of
photographs. These photographs would show that Ms. Lambert was lying when she
gave her statement about Ms. Buck throwing the telephone across the room.
Followed to its logical end, what possible reason would the police have to discredit
Ms. Lambert's statement that Ms. Buck threw the telephone across the room?
Certainly, they were not interested in ruling out evidence of Ms. Buck's
involvement. Certainly, Ms. Buck's throwing the telephone across the room and the
location of the cord around Laurie Show's leg are not mutually exclusive. It appears
that the telephone was close to the entrance of the bedroom, by the bed, when
Laurie picked it up. If Ms. Buck threw it across the relatively small bedroom, it
could easily have landed near the closet where Laurie's body came to rest. With the
Page 495 of 2301
base separated from the handset, the apparatus could have extended across the
floor on the opposite, i.e., window, side of the room. With respect to wrapping the
cord around the leg, Laurie's body could have come to rest on top of the cord and
the telephone could have been moved as the several medical and police personnel
tended to Laurie or processed the crime scene.
This allegation of misconduct assumes that the police took every detail of Ms.
Lambert's statement in the early hours of December 21, 1991, and sought to
orchestrate the items of physical evidence available to them, in this case, the
photographs, to discredit that statement. This just does not make any sense. In so
"discrediting" Ms. Lambert's statement, the police would have been compromising
evidence of Ms. Buck's involvement. The police have never, under any
circumstances or under any interpretation of the evidence, sought to diminish Ms.
Buck's involvement. In fact, the Commonwealth pursued a first degree murder
prosecution against Ms. Buck resulting in a jury verdict of second degree murder in
September 1992.
As to the issue of after-discovered evidence, the crime scene photographs were
certainly available to Mr. Shirk in 1992. The crime scene drawings prepared by
Officer Weaver were available as well. In fact, Officer Weaver took the stand in
1992 and was cross-examined by Mr. Shirk. If any discrepancy between the
photographs and the drawing were of any importance to the Lambert defense effort
in 1992, they would have been raised at that time. This is certainly not evidence
which was unavailable at the time of trial. The only thing "unavailable" at the time
of trial was the unfounded suspicion that there is something untoward about these
photographs due to the fact that they are not entirely consistent with the crime
scene drawings.
With respect to "prosecutorial misconduct," petitioner has established nothing by
way of facts or evidence to show that these photographs were somehow fabricated
or changed. Under the analysis required in a PCRA proceeding, nothing about these
photographs undermined the truth-determining process or would have changed the
outcome of the trial.
2. Footprints in the hallway and bedroom
Petitioner presented the testimony of a representative of Compleat Restorations.
Compleat Restorations was called to the scene on December 23, 1991, to clean the
condominium at the request of Mrs. Show's insurance company. Compleat
Restorations took some photographs, one of which shows a reddish smudge or
mark on the floor in the tile entranceway. This mark could be interpreted to be a
footprint. This is now presented by petitioner as proof that the testimony in 1992
that there was no blood in the hallway or any footprints in the hallway was false,
fabricated and perjured.
The fact that a Compleat Restorations photograph shows a smudge in the
entranceway which could be viewed as a footprint establishes nothing. Compleat
Restorations came into the condominium three days after the murder. In that time,
literally dozens of persons were in and out of the home. Testimony was that the
blood on the carpet on Laurie's bedroom had soaked through to the point where it
had stained the concrete underneath. There were copious amounts of blood all over
the bedroom. Anyone going in and out of that room could well have tracked blood
Page 496 of 2301
out through the hallway. To say that a smudge on the floor which looks like a
footprint had to be the footprint of the murderer (and no one else) and was,
therefore, hidden by the police is just not true. The Compleat Restorations'
photographs do show markings on the floor which could be interpreted to be bloody
shoe prints. This does not establish that the shoe prints were placed there by the
killer.
Officer Weaver testified at trial that there was a bloody footprint in the hallway and
that he believed that it was made by medical personnel. (N.T., Trial at 38, 49-50,
54-55.) He also testified that he saw no distinct footprints in the bedroom. (N.T.,
Trial at 53-54.) Pennsylvania State Polic e Trooper Anthony Suber testified credibly
about this at the PCRA hearing, as well. (N.T., P.C.R.A. at 6539-40, 6545.)
Perhaps petitioner and her counsel disagree with the police assessment on the
morning of December 20, 1991, about the relevance or the importance of the
footprints in the bedroom. That issue was available to petitioner and her defense
counsel at trial and, in fact, there was a significant amount of discussion and
argument over footprints at the scene. Nothing about the case has changed since
that time.
Finally, Trooper Suber, who took the photographs at the crime scene, took a
videotape of the interior and the exterior of the condominium at the conclusion of
his work. By that time most of the investigative personnel had cleared out of the
condominium, Laurie Show's body had been taken to the morgue, and the
investigation was largely completed. He photographed, by way of a video camera,
the entire interior of the Show condominium before he left that morning. The video
shows some markings on the tile floor which could well have been consistent with a
significant amount of traffic in and out of the condominium that morning. This video
was taken prior to the photographs taken by Compleat Restorations. There are
blood spatters and markings on the wall just inside the doorway with corresponding
spots, presumably blood, on the floor just underneath. Trooper Suber carefully
recorded these on the videotape. That tape was available to trial counsel and was
shown at the trial.
The photographs of the front hallway are very important to petitioner's theory of
this case. In the story she told at trial, she attempted to rescue Laurie Show by
grabbing her by the wrists and dragging her from the bedroom to the hallway. At
that point, Laurie Show had been stabbed in the back and, presumably, would have
been bleeding profusely.(100) Yet, the crime scene photographs show very little
blood in the front hallway. This led Mr. Kenneff to pose the question in his closing
argument: "Where is the blood?" (N.T., Trial at 1283.) Mr. Kenneff was referring to
the crime scene photographs and pointing out that the physical evidence did not
support Ms. Lambert's story that she became Laurie Show's "rescuer" that morning.
Ms. Lambert's response to this is that the police altered or fabricated photographs
to dispute her story.(101) She contends: (1) that the hallway was cleaned up before
the photographs were taken; or (2) a rug was moved so as to hide bloody
footprints while the photographs were taken; or (3) the photographs were
"cropped" so as to cut out bloody footprints.
In reality, several of the photographs of the hallway show an Oriental type throw
rug which is positioned in somewhat of an angle. A careful inspection of several of
Page 497 of 2301
these photographs shows a reddish smudge near the doorway, which could
certainly be a mark made by a shoe which had tracked across blood. One of these
photographs shows a figure standing outside the condominium door, who was later
identified as Reverend Samuel Knupp. Reverend Knupp testified that he was
present at the condominium that morning and had been summoned there to assist
Mrs. Show. (N.T., PCRA at 5939, 5941-43.) This would establish that the
photograph of the hallway was taken that morning and not later that night or the
next day as petitioner suggests. In any event, on certain of the photographs, a
reddish smudge is visible. The fact that the carpet may have been moved to cover
a portion of the smudge does not suggest a sinister cover up. Rather, it suggests
that the throw rug was easily moved and shifted to different positions as people
moved in and out of the condominium that day.
With respect to the "cropping" of photographs, Trooper Suber testified that certain
machines which print photographs from negatives will sometimes cut the print at
an inappropriate point. (N.T., PCRA at 6525-26.) This could easily have been done
in the many copies made of the many photographs which are now in the record of
this case. It is important to note that there are "non- cropped" photographs of the
same door, hallway and portion of the wall showing a full view.
Petitioner argues that the photographs show a blood spatter on the wall and at
least one bloody footprint in the hallway. She contends that this establishes that
Mr. Kenneff's "where's the blood?" argument was false and misleading. The
photograph of the wall showing the blood spatter just inside the front door of the
condominium was carefully reviewed at trial. The photographs of the entranceway
to the condominium were available for all to see at trial. Mr. Kenneff's argument
that there is no physical evidence to support Ms. Lambert' s story was absolutely
correct. The fact that there is a bloody footprint and a blood spatter on the wall
does not support her contention that she dragged the mortally wounded and
bleeding Laurie Show by the wrists into the hallway. Judging from the amount of
blood on the carpet in the bedroom, it is logical to conclude that were Ms.
Lambert's story to be true, there would be copious amounts of blood in the hallway.
The court understood Mr. Kenneff's argument to be a reference to a lack of
significant blood in the hallway. The fact that there was a blood spatter and a
footprint or two does not render the "where's the blood?" argument false or
misleading.
3. The white sweatshirt
Petitioner presented evidence that Ms. Buck wore a white sweatshirt on the
morning of the murder. She also presented testimony that Ms. Buck appeared at
Penn Manor High School after the murder wearing a white or off-white sweatshirt
turned inside out. Petitioner points to the white sweatshirt in the crime scene
photographs and argues that this is Ms. Buck's sweatshirt, placed there by the
police.
The problem is that there is no testimony which would establish that the police had
Ms. Buck's sweatshirt or that the police had access to Ms. Buck's sweatshirt while
the crime scene photographs were taken or when they were allegedly fabricated in
the early morning hours of December 21, 1991. The bald assertion that the white
sweatshirt lying near or next to Laurie Show's body in certain crime scene
Page 498 of 2301
photographs is Ms. Buck's sweatshirt is without any foundation in the evidence.

Ms. Lambert contends that photographs of the crime scene are missing or they
were destroyed. She bases this argument on essentially two grounds: (1) the
testimony of Stephen Hale; and (2) by inference from the fact that the photographs
produced to her counsel during the federal proceeding were not produced all at one
time, in logical sequence, accompanied by a printed log.
Mr. Hale is a retired polic e officer from rural Ohio who has experience in
investigating crime scenes. He has taken photographs of crime scenes. He offered
his opinion that had he photographed the crime scene at the Show condominium on
December 20, 1991, he would have taken more pic tures. Ms. Rainville, as counsel
for Ms. Lambert, argues from this "opinion" that some pictures must, therefore, be
missing. That is, because the Commonwealth did not produce in federal discovery
the number and type of photographs Mr. Hale would have taken, the
Commonwealth must, therefore, be hiding something. All Mr. Hale was able to
establish at the PCRA hearing was that the police officers taking the crime scene
photographs were "incompetent" in his view. But this is not a case about
incompetent photographers or negligence on the part of an investigating police
department. This is a case where the court is evaluating claims of after-discovered
evidence, prosecutorial misconduct and ineffective assistance of counsel. The fact
that Mr. Hale, or his "ordinary competent crime scene photographer," might have
done more than Trooper Suber and Pennsylvania State Police Trooper Joseph C.
Reeves did is of little or no consequence to this case. Perhaps rather than four rolls
of film, they should have taken ten rolls of film. That argument invites nothing
more than speculation and leads nowhere. The fact is there were ample
photographs taken for the Commonwealth, the defense and the court to understand
the nature of the crime scene at the 1992 trial. No issue was raised as to the
photographs at that time.
With respect to the "destruction" of photographs, Detective Geesey testified that he
took steps to verify that the District Attorney's Office had all the Pennsylvania State
Police photographs prior to turning them over to petitioner's counsel in 1997. (N.T.,
PCRA at 3900.) Lieutenant Renee Schuler was asked to obtain photographs from
East Lampeter. Photographs from the District Attorney's files were also obtained. It
appears that the photographs were produced in stages to petitioner's counsel in
Philadelphia pursuant to the district court's order. The photographs were not
produced all at one time, in an orderly fashion. This appears entirely reasonable
given the fact that the various crime scene photographs had been used in two
preliminary hearings and two homicide trials more than five years before the
federal discovery order. It was established at the PCRA hearing that there was no
set procedure or protocol for the storage of photographs. It appears likely that
some were in the District Attorney's files, certain photographs were with the
Pennsylvania State Police and others may have been at East Lampeter Township.
The record makes clear that reasonable and good faith efforts were made to locate
all available photographs.
The "destruction of photographs" claim basically arose in the discovery phase to the
federal habeas proceeding. A number of witnesses testified in the PCRA hearing as
to the manner in which the Lancaster County District Attorney's Office produced
Page 499 of 2301
photographs to petitioner's counsel in Philadelphia. Several witnesses testified to

the so-called "Christmas Eve production" where a series of photographs arrived in
the offices of Schnader Harrison Segal & Lewis, counsel for petitioner, on December
24, 1996. It appears from all accounts that photographs were received from the
Lancaster County District Attorney's Office in several stages. This manner of
complying with the discovery directives of the district court, combined with the fact
that the State Police did not take the hundreds of photographs Mr. Hale would have
taken, has led to petitioner's conclusion that photographs were hidden or destroyed
rather than disclosed to her counsel in Philadelphia prior to the habeas hearing. As
we discussed above, it appears more likely that the production of photographs was
accomplished in stages because the photographs were located in several different
places.
As an ironic commentary on this issue, petitioner's counsel found themselves poorly
organized and frustrated when it came time to organize their photographs to move
their admission into evidence during the PCRA hearing. On June 9, 1998, during the
questioning of District Attorney Madenspacher, counsel for petitioner attempted to
have certain photographs shown to the witness. There was confusion as to the
numbering and location of the exhibits despite the fact that the court had dedicated
a secure area adjacent to the courtroom for the storage of evidence. In addition,
counsel for petitioner had at least two paralegals at all times assisting the two
attorneys trying this case. Nevertheless, when attempting to organize and present
certain photographs, counsel for petitioner were unable to locate the exhibits.
There were several breaks taken during the afternoon session for the purpose of
locating these photographs. Christy Fawcett, Esquire, counsel for the
Commonwealth, made the following statement for the record:
I would like to place on the record that we have now spent approximately 15 to 20
minutes attempting to straighten out exhibits that were previously marked by the
petitioner.
And in addition we also spent some time during Mr. Madenspacher's testimony
attempting to clarify some of those issues. In addition to what has been today,
there was a period at the beginning of the case, and this frankly may or may not be
on the record, I don't recall, but where there was several hours spent trying to
clear up mismarking of exhibits.
And my purpose for requesting that this be placed on the record is not to indicate
in anyway that I think anybody was deliberately trying to rearrange or cause
problems with the exhibits, but I think it is instructive and illustrative of the
problems that occur when there are large numbers of photographs and other
exhibits that - and other items of evidence that are being given into discovery, for
instance, being attempted to locate, subsequent to a trial, to give to counsel and so
forth.
And I think it's an illustration of how mistakes sometimes happen that are nobody's
fault. They're simply honest mistakes and I think that's occurred here and, as I
argue to the court later on, that could've been easily what occurred at later points
in this case.
(N.T., PCRA at 5806-07.)
Page 500 of 2301
In essence, petitioner's counsel could not locate photographs that had previously
been marked, were somewhere in the courtroom or in the evidence room, and
which they wished to show to a witness. The court quite agrees with counsel's
statement that the organization, management and retrieval of large numbers of
exhibits, photographs or otherwise, can be very difficult.(102) The PCRA hearing was
a clinic on this subject. It is not at all hard for this court to believe that the District
Attorney's Office, East Lampeter Township and the Pennsylvania State Police might
have had difficulty locating and producing all photographs of the crime scene in one
complete and well-orchestrated production. Human nature and the litigation
process being what they are, it is completely understandable how these
photographs could have been produced in 1996 and 1997 in several stages without
any sinister significance. There simply is no proof of any prosecutorial misconduct,
destruction of evidence or fabrication of evidence arising out of these facts with the
crime scene photographs.
In early to mid-January 1992, Dean Haas, Hazel Show's nephew, was helping clean
the Show condominium. He found a pearl earring on the tile floor just inside the
front door up against a baseboard. Mrs. Show turned this earring over to Corporal
Renee Schuler and told her she did not recognize the earring as her daughter's.
Corporal Renee Schuler turned the earring over to Detective Savage who prepared
a report dated February 7, 1992. The report notes that the earring was shown to
Mr. Yunkin:
On 02-07-92, this officer showed the pearl stud earring to Lawrence Yunkin. At that
time, Yunkin stated that he is sure that Michelle Lambert did, in fact, own a set of
earrings exactly like the earring that this officer presented to him. Yunkin stated he
does not recall when Michelle may have worn said earrings, did not recall if she had
this type of earring on the morning of 12-20-91 and did not recall Tabatha Buck
having earrings on on 12-20-91. Yunkin stated that other than remembering that
Lambert had earrings exactly like these, he could provide no other information as
to where they were at this time when she wore them or any other information.
Petitioner's contends that there is misconduct associated with this pearl earring.
Specifically, she claims that the report of Detective Savage, (Petitioner's Exhibit
1190), was a "deliberate falsification of evidence" because Mr. Yunkin had told the
police on February 5, 1992, that he sometimes wore the earring. Petitioner is
actually referring to the testimony of Detective Barley from the PCRA hearing.
Detective Barley testified that Mr. Yunkin told him he wore "an earring." (N.T.,
PCRA at 677.) Mr. Yunkin never acknowledged to Detective Barley that he wore
that specific pearl earring. The most Mr. Yunkin said was that on occasion he wore
an earring similar to that one but did not state or admit that he wore that earring
at any time.
Whether or not Mr. Yunkin acknowledged that he wore the pearl earring found in
the Show condominium, there is no proof whatsoever of destruction of evidence,
after-discovered evidence, prosecutorial misconduct or any other untoward
behavior regarding the pearl earring. In fact, Ms. Lambert' s defense counsel at
trial emphasized the earring and suggested very strongly that Mr. Yunkin wore that
Page 501 of 2301
earring that morning. Roy Shirk had available to him Mr. Yunkin's printed
statement, a 19-page document, which was marked in the PCRA hearing as
Petitioner's Exhibit 1661. Mr. Shirk was aware that the earring had been found in
the condominium, was aware that Mr. Yunkin wore earrings, and worked very hard
to find someone who could say that Mr. Yunkin wore that pearl earring. In the PCRA
hearing, Mr. Shirk testified that Richard Jeffries "went to great lengths . . . to find
people who had seen Mr. Yunkin wearing that earring." (N.T., PCRA at 3388.) Ms.
Lambert had told Mr. Shirk that Mr. Yunkin wore that specific earring.
Assuming the complete truth of all of petitioner's allegations regarding misconduct
as to the earring, they come to nothing. Mr. Shirk believed that Mr. Yunkin wore
the earring, searched for witnesses to support this, and cross- examined Mr. Yunkin
on whether he wore the earring. He could have done nothing more with the earring
at trial.
Mr. Shirk cross-examined Mr. Yunkin about the pearl earring in a thorough and
forceful way. It was obvious to the court that Mr. Shirk was prepared on this issue
and he, in fact, established that the earring was one that Mr. Yunkin had worn on
occasion or similar to one that Mr. Yunkin had worn on occasion. Mr. Shirk showed
Mr. Yunkin a photograph of the pearl earring at trial and asked him if he been
shown that by the police. Mr. Yunkin testified that he did talk about the earring
with the police and said, "I said it looks like an earring that Michelle owns." (N.T.,
Trial at 258.) Mr. Shirk then asked him:
Q. But who wore them?
A. I wore -- About three times I wore one.
Q. You wore the pearl earrings?
A. One,, yes.
(N.T., Trial at 258-59.)
Mr. Yunkin went on to tell Mr. Shirk at trial that he had told the police he wore the
earring. Mr. Shirk then argued to the court that the police intentionally left out a
reference to Mr. Yunkin's wearing the earring in the report they filed. He also
accused the police of leaving that information out of Mr. Yunkin's statement. In
fact, Mr. Yunkin was not certain that he told the police about the earring in giving
his statement. He was sure that he told Corporal Solt about the earring in his
meeting with Corporal Solt just prior to trial. (N.T., Trial at 259.)
Mr. Shirk moved for a mistrial on the basis of the Commonwealth's failing to
disclose to him that Mr. Yunkin wore the pearl earring. Mr. Shirk argued that the
defense was not notified that Mr. Yunkin wore a pearl earring like that and
contended "it was kept out of his statement." (N.T., Trial at 1181.) Mr. Kenneff
noted to the court that he found out that Mr. Yunkin wore the pearl earring from
Mr. Shirk. (N.T., Trial at 1197.) The court found there to be no prejudice and no
evidence that the information was "kept out of the statement" or withheld from the
defense. Mr. Shirk made every good use of the information about the pearl earring
in cross-examining Mr. Yunkin. Under cross-examination by Mr. Shirk, Mr. Yunkin
Page 502 of 2301
admitted that he wore a pearl earring. That appears to the court to be the most use
Mr. Shirk could have made of the earring at trial.
The earring itself was apparently a generic pearl-like earring, as described by a
number of witnesses. There was nothing distinctive about the earring. In fact, the
earring could have come from Mr. Yunkin, from Ms. Lambert or from Ms. Buck. We
ruled out the fact that it may have come from Laurie Show because her mother
stated early on in the investigation that her daughter did not own an earring like
that. The fact that Mr. Yunkin wore earrings and the fact that the earring was of a
generic type does not establish what petitioner wants to establish: that Mr. Yunkin
wore that earring in the condominium that morning and that it fell out while he was
murdering Laurie Show. There simply is no factual basis for this finding nor is there
enough of a basis to draw any inference in petitioner's favor on this point.
O. Ro bert Reed's Testimony
Robert S. Reed was called as a witness by petitioner. Mr. Reed is a former East
Lampeter Township police officer who participated to some extent in the
investigation of this case. Mr. Reed was called as a witness in the PCRA hearing on
May 11, 1998. Two days before that, he had been convicted of several felonies
involving sexual assaults on a minor. At least two of these charges carried with
them mandatory minimum sentences of five years each.
When Mr. Reed came into the courtroom, he stated his name and then indicated
that he did not wish to answer questions. He was given an opportunity during a
recess to consult with his attorney and then returned to the witness stand. At that
time, the following colloquy occurred:
THE COURT: Mr. Reed, you indicated a few moments ago that you did not wish to
answer any questions until you had a chance to speak with your attorney. Is that
correct?
THE WITNESS: That's correct, your Honor.
THE COURT: All right. Have you had a chance now to speak with your attorney?
THE WITNESS: Yes, I did, your Honor.
THE COURT: All right. And is that Attorney Robert Reese?
THE WITNESS: That's correct.
THE COURT: Having spoken with Mr. Reese, do you wish to answer questions at
this time?
THE WITNESS: No, I do not.
THE COURT: And why is that, Mr. Reed?
THE WITNESS: At this time I'd just like to reserve that for a later time, your Honor.
Page 503 of 2301
I have no explanation at this time. I just don't want to answer any questions.
THE COURT: Okay. Mr. Reed, is your refusal to answer any questions today
motivated in any way by a concern against self incrimination?
THE WITNESS: No, your Honor.
(N.T., PCRA at 1539-40.)
At that point, a conference was held at sidebar with counsel. Counsel discussed
with the court whether there was a legitimate Fifth Amendment privilege which
could be invoked by Mr. Reed. The court then explained to Mr. Reed that if he
refused to answer a question, the court could direct him to answer and his failure
to comply could result in a contempt citation. The court further advised him that if
it was a matter of self incrimination, he could invoke his rights under the Fifth
Amendment of the United State Constitution and, if satisfied that there was a basis
on which to invoke the privilege, we would not direct him to answer the question.
Our research on this issue during the trial disclosed that a witness's right to invoke
the Fifth Amendment extends to potential criminal liability that is collateral or
remote. This court was aware that Officer Reed was one of the police officers whose
conduct was condemned by the federal district court in 1997 and who was referred
to the United States Attorney's Office for investigation. This court has no idea as to
the status or progress of any such investigation. However, the fact remained on
May 11, 1998, that there was a potential open investigation in the United States
Attorney's Office in the Eastern District of Pennsylvania and that answers to any
questions put to Mr. Reed during the PCRA hearing could have bearing on his
culpability on any charges or allegations being investigated by the United States
Attorney. This court honestly believed that the privilege would apply even if the
possibility of investigation, charges or conviction in federal court was remote.(103)
<, P>The court then gave permission to petitioner's counsel to question Mr. Reed.
In response to a series of questions, he asserted his privilege under the Fifth
Amendment and refused to answer. It became clear that he was asserting this
privilege as to every question. For example, he responded to a question as to his
employment status by invoking the Fifth Amendment privilege:
Q. Mr. Reed, where were you employed in 1991?
A. I'm refusing to answer that under the Fifth Amendment.
(N.T., PCRA at 1544-45.)
We ruled that it was proper for Mr. Reed to invoke the Fifth Amendment privilege in
light of the allegations made in the federal proceeding. The question remains for
our purposes, what is the remedy? Petitioner's counsel argue that we should draw
an adverse inference to his assertion of the Fifth Amendment privilege on each
question. The Commonwealth contends that Mr. Reed should be considered
"unavailable" and that his testimony in the federal proceeding should be used as his
Page 504 of 2301
testimony in this proceeding.

Generally, the fact finder may not draw an inference from a witness's exercise of
his constitutional right not to incriminate himself regardless of whether the
inference is favorable to the prosecution or the defense. Commonwealth v.
Greene, 445 Pa. 228, 231, 285 A.2d 865, 867 (1971). In this case, the initial
colloquy with Mr. Reed disclosed that he was not so much concerned about self
incrimination as he was simply unwilling to participate in the hearing. Given his
apparent state of mind following the conviction on the sex offenses, this was
understandable. With the explanation given to him as to his options in answering
questions, it appears that Mr. Reed used the Fifth Ame ndment privilege against self
incrimination as a "ticket" to not answer any questions. He appeared hostile to the
proceedings and, at one point, refused to look at the river search videotape which
was played directly in front of him and about which he was asked some questions.
The court noted for the record that Mr. Reed did not look at the television screen
for the entire eight minutes it took to play the video. (N.T., PCRA at 1554.) It
appears that Mr. Reed may well have been angry with himself or at the world. In
any, case, this led to a, wholesale lack , of cooperation with counsel's questions.
Given the circumstances and in light of Greene, it seems appropriate to consider
Mr. Reed "unavailable." We have, therefore, considered his testimony from the
federal proceeding, which was presented on Monday, April 14, 1997, the tenth day
of the habeas corpus hearing. (N.T., Habeas Hearing at 2184-2228.)
On June 10, 1998, counsel for petitioner submitted a document entitled "Petitioner
Lisa Lambert's List of Admissions to be Offered into Evidence." The document
contains a long listing of page references from the transcript of the federal habeas
proceeding involving the testimony of Detective Solt, former Detective Barley,
Officer Bowman, Mr. Kenneff, former Chief Jacob A. Glick, District Justice Savage,
Lieutenant Renee Schuler and Officer Weaver. Each of these witnesses was called
by petitioner at the PCRA hearing. The proposed admissions refer to substantial
portions of the deposition and federal court testimony of these witnesses. They are
offered in this proceeding as "admissions" by these witnesses. We addressed the
proposed use of petitioner's federal habeas corpus record in this proceeding in an
opinion filed April 6, 1998. See Commonwealth v. Lambert, 76 Lanc. L. Rev. 169
(1998). In that opinion, we considered the various arguments in favor of the
request that we accept the federal habeas record as the evidentiary record for the
PCRA. We ruled at that time that there is no basis in law or in common sense for so
doing. With respect to the federal habeas record, we noted:
This is not to say that the record produced in April 1997 in federal court cannot be
put to any use in this proceeding. As all parties have agreed, the record contains
testimony under oath and may be used in the same way prior testimony under oath
can be used in any proceeding. The court would prefer not to decide this case on a
series of admissions extracted from depositions and from the federal record. The
court is aware that Rule 1507, 'Disposition Without Hearing,' provides for the
disposition of a petition without a hearing when the petition and answer show that
there is no genuine issue concerning any material fact. Pa. R. Crim. P. 1506(b). The
court does not view this Rule as an invitation to the parties to submit this case in a
posture similar to a motion for summary judgment under Rules 1035.1 through
Page 505 of 2301
1035.5 of the Rules of Civil Procedure.

76 Lanc. L. Rev. at 182.
Our position has not changed since that time. In fact, counsel for petitioner put the
federal habeas record to good use during the PCRA proceeding. The record was
used to impeach witnesses, to refresh the recollection of witnesses and, in the case
of Officer Reed, to provide testimony where a witness has become "unavailable" for
the PCRA hearing. The wholesale use of testimony from the federal proceeding and
the ensuing necessary argument as to whether certain statements constitute
admissions under the law was precisely what we hoped to avoid in holding a PCRA
hearing. Now, after a lengthy hearing, we believe the request that we consider
statements from the federal proceeding as "admissions" is superfluous. We,
therefore, deny the request that the proposed admissions contained in petitioner's
pleading be used as evidence in this case.
The elements of a PCRA ineffective assistance of counsel claim are discussed in
Section III.B.1.b, supra, of this opinion. As to each allegatio n of ineffective
assistance, Ms. Lambert must show: (1) there is merit to the underlying claim; (2)
counsel had no reasonable basis for his course of conduct; and (3) that there is a
reasonable probability that but for the act or omission in question, the outcome of
the proceeding would have been different. There are 22 allegations of ineffective
assistance of counsel regarding Mr. Shirk in petitioner's second amended petition.
(Exhibit A, Section C.) We will address those allegations in this section.
1. Failing to push for discovery

Mr. Shirk, Ms. Lambert's trial counsel, did, in fact, request discovery. He requested
and "pushed for" all information to which he was entitled under Pa. R. Crim. P. 305.
In fact, Mr. Shirk requested a conference with the court on discovery and presented
his concerns before trial.
Petitioner criticizes Mr. Shirk for failing to obtain the level of discovery she achieved
in the federal habeas proceeding. The simple answer to that is the Rules of Criminal
Procedure in Pennsylvania do not provide for that kind of discovery. In the federal
proceeding, petitioner's counsel took in excess of 50 depositions and caused the
production of attorney work product from the prosecuting attorney. The level of
discovery permitted by the district court far exceeded the scope of discovery under
the Pennsylvania Rules of Criminal Procedure. This court is satisfied that Mr. Shirk
made a request for all materials discoverable under Pa. R. Crim. P. 305 and Brady.
2. Failing to call character witnesses
This issue has been previously litigated. This court considered the claim raised by
Mr. Epstein on behalf of Ms. Lambert. See Commonwealth v. Lambert, March 14,
1995, slip op. at 6-24. No additional evidence was offered on this issue at the PCRA
hearing.
Page 506 of 2301
3. Failing to use an expert in speech

Mr. Shirk retained a well known forensic pathologist, Dr. Mihalakis, to testify on the
issue of speech in this case. Dr. Mihalakis prepared a report for Mr. Shirk in which
he discussed the possibilities of speech for Laurie Show.
The "underlying claim" here is that a speech expert would have established that
Laurie Show could not have spoken to her mother. This is a claim of questionable
merit. As we have seen from the lengthy testimony at the PCRA hearing, this is an
area on which experts sharply disagree. We have had the opportunity to consider
the testimony of Dr. Larson in this case. We find that there is no reasonable
probability that the outcome of the proceeding would have been different had Mr.
Shirk called Dr. Larson or an expert in Dr. Larson's
field to testify at the trial. For a more complete discussion of the impact of expert
testimony on the issue of Laurie Show's dying declaration, see Section VII.A, supra.
4. Failing to use an expert on abuse and rape trauma
Mr. Shirk cannot be ineffective for failing to call an expert on a subject that is not
relevant under Pennsylvania law. Had Mr. Shirk presented Dr. Burgess or a similar
expert at trial, she/he would not have been permitted to testify. See discussion of
this issue in Section VII.C, supra.
5. Failing to use an expert in pathology
In fact, Mr. Shirk did use an expert in pathology. Dr. Mihalakis was unable to
determine whether the major vessels in Laurie Show's neck were cut. As we have
seen, Dr. Penades, who performed the autopsy, and Dr. Annese, a throat surgeon
who attended the autopsy, testified that the major vessels were not cut.
Specifically, petitioner is referring to the carotid artery. Drs. Baden and Smialek,
world renowned forensic pathologists called by petitioner at the PCRA hearing,
could not offer an opinion as to whether the carotid artery was cut. All the
information made available to them would have been available to a pathologist
retained by Mr. Shirk at the time of trial. Drs. Burton and Ross offered opinions
based upon the autopsy photographs and the autopsy report that the carotid was
not cut.
We find that no expert, EMT or board certified forensic pathologist, could have
countered the clear and unequivocal testimony of Drs. Penades and Annese that
the carotid artery was intact.
6. Failing to use an expert in crime scene photography
Petitioner contends that her expert in crime scene photography, Stephen Hale, has
demonstrated that the prosecution has destroyed evidence. We have not been able
to make that finding based upon the testimony of Stephen Hale. Mr. Hale basically
testified that he would have done a better job than Troopers Suber and Reeves.
That does not establish that the state police or the East Lampeter Township police
destroyed evidence. There is no merit to this claim.
Page 507 of 2301
7. Failing to use an expert in document authenticity

This is an interesting claim in light of William Ries's testimony that he could not
determine whether Ms. Lambert's statement was altered or fabricated. Mr. Ries was
the document expert called by petitioner in this PCRA hearing. Upon examination of
the five and one-half typewritten pages and the one and one-half handwritten
pages, Mr. Ries could not say whether Ms. Lambert's signature was placed on the
statement before or after the statement was prepared.
The wild assertion that Ms. Lambert's statement was fabricated is simply contrary
to the evidence. We discussed this issue in Section VII.L, supra. In light of Ms.
Lambert's testimony at trial that her statement contains that which she told
Corporal Solt, in light of Mr. Shirk's testimony at the PCRA hearing that he went
over the statement with her very carefully and in light of her letter of December 23,
1991, where she adopts the portion of the statement which is handwritten, an
attack on the authenticity of her statement at trial would have been a peculiar
move indeed for Mr. Shirk.
8. Failing to give Ms. Lambert her statement to review
There is no merit to this claim. See Section VII.L, supra.
9. Failing to attack Detective Barley about the pink bag
Mr. Shirk viewed the edited river search video, which shows a pink bag embedded
in ice. He was present for Detective Barley's testimony at trial that the police did
not find the trash bag. Mr. Shirk did not confront Detective Barley about this
inconsistency. There are three possible explanations for this: (1) Mr. Shirk did not
make the connection and missed an opportunity to impeach Detective Barley; (2)
Mr. Shirk did not find there to be anything of evidentiary value about the pink trash
bag; or (3) Mr. Shirk was aware that a bag was found but chose not to highlight
this issue as it was strongly suggestive of Ms. Lambert's involvement in the
murder.
Given the level of Mr. Shirk's preparation for trial and his understanding of the
factual and legal issues, it is unlikely that he simply "missed" an opportunity to
impeach Detective Barley. It is more likely that he chose to keep his client as far
away from the trash bag as possible because of the implications arising from her
knowledge of or disposal of the bag. It is equally likely that he, in essence, agreed
with Detective Barley that there was nothing of evidentiary value found in the bag.
In the event that Mr. Shirk considered the pink trash bag a collateral issue, he
showed good sense and effective trial strategy by not impeaching Detective Barley
on a collateral issue.
10. Failing to have Ms. Lambert and her family testify about the "29
questions"
Mr. Shirk made a strategic decision as to the use of the "29 questions" at trial. It
was his purpose to use the document to demonstrate Mr. Yunkin's involvement in
the murder. The "29 questions" did nothing to exculpate Ms. Lambert. In fact, in
Page 508 of 2301
that suspect document, she refers to "our prank," she refers to "Laurie's scary dead
eyestare," and she acknowledges participating in the conspiracy and the cover up.
(See Petitioner's Exhibit 1119; Addendum to this Opinion.) To open the door
through Ms. Lambert's testimony to these issues would have served no purpose.
There has been no showing here by petitioner that anyone in the Lambert family
had any light to shed on the "29 questions."
11. Failing to get an expert to replace Dr. Mihalakis
Petitioner contends that Mr. Shirk should have sought a continuance or obtained an
expert to replace Dr. Mihalakis. This issue is the subject of the discussion in Section
VII.H, supra.
With the considerable testimony on Laurie Show's ability to speak, the damage
done to Laurie Show's neck and her physical condition following the assault that
morning, we know that the subject matter of Dr. Mihalakis's testimony is a subject
matter upon which experts disagree. We have had the benefit of three well
qualified experts who offered their opinions that Laurie Show could not have
spoken. We have the benefit of three experts who say that Laurie Show could have
spoken. As we noted in Section VII.A, supra, "Laurie Show's Dying Declaration,"
this is an area where the expert testimony is one factor to be considered on the
question of Mrs. Show's credibility as to the "dying declaration."
With the benefit of all the expert discussion at the PCRA hearing, we can say with
confidence that Mr. Shirk's finding an expert to replace Dr. Mihalakis would not
have changed the outcome of this proceeding. Our conclusion now is the same as
our conclusion then. The additional mountain of expert opinions, pro and con, has
not changed that finding.
12. Failing to present evidence available that showed Mr. Yunkin's
involvement
Here petitioner is referring specifically to the statement made by Mr. Yunkin to
Hector Feliciano as he (Yunkin) was leaving work the week before the murder. The
out-of-court statement by Mr. Yunkin to Mr. Feliciano is hearsay. Mr. Shirk is not
ineffective for failing to elicit hearsay from a witness. In fact, Mr. Shirk articulated a
legitimate tactical reason for keeping the Feliciano statement out of evidence. See
discussion of Brady/Giglio claim 12, infra.
13. Failed to have John Balshy look at other writings in blood at the scene
John C. Balshy testified at trial that the letters "T" and "B" were written in blood on
the closet door. (N.T., Trial at 956.) This court viewed the photographs at trial and
did not agree with Mr. Balshy's "findings."
It is interesting to note that at the PCRA hearing, Mr. Shirk's own investigator,
Richard Jeffries, felt the same way. In fact, it was Mr. Jeffries who contacted Mr.
Balshy in 1992. When Mr. Balshy contacted Mr. Jeffries about his "finding" the
letters written in blood, Mr. Jeffries disagreed with him. Mr. Jeffries testified at the
PCRA hearing that he continues to believe that those letters are not written in blood
on the closet door. (N.T., PCRA at 7694.) This court found Mr. Balshy less than
Page 509 of 2301
credible on that point. See Section VII.M, supra.

Mr. Shirk is not ineffective for failing to ask Mr. Balshy to look at other writings in
blood at the scene given the fact that his testimony as to the writings he "found"
was incredible. It certainly did not undermine the truth-determining process.
14. Failed to recognize that the last part of Ms. Lambert's statement was
altered
This issue has been considered in Section VII.L, supra, and in our discussion of
allegation of ineffective assistance 7, supra, in this section.
Two brief points bear repeating. One, Ms. Lambert acknowledged in her testimony
at trial that her statement was accurate. Two, Ms. Lambert wrote a letter on
December 23, 1991, to Mr. Yunkin where she adopted the information contained in
the last page of her statement. There is no evidence whatsoever in this or any
other record that the last page of her statement was "obviously altered."
15. Failed to present available evidence that Mr. Yunkin was lying about
what Ms. Lambert wore during the murder
Petitioner contends that Mr. Shirk was ineffective because he failed to present
available evidence that Mr. Yunkin was lying about what Ms. Lambert wore during
the murder.
Mr. Shirk cross-examined Mr. Yunkin on his recollection of what Ms. Lambert was
wearing. Mr. Shirk made a point of arguing to this court that Mr. Yunkin must have
been lying in that testimony. All of the "inconsistent" statements made by Mr.
Yunkin regarding Ms. Lambert's attire that morning were available to Mr. Shirk. Mr.
Shirk fully and completely litigated this issue in the trial. There is no merit to the
claim set forth in the petition on this point.
16. Failed to present available corroborating evidence about the date rape
Petitioner claims that Mr. Shirk was ineffective in that he failed to present evidence
corroborating the Yunkin date rape of the victim. In the first place, the police
reports are hearsay and would not have been admissible at trial. There does not
appear to be any credible evidence that there was, in fact, such a date rape. There
were suggestions and references made as to this possibility in police reports. That
is not competent evidence. Mr. Shirk was not ineffective for the failure to offer
hearsay at trial.
17. Failed to point out the time of death as listed on the autopsy report
The autopsy report notes the time of death as 7:15 a.m. This is simply contrary to
a significant amount of evidence. Perhaps Mr. Shirk understood that the time on
the autopsy report was an approximation. Perhaps Mr. Shirk was aware that the
911 call had been made at 7:35 a.m. and that persons on the scene saw signs of
life after the call. Whether Mr. Shirk was aware of that or not in 1992, we are
Page 510 of 2301
certainly aware of those facts today. There is no merit to the claim.
18. Failed to present evidence that Ms. Lambert was not jealous
To suggest that Ms. Lambert was not jealous of Mr. Yunkin's involvement with
Laurie Show in the summer of 1991 would be a significant departure from reality.
At trial, there was, as Mr. Shirk described, a "parade" of teenage witnesses who
described the animosity from Ms. Lambert to Laurie Show at that time. Mrs. Show
testified as to specific incidents in which Ms. Lambert acted in an irrational,
hysterical and jealous rage.
The fact that Michelle Lambert might have been sexually active with another man
during the summer of 1991 does not establish a lack of jealousy. It would probably
not have been effective trial strategy for Mr. Shirk to enhance his client's
outrageous behavior in the summer of 1991 with proof of some sexual promiscuity.
In any event, this contention has no merit.
19. Failed to present evidence in news video footage that Ms. Lambert did
not appear pregnant
There was no evidence offered at the PCRA hearing on this claim.
20. Failed to present evidence of Mr. Yunkin's scratches and bruises

As with so many of these issues, petitioner never really presented any evidence in
support of this contention. After nearly nine weeks of hearing testimony, we do not
know whether there exists any "news footage" showing that Mr. Yunkin had
scratches and/or bruises on his face. What we do know is that the prison records
show that he had no bruises or scratches upon his commitment to Lancaster
County Prison on December 21, 1991. (Commonwealth's Exhibit 49.) The nurse
who did his intake physical examination at the prison on December 21 testified that
he had no scratches or bruises. (N.T., PCRA at 6354.) There is no merit to this
contention.
21. Failed to present evidence of "another Michelle"
The contention that there was "another Michelle" who had been "involved with the
victim" is very misleading. There certainly was no person at any time material to
this case who was "involved with the victim" to the extent that Lisa Michelle
Lambert was "involved with the victim." To suggest that Laurie Show might have
known another girl named Michelle is of no consequence. The inference here is that
Laurie Show was referring to this other Michelle in her dying declaration. Given the
history between Ms. Lambert and Laurie Show, given what we know of Ms.
Lambert's participation that morning by her own admission, and given the
demonstrated fear Ms. Show had of Michelle Lambert during the summer and fall of
1991, to suggest that the dying declaration may have referred to another Michelle
has no basis in fact.
Page 511 of 2301
22. Failed to get Ms. Lambert's statement suppressed due to a violation of

Pennsylvania's six hour rule
The "six hour rule" issue did not surface until Detective Solt was testifying in the
PCRA hearing on May 20, 1998. Detective Solt testified that he took a statement
from Ms. Lambert and that at around 4 o'clock in the morning on December 21,
1991, he telephoned Assistant District Attorney Kenneff to consult with him. (N.T.,
PCRA at 3076-77.) The subject matter of this consultation was whether the
questioning could proceed in light of the "six hour rule." Displaying some confusion
over this issue, petitioner's counsel asked Detective Solt to explain. He went on to
explain to them that a person in custody must be arraigned within six hours and
that a statement taken beyond this six hour period from the time of arrest might
well be illegal. (N.T., PCRA at 3079-80.)
The second amended petition was submitted to the court by petitioner on June 10,
1998, during the hearing and after Detective Solt's testimony. This amended
petition contains this allegation of ineffective assistance based on the "six hour
rule." This "learn as you go" approach has led to yet another frivolous issue
introduced into this hearing. We will address the issue because it has been raised.
In Commonwealth v. Davenport, 471 Pa. 278, 370 A.2d 301 (1977), the
Pennsylvania Supreme Court ruled that a statement taken from a defendant more
than six hours after arrest may be suppressed. This rule was qualified in
Commonwealth v. Duncan, 514 Pa. Super. 395, 525 A.2d 1177 (1987). Our
courts have since held that the Duncan/Davenport rule is not to be applied in a
mechanistic fashion. Voluntary statements given by a defendant and initiated within
six hours after arrest may not be suppressed just because the process of obtaining
the statement runs over six hours. Commonwealth v. Odrick, 410 Pa. Super.
245, 599 A.2d 974 (1991). See also Commonwealth v. Bond, 539 Pa. 299, 652
A.2d 308 (1995).
Detective Solt's candid testimony about his concerns for the Duncan/Davenport
rule were intended to explain why he bro ke off the interview. Mr. Kenneff advised
him that he could take no new information but that he could obtain clarifications
and confirmations of information he had already taken from Ms. Lambert.
Mr. Shirk was asked by petitioner's counsel why he did not have the statement
suppressed. He testified that he was familiar with the Duncan/Davenport rule
and that he felt it would be a fruitless exercise to seek to have the statement
suppressed. He noted that Ms. Lambert all but confirmed the contents of her
statement in the letter of December 23,1991, to Mr. Yunkin. Second, he was aware
that recent developments in the law would probably have supported the use of the
statement because Ms. Lambert had begun the statement within the six hour
period of time. Further, the last part of the statement, where she changed her story
as to her attire at the time of the murder, was apparently given voluntarily and not
in response to questions.
Mr. Epstein, a specialist in criminal law from Philadelphia and Ms. Lambert's
appellate counsel, testified that he did not think there was any merit to a
suppression issue based on the Duncan/Davenport rule.
Page 512 of 2301
Mr. Shirk stated a clear tactical reason for not seeking to suppress the statement.
He certainly had a reasonable basis for his course of conduct. The content of Ms.
Lambert's statement, even if the statement itself had been suppressed, would have
been admitted through her subsequent letters and statements to others.

Ms. Lambert contends that Mr. Epstein was ineffective. Mr. Epstein was hired as
appellate counsel to pursue the issues raised on appeal by Mr. Shirk. Mr. Epstein
was given permission to expand on these issues in his amended post verdict
motions. Petitioner contends that he was ineffective for failing to address "the
many irregularities in the record." This allegation is too vague to merit any
response. The court is uncertain as to these "irregularities" and dismisses this
contention as having no merit.
Petitioner contends that Mr. Epstein was ineffective for failing to call the experts
that petitioner's counsel called at the federal habeas hearing. In fact, Mr. Epstein
was pursuing an appeal to the Pennsylvania Superior Court. Typically, expert
witnesses do not testify in the appellate courts. Mr. Epstein may also have
recognized that expert testimony is not after-discovered evidence and chose not to
call these experts in the post verdict hearing. There simply is no merit to the claim
that he should have called experts during the appeal process.
Petitioner's contention that he failed to raise all the claims contained in the petition
for writ of habeas corpus and that he failed to move for discovery is misguided. Mr.
Epstein was pursuing a remedy in a different forum. He was pursuing a direct
appeal to the Pennsylvania Superior Court. Perhaps had the Lambert family
retained him to file a Post Conviction Relief Act petition after the direct appeals had
been exhausted, this might have been a different story. His appeal to the
Pennsylvania Superior Court would not have been the appropriate place to move for
discovery or to raise the various issues raised in the petition for writ of habeas
corpus.
Mr. Epstein was certainly not ineffective for failing to raise the "six hour rule." He
made a reasonable judgment there was no Duncan/Davenport issue. We
discussed this issue in the section above regarding Mr. Shirk. The same analysis
applies.
Finally, the contention that Mr. Epstein was ineffective for failing to preserve issues
raised by Mr. Shirk has no merit. He chose to proceed with those issues he found to
be meritorious. This was within his professional judgment. Petitioner has not
demonstrated that he was without a reasonable basis for his course of conduct.

Petitioner contends that the District Attorney of Lancaster County has gone on
record as agreeing that she is entitled to relief. This argument appears throughout
Page 513 of 2301
her pleadings and briefs in this and other courts.

This issue arises from a discussion which took place during the habeas corpus
proceeding following Mrs. Show's testimony in the district court's chambers. At that
time, Mrs. Show informed the court and counsel of her new recollection about
seeing Mr. Yunkin's car in the condominium complex on the morning of December
20, 1991. After Mrs. Show's in-chambers testimony, District Attorney
Madenspacher conceded that "some relief. . . is justified in this particular case."
(N.T., Habeas Hearing at 2701.) The district court then asked: "So, are we agreed
that the Petitioner will tonight be released into the custody of Ms. Rainville?" To
which Mr. Madenspacher replied, "I don't see how I can object to that, your Honor."
(N.T., Habeas Hearing at 2704.)
This "concession" has been offered as justification, in and of itself, of Ms. Lambert's
entitlement to the habeas, and now PCRA, relief. To contend that the
Commonwealth has somehow agreed that Ms. Lambert should be released, should
be given a new trial or should be declared innocent, ignores Mr. Madenspacher's
actions on the record of the federal habeas proceeding the very next day. When
court convened, Mr. Madenspacher made an oral motion for reconsideration and a
stay of the district court's order of the previous day granting relief to Ms. Lambert:
MR. MADENSPACHER: . . . .
Yesterday, you Ordered the interim relief of petitioner.
THE COURT: With the consent of the Commonwealth.
MR. MADENSPACHER: Your Honor, I agree I agreed to that. In retrospect, I was
wrong.
I reviewed carefully last night the testimony of what went on inside Chambers, and
I said I still feel that certain significant things have happened regarding Mrs. Show,
and I had an obligation to make that clear to the Court.
But in reading it carefully, you said that: This testimony is totally consistent with
what Miss Lambert has said since 1992.
In retrospect, when I consider that, that is wrong, your Honor.
Miss Lambert consistently since her trial, and even in this proceeding, has
maintained that she was never in that apartment complex.
The significance of Mr. Madenspacher's statement on the day after the "concession"
is that he retracted his statement of the previous day. The Third Circuit took pains
to point this out. In the Third Circuit's opinion on the subject of the District
Attorney's "concession," the court pointed out that the district court "did not
recognize that the Commonwealth withdrew this concession the very next day."
134 F.3d 511 n.11. The Court of Appeals clarified, and this court believes, that the
"concession," to the extent there ever was a concession, to relief, was withdrawn
Page 514 of 2301
on the record at the next available opportunity. We find no basis in this record to
grant relief on the basis of any agreement or concession by the Commonwealth.
In the most recently amended PCRA petition, petitioner sets forth a catalog of
Brady/Giglio violations under the general heading of "A Miscarriage of Justice was
Caused by Many Acts of Intentional Prosecutorial Misconduct." (Exhibit A, Section
B.) These begin at page 14 of Exhibit A and the numbering begins with the number
32 in a series of allegations of intentional prosecutorial misconduct. To address
these Brady/Giglio claims, we will follow the numbering system in the petition. A
discussion of the legal issues raised by these Brady/Giglio claims can be found in
Section III.B.1.a and Section VII.F.2, supra.
We will refer to these as Brady claims, unless otherwise noted. Brady requires the
disclosure of exculpatory material to the defense. Giglio extends Brady to include
material pertinent to the credibility of witnesses.
32. Failed to disclose the identify of the medical people at the crime scene
Corporal Renee Schuler's report of December 31, 1991, contains two references to
ambulance vehicles present on the scene that morning. (Petitioner's Exhibit 1607,
Commonwealth's Exhibit 4.)(104) This report was turned over to Mr. Shirk in
discovery prior to the trial. Mr. Shirk had every opportunity to obtain the identity of
each person from the investigating police officers or from the Community Hospital
or East Lampeter Township Ambulance Departments, interview them and determine
whether to call them as witnesses at trial. They were not kept secret. Brady does
not require that the Commonwealth do the investigative work for defense counsel.
There was no question and no secret about the fact that emergency personnel were
all over the crime scene that morning. As to the allegation that three "medical
people" determined that the victim's carotid artery was severed, that is, in fact, a
miscasting of the evidence. Mr. Zeyak is certain it was severed, Ms. Harrison
testified that she was influenced by Mr. Zeyak's recollection and Mr. May believes it
was severed. This issue is addressed more completely in Section VII.A., supra.
33. Failed to disclose that the Chapmans were at the scene prior to the
medical people
Mr. Chapman was referred to in Corporal Renee Schuler's report of December 31,
1991. (Petitioner's Exhibit 1607; Commonwealth's Exhibit 4.) Mr. Shirk was aware
that he had been in the condominium and had every right and opportunity to
interview him and call him as a witness.
34. Failed to disclose that victim's carotid artery was severed
See Section VII.A, supra.
35. Failed to disclose that Tom Chapman made a call to 911

Page 515 of 2301
1991. (Petitioner's Exhibit 1607; Commonwealth's Exhibit 4.)

Mr. Chapman's identity and his presence at the scene that morning were known to
the police and, through the discovery process, known to Mr. Shirk. In fact, the
report identifies Mr. Chapman as the person making the 911 call.
36. Failed to disclose that Ms. Berry saw Hazel Show leave the school at
7:25
Corporal Renee Schuler's report of January 2, 1992, (Petitioner's Exhibit 2081),
indicates that Mrs. Show spoke to a secretary at Conestoga Valley Junior High
School on the mo rning of December 20, 1991. There has been no showing that the
investigating police officer knew the identity of the secretary or attached any
importance to the identity of the secretary with whom Mrs. Show spoke. There is
no evidence in this hearing of an intentional failure to disclose that name. In fact,
the report reflects that there was a conversation between Mrs. Show and a
secretary and certainly the identity of the secretary could have been easily
determined had defense counsel chosen to contact Conestoga Valley.
This was not a Brady violation. Mr. Shirk was aware from the January 2, 1992,
report that Mrs. Show spoke to a secretary immediately before leaving the school.
The report was among the documents produced to him in discovery. (See
Commonwealth's Exhibit 4.) In her testimony in this court, Ms. Berry testified that
Mrs. Show left the school at "approximately 7:25 a.m." (N.T., PCRA at 52.) It was
necessary for Ms. Berry to review a police report to refresh her recollection. (See
Petitioner's Exhibit 2035) She did not recall looking at the clock. She admitted: "I
don't remember anything definite about what time she left." (N.T., PCRA at 53.)
She recalls that Mrs. Show left prior to the arrival of the secretary who gets in at
7:30 a.m. (Id.) This is far from precise. It is the best recollection available to Ms.
Berry and her testimony was credible to this court. Did the secretary who gets in at
7:30 get in five minutes early or five minutes late? Did Mrs. Show leave ten
minutes before that secretary arrived? Fifteen minutes? Five minutes?
From the various times described by various witnesses in 1992 and at the 1998
PCRA hearing, it is likely that many of these times were approximations and
estimates. There is no evidence that all relevant parties had coordinated their
watches or any testimony that each was going by a certain clock. The only time
that appears to be in any way certain was the time the 911 call was received by
Lancaster County Wide Communications, that is, 7:35 a.m. Given the fact that Ms.
Berry's testimony about time was an approximation and given the fact that there
are variables affecting the time line that morning, Ms. Berry's testimony as
presented to this court in the PCRA hearing was not material in the sense that
there is no showing that it would have changed the outcome of the case in 1992.
37. Failed to disclose interview of a neighbor, Lena Fisher, wherein she

stated she heard screams and saw a man leave at 7:15
In fact, this "man" appears to have been Brad Heisler. What were not "disclosed"
were Corporal Renee Schuler's own personal notes from her interviews and
discussions during the early stage of the investigation. There is absolutely no duty
under Brady or under Rule 305 for a prosecuting officer or investigating officer to
Page 516 of 2301
disclose his or her personal notes. In fact, the subject matter of these "notes" could
reasonably been have viewed as included in the various police reports regarding
the events of that morning. There are reports noting that Brad Heisler was on the
scene, but the reports vary in terms of the timing and location of his presence.
From the various reports, we can conclude that Mr. Heisler came to pick Laurie
Show up for school and that he went into the condominium very briefly after the
Kleinhans went in but before the police arrived. This would be entirely consistent
with Lena Fisher's observations as noted by Corporal Schuler.
Lieutenant Renee Schuler testified at the PCRA hearing that her notes, taken in
shorthand, confirmed an observation by Ms. Fisher, that she saw Brad and another
man "stop and leave." (N.T., PCRA at 3827-28.) She never wavered from this
testimony. If this was Ms. Fisher's recollection, then that would be consistent with
Mr. Heisler's brief visit to the condominium that morning.
Petitioner's argument that this is a failure to disclose material information is
premised on an assumption that the "man" was Lawrence Yunkin and that Corporal
Renee Schuler recorded in shorthand that Ms. Fisher saw the man "stand up and
leave." To accept this version, we must accept the expert testimony on shorthand
from Leola Bennett and of two secretaries from Schnader Harrison Segal & Lewis
that Corporal Schuler actually wrote "stand up and leave" and not "stop and leave."
Lieutenant Schuler testified unequivocally at the PCRA hearing that she used her
own system of shorthand based on what she learned in school and that the symbol
she used was her symbol for "stop" not "stand up." (N.T., PCRA at 3828.)
38. Failed to disclose that Jim and Craig Ellis denied seeing Mr. Yunkin at
McDonald's
39. Failed to disclose that Ms. Bayan saw Mr. Yunkin driving his car on a
street he said he was not on
See Section VII.F, supra.
40. Failed to disclose that Mr. Yunkin said he drove by "twice"

41. Failed to disclose that Ms. Bayan saw the three suspects in the car at
the condominium
42. Failed to disclose that Ms. Bayan saw Mr. Yunkin drive the getaway car
"fast"
Page 517 of 2301
43. Failed to disclose that Mr. Yunkin claimed he was not working on
December 20th
44. Failed to disclose that Mr. Yunkin saw a male student waiting for the
bus and that no one was waiting for the bus that morning
Jay M. Garber testified at the PCRA hearing that he dropped his grandson off at the
bus stop at the entrance to the Oaks Condominium complex that morning. (N.T.,
PCRA at 6082.) This establishes that there was someone waiting for the bus that
morning. There is no proof that the police failed to disclose that Mr. Yunkin told
them he saw a male standing waiting for the bus.
45. Failed to disclose that there were multiple blood stains in the hallway
by the front door
Photographs taken by the Pennsylvania State Police at the Show condominium the
morning of the murder were available for inspection by defense counsel. At the
1992 trial, there was testimony about blood spatter on the wall in the hallway by
the front door.
The only photographs introduced at the PCRA hearing showing blood on the floor in
the hallway were from Compleat Restorations, a company retained to perform
clean-up at the Show condominium. Compleat Restorations came into the
condominium on December 23, 1991, the third day after the murder. In the
interim, police, family, medical personnel, neighbors and friends who assisted in
cleaning up the condominium were in and out of the premises.
To say that the "stains" or "spots" on the floor in the hallway are indicative of
bloody footprints left by the murderer is patently unreliable. Those footprints could
have been placed there by anyone who entered the condominium and walked in the
vicinity of the bedroom.
See Section VII.M., supra.
46. Failed to disclose that the front hallway showed signs of an obvious
struggle
Photographs introduced at the 1992 trial and at the 1998 PCRA hearing clearly
show evidence of some blood spatter on the wall in the hallway. The amo unt of
blood was relatively insignificant in relation to the amount of the blood in the
bedroom. There was testimony at the trial and argument by counsel as to the
amount of blood in the hallway and as to the significance. There was also testimony
regarding markings on the wall. Finally, Trooper Suber's videotape clearly shows
markings on the wall on the inside of the front door consistent with a struggle. This
court finds no evidence of a Brady violation on this point.
Page 518 of 2301
47. Failed to disclose that Mr. Kleinhans went upstairs and saw the blood
in the hallway
Petitioner has produced no evidence that Mr. Kleinhans told the police that he saw
blood in the hallway that morning. He testified in his deposition and he testified in
the PCRA hearing that he saw blood in the front hallway. Mr. Kleinhans testified at
trial but was not asked, by either side, about what he saw in the Show residence.
Mr. Kleinhans is not the only person who observed the front hallway. There has
never been any question that there was some blood in the hallway. Mr. Kleinhans
had nothing to add on this subject.
48. Failed to disclose the unedited video of the river search

It is clear that there were two videos made of the river search, one recorded by
"Smokey" Roberts containing sound and lasting approximately 13 minutes and
another, also recorded by Mr. Roberts from his original tape, lasting approximately
8 minutes and containing no sound.
It is equally clear that the editing to the tape was done by Mr. Roberts before he
gave the tape to the police. See Section VII.K, supra. There is no proof that the
police cut, edited, changed or altered the videotape of the river search. It appears
that Mr. Roberts made the decision to remove the sound.
This court had the opportunity to view the edited and the unedited videotapes on
several occasions during the hearing. We viewed the footage of Detective Barley
bending over and looking at what appears to be a pink trash bag. We heard the
statement, "What do you got, a bag?" and we saw Detective Barley wave at the
camera at that time. To this court, sitting as fact finder, there is nothing about the
unedited, longer tape which appears to be in any way sinister or problematic.
Detective Barley's "wave" seemed to be little more than an indication that there
was nothing of significance. It was not the hurried "let's keep the cameras away
from this important evidence" gesture as argued by petitioner. All that the unedited
tape shows is that Detective Barley found a bag and that it appeared to be a pink
trash bag. The edited version, viewed by Mr. Shirk prior to trial shows a pink bag
as well. The edited tape was provided to Mr. Shirk and he testified that he viewed
that tape. (N.T., PCRA at 3363.) He was, therefore, aware that there was a tape
made of the river search and that a pink bag was found during the course of that
search. A police report produced to him referred to the tape as "edited."
(Petitioner's Exhibit 1295; Commonwealth's Exhibit 4.)
Mr. Shirk could have asked to see the unedited tape. His failure to do so was not
ineffective or negligent. The bottom line is he knew that a pink trash bag was
located by the police and if he thought there was some significance to that, he
could have pursued the issue in further discovery or in questioning witnesses at
trial.
Petitioner's counsel would have the court believe that a pink bag was discovered
containing incriminating evidence (presumably to Mr. Yunkin) which was then
emptied of its contents (inculpatory to Mr. Yunkin; exculpatory to Ms. Lambert) and
then repacked in ice so that someone (presumably Detective Barley) could be
Page 519 of 2301
filmed digging around the bag with the tip of his shoe and a stick to demonstrate
that the bag was embedded in ice. There is simply no proof that this took place.
There are only the bald assertions of petitioner's counsel.
The important facts are that Mr. Shirk knew there was a search of the river, knew
who was involved, knew that a tape was made, knew that the tape had been
edited, viewed that tape, knew that a pink bag was found and had every
opportunity to question police witnesses, Mr. Yunkin, and his client, and to develop
the significance of those points at trial.
49. Failed to disclose that the phone cord was broken in half
In fact, photographs taken by the state police at the crime scene show the phone
cord broken in half. This is neither consistent nor inconsistent with Ms. Lambert's
testimony. The fact that Ms. Buck threw the phone across the room does not
necessarily mean the phone cord snapped. The fact that the cord was snapped does
not necessarily mean that the phone was thrown. It appears clear that the phone
cord snapped or was broken during the course of the struggle that morning. The
struggle was described by both Ms. Lambert and Ms. Buck, each with a different
perspective. Photographs of the victim's bedroom showing her legs and feet clearly
depict a torn telephone cord. (See Petitioner's Exhibits 1742, 1747, 1749, 1749-A.)
See Section VII.M, supra.
50. Failed to disclose that a sneaker was found by the river

A sneaker was found in the Pequea Creek, which empties into the Susquehanna
River. This was well described at the PCRA hearing. (N.T., PCRA at 823-24.) The
sneaker found was a canvas sneaker packed with mud and showing signs of what
was described as "black rot." This black rot suggested to Detective Barley that the
sneaker had been a denizen of the deep for longer than two or three days.
Detective Barley made the decision that the sneaker was of no evidentiary value
and, as would be common practice with anything, fish or otherwise, caught in a
river and determined to have no value, he threw it back. The police are not
required under Brady or any other authority to disclose to the defense every
insignificant item disclosed during a search. Does Brady require that the police, in
making a search of a creek and river bed and banks, catalog and save every item
located? There is nothing to indicate that the sneaker found in the creek had any
evidentiary value at all. Nothing learned in the PCRA hearing would suggest that
Detective Barley found a sneaker that had any significance to this case. That is the
bottom line for a Brady analysis.
51. Failed to disclose that a clump of hair was found precisely where Ms.
Lambert testified Ms. Buck threw it
The "finding" of a clump of hair "precisely where Ms. Lambert testified Tabitha Buck
threw it" resulted from petitioner's counsel's enlargement of a photograph and their
opinion that an item in that enlarged photograph constitutes a clump of hair.
Page 520 of 2301
(Petitioner's Exhibit 1785.) The clump of hair was not visible on the small
photograph. The photograph was produced to Mr. Shirk in 1992. This is really a
claim that Mr. Shirk was not as diligent as Ms. Rainville in having the photograph
enlarged so as to identify a clump of hair. There is no merit to this as a Brady
violation or as an ineffective assistance of counsel claim.
More importantly, there was hair, or clumps of hair, found on the floor of Laurie
Show's bedroom in the course of the investigation. In fact, Mr. Shirk went to the
trouble, and the County went to the expense, of hiring a hair and fiber expert to
testify at the 1992 trial. The expert testified that the hair was cut, not pulled or
torn. (N.T., Trial at 980.)
It is difficult to imagine that a clump of hair, conclusively established by the
defense at the 1992 trial to have been cut by a knife, would fall anywhere
"precisely" where someone threw it during the kind of struggle described by all
participants. Mr. Shirk knew there was hair on the floor of the bedroom and he
made every effort to make use of that testimony in his defense of Ms. Lambert at
trial. His use of expert testimony and his arguments were in an effort to confirm
Ms. Lambert's story that Ms. Buck went after Laurie Show with a knife and cut off
pieces of her hair. (105) The expert confirmed that the hair was cut with a sharp
object. (N.T., Trial at 980.) There certainly was no Brady violation here.
52. Failed to disclose that a bloodhound found the rope based on Ms.
Buck's scent
See Section VII.D.3, supra.
53. Failed to disclose that Scott Hershey told the prosecution that Laurie
wanted to get even with Michelle and Brad had heard rumors Lawrence
was going to beat him up
54. Failed to disclose Officer Fassnacht's report of Mr. Yunkin's rape of Ms.
Show
Two East Lampeter Township police reports refer to the allegation that Lawrence
Yunkin raped Laurie Show. These reports were each produced to Mr. Shirk. (See
Commonwealth's Exhibit 4.)
The first report was Corporal Renee Schuler's report dated January 2, 1992. At
page 7 of that report, Officer Schuler related the facts of a previous harassment
incident which occurred at Root's Market in September 1991. The report contains
the following sentence: "This was the first time Hazel mentioned to Lambert that
Laurie was raped by Yunkin." On page 8 of the same report, Officer Schuler related
a conversation John and Hazel Show had with their daughter regarding her
involvement with Mr. Yunkin. Page 8 of Officer Schuler's January 2, 1992, contains
the following sentence: "Hazel then spoke to Laurie about this and Laurie indicated
Page 521 of 2301
she had been raped by Yunkin."

Commo nwealth's Exhibit 4 contains a copy of another East Lampeter Township
police report dated August 10, 1991. It concerns Incident No. 3648-1991 which
apparently was an investigation of an ongoing harassment by Ms. Lambert of Laurie
Show. The report is prepared by an officer who is not identified on the report. The
officer refers to working with Officer Abram but does not identify himself or herself
on the report. This report was produced to Mr. Shirk and contains the following
sentence: "Show only last night told her mother that Yunkin raped her in the end of
June, while they were in Yunkin's van. After that, she left him." (See
Commonwealth's Exhibit 4.) The record of this case proves that there was no
Brady violation.
55. Failed to disclose that Larry Ware heard Mr. Yunkin say he would be in
jail for murder
In Corporal Renee Schuler's report dated January 10, 1992, at page 3, there is a
reference to a discussion involving Larry Ware and Hector Feliciano. This refers to
Mr. Yunkin's speaking of not being at work on December 23, 1991, because he
would "be in jail." This report was provided to Mr. Shirk during discovery. Whether
there was a specific disclosure about Mr. Ware actually hearing Mr. Yunkin say he
would be in jail for the murder is unclear. Certainly the report identifies Mr. Ware,
identifies Mr. Feliciano and refers to the conversation in question. Had Mr. Shirk
wished to pursue this, this information was available during discovery.
As to whether this was a Brady violation, the question of "materiality" warrants
discussion. Mr. Shirk testified at the PCRA hearing that he specifically stayed away
from this area of testimony at trial. He did not put Mr. Feliciano on the stand to
testify as to Mr. Yunkin's statement. Mr. Shirk described in clear terms that he
wanted to avoid associating any of the three participants with any evidence of
premeditation or specific intent. (N.T., PCRA at 3474-75.) Mr. Shirk explained that
had he established that Mr. Yunkin was expressing an intention to kill someone,
then that "specific intent" could have been ascribed to his own client. Ms. Lambert
was constantly in Mr. Yunkin's company and undoubtedly was in Mr. Yunkin's
company on the morning of December 20, 1991.
It appears that the information which is the subject of this alleged Brady violation
was made known to Mr. Shirk. It does not appear that it was in any way "material"
to the defense. In fact, Mr. Shirk was aware of the information, was aware of the
conversation in which Mr. Yunkin is reported to have stated that he was going to
kill someone, and specifically chose not to use that information. There certainly was
no Brady violation here.
56. Failed to disclose that Mr. Kenneff told the Yunkins to stop sending
money to Ms. Lambert
In fact, there is no evidence that Mr. Kenneff told Lawrence Yunkin's parents to
stop sending money to Ms. Lambert. It has been established through the testimony
Page 522 of 2301
of Mr. Cody, counsel for Mr. Yunkin in 1992, that it was Mr. Cody who told the
Yunkins to cease any further contact with Ms. Lambert when she was in prison. This
was confirmed by Lawrence Yunkin's mother, Johnnie May Yunkin. (N.T., PCRA at
6462, 7592.)
57. Failed to disclose that the prosecution found a license plate in the back
of Yunkin's car
During an inventory search of the Yunkin car, a license p, late was discovered. The
license plate corresponded with a license number contained in Officer Bowman's
notes.
Petitioner's theory of the case is that Mr. Yunkin drove in the condominium complex
in a vehicle with a license number YHM-028 and that later in the day to hide this
fact, he changed the license plate and left the YHM-028 license plate in his car. The
specific Brady claim is that the police knew he was seen in the condominium
complex with the YHM-028 license plate and that they later found the incriminating,
material license plate in his car and failed to disclose this to Mr. Shirk.
In fact, Ms. Lambert testified in the PCRA hearing that she was with Mr. Yunkin the
entire day.(106) Ms. Lambert at no time observed Mr. Yunkin changing a license
plate on his car. Further, the license plate on the brown Mercury which was driven
by Mr. Yunkin that morning and the YHM-028 license plate found inside the car
were both registered to Mr. Yunkin. Detective Savage testified that he or Officer
Bowman ran the license plate found in the car and found that it was registered to
Mr. Yunkin. (N.T., PCRA at 4428-31.) Its use as perhaps hiding Mr. Yunkin's
presence in the condominium was eliminated. Why would Mr. Yunkin place a license
plate on his car, registered to another vehicle in his name, to mislead the
authorities as to his presence that morning?(107)
58. Failed to disclose that at least one eyewitness reported seeing this
license plate at the crime scene on the morning of the murder
See discussion of Brady/Giglio claim 57, supra.
59. Failed to disclose Mr. Yunkin's letters to Shawn Lapp
Petitioner claims that these letters demonstrate that Mr. Yunkin was lying to Ms.
Lambert in his letters to her in prison, demonstrate that Ms. Lambert believed Mr.
Yunkin was a rapist, and demonstrate that Laurie Show had filed charges for rape
against Mr. Yunkin. Petitioner has not established any relevance or materiality of
this information. This evidence links to Ms. Lambert's "Burgess theory" that she
was manipulated by Mr. Yunkin, abused by Mr. Yunkin and afraid of criminal
Page 523 of 2301
charges from Laurie Show.

Further, the "Burgess" evidence is relevant only to a very limited issue which, as
the case has developed, is not being pursued by the Commonwealth. The Shawn
Lapp letters are only material to the extent that they relate to the expert opinion of
Dr. Burgess, i.e., that Mr. Yunkin manipulated Ms. Lambert. This opinion is not
relevant under Pennsylvania law. Therefore, the letters are not material. There has
been no showing of materiality necessary to establish a Brady violation.
60. Failed to disclose that the victim had identified the killers by writing in
her own blood
Petitioner makes the claim that the Commonwealth should have disclosed
something that was never there. At the 1992 trial, Mr. Shirk argued that Laurie
Show had written the initials "TB" for Tabitha Buck and "B" for Buck. At the federal
hearing, petitioner's counsel added the initials "BY" for "Butch" Yunkin. Mr. Shirk
argued that Laurie Show's dying act was not to identify "Michelle" but rather to
write "TB" on the closet door. This was the subject of expert testimony by John C.
Balshy, a crime scene investigator who first "discovered" the "TB" initials in blood.
This court had every opportunity to view at trial the photographs referre d to by
Messrs. Shirk and Balshy and found that the initials were not there. The court did
not accept Mr. Shirk's argument on this point and did not accept Mr. Balshy's
expert testimony that the initials were written in blood on the closet door.
Ms. Lambert contends it is a constitutional violation for the Commonwealth not to
anticipate a creative and ultimately unsuccessful argument based upon an
interpretation of evidence to create an issue that might possibly distract, confuse or
miscast the truth in the interest of raising a reasonable doubt at trial. In fact, Mr.
Shirk made a valiant effort to argue the existence of something that really was not
there. He did that in good faith to make every possible use of every possible item
of evidence in Ms. Lambert's defense. He based his argument on the "findings" of
Mr. Balshy, which this court, or fact finder, considered and did not accept. There is
no indication anywhere that the initials "BY" appear anywhere in Laurie Show's
bedroom, let alone on the carpet or the closet door.
To demonstrate the problems with this claim, we look to the testimony of Richard
W. Jeffries at the PCRA hearing. Mr. Jeffries is a licensed private investigator who
was court appointed to assist Mr. Shirk in the defense of Lisa Michelle Lambert in
1992. (108)
In the PCRA hearing, Mr. Jeffries testified in the Commonwealth's case about the
"TB" initials. He stated that Mr. Balshy contacted him in 1992 with the "revelation"
that he had found Tabitha Buck's initials in blood on the closet door. Mr. Jeffries
demonstrated that his ability to analyze evidence was not colored by the side he
represented when he candidly acknowledged that he did not agree with Mr. Balshy.
He did not agree with Mr. Shirk's use of Mr. Balshy as a witness in 1992. In fact,
Mr. Jeffries testified before us in 1998 that he looked at the photographs which had
been enlarged by Mr. Balshy and determined that the initials "seen" by Mr. Balshy
on enlargement would have, in fact, been one- half to three-quarters of an inch
high. Mr. Jeffries found it unlikely, and this court completely agrees, that a person
in the condition of Laurie Show after her killers left the condominium could have
Page 524 of 2301
been capable of crawling across the floor and inscribing in rather minu, te
characters several initials of her killers on the closet door. (109) (N.T., PCRA at 7693.)
61. Failed to disclose Mr. Yunkin's admission that he sometimes wore the
earring found at the crime scene
There is no evidence that Mr. Yunkin wore the earring found at the crime scene.
There was evidence that Mr. Yunkin wore an earring similar to that earring. In fact,
it appears that there are many, many earrings similar to that which was found on
the floor of the condominium.
At trial, Mr. Shirk was aware and questioned Mr. Yunkin about the fact that Mr.
Yunkin wore a similar earring on occasion. This was an important point of Mr.
Shirk's defense and was fully litigated and fully argued to this court. This issue is
more fully developed in Section VII.N, supra. The possibility that the earring found
in the Show condominium was worn by Mr. Yunkin at the time of the murder was
well presented to this court. It did not affect the outcome of the trial. That, in itself,
is proof that the information was not material for Brady purposes.
62. Failed to disclose that Pat Fry described the two suspects as having
"broad shoulders or bulky clothes"
Officer Jere Schuler of the West Lampeter Township Police Department interviewed
Fred Fry at his residence on the day of the murder. Officer Schuler's report is dated
January 2, 1992, and was one of the police reports provided to Mr. Shirk in
discovery. (See Commonwealth's Exhibit 4.)
In the report, Officer Schuler related a description given of the two suspects who
Mr. Fry saw at approximately 7:12 a.m.: "Both appeared to be between 5'5" and
5'8"." He described both as being "none too slim." He felt they both had "bulky
clothing on."
A report of Officer Bowman's meeting with Mr. and Mrs. Fry on December 22, 1991,
was also contained in the materials provided to Mr. Shirk in discovery. This report
describes a meeting where Officer Bowman showed various items of clothing which
had been recovered during the investigation. The Frys felt that the Miami Dolphins
jacket looked familiar but were unable to identify any of the other items of clothing
with any degree of certainty.
Officer Jere Schuler also interviewed Pat Fry on the morning of December 20, 1991.
Mrs. Fry described two individuals who she believed were female wearing hooded
sweatshirts or jackets. This report was dated January 2, 1992, and was provided to
Mr. Shirk in discovery. (See Commonwealth's Exhibit 4.)
63. Failed to disclose that the Frys thought the two people they saw wer, e
Hispanic
The e, thnic origin of the two people seen by the Frys was never an issue
Page 525 of 2301
and would certainly not have effected the outcome of the trial. Officer Jere
Schuler interviewed Mr. and Mrs. Fry. His report of January 2, 1992,
contained a summary of the interview and was produced to Mr. Shirk. (See
Commonwealth's Exhibit 4.) Neither Mr. nor Mrs. Fry could provide a
description of the faces of the two people they observed. The reference to
"appearing Hispanic" comes from Sergeant Carl Harnish's narrative
account of what he heard from various police officers that morning. There
is no report of the Frys making this statement to anyone.
64. Failed to disclose that the Gladfelters were two of only eight people on
Yunkin's visitor list in prison
There is no obligation on the part of the Commonwealth to disclose a
material witness's prison visitor list. Failure to disclose that which defense
counsel can access on his own is not a Brady violation.
65. Failed to disclose that Mr. Fry said it was "too dark" to see
66. Failed to disclose that Laura Thomas had made a false kidnaping report
Ms. Thomas never made a false report to law enforcement regarding a
kidnaping. See Section VII.I, supra.
67. Failed to disclose that Pat Fry said the person wearing the Miami
Dolphins jacket was wearing black sweatpants
68. Failed to disclose that neither Laura Thomas nor her father, Floyd
Thomas, said anything about "slit her throat" in their initial interviews
All the police reports involving discussions with Laura Thomas and Floyd
Thomas were disclosed. If there were inconsistencies between early
reports and subsequent reports, these inconsistencies were available to
defense counsel for cross-examination purposes. In fact, Mr. Shirk made
good use of these inconsistencies.
Commonwealth Exhibit 4 contains a report of Officer Bowman's interview
of Laura Thomas on January 2, 1992. Interestingly, this report describes
one of the plots to kidnap Laurie Show: "Lambert would then take Show,
tie her to a phone pole and shave her head and 'slit' Laurie's throat."
Certainly, Mr. Shirk was aware of this interview by virtue of the
Commonwealth's response to his discovery request.
Page 526 of 2301
This report is somewhat inconsistent with Corporal Renee Schuler's report

of January 10, 1992, regarding an interview with Laura Thomas on January
5, 1992. Ms. Thomas at that time related Ms. Lambert's plans to do harm to
Laurie Show but did not mention anything about "slitting her throat."
Again, this document was available to Mr. Shirk. To the extent that there
was an inconsistency between the two reports, he was in a position to
question Ms. Thomas about her interviews with the police. There was no
failure to disclose. For further discussion of this issue, see Section VII.I,
supra.
69. Failed to disclose that Tabby had admitted her prior involvement in a
murder in Alaska
There was no evidence offered at the PCRA hearing on this claim. This
evidence would not be admissible at trial.
70. Failed to disclose that Woody Woodward knew that Tabby had fought
Laurie
71. Failed to disclose that Rick Lentz saw Tabby fight Laurie and heard
Tabby tell Laurie that she was "going to get her"
This claim involves evidence of Tabitha Buck's animus or bad acts prior to
the murder. The Commonwealth has no duty to discover, uncover or relate
to the defense negative information about a co-defendant. In fact, the
Commonwealth at all times asserted that Tabitha Buck was involved in the
killing. Evidence which would establish Ms. Buck's motive or conduct
would in no way exculpate Ms. Lambert. Such evidence simply would not
be material to this case. See Section VII.D.2, supra.
72. Failed to disclose that the rope found around the body was 12 feet
long, not 23- feet or 24-1/2 feet as testified to, and not 22' 5" as the
rope in evidence appears to be
The rope was at all times available to defense counsel to be measured. The
significance of mistakes in measurement or discrepancies between reports
about the lengths of the various ropes seems questionable at best. After
extensive testimony and argument, this court does not find the
inconsistencies to be material. We do not believe Brady places an
affirmative duty to disclose the respective lengths of the various ropes.
The Commonwealth produced these ropes to defense counsel for
inspection. They could have been tested, compared and measured in the
discretion of defense counsel. The Commonwealth certainly met its duty of
disclosure as to the ropes.
Page 527 of 2301
73. Failed to disclose that someone fabricated a story that Hazel Show had
called home and spoken to Laurie from the school, and that Laurie had told
her mother that Michelle was there or on her way over
This is one version of the events of that morning which is reflected in
Sergeant Harnish's report. (Petitioner's Exhibit 1351.) It is likely that this
version reflects a misunderstanding that was communicated during the
course of the confusion that morning. This information is not in any way
exculpatory or favorable to petitioner.
74. Failed to disclose that Officer Weaver was not dispatched to crime
scene
The dispatch reports were available to defense counsel, as they were
available to counsel for the Commonwealth. In fact, Officer Weaver was
not specifically directed to report to the condominium. However, he heard
the call over his radio, was in the vicinity and followed proper procedure
and responsible conduct in responding to the call.
This "fact " is material only to the conspiracy theory which first surfaced at
the federal habeas hearing and was a significant part of the PCRA hearing.
Under the conspiracy theory, Robin Weaver went to the condominium
without being officially dispatched so as to begin his "frame up" of Ms.
Lambert. The conspiracy theory was never even suggested by the defense
at trial. Simply stated, there was absolutely no significance at trial as to
whether Officer Weaver was dispatched to the scene. The information was
not "material" under Brady and Giglio.
75. Failed to disclose that Ms. Lambert's telephone records showed no

telephone calls to the Show residence
During the period of time when Ms. Lambert was making the many
harassing and threatening phone calls to the Show residence, she was
making them from her apartment on Route 340 in Bridgeport. This is
within the same township as the Show home and then would have been
local calls. Detective Savage testified that he looked into telephone records
and determined that the telephone company did not keep records of local
calls. (N.T., PCRA at 4343-4350.) When Ms. Lambert and Mr. Yunkin moved
to Pequea, a rural township on the southwest of Lancaster City, they had
no telephone. It appears that there were no records to disclose.
76. Failed to disclose that the dispatch records show that Detective Savage
arrived on the scene at 9:17
There was testimony that the recorded time of Detective Savage's and two
other police officers' arrival at the scene was made arbitrarily. It is clear
that this record does not accurately reflect the time when any of them
arrived or left. (N.T., PCRA at 4690-4725) Lancaster County Wide
Page 528 of 2301
Communications relies upon the officers to report their time of arrival.

Detective Savage, Officer Bowman and Corporal Schuler were all recorded
by Lancaster County Wide Communications as arriving at 9:17 a.m. In fact,
they each arrived earlier than 9:17 a.m. It seems likely that one of the
group, or someone else, reported them as present at 9:17 a.m. The time
coincides with the report by Officer Jan Fassnacht that he left the scene at
9:17 a.m.
77. Failed to disclose that Hazel Show failed to tell many people at the
murder scene that Laurie spoke until two hours after the murder
All police reports regarding what Mrs. Show said and what Mrs. Show did
not say on the morning of the murder were available to defense counsel.
Defense counsel had every available opportunity to raise these
discrepancies. In fact, petitioner's contention is not true. Mrs. Show told
Lisa Hinkle Billiter almost immediately after Laurie's death that Laurie had
spoken to her. See discussion of Laurie Show's Dying Declaration, Section
VII.A, supra.
78. Failed to disclose the postcard that Mr. Yunkin wrote Hazel Show
immediately after the murder, setting up Ms. Lambert
The phrase "setting up Lambert" is purely a product of petitioner's
counsel's argument. The postcard from a material witness to the mother of
the victim, having been reviewed by the court, does not appear to be
material. In fact, Mr. Shirk testified that the postcard was not exculpatory.
The contents of the postcard are reprinted in Section VII.G, supra. Further,
Mr. Shirk testified at the PCRA hearing that the postcard was not
exculpatory as to Ms. Lambert. (N.T., PCRA at 3520-21.)
79. Failed to disclose that the tip of the knife was in Buck's jacket
There is no clear evidence as to the location of the tip of the knife. Ms.
Buck testified that she put the tip of the knife in the pocket of her Dolphins
jacket and that she later discarded the tip at the Lambert/Yunkin
residence. Judge Cullen, then court-appointed counsel to Ms. Buck in 1992,
testified that he felt something sharp and metallic when he reached into
the jacket pocket during his closing argument in the Buck trial. He never
looked into the pocket and only assumed it was the tip of the knife. (N.T.,
PCRA at 7713.) Even if the tip of the knife was in Ms. Buck's jacket, that
does not exculpate Ms. Lambert in any way. It is, in fact, consistent with
Ms. Buck's story that Ms. Lambert at some point handed her the tip of the
knife and she put it in her jacket pocket. The Dolphins jacket was available
for inspection by Mr. Shirk at all times. There is no testimony to establish
that the Commonwealth ever knew that the knife tip was in the jacket
pocket. It stands to reason that the Commonwealth would have used the
knife tip as evidence at both the Lambert and Buck trials.
80. Failed to disclose that witnesses saw Ms. Buck wearing her sweatshirt
Page 529 of 2301
inside-out at school
Carol Blackburn testified that Ms. Buck was wearing a white or gray or offwhite sweatshirt turned inside out when she reported to school after the
murder. (N.T., PCRA at 1119.) She was as available to defense counsel as
she was to the Commonwealth for an interview before trial. It is not a
Brady violation to fail to disclose information that is readily available to
the defense.
81. Failed to disclose that Ms. Buck's hands were swollen

Donna Mallik testified at the PCRA hearing that Ms. Buck's hands seemed
swollen. (N.T., PCRA at 3677.) She also testified at the 1992 trial, (N.T.,
Trial at 601-06), and could certainly have been cross-examined as to her
observations of Ms. Buck's hands. Again, Ms. Buck's involvement in the
murder, the conditions of her hands, the identity of her clothing, the
condition of her face and anything else which might implicate her does
nothing to exculpate Ms. Lambert. At all times, the Commonwealth offered
its theory of the case that both girls were present in the condominium and
both girls participated in the murder.
See Section VII.D, supra.
82. Failed to disclose that Ms. Buck admitted that her hands hurt on the
morning after the murder
83. Failed to disclose Officer Flory's interview with Laura Thomas

The interview was conducted at Conestoga Valley High School on the day
of the murder. There is a brief account of the discussion in Officer Flory's
report of January 17, 1992. The report does not contain Brady material.
Further, Mr. Shirk's cross-examination of Laura Thomas at trial
demonstrated that he was well aware of the facts related by Ms. Thomas
to Officer Flory.
84. Failed to disclose Officer Flory's interview with Brad Heisler

of the murder and was described by Officer Flory in his report of January
17, 1992. The report of the discussion does not contain Brady material.
85. Failed to disclose that Hazel Show saw Mr. Yunkin drive away from the
scene in the complex
Page 530 of 2301
It is unclear that Mrs. Show saw Mr. Yunkin drive away from the complex
that morning. Her recollection, to the extent that she had one in 1991 and
1992, was communicated to Detective Savage. She was not able to give
him any specific information. From these facts, it is difficult to determine
exactly what Detective Savage should have disclosed. Mrs. Show did
testify that Detective Savage told her to let him know if her memory about
seeing a car that morning became clearer. See discussion of Hazel Show's
Recollection, in Section VII.G, supra.
86. Failed to disclose that Ms. Buck's sweatshirt had Laurie's blood on it
Petitioner has failed to establish that the white sweatshirt in evidence was
Ms. Buck's sweatshirt. The white sweatshirt which was marked Petitioner's
Exhibit 1002 was also introduced at the trial of this case in 1992. It is
identified on the evidence envelope as "white sweatshirt with blood stain
located on floor to victim's right side." It was examined by Donald Bloser
on March 13, 1992.
Ms. Buck has acknowledged that she was wearing a white sweatshirt at
the time of the murder. She also testified that she wore her Miami
Dolphins jacket in the Show condominium that morning. (N.T., PCRA at
6665-66.) This fact alone would make it highly unlikely that the white
sweatshirt worn by Ms. Buck would have any blood on it since it was
covered by a heavy jacket. Petitioner has asked the court to make a leap
from Ms. Buck's testimony about wearing a white sweatshirt to the
conclusion that the white sweatshirt in evidence was Ms. Buck's.
Petitioner's counsel showed the white sweatshirt, turned inside out, to
Carol Blackburn, the attendance officer at Penn Manor High School, during
the PCRA hearing. Ms. Blackburn acknowledged that the white sweatshirt,
worn inside out on Ms. Buck when she reported to school on December 20,
1991, was similar. She also acknowledged that there was nothing unique
about the sweatshirt and it was not unlike any other "whitish" sweatshirt.
(N.T., PCRA at 1123.)
In order to establish a Brady/Giglio violation on this issue, petitioner
should first establish that the white sweatshirt that "had Laurie's blood on
it" was, in fact, Ms. Buck's. She has not done this. She, therefore, has not
established a Brady violation.
See Section VII.M.3, supra.
87. Failed to disclose that Ms. Buck's sweatshirt had cuts in it made by a
sharp object
Ms. Buck testified at the PCRA hearing as to the appearance of the
sweatshirt she was wearing on the morning of the murder: A. It's white,
long sleeved with blue decorating glue that I had used, made it myself,
Page 531 of 2301
had my name in the upper left hand corner and on the back it had 1992.
Q. So it had your name, Tabby, on it?
A. Yes.
Q. And it had 1992 on the back.
A. Yes.
Q. That was printing you placed on the sweatshirt yourself?
A. Yes.
(N.T., PCRA at 6625.)
Ms. Buck did not leave her sweatshirt in the Show condominium when she
and Ms. Lambert left that morning. When questioned as to what she was
wearing when she went to school later that morning, she testified:
Q. When you arrived at school that day, what were you wearing on the
upper part of your body?
A. The same sweatshirt I was wearing that morning.
Q. That's the same sweatshirt you described to us?
A. Yes.
(N.T., PCRA at 6659-60.)
By Ms. Buck's description, her sweatshirt was different from the one that
was entered into evidence in 1992. There has never been any proof that
the sweatshirt found at the crime scene was, in fact, Ms. Buck's
sweatshirt. Ms. Lambert contends that the police obtained Ms. Buck's
white sweatshirt during the investigation and then brought it back to the
condominium to put in the "staged" crime scene photographs. There really
is no proof of this, however. In fact, Ms. Buck describes a sweatshirt that
is different from the sweatshirt which was found in the condominium and
which appeared in the photographs. There can be no Brady/Giglio violation
on this point because there is no proof that the sweatshirt was, in fact, Ms.
Buck's.
88. Failed to disclose that Ms. Buck's sweatshirt appeared in the "faked"
crime scene photos
Whether the crime scene photographs were "faked" is discussed in Section
VII.M, supra. Regardless of whether the photographs were real or "faked,"
a white garment appears next to the body of Laurie Show. These
Page 532 of 2301
photographs were available to the Commonwealth and to the defense

before and during trial. It is difficult to imagine how there could be a Brady
violation for failing to disclose what appears on a photograph produced to
defense counsel.
89. Failed to disclose that the rope obtained by police at K- Mart came in a
bag with a picture of a man pulling a Christmas tree
The package of the new rope which was introduced at trial to show the
similarity between the rope at the crime scene and the rope purchased by
Ms. Lambert at K- Mart showed a man pulling an evergreen tree, for
whatever relevance that might have. The rope was obtained in the course
of the Commonwealth's trial preparation. It does not constitute Brady
material.
90. Failed to disclose that the rope found at the river was 24" long, not
24.5 feet, as testified to by Detective Savage to Lambert's trial
91. Failed to disclose that the rope purported to be found at the crime
scene was 22 feet 5 inches
92. Failed to disclose that Ms. Buck's jacket had blood on it
In fact, in the testing done on the jacket prior to the Lambert trial, no
blood was found on the Buck jacket. Donald Bloser, of the Pennsylvania
State Police crime lab, testified that he took samples from discreet
sections of Ms. Buck's Miami Dolphins jacket and found no blood. (N.T.,
Trial at 609; N.T., PCRA at 194.) After the Lambert trial and in preparation
for the Buck trial, Mr. Bloser examined the jacket more thoroughly for
blood and found some blood in the area of the hood. The Commonwealth
was not aware that there was blood on the Buck jacket prior to the
Lambert trial. There was, therefore, nothing to disclose. In any event, this
information is not material for purposes of a Brady analysis.
93. Failed to disclose that Dr. Annese (a) worked with Hazel Show, (b) had
Mrs. Show over to his home for a party, (c) treated Laurie, (d) had treated
patients referred to him by Dr. Show, and (e) had received financial
benefits from Dr. Show's referrals
No testimony or any other evidence at the PCRA hearing established that
the Commonwealth had any knowledge of any relationship between Dr.
Annese and the Show family prior to the 1992 trial. Dr. Annese testified in
1992 and was available for cross-examination by the defendant as to the
basis for his opinions and as to any bias, interest or motive. At the PCRA
hearing, petitioner failed to establish that Dr. Annese's minimal
Page 533 of 2301
involvement with the Show family in any way colored his trial testimony.
This is not a Brady violation for two reasons: (1) the information is not
"material" as that term is defined for Brady purposes; and (2) there is no
proof that the Commonwealth was aware of any relationship prior to trial.
94. Failed to disclose that Mr. Kleinhans saw Brad Heisler enter the
apartment prior to the police or medical personne l
95. Failed to disclose that the front door of the Show condominium was
"wide open" for Mr. Heisler and Mr. Kleinhans to enter and thus the door
neither closed nor locked automatically
96. Failed to disclose that Mr. Yunkin described the woman who waited on
him at McDonald's as white, older and with grayish hair, when he was
interviewed by the police in early 1992
Mr. Yunkin testified at the PCRA that he told the police that the person who
waited on him at the McDonald's was "an older woman and that she was
white." (N.T., PCRA at 4515.) This was not in a report provided to defense
counsel. Petitioner appears to contend that this information would have
been impeachment material for Yvette Rodriquez at trial. Ms. Rodriquez
testified that she was the manager at the McDonald's that morning and
that she observed Mr. Yunkin. She was not sure that she served him. (N.T.,
Trial at 592.) An inconsistency between Mr. Yunkin's description of the
person who served him and the actual appearance of Ms. Rodriquez is not
Brady material. There is nothing about this information which is
exculpatory or favorable to Ms. Lambert, nothing which would affect the
outcome of the case and nothing of any consequence which would impugn
the credibility of either Mr. Yunkin or Ms. Rodriquez.
97. Failed to disclose that the person who took the 7:35 a.m. call to 911
determined that Laurie Show was unconscious from the information
provided in the telephone call, and had training to make that
determination
According to the testimony of Richard Harrison of Lancaster County Wide
Communications, the 911 operators did not have formal training in
classifying calls as "unconscious person" or some other classification.
(N.T., PCRA at 4703-04.) He testified that "back in 1991 it was more or
less our in-house training and on-the-job experience at that time." (N.T.,
PCRA at 4704.)
The inference here is that a 911 operator/dispatcher made a diagnosis
that Laurie Show was "unconscious" based upon information give to
him/her with the benefit of sufficient training to make that determination.
Page 534 of 2301
It appears from Mr. Harrison's testimony that there was not this kind of
training. It also appears from his testimony that "unconscious person" is
their highest level of priority and is a code used when someone is in a life
threatening condition. Whether Laurie Show was conscious or unconscious
when the 911 call was made, there is no question that she was in a very
serious and life threatening condition.
In any event, the 911 dispatch records were available to defense counsel
in 1992 if he believed these were material. There can be no Brady violation
for the failure to disclose information that could have been obtained by
defense counsel.

Petitioner contends that she must be released and cannot be retried under
Smith. In Section III.B.1.a, supra, we discussed the legal impact of Smith
in this case. Essentially, if the conduct of the prosecution in this case was
intentionally undertaken to prejudice Lisa Michelle Lambert to the point
that she was denied a fair trial, then Smith would apply and double
jeopardy would bar any subsequent retrial on these charges.
At various points in Section VII, supra, we discussed the allegations of
prosecutorial misconduct. We reviewed the claims regarding the "29
questions," Lawrence Yunkin's statement, Kathleen Bayan's story, the
involvement of Dr. Mihalakis, the river search, Ms. Lambert's statement,
and the crime scene photographs. In addition, we reviewed 66 allegations
of discovery or Brady/Giglio violations. We have considered all of these
points in our analysis of whether there was prosecutorial misconduct
under the PCRA, new evidence exculpatory to petitioner, or constitutional
violations of the Commonwealth's duty of disclosure. We have also
considered each of these allegations insofar as they might establish
intentional prosecutorial misconduct undertaken to prejudice defendant to
the point of the denial of a fair trial.
This is not a Smith case. There is not one item raised by petitioner and
proven by competent evidence which compares to the intentional acts of
misconduct in the Smith case. We find no evidence of any intentional
conduct by the District Attorney's Office or by the investigating police
officers which would establish conduct intentionally undertaken to
prejudice Lisa Michelle Lambert to the point of a denial of a fair trial.
VIII. CONCLUSION: THE QUESTION OF INNOCENCE
We are left with the question posed by our first reference in this opinion to
the elements of a PCRA claim: Was this a "fundamentally unfair"
conviction? Is Lisa Michelle Lambert an innocent woman wrongly
convicted? We have referred throughout this opinion to facts which
established guilt and which have been resolved in the post verdict stage
and in the PCRA proceeding. Many important facts were established in the
1992 trial and have been unshaken throughout the many petitions,
Page 535 of 2301
motions, hearings and court orders entered across the history of this case.
We know that in the spring, summer and fall of 1991, Lisa Michelle
Lambert demonstrated, time and again, hostility and aggression toward
Laurie Show. We know of the many hysterical phone calls, the menacing
language and the relentless, threatening conduct. There is no question
that Ms. Lambert contemplated, over an extended time period, the
possibility of doing physical harm to Laurie Show. We find that Ms.
Lambert discussed killing Laurie Show on at least two occasions.
The witnesses in this case have established that Ms. Lambert enlisted
others to kidnap and assault Laurie Show, and that Ms. Lambert assaulted
Laurie Show at the East Towne Mall. We know that credible witnesses,
among them Hazel Show, Laura Thomas, Floyd Thomas, Rose Metzger, and
George Haas, established beyond any doubt that Ms. Lambert hated Laurie
Show and that Laurie Show was terrified of Ms. Lambert.
We find credible Tabitha Buck's testimony that Ms. Lambert came to her
home the night before the murder and arranged for Ms. Buck to
accompany her to Laurie Show's home. We find Ms. Buck's testimony that
Ms. Lambert arranged for Mrs. Show to be out of the condominium that
morning to be credible and we find there to be no question at all that Ms.
Lambert's purpose in going to the condominium that morning was to inflict
serious harm to Laurie Show.
In 1992, we found that Ms. Lambert bought a rope, ski masks, and gloves
and took these items, along with a knife from her kitchen, to the Show
condominium that morning. We reject the preposterous suggestion that
these items were for the purpose of cutting a Christmas tree.
We know that Ms. Lambert planned the events of December 20, 1991, and
we know that she participated in the assault leading to Laurie Show's
death. There are several versions of exactly what happened at or about
7:00 a.m. in the Show condominium that morning, but we have never
wavered from our belief as to the truth of that morning. It was our belief
in 1992, and remains our belief today, that Ms. Lambert went to that
condominium that morning to assault Laurie Show or to kill Laurie Show.
Even if her purpose had been "only" to assault Laurie, at some point
during the assault, Ms. Lambert formed the specific intent to kill. Injuries
such as those inflicted on Laurie Show were not inflicted accidentally. The
injuries to Laurie Show demonstrate that the person who inflicted them
had a specific intent to kill. We saw no reason in 1992 to believe that after
all the harassment, stalking, and threatening behavior that preceded
December 20, 1991, after enlisting Ms. Buck, planning the trip to the Show
condominium and obtaining the materials used for the crime, that Lisa
Michelle Lambert suddenly turned into a passive, terrified observer in the
condominium. Consistent with her actions toward Laurie Show in the
months before the murder and her activities on the day before the killing,
Ms. Lambert went to that condominium with a plan. Once inside, she
carried out that plan.
These are the facts as this court viewed them in 1992. Yet, there is a fall
Page 536 of 2301
back position. What if Ms. Lambert had been telling the truth at trial and
the killer was really Tabitha Buck? Under the facts as testified to by Ms.
Lambert at trial, she was guilty of first degree murder on an accomplice
basis. Under Ms. Lambert's version of that morning, as presented at trial,
she planned to go to the Show condominium and she enlisted Ms. Buck to
go with her. She took certain items with her consistent with an intent to
inflict bodily harm to Laurie Show. She participated in the assault and, at
one point, held Laurie Show's legs down while Ms. Buck cut her throat. She
then fled the scene and took no steps to report this incident to the
authorities. When arrested, she presented an alibi story which she had
discussed with Mr. Yunkin and Ms. Buck. Ms. Lambert would be an
"accomplice" if she had the intent of promoting or facilitating the murder
and if she aided or agreed or attempted to aid Ms. Buck in planning or
committing the murder. 18 Pa. C.S. Section 306. From Ms. Lambert's
description of holding down Laurie's legs while Ms. Buck slit Laurie's
throat, we could reasonably conclude that she had the intent of
"promoting or facilitating" the killing and that she planned, or aided, or
attempted to aid Ms. Buck. In fact, we do not believe that is what
happened. Yet, based upon the story Ms. Lambert presented at trial, a
verdict of first degree murder on an accomplice basis would have been
supported by the evidence.
We know that Ms. Lambert then fled the scene. Regardless of whether she
was picked up in the condominium complex by Mr. Yunkin or whether she
was picked up by Mr. Yunkin on Oak View Road, Lisa Michelle Lambert fled
the murder in haste and did not look back.
In his closing argument, Mr. Kenneff suggested that whoever committed
this murder was guilty of first degree murder. This court believed that to
be true at the time and believes it to be true today. The crime scene
photographs, the autopsy photographs, the condition of the condominium,
and the condition of the body of Laurie Show led this court to one
inescapable conclusion: whoever performed these acts did so with a level
of rage completely inconsistent with any accidental killing or a death
incidental to a "prank." We firmly believed in 1992 that Lisa Michelle
Lambert drew the knife across the throat of Laurie Show, causing her
death. She was the only person with the level of emotion, the focus of
purpose and the clear opportunity to have performed that dreadful act.
There is no question that Ms. Lambert is not, and never will be, "innocent"
of this crime.
CRIMINAL
COMMONWEALTH OF : No. 0423 - 1992
PENNSYLVANIA:
Page 537 of 2301
v.: Post Conviction Relief Act

LISA MICHELLE LAMBERT:
ORDER
AND NOW, this 24th day of August, 1998, upon consideration of the
petition filed under the Post Conviction Relief Act, 42 Pa. C.S.A. Section
9541, et seq. (1998 Supp.), the evidence admitted at the hearing and the
arguments of counsel, and for the reasons set forth in the attached
opinion, this court finds that petitioner has failed to prove that she is
entitled to relief under the Act. Therefore, her petition shall be denied.
BY THE COURT:
LAWRENCE F. STENGEL
JUDGE
ATTEST:
Copies to: Christina Rainville, Esquire
Christy H. Fawcett, Esquire
ADDENDUM TO OPINION
1. List of Documents Filed with the Court in this Case

2. The "29 Questions" - Petitioner's Exhibit 1119
Footnotes :
(Return to Table of Contents)
Page 538 of 2301
1. Ms. Lambert's petition is governed by the PCRA, as amended on

November 17, 1995. The amended Act is applicable to all petitions filed
after January 16, 1996.
2. Brady v. Maryland, 373 U.S. 83 (1963).
3. The issues for consideration in Ms. Lambert's post verdict motions
included: error to deny defendant's motion for change of venue and/or
venire; error to deny the motion for sanctions relative to the alleged
prosecutorial misconduct in contacting defense expert, Dr. Isidore
Mihalakis; error to admit the statement of co-defendant Tabitha Buck;
error to allow the trier of fact to take notes during trial and potentially use
them during deliberation; error to affirm and read the Commonwealth's
points for charge Nos. 3 and 4; error not to grant a mistrial when the
request for supplemental discovery of Laura Thomas was not granted;
error not to grant a mistrial when the request for supplemental discovery
of Mrs. Show was not granted; error not to grant a mistrial when the
supplemental discovery of Richard Kleinhans was not granted; error not to
grant a mistrial when the prosecution withheld evidence that a jergo was
discarded and that they were aware of its location; error to qualify Dr.
Enrique Penades as an expert in forensic pathology since he was not board
certified; error not to grant a mistrial when the prosecution withheld from
discovery a portion of Yunkin's statement of February 4, 1992; error not to
grant a mistrial when the assistant district attorney asked defendant's
expert witness, Dr. Samuel J. Golub, two questions beyond his area of
expertise; and insufficient evidence existed to sustain the verdict.
4. The post verdict motions were filed on July 28, 1992. The last trial
transcript was filed on September 23, 1992, and a briefing schedule was
issued by the trial court on October 23, 1992. Counsel for defendant, at the
request of Ms. Lambert's family, requested additional time to file an
amended or supplemental brief in support of post verdict motions. Given
the gravity of charges and the many issues raised on appeal, the court
granted all of these requests for extensions of time. Defendant's last
motion was submitted to the court on June 3, 1994, and the matter was
ripe for disposition at that time.
5. There will be reference throughout this opinion to "the trial," "the post
verdict hearing," "the federal habeas hearing," and "the PCRA hearing."
The trial took place in July 1992 and resulted in a verdict of guilty of first
degree murder. The post verdict hearing was held on November 18 and 21,
1994, on defendant's claims of ineffective assistance of counsel and afterdiscovered evidence. The federal habeas hearing took place in the United
States District Court for the Eastern District of Pennsylvania in April 1997.
The PCRA hearing began on April 30, 1998, and continued through June
24, 1998.
6. The procedural posture of the case permitted the taking of testimony to
supplement the record on these two new issues. Ms. Lambert was
convicted of first degree murder and criminal conspiracy to commit
murder. At the time of sentencing, it was agreed between the assistant
district attorney and the defense attorney that the Commonwealth would
Page 539 of 2301
seek a sentence on the first degree murder conviction only. Because the
first degree murder conviction carried a mandatory life sentence, the court
was not requested to impose a sentence on the criminal conspiracy charge.
Technically, defendant had never been sentenced on the criminal
conspiracy and, therefore, her appeal period from a judgment of sentence
from that charge had not yet expired. This accommodation to defendant at
the time of formal sentencing on the first degree murder charge resulted in
a "loophole" through which the defense sought to introduce new evidence
in the hope of obtaining a new trial. It appeared to the court at that time
that all parties recognized that the loophole existed, that the loophole was
not the result of inadvertence either by any of the parties or by the court,
and that it existed because of an accommodation to Ms. Lambert. It was on
this basis, then, that the court had the capacity to receive new evidence
and consider defendant's request for a new trial at the time of the post
verdict hearing in November 1994.
7. Ms. Lambert enjoyed the benefit of two court-appointed attorneys and
one court-appointed criminal investigator. Mr. Shirk was appointed within
a day or two of Ms. Lambert's arrest for the murder of Laurie Show. He
requested the appointment of Alan G. Goldberg, Esquire, to assist him in
the case with the death penalty phase, if necessary. Both are experienced,
respected members of the Lancaster County bar who specialize in criminal
defense cases. Mr. Goldberg participated in the defense effort throughout
the investigation and trial. Mr. Shirk conducted the bulk of the defense on
guilt at trial. Mr. Goldberg assisted in arguing points of law to the court
and in the examination of some witnesses. Mr. Goldberg handled the death
penalty phase of the trial exclusively. Mr. Shirk appeared as a witness on
Ms. Lambert's behalf at the death penalty phase.
8. Prior to the Lambert trial, Mr. Yunkin entered into a plea agreement with
the Commonwealth. Essentially, the Commonwealth offered a plea of guilty
to obstruction of justice in exchange for testimony at the Lambert trial and
at the trial of Ms. Lambert's co-conspirator, Tabitha Buck. The condition of
the plea agreement was that Mr. Yunkin testify truthfully. After the
Lambert trial and after the Buck trial, Mr. Yunkin entered a plea, not to
obstruction of justice, but to third degree murder. The Commonwealth
indicated that it was justified in seeking the more serious charge because
Mr. Yunkin was not truthful in his testimony at the Lambert trial.
9. The evidence presented in the district court in very large part was
obtained through federal discovery and had previously been unavailable in
state court. For example, the Commonwealth was compelled to produce
the working notes of the prosecutor from the 1992 trial. Habeas
petitioners, unlike usual civil litigants in federal court, are not entitled to
discovery as a matter of ordinary course. Rule 6 of the Federal District
Court Rules Governing Habeas Corpus Cases provides that any party may
utilize the processes of discovery available under the Federal Rules of Civil
Procedure (Rules 26-37) if, and to the extent that, the judge allows such
discovery upon a showing of good cause. In the Advisory Committee Notes
to Rule 6, mention is made of the fact that Rule 6 is consistent with the
Supreme Court pronouncement in Harris v. Nelson, 394 U.S. 286 (1969),
regarding discovery in federal habeas proceedings: "[I]t is clear that there
Page 540 of 2301
was no intention to extend to habeas corpus, as a matter of right, the

broad discovery provisions
. . .of the new [Federal Rules of Civil Procedure]."
10. Petitioner's pleadings and briefs frequently characterize the
proceedings which occurred in the federal district court as a "trial" and
also refer to "pretrial" conferences. (See, e.g., Petitioner's Motion to File
the Federal Record at paras. 24-25, 28-29, 31-32.) There was no "trial" in
the district court; rather, the court held a habeas corpus hearing pursuant
to 28 U.S.C. Section 2254. The only trial ever held in Ms. Lambert's case
took place in the Court of Common Pleas of Lancaster County. That trial
resulted in a guilty verdict and sentence of life imprisonment for Ms.
Lambert's murder of Laurie Show.
11. The district court did not address other grounds raised in Ms.
Lambert's petition regarding ineffective assistance of counsel and afterdiscovered evidence.
12. In the habeas corpus proceeding, the Commonwealth was represented
by the Lancaster County Office of the District Attorney.
13. For the purpose of appealing from the grant of habeas corpus relief,
the District Attorney's Office retained private counsel.
14. Petitioner was free from April 21, 1997, until February 4, 1998,
approximately ten months.
15. On May 6, 1998, the PCRA proceeding was interrupted when the court
received an opinion from a two-judge motions panel of the Third Circuit
remanding the Fed. R. App. P. 23 application to the district court "with
instruction to grant the motion for release with such conditions as the
court considers appropriate" pending the disposition of Ms. Lambert's
petition for writ of certiorari. This order was immediately followed by an
order on May 6, 1998, from the Eastern District Court scheduling a hearing
in Philadelphia for May 8, 1998, directing the Commonwealth to
"immediately deliver Ms. Lambert to the custody of the Court." Ms.
Lambert was transported from the Lancaster County Prison to federal
court on May 7, 1998, pursuant to a further order from the district court
specifically setting forth the procedure for transfer of custody. Also on May
7, 1998, the Commonwealth made an emergency application to stay the
Third Circuit order which was granted the same day by the same motions
panel, pending the Commonwealth's application for rehearing if filed in a
timely fashion. On May 8, 1998, the Commonwealth filed an application for
rehearing with a suggestion for rehearing en banc which was granted by
the Court. Despite the Third Circuit's stay of its May 6, 1998, order on May
7, 1998, the district court nonetheless required the parties to be present at
the "release" hearing on May 8, 1998, as previously scheduled. Following
the hearing, upon stipulation of counsel, Ms. Lambert was returned to the
Lancaster County Prison and the PCRA hearing resumed on May 11, 1998.
The Commonwealth's petition for rehearing en banc was subsequently
granted followed by an order by the Chief Judge on May 15, 1998, vacating
Page 541 of 2301
the Motions Panel's order and opinion of May 6, 1998.

16. Ms. Lambert's counsel filed a petition with the Pennsylvania Supreme
Court for the exercise of plenary jurisdiction and emergency motion for
writ of prohibition to prevent reincarceration on January 28, 1998. On
January 30, 1998, the Supreme Court denied Ms. Lambert's petition and
emergency motion, without prejudice to her right to refile, as there was no
matter pending before any tribunal within the Commonwealth. Thereafter,
the PCRA petition was filed.
17. Given the number of complex factual and legal issues and the lengthy
nature of the proceeding, this court requested, on June 9, 1998, an
additional 60 days to dispose of this matter. Petitioner filed a four-page
objection to this court's request for extension. We were notified on June
18, 1998, by letter from the Prothonotary of the Pennsylvania Supreme
Court, that the Supreme Court had granted the request for a 60-day
extension to conclude this PCRA matter, the time being calculated from
June 25, 1998.
18. The court actually received a copy of the original order dated February
25, 1998, and a revised order dated February 25, 1998.
19. The motion to compel was ultimately filed with the Office of the Clerk
of Courts on March 9, 1998. During this PCRA proceeding, the court
permitted the parties to submit motions, petitions and briefs via facsimile.
This was done to accommodate the expedited schedule imposed by the
Pennsylvania Supreme Court and to allow the court to consider the parties'
filings as soon as possible. It was our procedure then t hat the originals be
filed by regular mail with the Clerk of Courts. Attached to this opinion is an
addendum which lists the documents filed in this case with a listing of the
date each document was received in chambers as well as the official filing
date with the Clerk of Courts. This addendum is attached to facilitate
review of the record by the appellate courts.
20. These Rules have been adopted by the Pennsylvania Supreme Court
and govern the conduct of any attorney practicing in Pennsylvania.
21. On March 17, 1998, Philadelphia Newspapers, Inc., t/a The
Philadelphia Inquirer, filed an action in the United States District Court for
the Eastern District of Pennsylvania seeking an injunction lifting the "gag"
order. See Philadelphia Newspapers, Inc., publisher of The Philadelphia
Inquirer v. Lancaster County Court of Common Pleas and The Honorable
Lawrence F. Stengel, Civil Action No. 98-CV-1393 (1998). After a hearing
on the matter, Philadelphia Newspapers' request for a temporary
restraining order was denied. The court referred to the litigation in the
Lancaster County Court of Common Pleas and noted that principles of
"common sense and comity" mandated that the objections to the order be
raised first before the judge who entered the order.
22. When the Third Circuit vacated the district court's order of April 21,
1997, the proceedings before the district court were rendered void ab
initio. See Stern v. Williams, 970 F.2d 1043, 1054-55 (2d Cir. 1992), cert.
Page 542 of 2301
denied, 508 U.S. 906 (1993) ("judgment [which has been vacated] or set
aside has no preclusive effect"); United States v. Williams, 904 F.2d 7, 8
(7th Cir. 1990) (vacated judgment "place[s] the parties in the position of
no trial having taken place at all"); Rushton Mining Co. v. Morton, 520 F.2d
716, 719 (3d Cir. 1975) (by definition, vacatur renders lower court's order
"void ab initio "). The Third Circuit's decision vacating the district court's
judgment not only found the district court's hearing was invalid because it
was without any authority to conduct that proceeding but it expressly
refused to give any weight to the district court's determinations: "[W]e do
not give weight to the district court's factual findings in this appeal." 134
F.3d at 509 n.1. The merits panel said that "[r]esolution of these difficult
questions must. . .await the appropriate forum." Id. at 524-25. Among the
"difficult questions" identified were "serious factual issues concerning the
district court's finding that Lambert was actually innocent of first degree
murder." Id. at 524. The "appropriate forum" referred to is "the state
courts." Id.
23. See Section VII.P on admissions, infra.
24. The court held that as Ms. Lambert had been found guilty of an offense
punishable by life in prison, Rule 4009 of the Rules of Criminal Procedure
clearly prohibits any entitlement to bail. There was simply no basis in law
or fact for this court to grant the request for bail.
25. Rule 1502 of the Pennsylvania Rules of Criminal Procedure entitled,
"CONTENT OF PETITION FOR POST-CONVICTION COLLATERAL RELIEF;
REQUEST FOR DISCOVERY," was amended in 1997 to address requests for
discovery in PCRA petitions. Specifically, Paragraph (a)(16) requires that a
request for discovery be included in the petition: "(a) A petition for postconviction collateral relief. . .shall contain substantially the following
information:. . .(16) if, applicable, any request for discovery." Paragraph
(e) sets forth the standards for permitting discovery. Except as provided in
Rule 1502(e)(2) for death penalty cases, no discovery is permitted at any
stage of the proceedings, except upon leave of court with a showing of
exceptional circumstances. Pa. R. Crim. P. 1502(e)(1). This language
implements 42 Pa. C.S.A. Section 9545(d)(2): "No discovery, at any stage
of proceedings under this subchapter, shall be permitted except upon
leave of court with a showing of exceptional circumstances." Ms. Lambert
submitted nothing which demonstrated, in any substantive manner, that
any truly exceptional circumstances warranted granting her request for
discovery. The "proof" of "exceptional circumstances" was the same
phrase which pervades her filings in this court and elsewhere, that she is
"the victim of the worst prosecutorial misconduct in the history of the
English-speaking world." Such a conclusory characterization, by itself, was
insufficient to meet the requirements of Rule 1502(e). Ms. Lambert's
situation is neither different from, nor more substantive than, that which
any PCRA petitioner might be expected to claim, namely, that he or she
"didn't do it." Moreover, much of what Ms. Lambert sought to obtain in
discovery was otherwise available to her.
26. These arguments were heard via a speaker phone in the courtroom to
accommodate the interest of the public and because of security concerns
Page 543 of 2301
voiced by petitioner's counsel.

27. The motion for sanctions was filed with the Clerk of Courts one day
after the April 14, 1998, amended order limiting publicity was entered. The
persons who were the subject of petitioner's motion for sanctions were
subject to restrictions which were removed by the amended gag order.
28. This court is cognizant of Rule of Criminal Procedure 1504 which
requires the appointment of counsel for a defendant on her first post
conviction relief petition if the court is satisfied that "the defendant is
unable to afford or otherwise procure counsel." Pa. R. Crim. P. 1504(a)
(emphasis added). Under the circumstances of this case, we found that
petitioner was able to "otherwise procure counsel."
In Commonwealth v. Duffey, No. 156 Capital Appeal Docket (May 21,

1998) (to be reported at: 713 A.2d 63), the Supreme Court considered the
question of whether the appellant's pro se status was a "fiction" given the
fact that attorneys filed and signed notices of appeal from two trial court
orders. The Court cited Rule 9020 of the Pennsylvania Rules of Criminal
Procedure which states that all motions for relief shall be made by written
motion and shall be signed by the person or attorney making the motion.
The signature of an attorney "s hall constitute a certification that the
attorney has read the motion, that to the best of the attorney's knowledge,
information, and belief there is good ground to support the motion, and
that it is not interposed for delay." Pa. R. Crim. P. 9020(b)(1). The
Supreme Court held that nothing in Rule 9020 permits an attorney to sign
pleadings for pro se defendants. "To the contrary, an attorney's signature
is a legal certification that gives good cause to support the pleading, and
an attorney cannot avoid that certification through the addition of creative
language describing the attorney as a mere 'preparer' on behalf of a pro se
defendant. Thus, when an attorney signs and files a pleading for an
unrepresented defendant, that attorney will be deemed to represent that
defendant. We do not condone counsel's attempts to file a notice of appeal
without entering an appearance in this case." The Supreme Court
concluded that the attorneys who signed the notices of appeal became the
defendant's attorneys of record for the appeal when they filed the notices
with the court. (Slip op. at 11-12.) Likewise, the attorneys in this case,
Christina Rainville and Peter Greenberg, signed the PCRA petition, and
every other document filed with the court, as counsel for Ms. Lambert.
These attorneys became Ms. Lambert's attorneys of record for this PCRA
proceeding when they filed the petition with this court on February 2,
1998. Clearly, petitioner was able to "otherwise procure counsel" and did
not require court appointment of counsel in this case.
29. Acknowledging the need for a showing of exceptional circumstances to
justify discovery in this PCRA, petitioner claimed that discovery was
warranted because "the Commonwealth is presenting new witnesses
against Petitioner and neither Petitioner nor her counsel have the slightest
idea who these individuals are, what there [sic] testimony is going to be,
Page 544 of 2301
whether deals or other promises have been made in exchange for the
testimony, or whether they are withholding other evidence favorable to
Petitioner." The court did not find these ci, rcumstances to be exceptional.
30. Giglio v. United States, 405 U.S. 150 (1972).
31. The case law indicates that there is no requirement that the
Commonwealth furnish investigative services to PCRA petitioners. See
Commonwealth v. Strong, 522 Pa. 445, 563 A.2d 479 (1989);
Commonwealth v. Woods, 394 Pa. Super. 223, 575 A.2d 601 (1990). See
also Commonwealth v. Gelormo, 327 Pa. Super. 219, 475 A.2d 765 (1984)
("There is no constitutional mandate, either federal or state, that experts
be appointed at public expense to assist in preparation of a defense
whenever requested by one accused of a crime").
32. Petitioner's counsel indicated on the record at the time of argument on
this motion that the motion in limine to exclude the testimony of Dr.
Burton was withdrawn.
33. See Section VII.C, infra.
34. The testimony in the federal district court of Professor Wolfram
involved the ex parte communication of Assistant District Attorney John A.
Kenneff with Dr. Isidore Mihalakis in connection with Ms. Lambert's civil
trial in 1992. Specifically, this expert testified that such conduct, that is,
contacting an expert witness for the defense without the consent of
defense counsel, was a "no-brainer." (Notes of Testimony ("N. T."), Habeas
Hearing at 1007.) The interpretation of the Rules of Professional Conduct
and the Rules of Criminal Procedure is a legal issue to be decided by a
court, for which use of an expert would be wholly inappropriate. A court
may not abdicate its role to determine the ultimate issue by allowing
expert testimony. See Commonwealth v. Neal, 421 Pa. Super. 478, 481,
618 A.2d 438, 439 (1992) (improper for court to admit testimony of an
attorney addressing the legal issue to be decided by the court). For these
reasons, this court granted the Commonwealth's motion in limine.
35. The court issued an order on April 13, 1998, scheduling the PCRA
hearing to begin on Monday, April 27, 1998. In furtherance of that order,
on April 14, 1998, a writ of habeas corpus was issued directing the
superintendent at the Edna Mahan Correctional Facility for Women in New
Jersey to produce Ms. Lambert at the PCRA hearing in Lancaster on April
27, 1998. Petitioner resisted any effort to effectuate her transfer to
Lancaster County Prison. Ms. Lambert's counsel went so far as to send a
letter to New Jersey Assistant Attorney General Ronald Bollheimer
essentially advising him that Ms. Lambert was protesting being moved,
pursuant to the writ issued by this court, from the New Jersey prison,
where she was ordinarily confined, to the Lancaster County Prison, and
threatening to hold New Jersey officials responsible for what she claimed
would be compliance with an illegal order. The strong inference in
counsel's correspondence, if not an o utright demand, was that New Jersey
should refuse to obey the court's order. On April 22, 1998, the court
received a letter from petitioner's counsel informing it of Ms. Lambert's
Page 545 of 2301
filing of her petition for writ of certiorari and motion for release from
custody pursuant to Fed. R. App. P. 23. In this letter, counsel referred to
Supreme Court Rule 36(1), which they claimed applied to Ms. Lambert so
long as she remained in custody. Rule 36 governs the custody and release
of federal and state prisoners pending appellate review of a decision in a
federal habeas corpus proceeding. Specifically, Rule 36(1) provides that
pending review of a decision in a federal habeas corpus proceeding, "the
person having custody of the prisoner shall not transfer custody to another
person" without the permission of the court, justice, or judge rendering
the decision that is under review. Petitioner's counsel claimed that no such
authorization existed for the transfer of Ms. Lambert from the Edna Mahan
Correctional Facility to the Lancaster County Prison for purposes of the
PCRA proceeding which was to commence on April 27, 1998. Through a
series of telephone calls and letters, the Pennsylvania Department of
Corrections confirmed for the court that Ms. Lambert is and always has
been in the custody of the Pennsylvania Department of Corrections and
that, although convicted in Pennsylvania, is incarcerated in the New Jersey
facility pursuant to the provisions of the Interstate Corrections Compact,
61 P.S. Section 1061 et seq. (1998 Supp.). Ms. Lambert's official status is
as a prisoner of the Pennsylvania state system. Therefore, the
Pennsylvania Department of Corrections is the "custodian" of Ms. Lambert.
Based upon this information, the hearing was rescheduled for April 29,
1998, and again a writ of habeas corpus issued directing the
superintendent at the Edna Mahan Correctional Facility to produce Ms.
Lambert at the hearing on April 29, 1998. Once the status of custodian was
confirmed, an application, pursuant to Rule 36.2, was filed by the
Commonwealth with the Third Circuit seeking authorization for Ms.
Lambert's transfer to the Pennsylvania prison authorities. That
authorization was obtained on April 29, 1998. An order was entered on
April 29, 1998, again directing the superintendent to produce Ms. Lambert.
She was transferred to Lancaster on the evening of April 29, 1998. As the
hearing was scheduled to begin on April 29, 1998, the court heard oral
argument on several outstanding motions on April 29, 1998, but heard no
testimony in t he case until petitioner was present in the courtroom on
April 30, 1998.
36. The 1995 amendments substituted the word "changed" for the word
"affected." This amendment appears to have substituted a more strict test
from what had been in place before.
37. Renee L. Schuler is currently a lieutenant with the East Lampeter
Township Police Department. In 1991-1992, she had the rank of corporal
with the same department.
38. Counsel for petitioner miscited and misr, epresented the law when
presenting legal argument to the court on many occasions. See, e.g.,
petitioner's reliance on Commonwealth v. Wells, 322 Pa. Super. 380, 469
A.2d 672 (1983), appeal after remand, 345 Pa. Super. 623, 496 A.2d 855,
rev'd, 513 Pa. 463, 521 A.2d 1388 (1987), in support of her motion to file
the federal habeas record as the record of this PCRA proceeding,
Commonwealth v. Bonaparte, 366 Pa. Super. 182, 530 A.2d 1351 (1987)
(plurality), in support of her motion for bail, and Commonwealth v. Reese,
Page 546 of 2301
444 Pa. Super. 38, 663 A.2d 206 (1995), in support of her motion to
exclude the expert testimony of Dr. Levin and all evidence not introduced
at the 1992 trial and to limit the Commonwealth's witnesses.
39. The notes of testimony for this PCRA proceeding were lodged with the
Clerk of Courts on August 3, 1998. There are more than 8,000 pages of
testimony contained in 36 bound volumes. Counsel requested 30 days to
review the notes of testimony and file objections to the transcript with the
court. Given the enormity of the record, this request was granted on
August 11, 1998. Therefore, citations in this opinion will be to the
"unofficial" notes of testimony which are subject to change at a later date.
40. Detective Solt is presently employed by the Lancaster County District
Attorney's Office. In 1991 and 1992 he was a corporal with the
Pennsylvania State Police and assisted in the investigation of the Show
murder.
41. Ronald W. Savage was a detective with the East Lampeter Township
Police Department in 1991-1992. At the time of the PCRA hearing, he was
a district justice.
42. A federal court has offered the following definition: "A 'hostile'
witness, in the jargon of evidence law, is not an adverse party but a
witness who shows himself or herself so adverse to answering questions,
whatever the source of the antagonism, that leading questions may be
used to press the questions home." Rodriquez v. Banco Central Corp., 990
F.2d 7, 12-13 (1st Cir. 1993).
43. The assumption, of course, is that the federal investigating authorities
will be moved by what is decided here. It is already clear that the federal
courts disregarded findings of fact made by this court in the 1992 trial,
e.g., the dying declaration and the import of the "29 questions." It is
already clear that Mr. Greenberg has taken a position that no court should
give any deference to this court's findings and it is clear that whatever
investigation is being done is at the request of the federal district court
and by federal authorities, and not at the behest of any state court or by
state authorities.
44. In the July 19, 1994, opinion, this court erroneously stated that the
murder took place on the morning of December 21, 1991. In , fact, the ,
murder took place on D, ecember 20, 1991. The questioning of the
suspects took place in the early morning hours of December 21, 1991. For
the sake of clarity, we corrected the date in the material quoted above.
The mistake remains in the original.
45. Now referred to as the "29 questions."
46. It appears that the district court had reservations about the credibility
of Mr. Kleinhans's testimony. In the habeas corpus opinion, the district
court discussed this court's findings of fact as set forth in the slip opinion
cited above. Where this court's discussion of Mr. Kleinhans is quoted in the
Page 547 of 2301
federal court opinion, the district court included a footnote which reads as
follows:
We note, although this does not play a part in our decision, the following
excerpts from Mr. Kleinhans's testimony at the habeas hearing:
Q. I noticed in here that you have a little hard time hearing what is being
said.
A. Yes.
Q. Back in '91, did you also have a hard time hearing as well?
A. Not as much as now, no.
Q. Was it okay then?
A. It wasn't okay. But -Q. It was not okay?
A. No.
Lambert v. Blackwell, 962 F. Supp. at 1524 n.7.
The only possible purpose to include a reference to Mr. Kleinhans's

testimony in federal district court about his ability to hear would be to cast
doubt on this court's reliance on Mr. Kleinhans in 1992. In fact, this court
had every opportunity to observe Mr. Kleinhans as he testified and counsel
for defense had every opportunity to cross-examine Mr. Kleinhans on his
ability to see, to hear or to know the things about which he testified. His
ability to hear what was going on on December 20, 1991, was a part of our
assessment of his credibility. The federal district court's reference to this
could have only been intended to cast doubt on our finding that Mr.
Kleinhans was credible. The proper place to assess Mr. Kleinhans's
credibility in this case was in 1992, not retrospectively in 1997.
47. Subsequent attempts at the state court PCRA hearing in 1998 to use
Page 548 of 2301
these depositions for impeachment purposes evidenced poorly focused

questioning which provided more obfuscation than explication of the
issues.
48. For the reader who suspects that this court is attempting to match the
hyperbole of the federal habeas proceeding, one might question why the
federal district court was referring to the 1992 trial as the "alleged trial"
on the fourth day of a three-week hearing. (See N.T., Habeas Hearing at
949.)
49. Exhibit A to the PCRA petition, which will be referred to throughout
this opinion, was attached to Petitioner's Second Motion for Leave to
Amend, which was filed with the court on June 10, 1998, and granted on
June 16, 1998. Exhibit A contains the listing of petitioner's claims.
50. Actual innocence is actually a creation of federal case law, not the
habeas statute. A commentator has noted: "The habeas statute, of course,
makes no mention of 'actual innocence' as a criterion for gaining access to
a habeas forum. Thus, the pervasive role that innocence currently occupies
in the jurisprudence illustrates the Court's common-law approach to
defining the scope of the writ." Jordan Steiker, Innocence and Federal
Habeas, 41 U.C.L.A. L. Rev. 303, 388 (1993).
51. The "ward" is an unofficial, pejorative designation for a large area of
downtown Lancaster.
52. Later, under oath in a courtroom, Ms. Lambert testified that this was,
in fact, her plan. Her only quarrel was that she never told the kids that she
was going to "slit Laurie's throat." Much later, in a federal courtroom,
where Michelle, now called Lisa and represented by two lawyers from
Philadelphia, said that the "slit her throat" language in a police report was
a fabrication and a violation of her constitutional rights.
53. Recently, at the PCRA hearing, Ms. Buck testified that she knew the
night before the murder that Mrs. Show was going to be gone. She had
said under oath last year that she did not know it until the morning of the
murder.
54. If Michelle had really helped Laurie get out of the condo, there must
have been blood all over the floor. The police had to clean the blood up to
prove Michelle was lying.
55. Dr. Larson's opinions as to the possibility of speech were, in effect,
medical conclusions.
56. It is interesting to note that the federal district court sought to
discredit the trial testimony of Dr. Penades by reference to an interview he
gave to a reporter from the Lancaster New Era and reported in that
newspaper on April 1, 1997. It appears that the reporter, Andrea S. Brown,
testified in the habeas proceeding as to her conversation with Dr. Penades.
The district court noted that Dr. Penades "may well have retracted most or
Page 549 of 2301
all of his trial testimony" in that interview. See Lambert v. Blackwell, 962
F. Supp. at 1528-29 n.13. The testimony of Ms. Brown was offered by
petitioner in this case. We ruled that Ms. Brown's testimony as to an outof-court statement made to her by Dr. Penades, and, offered for its truth,
was hearsay.
57. There is little question that Dr. Larson appeared as much as an
advocate as he was an expert witness. In the federal proceeding, he took a
somewhat more aggressive posture. There, Dr. Larson offered an opinion
that the carotid artery was cut and went on to say that this meant, in
short, that Laurie Show could not possibly have spoken. (N.T., Habeas
Hearing at 54, 61, 73.) It was enough of a stretch for him to say that the
carotid was cut. He went completely beyond his realm of expertise into the
realm of medical opinion by testifying on the significance of the cut
carotid. (N.T., Habeas Hearing at 73-74.) Perhaps because the evidentiary
standards are different from federal to state court, Dr. Larson was not
asked about the significance of the cut carotid artery at the PCRA hearing.
In addition, when asked by Mr. Madenspacher in federal district court how
he reconciled his testimony with the testimony of the two physicians who
actually looked into the neck of Laurie Show and observed that the carotid
was intact, Dr. Larson simply stated that he believed they were not telling
the truth. (N.T., Habeas Hearing at 112-13.)
58. In fact, he testified that he did not review the report and noted that he
really meant to say that the victim was Laurie Show. (N.T., PCRA at 3158.)
59. Dr. Burton expressed serious reservations about Dr. Baden's judgment
in making that statement. He stated, when asked about Dr. Baden's
willingness to rely on the diagnosis made by an EMT: "My belie f is that
testimony will haunt Dr. Baden." (N.T., PCRA at 6980.)
60. In fact, what Mr. Zeyak identified as the severed carotid artery was
later identified by Roger J. Levin, M.D., as musculature, which was partly
torn by the knife.
61. Dr. Levin testified at the PCRA hearing and in federal court that, at
least theoretically, the injury to Laurie Show's neck could have been
repaired. He acknowledged the difficulty transferring her to a competent
trauma center and does not believe the failure of medical personnel to
resuscitate her was in any way remiss. Simply by way of comparing this
wound to other damage to the throat and neck which he has observed in
surgery, he offered the opinion that under ideal circumstances, a
correction could have been made. The medical school professor and throat
surgeon was then questioned:
THE COURT: So it is your testimony you could have fixed this?
Page 550 of 2301
THE WITNESS: Sure.

THE COURT: That it would all be -- just like that (snapping fingers)?
THE WITNESS: Oh, not like that, but a tracheostomy, but it is certainly
repairable. BY MR. GREENBERG:
Q. Well, is it your testimony that we don't need you to fix it, that it
would just fix by itself?
THE COURT: Heal by itself, like a wound on the fingers?
THE WITNESS: No. I think it needed to be closed, but I think had it not
been closed, over time it would have closed, assuming she could have
breathed.
THE COURT: And it would all grow back together and she'd be normal.
THE WITNESS: Yes. Essentially.
THE COURT: Do you also think that severed limbs regenerate
themselves?
THE WITNESS: No, they don't.
(N.T., Habeas Hearing at 2777-2778.)

62. This statement was admitted under the "excited utterance" exception
to the hearsay rule.
63. The federal district court, in support of its conclusion that the vagus
and laryngeal nerves were severed thereby making speech impossible,
dismissed Mrs. Show's testimony of the dying declaration as the rantings
of a hysterical woman in such emotional upheaval that she could not
accurately recall whether, in fact, her daughter spoke to her before her
death or whether some unscrupulous policemen exploited the situation for
their good by suggesting that her daughter spoke. The court stated:
At the end of her dramatic testimony. . .Mrs. Show reiterated her belief
that her daughter said, "Michelle did it.". . . We have not the slightest
Page 551 of 2301
doubt that this constitutes Mrs. Show's sincere belief. But amid the
maelstrom of emotions that day, it is not hard to see how she could be
mistaken--or, worse, suggested--into this belief. The earliest accounts
by East Lampeter Police, as confirmed by their testimony before us,
was that Hazel Show, understandably hysterical, repeated over and
over, 'It was a setup! Michelle did it!' . . . It was at this world-ending
time a small step to make her deduction into a recollection that her
daughter said those words. And it is a measure of the depressing
record before us that we cannot exclude the possibility that some law
enforcement official suggested this small step to her.
962 F. Supp. at 1529 n.13 (citations omitted).

64. The document actually contained 31 questions and answers, but only
29 of these are numbered. During the 1992 trial and the post verdict
hearing and arguments, the document was referred to as the
"questionnaire." During the PCRA hearing, counsel and the witnesses
referred to this document as the "29 questions" and that designation will
continue in this discussion.
65. In the federal habeas proceeding, the district court appeared to find
something wrong with this argument. In fact, it is an elementary tenet of
the law that a fact finder is always free to accept all or part or none of the
evidence offered. See Pa. SSJI (Crim) No. 4.17(1) ("[Y]ou must judge the
truthfulness and accuracy of each witness's testimony and decide whether
to believe all or part or none of that testimony"), citing Commonwealth v.
Williams, 323 Pa. Super. 512, 521-22, 470 A.2d 1376, 1381 (1984);
Commonwealth v. Dolny, 235 Pa. Super. 241, 250-51, 342 A.2d 399, 404
(1975). To somehow suggest that the prosecutor was dishonest for
making this argument or that the court was less than alert for accepting
the argument is simply to misunderstand basic criminal trial practice.
66. See Lambert v. Blackwell, 962 F. Supp. at 1529-1532.
67. Petitioner's Exhibit 1474 appears to have surfaced with Ms. Lambert's
federal habeas petition and was not involved in any prior proceeding.
68. The Federal Rules of Evidence do not seem to provide for expert
Page 552 of 2301
testimony on the subject of witness credibility. The federal district court's

opinion contains no citation to any authority, statute, case or otherwise,
which would support admission of such testimony. The best we have is the
court's description of the testimony as "dramatic." In state court criminal
cases, the term "dramatic" is not a synonym for "relevant" or
"admissible."
69. See Commonwealth v. O'Searo, 466 Pa. 224, 352 A.2d 30 (1976)
(expert testimony of clinical psychologist to substantiate and corroborate
the defendant's version of the critical events and the case was prohibited);
Commonwealth v. Evans, 412 Pa. Super. 332, 603 A.2d 608 (1992)
(reversible error to admit detective's testimony as to child sexual abuse
accommodation syndrome as such testimony was proffered solely to
enhance the witness's credibility after defense counsel pointed out that
the children did not immediately report abuse); Commonwealth v. Purcell,
403 Pa. Super. 342, 589 A.2d 217 (1991) (expert testimony on dynamics
of child sexual abuse may not be used by Commonwealth to bolster
credibility of alleged victim of child abuse; child had not reported alleged
sexual abuse until six and one-half years after the first incident);
Commonwealth v. Smith, 389 Pa. Super. 626, 567 A.2d 1080 (1989)
(counsel ineffective for not objecting to expert's opinion as to the truth
telling capabilities of a seven year old child); Commonwealth v. Newman,
382 Pa. Super. 220, 555 A.2d 151 (1989) (defendant not permitted to offer
expert witness opinion that defendant was hexed where defendant
believed himself to be a victim of Voodoo).
70. They were not offered for the truth of the matters set forth in the
letters but as an expression of the state of mind of the reader and the
writer. For a classic definition of the term "hearsay," see generally Baird v.
Unemployment Compensation Board, 30 Pa. Cmwlth. 118, 121, 372 A.2d
1254, 1257 (1977) (hearsay constitutes statements made outside of court
offered for the truth of the matter(s) contained therein).
71. The charge against Sergeant Bowman characterized the tone of much
of petitioner's case. There was no question at the outset of this hearing
that Sergeant Bowman was considered by petitioner's counsel to be one of
the gang rapists. So much so, that they subpoenaed his bank records for a
three month period in 1991, when Sergeant Bowman asserted that he was
in Virginia Beach, Virginia, with his wife on their honeymoon at the time of
the alleged rape, i.e., June 17, 1991. At oral argument in the courtroom on
the motion to compel the production of these bank records, petitioner's
counsel, Christina Rainville, Esquire, informed the court that Ms. Lambert
was no longer accusing Sergeant Bowman of being a rapist. However, Ms.
Rainville allowed, Sergeant Bowman was welcome to come into court and
clear his name of this allegation. (N.T., PCRA at 3460.) The court informed
Ms. Rainville at that time that this is not how the system works. One does
not cast serious and harmful accusations out into the public place and then
invite the "accused" to come in and clear his name. This approach to
investigation, discovery and litigation shows the kind of paranoia that
appears to motivate the petitioner and certainly follows in the wake of her
counsel's efforts. Despite the fact that Mr. Bowman was never identified as
a rapist, never placed at the scene, never connected in any way with the
Page 553 of 2301
alleged rape, it was necessary for him to come into court, with his wife,
and testify as to their whereabouts, their activities and their expenditures
on their honeymoon seven years ago.
72. The corrections officer at the state correctional institution at
Cambridge Springs was charged with and convicted of each of the
following crimes: aggravated indecent assault, formerly codified at 18 Pa.
C.S.A. Section 3125(5); indecent assault, formerly codified at 18 Pa. C.S.A.
Section 3126(a)(5); and official oppression, see 18 Pa. C.S.A. Section
5301. As to none of these offenses was forcible sexual conduct an element.
(N.T., PCRA at 7578-79.)
73. In testimony at the PCRA hearing, Ms. Lambert contrasted he r
involvement with Mr. Epstein as her attorney with how helpful she has
been to Ms. Rainville and Mr. Greenberg. She testified that in the first
telephone call she had with Ms. Rainville, she told Ms. Rainville that she
needed to hire a "clothing expert about the jergo, speech expert, a
pathologist, an expert on handwriting, every -- everything that you asked
me I said that we could get an expert for it." (N.T., PCRA at 5162.) It
appears that Ms. Lambert even assisted in writing the reports of her own
expert witnesses. To this end, she gave the following testimony:
Q. In the federal proceeding, what, if anything, did you ask to see of drafts
of expert reports?
A. As soon as an expert gave a draft, I asked you to send it to me and I
would read it right away.
Q. And what, if anything, did you do after you read it?
A. I would look at it and then I would write down questions for you to ask
the expert.
Q. And did we make changes to the expert reports based on your
comments?
A. Yes. I would ask you to ask them a question and give their best opinion
to a degree of scientific certainty and then you would ask them and
whatever they said would be included in the reports.
(N.T., PCRA at 5168-69.)
Page 554 of 2301
Ms. Lambert would have this court believe that once safe in the confines of
the Edna Mahan Correctional Facility in New Jersey, she was able not only
to assist her attorneys but to participate in the writing of expert reports.
Normally, experts write their own reports. The blithe acknowledgment by
petitioner and petitioner's counsel to the act of participation in the writing
of expert reports provides considerable insight into a number of issues in
this case.
74. The "loop" is an unofficial designation of a large block composed of
several streets and extending over eight or nine city blocks in downtown
Lancaster. It has long been a hang out for teenagers in cars or on foot.
75. There was considerable testimony at the PCRA hearing regarding
certain scratches on Ms. Buck's shoulder and back. Photographs were
taken of her at the time of her arrest and Lieutenant Renee Schuler
testified as to observing those scratches. The scratches were discernible
on the photographs admitted into evidence. Ms. Buck was asked about
these scratches and was unable to provide any explanation fo r them. She
does not believe she sustained those scratches on the morning of
December 20 because she was wearing a sweatshirt and her Miami
Dolphins jacket over top of the sweatshirt at all times. She believes she did
them herself by scratching her back. (N.T., PCRA at 6665.)
76. The letter to Mr. Pugh was written four days after her deposition. Ms.
Buck testified that she sent the letter from the Lancaster County Prison
before being returned to the State Correctional Institution at Muncy. (N.T.,
PCRA at 6692.)
77. The fact that the warrant was issued in the office of District Justice
Savage is more coincidence than anything else. District Justice Savage's
office happens to have jurisdiction over the area where Ms. Bayan resided.
78. The distinction between exculpatory evidence and favorable evidence
is that exculpatory evidence extrinsically tends to establish a defendant's
innocence of the crimes charged, contrasted to that which, albeit
favorable, is merely collateral or impeaching. Commonwealth v. Hudgens,
400 Pa. Super. 79, 97-98, 582 A.2d 1352, 1361 (1990); Commonwealth v.
Redmond, 395 Pa. Super. 286, 577 A.2d 547, 552 (1990); Commonwealth
v. Hicks, 270 Pa. Super. 546, 550, 411 A.2d 1220, 1222 (1979). The
evidence suppressed in Redmond was the identity of a confidential
informant who gave information concerning an alternative suspect in a
murder case, where the prosecution's case rested on the testimony of only
one police officer. Redmond, 395 Pa. Super. at 298, 577 A.2d at 552. The
court opined that t he evidence was both exculpatory and material, as there
was reasonable probability that the evidence might have made a difference
in the outcome of the case. Id. at 299, 577 A.2d at 553.
79. During the federal habeas corpus hearing, Mrs. Show informed District
Attorney Madenspacher that she recalled seeing a car of brownish color
the morning of the murder as she reentered the condominium complex.
Her memory was refreshed as she sat in the courtroom listening to the
testimony of former Detective Savage. This was immediately brought to
Page 555 of 2301
the attention of the federal judge, who conducted a hearing in chambers

on April 16, 1997. Mrs. Show's recollection was then made a part of the
federal record.
81. See Lambert v. Blackwell, 962 F. Supp. at 1546.
82. This argument was accepted by the district court. Lambert v.
Blackwell, 962 F. Supp. at 1546.
83. The district court found that Mr. Kenneff's "violation" of an ethical duty
in contacting Dr. Mihalakis was a "no-brainer," which is an interesting
characterization of an issue which required expert testimony. This finding
is just not true. At least three bar association ethical committees have
concluded that the Rules of Professional Conduct do not expressly prohibit
a lawyer from contacting an expert retained by opposing counsel and that
the resolution of the issue is "fact sensitive." See Philadelphia Bar
Association Professional Guidance Comm., Guidance Op. 94-22 (1995). See
also ABA Comm. on Ethics and Responsibility, Formal Op.93-378 (1993);
New York State Bar Ass'n, Comm. on Professional Ethics, Ethical Op. 577
(1986).
84. This is a concept which does not appear to have been lost on the
district court. See Lambert v. Blackwell, 962 F. Supp. at 1547 n.39.
85. The Reed report, Petitioner's Exhibit 1299, is not contained in
Commonwealth's Exhibit 4, a compilation of all reports given to Mr. Shirk
in discovery.
86. Only recently, in the 1995 amendments to the Juvenile Act, can an
offender's juvenile record be used for impeachment purposes, much like
an adult record. 42 Pa. C.S.A. Section 6354(b)(4) (1998 Supp.) This was
not the state of the law in 1992.
87. Petitioner tends to define "perjury" as "information which does not
help her." Or, petitioner points to evidence which she finds incredible or
with which she disagrees and labels it "perjury." See, e.g., Lambert v.
Blackwell, 962 F. Supp. at 1531 (Mr. Yunkin's testimony about the "29
questions"), 1535 (Mr. Yunkin's statement about picking up Ms. Lambert
and Ms. Buck on Oak View Road), 1545 n.35 (Mr. Savage's testimony about
Mr. Yunkin's recorded statement), and 1542 (Detective Solt's testimony
about taking the statement from Ms. Lambert).
88. Testimony at the PCRA hearing established that Ms. Lambert gave the
first part of her statement to Corporal Solt sitting at a desk in the East
Lampeter Township police station. Thereafter, she was moved to another
portion of the station, where she sat in the open squad room. Lieutenant
Renee Schuler testified that from that vantage point, Ms. Lambert was able
to hear the ongoing broadcast over the police radio about the progress of
the efforts to locate the bag Ms. Lambert and Mr. Yunkin threw into the
Page 556 of 2301
dumpster behind the K-Mart after the murder. (N.T., PCRA at 3838-39,
3840-41.) It is entirely likely and believable that Ms. Lambert heard the
transmission that the bag had been found and, at that point, chose to come
clean with Corporal Solt about what she was wearing that morning.
89. The closest petitioner can come would be the closing argument of
James P. Cullen, Esquire, (now Judge Cullen) defense counsel in the Buck
trial. Mr. Cullen referred to the clothing worn by Ms. Lambert on the
morning of the murder and argued that it was ridiculous to think that she
would be wearing that clothing. He was clearly attempting to implicate Mr.
Yunkin in the murder. His reference was to an oversized flannel shirt and
he did not specifically refer to the sweatpants.
90. We should bear in mind that this theory is generated by the creative
machinery which would have us believe that Ms. Lambert's incriminating
statement was actually the result of a truth serum injection, that Ms.
Lambert's admission to wearing clothing found in the dumpster was
actually the result of a fabricated statement, that the crime scene
photographs were actually taken after the body was carried back into the
condominium by crooked police officers under the cover of night, and that
the dying declaration was really the result of a cunning detective's
suggestion to a distraught mother that she lie through two preliminary
hearings and two homicide trials to support a "frame up" that would
presumably convict defendant, who said she was once gang raped by three
police officers.
91. Of course, the best way to address this issue would have been to ask
Mr. Yunkin to try the pants on during his testimony. Neither side suggested
this step.
92. The federal testimony by Mr. Roberts, after viewing both videotapes,
was that he had, in fact, edited the video before giving it to the police:
Q. Is it possible that you edited those items out when you made this?
A. Sure. I probably did. I don't think anybody had anything to do with that
but me.
...
THE COURT: I'm a little confused based on that last answer you gave,
couple answers ago to Mr. Madenspacher.
THE WITNESS: Sure.
Page 557 of 2301
...
THE COURT: You have no reason to believe that when you made the copy
originally, that you gave it to them in an edited form?
THE WITNESS: I think it was in an edited form when I gave it to them,
yes. I think now -THE COURT: And it was edited?
THE WITNESS: -- after seeing it, I -THE COURT: Why would it have been edited?
THE WITNESS: By me.
THE COURT: Why would you have edited it? It might have been an
important thing.
THE WITNESS: To cut out the walking and to cut out something else. But
nothing -- it wasn't an important situation at all to me.
THE COURT: It is now.
THE WITNESS: I know.
THE COURT: So I want you to be very careful. You're being 'very sloppy' in
your answers, so let's try this again. Go ahead. I'm not going to let you
leave here until we find the truth. That's the purpose of this. You
understand that?
THE WITNESS: Well, I would not lie on the stand.
THE COURT: And you understand that you're under oath, don't you?
THE WITNESS: Yes, I do, and I would -THE COURT: Good. And I want you to be -THE WITNESS: And I would not lie on this stand.
THE COURT: I want you to be 'very careful.'
Page 558 of 2301
93. The federal district court concluded that a sneaker was found inside a
plastic bag. See Lambert v. Blackwell, 962 F. Supp. at 1543. However, a
review by this court of both videotapes of the river search confirms that
the pink bag and the other bag were both empty. A conclusion that one of
these bags contained a sneaker re quires a leap from the premise that Mr.
Yunkin's sneakers were put in a plastic bag to the conclusion that because
plastic bags were found, they must have contained sneakers and those
sneakers were then destroyed by the police. This "leap" requires reliance
on another unfounded assumption: that the police within a day or two
after the murder, were doing everything possible to destroy proof of Mr.
Yunkin's involvement. This is contrary to the credible testimony of both Mr.
Madenspacher and Mr. Kenneff that the Commonwealth was very
interested in any evidence which would tie Mr. Yunkin into the murder.
Further, this "leap" assumes that the police ignored another reality: that a
bag containing Mr. Yunkin's sneakers but discarded by Ms. Lambert would
have been further evidence of her involvement in the murder or in the
conspiracy. Moreover, a sneaker was found but not until the second search
conducted on December 23, 1991. Mr. Roberts was not present on
December 23, 1991, and no videotape was done of that search.
94. On cross-examination Ms. Lambert explained that the items were first
placed in a white bag and it was when they arrived at the river that Mr.
Yunkin took the white bag and placed it inside a red trash bag weighted
down with rocks. Ms. Lambert then threw the red bag into the river. (N.T.,
Trial at 1154-55.) Mr. Yunkin testified that the bag thrown into the river
was white. (N.T., Trial at 262-63.)
95. Petitioner's Exhibit 1016-A is a 16-page Pennsylvania State Police
Investigative Report by Corporal Solt concerning his interviews with Ms.
Lambert on December 21, 1991. Attached to the report is a photocopy of
the seven page "Solt Statement" signed by Ms. Lambert, five and one-half
typed pages and one and one-half handwritten pages. The body of the 16
page report contains a summary and quotes from the 7 page statement.
96. This is a story created by Ms. Lambert, Ms. Buck and Mr. Yunkin in
preparation for possible questioning by the police.
97. At this point, Corporal Solt began to take a second statement from her,
i.e., the "Solt Statement." He asked Corporal Renee Schuler of East
Lampeter to assist him by taking notes as Ms. Lambert talked. Corporal
Solt then typed out the statement and gave it to Ms. Lambert for her
review and approval. This is Petitio ner's Exhibit 1023.
98. Mr. Yunkin had, in fact, signed his statement the very same way.
99. We note that the federal district court found that the statement was a
"fabrication." See Lambert v. Blackwell, 962 F. Supp. at 1541-1542. There
is no mention in the district court's analysis of the December 23, 1991,
letter from Ms. Lambert to Mr. Yunkin nor is there any reference to Mr.
Page 559 of 2301
Shirk's testimony about his reviewing the statement very carefully with
Ms. Lambert prior to trial. Nor is there any reference to Ms. Lambert's clear
testimony at trial about the accuracy of the "Solt Statement." Perhaps had
these important facts been made available to the district court, the leap
from "unique" to "fabricated" would have been approached with
somewhat more caution. We do not accept the conclusion that Detective
Solt's testimony about the statement was "perjury" based upon Mr. Ries's
weak testimony that the statement was "unique."
100. Indeed, according to Dr. Smialek, the stab wound to the back would
have caused death within a matter of minutes.
101. It is worth considering that the charge of "fabricating" crime scene
photographs of the hallway concerns police conduct at the time of the
investigation or within the next day. At that point, Ms. Lambert had told
the police that Ms. Buck went crazy in the condominium and that she
(Lambert) turned away in horror. The story about grabbing Laurie Show's
wrists and attempting to pull her from the bedroom into the hallway did
not materialize until the trial. Yet, Ms. Lambert contends that the police
altered or staged photographs on December 20 or 21, 1991, to discredit a
story they would not hear until July 1992 in a courtroom.
102. At the start of the hearing, on April 30, 1998, petitioner's counsel
called Lieutenant Renee Schuler to the stand. Lieutenant Renee Schuler
was shown some 35 items of evidence which had been marked for
identification by petitioner's counsel. Normally, the court reporter would
mark exhibits but because of the large number of exhibits and because
many of these exhibits had been used previously by petitioner's counsel,
the court believed that the best system would be for them to use their own
numbering system. After 30 some exhibits had been shown to Lieutenant
Schuler, counsel for the Commonwealth pointed out that two items had
been marked Exhibit 883, two items had been marked Exhibit 900, none of
the exhibits marked had any dates or initials as to who marked them, and
that at least one empty envelope that came with an exhibit was no longer
attached to the exhibit. (N.T., PCRA at 137.) We took a recess and
determined that the safest course would be for the court reporter to mark
the exhibits. A substantial portion of the afternoon of April 30 and nearly
all of the morning of May 1, 1998, were consumed with the remarking and
organization of these exhibits. This substantial delay was caused by the
lack of any true organization of these important exhibits despite the good
efforts of petitioner's counsel. This is testimony itself to the difficulty in
managing large numbers of exhibits in a complex case where problems
arise from these circumstances without any dishonest or otherwise bad
motive.
103. As a practical matter, we believed and expressed to counsel at that
time that possible sanctions for his conduct in the Lambert investigation
imposed by the federal courts or any possible contempt citation for failure
to answer questions at the PCRA hearing would be of little concern to Mr.
Reed. He had just been convicted of five sex offenses. At the time this
discussion was taking place on May 11, 1998, Mr. Reed faced a substantial
state prison sentence. On July 6, 1998, Mr. Reed received a sentence of 9
Page 560 of 2301
to 18 years.
104. Commonwealth's Exhibit 4 is a compilation of police reports produced
to Mr. Shirk in discovery in 1992.
105. Ms. Buck, in her testimony at the PCRA hearing, confirmed that
Laurie's hair was cut with the knife. She recalls that Ms. Lambert cut
Laurie's hair.
106. She was emphatic about this because to establish her reason for not
seeking help for Laurie Show or contacting the authorities regarding the
brutal murder, she stated she was watched all day by Mr. Yunkin "like a
hawk." (N.T., PCRA at 5569.)
107. This is yet another example of an issue which on superficial analysis
looks bad. Upon careful consideration of what the license plate was, what
steps were taken by the police and what it ultimately might mean, what
looked bad has really no significance. An analysis of this issue which
proceeds beyond the superficial establishes no Brady violation.
108. Mr. Jeffries was listed as a Commonwealth witness in the PCRA case.
Despite this, and without leave of court or discussion with the
Commonwealth, petitioner's counsel retained Mr. Jeffries as their own
investigator. They did this despite the fact that Mr. Jeffries worked closely
with Mr. Shirk in 1992 and Mr. Shirk is the object of some 25 counts of
ineffective assistance of counsel.
109. We need not develop, but should note, that this theory is completely
at odds with the Baden/Smialek/Larson expert triumvirate which opined
that Ms. Show was dead anywhere from one minute (with the carotid
severed) to five minutes (under the best of conditions) after her wounds
were inflicted. Petitioner's counsel would have this court believe, by virtue
of Baden/Smialek/Larson that Ms. Show was dead almost immediately.
Yet, she was able to move across the floor to the closet door and inscribe
initials on the door. It appears that this would have taken much more
effort, thought and fine motor skill than the breathy, hoarse whisper she
uttered to her mother as she died.
Copyright 1997,1998, County of Lancaster, Pennsylvania. All Rights
Reserved.
Page 561 of 2301

Page 562 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
11 of
of308
456
454

June
June 14, 2016
Stan J. Caterbone
Freedom From Covert Harassment &
Surveillance,
1250 Fremont Street

Lancaster, PA 17603
scaterbone@live.com
717-669-2163
June 14, 2016

Dave Brown
Pearson Koutcher Law
1650 Arch Street
Suite 2501
Phone: 215-391-4963
Fax Number: 267-319-1233
cc:
Linda Stein, lstein@21st-centurymedia.com, @lsteinreporter on Twitter
Re: Letter of January 23, 1998 to Ms. Christina Rainville, Former Attorney for Lisa Michelle
Lambert
Dave,
Attached is a letter that I wrote to Ms. Christina Rainville, Lisa's former attorney. This will provide
you with some information that you might use in the future. First it brings to light that I was
raising issues of prosecutorial misconduct within the Lancaster County DA's office before Lisa's
PCRA Hearing of April of 1998. Second, it demonstrates just how effective they were at
brainwashing and conditioning me. During June of 1987 after my meeting with ISC Executive
Larry Recsh my mental capacity became front and center. During that time I denounced anyone
who conveniently mentioned me and mental illness in the same sentence. It was the perfect
cover story to hide all of my allegations of misconduct by ISC, and by my Board of Directors of
Financial Management Group, Ltd., Then my Mom came to me pleading for me to take my
medicine. She would say, Stan, do it for me. I would give in and low and behold, someone
would provide me with a job or a source of income. In 1988 Dave and Pam Pflumm gave me
some work painting their new purchased property at 4538 Main Street, Conestoga. Then Scott
Robertson negotiated a settlement with Bob Kauffman for him to purchase all of my stock in
Financial Management Group, Ltd. I had paid $20,000 for my stock in 1986 and Bob extorted it for
about $125,000 in November of 1988.
Then, Scott Robertson came to me and wanted me to be a trouble-shooter up at Tony Bongiovi's
Power Station Studios in New York. Of course, me, Tony and Scott worked together in 1987 on
the Digital Movie. Now, in the summer of 1987 Tony wanted me to oversee and manage all of his
business affairs. One night in the summer of 1987, while on the Wildwood Boardwalk Tony
offered to pay me to oversee every business project he was involved in and provide me an
equity interest in all of them. This included the Digital Movie, his interest in the Pier on the
Wildwood Boardwalk, his project involving finding the missing plane of Amiela Aehart, Power
Station Studios, Wid, the Comedian, etc., then Scott wanted me to write the business plan for the
American Helix CD-ROM division and provide consulting for the same. At the time I was being a

Letter to Lambert Author Dave Brown
Page 563 of 2301

Page 2 of 456

June 14, 2016
good boy and took my medicine for a mental deficiency that was created by the Lancaster
Establishment as a cover story. But, what choice did I have, it was the only way they would let
me work and provide income.
Well, after awhile, after I would get settled in at making a living once again, something would
happen that would reignite the flames of the fraud and extortion of 1987. Now, you must
understand, I was the only person in Lancaster making allegations against ISC and Chem Con.
Back then ISC and James Guerin were considered Royalty. Then in or about 1989 some
information was beginning to surface about ISC and the fraud. Well, by 1991, I again was proven
to be right and I began to revisit my legal claims. Low and behold, my income would
disappear, and before you know it the cash I had in the bank would dwindle due to the
fact I had to use it to pay my living expenses. This cycle would repeat itself again in
1998 and again in 2001 (1987; 1991; 1998; 2002). Every time it did, the claims of
mental illness would surface again. It was an effective conditioning tool, as well as a
means to discredit my allegations. And, of course they would effectively extort my
savings and my income sources.
After careful research, I began to put things together in 2004 when I began to again peruse my
legal claims. Well, on May 16, 2005 I filed as pro se and in the beginning of 2005 or late 2004 the
all out assault with electronic harassment began to supplement the always pervasive organized
stalking initiative, which began back in 1987.
My point being that I raised the legitimate issues regarding the fact that the Lancaster County
District Attorney's Office, through the malicious and selective prosecution of both myself in 1987,
and then Lisa in 1992 constitutes a bona fide criminal enterprise as defined in the RICO statutes.
BEFORE THE PCRA HEARING OF APRIL OF 1992.
Hope this helps.


1250 Fremont Street

Lancaster, PA 17603
717-669-2163
ACTIVE COURT CASES
Superior Court of Pennsylvania AMICUS for Kathleen Kane Case No. 1164 EDA 2016; Case No.
1561 MDA 2015; 1519 MDA 2015
Lancaster County Court of Common Pleas Case No. 08-13373; 15-10167; 06-03349, CI-0603401

Page 564 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
33 of
of308
456
454

June
June 14, 2016

Page 565 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
44 of
of308
456
454

June
June 14, 2016
1 of 2

Page 566 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
55 of
of308
456
454

June
June 14, 2016
Daily Local News (http://www.dailylocal.com)

Dave Brown collaborates with Lisa Michelle Lambert for novel titled Love, Murder and Corruption in Lancaster County: My
Story
By Linda Stein, lstein@21st-centurymedia.com, @lsteinreporter on Twitter

Tuesday, June 7, 2016
After writing four sports-related books, local author and lawyer, Dave Brown, took a walk on
the dark side.
His most recent title is a true crime tome: Love, Murder and Corruption in Lancaster County:
My Story, co-written with Lisa Michelle Lambert, who was convicted of the Dec. 20, 1991
murder of her romantic rival, Laurie Show.
I had followed Lisa Lamberts case in the papers over the years, dating back to the 1990s,
said Brown, 55. I always thought she got a raw deal. I thought it was very unfortunate.
Although he specializes in workers compensation cases and has no desire to branch out into
criminal law practice, Brown said that as a reader, he has an interest in true crime in general.
He believes a lot of people are wrongly convicted based on misconduct by police and
prosecutors.
Brown was thinking about what topic to write about next and decided that Lamberts story
would make for a compelling book. He wrote Lambert a letter then went up to the womens
state prison in Framingham, Mass., where Lambert, who maintains her innocence, is serving a
life sentence and spoke with her.
She herself is quite articulate, he said.
Lambert, 43, earned a college degree from Boston University while in a prison program and
finished a valedictorian, he said. Lambert had also written some chapters about her turbulent
childhood and abusive boyfriend and the abuse she suffered in prison, he said. (In 2007 the
state of Pennsylvania paid Lambert $35,000 to settle allegations of sexual abuse by prison guards. She was also assaulted by other
inmates at a prison in New Jersey, where she had been transferred.)
She wrote probably 80 percent of the book, said Brown. She writes so well that I was proud to write with her.
They decided to collaborate on the book with Lambert telling her story and Brown writing legal commentary. Their four-year long
collaboration entailed drafts sent back and forth in the mail and resulted in an 800-page manuscript that the publisher deemed too long.
Now cut in half, the book was published in February by Camino Books.
I talked to (Lambert) on the phone a couple hundred times since this started, about once a week, Brown said.
One interesting aspect of the case is that a federal judge, Stewart Dalzell, cited wholesale prosecutorial misconduct and threw out
Lamberts conviction in 1997. Dalzell held the misconduct was so outrageous the commonwealth should never be given an opportunity
to retry her, Brown noted.
However, Dalzells decision was overturned on appeal and the same judge, Lawrence F. Stengel, who convicted Lambert during a bench
trial in Lancaster County, convicted her again at a retrial. Brown said Dalzell was overturned on a technicality, because Lambert had
not exhausted her state court remedies before appealing to the federal court system.
The (Lancaster) community had it out for Lisa Lambert, said Brown. They didnt know all the facts. The two other people (Tabitha
Buck and Lawrence Yunkin) were the ones who really carried out the murder. Buck is serving a life sentence without the possibility of
parole and Yunkin served about 12 years out of a 10 to 20 years sentence for his role in the crime.
6/14/2016 2:00 AM
2 of 2

Page 567 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
66 of
of308
456
454
June
June 14, 2016
Stengel took umbrage that Dalzell walked all over his original decision, said Brown. Although Lambert appeared to have exhausted her
appeals after being rebuffed by the U.S. Supreme Court, Brown said new evidence has come to light and he is hopeful she will be
exonerated at long last.
Brown said that new evidence is an admission of misconduct that John Kenneff, the assistant district attorney who prosecuted Lambert,
allegedly made before his death.
Incredible corruption pervaded the Lancaster judicial system, Brown said.
Brown also hopes to find a new criminal lawyer in Pennsylvania to take up the cudgel on Lamberts behalf, working with a Los Angeles
attorney who is interested in the case.
Shes looking at a life sentence unless we can get this reversed, said Brown.
Brown, who grew up in Strafford and graduated from Conestoga High School, loved to read and write since I was a little kid. He went
to Gettysburg College, worked awhile and then attended law school at Dickinson. Although he likes practicing law, I always wanted to
publish a book more than anything.
I enjoy being a lawyer but my true passion is writing, said Brown.
He has also been a big sports fan since childhood, hence his interest in writing about sports, especially baseball. Brown lives in Chester
Springs with his wife, Kim, and their two sons, ages 12 and 11, and their 7-year-old daughter.
Brown will be signing copies of Love, Murder and Corruption in Lancaster County: My Story at three Barnes & Noble branches on
June 18: 10 a.m. at Fairless Hills; 1 p.m. at Neshaminy; and 4 p.m. at Plymouth Meeting.
URL: http://www.dailylocal.com/general-news/20160607/chester-springs-man-co-authors-murder-novel
2016 Daily Local News (http://www.dailylocal.com)
6/14/2016 2:00 AM

Page 568 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
77 of
of308
456
454

June
June 14, 2016
January 23, 1997

Mr. St an J. Cat erbone
220 St one Hill Road
Conest oga, PA 17516
Ms. Christ ina Rainville

1300 Market St reet
RE: Previously discussed m at t ers.
Dear Ms. Rainville:
I t hank you for your help regarding t he enclosed m at erials. As I have discussed
previously, I would appreciat e your legal opinion as t o t he ext ent of m y legal right s
concerning t he following circum st ances.
I will at t em pt t o describe t he m any legal issues t hat are cont ained herein, and I have
provided docum ent at ion subst ant iat ing m y claim s. Due t o t he com plexit y and
sensit ive nat ure of t hese issues, I have t ried t o reduce t he paper t o it s sim plest
form , while also prot ect ing t he int egrit y of m y claim s. I have also provided aut hent ic
conversat ions, which I recorded m erely in m y defense as an accurat e account of t he
act ivit ies surrounding m y sudden dem ise. I possess m any m ore form s of evidence,
including over 9000 paper im ages t hat I had m icrofilm ed in Novem ber of 1987.
I realize t hat you offered t o review only a few docum ent s, however it was necessary
t o form ulat e t he docum ent s in a way t hat was sufficient t o challenge t he legal issues
t hat I am quest ioning. Docum ent s 1 & 2 would provide a glim pse int o t he legal
m erit s of m y claim s. The following is an at t em pt t o provide you wit h a brief
descript ion of t he act ivit ies and act ions cont ained in t hese m at t ers. Please
underst and t hat I have not included any relat ed act ivit ies t hat cont inued during
1991, especially concerning I SC and t he Cent ral I nt elligence Agency ( CI A) .
The following is a legend of t he conversat ions cont ained on t he Com pact Disc:
2. 09/ 29/ 87 - A segm ent of t he int erview wit h t he PA Securit ies and Exchange
Com m ission, Agent Howard Eisler, At t orney Robert Beyer, Client
Millard Johnson, and m yself, present .
3. 02/ 24/ 88 - Meet ing wit h At t orney Sandra Gray, of San Diego, California.
4. 07/ 10/ 87 - Phone conversat ion wit h Chuck Sm it h, President of Lancast er
Aviat ion.
5. 07/ 07/ 87 - Phone conversat ion wit h At t orney David Drubner.
6. 07/ 21/ 87 - Meet ing in Hollywood California wit h t he owner of Gam illion Film
St udios, who was seeking m y help t o secure financing. Also present is
Marcia Silen, a producer of t he Digit al Movie .
7. 10/ 27/ 87 - Telephone conversat ion wit h Pennsylvania Securit ies & Exchange

Page 569 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
88 of
of308
456
454

June
June 14, 2016
Com m ission Agent , Howard Eisler.

8. 10/ 26/ 87 - Det ect ive Boden, of t he Pennsylvania At t orney Generals office.
9. 02/ 24/ 97 - ABC News 20/ 20 segm ent on I nt ernat ional Signal & Cont rol, and
Arm s t o I raq.
Please forgive t he form of t he following narrat ive, however it is especially draining t o
prepare t hese m at erials. This is t he first t im e t hat I have at t em pt ed t his t ask, wit h
t he except ion of various effort s which were int ended t o m erely defend m yself, m y
person, m y charact er, m y reput at ion, or m y asset s. You will event ually discover t hat
t he quest ion of m y m ent al condit ion is of grave im port ance t o m y perpet rat ors. For
t he record, I do suffer from Bi Polar Mood Disorder, however, no where during all of
t hese act ivit ies can anyone prove t hat I have act ed irrat ionally or insane, t he t rut h t o
m y act ions are well recorded, however t he m assive at t ack on m y m ent al condit ion is
proven t o be cent ered around lies and hearsay.
Any help pert aining t o t hese m at t ers, no m at t er how sm all, will be great ly
appreciat ed. Please invoice m e accordingly.
Th e Ba ck gr ou nd.
Ten years ago I had built a financial firm , Financial Managem ent Group, Lt d., ( FMG) .
I n 1985 I had conduct ed a m arket ing st udy t hat included int erviewing m ore t han 5
local physicians, all of subst ant ial wealt h or incom e. I had m erely described m y
st rat egic plan for FMG, and t hey gave m e feedback, all posit ive and ent husiast ic. I n
1986 I incorporat ed 11 different corporat ions, all under t he ownership of FMG. To
at t ract local t alent , FMG was owned by not only t he 3 principals, but st ock was
offered t o every professional in t he organizat ion, including sat ellit e offices. I had
raised approxim at ely $400,000 of capit al t o st art t he com pany, and I did it in
com pliance of t he PA SEC Rule 144 Regulat ion D public offering.
I n one year, we had phenom enal growt h. By June of 1987 we had invest ed
approxim at ely $50 m illion of client funds. We provided relat ively m ost of t he financial
services necessary during ones lifet im e. On t he st reet s our organizat ion was wort h
approxim at ely $4 m illion, which is st rict ly correlat ed t o t he com m issions paid out .
We had at least 10 sat ellit e offices, and covered 5 st at es. We also owned an int erest
in t he PSG Broker Dealer, which was wort h anot her $1.5 m illion.
I was Execut ive Vice President and Secret ary of FMG. I was President and Secret ary
of FMG Advisory, which was our Regist ered I nvest m ent Advisor ( RI A) . I had been
pushing t hrough t he approval process wit h t he Pennsylvania Securit ies and Exchange
Com m ission for m ore t han 6 m ont hs, concerning t he RI A.
I n early 1987 I had developed a m ort gage banking operat ion. I had negot iat ed wit h
a large Sout hwest ern m ort gage firm t o provide m ort gages for East ern Pennsylvania.
Our lending capacit y ranged from a m inim um of $3 m illion and as high as $100
m illion. Even m ore im port ant was t he fact t hat t his lending capacit y was very and
som et im es m ore com pet it ive t han ot her area lending inst it ut ions, I had short ly
developed a very large list of client s for whom I was t rying t o secure financing for
various t ypes of proj ect s.
Com bining t he m ort gage banking services wit h t he abilit y of FMG t o secure financing

Page 570 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
99 of
of308
456
454

June
June 14, 2016
t hrough equit y invest m ent program s, I was very at t ract ive t he real est at e
com m unit y t hat had deals t o finance. My second cousin, in Houst on, TX, provided m e
wit h t his opport unit y. I n t he m at er of 2 m ont hs, we had m et not only wit h several
large local developers, I had also begun business wit h com panies locat ed in m ore
t han 5 ot her st at es. I had provided a com m it m ent let t er for $5 m illion m ort gage for
Norris Boyd, of Boyd Wilson, for t he Village of Old Hickory. Norris Boyd had
personally inform ed m e t hat I had a bet t er deal t han t he Com m onwealt h Nat ional
Bank ( who will lat er illegally reposes m y airplane) , where t he loan was current ly
secured.
I n February of 1987, because of our abilit y t o raise capit al, Scot t Robert son
request ed t hat I assist him in visit ing Power St at ion St udio, who was t rying t o secure
financing for a m ovie. Reluct ant ly, due t o t he risk involved wit h m ot ion pict ure
invest m ent s, I went t o Power St at ion St udios, in Manhat t an. Tony Bongiovi built
Power St at ion St udios t o be am ong of an elit e few. The nam es of st ars t hat recorded
t here was very im pressive. Tony also produced t he sound t rack for St ar Wars, which
was very profit able, and st ill is. Anot her proj ect , alt hough cont roversial, was his
cousin, Jon Bon Jovi. Power St at ion is where Jon Bon Jovi began his am azing career,
under early developm ent of Tony, his cousin. Cont ract ual disput es ruined t he
relat ionship, which put large sum s of m oney t o risk. Jon Bon Jovi is one of t he
leading all t im e m usicians, in t erm s of revenues.
Tony described his proj ect , which was not m erely j ust a m ovie. Tony want ed t o
develop t he first Digit al Movie . Given m y t hirst for t echnology, along wit h a
dem onst rat ed knowledge, I becam e infat uat ed wit h t he concept , t he concept of
providing t he highest qualit y of sound, along wit h t he highest qualit y of video. I had
researched t he m erit s of t he t echnology, which com plim ent ed m y own vision, and
found a t rem endously feasible proj ect , one which would have t he pot ent ial t o have a
m aj or im pact int o t he film and video indust ries. I had always personally believed t hat
sound was as im port ant as t he pict ure for t he t ruest sense of ent ert ainm ent . The
following docum ent s will dem onst rat e m y invest m ent int o t his t echnology, along wit h
m y keen sense of percept ion. Today we call t his Direct Broadcast Sat ellit e DSS,
which is current ly causing t he cable indust ry great pains. The consequences of digit al
t echnologies t o t he world of inform at ion is what now gives us t he I nform at ion
Highway, and all of it s peripheral com ponent s.
The following docum ent s will easily confirm m y int erest s t o t he preceding t hree
businesses, FMG, t he m ort gage banking operat ion, and t he Digit al Movie proj ect .
The relat ionship t o m y part ners was less t han am icable. I n developing FMG I agreed
t o let Mr. Robert Kauffm an ( Kauffm an) act as President , upon t he condit ion t hat we
each own t he sam e am ount of st ock. Mr. Michael Hart let t ( Hart let t ) did cont ribut e t o
t he early developm ent of FMG. Since Kauffm an could not cont rol m e, Kauffm an and
Hart let t would of at t em pt t o buy m e out , well aft er I creat ed and incurred t he m ost
risk, and aft er t he proven success of t he organizat ion. I n t he Spring of 1987, I had t o
personally t ake cont rol of t he Board of Direct ors t o undue a m erger t hat present ed
great risk t o t he com pany, and m y invest m ent . As part of our st rat egic plan, we
agreed t o purchase an int erest in a Broker Dealer, rat her t han spending t he capit al
and hum an resources in which it would require. I had personally t raveled t o
Washingt on D.C., t o visit t his com pany, which was Kauffm ans idea, and I lit erally
found an em pt y shell. I found offices full of em pt y cart ons, em py file cabinet s, and
t his was t he com pany t hat was responsible for processing all of t he securit ies
business t hat our brokers t ransact . This process was vit al t o our organizat ion.

Page 571 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
10
10 of
of308
456
454

June
June 14, 2016
I im m ediat ely flew t o At lant a, GA, t o visit anot her com pany, PSC, which had been
court ing our com pany for a relat ionship for alm ost a year. I t was a com pany t hat
provided t echnology, service, affiliat es which account ed for several of t he past
president s I nt ernat ional Associat ion for Financial Planners, of which I served as Vice
President t he Cent ral Pennsylvania Chapt er. ( This associat ion provided m e wit h t he
nat ional exposure t o develop FMG.) I n May of 1987, while t raveling t o a conference
in Palm Springs, CA, t he FMG Board of Direct ors approve t he m erger of PSG, I had
vot ed via t elephone from an airport in Chicago.
The would be t he last t im e t hat I would vot e at an FMG Board of Direct ors m eet ing.
This is when I loose virt ually everyt hing t hat is vit al t o a businessm an, m y asset s,
excellent credit rat ing and m y spot less reput at ion, m y professional designat ions and
licenses, t he opport unit y t o cont inue t he vast business opport unit ies t hat I have
developed, and m ost painfully, m y dignit y - - - all wit hout m erit or reasonable cause.
June 2 3 , 1 9 8 7
10: 30 am . I have a schedule m eet ing wit h Mr. Larry Resch and Mr. Carl
Jacobson,bot h of I nt ernat ional Signal & Cont rol, ( I SC) and Unit ed Chem Con. The
m eet ing was t o discuss different financial deals. Upon arriving, Mr. Resch disclosed
t o m e t hat t hey had t o fly Carl out of t he count ry t his m orning, he will not be here.
I rem em ber t hat t here was a lot of nam es and places, all over t he world, t hat
m ent ioned.
During our discussions, I had becom e annoyed at som et hing, so I began m aking
assert ions t hat I SC and Mr. Jam es Guerin was involved wit h fraudulent act ivit ies. I
furt her described som e of t hose act ivit ies.
I did not know t hat Mr. Resch was as close t o Mr. Jam es Guerin as you could get .
At approxim at ely 3: 00 t hat sam e aft ernoon, I had Russell Locksm it h com pany
change t he locks t o m y office door. Bet ween m y part ners and I SC, I apparent ly
becam e concerned.
2 Days lat er, on June 25t h, via t elephone, Mr. Kauffm an carelessly report ed t hat 2
st ock cert ificat es were issued, wit hout m y aut horizat ion.
First , I , act ing as Secret ary ,I m ust aut horize and issue st ock cert ificat es, in
accordance t o t he Art icles of I ncorporat ion.
Secondly, Kauffm an and com pany m ust have burglarized m y office t o gain access t o
t he corporat e records, which were under m y cust ody, as defined in t he Art icles.
Several days lat er, during t he night , I had went int o m y office and rem oved all of m y
files, and upon finding a forged st ock cert ificat e wit h anot her Board of Direct or
signing as m yself and as Secret ary, which violat ed several bylaws of t he Art icles of
I ncorporat ion.
The next day I went t o t he office of m y at t orney, Mr. Joseph, who advised m e t o
ret urn all of t he corporat e files, and essent ially suggest ed t hat I go hom e and get

Page 572 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
11
11 of
of308
456
454

June
June 14, 2016
som e rest . Mr. Roda would lat er represent Mr. William Clark, corporat e legal counsel
for I SC against Mr. Jam es Guerin in cont ract disput e for several m illion dollars.
That aft ernoon, I loaded all of m y files int o m y airplane, t o t ransport t o St one Harbor
NJ, where I was rent ing anot her house for t he Digit al Movie proj ect . I had secured
pilot s from Rom ar Aviat ion t o t ransport t he files early t he next m orning. I had driven
t o New Jersey t hat evening.
That next m orning, t he pilot t hat I had hired t o fly m y plane, t elephoned m e and
inform ed m e t hat m y plane was repossessed and locked in a hanger, and he would
not be able t o deliver m y files.
Those files were t he only m eans of subst ant iat ing t he t rut h in order t o prot ect m yself
from what ever was happening.
My first paym ent t o Com m onwealt h Nat ional Bank, was not due for anot her m ont h.
I n short , I finally found a pilot at t he Cape May Airport t o fly t o Lancast er t o m y
files.He ret urned hours lat er wit h m y files, and would only m ent ion som e incident
involving a gun. Lat er I would be t old t hat he died a m yst erious deat h t he next
m ont h.
Not knowing t hat Com m onwealt h Nat ional Bank, t he sam e bank t hat I was about t o
t ransfer $5 Million m ort gage t o m y m ort gage operat ions, had act ually repossessed
m y t it led airplane in t he m iddle of t he night . And convenient ly wit h all of m y files
aboard. What bank repossesses legit im at e possessions in t he m iddle of t he night ?
This will be t he end of m y life as I know it , I had dem onst rat ed m y success, m y
reput at ion was exem plified t hrough m y abilit y t o develop FMG, and m y financial
credit was flawless. I n t he following m ont hs, I will suspiciously loose everyt hing;
including m y asset s, m y business int erest s, m y reput at ion, m y credit , and t he m ost
valuable of all, m y opport unit y; and ult im at ely, m y dignit y. I n realit y, I was never
even given t he chance t o fail.
I will cont end, and prove, t hat all of t he act ions were wit hout m erit and m any of
which were fraudulent t hem selves, and I know t hat I can subst ant iat e t hat
st at em ent .
According t he Art icles of I ncorporat ion, I was never legally rem oved as Secret ary, or
any ot her official dut ies. Because, t here cant be a Board of Direct ors Meet ing
wit hout m e, t he Secret ary. The record in t he prelim inary hearing t ranscript clearly
proves t hat t here was no legal Board of Direct ors Meet ing t hat rem oved m e.
I never resigned from any posit ions or official dut ies of FMG, nor was I ever officially
and legally rem oved from t he sam e.
I was a Tenant , wit h a $500,000 personal guarant ee at t ached t o t he lease of FMG,
Lt d.
The forgery of st ock cert ificat es violat ed t he bylaws of t he Art icles of I ncorporat ion,
t hus, as Secret ary, m y dut ies were t o safeguard t he corporat e records.
The evidence indicat es t hat all of t he arrest s were fabricat ed, t he airplane
repossession was illegal, and all of t he allegat ions of insanit y were m alicious.

Page 573 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
12
12 of
of308
456
454

June
June 14, 2016
I n Sept em ber of 1987, in t he Report t o t he Board of Direct ors of Ferrant i

I nt ernat ional, raised a quest ion of subst ant ial risk, unlike t hat of which Ferrant i was
accust om ed. The report caut ioned any alliance due t o t he relat ed CI A act ivit ies
connect ed t o I SC, and t he lack of st abilit y of t he cust om ers ( I raq?) . At t hat sam e
t im e, I was m aking public allegat ions against I SC. My conversat ions posed
considerable risk t o t hose connect ed wit h t he pending deal wit h Farrant i.
I can subst ant iat e m y claim t hat ; everyt hing t hat t ranspired during t he days
im m ediat ely following t he forged st ock cert ificat e, of FMG, Lt d., st ock on June 25,
1987 was illegal and violat ed several of t he bylaws of t he Art icles of I ncorporat ion I
was t he only officer t hat was in com pliance wit h t he bylaws of t he Art icles of
I ncorporat ion, and t he only officer t hat did not violat e crim inal codes.
I can subst ant iat e m y claim t hat I had an int erest in Digit al Technologies , including
pat ent research from Mr Joel Goldham m er, of t he law firm of Seidel, Gonda,
Goldham m er & Abbot t , P.C. of Philadelphia, which violat ed several st at ut es of
int ellect ual propert y right s. I can subst ant iat e m y claim s t hat all of t he arrest s and
hospit alizat ions were m alicious and illegal, violat ing several of m y civil right s.
I can subst ant iat e m y claim t hat m y allegat ions of fraud wit hin I nt ernat ional Signal &
Cont rol, Plc., were m ot ive for m any of m y perpet rat ors.
I can subst ant iat e m y claim t hat t he Pennsylvania At t orney Generals Office, and t he
Pennsylvania Securit ies and Exchange Com m ission; aided and abet t ed in t he sale of
Arm s and Technologies t o I raq, by virt ue of t he fact t hat I m ade form al com plaint s
involving t he sam e, and bot h agencies violat ed m y const it ut ional right s t o suppress
t he t rut h of m y com plaint s.
I can subst ant iat e t he legal validit y of t he recorded conversat ions for m y defense.
My int erest s in Digit al Technologies , and m y dem and t o be rest ored t o whole, is
t he m at t er at hand.
I Rem ain,
St an J. Cat erbone
Enclosure CD- ROM
Court tightens rules in whistle-blower cases : National-World : Albuque...
2 of 3
http://www.abqtrib.com/news/2007/mar/28/court-tightens-rules-whistle-...

Page 574 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
13
13 of
of308
456
454
National-World

June
June 14, 2016
search abqtrib.com
Home Business National/World Business
Court tightens rules in whistle-blower cases

Mark Sherman/Associated Press
Wednesday, March 28, 2007
WASHINGTON The Supreme Court made it harder

Tuesday for federal whistle-blowers to share in the
proceeds from fraud lawsuits against government
contractors.
STORY TOOLS
E-mail story
Comments
iPod friendly
Printer friendly
MORE NATIONAL/WORLD
BUSINESS
Intel CEO gets $6.18M in 2006
compensation
New Mexico, Virgin Galactic
reach agreement on lease for
space tourism base
Union, suit factory working hand
in glove
The court ruled 6-3 that James Stone, an 81-year-old

retired engineer, may not collect a penny for his role in
exposing fraud at the now-closed Department of Energy's
Rocky Flats nuclear weapons plant, northwest of Denver.
Writing for the court, Justice Antonin Scalia said Stone
was not an original source of the information that resulted
in the ordering of Rockwell International, now part of
aerospace giant Boeing Co., to pay the government
nearly $4.2 million for fraud connected with environmental
cleanup at the Rocky Flats plant.
SHARE THIS STORY [?]
Rockwell must pay the entire penalty anyway. The only

question before the court was whether Stone would get
his cut.
The company, backed by defense, energy and pharmaceutical interests, wanted the justices to
restrict when an individual can collect for suing on the government's behalf.
The Bush administration backed Stone, arguing that it was in the government's interest to
encourage whistle-blowers, even though the government keeps more money now that Stone has
lost.
Ten most e-mailed stories from abqtrib.com:

1. Editorial: Lobos coach has to win big to justify pay
2. Can Northeast Heights neighborhood embrace new
urbanism?
3. The loopy legislation of 2007
4. Red-light cameras linked to fee drop
5. Communities start cleanup after twisters
6. New Lobos coach tells Giddens to get on board, stay
there
7. The man behind Mesa del Sol is no stranger to getting
things done
8. Sculptor Glenna Goodacre regains consciousness
9. Kate Nash: Legislators had reason to be fed up with
governor
10. N.M. Medicaid changes worry hospitals
The False Claims Act allows individuals, acting on the government's behalf, to file fraud suits
against companies that do business with the government.
If they prevail, they receive a portion of what the contractor must pay the government. Lower federal
courts ruled in Stone's favor.
This site does not necessarily agree with posted comments, they are the sole responsibility of the person
posting them. Readers will be banned for posting defamatory, obscene, abusive, threatening or an invasion of
privacy comments. Read our privacy agreement.
Add your comments

(Requires free registration.)
Username:
Today's Headlines
Richardson's Quest
LoboZone
TribVid
Events Calendar
Restaurant Guide
Podcasts
Alerts
Comics
Bill Richardson Log

Roundhouse Report
Food City
ABQ AV Club
Be all you can bee
Trib Sports Extra
Wolf Tracks
Split Personality
No harm, no Fowler
High School Sports
The Flip Side
Password:
(Forgotten your password?)
Comment:
3/28/2007 8:35 PM
Los Angeles Times: Archives
1 of 19
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
ARCHIVES
NEWS
ENTERTAINMENT
JOBS
CARS
HOMES
RENTALS
MORE CLASSIFIEDS
SALES & DEALS
BUSINESS DIRECTORY
Coupons | Newspaper Ads
PLACE AN AD
ARCHIVES
Basic Search
Advanced Search
Saved Search
Logout
Account & Purchases
Knowledge Center
Archives Trouble
Report
latimes.com Site
Services
ARCHIVES HELP &
INFO
OTHER SECTIONS
Page 575 of 2301

Pager
Page 14
14 of
of308
456
454

June
June 14, 2016
MEMBER SERVICES SIGN UP
HOME | HELP
CLASSIFIEDS
JOBS CARS HOMES
Join now!
RENTALS
SHOPPING
search
i
j
k
l
m
n
Site
j
k
l
m
n
Web
Go
Start a New Search | Back to Results

Printer-Friendly Format
COLUMN ONE; A Bitter Lesson for Lancaster County; Judge says Pennsylvania community 'lost its soul'
in push to convict woman of murder. Residents claim he, not they, are mocking justice. Right or wrong,
his ruling challenges U.S. court system's balance of power. Series: * Second of two parts; [Home Edition]
BARRY SIEGEL. Los Angeles Times. Los Angeles, Calif.: Nov 10, 1997. pg. 1
Full Text (8866 words)
About the Archive

Pricing
Terms of Service
Search Tips
FAQ
Stories Prior to 1985
Obituaries
Rights and Permissions
OTHER SERVICES
Prof. Research Service
Back Issues
Front Page Reprints
Commem. Front Pages
Books
6/4/2005 9:58 AM
2 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 576 of 2301

Pager
Page 15
15 of
of308
456
454

June
June 14, 2016
Custom Reprints
Photos
OTHER RESOURCES
(Copyright, The Times Mirror Company; Los Angeles Times 1997 all Rights reserved)
Other Archives
Microfilm
By midmorning on the first day of Lisa Michelle Lambert's federal habeas corpus hearing, U.S. District Judge Stewart Dalzell
already could be seen displaying alarm over what he was hearing.
From the lawyers' briefs alone, he'd read enough to persuade him to grant Lisa's request for this uncommon federal review of a
state murder conviction. He'd read enough to suspect that just possibly,Lisa Lambert, although sentenced to life without parole,
hadn't killed Laurie Show over a teenage romantic rivalry. He'd read enough to surmise that just maybe, Lisa's boyfriend,
Lawrence "Butch" Yunkin, along with a girl named Tabitha Buck, had killed Laurie.
Now, he was listening to evidence that served only to deepen his concerns regarding Lancaster County's prosecution of Lisa.
It was March 31. Computers, boxes of documents and piles of papers filled the small hearing room on the fifth floor of the
federal courthouse in downtown Philadelphia. Lisa's parents sat in the first row, Laurie Show's behind them. Reporters and
court personnel occupied the jury box. On the stand, an expert witness for Lisa's side, Northwestern University speech
professor Charles Larson, was testifying.
Contrary to the autopsy report, Larson believed--as did three emergency medical technicians and the Philadelphia medical
examiner--that Laurie Show's left carotid artery had been severed by whoever slashed her throat. This, he explained, left her
unable to say "Michelle did it," as Laurie's mother, Hazel, had claimed. Her vocal tract was "destroyed," her left brain
hemisphere "dying." She was "totally incapable of speech."
How, asked Lisa's attorney, Christina Rainville, could two doctors have signed an autopsy report saying that the carotid arteries
weren't "involved"?
Those two doctors were both Lancaster County physicians, one the part-time coroner, the other an ear-nose-and-throat
specialist.
"I don't think they were telling the truth," Larson replied.
Dalzell peered over gold wire-rimmed bifocals at the witness. "Oh," he said. "Well, OK."
So it went, hour by hour, for 15 days.
That this hearing was even being held appalled most in Lancaster County, about 75 miles west of Philadelphia. In the 1991
killing of Laurie Show, Lisa had already been found guilty of first-degree murder, Tabitha Buck of second-degree, Butch Yunkin
of third-degree. Now here was Lisa, claiming her innocence, claiming all sorts of prosecutorial abuse. Now here was Lisa,
seeking a federal order freeing her because the state had illegally imprisoned her.
For Lisa to cast herself as an innocent victim was maddening enough. For a federal judge to take her seriously was
unimaginable. Yet that was just what was happening in this Philadelphia courtroom.
The second day of the hearing found Dalzell puzzling over two quite different versions of a videotaped police search of the
Susquehanna River. The one initially provided by the Lancaster County district attorney, eight minutes long, had no soundtrack,
and no images of police finding a pink bag Lisa said she'd thrown there. The second, obtained through discovery only after
Rainville realized she'd been sent an edited tape, was four minutes longer. It had sound. It also had an officer kicking at a pink
6/4/2005 9:58 AM
3 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 577 of 2301

Pager
Page 16
16 of
of308
456
454

June
June 14, 2016
bag while another asked, "What do you got, a bag?"

After watching these tapes, Dalzell removed his glasses and rubbed his eyes, something he'd do more than once during the
three-week hearing. He studied Lisa, also something he'd do more than once, especially in the hearing's early days. Lisa,
sobbing off and on, was staring down at the table where she sat, bent over, her hands between her legs. Dalzell looked as if he
were trying to fathom her character.
The third day found Dalzell puzzling over Lisa's initial statement to the police. He listened to East Lampeter Police Det.
Raymond Solt try to reconcile the typewritten first page, where Lisa says she wore her own clothes at the murder scene, and a
handwritten last page where Lisa says she wore Butch's sweatpants. He listened to Solt explain how he destroyed all his notes
from the interview. By the time Solt stepped down, the judge was referring openly to "Ms. Lambert's alleged statement."
With Det. Ronald Barley on the stand later that afternoon, Dalzell grew even more openly dissatisfied. Barley was a
well-regarded detective in Lancaster County. A "very thorough investigator" is how Ted Darcus, chairman of Lancaster's City
Council, considered him. Barley "dealt well with people in our community accused of crimes." Yet this wasn't apparent to
Dalzell.
Barley, being questioned about the taped interview he helped conduct with Butch Yunkin--a tape full of laughter, clicks and
obvious gaps--kept waffling so much that Dalzell finally snapped: "Answer her question! Yes or no?" Rather than heed the
suggestion, Barley grew even more evasive. Asked about a critical spot where the recorder clicked off, he denied even being in
the interview room at that moment.
Dalzell had heard enough. He called a recess and ordered all the lawyers into his chambers.
"I want to know what is going on here," he told Lancaster County Dist. Atty. Joseph Madenspacher. "I'm hearing perjured
testimony. . . . As we had with Det. Solt, {Barley} is contradicting his own statement. . . . My patience has just run out. . . . I'm
afraid the commonwealth is allowing perjured testimony in federal court. . . . I'm being lied to. . . . This man gives me the
unbelievably fantasti statement that suddenly he 'evaporated.' It's totally incredible, and I'm afraid I'm going to have to refer this,
if this keeps up, to the United States attorney. . . ."
Madenspacher shifted uneasily. This hadn't been his case to try. He'd left the prosecution to his seasoned first assistant, John
Kenneff. "I understand what the court is saying . . .," he replied. "I don't know what I'm going to do, but I'm going to do
something."
Little changed, though, when Barley resumed the stand. He didn't recall his colleague, Det. Ronald "Slick" Savage, turning the
tape recorder on and off. He destroyed his notes after taking Butch's statement.
"No, no . . . please answer her questions. Will you do that?" Dalzell interrupted at one point.
"You knew . . . because you took the statement?" the judge asked later. "Or did you disappear for that part? . . . Oh, do you
have that ability to appear and disappear at will?"
By the time Barley tried to explain how he "completely forgot" they'd found a pink bag during the river search--a pink bag that
Lisa told them contained Butch Yunkin's bloodied sneakers--Dalzell was beside himself. It helped his mood little when, with
Barley still on the stand, Rainville moments later played the segment of unedited videotape that showed an officer kicking the
6/4/2005 9:58 AM
4 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 578 of 2301

Pager
Page 17
17 of
of308
456
454

June
June 14, 2016
pink bag, then waving the camera off.

"No, that's not me," Barley said.
Rainville inched the videotape ahead a moment. "No, no ma'am."
Again she moved the tape forward. Now the man at the river could be seen clearly.
"That is me," Barley allowed. "I don't know why I waved at that point."
Dalzell again peered over his eyeglasses. "Who were you waving to? The record should reflect that the witness definitely waved
directly at the camera. What in the world were you doing, if you weren't waving to the camera?"
Barley looked blank. "I don't recall, sir."
Defendant Alleges Gang Rape
On the seventh day, Dalzell began to hear Lisa Lambert's story of being gang-raped by three policemen six months before
Show's murder.
Lisa--her extravagant eye makeup toned down but still too thick for Rainville's taste--had started testifying the previous day.
Now she described being stalked by an officer named Robin Weaver, of vainly calling his police chief to complain, of receiving
threatening calls after the alleged attack. She explained how fear had kept her from telling this story before. Finally, she
explained why she now was willing to talk.
In a deposition given to Lisa's attorneys before the hearing, Weaver, without being asked, had referred to the gang-rape
accusation. He thought Lisa had cited it in her habeas petition, but she had not. The charge had never been raised publicly. To
Lisa, Weaver's comment, therefore, provided independent proof of her claim: "There is no way that he could have ever known
about that unless he was there and he did it. It was not raised in the petition."
Dalzell interrupted: "Is that true?"
"That is true, your honor," said Rainville, who had been appointed by the judge to represent Lisa on a pro-bono basis.
Dalzell again had heard enough: "We'll take another recess. . . . I want {Weaver} here this afternoon, and I don't want anyone to
say a word about what has come up here. If he resists, please tell me. I will have the marshal arrest him, OK?"
Moments later, Dalzell learned that prosecutor John Kenneff already had discussed the rape allegation with Weaver.
"So he's been coached . . . ," Dalzell exclaimed.
The judge's budding animosity toward Kenneff was palpable. The prosecutor had not yet appeared before him, but the residue
of his work at the Lambert trial was everywhere.
"I'm going to direct that Mr. Kenneff have no further contact with any witness in this case. . . ," Dalzell declared. "And he might
want to consult with counsel. . . . I'm going to want to hear about this, because in the context of this case, Mr. Kenneff, God help
6/4/2005 9:58 AM
5 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 579 of 2301

Pager
Page 18
18 of
of308
456
454

June
June 14, 2016
him, if he coached this witness. God help him. . . . Mr. Kenneff, at his election, should retain counsel for proceedings that may
follow this one."
On the witness stand that afternoon, Weaver absorbed the full brunt of Dalzell's rancor. The judge grilled him: Have you talked
to any human beings? You understand you're in federal court? You understand the laws of the United States apply? You
understand you're under oath?"
Weaver said he did, and then denied any involvement in a rape of Lisa Lambert. Dalzell, though, wasn't finished.
Weaver had been among the first on the murder scene. It was he who'd initially questioned Hazel Show, and it was he who had
written the police report. Yet, nowhere in it had he indicated that Hazel Show heard her daughter make a dying declaration
about Lisa. Nor had he done so in a final report written three weeks later.
"Yes or no," the judge demanded. "Did you hear Hazel Show report a dying declaration?"
"I don't remember. . . . " Weaver replied. "She could have or she may not have."
"Is it your testimony that you would not have put it in a report if Hazel Show had told you about a dying declaration, that you
would not have put it down in that report? Is that your testimony? Yes or no?"
"No."
"So the fact that you don't make reference to a dying declaration, is some evidence that she didn't tell you that. Correct?"
"You can infer that, yes, sir."
"Oh," the judge said. "I could infer it. Could I infer anything else from that?"
Mounting Anger Among Citizenry
Day by day, watching from afar or from a courtroom seat, the citizens of Lancaster County grew ever more amazed and furious
as the Lambert hearing unfolded. This is shocking us, they declared. This is shaking our confidence in the American judicial
system.
What troubled them, though, were not the revelations coming out of Dalzell's courtroom. It was, rather, Dalzell's conduct.
The judge was "making the county look bad." The judge sounds as if he "revels in publicly humiliating Lancaster County."
Most irksome of all was the judge's handling of Lancaster County authorities. He was "discourteous" to the police officers and
John Kenneff. He sighed and rolled his eyes and looked at the ceiling as they testified. He interrupted with his own questions,
as if to assist the defense. He acted as if he didn't believe them.
Many in Lancaster County just couldn't fathom such an attitude. The police and prosecutors were their neighbors, their friends,
their protectors. They couldn't possibly manipulate evidence. They couldn't possibly lie.
By midway through the hearing, a certain tone of frantic fear could be heard in the county's response. Don't believe the "lies and
6/4/2005 9:58 AM
6 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 580 of 2301

Pager
Page 19
19 of
of308
456
454

June
June 14, 2016
untruths" being aimed at our police, urged East Lampeter Supervisor Chairman John Shertzer. Don't "rush to judgment." It's
"unfortunate that so much is being made of such insignificant points."
In his opening statement at the hearing, Madenspacher, the district attorney, had allowed that the investigation hadn't been
"perfect," that maybe they'd been a little "careless," maybe a little "sloppy." Others, though, refused even to acknowledge that
much. All sorts of citizens instead continued to offer glowing tributes to the police and prosecutors.
No one official drew more accolades than did John Kenneff. He is a big, heavyset man with a full, broad Irish face. Growing up
in Lancaster County, Kenneff was considered a fine schoolboy, a high achiever. Not Harvard-level material, but his college,
Villanova University, was nonetheless a good school. Not as good as the University of Pennsylvania, but the next step.
He'd come back after law school, opened a private practice, worked his way up through the D.A.'s office. He came to all the
Fourth of July picnics; he brought his family, he brought his dog. He was known as a committed, persistent prosecutor, one of
the fairest and most reasonable in the county.
Even the defense attorneys who went up against him said as much. Even they called him a decent, honest guy. To Terry
Kauffman, a dairy farmer and chairman of the board of county commissioners, that particularly carried a lot of weight: "A lot of
people I know here, from both sides of the aisle, say he's the best. I know them, and I've known Jack Kenneff for years. I don't
know Stewart Dalzell."
Darcus--the chairman of the Lancaster City Council, a black man from West Virginia who followed a Boys' Club job to Lancaster
30 years ago and happily settled--believed he possessed an especially close take on John Kenneff's character. They'd been
involved together in a "Weed and Seed" anti-crime development program in Lancaster's minority community. So Darcus saw
Kenneff not just as a prosecutor, but a community leader. Also as a father: Kenneff's children went to the same Catholic school
as Darcus' son.
"I've seen how he cares about people," Darcus said. "I've seen him deal with people in my community. I've seen him go beyond
what was needed. Knowing Jack Kenneff, I just can't picture this man doing what the judge says. I wonder how that judge
sleeps at night."
Denials From the Prosecutor
No, John Kenneff insisted. No, he didn't think Butch Yunkin's sweatpants were a critical issue at the murder trial. No, he had no
recollection of looking at the sweatpants the state put into evidence.
It was April 15, the hearing's 11th day. Kenneff had taken the witness stand soon after court convened. Questioning him was
Peter Greenberg, Rainville's husband, a partner at their law firm and one of Philadelphia's most-accomplished litigators.
At the trial, the state's theory of the murder had Lisa wearing Butch's extra-large men's sweatpants, found full of blood in a
dumpster after the attack. Trial judge Lawrence F. Stengel accepted this theory and thought it significant. So Kenneff's answers
now caused Dalzell to lean forward.
"Did you make a conscious judgment at trial as to who was wearing the clothing that you put into evidence?" Greenberg asked.
"It was my understanding that Miss Lambert had admitted to wearing the clothing . . . ," Kenneff replied.
6/4/2005 9:58 AM
7 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 581 of 2301

Pager
Page 20
20 of
of308
456
454

June
June 14, 2016
Dalzell interrupted: "I don't think that's the question he asked you. And I think you ought to listen more carefully to Mr.
Greenberg's questions because I don't think you're answering them. . . . That question can be answered yes or no."
So it went through much of the morning. Lancaster County citizens were right: Dalzell by then couldn't hide his dismay for their
assistant district attorney. The moments when the judge removed his glasses and rubbed his eyes were adding up.
For 10 days he'd been exposed to an ever-more disturbing portrait of how Kenneff had prosecuted Lisa Lambert. He'd listened
to the pathologist Isidore Mihalakis--a defense witness at Lisa's murder trial--describe private conversations with Kenneff that
Dalzell thought constituted witness-tampering. He'd heard how authorities had concealed critical testimony by Hazel Show's
neighbor Kathleen Bayan. He'd been presented evidence that convinced him the state had "lost" an earring of Butch's found on
the victim's body. He'd been presented evidence that convinced him the state had edited critical video and audiotapes.
Now the man who oversaw the state's efforts sat before Dalzell on the witness stand.
No, Kenneff was testifying. He didn't recall looking at the river-search video.
"You didn't think it worthwhile to look at the video?" Greenberg asked.
"I didn't think what happened at the river was a contested issue," Kenneff replied.
This time, Greenberg snapped before the judge could: "You've been in this business long enough to know that when I ask a
question you're supposed to answer it?"
"Right," Kenneff agreed.
Dalzell joined in now: "It would be nice if you would do that. . . . I want to warn you, sir, that, if you don't do that, you are going to
put me into a position where this will have to get unpleasant. Do you understand that? . . . The record should reflect that you
have been consistently unresponsive to the questions. . . . "
Greenberg turned back to the matter of Butch's sweatpants. Now, Kenneff has even resisted saying he based the case on the
theory that Lisa wore Butch's clothing. He no longer, in fact, was sure whether the sweatpants were Butch's.
The pair he'd produced for the habeas hearing, after all, were much smaller than men's extra-large. "The sweatpants would
have looked ridiculous if worn by 6-foot-1-inch-tall Butch," Kenneff had argued in a written response just before the hearing.
"You are the same person . . . " Greenberg asked, "saying that the sweatpants would have looked ridiculous on Butch, who put
Butch on to testify in Lisa's trial . . . that they were his sweatpants, these very same sweatpants that would have looked
ridiculous on him?"
"Correct."
"These are the same sweatpants that Judge Stengel found belonged to Butch?"
"Correct."
6/4/2005 9:58 AM
8 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 582 of 2301

Pager
Page 21
21 of
of308
456
454

June
June 14, 2016
"And if you had your way, Lisa would have been executed based on that evidence, wouldn't she?"
Kenneff hesitated; Dalzell spoke: "Yes or no," the judge ordered.
"That would be correct."
Greenberg erupted: "Do you think this is some kind of game? . . . Do you realize that there is a human being sitting here who is
in jail serving a life sentence based on the evidence you put on . . . that you are now disowning. . . . Not only are you disowning
it, you are committing perjury. . . . Are you sure it is Miss Lambert who is a dangerous person in this courtroom?"
Handling of Letter Infuriated Judge
In the end, the commonwealth's handling of the controversial 29 Question Letter was what most inflamed Dalzell.
Lisa had written Butch from jail, asking a series of questions. The answers Butch had scrawled under each question, the judge
felt, left no doubt that he was the murderer of Laurie, and that his accomplice was Tabitha Buck. That the letter was authentic
seemed equally certain to Dalzell: Both the state and defense experts had affirmed there'd been no alteration.
Yet, Kenneff--after stipulating to the experts' opinions--had let Butch testify at Lambert's trial that the questions were altered.
That the prosecutor knew his witness was committing perjury appeared obvious to Dalzell. At Butch's plea-bargain hearing after
Lisa's conviction, Kenneff wanted to revoke their deal precisely because of this perjury.
Experts had reviewed the 29 Questions Letter and Butch's trial testimony, Kenneff told the judge at that Oct. 10, 1992, hearing.
"They advised us that his testimony . . . regarding that {letter} that was false . . . . It is our opinion that he testified falsely . . . on
that basis we feel we are entitled to withdraw from the original plea agreement."
There just was no ambiguity, Dalzell felt: Kenneff knew that Butch committed perjury on a material issue, regarding a document
that established Lisa's innocence.
Under such circumstances, Dalzell believed Kenneff had an unambiguous ethical obligation to take remedial action with the
court that convicted Lambert. The Pennsylvania Rule of Professional Conduct was clear about this: "A lawyer shall not
knowingly . . . offer evidence that the lawyer knows to be false. If a lawyer has offered material evidence and comes to know of
its falsity, the lawyer shall take reasonable remedial steps."
Yet far from complying with this rule, it looked to Dalzell as if Kenneff had encouraged Judge Stengel to accept Butch's perjured
testimony. "I think he's just like any other witness," Kenneff told Stengel when Lisa's attorney moved for a mistrial based on
Butch's perjury. "You can believe some of it, all of it, or none."
It was worse than that, in Dalzell's eyes. For, after obtaining a conviction based partly on this perjured testimony, Kenneff had
coolly proceeded to seek the death penalty for Lisa Lambert.
Now, remarkably, Kenneff at this habeas hearing--and in written responses that looked to Dalzell to be blatantly false--was back
to arguing that some of the 29 questions had been initially written in pencil, then altered. In other words, Kenneff, before Dalzell,
was defending testimony by Butch that he had told two other judges was a lie.
6/4/2005 9:58 AM
9 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 583 of 2301

Pager
Page 22
22 of
of308
456
454

June
June 14, 2016
"Do you want to take remedial actions with Judge Dalzell?" Peter Greenberg asked.
Here the judge interceded: "I was just going to ask that myself. . . ."
It was the morning of April 16, the hearing's 12th day. Kenneff had been on the stand for hours.
"Well, your honor," Kenneff responded. "I think I still feel the same way about the 29 questions. . . . That there is some type of
tampering with it. . . . "
"No, no, no, sir," Dalzell interrupted. "I am going to jump in here. You said in your answer to me that there was pencil. And you
have testified under oath here that your expert and the defense expert said there was no graphite. . . . "
"Judge," Kenneff began.
Dalzell spoke over him: "I want to warn you, sir, you are under oath, and you are subject to the rules of professional
responsibility. . . . Do you retract that statement that you signed . . . as to pencil? Yes or no?"
"I just don't think I can answer that question yes or no, judge."
Dalzell turned to Madenspacher, Kenneff's supervisor. "Does the commonwealth retract it?"
Madenspacher rose. "Yes, your honor. We retract it."
"Thank you," Dalzell said. He turned back to Kenneff. "Your boss just retracted it. Next question."
Their confrontation hadn't peaked yet.
The climax came minutes later, when Greenberg began listing all the pieces of evidence that the district attorney's office kept
from Roy Shirk, Lisa's attorney at her trial. What if Shirk had the names of the emergency medical technicians? What if he knew
the police had found a pink bag? What if he had the unedited river-search video? What if he knew a neighbor had seen Butch at
the crime scene?
"Well," Kenneff tried to answer, "the Pennsylvania Rule provides for certain . . . "
That's as far as he got. Dalzell exploded: "No. Excuse me. We're talking here--let me just make something clear to you. We're
talking here about something called the United States Constitution, and in particular the 14th Amendment thereof, which has a
clause in it that refers to due process of law. OK? Have you heard of that?"
"Yes sir."
"That's what we're talking about. . . . So we're not talking about the Pennsylvania Rules of Criminal Procedure. We're talking
about due process of law here. . . . That's what we're talking about here. You got it? Do you understand?"
"Yes," Kenneff replied.
6/4/2005 9:58 AM
10 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 584 of 2301

Pager
Page 23
23 of
of308
456
454

June
June 14, 2016
Biggest Drama Begins to Unfold

As it happened, the confrontation between Dalzell and Kenneff was neither the most dramatic nor revealing sequence to occur
on this 12th day of Lisa's habeas hearing. The event that would eclipse it began only after Kenneff left the witness stand, and
court adjourned for lunch.
Madenspacher, walking toward his hotel, bumped into Hazel Show's brother, who reported that his sister needed to talk to him.
Back at the Holiday Inn in downtown Philadelphia, where both were staying, Madenspacher walked up to Show's room.
Sobbing as she talked, the murder victim's mother told him her story.
During the hearing that morning, she'd suddenly recalled the morning of the murder: As she drove up Black Oak Road to her
condo, on her way to find Laurie's body, a brownish-colored car passed, heading out of the condo complex. It was Butch's car.
She looked at Butch. There was recognition on his face. He pushed down someone with blond hair. There was also a third
person in the back seat, with black hair.
She'd told this to Det. Ron Savage back then. Savage had come to her house saying one of her neighbors had seen Butch's car
leave the complex. She'd started to say she had too. Savage had stopped her, told her not to dwell on that. They had so many
witnesses saying Butch wasn't there. Besides, this neighbor lady was kind of disturbed anyhow. Probably wouldn't be a reliable
witness. We were better to go with Butch not being there.
Hazel was sobbing harder now. She'd forgotten about it, she told Madenspacher. She'd put it aside. Until now.
Madenspacher was reeling. Hazel's story fit exactly with testimony given by that "neighbor lady," Kathleen Bayan, on the
hearing's fourth day. Testimony that Hazel hadn't heard because she'd left the courtroom early that day. Testimony that had
never been produced at Lisa's murder trial. Testimony that Kenneff knew about back then but had never shared with Lambert's
attorney. Testimony that Savage had tried to water down while taking Bayan's initial statement, then dismissed as coming from
a woman with "an emotional problem."
Hazel's story also fit perfectly with something else: Lisa Lambert's testimony at her trial. There she'd told of driving by Hazel
Show, of Butch saying, "Oh . . . it's Hazel," of Butch pushing her head down.
Madenspacher pondered. If true, it seemed to him that this story knocked out the underlying theory of the trial, which was that
Butch wasn't at the condo. It didn't mean Butch was actually inside; it didn't clear Lisa; it could be explained. But it was a new
story. It changed the theory of the case. Madenspacher felt as if he were slipping into shock.
"You sure?" he asked. "Let's hear it again."
Hazel repeated her story.
Madenspacher had no choice: He had to get this to the judge. He couldn't suppress it. The only question was, when and how? It
was going to come out anyway, Madenspacher figured. So let's get the bad news over with.
The conference in Dalzell's chambers began at 1:40 p.m. that day. Present were the judge, the lawyers for all sides, Hazel
Show and Lisa Lambert.
6/4/2005 9:58 AM
11 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 585 of 2301

Pager
Page 24
24 of
of308
456
454

June
June 14, 2016
Hazel Show told her story again, this time before a court reporter: Well, when I was sitting in the courtroom today, I realized that
I had seen Lawrence's {Butch's} car with passengers drive out of our condominium complex. . . . Det. Savage said that I wasn't
to dwell on it. . . . I never thought anymore about it until I was sitting in there. . . . It all just came back.
By now, Lisa was sobbing along with Hazel.
"It's OK, Miss Lambert," Dalzell said. "It's OK."
To Dalzell, this revelation was the final straw. Throughout Lisa's trial the state had been at pains to keep Butch as far from the
Show condo as possible. No doubt that was why the state had never disclosed anything about Hazel's report or Bayan.
To Dalzell, it wasn't just that Hazel's and Bayan's accounts were consistent with Lisa's testimony at trial five years ago: Just
about everything being revealed at this hearing was consistent with Lisa's testimony back then.
From all he'd heard, Dalzell now believed that the commonwealth's misconduct had been so substantive, it had undermined the
state court's ability to find the truth. He believed the commonwealth had committed at least 25 separate instances of
prosecutorial misconduct--all constitutional violations, all violations of the norms of a civilized society.
It seemed clear to him that Laurie Show did not say "Michelle did it." It seemed clear that Butch, in the 29 Questions Letter,
confessed to the murder. It seemed clear Lisa didn't wear Butch's sweatpants on the morning of the murder. It seemed clear the
police had fabricated Lisa's initial statement.
Worse yet, in Dalzell's view, the commonwealth still hadn't stopped its treachery. At this habeas hearing the state had produced
not the extra-large sweatpants of Butch's from the original trial, but a smaller girl's pair. The commonwealth, Dalzell believed,
had perpetrated a fraud on the federal court; the commonwealth had swapped evidence.
At least six state witnesses, by Dalzell's count, had perjured themselves before him. One, Ron Savage--now an elected district
justice in Lancaster County--likely obstructed justice. And now this: now Hazel's revelation, right before his eyes. Hazel had
every reason to want Lisa's petition denied; Hazel sincerely believed Lambert did it. Yet still she'd felt compelled to tell this
story. Dalzell had never seen a more courageous act.
"Well," the judge told those gathered in his chambers. "Now we come to the question of relief. Does the commonwealth intend
to defend this case?"
All eyes turned to Madenspacher.
The Lancaster County district attorney had been looking uncomfortable in recent days. Nothing he'd heard rose to the level of
conscious misconduct or obstruction, he kept insisting. But he had to admit, it hadn't been a perfect trial or investigation. He
wished certain things had been done differently.
In Lancaster County, then as now, there were many who wanted their district attorney to fight ferociously. There were many who
wanted their district attorney to defend their honor, to insist they'd done nothing wrong, to match Lisa's lawyers blow for blow.
Yet, Madenspacher, at this moment, wasn't sure what should be done. Everything, he would say later, was "spinning in my
mind." It was "awful tough" operating away from the office. It "would have been nice" to have known everything from the start.
6/4/2005 9:58 AM
12 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 586 of 2301

Pager
Page 25
25 of
of308
456
454

June
June 14, 2016
"Now, obviously . . . " he finally told the judge. "There is some relief that is justified in this particular case. . . ."
That was all Dalzell needed; he now had the commonwealth's assent. The state hadn't even put on its case yet, but he meant to
get Lisa out of prison. He also meant to get Savage off the bench forever; he didn't see how Savage could hear cases anymore,
and he planned to tell the Pennsylvania Supreme Court just that.
"You can make a choice overnight," Dalzell advised the district attorney, "whether you want to defend this case, put on your own
witnesses. In the meantime, I'm going to release Ms. Lambert into some agreed-upon custody. . . . Because it's quite clear now
that the petitioner is entitled to relief, the only question is how much."
Off to one side, a dismayed Hazel Show tried to interject: "Laurie told me she did it. . . . "
Madenspacher's voice overrode hers. "Yes, I agree relief is warranted, and I think we're talking now. . . . "
"About what relief," the judge said.
"What relief, your honor . . . "
"I can tell you, Mr. Madenspacher, that I've thought about nothing else but this case for over three weeks, and in my experience,
sir, and I invite you to disabuse me of this at oral argument, I want you and I want the Schnader firm to look for any case in any
jurisdiction in the English-speaking world where there has been as much prosecutorial misconduct, because I haven't found it. .
. . So are we agreed that the petitioner will tonight be released into the custody of Ms. Rainville?"
Madenspacher nodded. "I don't see how I can object to that, your honor."
Stunned Response in Lancaster County
In bars and cafes, street corners and living rooms, the citizens of Lancaster County gasped at the news of Lisa's release. Their
district attorney may not have seen reason to object, but they did. Most sounded stunned; many sounded enraged. One man, at
8 a.m. on the morning after her release, anonymously called in a phone threat to the Lancaster Sunday News, saying he would
kill Lambert if she returned to Lancaster.
Maybe there were "mistakes," the more rational by now were willing to allow. Maybe there was "sloppy" police work. Maybe Lisa
even deserves a new trial. Nothing more than that, though. Certainly not her freedom. She was there, she was an accomplice,
she was a co-conspirator. Give her a new trial, remand it elsewhere even. But don't just let her go. You can't just let her go.
"Lambert is not innocent--how could she be?" the Lancaster New Era editorialized the day after Hazel Show's revelation. " . . .
even with newly revealed evidence that supports her claims, Lambert is still irrevocably involved in the events that lead to Laurie
Show's murder. These facts must not be drowned out by the explosive revelations at Lambert's federal appeals hearing. . . . "
As it happened, these thoughts exactly echoed those offered by Judge Stengel, who'd presided at Lisa's murder trial. "Even if
Lambert's story at trial was completely credible," Stengel had declared in his written opinions, "she would still be an accomplice
to the crime of murder. . . . The single most important fact on the issue of guilt is whether Ms. Lambert was present in the Show
condominium at the time of the killing. By her own admission, she was present. . . . "
6/4/2005 9:58 AM
13 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 587 of 2301

Pager
Page 26
26 of
of308
456
454

June
June 14, 2016
Dalzell, however, simply did not accept this notion, at least not in a federal habeas hearing.
On the proceeding's final day, when Madenspacher in his closing argument spoke of Lambert being guilty at least as an
accomplice or conspirator, Dalzell waved him off. "She wasn't charged with conspiracy was she?" he declared. "She was
charged with first-degree murder. So the only issue before me is actual innocence of first-degree murder. That is what she was
convicted of."
In fact, the law is murky on this point. Lisa was actually charged with criminal homicide, which in Pennsylvania encompasses all
degrees of murder. How her conviction for first-degree murder affects her exposure to lesser murder charges is a matter for
debate.
So, Madenspacher tried to argue: "What I am saying here is that charged with criminal homicide, she could be found guilty of
murder in the first degree . . . or she could have been found guilty of second degree . . . or she could be found guilty of third
degree."
That didn't sway Dalzell: "But if one took her testimony, she said that she did everything possible to de-escalate what spun out
of control. . . . By her own testimony she exited when it started spinning out of control. So therefore, it was not 'reasonably
foreseeable' from her point of view, so the argument would go."
The judge then cut things off: "Let's not waste time debating that."
Dalzell had good reason for not wishing to bother further with this issue. By then--after 14 days of testimony covering 3,225
pages of transcript--the judge wasn't thinking only about Lisa's conduct at the Show condo. He was thinking about the 14th
Amendment of the Constitution, and the role of a federal habeas corpus in upholding the unalienable right of due process.
Among other historic cases, Dalzell's mind was on a 1973 opinion by then-Justice William H. Rehnquist, in United States vs.
Russell. There, Rehnquist predicted that "we may some day be presented with a situation in which the conduct of law
enforcement agents is so outrageous that due process principles would absolutely bar the government from invoking the judicial
processes to obtain a conviction."
That day, Dalzell decided at the close of Lambert's hearing, had come.
While presiding at a habeas hearing, he reminded himself, he effectively sat as a court of equity--a court operating under a
system of law designed to protect rights and deliver remedial justice. He recalled the ancient maxim that "equity delights to do
justice, and not by halves." To give Lisa full relief, it seemed to him imperative that he do nothing to benefit or empower those
who had wronged her.
He would not just release Lisa, Dalzell decided. An outrageous violation of due process required even more severe sanction. He
would bar the state from ever retrying her. He would strip the state of its natural right to adjudicate a murder committed within its
boundaries.
He wrote his 90-page opinion over the weekend, after court adjourned at 4:10 p.m. on Friday, April 18. Before a packed
courtroom late the following Monday morning, he declared Lisa "by clear and convincing evidence" to be "actually innocent of
first-degree murder."
6/4/2005 9:58 AM
14 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 588 of 2301

Pager
Page 27
27 of
of308
456
454

June
June 14, 2016
"If Lisa Lambert's is not the 'situation' to which Chief Justice Rehnquist referred, then there is no prosecutorial malfeasance
outrageous enough to bar a reprosecution. . . ." he proclaimed. "We have now concluded that Ms. Lambert has presented an
extraordinary, indeed, it appears, unprecedented case. We therefore hold that the writ should issue, that Lisa Lambert should
be immediately released, and that she should not be retried."
In scorching language, Dalzell explained just why: "We have found that virtually all of the evidence which the commonwealth
used to convict Lisa Lambert of first-degree murder was either perjured, altered or fabricated. Such total contempt for due
process of law demands serious sanctions. The question we must now answer is whether . . . the commonwealth is entitled to
get another try at convicting Lisa Lambert and sending her to prison for the rest of her life. . . . In short, the question is whether
we may accept a promise from anyone on behalf of the commonwealth that a trial will be fair 'next time.' "
No, Dalzell concluded, we cannot.
"We hold that the due process clause of the 14th Amendment bars the commonwealth from invoking judicial or any other
proceedings against Lisa Lambert for the murder of Laurie Show. . . . Equitable considerations preclude our leaving the decision
whether to retry Lisa Lambert in the hands of those who created this gross injustice. . . . "
As far as legal researchers could tell, there was an accepted basis, but no exact precedent for a federal judge in Dalzell's
situation to take such action. Dalzell did not stop there.
He was, he announced in his opinion, going to refer the matter of Kenneff's "blatantly unethical and unconstitutional" actions to
the Pennsylvania Disciplinary Board. He also was going to refer the whole Lambert prosecution to the U.S. attorney for
investigation of "possible witness intimidation, apparent perjury by at least five witnesses in a federal proceeding, and possible
violations of the federal criminal civil rights laws."
Still, Dalzell wasn't finished. He felt compelled, in the two final pages of his opinion, to address the question of just why all this
had happened in Lancaster County.
"Those who have read this sad history," he wrote, "may well ask themselves, 'How could a place idealized in Peter Weir's
'Witness' become like the world in David Lynch's 'Blue Velvet'?' Because it is so important to that community and indeed to
many others to prevent a recurrence of this nightmare, we offer a few reflections on the record."
Laurie Show's grandfather, Dalzell pointed out, was, in the 1980s, the coroner of Lancaster County. Her mother was "a paragon
of morality" who kept "a picture-perfect home." By contrast, Lisa Lambert was "as though delivered from Central Casting for the
part of villainess." By the testimony of even those who loved her, "she was at the time literally 'trailer trash.' " The community
"thus closed ranks behind the good family Show and exacted instant revenge against this supposed villainess." Almost
immediately after "the snap judgment" was made, law enforcement officials uncovered "inconvenient facts," but soon
"discovered a balm for these evidentiary bruises, Lawrence Yunkin." Thus "Lancaster's best made a pact with Lancaster's worst
to convict the 'trailer trash' of first-degree murder."
Dalzell's parting words: "In making a pact with this devil, Lancaster County made a Faustian bargain. It lost its soul and it almost
executed an innocent, abused woman. Its legal edifice now in ashes, we can only hope for a 'Witness'-like barn-raising of the
temple of justice."
6/4/2005 9:58 AM
15 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 589 of 2301

Pager
Page 28
28 of
of308
456
454

June
June 14, 2016
Uprising Began With Calls, Letters

The uprising in Lancaster County in the wake of Dalzell's ruling began first with the usual letters to editors and calls to radio talk
shows.
The legal system is a "crock of crap." How could Dalzell destroy the reputation of "honorable and decent people" for the
purpose of freeing a "cold-blooded killer?" What kind of justice do we have?
Soon enough, such talk escalated. All sorts of theories about Dalzell's motives began circulating. Something's been going on
behind the scenes, it was suggested. Something behind what Dalzell did, something we don't know about.
Ted Byrne, the conservative radio talk show host in Lancaster County, pored through Dalzell's decisions in a law library. Then,
seeking hidden connections, he analyzed the activities of the attorneys at Dalzell's old law firm and Rainville's firm.
It was considered significant that Dalzell and Greenberg, 30 years before, had been classmates at the University of
Pennsylvania. Some talk had it that they were old pals. Some talk had it that Dalzell had handed the Lambert case to his own
"carefully assembled defense team."
Had Dalzell reached the end of a career path? Had he felt unfulfilled? Had he wondered how he might become an appellate
judge? Had he seen a challenge to the controversial habeas corpus situation as a means to garner attention?
For that matter, how did the Lambert case get to Dalzell in the first place? Had not Dalzell displayed an excessive personal
interest in Lisa in his chambers? Was it possible that they had a relationship?
"We must begin to think who it was that had to gain from this travesty of justice other than Lambert," suggested one citizen in a
letter to the editor. "My vote goes to Judge Stewart Dalzell. It would appear that it is an appropriate time for this newspaper to
dig very deep into the archives of the noteworthy judge to determine what it was or who it was that set him on his grudge
mission to 'punish' the county for sins of the past committed against him."
Such comments reflected as much bewilderment as paranoia. They came from a citizenry who well knew Lisa Lambert, and
well knew those who had prosecuted her. Yet rarely did anyone, amid all the outpouring of emotion and speculation, feel
inclined to discuss the particulars of the Lambert case as revealed in Dalzell's courtroom.
More common was East Lampeter Supervisor Chairman John Shertzer's response. "There were a lot of false accusations
throughout the trial. . . . We never had the opportunity to address those," Shertzer told a reporter, before confessing that he, in
fact, couldn't address them: "There are some things about this that I don't have a lot of background in. But I just know these
people. . . . They were treated very abusively on the stand by Lambert's attorneys as well as the judge."
Lancaster's citizens were struggling to hold together a way of viewing their world. Even those willing to acknowledge certain
blemishes in that world--even those willing to acknowledge official wrongdoing in the Lambert case--found themselves laboring
to understand what Dalzell had done. No matter what was revealed in a Philadelphia courtroom, no matter what Lancaster
authorities did or failed to do, it seemed incomprehensible that Dalzell would let Lisa Lambert walk free, without at least a retrial.
Not even Lisa's parents had hoped for that back when their daughter's appeals first started. Their dream, Leonard Lambert told
a reporter then, was that Lisa receive "a level of punishment that's not greater than what's deserved. . . . It's a known fact that
6/4/2005 9:58 AM
16 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 590 of 2301

Pager
Page 29
29 of
of308
456
454

June
June 14, 2016
she was there. But something could argue that maybe she doesn't deserve more than aggravated assault or third-degree
murder."
Dalzell went too far, even the more reasonable in Lancaster County now declared. He was a disgrace to the legal profession.
He had made a mockery of justice. He was a man without honor.
Hazel Show, more than anyone, sounded the clarion. "Thank you for listening to me," she'd told Dalzell on the hearing's last
day. "My parents brought me up to be truthful, and I believe in God. . . . So it is up to me to tell the truth." Yet soon after,
whether out of confusion or regret at what she'd wrought, Show began to backtrack and revise.
Never in her "wildest dreams," she declared, had she thought her story would free Lisa. All her story proved was that she got
home just as the killers left, in time to hear her daughter's dying declaration. But the judge "didn't want to hear that." The judge
"wouldn't let me say that."
No matter that Madenspacher insisted Hazel never mentioned this notion to him in their hotel meeting. No matter that she never
mentioned this notion while on the witness stand on the hearing's last day. It now became her constant refrain. "We have to get
this judge off the bench," she began declaring publicly. "There is not one bit of justice in him."
They began first with a petition drive. Hazel's ex-husband, John Show, drew it up, calling for Congress to "investigate" Dalzell
and take "corrective action," including impeachment. Show's girlfriend took it to her beauty shop, where customers clamored to
sign it. Local businesses started stocking piles on their front counters. Volunteers called for extra copies, carried them door to
door, offered them at yard sales. One couple outside a Kmart parking lot on a hot Sunday collected more than 500 signatures.
On the morning after an ad for the petition appeared in the Lancaster newspapers, John Show walked to his mailbox and found
300 envelopes. By mid-September, he had 37,000 signatures.
Then came Hazel Show's 10-page "Citizens Action Report," the keystone of her newly launched national campaign seeking to
reform the entire federal judiciary. Now the Shows wanted, among a host of items, to bar federal judges from banning retrials, to
fix stricter guidelines for appointing federal judges, to limit federal judges' terms in office. Hazel Show's words and image soon
became ubiquitous in Lancaster County.
Television provided one forum, both local talk shows and the national tabloids. Politicians provided another. The
Washington-based Judicial Selection Monitoring Project, an arch-conservative organization seeking to block the appointment of
what it calls "activist liberal judges," featured both Shows in a 15-minute videotape that lambasted Dalzell and misidentified him
as a Clinton appointee.
The Shows, accompanied by 16 friends and relatives, took their campaign to Washington on Sept. 17, where Pennsylvania
Sen. Arlen Specter, along with Reps. Joseph R. Pitts and George W. Gekas, accepted cartloads of petitions. The lawmakers,
weeks before, had introduced legislation that would severely restrict federal judges' power to bar retrials during habeas
proceedings--a bill specifically designed to reverse Dalzell's decision. Now, to the Shows, Specter agreed to call it the "Laurie
Bill" and promised them a Senate Judiciary Committee hearing. Wherever they went, the Shows were applauded and courted.
"How often do you get to do this?" Hazel observed.
"I think we made an impact," John offered.
6/4/2005 9:58 AM
17 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 591 of 2301

Pager
Page 30
30 of
of308
456
454

June
June 14, 2016
Argument That Judge Brought It on Himself

It can fairly be argued that Dalzell brought some of this on himself. He may have overly embraced Lisa Lambert's account of
events, and unduly diminished her role. He may not have needed to rough up witnesses in his courtroom as much as he did. He
certainly need not have painted Lancaster County with such a broad brush at the end of his opinion.
How could he claim to know this county, his critics asked. How could he claim to know our citizens? How could he say such
things about us?
Yet, valid as such claims may be, it most likely will be Dalzell who leaves a lasting impact, not those fueling the backlash
against him.
Whether right or wrong, whether he operated entirely within his bounds, a federal judge consumed by moral outrage has, as he
intended, sent a message. The idea behind Lisa Lambert's outright release was not, finally, to let a guilty person go free. It was
to let the powers of the state know they can't violate bedrock principles of the Constitution and get away with it.
They haven't.
In early May, the U.S. attorney's office in Philadelphia, responding to Dalzell's referral, announced it had launched a criminal
investigation into those who investigated and prosecuted Lisa Lambert. Aiding them will be the FBI and the Justice
Department's civil rights division. They will focus on John Kenneff and seven police officers, among them Ronald Savage,
Ronald Barley, Robin Weaver and Raymond Solt.
Days later, the U.S. 3rd Circuit Court of Appeals, in refusing Lancaster County's motion for a temporary stay of Dalzell's order,
said "the commonwealth has not demonstrated that it is likely to prevail on the merits of its appeal. . . . We remind the
commonwealth that Judge Dalzell's factual findings are based on his view of the credibility of the witnesses and testimony. . . .
We can only reverse if we find them clearly erroneous."
In that written opinion, the appellate panel also chastised the commonwealth for calling Lisa Lambert a "convicted killer" in its
brief. She "no longer has that status," the 3rd Circuit reminded. "Indeed, that description is inflammatory and inappropriate,
given {Dalzell's} findings of actual innocence. . . . "
What remains to be seen is whether Dalzell will ultimately be allowed his unprecedented involvement in a state's sovereign
affairs. At the habeas hearing's end, Lancaster County hired its own high-powered Pennsylvania law firm, Sprague & Lewis,
known for its political connections, particularly to the Republican Party. On Oct. 21, when lawyers for both sides argued the
merits of the county's appeal before a 3rd Circuit panel, the appellate judges grilled them on a critical question: Did Lisa
Lambert exhaust all her appeals in Pennsylvania's courts before turning to a federal judge for help?
This issue, rather than any question of Lisa's innocence or a prosecutor's malfeasance, is what presently fuels a nationwide
debate in the legal community and beyond. Elemental principles of law and government in this country normally restrain federal
intrusion until a state has heard all claims, and has been given the chance to correct its own errors. Just weeks ago, a 3rd
Circuit panel--saying "we are sensitive to the independence of the Pennsylvania courts and of that state's sovereignty"--denied
another convict's habeas petition because he hadn't exhausted his state appeals.
Dalzell, in his opinion, recognized these principles, then essentially dismissed them. The Pennsylvania General Assembly, he
6/4/2005 9:58 AM
18 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Page 592 of 2301

Pager
Page 31
31 of
of308
456
454

June
June 14, 2016
pointed out, amended its statutes in 1995 to exclude "actual innocence" as a basis for certain appeals. By doing so, Dalzell
declared, Pennsylvania, in effect, relinquished its jurisdiction over claims such as Lisa Lambert's, and placed them "squarely
into the federal forum." And even if Pennsylvania were willing to consider some of Lambert's claims, Dalzell added, "we find that
the state proceedings that would follow if we dismissed this action are ineffective to protect the rights of Ms. Lambert."
By thus declaring his utter distrust in Pennsylvania's ability to deliver justice, Dalzell has challenged the fundamental balance of
power between state and federal courts that governs the judicial system. This is why five state attorneys general--including
California's--have joined Pennsylvania in an amicus brief that talks of the Dalzell ruling's "potential to seriously weaken, if not to
dismantle entirely, the system for litigating habeas actions." This is why law-and-order-minded national politicians have their
knives out for Dalzell. This is why Lisa Lambert's federal hearing promises to be one of the most carefully reviewed cases in
criminal law for a long time to come.
This is also why Dalzell's actions will leave a legacy no matter what the outcome of the present appeals. His ruling may or may
not stand, his ruling may or may not establish a formal precedent, but--by granting a hearing and allowing widespread
discovery--Dalzell has required that attention be paid to what happened in a Lancaster County courtroom in the summer of
1992. He's shown why the federal habeas corpus action is essential to the integrity of the judicial system.
Dalzell has also set a moral, if not legal, example. Rulings in one case often affect other rulings. One judge's decision shapes
not just the outcome of a particular case, but also the character of justice. What he doesn't allow, others likewise forbid.
In mid-May, in Lancaster County court, Lisa Lambert's original trial lawyer, Roy Shirk, serving as defense attorney in a routine
burglary case, rose to ask for a mistrial. As in the Lambert case, he argued, prosecutors in this one had failed to turn over
exculpatory evidence to the defense. Shirk most likely meant only to put this commonplace claim into the record for later review,
but Judge Paul K. Allison, to the lawyers' astonishment, promptly granted his request.
Yes, the judge said in declaring a mistrial, this is exactly what Dalzell felt happened to Lisa Lambert.
PHOTO: Lisa Michelle Lambert walks ahead of lawyers, Peter Greenberg and Christina Rainville, to court hearing.;
PHOTOGRAPHER: Associated Press; PHOTO: Lancaster County Dist. Atty. Joseph Madenspacher talks to news media after
judge ruled Lisa Michelle Lambert innocent of charges.; PHOTOGRAPHER: Associated Press; PHOTO: Hazel Show, left,
stands in bedroom where daughter, Laurie, was murdered.; PHOTOGRAPHER: Associated Press; PHOTO: Laurie's father,
John Show, above, hugs woman identified as his girlfriend, after judge ruled Lisa Michelle Lambert innocent.;
PHOTOGRAPHER: Associated Press; PHOTO: U.S. District Judge Stewart Dalzell was assigned the writ of habeas corpus that
set him on a course to freeing Lisa Michelle Lambert.; PHOTOGRAPHER: Associated Press
Credit: TIMES STAFF WRITER
Reproduced with permission of the copyright owner. Further reproduction or distribution is prohibited without permission.
Subjects:
Judicial reviews, Acquittals & mistrials, Murders & murder attempts, Prosecutions, Series & special reports
Locations:
Lancaster County Pennsylvania
People:
Lambert, Lisa, Show, Laurie
Document types: News
LANCASTER, Pa.
Dateline:
PART-A; National Desk
Section:
ISSN/ISBN:
04583035
6/4/2005 9:58 AM
19 of 19

Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave Brown
Text Word Count 8866
Document URL:
Page 593 of 2301

Pager
Page 32
32 of
of308
456
454

June
June 14, 2016
Reproduced with permission of the copyright owner. Further reproduction or distribution is prohibited without permission.
Copyright 2005 Los Angeles Times | Privacy Policy | Terms of Service
Home Delivery | Advertise | Archives | Contact | Site Map | Help
PARTN ERS:
6/4/2005 9:58 AM
Supreme Court puts limit on whistle-blowers in nuclear case
1 of 1
http://www.azcentral.com/news/articles/0328Scotus-WhistleBlower0328...

Page 594 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
33
33 of
of308
456
454

June
June 14, 2016
Supreme Court puts limit on whistle-blowers

in nuclear case
Mark Sherman
Associated Press
Mar. 28, 2007 12:00 AM
WASHINGTON - The Supreme Court left an 81-year-old retired engineer without a penny to show for his role in
exposing fraud at a former nuclear weapons plant in a ruling that makes it harder for whistle-blowers to claim cash
rewards.
James Stone stood to collect up to $1 million from a lawsuit he filed in 1989 against Rockwell International, now part of
aerospace giant Boeing Co., over problems with environmental cleanup at the now-closed Rocky Flats plant northwest
of Denver.
A court eventually ordered Rockwell to pay the government nearly $4.2 million for false claims the company submitted.
Stone could have received up to a quarter of Rockwell's payment, under the False Claims Act.
But Justice Antonin Scalia, writing in the 6-2 ruling Tuesday, said Stone was not entitled to recover any money
because he lacked "direct and independent knowledge of the information upon which his allegations were based."
Scalia said Stone had little connection to the jury's verdict against Rockwell.
The company still must pay the penalty. The only question before the court was whether Stone would get a cut.
The outcome was cheered by business groups that wanted the court to limit whistle-blowers in false claims lawsuits.
Since Congress reinvigorated the Civil War-era law in 1986, those suits have returned $11 billion to the government.
Recent high-profile cases include settlements with leading pharmaceutical manufacturers.
James Moorman, president of the advocacy group Taxpayers Against Fraud Education Fund said that individuals
whose information leads the government to pursue fraud can be told years later that they can't collect anything,
Moorman said.
3/28/2007 8:38 PM

Page 595 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
34
34 of
of308
456
454
(Slip Opinion)

June
June 14, 2016
OCTOBER TERM, 2006
Syllabus
NOTE: Where it is feasible, a syllabus (headnote) will be released, as is
being done in connection with this case, at the time the opinion is issued.
The syllabus constitutes no part of the opinion of the Court but has been
prepared by the Reporter of Decisions for the convenience of the reader.
See United States v. Detroit Timber & Lumber Co., 200 U. S. 321, 337.
SUPREME COURT OF THE UNITED STATES

Syllabus
ROCKWELL INTERNATIONAL CORP. ET AL. v.

UNITED STATES ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR
THE TENTH CIRCUIT
No. 051272.
Argued December 5, 2006Decided March 27, 2007
While employed as an engineer at a nuclear weapons plant run by petitioner Rockwell under a Government contract, respondent Stone predicted that Rockwells system for creating solid pondcrete blocks
from toxic pond sludge and cement would not work because of problems in piping the sludge. However, Rockwell successfully made such
blocks and discovered insolid ones only after Stone was laid off in
1986. In 1989, Stone filed a qui tam suit under the False Claims Act,
which prohibits submitting false or fraudulent payment claims to the
United States, 31 U. S. C. 3729(a); permits remedial civil actions to
be brought by the Attorney General, 3730(a), or by private individuals in the Governments name, 3730(b)(1); but eliminates federalcourt jurisdiction over actions based upon the public disclosure of allegations or transactions . . . , unless the action is brought by the Attorney General or the person bringing the action is an original source
of the information, 3730(e)(4)(A). An original source has direct
and independent knowledge of the information on which the allegations are based and has voluntarily provided the information to the
Government before filing an action . . . based on the information.
3730(e)(4)(B). In 1996, the Government intervened, and, with
Stone, filed an amended complaint, which did not allege that Stones
predicted piping-system defect caused the insolid blocks. Nor was
such defect mentioned in a statement of claims included in the final
pretrial order, which instead alleged that the pondcrete failed because a new foreman used an insufficient cement-to-sludge ratio.
The jury found for respondents with respect to claims covering the
pondcrete allegations, but found for Rockwell with respect to all other

Page 596 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
35
35 of
of308
456
454

June
June 14, 2016
ROCKWELL INTL CORP. v. UNITED STATES

Syllabus
claims. The District Court denied Rockwells postverdict motion to
dismiss Stones claims, finding that Stone was an original source.
The Tenth Circuit affirmed in part, but remanded for the District
Court to determine whether Stone had disclosed his information to
the Government before filing the action. The District Court found
Stones disclosure inadequate, but the Tenth Circuit disagreed and
held that Stone was an original source.
Held:
1. Section 3730(e)(4)s original-source requirement is jurisdictional.
Thus, regardless of whether Rockwell conceded Stones originalsource status, this Court must decide whether Stone meets this jurisdictional requirement. Pp. 811.
2. Because Stone does not meet 3730(e)(4)(B)s requirement that a
relator have direct and independent knowledge of the information on
which the allegations are based, he is not an original source.
Pp. 1218.
(a) The information to which subparagraph (B) speaks is the information on which the relators allegations are based rather than
the information on which the publicly disclosed allegations that triggered the public-disclosure bar are based. The subparagraph standing on its own suggests that disposition. And those allegations are
not the same as the allegations referred to in subparagraph (A),
which bars actions based on the public disclosure of allegations or
transactions with an exception for cases brought by an original
source of the information. Had Congress wanted to link originalsource status to information underlying public disclosure it would
have used the identical phrase, allegations or transactions. Furthermore, it is difficult to understand why Congress would care
whether a relator knows about the information underlying a publicly
disclosed allegation when the relator has direct and independent
knowledge of different information supporting the same allegation.
Pp. 1214.
(b) In determining which allegations are relevant, that term is
not limited to allegations in the original complaint, but includes the
allegations as amended. The statute speaks of the relators allegations, simpliciter. Absent some limitation of 3730(e)(4)s requirement to the initial complaint, this Court will not infer one. Here,
where the final pretrial order superseded prior pleadings, this Court
looks to the final pretrial order to determine original-source status.
Pp. 1417.
(c) Judged according to these principles, Stones knowledge falls
short. The only false claims found by the jury involved insolid pondcrete discovered after Stone left his employment. Thus, he did not
know that the pondcrete had failed; he predicted it. And his predic-

Page 597 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
36
36 of
of308
456
454
Cite as: 549 U. S. ____ (2007)

June
June 14, 2016
Syllabus
tion was a failed one, for Stone believed the piping system was defective when, in fact, the pondcrete problem would be caused by a foremans actions after Stone had left the plant. Stones original-source
status with respect to a separate, spray-irrigation claim did not provide jurisdiction over all of his claims. Section 3730(e)(4) does not
permit jurisdiction in gross just because a relator is an original
source with respect to some claim. Pp. 1718.
3. The Governments intervention in this case did not provide an
independent basis of jurisdiction with respect to Stone. The statute
draws a sharp distinction between actions brought by a private person under 3730(b) and actions brought by the Attorney General under 3730(b). An action originally brought by a private person, which
the Attorney General has joined, becomes an action brought by the
Attorney General only after the private person has been ousted.
Pp. 1820.
92 Fed. Appx. 708, reversed.
SCALIA, J., delivered the opinion of the Court, in which ROBERTS,
C. J., and KENNEDY, SOUTER, THOMAS, and ALITO, JJ., joined. STEVENS,
J., filed a dissenting opinion, in which GINSBURG, J., joined. BREYER, J.,
took no part in the consideration or decision of the case.

Page 598 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
37
37 of
of308
456
454

June
June 14, 2016
Cite as: 549 U. S. ____ (2007)
Opinion of the Court

NOTICE: This opinion is subject to formal revision before publication in the
preliminary print of the United States Reports. Readers are requested to
notify the Reporter of Decisions, Supreme Court of the United States, Washington, D. C. 20543, of any typographical or other formal errors, in order
that corrections may be made before the preliminary print goes to press.

_________________
No. 051272
_________________
ROCKWELL INTERNATIONAL CORP., ET AL.,

PETITIONERS v. UNITED STATES ET AL.
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF
APPEALS FOR THE TENTH CIRCUIT
[March 27, 2007]
JUSTICE SCALIA delivered the opinion of the Court.

The False Claims Act, 31 U. S. C. 37293733, eliminates federal-court jurisdiction over actions under 3730
of the Act that are based upon the public disclosure of
allegations or transactions unless the action is brought by
the Attorney General or the person bringing the action is
an original source of the information. 3730(e)(4)(A). We
decide whether respondent James Stone was an original
source.
I
The mixture of concrete and pond sludge that is the
subject of this case has taken nearly two decades to seep,
so to speak, into this Court. Given the long history and
the complexity of this litigation, it is well to describe the
facts in some detail.
A
From 1975 through 1989, petitioner Rockwell International Corp. was under a management and operating
contract with the Department of Energy (DOE) to run the
Rocky Flats nuclear weapons plant in Colorado. The most

Page 599 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
38
38 of
of308
456
454

June
June 14, 2016

significant portion of Rockwells compensation came in the

form of a semiannual award fee, the amount of which
depended on DOEs evaluation of Rockwells performance
in a number of areas, including environmental, safety, and
health concerns. United States ex rel. Stone v. Rockwell
Intl, Corp., 92 Fed. Appx. 708, 714 (CA10 2004).
From November 1980 through March 1986, James Stone
worked as an engineer at the Rocky Flats plant. In the
early 1980s, Rockwell explored the possibility of disposing
of the toxic pond sludge that accumulated in solar evaporation ponds at the facility, by mixing it with cement. The
idea was to pour the mixture into large rectangular boxes,
where it would solidify into pondcrete blocks that could
be stored onsite or transported to other sites for disposal.
Stone reviewed a proposed manufacturing process for
pondcrete in 1982. He concluded that the proposal would
not work, App. 175, and communicated that conclusion to
Rockwell management in a written Engineering Order.
As Stone would later explain, he believed the suggested
process would result in an unstable mixture that would
later deteriorate and cause unwanted release of toxic
wastes to the environment. Ibid. He believed this because he foresaw that the piping system that extracted
sludge from the solar ponds would not properly remove
the sludge and would lead to an inadequate mixture of
sludge/waste and cement such that the pond crete blocks
would rapidly disintegrate thus creating additional contamination problems. Id., at 290.
Notwithstanding Stones prediction, Rockwell proceeded
with its pondcrete project and successfully manufactured
concrete hard pondcrete during the period of Stones
employment at Rocky Flats. It was only after Stone was
laid off in March 1986 that what the parties have called
insolid pondcrete blocks were discovered. According to
respondents, Rockwell knew by October 1986 that a substantial number of pondcrete blocks were insolid, but

Page 600 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
39
39 of
of308
456
454
Cite as: 549 U. S. ____ (2007)

June
June 14, 2016
DOE did not become aware of the problem until May 1988,
when several pondcrete blocks began to leak, leading to
the discovery of thousands of other insolid blocks. The
media reported these discoveries, 3 Appellants App. in
Nos. 991351, 991352, 991353 (CA10), pp. 88938 to
88939; and attributed the malfunction to Rockwells
reduction of the ratio of concrete to sludge in the mixture.
In June 1987, more than a year after he had left Rockwells employ, Stone went to the Federal Bureau of Investigation (FBI) with allegations of environmental crimes at
Rocky Flats during the time of his employment. According
to the court below, Stone alleged that
contrary to public knowledge, Rocky Flats accepted
hazardous and nuclear waste from other DOE facilities; that Rockwell employees were forbidden from
discussing any controversies in front of a DOE employee; that although Rocky Flats fluid bed incinerators failed testing in 1981, the pilot incinerator remained on line and was used to incinerate wastes
daily since 1981, including plutonium wastes which
were then sent out for burial; that Rockwell distilled
and fractionated various oils and solvents although
the wastes were geared for incineration; that Stone
believed that the ground water was contaminated
from previous waste burial and land application, and
that hazardous waste lagoons tended to overflow during and after a good rain, causing hazardous wastes
to be discharged without first being treated. App. to
Pet. for Cert. 4a.
Stone provided the FBI with 2,300 pages of documents,
buried among which was his 1982 engineering report
predicting that the pondcrete-system design would not
work. Stone did not discuss his pondcrete allegations with

Page 601 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
40
40 of
of308
456
454

June
June 14, 2016

the FBI in their conversations.1

Based in part on information allegedly learned from
Stone, the Government obtained a search warrant for
Rocky Flats, and on June 6, 1989, 75 FBI and Environmental Protection Agency agents raided the facility. The
affidavit in support of the warrant included allegations (1)
that pondcrete blocks were insolid due to an inadequate
waste-concrete mixture, App. 429, (2) that Rockwell
obtained award fees based on its alleged excellent
management of Rocky Flats, id., at 98, and (3) that Rockwell made false statements and concealed material facts in
violation of the Resource Conservation and Recovery Act
of 1976 (RCRA), 90 Stat. 2811, 42 U. S. C. 6928, and 18
U. S. C. 1001. Newspapers published these allegations.
In March 1992, Rockwell pleaded guilty to 10 environmental violations, including the knowing storage of insolid
pondcrete blocks in violation of RCRA. Rockwell agreed to
pay $18.5 million in fines.
B
In July 1989, Stone filed a qui tam suit under the False
Claims Act.2 That Act prohibits false or fraudulent claims
for payment to the United States, 31 U. S. C. 3729(a),
and authorizes civil actions to remedy such fraud to be
brought by the Attorney General, 3730(a), or by private
individuals in the Governments name, 3730(b)(1). The
Act provides, however, that [n]o court shall have jurisdiction over an action under this section based upon the
public disclosure of allegations or transactions . . . from
the news media, unless the action is brought by the Attorney General or the person bringing the action is an origi
1 Stone claimed the contrary, but the District Court found that he had
failed to establish that fact.
2 Qui tam is short for qui tam pro domino rege quam pro se ipso in
hac parte sequitur, which means who pursues this action on our Lord
the Kings behalf as well as his own.

Page 602 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
41
41 of
of308
456
454
Cite as: 549 U. S. ____ (2007)

June
June 14, 2016
nal source of the information. 3730(e)(4)(A). An original source is an individual who has direct and independent knowledge of the information on which the allegations
are based and has voluntarily provided the information to
the Government before filing an action under this section
which is based on the information. 3730(e)(4)(B).
Stones complaint alleged that Rockwell was required to
comply with certain federal and state environmental laws
and regulations, including RCRA; that Rockwell committed numerous violations of these laws and regulations
throughout the 1980s3; and that, in order to induce the
Government to make payments or approvals under Rockwells contract, Rockwell knowingly presented false and
fraudulent claims to the Government in violation of the
False Claims Act, 31 U. S. C. 3729(a). As required under
the Act, Stone filed his complaint under seal and simultaneously delivered to the Government a confidential disclosure statement describing substantially all material
evidence and information in his possession, 3730(b)(2).
The statement identified 26 environmental and safety
issues, only one of which involved pondcrete. With respect
to that issue, Stone explained in his statement that he had
3 The laws and regulations allegedly violated included DOE Order

Nos. 5480.2 (Dec. 1982), 5483.1 as superseded by 5483.1A (June 22,
1983), and 6430.1 (Dec. 12, 1983) (DOE General Design Criteria Manual); Colo. Rev. Stat. 255501 et seq. (1982) (Hazardous Substances),
257101 et seq. (1982 and Supp. 1988) (Air Quality Control Program),
257501 et seq. (Asbestos Control), 2515101 (Hazardous Waste
Management Act, 258201 (1982) (Water Quality Control Act), 2511
101 (1982 and Supp. 1988) (Radiation Control), 2922101 (Hazardous
Substance Incidents), 255503 (1982), 258506, 258608, 2515
308 through 2515310, and 2922108; the Occupational Safety and
Health Act of 1970, 29 U. S. C. 651 et seq.; the Atomic Energy Act of
1954, as amended, 42 U. S. C. 2011 et seq.; the Energy Reorganization
Act of 1974, 42 U. S. C. 5801 et seq.; the Water Pollution Prevention
and Control Act, 33 U. S. C. 1251 et seq.; the Clean Air Act, 42 U. S. C.
7401 et seq.; the Safe Drinking Water Act, 42 U. S. C. 300f et seq.; and
regulations promulgated under these statutes.

Page 603 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
42
42 of
of308
456
454

June
June 14, 2016

reviewed the design for the pondcrete system and had

foreseen that the piping mechanism would not properly
remove the sludge, which in turn would lead to an inadequate mixture of sludge and cement.
In December 1992, Rockwell moved to dismiss Stones
action for lack of subject-matter jurisdiction, arguing that
the action was based on publicly disclosed allegations and
that Stone was not an original source. The District Court
denied the motion because, in its view, Stone had direct
and independent knowledge that Rockwells compensation
was linked to its compliance with environmental, health
and safety regulations and that it allegedly concealed its
deficient performance so that it would continue to receive
payments. App. to Pet. for Cert. 61a.
The Government initially declined to intervene in
Stones action, but later reversed course, and in November
1996, the District Court granted the Governments intervention. Several weeks later, at the suggestion of the
District Court, the Government and Stone filed a joint
amended complaint. As relevant here, the amended complaint alleged that Rockwell violated RCRA by storing
leaky pondcrete blocks, but did not allege that any defect
in the piping system (as predicted by Stone) caused insolid
pondcrete.4 Respondents clarified their allegations even
further in a statement of claims which became part of the
final pretrial order and which superseded their earlier
pleadings. This said that the pondcretes insolidity was
due to an incorrect cement/sludge ratio used in pondcrete
operations, as well as due to inadequate process controls
and inadequate inspection procedures. App. 470. It
continued:
4 In addition to the pondcrete allegations, respondents charged Rockwell with concealing problems with saltcrete (a mixture of cement and
salt from liquid waste treatment processes) and spray irrigation (a
method of disposing of waste water generated by the sewage treatment
plant at Rocky Flats).

Page 604 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
43
43 of
of308
456
454
Cite as: 549 U. S. ____ (2007)

June
June 14, 2016
During the winter of 1986, Rockwell replaced its then

pondcrete foreman, Norman Fryback, with Ron Teel.
Teel increased pondcrete production rates in part by,
among other things, reducing the amount of cement
added to the blocks. Following the May 23, 1988 spill,
Rockwell acknowledged that this reduced cement-tosludge ratio was a major contributor to the existence
of insufficiently solid pondcrete blocks on the storage
pads. Id., at 476477.
The statement of claims again did not mention the piping
problem asserted by Stone years earlier.
Respondents False Claims Act claims went to trial in
1999. None of the witnesses Stone had identified during
discovery as having relevant knowledge testified at trial.
And none of the documents Stone provided to the Government with his confidential disclosure statement was
introduced in evidence at trial. Nor did respondents allege
at trial that the defect in the piping system predicted by
Stone caused insolid pondcrete. To the contrary, during
closing arguments both Stones counsel and the Governments counsel repeatedly explained to the jury that the
pondcrete failed because Rockwells new foreman used an
insufficient cement-to-sludge ratio in an effort to increase
pondcrete production.
The verdict form divided the False Claims Act count into
several different claims corresponding to different awardfee periods. The jury found in favor of respondents for the
three periods covering the pondcrete allegations (April 1,
1987, to September 30, 1988), and found for Rockwell as to
the remaining periods. The jury awarded damages of
$1,390,775.80, which the District Court trebled pursuant
to 31 U. S. C. 3729(a).
Rockwell filed a postverdict motion to dismiss Stones
claims under 3730(e)(4), arguing that the claims were
based on publicly disclosed allegations and that Stone was

Page 605 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
44
44 of
of308
456
454

June
June 14, 2016

not an original source. In response, Stone acknowledged

that his successful claims were based on publicly disclosed
allegations, but asserted original-source status.
The
District Court agreed with Stone. The United States
Court of Appeals for the Tenth Circuit affirmed in relevant
part, but remanded the case for the District Court to
determine whether Stone had disclosed his information to
the Government before filing his qui tam action, as
3730(e)(4)(B) required. On remand, the District Court
found that Stone had produced the 1982 engineering order
to the Government, but that the order was insufficient to
communicate Stones allegations. The District Court also
found that Stone had not carried his burden of proving
that he orally informed the FBI about his allegations
before filing suit. On appeal, the Tenth Circuit disagreed
with the District Courts conclusion and held (over the
dissent of Judge Briscoe) that the 1982 engineering order
sufficed to carry Stones burden of persuasion. 92 Fed.
Appx. 708. We granted certiorari, 548 U. S. ____ (2006), to
decide whether Stone was an original source.
II
Section 3730(e)(4)(A) provides that
[n]o court shall have jurisdiction over an action under
this section based upon the public disclosure of allegations or transactions in a criminal, civil, or administrative hearing, in a congressional, administrative, or
Government Accounting Office report, hearing, audit,
or investigation, or from the news media, unless the
action is brought by the Attorney General or the person bringing the action is an original source of the information. (Footnote omitted.)
As discussed above, 3730(e)(4)(B) defines original
source as an individual who [1] has direct and independent knowledge of the information on which the allegations

Page 606 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
45
45 of
of308
456
454
Cite as: 549 U. S. ____ (2007)

June
June 14, 2016
are based and [2] has voluntarily provided the information

to the Government before filing an action under this section which is based on the information. As this case
comes to the Court, it is conceded that the claims on which
Stone prevailed were based upon publicly disclosed allegations within the meaning of 3730(e)(4)(A). The question
is whether Stone qualified under the original-source exception to the public-disclosure bar.
We begin with the possibility that little analysis is
required in this case, for Stone asserts that Rockwell
conceded his original-source status. Rockwell responds
that it conceded no such thing and that, even had it done
so, the concession would have been irrelevant because
3730(e)(4) is jurisdictional. We agree with the latter
proposition. It is true enough that the word jurisdiction
does not in every context connote subject-matter jurisdiction. Noting that jurisdiction is a word of many, too
many, meanings, we concluded in Steel Co. v. Citizens for
Better Environment, 523 U. S. 83 (1998), that establishing
the elements of an offense was not made a jurisdictional
matter merely because the statute creating the cause of
action was phrased as providing for jurisdiction over
such suits. Id., at 90 (quoting United States v. Vanness, 85
F. 3d 661, 663, n. 2 (CADC 1996)). Here, however, the
issue is not whether casting the creation of a cause of
action in jurisdictional terms somehow limits the general
grant of jurisdiction under which that cause of action
would normally be brought, but rather whether a clear
and explicit withdrawal of jurisdiction withdraws jurisdiction. It undoubtedly does so. Just last Term we stated
that, [i]f the Legislature clearly states that a threshold
limitation on a statutes scope shall count as jurisdictional,
the courts and litigants will be duly instructed and will
not be left to wrestle with the issue. Arbaugh v. Y & H
Corp., 546 U. S. 500, 515516 (2006) (footnote omitted).
Here the jurisdictional nature of the original-source re-

Page 607 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
46
46 of
of308
456
454
10

June
June 14, 2016

quirement is clear ex visceribus verborum. Indeed, we

have already stated that 3730(e)(4) speaks to the power
of a particular court as well as the substantive rights of
the parties. Hughes Aircraft Co. v. United States ex rel.
Schumer, 520 U. S. 939, 951 (1997).
Stones contrary position rests entirely on dicta from a
single Court of Appeals decision, see United States ex rel.
Fallon v. Accudyne Corp., 97 F. 3d 937, 940941 (CA7
1996). Accudyne thought it significant that jurisdiction
over False Claims Act cases is conferred by 28 U. S. C.
1331 and 1345 (the federal-question and United-Statesas-plaintiff provisions of the Judicial Code) and 31
U. S. C. 3732(a) (the provision of the False Claims Act
establishing federal-court venue and conferring federalcourt jurisdiction over related state-law claims), rather
than 3730, which is the section referenced in
3730(e)(4). To eliminate jurisdiction, the court believed,
it is those jurisdiction-conferring sections that would have
to be referenced. We know of nothing in logic or authority
to support this. The jurisdiction-removing provision here
does not say no court shall have jurisdiction under this
section, but rather no court shall have jurisdiction over
an action under this section. That is surely the most
natural way to achieve the desired result of eliminating
jurisdiction over a category of False Claims Act actions
rather than listing all the conceivable provisions of the
United States Code whose conferral of jurisdiction is being
eliminated. (In addition to the provisions cited by the
Accudyne court, one might also have to mention the diversity-jurisdiction provision, 28 U. S. C. 1332, and the
supplemental-jurisdiction provision, 1367.)
Accudyne
next observed that the public-disclosure bar limits only
who may speak for the United States on a subject and who
if anyone gets a financial reward, not the categories of
disputes that may be resolved (a real jurisdictional
limit). 97 F. 3d, at 941. But this is a classic begging of

Page 608 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
47
47 of
of308
456
454
Cite as: 549 U. S. ____ (2007)

June
June 14, 2016
11
the question, which is precisely whether there has been

removed from the courts jurisdiction that category of
disputes consisting of False Claims Act qui tam suits
based on publicly disclosed allegations as to which the
relator is not an original source of the information. Nothing prevents Congress from defining the category of
excluded suits in any manner it wishes. See, e.g., 28
U. S. C. 1500 (no jurisdiction over any claim for or in
respect to which the plaintiff . . . has pending in any other
court any suit . . . against the United States). Lastly,
Accudyne asserted that the Supreme Court had held that
a similar reference to jurisdiction in the Norris-LaGuardia
Act, 29 U. S. C. 101, 104, limits remedies rather than
subject-matter jurisdiction. 97 F. 3d, at 941 (citing Burlington Northern R. Co. v. Maintenance of Way Employes,
481 U. S. 429, 444446 (1987)). But the language of the
Norris-LaGuardia Act is in fact not similar. It provides
that [n]o court of the United States shall have jurisdiction
to issue any restraining order or temporary or permanent
injunction in any case involving or growing out of any
labor dispute . . . . 29 U. S. C. 104 (emphasis added). It
is facially a limitation upon the relief that can be accorded,
not a removal of jurisdiction over any case involving or
growing out of a labor dispute. Here, by contrast, the text
says [n]o court shall have jurisdiction over an action
under this section.
Whether the point was conceded or not, therefore, we
may, and indeed must, decide whether Stone met the
jurisdictional requirement of being an original source.
III
We turn to the first requirement of original-source
status, that the relator have direct and independent
knowledge of the information on which the allegations are
based. 31 U. S. C. 3730(e)(4)(B). Because we have not
previously addressed this provision, several preliminary

Page 609 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
48
48 of
of308
456
454
12

June
June 14, 2016

questions require our attention.

A
First, does the phrase information on which the allegations are based refer to the information on which the
relators allegations are based or the information on which
the publicly disclosed allegations that triggered the publicdisclosure bar are based? The parties agree it is the former. See Brief for Petitioners 26, n. 13; Brief for United
States 24, and n. 8; Brief for Respondent Stone 15, 21.
But in view of our conclusion that 3730(e)(4) is jurisdictional, we must satisfy ourselves that the parties position
is correct.
Though the question is hardly free from doubt,5 we
agree that the information to which subparagraph (B)
speaks is the information upon which the relators allegations are based. To begin with, subparagraph (B) standing
on its own suggests that disposition. The relator must
have direct and independent knowledge of the information on which the allegations are based, and he must
provid[e] the information to the Government before filing
an action under this section which is based on the information. Surely the information one would expect a relator to provide to the Government before filing an action
. . . based on the information is the information underlying the relators claims.
Subparagraph (A) complicates matters. As described
earlier, it bars actions based on the public disclosure of
allegations or transactions and provides an exception for
5 The
Courts of Appeals have divided over the question. See United

States ex rel. Laird v. Lockheed Martin Eng. & Science Servs. Co., 336
F. 3d 346, 353355 (CA5 2003) (describing the Courts of Appeals
divergent approaches). Only by demoting the actual text of 3730(e)(4)
to a footnote and then paraphrasing the statute in a way that assumes
his conclusion can JUSTICE STEVENS assert (without further analysis)
that the statutes meaning is plain. See post, at 1, 2 (dissenting
opinion).

Page 610 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
49
49 of
of308
456
454
Cite as: 549 U. S. ____ (2007)

June
June 14, 2016
13
cases brought by an original source of the information.

If the allegations referred to in subparagraph (B)s phrase
requiring direct and independent knowledge of the information on which the allegations are based, are the same
allegations referred to in subparagraph (A), then original-source status would depend on knowledge of information underlying the publicly disclosed allegations. The
principal textual difficulty with that interpretation is that
subparagraph (A) does not speak simply of allegations,
but of allegations or transactions. Had Congress wanted
to link original-source status to information underlying
the public disclosure, it would surely have used the identical phrase, allegations or transactions; there is no conceivable reason to require direct and independent knowledge of publicly disclosed allegations but not of publicly
disclosed transactions.
The sense of the matter offers strong additional support
for this interpretation. Section 3730(e)(4)(A) bars actions
based on publicly disclosed allegations whether or not the
information on which those allegations are based has been
made public. It is difficult to understand why Congress
would care whether a relator knows about the information
underlying a publicly disclosed allegation (e.g., what a
confidential source told a newspaper reporter about insolid
pondcrete) when the relator has direct and independent
knowledge of different information supporting the same
allegation (e.g., that a defective process would inevitably
lead to insolid pondcrete). Not only would that make little
sense, it would raise nettlesome procedural problems,
placing courts in the position of comparing the relators
information with the often unknowable information on
which the public disclosure was based. Where that latter
information has not been disclosed (by reason, for example, of a reporters desire to protect his source), the relator
would presumably be out of court. To bar a relator with
direct and independent knowledge of information underly-

Page 611 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
50
50 of
of308
456
454
14

June
June 14, 2016

ing his allegations just because no one can know what

information underlies the similar allegations of some other
person simply makes no sense.
The contrary conclusion of some lower courts rests on
the following logic: The term information in subparagraph (B) must be read in tandem with the term information in subparagraph (A), and the term information in
subparagraph (A) refers to the information on which the
publicly disclosed allegations are based. See, e.g., United
States ex rel. Laird v. Lockheed Martin Eng. & Science
Servs. Co., 336 F. 3d 346, 354 (CA5 2003). The major
premise of this reasoning seems true enough: information in (A) and (B) means the same thing. The minor
premise, howeverthat information in (A) refers to the
information underlying the publicly disclosed allegations
or transactionsis highly questionable. The complete
phrase at issue is unless . . . the person bringing the
action is an original source of the information. It seems
to us more likely (in light of the analysis set forth above)
that the information in question is the information underlying the action referred to a few words earlier, to-wit, the
action based upon the public disclosure of allegations or
transactions referred to at the beginning of the provision.
On this interpretation, information in subparagraph (A)
and information on which the allegations are based in
subparagraph (B) are one and the same, viz., information
underlying the allegations of the relators action.
B
Having determined that the phrase information on
which the allegations are based refers to the relators
allegations and not the publicly disclosed allegations, we
confront more textual ambiguity: Which of the relators
allegations are the relevant ones? Stones allegations
changed during the course of the litigation, yet he asks
that we look only to his original complaint. Rockwell

Page 612 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
51
51 of
of308
456
454
Cite as: 549 U. S. ____ (2007)

June
June 14, 2016
15
argues that Stone must satisfy the original-source exception through all stages of the litigation.
In our view, the term allegations is not limited to the
allegations of the original complaint. It includes (at a
minimum) the allegations in the original complaint as
amended. The statute speaks not of the allegations in the
original complaint (or even the allegations in the complaint), but of the relators allegations simpliciter.
Absent some limitation of 3730(e)(4)s requirement to the
relators initial complaint, we will not infer one. Such a
limitation would leave the relator free to plead a trivial
theory of fraud for which he had some direct and independent knowledge and later amend the complaint to
include theories copied from the public domain or from
materials in the Governments possession. Even the
Government concedes that new allegations regarding a
fundamentally different fraudulent scheme require reevaluation of the courts jurisdiction. See Brief for United
States 40; Tr. of Oral Arg. 40.
The rule that subject-matter jurisdiction depends on
the state of things at the time of the action brought,
Mollan v. Torrance, 9 Wheat. 537, 539 (1824), does not
suggest a different interpretation. The state of things and
the originally alleged state of things are not synonymous;
demonstration that the original allegations were false will
defeat jurisdiction. Anderson v. Watt, 138 U. S. 694, 701
(1891); Morris v. Gilmer, 129 U. S. 315, 326 (1889). So
also will the withdrawal of those allegations, unless they
are replaced by others that establish jurisdiction. Thus,
when a plaintiff files a complaint in federal court and then
voluntarily amends the complaint, courts look to the
amended complaint to determine jurisdiction. See Wellness Community-Nat. v. Wellness House, 70 F. 3d 46, 49
(CA7 1995); Boelens v. Redman Homes, Inc., 759 F. 2d 504,

Page 613 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
52
52 of
of308
456
454
16

June
June 14, 2016

508 (CA5 1984).6

Here, we have not only an amended complaint, but a
final pretrial order that superseded all prior pleadings and
controll[ed] the subsequent course of the action, Fed.
Rule Civ. Proc. 16(e). See Curtis v. Loether, 415 U. S. 189,
190, n. 1 (1974) (where a claim was not included in the
complaint, but was included in the pretrial order, it is
irrelevant that the pleadings were never formally
amended (citing Fed. Rules Civ. Proc. 15(b), 16)); Wilson
v. Muckala, 303 F. 3d 1207, 1215 (CA10 2002) ([C]laims,
issues, defenses, or theories of damages not included in
the pretrial order are waived even if they appeared in the
complaint and, conversely, the inclusion of a claim in the
pretrial order is deemed to amend any previous pleadings
which did not include that claim); Syrie v. Knoll Intl, 748
F. 2d 304, 308 (CA5 1984) ([I]ncorporation of a [new]
claim into the pre-trial order . . . amends the previous
pleadings to state [the new] claim). In these circumstances, we look to the allegations as amendedhere, the
statement of claims in the final pretrial orderto determine original-source status.
The Government objects that this approach risks driving
a wedge between the Government and relators. It worries
that future relators might decline to acquiesc[e] in the
Governments tactical decision to narrow the claims in a
case if that would eliminate jurisdiction with respect to
the relator. Brief for United States 44. Even if this policy
concern were valid, it would not induce us to determine
6 It
is true that, when a defendant removes a case to federal court

based on the presence of a federal claim, an amendment eliminating
the original basis for federal jurisdiction generally does not defeat
jurisdiction. See Carnegie-Mellon Univ. v. Cohill, 484 U. S. 343, 346,
357 (1988); St. Paul Mercury Indemnity Co. v. Red Cab Co., 303 U. S.
283, 293 (1938). But removal cases raise forum-manipulation concerns
that simply do not exist when it is the plaintiff who chooses a federal
forum and then pleads away jurisdiction through amendment.

Page 614 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
53
53 of
of308
456
454
Cite as: 549 U. S. ____ (2007)

June
June 14, 2016
17
jurisdiction on the basis of whether the relator is an original source of information underlying allegations that he
no longer makes.
IV
Judged according to the principles set forth above,
Stones knowledge falls short. The only false claims ultimately found by the jury (and hence the only ones to
which our jurisdictional inquiry is pertinent to the outcome) involved false statements with respect to environmental, safety, and health compliance over a one-and-ahalf-year period between April 1, 1987, and September 30,
1988. As described by Stone and the Government in the
final pretrial order, the only pertinent problem with respect to this period of time for which Stone claimed to
have direct and independent knowledge was insolid pondcrete. Because Stone was no longer employed by Rockwell
at the time, he did not know that the pondcrete was insolid; he did not know that pondcrete storage was even
subject to RCRA; he did not know that Rockwell would fail
to remedy the defect; he did not know that the insolid
pondcrete leaked while being stored onsite; and, of course,
he did not know that Rockwell made false statements to
the Government regarding pondcrete storage.
Stones prediction that the pondcrete would be insolid
because of a flaw in the piping system does not qualify as
direct and independent knowledge of the pondcrete
defect. Of course a qui tam relators misunderstanding of
why a concealed defect occurred would normally be immaterial as long as he knew the defect actually existed. But
here Stone did not know that the pondcrete failed; he
predicted it. Even if a prediction can qualify as direct and
independent knowledge in some cases (a point we need not
address), it assuredly does not do so when its premise of
cause and effect is wrong. Stones prediction was a failed
prediction, disproved by Stones own allegations. As Stone

Page 615 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
54
54 of
of308
456
454
18

June
June 14, 2016

acknowledged, Rockwell was able to produce concrete

hard pondcrete using the machinery Stone said was
defective. According to respondents allegations in the
final pretrial order, the insolidity problem was caused by a
new foremans reduction of the cement-to-sludge ratio in
the winter of 1986, long after Stone had left Rocky Flats.
Stone counters that his original-source status with
respect to his spray-irrigation claim (which related to a
time period different from that for his pondcrete claim,
App. 492) provided jurisdiction with respect to all of his
claims. We disagree. Section 3730(e)(4) does not permit
jurisdiction in gross just because a relator is an original
source with respect to some claim. We, along with every
court to have addressed the question, conclude that
3730(e)(4) does not permit such claim smuggling. See
United States ex rel. Merena v. SmithKline Beecham Corp.,
205 F. 3d 97, 102 (CA3 2000); Hays v. Hoffman, 325 F. 3d
982, 990 (CA8 2003); Wang ex rel. United States v. FMC
Corp., 975 F. 2d 1412, 14151416, 1420 (CA9 1992). As
then-Judge Alito explained, [t]he plaintiffs decision to
join all of his or her claims in a single lawsuit should not
rescue claims that would have been doomed by section
(e)(4) if they had been asserted in a separate action. And
likewise, this joinder should not result in the dismissal of
claims that would have otherwise survived. SmithKline
Beecham, supra, at 102.
Because Stone did not have direct and independent
knowledge of the information upon which his allegations
were based, we need not decide whether Stone met the
second requirement of original-source status, that he have
voluntarily provided the information to the Government
before filing his action.
V
Respondents contend that even if Stone failed the original-source test as to his pondcrete allegations, the Gov-

Page 616 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
55
55 of
of308
456
454
Cite as: 549 U. S. ____ (2007)

June
June 14, 2016
19
ernments intervention in his case provided an independent basis of jurisdiction. Section 3730(e)(4)(A) permits
jurisdiction over an action based on publicly disclosed
allegations or transactions if the action is brought by the
Attorney General. Respondents say that any inquiry into
Stones original-source status with respect to amendments
to the complaint was unnecessary because the Government had intervened, making this an action brought by
the Attorney General.7 Even assuming that Stone was an
original source of allegations in his initial complaint, we
reject respondents intervention argument.
The False Claims Act contemplates two types of actions.
First, under 3730(a), [i]f the Attorney General finds that
a person has violated or is violating section 3729, the
Attorney General may bring a civil action under this
section against the person. Second, under 3730(b), [a]
person may bring an action for a violation of section 3729
for the person and for the United States Government.
When a private person brings an action under 3730(b),
the Government may elect to proceed with the action,
3730(b)(4)(A), or it may declin[e] to take over the action,
in which case the person bringing the action shall have the
right to conduct the action, 3730(b)(4)(B). The statute
thus draws a sharp distinction between actions brought by
the Attorney General under 3730(a) and actions brought
by a private person under 3730(b). An action brought by
a private person does not become one brought by the
Government just because the Government intervenes and
elects to proceed with the action. Section 3730 elsewhere
refers to the Governments proceed[ing] with an action
brought by a person under subsection (b)which makes
crystal clear the distinction between actions brought by
7 The Government includes a significant caveat: In its view, intervention does not cure any pre-existing defects in Stones initial complaint;
it only cures defects resulting from amendments to the pleadings.

Page 617 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
56
56 of
of308
456
454
20

June
June 14, 2016

the Government and actions brought by a relator where

the Government intervenes but does not oust the relator.
Does this conclusion cast into doubt the courts jurisdiction with respect to the Government as well? After all,
3730(e)(4)(A) bars jurisdiction over any action brought
under 3730, as this one was, unless the action is brought
(1) by the Attorney General or (2) by an original source;
and we have concluded that this is brought by neither.
Not even petitioners have suggested the bizarre result
that the Governments judgment must be set aside. It is
readily enough avoided, as common sense suggests it must
be, by holding that an action originally brought by a private person, which the Attorney General has joined, becomes an action brought by the Attorney General once the
private person has been determined to lack the jurisdictional prerequisites for suit. The outcome would be similar to that frequently produced in diversity-jurisdiction
cases, where the courts of appeals . . . have the authority
to cure a jurisdictional defect by dismissing a dispensable
nondiverse party. Grupo Dataflux v. Atlas Global Group,
L. P., 541 U. S. 567, 573 (2004) (citing Newman-Green,
Inc. v. Alfonzo-Larrain, 490 U. S. 826, 837 (1989)); see
United States Steel Corp. v. EPA, 614 F. 2d 843, 845 (CA3
1979) ([T]here are instances when an intervenors claim
does not rise and fall with the claim of the original party);
7C C. Wright, A. Miller, & M. Kane, Federal Practice and
Procedure 1920, p. 491 (2d ed. 1986) ([A]n intervenor
can proceed to decision after a dismissal of the original
action . . . if there are independent grounds for jurisdiction
of the intervenors claim). What is cured here, by the
jurisdictional ruling regarding Stones claim, is the characterization of the action as one brought by an original
source. The elimination of Stone leaves in place an action
pursued only by the Attorney General, that can reasonably
be regarded as being brought by him for purposes of
3730(e)(4)(A).

Page 618 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
57
57 of
of308
456
454
Cite as: 549 U. S. ____ (2007)

June
June 14, 2016
21
*
*
*
We hold that the District Court lacked jurisdiction to
enter judgment in favor of Stone. We reverse the Tenth
Circuits judgment to the contrary.
It is so ordered.
JUSTICE BREYER took no part in the consideration or
decision of this case.

Page 619 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
58
58 of
of308
456
454

June
June 14, 2016
Cite as: 549 U. S. ____ (2007)
STEVENS, J., dissenting

_________________
No. 051272
_________________
ROCKWELL INTERNATIONAL CORP., ET AL.,

PETITIONERS v. UNITED STATES ET AL.
ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF
APPEALS FOR THE TENTH CIRCUIT
[March 27, 2007]
JUSTICE STEVENS, with whom JUSTICE GINSBURG joins,

dissenting.
Any private citizen may bring an action to enforce the
False Claims Act, 31 U. S. C. 37293733, unless the
information on which his allegations are based is already
in the public domain. Even if the information is publicly
available, however, the citizen may still sue if he was an
original source of that information. 3730(e)(4)(A) (No
court shall have jurisdiction over an action under this
section based upon the public disclosure of allegations or
transactions . . . unless the action is brought by the Attorney General or the person bringing the action is an original source of the information). Because I believe the
Court has misinterpreted these provisions to require that
an original source in a qui tam action have knowledge of
the actual facts underlying the allegations on which he
may ultimately prevail, I respectfully dissent.
In my view, a plain reading of the statutes provisions
specifically, 3730(e)(4)(A) and (B)makes clear that it is
the information underlying the publicly disclosed allegations, not the information underlying the allegations in
the relators complaint (original or amended), of which the
relator must be an original source.1 Moreover, the stat
1 Section
3730(e)(4)(A) states that

Page 620 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
59
59 of
of308
456
454

June
June 14, 2016

utes use of the article an, rather than the, in describing the original source indicates that the relator need not
be the sole source of the information.
By contrast, the majoritys approach suggests that the
relator must have knowledge of actual facts supporting
the theory ultimately proven at trialin other words,
knowledge of the information underlying the prevailing
claims. See ante, at 17 (limiting the relevant jurisdictional
inquiry to those false claims ultimately found by the
jury). I disagree. Such a view is not supported by the
statute, which requires only that the relator have direct
and independent knowledge of the information on which
the publicly disclosed allegations are based and that the
relator provide such information to the Government in a
timely manner. As I read the statute, the jurisdictional
inquiry focuses on the facts in the public domain at the
time the action is commenced. If the process of discovery
leads to amended theories of recovery, amendments to the
original complaint would not affect jurisdiction that was
proper at the time of the original filing.2
No court shall have jurisdiction over an action under this section based
upon the public disclosure of allegations or transactions in a criminal,
civil, or administrative hearing, in a congressional, administrative, or
Government Accounting Office report, hearing, audit, or investigation,
or from the news media, unless the action is brought by the Attorney
General or the person bringing the action is an original source of the
information. (Footnote omitted.)
Section 3730(e)(4)(B) then states that
For purposes of this paragraph, original source means an individual
who has direct and independent knowledge of the information on which
the allegations are based and has voluntarily provided the information
to the Government before filing an action under this section which is
based on the information.
2 The majoritys approach requires courts to reevaluate jurisdiction
over a qui tam action brought by an original source every time the
complaint is amended. Such an approach, the Government has argued,
will interfere with its ability to tailor the claims advanced as it sees
appropriate. By contrast, under the approach I would adopt, the

Page 621 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
60
60 of
of308
456
454
Cite as: 549 U. S. ____ (2007)

June
June 14, 2016
In this case, as the Court points out, the fact that Rockwell was storing thousands of insolid pondcrete blocks at
the Rocky Flats facility had been publicly disclosed by the
news media before Stone filed this lawsuit. Ante, at 3, 4.
In my view, the record establishes that Stone was an
original source of the allegations publicly disclosed by the
media in June 1989, even though he thought that the
deterioration of the pondcrete blocks would be caused by
poor engineering rather than a poor formula for the mixture. The search warrant that was executed on June 6,
1989, and the Federal Bureau of Investigation (FBI) affidavit that was released to the news media on June 9,
1989, were both based, in part, on interviews with Stone
and on information Stone had provided to the Government, including the 1982 Engineering Order.
With respect to earlier media coverage of the pondcrete
leakage discovery in May 1988, however, Stones status as
an original source is less obvious. Stone first went to the
FBI with allegations of Rockwells environmental violations in March 1986. App. 180. He subsequently met with
several FBI agents over the course of several years. Id., at
180182. During those meetings he provided the FBI with
thousands of pages of documents, including the Engineering Order, in which he predicted that the pondcrete system design would not work. On the basis of that record, it
seems likely that Stone (1) had direct and independent
knowledge of the information on which the [publicly disclosed] allegations [we]re based and (2) voluntarily provided such information to the Government before filing
suit. It is, however, his burden to establish that he did so.
Because there has been no finding as to whether Stone
jurisdictional inquiry relates only to whether the relator was an original source of the information underlying the public disclosures, which
can easily be determined when an action is filed and need not be
revisited during later stages of the litigation.

Page 622 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
61
61 of
of308
456
454

June
June 14, 2016

was an original source as to those public disclosures, I

would vacate and remand for a determination whether
Stone was in fact an original source of the allegations
publicly disclosed by the media in 1988 and 1989.

Page 623 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
62
62 of
of308
456
454

June
June 14, 2016
November 23, 1997
Page 1
Mr. Stan J. Caterbone

220 Stone Hill Road
Conestoga, PA 17516
Ms. Christina Rainville
1300 Market Street
RE:
Previously discussed matters.
Dear Ms. Rainville:

I thank you for your help regarding the enclosed materials. As I have discussed previously, I would
appreciate your legal opinion as to the extent of my legal rights concerning the following
circumstances..
I will attempt to describe the many legal issues that are contained herein, and I have provided
documentation substantiating my claims. Due to the complexity and sensitive nature of these
issues, I have tried to reduce the paper to its simplest form, while also protecting the integrity of my
claims. I have also provided authentic conversations, which I recorded merely in my defense as an
accurate account of the activities surrounding my sudden demise. I possess many more forms of
evidence, including over 9000 paper images that I had microfilmed in November of 1987.
I realize that you offered to review only a few documents, however it was necessary to formulate
the documents in a way that was sufficient to challenge the legal issues that I am questioning.
Documents 1 & 2 would provide a glimpse into the legal merits of my claims. The following is an
attempt to provide you with a brief description of the activities and actions contained in these
matters. Please understand that I have not included any related activities that continued during
1991, especially concerning ISC and the CIA.
The following is a legend of the conversations contained on the Compact Disc:
1. 09/29/87 - A segment of the interview with the PA Securtiies and Exchange
Commission, Agent Howard Eisler, Attorney Robert Beyer, Client Millard Johnson, and
myself, present.
2. 02/24/88 - Meeting with Attorney Sandra Gray, of San Diego, California.
3. 07/10/87 - Phone conversation with Chuck Smith, President of Lancaster Aviation.
4. 07/07/87 - Phone conversation with Attorney David Drubner.
5. 07/21/87 - Meeting in Hollywood California with the owner of Gamillion Film Studios,
who was seeking my help to secure financing. Also present is Marcia Silen, a producer
of the Digital Movie.
6. 10/27/87 - Telephone conversation with Pennsylvania Securities & Exchange
Commission Agent, Howard Eisler.
7. 10/26/87 - Detective Boden, of the Pennsylvania Attorney Generals office.
8. 02/11/91 - NBC News documentary of illegal shipments of Arms and Munitions to Iraq.

Page 624 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
63
63 of
of308
456
454
November 23, 1997

June
June 14, 2016
Page 2
9. 02/28/91 - ABC News 20/20 segment on International Signal & Control, and Arms to
Iraq.
Please forgive the form of the following narrative, however it is especially draining to prepare these
materials. This is the first time that I have attempted this task, with the exception of various efforts
which were intended to merely defend myself, my person, my character, my reputation, or my
assets. You will eventually discover that the question of my mental condition is of grave
importance to my perpetrators. For the record, I do suffer from Bi Polar Mood Disorder, however,
no where during all of these activities can anyone prove that I have acted irrationally or insane, the
truth to my actions are well recorded, however the massive attack on my mental condition is proven
to be centered around lies and hearsay.
Any help pertaining to these matters, no matter how small, will be greatly appreciated. Please
invoice me accordingly.
The Background.
Ten years ago I had built a financial firm, Financial Management Group, Ltd., (FMG). In 1985 I
had conducted a marketing study that included interviewing more than 5 local physicians, all of
substantial wealth or income. I had merely described my strategic plan for FMG, and they gave
me feedback, all positive and enthusiastic. In 1986 I incorporated 11 different corporations, all
under the ownership of FMG. To attract local talent, FMG was owned by not only the 3 principals,
but stock was offered to every professional in the organization, including satellite offices. I had
raised approximately $400,000 of capital to start the company, and I did it in compliance of the PA
SEC Rule 144 Regulation D public offering.
In one year, we had phenomenal growth. By June of 1987 we had invested approximately $50
million of client funds. We provided relatively most of the financial services necessary during ones
lifetime. On the streets our organization was worth approximately $4 million, which is strictly
correlated to the commissions paid out. We had at least 10 satellite offices, and covered 5 states.
We also owned an interest in the PSG Broker Dealer, which was worth another $1.5 million.
I was Executive Vice President and Secretary of FMG. I was President and Secretary of FMG
Advisory, which was our Registered Investment Advisor (RIA). I had been pushing through the
approval process with the Pennsylvania Securities and Exchange Commission for more than 6
months, concerning the RIA.
In early 1987 I had developed a mortgage banking operation. I had negotiated with a large
Southwestern mortgage firm to provide mortgages for Eastern Pennsylvania. Our lending capacity
ranged from a minimum of $3 million and as high as $100 million. Even more important was the
fact that this lending capacity was very and sometimes more competitive than other area lending
institutions, I had shortly developed a very large list of clients for whom I was trying to secure
financing for various types of projects.
Combining the mortgage banking services with the ability of FMG to secure financing through
equity investment programs, I was very attractive the real estate community that had deals to
finance. My second cousin, in Houston, TX, provided me with this opportunity. In the mater of 2
months, we had met not only with several large local developers, I had also begun business with

Page 625 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
64
64 of
of308
456
454
November 23, 1997

June
June 14, 2016
Page 3
companies located in more than 5 other states. I had provided a commitment letter for $5 million
mortgage for Norris Boyd, of Boyd Wilson, for the Village of Old Hickory. Norris Boyd had
personally informed me that I had a better deal than the Commonwealth National Bank (who will
later illegally reposes my airplane), where the loan was currently secured.
In February of 1987, because of our ability to raise capital, Scott Robertson requested that I assist
him in visiting Power Station Studio, who was trying to secure financing for a movie. Reluctantly,
due to the risk involved with motion picture investments, I went to Power Station Studios, in
Manhattan. Tony Bongiovi built Power Station Studios to be among of an elite few. The names of
stars that recorded there was very impressive. Tony also produced the sound track for Star Wars,
which was very profitable, and still is. Another project, although controversial, was his cousin, Jon
Bon Jovi. Power Station is where Jon Bon Jovi began his amazing career, under early development
of Tony, his cousin. Contractual disputes ruined the relationship, which put large sums of money to
risk. Jon Bon Jovi is one of the leading all time musicians, in terms of revenues.
Tony described his project, which was not merely just a movie. Tony wanted to develop the first
Digital Movie. Given my thirst for technology, along with a demonstrated knowledge, I became
infatuated with the concept, the concept of providing the highest quality of sound, along with the
highest quality of video. I had researched the merits of the technology, which complimented my
own vision, and found a tremendously feasible project, one which would have the potential to have
a major impact into the film and video industries. I had always personally believed that sound was
as important as the picture for the truest sense of entertainment. The following documents will
demonstrate my investment into this technology, along with my keen sense of perception. Today
we call this Direct Broadcast Satellite DSS, which is currently causing the cable industry great
pains. The consequences of digital technologies to the world of information is what now gives us
the Information Highway, and all of its peripheral components.
The following documents will easily confirm my interests to the preceding three businesses, FMG,
the mortgage banking operation, and the Digital Movie project.
The relationship to my partners was less than amicable. In developing FMG I agreed to let Mr.
Robert Kauffman (Kauffman) act as President, upon the condition that we each own the same
amount of stock. Mr. Michael Hartlett (Hartlett) did contribute to the early development of FMG.
Since Kauffman could not control me, Kauffman and Hartlett would of attempt to buy me out, well
after I created and incurred the most risk, and after the proven success of the organization. In the
Spring of 1987, I had to personally take control of the Board of Directors to undue a merger that
presented great risk to the company, and my investment. As part of our strategic plan, we agreed
to purchase an interest in a Broker Dealer, rather than spending the capital and human resources in
which it would require. I had personally traveled to Washington D.C., to visit this company, which
was Kauffmans idea, and I literally found an empty shell. I found offices full of empty cartons,
empy file cabinets, and this was the company that was responsible for processing all of the
securities business that our brokers transact. This process was vital to our organization.
I immediately flew to Atlanta, GA, to visit another company, PSC, which had been courting our
company for a relationship for almost a year. It was a company that provided technology, service,
affiliates which accounted for several of the past presidents International Association for Financial
Planners, of which I served as Vice President the Central Pennsylvania Chapter. (This association
provided me with the national exposure to develop FMG.)

Page 626 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
65
65 of
of308
456
454
November 23, 1997

June
June 14, 2016
Page 4
In May of 1987, while traveling to a conference in Palm Springs, CA, the FMG Board of Directors
approve the merger of PSG, I had voted via telephone from an airport in Chicago.
The would be the last time that I would vote at an FMG Board of Directors meeting.
This is when I loose virtually everything that is vital to a businessman, my assets, excellent credit
rating and my spotless reputation, my professional designations and licenses, the opportunity to
continue the vast business opportunities that I have developed, and most painfully, my dignity --all without merit or reasonable cause.
June 23, 1987
10:30 am. I have a schedule meeting with Mr. Larry Resch and Mr. Carl Jacobson, both of
International Signal & Control, (ISC) and United Chem Con. The meeting was to discuss
different financial deals. Upon arriving, Mr. Resch disclosed to me that they had to fly Carl
out of the country this morning, he will not be here.
I remember that there was a lot of names and places, all over the world, that mentioned.
During our discussions, I had become annoyed at something, so I began making assertions
that ISC and Mr. James Guerin was involved with fraudulent activities. I further described
some of those activities.
I did not know that Mr. Resch was as close to Mr. James Guerin as you could get.
At approximately 3:00 that same afternoon, I had Russell Locksmith company change the
locks to my office door. Between my partners and ISC, I apparently became concerned.
2 Days later, on June 25th, via telephone, Mr. Kauffman carelessly reported that 2 stock
certificates were issued, without my authorization.
First, I, acting as Secretary ,I must authorize and issue stock certificates, in accordance to the
Articles of Incorporation.
Secondly, Kauffman and company must have burglarized my office to gain access to the
corporate records, which were under my custody, as defined in the Articles.
Several days later, during the night, I had went into my office and removed all of my files, and
upon finding a forged stock certificate with another Board of Director signing as myself and
as Secretary, which violated several bylaws of the Articles of Incorporation.
The next day I went to Mr. Joseph Rodas office, who advised me to return all of the
corporate files, and essentially suggested to go home and get some rest. Mr. Roda would later
represent Mr. William Clark, corporate legal counsel for ISC against Mr. James Guerin in
contract dispute for several million dollars.

Page 627 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
66
66 of
of308
456
454
November 23, 1997

June
June 14, 2016
Page 5
That afternoon, I loaded all of my files into my airplane, to transport to Stone Harbor NJ,
where I was renting another house for the Digital Movie project. I had secured pilots from
Romar Aviation to transport the files early the next morning. I had driven to New Jersey that
evening.
That next morning, the pilot that I had hired to fly my plane, telephoned me and informed me
that my plane was repossessed and locked in a hanger, and he would not be able to deliver my
files.
Those files were the only means of substantiating the truth in order to protect myself from
whatever was happening.
My first payment was not due for another month. In short, I finally found a pilot at the Cape
May Airport to fly to Lancaster and get my files. He returned hours later with my files, and
would only mention some incident involving a gun. Later I would be told that he died a
mysterious death the next month.
Not knowing that Commonwealth National Bank, the same bank that I was about to transfer
$5 Million mortgage to my mortgage operations, had actually repossessed my titled airplane
for reasons that are purely fabricated, and conveniently with all of my files.
This will be the end of my life as I know it, I had demonstrated success, my reputation was
exemplified in my ability to develop FMG, and my credit was flawless. I in the following
months, I will suspiciously loose everything, including; my assets, my business interests, my
reputation, my credit, and the most valuable of all, my opportunity; and ultimately, my
dignity. In reality, I was never even given the chance to fail.
I will contend, and prove, that all of the actions, were without merit and many of which were
fraudulent themselves, and I know that I can substantiate that statement.
According the Articles of Incorporation, I was never legally removed as Secretary, or any
other official duties. Because, there cant be a Board of Directors Meeting without me, the
Secretary. The record in the preliminary hearing transcript clearly proves that there was no
legal Board of Directors Meeting that removed me.
I never resigned from any positions or official duties of FMG, nor was I ever officially and
legally removed from the same.
I was a Tenant, with a $500,000 personal guarantee attached to the lease of FMG, Ltd.
The forgery of stock certificates violated the bylaws of the Articles of Incorporation, thus , as
Secretary, my duties were to safeguard the corporate records.
The evidence indicates that all of the arrests were fabricated, the airplane repossession was
illegal, and all of the allegations of insanity were malicious.
In September of 1987, in the Report to the Board of Directors of Ferranti International,
raised a question of substantial risk, unlike that of which Ferranti was acustomed. The report

Page 628 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
67
67 of
of308
456
454
November 23, 1997

June
June 14, 2016
Page 6
cautioned any alliance due to the related CIA activities connected to ISC, and the lack of
stability of the customers (Iraq?). At that same time, I was making public allegations
against ISC. My conversations posed considerable risk to those connected with the pending
deal with Farranti.
I was the only person protecting the interests of Financial Management Group, Ltd., I was the
only person protecting my interests in the Digital Movie, I was the only person protecting
my assets, I was the only person defending my actions, I was the only person that never
committed a crime, and unfortunately, regarding ISC and Arms to Iraq, I was the only
person protecting my country.
As it turns out, I was instinctively accurate about the evolution of digital technologies, I was
first person to identify the ISC fraud, the largest in the history of the United States, and I was
one of the few persons that has done absolutely nothing wrong, in any sense.
I Remain,
Stan J. Caterbone

Page 629 of 2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePage
Brown
68 of 456

June 14, 2016
Letter to Matt Samley of Xakellis Reese & Pugh re ISC Opinion and Invoice
Stan J. Caterbone
220 Stone Hill Road
Conestoga, PA 17516
April 7, 1998
Mr. Matt Samley
Xakellis, Reese & Pugh
129 East Orange Street
Lancaster, PA 17603
Re: Outstanding Invoice
Dear Mr. Samley:
I refute payment of the above mentioned invoice for the following reasons:
1. Reasonable Time As Promised. On or about November 24, 1997, we had a
telephone conversation while at my office of Pflumm Contractors, Inc., when
you had offered to update your progress on my request for a legal opinion
relating to the matters described herein. You had indicated that you were
busy, and that I would have a letter soon. I had stated that I was in no
immediate need, as long as it was within a reasonable amount of time. You
had promised me that it would be forthcoming immediately following the
Christmas Holidays. And I agreed with that time schedule.
I received the document on February 28, 1998, some 50 or so days after your
promised time schedule, and by your own accounting of my billing hours, it
took you approximately 60 days to complete the last 40 minutes of your
efforts.
This certainly does not constitute reasonable, as you had promised, and raises
questions as to your good faith efforts regarding my issues. Furthermore, I had
never had any conversations with you pertaining to these matters since that
conversation on or about November 24th, which you had an ethical obligation
to notify me if you were not able to deliver your opinion as promised.
2. Conflict of Interest. Immediately following my departure of Pflumm

Contractors, Inc., on February 20th, 1998 and my sworn statement to the PA
Unemployment Compensation Review Board, given the fact that you
represent David Pflumm and Pflumm Contractors, Inc., constitutes a conflict
of interest by most if not all of your Professional Code of Ethics . The fact
that you have conveniently delivered your legal opinion immediately
Page 1 of 2
April 7, 1998

Page 630 of 2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePage
Brown
69 of 456

June 14, 2016
Letter to Matt Samley of Xakellis Reese & Pugh re ISC Opinion and Invoice
following my departure of February 20th, certainly raises some questions as

to the timing of your legal opinion, which is dated February 26th.
3. The Legal Opinion. The following paragraph will serve my purpose,

Regarding the arrest and subsequent prison term, that should have been dealt
with through the appellate process and Post-Conviction Relief Act process and
frankly I do not see anything here at this time that could be done regarding and
arrest ten years ago and that time was served. To expunge a record now would
probably be beyond the statute of limitations for doing so. Finally, even it it
were possible, the fact that this presumably went to a jury and the jury found you
guilty seemed to indicate that at least based on the evidence provided, the jury
had some belief to find you guilty of what you were bound over for trial for.
Where on Gods earth did you find any information to insinuate that I was ever
convicted of any crime. Thank you, you have just proven my point. That
preceding statement, given the wealth of information that you have in your
possession, substantiates the fundamental foundation of the legal issues that I am
questioning, which undermines the framework of my civil, constitutional, and
shareholder rights.
I request that you immediately return all of my documents, and attest that no
copies of both paper and or audio have been retained by you or by Xakellis,
Reese & Pugh.
I remain,
Stan J. Caterbone
cc: Samleyfile
Page 2 of 2
April 7, 1998

Page 631 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
70
68
68 of
of308
456
454

June
June 14, 2016
P
usps.com
Mailed from 17603

062S0000000315
Commercial Base Pricing
Click-N-Ship
1 lb 0 oz
9407 8036 9930 0017 7880 05 0075 0001 0040 5671

$7.50
US POSTAGE
Flat Rate Env

Signature
Confirmation
07/25/15
0006
C000
PRIORITY MAIL 3-DAY
STAN CATERBONE
AMG
1250 FREMONT ST
SIGNATURE REQUIRED
SHIP
WATERBURY VT 05671-9800
TO: CHRISTINA RAINVILLE

AGENCY OF HUMAN SERVICES
103 S MAIN ST
USPS SIGNATURE TRACKING #
9407 8036 9930 0017 7880 05
Cut on dotted line.
Instructions
the package.
Signature Confirmation / Insurance Number:
9407 8036 9930 0017 7880 05

Trans. #:
Print Date:
Ship Date:
Expected
Delivery Date:
Insured Value:
From:

To:

343261455
07/25/2015
07/25/2015
07/28/2015
$50.00

Insurance Fee
Signature Confirmation
(Electronic Rate)
Total
$5.05
$0.00
$2.45
$7.50
STAN CATERBONE
AMG
1250 FREMONT ST
CHRISTINA RAINVILLE
AGENCY OF HUMAN SERVICES
103 S MAIN ST
WATERBURY VT 05671-9800
* Commercial Base Pricing Priority Mail rates apply. There is no fee for USPS
Tracking service on Priority Mail service with use of this electronic rate shipping
label. Refunds for unused postage paid labels can be requested online 30 days from
the print date.

Page 632 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
71
69
69 of
of308
456
454

June
June 14, 2016
EXAMINATION UNDER OATH OF

STANLEY J. CATERBONE
TAKEN BY:
ALLSTATE INSURANCE COMPANY
BEFORE:
DIANE F. FOLTZ, RMR

NOTARY PUBLIC
DATE:
JUNE 9, 2016, 9:15 A.M.
PLACE:
LANCASTER COUNTY BAR

ASSOCIATION
28 EAST ORANGE STREET
LANCASTER, PENNSYLVANIA
APPEARANCES:
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN
BY: CHRISTOPHER M. REESER, ESQUIRE
FOR - ALLSTATE INSURANCE COMPANY
Stan J. Caterbone Under Oath
Page 1 of 51
June 9, 2016

Page 633 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
72
70
70 of
of308
456
454

June
June 14, 2016
WITNESSES
NAME
BY: MR. REESER
EXAMINATION
5
6
7
8
9
10
11
12
EXHIBITS
13
14
CATERBONE EXHIBIT
15
1.
PRODUCED AND MARKED
LIST OF ITEMS
13
16
17
18
19
20
21
22
23
24
25
Page 2 of 51
June 9, 2016

Page 634 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
73
71
71 of
of308
456
454
1
2
STANLEY J. CATERBONE, called as a witness, being

duly sworn, testified as follows:
3
4

June
June 14, 2016
EXAMINATION
BY MR. REESER:
Could you state your name, please?
Stanley J. Caterbone, C-a-t-e-r-b-o-n-e.
Would you mind if I called you Stan or Stanley?
Stan.
Stan, okay.
10
And my name's Chris Reeser.
You can
call me Chris.
11
All right.
12
I'm not a real formal guy.
I have been asked to
13
take a statement from you relative to an insurance claim
14
which I understood to have occurred as a result of
15
something on April 3rd of 2016, but by some correspondence
16
that I received from you, my understanding is that is not
17
the date of loss.
18
19
No.
That date is the date that I started the
spreadsheet --
20
Okay.
21
-- of the items lost or vandalized.
22
All right.
This statement is part of the process
23
of collecting information and evaluating the claim.
24
Allstate's policy, as does just about any insurance
25
company's policy, provides that part of the duty of an
Page 3 of 51
June 9, 2016

Page 635 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
74
72
72 of
of308
456
454

June
June 14, 2016
insured is to give an examination under oath --
Okay.
-- at the request of the insured -- at the
request of the insurer, so that is what this is.
I've had --
Go ahead.
I've had -- I've collected on two or three
Go ahead.
policies with the same types of claims, and I've never been
put under oath --
10
Okay.
11
-- on the record.
12
So noted.
13
Okay.
14
And I'll ask you about that.
15
And I don't mind under oath.
16
All right.
17
I just, you know --
18
All right.
19
-- have never experienced it.
20
Okay.
22
Sure.
23
This is part of what the insurer is allowed to
21
24
25
Well --
Well, a first time for everything.
This
is --
ask of their insured.

A
Oh, I don't mind at all.
Page 4 of 51
June 9, 2016

Page 636 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
75
73
73 of
of308
456
454
1
2
Okay.
Great.

June
June 14, 2016
So I'm going to ask you some
questions about that.
Okay.
I usually when I take these statements -- and
I've taken a couple of them -- have some information about
the claim.
claim.
Okay.
So --
10
Can I give you a brief history --
11
Go.
12
-- to put it in perspective?
13
Yeah.
14
I am a federal whistleblower.
I have very little information about this
Go.
I blew the whistle
15
on International Signal Control or ISC in 1987.
16
indicted in 1991 for a billion dollar fraud and selling
17
illegal arms to Iraq.
18
1987 they --
19
I'm sorry.
20
Yes.
21
operations.
22
Okay.
23
Now, since -- I've been trying to get into
They were
Now, I was a shareholder, and in
You were a shareholder in ISC?
They solicited me to finance some
So I'm a legitimate, bona fide whistleblower.
24
courts, hired various attorneys from '87 all the way up.
25
In 2005 I entered the federal court system as a pro se
Page 5 of 51
June 9, 2016

Page 637 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
76
74
74 of
of308
456
454
litigant.

June
June 14, 2016
I filed my own claims.
Okay.
Okay.
Now, here's what happened.
I became a
victim of organized stalking, electronic harassment or mind
control technologies.
show you some expert testimony -- is that what they do is
they break into your home, vandalize, steal, move things
around.
policies making the same types of claims.
Now, what happens is -- and I'll
And since '05 I've collected on two or three
10
losses are not a single-day loss.
11
period of time.
Now, these
They happen over a
12
Okay.
13
And I can't give you dates as far as when what
14
was taken, when that was taken, but that's just a
15
background for your reference as far as this is not an
16
ordinary claim.
17
When you say they, who is they?
18
Well, I don't know, you know.
19
say.
20
be agents.
21
It could be neighbors.
It's impossible to
It could be police.
It could be anybody.
But you believe that they are all in conspiracy
22
to punish you because of your activity as a federal
23
whistleblower?
24
25
A
that.
It could
I'm going to refer you to documents to explain

As a victim of electronic harassment and gang
Page 6 of 51
June 9, 2016

Page 638 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
77
75
75 of
of308
456
454

June
June 14, 2016
stalking, the victim -- part of the victimization is that
they break into your home.
Okay.
But you don't know who the they is?
Well, of course not.
Have you ever seen anybody in the act?
I have one person on a security camera video.
Okay.
That was in 2006.
And was there an insurance claim related to that?
10
Not to that particular person, no.
11
All right.
12
But there was a claim that year.
Harleysville
13
paid me once or twice, and there was another one.
14
unfortunately I'm also the victim of computer hacking.
15
These are all the reports from the past year on Geek Squad
16
and other companies reviewing and analyzing and fixing my
17
hard drives after they've been hacked.
But
18
Okay.
19
I filed about, oh, boy, since '06 or '07 probably
20
about four or five IC3 reports with the FBI.
21
I don't know what an IC3 report is.
22
It's an online complaint regarding anything
23
fraudulent online to the FBI.
24
Okay.
25
I've had face-to-face meetings with the FBI
Page 7 of 51
June 9, 2016

Page 639 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
78
76
76 of
of308
456
454

June
June 14, 2016
probably about 15 times.
Locally?
Philly and Harrisburg.
Is there a particular agent that you meet with?
No.
Could you tell me the names of any of the agents
No.
that you meet with?
No.
Okay.
10
I can verify the meetings, I mean.
11
What -- what's the reason for the meetings?
12
Complaints --
13
Okay.
14
-- about people, what they're doing to me.
15
You said you're a victim of electronic
16
harassment.
17
Okay.
18
What have been the other forms?
19
They use microwave technology, microwaves to
Now, I understand what computer hacking is.

Electronic harassment.
20
alter your brain state.
21
cause extreme pain in any part of your body.
22
create synthetic telepathy.
23
with the weapons.
24
25
It causes extreme -- they can

They can
They can essentially kill you
Now, in the 1950's the Russians used it against

our -- the U.S. Embassy in Moscow, the same weapons.
Page 8 of 51
Now,
June 9, 2016

Page 640 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
79
77
77 of
of308
456
454

June
June 14, 2016
in the 1970's there was what's called the Church Committee.
The CIA had to come clean on these programs.
supposed to have stopped them, but they didn't, and that's
-- there's Senate testimony.
then was Stansfield Turner.
Senate, and they admitted to all the programs that I'm
describing.
Okay.
MKUltra was the main program.
10
How do you know that?
11
How do I know what?
12
I mean, how do you know you're a victim of
13
The Director of the CIA back

He testified before the
microwave technology to alter your brain waves?
14
15
They were
Some nights I can't walk.
The pain is that bad.
What do you mean how do I know?
16
I mean, I don't know.
17
Don't get smart with me, or I'll walk out this
I don't know.
18
door.
19
20
I'm not being smart.
I'm trying
to understand this.
21
Okay.
22
How do I -- you know, how do I know I'm not?
23
Do you ever complain about it?
24
I mean, I have pain.
25
pain.
I don't know why I have
I just -- I'm trying to understand.
Page 9 of 51
June 9, 2016

Page 641 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
80
78
78 of
of308
456
454

June
June 14, 2016
10
Listen, yesterday I filed 300 pages in the
Pennsylvania Supreme Court on a case against Lancaster City
Police and the county residents.
Okay.
There are -- there is expert testimony in here
from, one, an NSA whistleblower named Karen Stewart who
will back up just about everything I say.
from a Julianne McKinney who is a former Army intelligence
officer.
The second is
The third is from a renowned expert named Nick
10
Begich whose father was killed by someone in the Hoover
11
Administration.
12
read them.
There are transcripts in here.
You can
13
Okay.
14
You can learn all about it.
15
May I have this?
16
No.
17
Okay.
18
Or I can give you it in electronic format.
19
20
21
22
23
You can make a copy.
have a PDF around my neck.

Q
I'll give you a copy.
Well, I see that it's a Petition for Allowance of
Appeal which means that it's -A
I'm appealing a Superior Court decision to the
Pennsylvania Supreme Court.
24
Okay.
25
I'm a very successful litigator by the way.
Page 10 of 51
June 9, 2016

Page 642 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
81
79
79 of
of308
456
454

June
June 14, 2016
11
How --
I'm the amicus for Kathleen Kane in her criminal
case in the Superior Court in Philadelphia.
movant for Lisa Michelle Lambert.
I'm also the
Okay.
I've got three Third Circuit cases now that are
7
8
9
10
awaiting decisions.
Q
And this is an appeal from the Lancaster County
Court of Common Pleas.
I assume it went then to the
Superior Court?
11
I took it to the Superior Court, right.
12
Okay.
13
They dismissed it --
14
Okay.
15
-- two weeks before oral arguments.
16
And what happened there?
Oral
arguments were scheduled for May 24th.
17
Okay.
18
They were scheduled since January.
Both cases
19
were arguably -- I mean, maliciously dismissed two weeks
20
before oral arguments.
21
before them.
22
23
Okay.
They didn't want me to appear
Give me some background.
you worked -- maybe I misheard you.
24
No.
25
Okay.
I mean, you said
Did you work for ISC?
You were a stockholder?
Page 11 of 51
June 9, 2016

Page 643 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
82
80
80 of
of308
456
454

June
June 14, 2016
12
Yes.
Okay.
He was a stockbroker back then.
he is?
Gib Armstrong sold me the stock in 1983.
Do you know who
Former Pennsylvania Senator.

Yeah, I'm familiar with the name.
Are you
employed right now?
No, I'm -- I collect Social Security disability
for symptoms and illnesses related to U.S. mind control,
documented, verified.
10
Huh.
11
They've been paying me since '08.
12
Okay.
13
for that?
Do they -- do they pay you by the month
Is it --
14
You never heard of Social Security disability?
15
I have.
16
Yeah.
17
Okay.
18
My first check was for $21,000.
They paid me.
19
applied in '09.
20
'05 when I declared I was full-time telepathic, but they
21
could only pay me back one year.
22
to '09 in one check, and then I've been getting monthly
23
checks ever since.
24
25
Okay.
They declared me disabled in December of
So they paid me back '08
Well, let's talk about this claim a little
bit.
Page 12 of 51
June 9, 2016

Page 644 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
83
81
81 of
of308
456
454

June
June 14, 2016
13
Okay.
I'm going to have this marked as Exhibit 1.
I have a new one here.
Okay.
Well, why don't you -- why don't we mark
-- can I take that, or do you need that?
Yeah.
No.
Okay.
We won't mark the one I have.
Here.
That's updated.
MR. REESER:
Do you want to put a sticker
(List of items produced and marked Exhibit No.
13
1.)
14
BY MR. REESER:
16
Okay.
on there?
12
15
Every day I have stuff
missing.
10
11
This is for you.
All right.
Now, I'm just going to go through
these items that you have --
17
Yeah.
18
-- listed in order from top to bottom.
19
You're
making a claim for a dishwasher?
20
Right.
21
Is this a dishwasher that was in your home?
22
Yeah, but you know -- I'm trying to think what
23
year that was actually broken.
24
Scratch the dishwasher off of that.
25
That might predate this.
The dishwasher is not being claimed, correct?
Page 13 of 51
June 9, 2016

Page 645 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
84
82
82 of
of308
456
454
Yes.
All right.

June
June 14, 2016
14
Yes, let's take that off.

And I should ask you this beforehand.
I kind of lost track.
Your brief or your petition that was
filed to the Supreme Court listed an address of 1250
Freemont Street.
That's -- that's your home address?
Yes.
Okay.
No.
All right.
10
In fact, I sent a copy of the deed in with the
11
claim.
12
13
Does anybody else live there with you?
I believe I saw that, which I think there were a
number of grantees.
14
My brothers.
15
Okay.
16
No.
17
And they wouldn't be insured under the Allstate
18
But none of them live there?
policy?
19
Yeah, they're listed as other insureds.
20
Okay.
21
Yeah.
22
Okay.
23
Do any of these items -- are they owners
of any of the items?
24
No.
25
Okay.
I purchased the policy for everybody.

Front and back door locks?
Page 14 of 51
June 9, 2016

Page 646 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
85
83
83 of
of308
456
454
Right.
Tell me about that.
Okay.

June
June 14, 2016
15
In July of 2015 -- yeah, July, 2015, the
benevolent Lancaster City Police Department served me with
a 302 petition, but what they did was they broke into my
house, smashed in the front door.
to pay for all the locks and the door, but they didn't.
8
9
10
Now, they were supposed
So I had to get a new front door, and I had to

get all the locks changed in the front and back door,
rekeyed.
11
Okay.
12
Mental health warrant.
13
All right.
14
I've had about eight of them.
15
do.
302 petition?
That's what they
That's part of the slander campaign.
16
What do they --
17
That's pretty routine.
18
What do they claim?
19
Well, I'm mentally ill.
20
Okay.
21
That's their -- that's their defense.
22
Is there a form of mental illness that they try
23
I make all this up.
to pin on you?
24
Oh, yeah.
25
What?
Page 15 of 51
June 9, 2016

Page 647 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
86
84
84 of
of308
456
454

June
June 14, 2016
16
Which one do you want?
Oh, there's been more than one?
Bipolar, schizophrenic, delusional disorder, you
4
5
6
What year?
name it.
Q
Okay.
Were you hospitalized or
institutionalized --
Oh, yeah.
-- as a result -- as a result of this one, the
one in July?
10
Oh, yeah, Fairmont.
11
For how long?
12
Oh, that was about five -- eight days, I guess.
13
And how did that end?
14
They always -- they give me a hearing.
15
Then they
have to release me.
16
Okay.
17
They're always pretty much the same.
It started
18
in '87.
19
Harbor Beach Patrol.
20
was making a movie with Tony Bongiovi who owns Power
21
Station Studios, one of the world's most famous recording
22
studios.
23
The first one was was somebody called up the Stone

My resume's in there.
In 1987 we're making a movie.
24
for an office down in Stone Harbor.
25
the movie in New Jersey on the boardwalk.
Page 16 of 51
But in 1987 I
I rented a home
We were going to shoot

Somebody called
June 9, 2016

Page 648 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
87
85
85 of
of308
456
454

June
June 14, 2016
17
the Stone Harbor Police Department and said I was running
to the beach to kill myself, totally made up, fabricated.
That's how it all started with the mental illness.
Okay.
Okay.
Smashed in your front door?
Oh, yeah, with -- like a drug raid.
So going back to the door for a second --
I stood
there and took pictures of them as they came through.
Do you actually have the pictures?
10
Oh, yeah, it's part of it.
11
Part of?
12
The -- they're in here.
Oh, let me see.
Where
13
are they?
14
are black and white.
15
pages.
16
only reason you could do that is if someone -- is if you
17
knew that someone was in there with a gun to their head.
18
was in -- I was in the upstairs window talking to them
19
trying to get them to get away from me quite honestly.
No, they're in this one.
This one.
No.
These
They're hard to see, but the next two
Totally illegal what they did.
The only way, the
20
Okay.
21
I filed a lawsuit against Lancaster City Police
22
in '08.
23
one of the documents I have here.
It's a federal lawsuit.
In fact, that's part of
24
Is that still ongoing?
25
I withdrew without prejudice because of the
Page 17 of 51
June 9, 2016

Page 649 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
88
86
86 of
of308
456
454

June
June 14, 2016
18
computer hacking, so I can re-file, go back to it any time
I want.
Okay.
Most of my lawsuits I withdrew without prejudice.
5
6
I just couldn't litigate with all the hacking.

Q
Can -- do you have any photographs that show the
damage to the door?
see a police officer --
I mean, I see a door that's open.
Yeah.
10
-- apparently standing there.
11
Yeah.
12
Okay.
13
In fact, I bought the door at the Habitat reuse
Yeah, I do.
14
it store.
15
to change all the locks.
But what happened was they charged me like $400

Wizard Lock did it.
16
Do you have -- do you have the receipt for that?
17
Yeah, I could dig that up.
18
You don't have it with you right now?
19
No.
20
You bought the door -- I'm sorry -- Habitat?
21
For Humanity.
22
Habitat?
23
Habitat for Humanity.
24
Oh, Habitat for Humanity.
25
The reuse it store.
I'm a little hard of hearing.
Page 18 of 51
June 9, 2016

Page 650 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
89
87
87 of
of308
456
454

June
June 14, 2016
19
Reuse it.
Out on Old Philadelphia Pike back behind
Greenfield.
door than was on there.
The door looks brand new, I mean, a better
The door, the replacement door you bought there?
Yeah.
What about the original door, was that -- had
8
9
that been there for years?

A
No, that was done in 1996.
My mother was part of
10
the Lancaster City Homeowners Rehab or Revitalization or
11
Rehab Program where if you qualify, they'll come in and
12
rehab your home, bring it up to code and put a seven-year
13
lien on your house for the cost of the improvements.
14
year 10 -- 10 or 15 percent comes off, so if you stay in
15
the house for 7 years, it's all free.
16
I see.
17
So the doors are part of that.
18
Okay.
19
'96 at the time.
20
And you may have said this.
21
didn't get it.
22
that -- the replacement door?
23
$20.
24
$20?
25
Yes.
Each
I apologize if I
How much did you actually pay for the door
Page 19 of 51
June 9, 2016

Page 651 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
90
88
88 of
of308
456
454

June
June 14, 2016
20
But it cost you 400 to get the locks replaced?
Yeah.
And that was done again by?
Wizard.
Wizard.
Locks.
And you can get me the receipt?
Yeah.
And my question about that was going to be did
Yeah.
10
you report this to the police, but I guess given the
11
circumstances --
12
Here's the situation.
I've -- I've been
13
reporting to the police ever since it started, but usually
14
they're part of the program.
15
complaints.
16
to sue them.
17
Okay.
18
I have letters which are a part of the documents
They won't take my
I mean, I had to sue them.
That's why I had
19
going to the police explaining the vandalism and the
20
break-ins that they won't, you know, report on or
21
investigate or...
22
And this happened July of '15?
23
July 8th, I think, yeah, 2015.
24
July 8th, 2015, okay.
25
Was there any other damage
done, physical damage to your house done --
Page 20 of 51
June 9, 2016

Page 652 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
91
89
89 of
of308
456
454

June
June 14, 2016
21
No.
-- as a result of that incident?
Just the door.
Okay.
5
6
The next one I have on your list is an
Apple Video iPod.

A
Right.
What they did was I can't -- the menu
button doesn't work.
'05 or '06.
Okay.
10
I since bought a replacement for it.
11
All right.
12
Now, that iPod I bought back in 2006,
You bought -- this particular Apple
Video iPod you bought in '05 or '06?
13
Yeah.
14
Where did you buy it at?
15
I might have bought it at a Best Buy in Florida.
16
Okay.
17
Boy, 3, $400 probably.
18
Okay.
19
It's when they first came out, so the video iPods
20
Do you remember what you paid for it?
And then when did you --
were expensive.
21
Yeah.
22
No.
23
-- just an iPod?
24
Right, video iPod.
25
And then you noticed a problem with it when?
This wasn't an iPhone.
Page 21 of 51
This was --
June 9, 2016

Page 653 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
92
90
90 of
of308
456
454
1
2

June
June 14, 2016
22
The button, you can't push the button, the main
button.
Okay.
Oh, boy.
fall of '15.
Okay.
No.
-- Best Buy or a repair store?
No, you can't.
10
Why not?
11
Why?
12
I mean, if I had a problem with my iPhone and
14
I'm not going to pay to get it fixed.
15
Okay.
16
I bought a replacement.
17
Okay.
13
18
19
20
21
22
23
When did you discover that?

Let me think.
That was probably in the
Did you take it to --
No.
No.
I --
Why is that -- I'm not -- I don't
understand why that's part of the insurance claim.

A
Because it was in my house and the house is
covered by the insurance.

Q
I mean, how do you know it just didn't -- I mean,
things wear down over time.

A
I mean --
I'm telling you the truth.
If you don't believe
24
me, that's fine, but don't -- don't harass me with
25
questions.
Page 22 of 51
June 9, 2016

Page 654 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
93
91
91 of
of308
456
454
1
2
23
I'm here to ask you questions, sir.
I told you what happened.
Okay.
They broke it.
They broke it?
Yes, someone broke it.
All right.
It's funny.
One day the button works, and the
next day it doesn't.
11
Okay.
12
Right.
13
How old --
14
I've had probably three stolen.
15
Oh, it was stolen?
16
Oh, yeah.
17
Okay.
18
I don't remember.
19
20
21
I'm just
trying to get an understanding as to -- things wear out.
10

June
June 14, 2016
or four stolen.
Q
Okay.
Bluetooth headset for phone.
When?
In the past year.
I had three
I had to buy replacements.

Well, you list $60, and that sounds about
what the value of a new Bluetooth would be.
22
Oh, no.
23
Oh, okay.
24
Does it say three beside there?
25
No, it doesn't.
No.
That's for three of them, I think.
Well, no.
Page 23 of 51
It says item number,
June 9, 2016

Page 655 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
94
92
92 of
of308
456
454
but they're consecutive.
not a quantity.

June
June 14, 2016
24
I'm assuming that's not -- that's
Oh, didn't the quantity print out?
that.
Oh, the quantity didn't print out.
be three.
No.
Let me see
That should
All right.
I paid like 20 bucks apiece for them up at Radio
Shack.
Do you have the receipts for them?
10
I'm not going to dig up all these receipts.
11
really not.
12
is harassment.
13
14
Maybe I didn't put the quantity in.
I'm a busy guy.
I'm
I can't be -- you know, this
Does that mean you don't have them, or you're
just not going to -- you're not going to dig them up?
15
I'm not going to take the time to dig them up.
16
Okay.
17
I have all my receipts.
18
back to '80, '82.
19
Okay.
20
I document everything.
21
I have my tax returns
I'm an expert in
information technologies.
22
Where in your house --
23
I have worked all over the world for the record.
24
I did defense contracts, optical publishing.
25
of -- I was one of four companies in the late '80's, early
Page 24 of 51
I was one
June 9, 2016

Page 656 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
95
93
93 of
of308
456
454

June
June 14, 2016
25
'90's that could manufacture CD-ROMs, me alone.
business.
were stolen?
Where did I have them?
Yeah.
It depends where I was.
Where were they stolen from?
Most likely either the bedroom which is in the
10
basement.
Okay.
I know my
Where in your house were the headsets that
In the bedroom, living room?
Yeah, the bedroom.
What do you mean?
Yeah.
11
Was there any sign of unlawful entry?
12
No, never is.
13
about that.
14
15
You'll read, the experts tell you
And I assume there was no report to the police
about these --
16
I can't report to the police anymore.
17
Okay.
Is it fair to say that with regard to any
18
of these items you haven't -- so I don't have to keep
19
asking you this, that you didn't report it to the police?
20
21
They get emails from me, but, no, there's no
official report.
22
All right.
23
The last official report I made was two thousand
24
-- was July 8th of 2015.
25
to report the computer hacking, and that night at 11:30
I went down to the police again
Page 25 of 51
June 9, 2016

Page 657 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
96
94
94 of
of308
456
454

June
June 14, 2016
26
they signed the mental health warrant on me --
Okay.
-- and gave me a bogus incident report.
All right.
The Bluetooth headsets, the three of
them were taken after that?
After what?
After the 302 petition.
Let me think.
Okay.
10
11
12
Yeah.
Yeah.
You don't have any idea who it was who
took them?
A
If I did I'd give you a name and report that to
everybody.
13
Okay.
14
Yes.
The hammer drill.

They broke it.
I'd say March 9th I started
15
my -- I'd say in March, 2016.
16
screened-in porch on my back and a six-foot fence.
17
it worked.
18
buy a replacement.
I'm putting on a new
The next day it didn't.
One day
So I had to go out and
19
How old was it?
20
I bought that one -- that's about the second or
21
third one they broke.
22
probably -- when did I buy that one?
That one I bought on eBay in
23
Do you still have it?
24
No.
25
Did you throw it out?
Page 26 of 51
Maybe '08.
June 9, 2016

Page 658 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
97
95
95 of
of308
456
454
Yeah.
All right.

June
June 14, 2016
27
You didn't take it someplace to see
if it could be fixed?
No.
What did you buy it for, how much?
How much?
How much.
Oh, boy.
9
10
That was a DeWalt.
I don't know -- $300 I think, 280.
New they're like --
I probably paid -- I
think I paid 60 something for that, somewhere around $60 --
11
Okay.
12
-- on eBay.
13
And then did you buy a replacement for it?
14
Yeah.
15
What did that cost?
16
The replacement I bought at -- oh, the tool store
17
out there next to the off-track betting.
18
of it?
19
Harbor Freight?
20
Harbor Freight.
21
drill.
22
Okay.
24
What is it?
25
Maybe 100?
23
What's the name
Harbor Tools.
I paid I think 60 for the hammer
But you have -- you have 100 listed here,
so --
Maybe it was 100.
Page 27 of 51
June 9, 2016

Page 659 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
98
96
96 of
of308
456
454

June
June 14, 2016
28
Maybe.
Okay.
Reciprocating saw.
Yeah.
What they did was they rigged it so that
the blade doesn't stay in.
You can't use it.
It just --
When you turn it on it comes out?
Well, when you use it, it comes out when you're
sawing.
Okay.
You can't -- you can't tighten it.
10
work, but it stopped.
11
I bought that at Lowe's.
12
13
It used to
That replacement I bought -- I think
The one, the one that's broken or the one, the
replacement one?
14
The replacement.
15
Where did you buy the one that's broken?
16
Harbor Tools.
17
Harbor Freight?
18
Harbor Freight.
19
Okay.
20
23
24
25
When did
you buy that?
21
22
Just so we're on the same page.
A
'06.
'05.
Q
Oh, boy.
Let's see.
I might have bought that in
'05, '06.
Okay.
Did you use that on a regular basis or
just once in a while?

A
What do you mean on a regular basis?
Page 28 of 51
June 9, 2016

Page 660 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePager
Page
Brown
99
97
97 of
of308
456
454

June
June 14, 2016
Did you use it once a week?
No.
Okay.
No.
No.
No.
No.
29
Did you use it --
No.
Reciprocating saws I probably used less
than any other tool actually.
I mean, a couple times?
But if I have a project I might use it a lot in a
8
9
10
11
12
two-week span.
Q
Yeah.
I mean, some people are do-it-yourself,
fixer-upper kind of people, and some people -A
Well, I used to have a contracting business in
college.
13
All right.
14
Stan Caterbone Painting and Renovating.
15
But you bought this in '05, '06?
16
assuming --
17
Right.
18
-- you were out of college by then.
19
I'm just saying I have experience.
20
21
22
I mean, I'm
I'm not just
a do-it-yourselfer.
Q
Well, no.
My -- some people do a lot of work
with their tools, and other people --
23
Oh, I do.
24
-- don't.
25
I do.
Page 29 of 51
June 9, 2016

Page 661 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePage
Pager
Page
Brown
100
98
98 of
of308
454
456
1
2
Okay.

June
June 14, 2016
30
And that's what I'm getting at.
I'm
trying to understand.
I do.
I don't.
Okay.
So I could have something for ten years, and it
doesn't get any use at all.
No.
And some people have it --
10
I use my tools.
11
-- for ten years, and they use it every day.
12
I use my stuff.
13
Fair enough.
I understand.
And you got a replacement at
14
Lowe's, and you have $100 here.
15
paid for the replacement?
Is that about what you
16
Uh-huh.
17
Do you have the receipt?
18
Yeah.
19
Okay.
20
Is it fair to say you're not going to dig
that up?
21
No.
22
Okay.
23
I didn't have to for the other claims.
24
25
No.
I'm not going to do that.
I'm not
going to do it for your company.

Q
Okay.
IPhone 5C, was that stolen?
Page 30 of 51
June 9, 2016

Page 662 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor DavePage
Pager
Page
Brown
101
99
99 of
of308
454
456

June
June 14, 2016
31
Broken.
When?
In fact, I got scammed on that, the 5C, the end
of last year.
Here's what happened.
They broke it, right,
so I put it on eBay to sell it so someone could reprogram
it, the software.
broken on it because it functioned, everything, but the
software was not functioning.
I assumed the software was what was
Okay.
So I put it on eBay.
10
They hacked my PayPal account.
So someone said that they
11
paid me with electronic funds.
Well, PayPal doesn't use
12
electronic funds.
13
the money.
Right.
Somebody bought it.
PayPal you use your account to transfer
Right.
14
Like a Visa account?
15
What's that?
16
Or a PayPal account.
17
PayPal account.
18
Okay.
19
So what they did was they filed a claim saying
Oh, a PayPal account.
20
that I never sent them the iPhone.
21
it until I got -- until I verified the money was in my
22
account.
I wasn't going to send
23
Uh-huh.
24
But because my PayPal account was hacked, I
25
couldn't access my PayPal account.
Page 31 of 51
Right.
Now, in my
June 9, 2016

Page 663 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
102
100
100 of
of308
456
454

June
June 14, 2016
32
PayPal account I had a cash balance of like $400.
went and awarded them judgment.
judgment.
So eBay
In eBay terms I'm saying
Uh-huh.
So they took the $150 or whatever selling price
out of my account, so I'm out the phone, plus the $150.
Okay.
So they scammed me.
All my accounts are hacked.
I file -- in all the courts I have electronic filing
10
privileges, Third Circuit, U.S. District Court, all the
11
state courts, the local courts.
12
which is the system where you file electronically --
Right.
My PACER account
13
I'm familiar with PACER.
14
-- I've been hacked since, oh, boy, November.
15
So
I got to run down to Philly every two weeks --
16
Okay.
17
-- to get my dockets, just to get dockets for all
18
19
20
my cases.
Q
Let me go back.
I'm -- you lost me on the phone
at some point.
21
Okay.
22
You had the phone.
23
phone?
24
Right, after it was unusable to me.
25
After it was unusable.
Page 32 of 51
You were looking to sell the
Why was it unusable to
June 9, 2016

Page 664 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
103
101
101 of
of308
456
454
you?

June
June 14, 2016
33
Because there was a software problem?
It just didn't -- it wouldn't function for me.
Okay.
So I replaced it.
of Apple.
How old was the phone?

I went to Samsung.
I got out
I had too many problems with Apple.
How old --
Apple wouldn't fix it.
Apple wouldn't do this.
They were harassing me on every -- I called customer
service about it, and they had harassed me, and I had to
10
report that, so I said the hell with it.
11
Radio Shack, and under Sprint's program they would pay your
12
old phone off if you're on a contract.
13
have a Samsung.
14
15
So I went to
So I went and now I
How old was the phone at the time that you tried
to sell it through eBay?
16
A couple months old.
17
Okay.
18
Five months old I think.
19
Was it under any warranty program with Apple
I had a warranty through Verizon, but I had to
20
21
22
or --
cut them out.
23
I don't follow you.
24
I had to get off of Verizon.
25
Okay.
So the phone wasn't fixable; you tried to
Page 33 of 51
June 9, 2016

Page 665 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
104
102
102 of
of308
456
454

June
June 14, 2016
34
sell it; you got scammed on the PayPal?
Yeah.
And eBay basically ruled against you?
Yeah, I can't even access eBay.
I can't buy
anything on eBay anymore.
Okay.
I'm hacked, every -- all my online accounts.
Okay.
Banking, bank accounts, PayPal, eBay, PACER.
10
filed complaints with the FBI, the Pennsylvania Attorney
11
General's Office, everybody.
12
When did this happen?
13
What happen?
14
The phone, the attempt to sell the phone.
15
I think January.
16
Of this year?
17
Yes, '16.
18
Did you file a complaint with the Attorney
19
I think January.
General's Office or --
20
Oh.
21
About this situation?
22
I file complaints with them all the time.
23
Okay.
24
Like I say, I am the amicus for Kathleen Kane in
25
Superior Court Case 1164 EDA 2016.
Page 34 of 51
I filed an amicus brief
June 9, 2016

Page 666 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
105
103
103 of
of308
456
454

June
June 14, 2016
35
May 3rd, so I'm a party to the case now.
everything to me.
They have to file
Okay.
Service me everything.
And I understand, you know, that process to some
extent, but what does it have to do with this?
it has relevance, I'm all ears.
8
9
A
the NSA.
Okay.
I mean, if
I just don't know.
In 1998 I had a meeting with an agent from
I was complaining again about things, and he told
10
me, he said, listen, Stan.
11
it's the good old boys.
He goes it's not us.
He said
This was in 1998.
12
Now, when Kathleen Kane started in the press,
13
she's been saying that the good old boys are behind her
14
problems.
15
stated for the record what the NSA agent told me about the
16
good old boys and how it relates to what she was saying.
So November 12th I wrote her a letter, and I
17
Uh-huh.
18
She replied back the next day, said she'd keep my
Okay.
19
information on file.
20
month or so ago I'd go up there every two weeks and deliver
21
documents to Strawberry Square to the Attorney General's
22
Office.
Ever since then from November till a
23
Okay.
24
I finally thought, you know what, I'll put screen
25
Tell me about the screen door locks.
door locks on on my screen doors.
Page 35 of 51
June 9, 2016

Page 667 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
106
104
104 of
of308
456
454

June
June 14, 2016
36
Uh-huh.
It didn't stop anything.
They'd work.
Are they still there?
I had to replace one or two of them.
Did you do that yourself?
Oh, yeah.
Do they work now?
Yes.
They'd break them.
They wouldn't work.
Well, supposedly.
I mean, one time they
10
didn't work.
11
Okay.
12
Lowe's.
13
For $30 it looks like?
14
Yeah.
15
Yes.
16
That was within two months ago.
17
Okay.
18
19
Where did you buy the replacements?
Is that what's on there?

Okay.
When did you replace them?
Sleepy's foam mattress.
I'm sorry.
Foam
memory mattress.
A
Here's the situation with that.
On the record,
20
I've been suffering from back pain since '87.
21
say '98 I've been going to the doctors on and off for it.
22
Last year I got a handicapped placard, and in the process I
23
used my medical reports regarding my back.
24
handicapped placard, and I got a long-term placard which
25
means it doesn't renew until 2020.
Page 36 of 51
Since I'd
So I got a
June 9, 2016

Page 668 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
107
105
105 of
of308
456
454

June
June 14, 2016
37
Okay.
Now, what they were doing is that aside from the
electromagnetic weapons, people were using some type of
device to put under my seats and under my bed that causes
excruciating pain.
6
7
Now, since '05 I was going up and getting laser

treatments to Leola Family Health Clinic in Leola.
Did you say Leola?
Yes.
10
Thank you.
11
Now, the doctor there, the chiropractor, he's the
12
one that signed off on my handicapped placard.
13
Okay.
14
He verified that if they -- they could be using
15
magnets.
16
that's what the Sleepy's is for.
It can throw my back out to cause pain.
17
All right.
18
Now, whether -- I mean, well, go ahead.
19
Have you actually found magnets?
21
No.
22
All right.
24
25
You ask
the questions.
20
23
So
You're not sure where they are within
the mattress?
A
I'm not sure.
No, I'm not.
No.
I'm not sure
how they do it, but they used to do it to my bicycle seat,
Page 37 of 51
June 9, 2016

Page 669 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
108
106
106 of
of308
456
454
my car seat, my bed.
Other nights...
3
4

June
June 14, 2016
Now, some nights I'm fine in the bed.
And you know when they're doing it based upon
when you have the pain?
Yes, it's the only way I know.
Okay.
38
What's the nature of your back problem?
Herniated disc, do you have a degenerative condition?
No.
Do you have -- I mean, you're going to a
10
11
12
chiropractor.
A
Is he -- is he treating you for anything?
I was getting laser treatments, but it stopped
being effective.
13
Okay.
14
So now the only treatment really is I'm applying
15
to Medicare.
16
house.
17
medicines.
18
19
I'm trying to get a whirlpool bath put in my
I'm trying to get them to pay for that.
Okay.
And pain
And what's the diagnosis other than -- I
mean, are you -- something other than back pain I presume?
20
I have that in here, I believe.
21
I'm going to get myself some more coffee over
22
there.
23
Water would be good.
24
I assume there's water in that pitcher.
25
Would you like any coffee or water?
If not,
I can go out and get you some.
Page 38 of 51
June 9, 2016

Page 670 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
109
107
107 of
of308
456
454

June
June 14, 2016
39
Let me see what document I have right here.
MR. REESER:
(Off the record.)
THE WITNESS:
with me.
BY MR. REESER:
And off the record.
No, I didn't bring my medical file
Okay.
If I know what?
If you know the answer to that question.
10
What was the question?
11
The question was what's the medical diagnosis?
12
Oh, it's a medical term.
13
That's fine.
14
15
That's all right.
I mean, if you know.
I can't.
If you don't -- if you don't know,
that's fine as well.

A
I went to -- okay.
January 29th medical -- Med
16
Express Urgent Care issued me pain medications.
17
they issued me pain medications, all for back.
18
they issued me pain medications.
19
March 23rd
May 10th
In 2009 I was receiving pain medicines from
20
Dr. Sullivan at the Abbeyville Family Clinic on Abbeyille
21
Road for back pain, severe.
22
a walker some nights.
It gets severe.
I have to use
23
I think you said you went to Leola Chiropractic?
24
Yeah, Leola Family Health Clinic.
25
Family Health
Clinic.
Page 39 of 51
June 9, 2016

Page 671 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
110
108
108 of
of308
456
454
1
2
3
4

June
June 14, 2016
40
That's not a chiropractor.
That's a medical
doctor?
A
No, he's inside there.
It's a -- it's a facility
where they have different doctors.
Okay.
Dr. Newhart, Paul Newhart, he was giving me laser
treatments.
guess it was about laser therapy.
the NFL.
10
I saw an article in the paper in '05 or '06 I

Now they're using it for
But it was effective for a while, and then it
stopped being effective a couple years ago, so I stopped.
11
When did you buy the bed?
12
I bought the bed three months ago.
13
Where did you buy it at?
14
Sleepy's, Manor Shopping Center.
15
Okay.
16
Now, I put the bed on there.
You understand why
17
I put it on there?
18
wouldn't think anything's wrong with it, but I'm putting it
19
on to document just what I'm telling you.
Now, if you went and saw the bed, you
20
Okay.
21
Oh, yeah.
You still use the mattress?

Yeah, because it's a memory foam with
22
a -- it vibrates.
23
the head, the mid-section, and for my back it's great.
It moves in three different positions,
24
Queen size, king size?
25
Full.
Page 40 of 51
June 9, 2016

Page 672 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
111
109
109 of
of308
456
454

June
June 14, 2016
41
Is that smaller than queen?
Yeah, not by much though.
So if you're not having the back issues --
Perfectly normal.
Then it's perfectly -- okay.
Yeah.
All right.
Yeah.
10
Okay.
11
Oh, which ones?
12
How many do you have?
13
How many did I have?
14
And $2,300, is that what you paid for
it?
Laptop computers.
How many are broken?
many's listed on there?
15
There's no number there.
16
Let me see.
17
How
I don't know why those quantities
aren't in there.
18
Yeah.
19
Let me see.
The policy goes -- the policy goes
20
back to '11, so it would have been one, two -- that would
21
be right.
Two.
22
Okay.
23
Two laptops, 400 bucks apiece.
24
right.
25
That's about
What kind of laptops, what brand?
Page 41 of 51
June 9, 2016

Page 673 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
112
110
110 of
of308
456
454
HP.

June
June 14, 2016
42
Oh, boy.
What happened to them?
They just sabotage them.
drives and everything.
usually.
6
7
What was the last one?
Compaq.
They fry the hard
They just fry them.
That's what this document is.
Viruses
It's all in there.
So they've crashed as a result of the viruses?
The hard drives have crashed?
Oh, yeah.
Have you looked into replacing the hard drives?
10
It is -- cost, it's not effective.
Yeah.
It's not --
11
it's not worth it because by the time you pay to do that,
12
it's already outdated technology, so you're going to have
13
an old processor.
14
15
sometimes --
16
You know, it just doesn't --
No, I -- I understand.
The economics of it
So what happened, so in August of last year, the
17
last laptop I replaced, I got a one-year service for Geek
18
Squad.
19
The laptops --
20
Fixing -- fixing the one I have.
21
Okay.
22
I've been in there about 20 times.
These aren't -- the ones that the Geek
Squad's fixing, they're not the HP or the Compaq?
23
Oh, no.
24
Okay.
25
That's a Lenovo I have now.
No.
Page 42 of 51
June 9, 2016

Page 674 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
113
111
111 of
of308
456
454

June
June 14, 2016
43
The HP and the Compaq, how old were those?
Within a year, a year old.
When did they crash?
Well, the last one crashed August of 2015.
one before that was probably -- let's see.
Maybe 2012.
2013.
8
9
Compaq, '15.
Probably two thousand and -- maybe '13.
or to Allstate about the one that crashed in '13 before -A
No.
11
-- last month?
12
No.
13
it in bulk.
It's too time consuming.
14
litigation.
I'm too busy trying to defend myself and
15
everything else, too busy documenting things I have to
16
document.
18
I do -- no, this is the way I do this.
Okay.
I do
I'm too busy with
The next item you have is cost to repair
computers from hacking.
19
Right.
20
Which -- are you talking about the same
21
Maybe
Did you make any report to your insurance agent
10
17
The
computers?
22
Yeah.
23
The --
24
I went to -- I went to other services after Geek
25
Squad was not performing their service effectively.
Page 43 of 51
June 9, 2016

Page 675 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
114
112
112 of
of308
456
454

June
June 14, 2016
44
Let me hold you up for a second now.
We talked
about the HP and the Compaq, and then you said you bought a
warranty in August to have a different computer serviced
by --
A Lenovo.
-- the Geek Squad?
Right.
Denovo?
Lenovo.
10
Lenovo?
11
L-e-n-o-v-o.
12
Is that the one that you're making the claim to
13
14
have repaired?
A
I had that serviced, yeah.
Yeah.
Yeah, I had it
15
done by the people on Harrisburg Pike there.
16
moved, right there at The Grille there, near the campus.
17
forget what his name is.
18
Near F&M you mean?
19
Yeah, The Campus Grille.
He had a computer
20
repair shop in there, but he just moved.
21
out to Liberty Place or somewhere.
22
And you paid $400 for that?
23
No.
24
Yeah.
25
Let me see.
He just
I think he moved
That was -- to the repair?
Cost to repair computers from
Page 44 of 51
June 9, 2016

Page 676 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
115
113
113 of
of308
456
454

June
June 14, 2016
45
hacking.
I guess that's cumulative over the past four
years.
Okay.
That's probably what that is.

Here's what happened.
A Plus on Columbia
Avenue.
Last year I made a formal
complaint to the Lancaster DA's Office.
the detective.
goes you're going to have to do something for me.
going to have to go get a private firm, analyze your
Okay.
I met with
He goes, well, Stan, he goes, listen.
10
computer and get a report.
11
seen the detective since.
He
You're
I did that, paid for it, never
12
Okay.
13
He never returned my calls.
He never -- I guess
14
I called him out on it.
15
wasn't going to do it, or it was going to come back saying
16
there wasn't a virus in it or it wasn't hacked, but he was
17
wrong, so he flew the coop from me.
I guess he thought, you know, I
18
So the $400 is cumulative --
19
Yes.
20
-- for three different computers?
21
Three or four.
22
And this would be over how many years span?
23
Three or four years.
24
Okay.
25
Do you have the bills for any of those
repairs?
Page 45 of 51
June 9, 2016

Page 677 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
116
114
114 of
of308
456
454

June
June 14, 2016
A lot of them are in here.
I'm sorry?
A lot of them are in here.
Okay.
No.
Why not?
You can see them right now.
Oh, sure.
I'm getting tired.
10
Could you send me copies of them?
I had a long week, so let's
wrap this up.
11
12
items.
13
14
I'm about two-thirds of the way through these
Let's make it another day then for the rest.
I've had enough.
15
Okay.
16
We can reschedule another time.
17
46
And I take it
I'll get a copy of the transcript?
18
I'll get you a copy of the transcript.
19
Great.
20
I would prefer to keep going.
21
No, I can't.
22
23
24
25
You don't mind breaking, do you?
I'm up since 4 o'clock most
mornings, so this is enough for me.

Q
Can you show me where those receipts are that
we've just talked about?

A
Let me see.
Page 46 of 51
June 9, 2016

Page 678 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
117
115
115 of
of308
456
454

June
June 14, 2016
47
Save you and me some time.
Okay.
In the folders that you're looking at right now,
That's $160.
are those copies of your receipts?
5
6
Here's one.
These are the copies of the reports from the
technical people.
Okay.
The Geek Squad was a one-time fee.
A Plus.
Okay.
Here's A Plus.
10
receipt.
11
Avenue.
12
service, the Geek Squad.
13
computer.
14
them where I got them.
Let's see.
Here's
Now I got to find the
This is what they wrote.

Okay.
Okay.
That's on Columbia
Here's my receipt for the tech
Here's my receipt for the actual
Can I have those receipts back?
I want to put
I don't want the stuff mixed up.
15
How can I get a copy of those receipts?
16
Just take them right now and get them.
17
Ask them to copy them, you'd be all right with
19
Sure.
20
Do you have other receipts for any of these other
21
items?
22
I have 30 years of receipts.
23
Here, I mean here in this building.
18
24
25
that?
Sure.
Do you have
them with you?

A
I don't know.
Page 47 of 51
June 9, 2016

Page 679 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
118
116
116 of
of308
456
454
I was looking at.
piece of paper.
A
48
Could you -- there was another one in there that

June
June 14, 2016
It was on an 11 -- 8 and a half by 11
Here, that was $160.
Let's see.
Let me go
through there quick and see if I can get the receipts.
Here's a receipt.
they changed my SIM card thinking that would stop the
hacking, but it didn't.
for -- that's just an in-take.
This is a Verizon.
This is a receipt, but it's not

These are the IC3 reports.
10
Let's see if the receipt's in here.
11
they're all the receipts I have.
12
Okay.
13
I believe.
14
What Verizon did was
Geek Squad.
No,
I mean, as far as the computers are
concerned.
15
And then there's no receipts in these documents?
16
Receipts for what?
17
Any of these items that we're talking about.
18
I don't know.
19
Okay.
20
I don't know.
21
I'll make copies of these.
22
I did not peruse all these files for receipts.
23
Would you like -- would you like me to make a
24
25
copy of that for your records?

A
No, I gave it to you.
Page 48 of 51
June 9, 2016

Page 680 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
119
117
117 of
of308
456
454

June
June 14, 2016
49
Okay.
I'm going to have to trust you.
changing documents on me all the time.
(Off the record.)
I got people
BY MR. REESER:
Okay.
Do you want to take these and copy them and bring
them back?
Or I can mail them back to you.
10
Well, aren't we going to continue this?
11
Actually what I have to do is I have to report
Sure.
12
back to Allstate, and they let me know if they want me to
13
continue it or not.
14
15
A
fine.
Okay.
You can take them then.
Mail them back.
16
Okay.
17
You're going to get educated.
18
19
20
Yeah, that'd be
And you will not -You're going to be
a changed man, trust me.

Q
You will not do the continuation, assuming we
have one, in the courthouse?
21
Why?
22
Because it's free.
23
Why don't we do it at Allstate's office, Allen's
24
25
office?
Q
Okay.
I'll see if I can arrange that.
Page 49 of 51
June 9, 2016

Page 681 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
120
118
118 of
of308
456
454

June
June 14, 2016
Or we can do it at my house.
1250 Freemont Street.
It's nice.
50
You can come to
It's nice there.
It's fixed up.
I have no problem with that.
All right.
I had enough of that courthouse.
Okay.
How long did this last?
Roughly an hour.
So it's about 20 after 10:00 roughly.
I don't know what time we
started.
10
That's pretty good.
11
So you want to adjourn for the day?
12
Yeah.
13
MR. REESER:
14
(The examination under oath was adjourned at
15
Okay.
Very good.
10:19 a.m.)
16
17
18
19
20
21
22
23
24
25
Page 50 of 51
June 9, 2016

Page 682 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
121
119
119 of
of308
456
454
COUNTY OF DAUPHIN
51
2
3

June
June 14, 2016
: SS
COMMONWEALTH OF PENNSYLVANIA
I, Diane F. Foltz, a Notary Public, authorized to
administer oaths within and for the Commonwealth of
Pennsylvania, do hereby certify that the foregoing is the
testimony of Stanley J. Caterbone.
8
9
I further certify that before the taking of said

statement, the witness was duly sworn; that the questions
10
and answers were taken down stenographically by the said
11
Reporter-Notary Public, and afterwards reduced to
12
typewriting under the direction of the said Reporter.
13
14
15
I further certify the said statement was taken at the

time and place specified in the caption sheet hereof.
I further certify I am not a relative or employee or
16
attorney or counsel to any of the parties, or a relative or
17
employee of such attorney or counsel, or financially
18
interested directly or indirectly in this action.
19
I further certify that the said statement
20
constitutes a true record of the testimony given by the
21
said witness.
22
23
IN WITNESS WHEREOF, I have hereunto set my hand

this 13th day of June, 2016.
24
_______________________
Diane F. Foltz, RMR
Notary Public
25
Page 51 of 51
June 9, 2016

Page 683 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
122
120
120 of
of308
456
454

June
June 14, 2016
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
______________________________________
EXCLUSIVE Transcripts of Whistleblower Testimonies as
Targeted Individuals of U.S. Sponsored Mind Control and
Related Hearings and Lectures
Published by Advanced Media Group June 2, 2016
______________________________________
June 5, 2016
TABLE OF CONTENTS
1. Background of Stan J. Caterbone as a Targeted Individual
2. Transcript of the Richmond City Council Public Hearing of May 19, 2015 Passing
a City Resolution 5-2 to Ban Spaced-Based Weapons in Support of the Many
Targeted Individuals Suffering Symptoms of the City.
3. Karen Stewart, NSA Whistleblower and Targeted Individual
4. There is no doubt that NSA is now run by sycophants and sociopaths
5. EXCLUSIVE: Former NSA Employee Speaks Out on its Corruption # Karen
Stewart
6. The Interview
7. NSA Whistleblower Comes Out of the Shadows Into the Light by Karen Stewart
8. The Interview
9. Julianne McKinney, US Army Intelligence Officer, Whistleblower, and Targeted
Individual
10.
Transcript Of Greg Szymanskis Interview With Julianne Mckinney
11.
Dr. Nick Begich, Author and Expert Researcher of U.S. Sponsored Mind
Control
12.
October 1, 2015 Nick Begich Lecture at the Covert Harassment Conference
in Berlin, Germany
Mind Control Transcripts
Page 1 of 183
173
Sunday, June 5, 2016

Page 684 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
123
121
121 of
of308
456
454

June
June 14, 2016
Stan J. Caterbone

1250 Fremont Street

Lancaster, PA 17603
__________________________________
EXCLUSIVE Transcripts of Whistleblower Testimonies as
Targeted Individuals of U.S. Sponsored Mind Control and
Related Hearings and Lectures
________________________________
June 2, 2016
BACKGROUND
Stan J. Caterbone's International Signal & Control or ISC Whistleblowing History and Mind
Control Relationships are outlined in the following statements and declarations, which have already
been proven and verified and have never been specifically contested in any court of law:
Stan J. Caterbone was a Federal Whistleblower in 1987 regarding ISC
The 29 False Arrests and Prosecutorial Misconduct that Stan J. Caterbone was subject to in 1987
through 2015 was an effort to cover-up the allegations made by Stan J. Caterbone in the Spring and
Summer of 1987 after the Meeting of June 23, 1987 with ISC and United Chem Con Executive Larry
Resch.
The ISC Fraud and Sales of Arms to Iraq Story by the ABC News Nightline with Ted Koppel and the
Financial Times of London in May, July, and September of 1991 was most likely initiated or was
corroborated by Lancaster Newspapers reporter Thomas Flannary.
Thomas Flannary's mysterious death in February of 2004 was either murder or was a cover story to
hide the fact that he was a CIA operative used to control the flow of information, disinformation, and
propaganda. It is highly subject that he began his career with Lancaster Newspapers in 1987 and is not
a native Lancastrian.
The ISC merger was not completed until December of 1987, 3 months after the False Arrests of Stan
J. Caterbone.
Page 2 of 183
173

Page 685 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
124
122
122 of
of308
456
454

June
June 14, 2016
The official meeting with the Pennsylvania Securities Commission Agent Howard Eisler in September of
1987, which was solicited by Agent Eisler was an effort to illegally interrogate Stan J. Caterbone without
a legal subpoena.
In the months after the June 23, 1987 meeting with ISC Executive Larry Resch Stan J. Caterbone had
personally solicited a vast array of local, state, and federal officials, including the FBI and Congressman
Robert Walker, PA State Representative Gibson Armstrong for assistance in the retaliation and slander
campaign that was in progress. There is credible linkage between the ISC Scandal, U.S. Sponsored
Mind Control, Stan J. Caterbone's family VICTIMIZATION of the same, and the participation of
LANCASTER COUNTY, PENNSYLVANIA.
The Zook Murder Appeal proves that Lancaster County Detective Michael Landis, Judge James Cullen,
and Judge Farina of the Lancaster County Court of Common Pleas were all involved in U.S. Sponsored
Mind Control before 2004 and before Stan J. Caterbone went public with his VICTIMIZATION of U.S.
Sponsored Mind Control.
Bobby Ray Inman, former director of the National Security Agency (NSA) was on the Board of
Directors of ISC and was involved in U.S. Sponsored Mind Control Technologies through his company
S.A.I.C. Corporation. Bobby Ray Inman would later be selected by Former President Bill Clinton for his
Director of Defense, but would later remove himself due to allegations and public scrutiny for his role in
the ISC scandal.
In the Fall of 1991 Robert Gates was nominated for Director of the Central Intelligence Agency (CIA)
and during his televised confirmation hearings the was subject to brutal array of questions concerning
his participation in the ISC scandal. He went on to be nominated and later would serve both the Bush
Administrations and the Obama Administrations as Secretary of Defense until resigning in 2011.
There have been at least 3 documented attempts on the life of Stan J. Caterbone; 1987, 1991, and
2004, all attempts at vehicular homicide. Thomas P. Caterbone's passing in 1996 was the result of a
wrongful death claim by Fulton Bank. Samuel A. Caterbone was most likely an KULTRA murder tactic in
Santa Barbara, California on December 25, 1984. Samuel P. Caterbone was most likely the result of an
MKULTRA murder tactic on July 20,2001 in New York city.
The above finding of facts and evidence corroborates a vast conspiracy and criminal enterprise that
violates both civil and criminal RICO statutes and antitrust statutes.
The above would constitute treble damages for Stan J. Caterbone and Advanced Media Group in U.S.
District Courts, specifically in the Eastern District for Pennsylvania Case No. 05-2288, 06-4650, 1402559, and other related cases; and Case No. 08-13373 in the Lancaster County Court of Common
Pleas.
Page 3 of 183
173

Page 686 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
125
123
123 of
of308
456
454

June
June 14, 2016
Stan J. Caterbone

1250 Fremont Street

Lancaster, PA 17603
Richmond City Council

May 19, 2015
Richmond City Council Public Hearing of May 19, 2015
Passing a City Resolution 5-2 to Ban Spaced-Based

Weapons in Support of the Many Targeted Individuals
Suffering Symptoms of the City
Transcribed for Advanced Media Group, Originally published:
May 19, 2015
Richmond, California City Council hears from victims and advocates and votes in support of the Space
Preservation Act and the Space Preservation Treaty to permanently ban spaced-based weapons.
Jovanka Beckles Council Member Introduced This Resolution
Page 4 of 183
173

Page 687 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
126
124
124 of
of308
456
454

June
June 14, 2016
RICHMOND CITY COUNCIL BANS SPACED-BASED WEAPONS

COUNCIL MEETING HELD MAY 19, 2015
Mayor:
One is to adopt a resolution in support of the Space Preservation Act and the Spaced-Based
Treaty to permanently ban Space-based weapons. And we have 15 speakers for this item.
Council Member Beckles, would you like to introduce this?
Beckles : I would. You know I think what I would like to do is just kind of rehash the statement of this
issue for those that dont have the agenda in front of them. The city of Richmond is a welcoming and safe
area for all of our residents. We have led the way in so many initiatives that protect and provide the rights
for all of our residents to feel safe. And so its imperative that Richmond adopt this resolution in order to
stand in solidarity with residents who claim to be under assault with spaced-based weapons that should be
outlawed by the Space Preservation Act.
Now, the thing about this is that were not trying something new here. This is in support of what is already
there at the federal level. So we say as a council we support this treaty thats already in affect and we also
support our residents who are feeling attacked by certain kinds of weapons. And so the purpose of this
resolution is to show support for our residents that identify themselves as targeted individuals by
supporting the Space Preservation Act thats been passed by Congress and the Space Preservation Treaty
to permanently ban spaced-based weapons.
Now, many targeted individuals believe they have been personally attacked by weaponry that should be
outlawed by the Space Preservation Act. Some years ago one of the residents who is going to talk now, I
met with her. I met with many of them, to talk about this issue. Ive also spoken with our police
department. The representative from the department was Captain Gagan to figure out how law
enforcement can support these individuals, first of all, by at least listening and not assuming, and actually
just taking reports of incidences that are reported. And the police department was open to that, and is
open to that, and are willing to work with our residents in helping them to feel safe. Because its important
that we all feel safe living in our city. And in our city we have put forth our best effort to listen and respect
the voices and wisdom and experiences of our residents.
And so I dont intend to ignore it and Im hoping that my colleagues on this (unclear word) wont ignore,
but support those who suspect they have been exposed to these types of inhumane attacks with the intent
to cause them great emotional and bodily harm. And Im encouraged by these residents, these citizens of
Richmond, who stood up to protect these other residents here. Id like to encourage other officials at the
local, state and national level to explore methods to expand support to all residents. And as many as
you can see those of us with an agenda in front of us, and those who dont have an agenda in front of
you, who may be watching, or the livecast on the web, is that there is no financial impact to this. This is
not going to cost anything and its not going to hurt anyone to pass it. But it certainly would continue to
cause emotional distress to those who are being targeted if we dont pass this. And I urge you to support
Page 5 of 183
173

Page 688 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
127
125
125 of
of308
456
454
all of our residents in the city.

June
June 14, 2016
Mayor: Do we have questions from council members? Okay, Vice Mayor.

V Mayor: Just real quickly. You mentioned that this was passed by Congress. Can you tell me when that
happened because Im trying to look it up now and I thought that was just introduced in 2001 and never
was
Beckles: Actually, Ms Anderson can probably answer that question. When was it passed at the federal
level, Ms Anderson?
Anderson:
9/10/2002. Space Preservation Act, former Congressman Dennis Cosenich had introduced
this bill.
Vice Mayor: But was that
Mayor:
Were sort of getting out of our process here. I think that (word unclear) do you have other
questions?
Vice Mayor: Well, Im looking at the sheet that youre looking at. It looks like thats when the Burkley
City Council passed a resolution, not when Congress passed the law. Im looking on line at the House
website. And I know that theres, I understand that theres been multiple versions of this so I dont know if
its been passed or not. But from what it looks like here, it doesnt look like that version was passed by
Congress, so I dont know if it was. But I understand the Burkley City Council passed it on 9/10 of 2002.
Mayor: Other questions from the council?
Mayor:
So I had a couple of questions. Im looking at the resolution and it talks about the Space
Preservation Act. Can you tell me what act that was? Theres never been a Space Preservation Act passed,
right?
Beckles: It wasnt passed. It was brought forward by the Representative, the Congressman at the time.
Because there were some, you know how it goes in Washington, theres just a lot of power play. So it
never gotbut it did get passed in 2002 in Burkley. So were making ours similar to the one that was
passed in Burkley.
Mayor: Well it doesnt say anything about Burkley here. All it says is the Space Preservation Act. Are you
talking about the resolution Burkley passed or are you talking about one of the two resolutions that
Representative Cosenich introduced in 2001 and 2002?
Beckles: Well because that one didnt pass were just making reference that it was brought forward by
Dennis Cosenich, and of course politics being the way they are, it did not pass. So this is, Im making
reference to and using the Burkley model as an example of ours.
Mayor: Which one of the Cosenich resolutions did the Burkley model refer to?
Anderson: HR3616. House Resolution 3616.
Mayor: I didnt hear you, what?
Anderson: House Resolution 3616.
Mayor: 3615.
Page 6 of 183
173

Page 689 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
128
126
126 of
of308
456
454
Anderson: 3616. 1. 6.

June
June 14, 2016
Mayor: The research I did on this, that resolution was substantially different than HR2977.
Anderson: Yes sir.
Mayor:
And significantly it omitted any references to chem trails, particle beams, electromagnetic
radiation, plasmas, extremely low frequency or ultra-high frequency energy radiation and mind control
technology. So, the question I have is, it seemed to me, it was your intent to include all these in it, right?
So if you go with HR3616 and we approve this, it will not include any of these things I named. Was that
your intent?
Beckles: That was not my intent. My intent, and working with staff, of course, it helped put this together,
because we know that we get help with our staff. The intention was to include all of the things that people
are feeling, yeah, that people are feeling the pressures of and feeling the attacks of, and so I think thatI
dont know how much of this issue that Burkley had in theirs. But I think that to include these, and this is
the resolution saying we support this treaty, this act. Then Id like to have it in there. Because again, to
me its important that we defend, that we support and that we protect our residents. And so if these are
the things that residents are saying theyre feeling, then it should be in there.
Mayor: Well, all Burkley did, and Im looking at the Burkley resolution, and it just says, It is the will of
the council and the city of Burkley that the US Senate and House of Representatives enact, and the US
President sign and enforce the Space Preservation Act. But Im confused because there were actually two
Space Preservation Acts introduced and I think if were going to do this right, we need to define which one
were going to support. Because theyre different.
Beckles: Youre absolutely right. And I want the best one to move forward as well, and Im sure that the
residents want the best one and so.
Mayor: Which one is the best one?
Anderson: HR2977.
Mayor: So that would be HR2977.
Anderson: Yes.
Beckles: Which is the one that includes
Anderson: Everything.
Mayor: Ok, so, with that in mind, I dont have any more council people... oh I do too. Council Member
yeah, Ive got a bunch; Council Member Martinez and Council Member McLaughlin.
Martinez: Yes, I wanted to change the language to say that we endorse the intent of the act since the
act is not actually in place.
Mayor: The intent of which act?
Martinez: The intent of the second act.
Mayor: The second one is HR3616.
Beckles: Are you talking about HR2977 which includes all that, right? Which includes the chem trails. Is
that right?
Mayor: Thats my understanding of it.
Beckles: Is that right, Council Member Martinez?
Page 7 of 183
173

Page 690 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
129
127
127 of
of308
456
454
Martinez: Is that the revision? Right.

June
June 14, 2016
Mayor: Council Member McLaughlin.

McLaughlin: Actually I did some research on this too. Apparently Representative Cosenich didnt read
fully the first resolution that was brought forward in his name. He brought it forward based on some
recommendations. And when he realized it was drawn out to the level that it was, he pulled it. And he
brought forward the second one, which is 3616, which I think is more general.
Many of us remember, just to share some input going back, many of us remember in the 80s, Ronal
Reagan brought forth the Strategic Defense Initiative, which was later dubbed Star Wars, you know, thats
where this all came from. Basically, it was to put weapons technology into space as a global shield, as a
supposed defense against China and the Soviet Union. It was later seen as infeasible. And many others..
many people saw this as the idea to put weapons in spacewas insane. And I happen to think it was a
crazy idea, as did the population at large.
Then the Clinton administration in 1993 morphed it into the Ballistic Missile Defense. Later in 2002, which
is currently now the Missile Defense Agency. But also, along the way, in 2002 Dennis Cosenich introduced
this bill, and its the second one that he fully introduced, 3616, which basically called for a ban on spacedbased weapons. And then it was, I think it was just introduced, a co-sponsor was Representative Barbara
Lee, and at a certain point, this Space Preservation Act that was just introduced was brought to the UN
and the Space Preservation Treaty was linked with it. And actually the UN had previously addressedset
upestablished, I guess the basis for this treaty by saying they wanted a permanent ban on spaced-based
weapons that passed in the United Nations that passed 156 to 0. Then Burkley supported the 2002 the
Space Preservation Act and I believe also, the Space Preservation Treaty.
So thats what Council Member Beckles is referring to in terms of the resolution that shes brought
forward. I dont know how anyone can not support not having weapons in space when it has been
supported by the UN and also been supported, clearly stated by many experts that its infeasible this
original Ronald Reagan plan to dub this Star Wars.
I think the resolution is fine as it is. It basically says that the residentsthe well-being of our residents is
of importance to us and it also, it doesnt state pro or con in terms of what individuals are saying. But it
just refers to the fact that our residents deserve to be protected. And in general it states that spacedbased weapons are something that the city of Richmond does not support. (applause)
Mayor: Okay, so would you call the public speakers?
Anderson:
Speakers are Amy Anderson, Jesse Beltrand, Dr. John Hall, Dr. Edward Spencer, Ben
Colonson, Lisa Becker and Derrick Robinson.

Beckles: Amy Lee Anderson.
Anderson:
Yes
Mayor: Could you come over here to the podium to speak, please?
Anderson: Good evening Council Members, Council Beckles. I really want to thank you for not deviating
your plan because I went on your Facebook and I saw why you came in office and you never deviated your
plan. You said that you wanted to first put the community first and from you doing that, I want to thank
Page 8 of 183
173

Page 691 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
130
128
128 of
of308
456
454
June
June 14, 2016
you first. And secondly, as a psychologist, a child psychologist, I want to thank you for putting up with
some of those pains I have suffered along this way. But I am here in happiness, in a moment of greatness.
I have a perfect city. Nowhere in the United States, no targeted individual can get this kind of support
that I have gotten. We just needed just one person, one city. And because of that, you all are our heroes,
and we want to thank you. And I can go on and say much much.
But we are dying within because the technology is so sophisticated. Its hard for someone who has no
experience to fathom it. It is so sophisticated. So what we are saying to you all is please let us help you
understand enough, as someone outside looking in to our lives. Because were in pain, we are tortured
and we are humiliated every day in our lives because our lives have taken on a path. We dont even know
how or why we have this type of people on this planet who would harm in this type of way. And I just want
to thank you all. And you, Mayor, for you being in the cityworking in the service. Being in the service. For
others to do this, I know that should sadden you. (applause)
Jesse Beltrand: Good evening, Mayor, Vice Mayor and City Council Members. My name is Jesse Beltrand.
Im the president of the International Center Against the Use of Covert Technologies. Our organization was
formed in 2010 in Sacramento California for the purpose to bring awareness to the general public and
legal systems around the world about serious human rights abuses with regards to the utilization of
remote influencing technologies. My colleagues and co-speakers today, hopefully well get John Hall, who
was the author of Guinea Pigs, Technologies of Control, which have been sent to each of you and signed. I
also have Dr. Edward Spencer, whos a Neurologist from the Yale School of Medicine and Ben Colonson who
is a PHD in psychology, and therapist, and co-author of a book about PTSD. I myself am a retired
Sacramento City Fire Paramedic and a recent graduate of HMI and do provide therapy to victims.
In 2010 I met Dr. Hall and when meeting him I discovered this phenomenon and asked, Why isnt
anything being done about this? He said its because of the symptomology. If everyone went to traditional
medicine and complained about what they were experiencing, they would be railroaded into the mental
health institutions. The fact of the matter is, this is affecting all demographics of society: the poor, the
rich, the elite. I see victims on a monthly basis and hear from hundreds of people every week. I currently
have over 23,000 correspondences from victims not only within, here in the United States, but around the
world.
What we have discovered is that there are hot pockets within the United States where there are victims
that are being exposed to these types of technologies. And as our speakers continue to speak they will
explain to you how that has developed. Currently the hot spots are New York, Florida, Chicago, Texas, and
California. Unfortunately, in California, the East Bay has the highest amount of victims that we have
collected in our database, within our study within our organization. This is why we are currently here
today.
Beckles: Your time has expired Sir.
Beltrand: Okay, thank you.
Beckles: Dr. John Hall. Dr. John Hall.
Beltrand: Dr. Hall is unable to be reached so were going to have Dr. Spencer here.
Spencer:
Mr. Mayor, City Council, thank you. Thank you for attacking this very difficult problem. And
Page 9 of 183
173

Page 692 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
131
129
129 of
of308
456
454
June
June 14, 2016
there are a lot of people around the world, especially in Europe, where I attended a counsel just recently,
in November, who thank you. Im a retired neurologist. I attended Stanford University, Yale University and
a residency at the University of California in San Francisco.
Ive studied this sort of problem for a period of time. And its been a mystery to me why medicine in
general does not approach this and study the multitude of documents that are out there. But this is the
case. And I wont answer this for you, because this is an ongoing study, ongoing problem. This is really
intense technology. Essentially what might be described as EEG heterodyning. The entire electrical activity
of the human brain can be captured in this super computer and certainly processed and then put back into
someone else. Imits science fiction. But unfortunately, its not science fiction. So naturally this is
difficult. So the technology is incredible. But basically this is a moral problem. Ethical problem. This is a
violation of the golden rule, any ethics, anything thats decent. And this is a major thing to consider. Its
also a violation of our constitutional rights. So thats an important thing to keep in mind.
To bring it back down to Richmond, I know there are a lot of targeted individuals here, and the police
encounter them. And cant understand this and help them. The medical community is hobbled by not
having a differential diagnosis. And many of the psychiatric disorders, they should say rule out
psychotronic disorders, but they dont. So they cant face it at all. Thank you.
Beckles: Ben Colonson
Colonson: I thank you all. Two minutes. Okay, lets go. Thank you all for your endurance. I see you listen
to a lot of humans. Im gonna talk really fast with two minutes to go. I am a psychologist. I have
evaluated many targeted individuals who have previously been diagnosed as delusional and psychotic and
my job is to deconstruct those diagnoses. Because of the methods of my colleagues that can actually
detect advanced nano-technology present in their bodies both through frequency emissions and
lymphaticbasicallylike when you fire a bullet theres a trajectory and the police can determine the
trajectory. There are chemical tests to do that. I was just gonna, very quickly, since its two minutes, this
is this months issue of Smithsonian Magazine that says, The Future is Here: Brain to Brain
Communication is Real. Targeted Individuals report synthetic telepathy, voices in their skull, people
putting thoughts in their head, things that up until now weve been told are complete delusion and lock
em up. But you know, the capabilities exist.
This is the National Nanotech Initiative. The last 15 years budgets of a billion and a half dollars just by the
federal governments non-black budgets. We dont know what they spend on the black budgets. Doing
experimental programs showing how nano sensors in people can give us much more data about humanity.
These technologies can be used for great good but they have apparently also been used for tremendous
evil in non-consensual human experimentation. There is great documentation on this.
I do think its a little unfortunate, that confusion about the Space Preservation Act. There arethe systems
SCADAS, theyre called. The acronym stands for Supervisory Control And Data Systems Systems. They
include a component of satellite communication from a central command post as well as components
inside the human beings, or targeted individuals. So although there is a component of these weapons
systems, and they are clearly weapons systems by the major nations on earth, theres an arms race on for
the mind at this time. Control of the human mind. The Human Brain Initiative is part of it. If I only have
Page 10 of 183
173

Page 693 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
132
130
130 of
of308
456
454
June
June 14, 2016
two minutes I have to stop there. I hope you will listen to these people. They are suffering greatly as nonconsensual experimentees.
Beckles: A question, really quick, to the speaker. Could you repeat the names of those two references
that you gave, the magazines? Can you give me the names of those again, please?
Colonson: The first one, the current issue of the Smithsonian Magazine. A main stream magazine, which
in this months issue, says communicating brain to brain. And this is merely what they are releasing
publicly. The majority of the most advanced weapons systems are classified and we dont know the full
capabilities. This is just the supplemental to the presidents budget, this years Nanotechnology Initiative.
And what I didnt get to say in my two minutes is the National Registry of Environmental Professionals,
which certifies people to do all kinds of environmental quality testing, has just certified SCADAS,
Supervisory Control And Data Administration Systems, as something that needs to be studied for its
environmental impact on the environment in general. And I am part of the HSCADAS task force, how
these SCADAS systems are impacting human beings. And there are thousands of reports from targeted
individuals that crimes are being committed against them. And my intention in coming here tonight was to
support their claims so that law enforcement, with as much
Mayor: I think she asked you the names of the magazinesso
Beckles: Thank you very much. Lisa Becker.
Becker: Hi. Good evening. My name is Lisa Becker and I came here from Racine, Wisconsin. I have been
a victim of this technology for 14 years. I have been tortured for 14 years. My justice department has
failed me. My executive branch has failed me. My senators have failed me. My congressmen have failed
me. You are the only people in this country who have had the courage to even put this on the agenda.
Thats why I flew all this way to thank you, and to address you. This is torture. And it is enslavement. And
any one of these people can tell you the same thing. We have suffered desperately. And Im sorry if Im
emotional. But Im very tired. But if you wont save us, save yourselves. Because I promise you, this will
come back to every one of you. Every one of us in this country are going to be tapped into these computer
systems and you are gonna see what this feels like. Do something now while you still can. Thank you.
Council Member: I have a question. Could you be more specific in terms of how you feel that youve
beenthe injustice.
Becker: You mean in terms of the justice department failing me?
Council Member: Well in terms of your being a victim.
Becker: You mean in what Im feeling?
Council Member: Yeah, explain a little bit to me how you perceive yourself as being.
Becker:
Sure, well I have actual photographs of burns on my body. When I went to my doctor, the
response was, Well how do I know you didnt do that to yourself? How do you address that? Ive passed
two psychological evaluations. Not one but two. The one physician said, Youre sound as a bell. I have no
idea whats going on with you. When I go to sleep, when I go to try to sleep, I feel like Im being lit up
like a Christmas tree. I feel like every cell in my body just bouncing out of my body. I cant even describe
it. I get electric shock up my rectum. I get electric shock up my nose. Ive woken up with burns on the
end of my tongue. Ive had burns on the palms of both my hands. I vibrate. I vibrate. I can barely hold a
Page 11 of 183
173

Page 694 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
133
131
131 of
of308
456
454
piece of paper without quivering. Does that answer your question?

June
June 14, 2016
Council Member: Im trying to find out whats the source.

Becker:
The source are these exotic weapons. They talk about, in 2977, they talk about the space
weapons, spaced-based weapons. Basically in that document they talk about exotic weapons. Thats what
were talking about. And the fact of the matter is they did complete that global surveillance network. My
cousin worked for the defense department. She worked on the global mapping of that system. And when I
told her what I was going through, all she could say was, Youre on your own. Well, I figured that out. I
figured that out. If you would please, I urge you to pass this. I realize you cant enforce it, but if you
would pass it, it might give other communities the courage to do the same thing and show our defense
department we are not the enemy. We are not to be attacked. We are not terrorists. Most of us are
defenseless women.
Mayor: Okay, thank you.
Becker: Thank you.
Beckles:
Our next speaker is Derrick Robinson, followed by Laquisha Baker, Dolores Hall, Kim, Alex,
Elizabeth Adams, Robert Swegan. Please come forward. Derrick Robinson.

Robinson: Good evening everyone. Im Derrick Robinson. In regards to the Space Preservation Act that
is before you, many of us have travelled here to say thanks very much for listening and responding to so
many that have come to you over the past couple of years. This is a momentous occasion for our
organization and for humanity. You are one of the very few governing authorities that has considered the
danger of psychotonic technologies. Research in this area has been ongoing since the 50s by government
agencies, corporations, criminal elements, and religious cults, etc. But, only since the arrival of the
internet, has this holocaust been made known to thousands of people who have found that they are
victims of psychotonic technologies. And that they have been sereptisciously victimized by them. And as
the devices proliferate and the public becomes more aware of these covert activities, legislation on a local
and national level will be needed to address the concerns with regard to a vulnerable society. Your
resolution today would be a giant step forward in ensuring the health, safety and well-being for all people.
Thank you.
Beckles: Laquisha Baker
Baker:
Hello to all the legislators, and city hall, Javanka, my girl Amy over there. I have been a
Richmond resident 40 plus years. Ive seen two of my friends try and fight this fight. But their minds are
gone and theres no coming back. My mother was a Black Panther. They killed her. She was only 58 years
old. And Im just happy at this moment that somebody in our town, our city, has opened the doors for
many people who couldnt make it, didnt make it, and were survivors of it. And I just want to say thank
you.
Beckles: Dolores Hall.
Hall: I did not know you were going to call me to speak. But I will share. I head up the Los Angeles
Freedom from Covert Harassment Group. Its a support group. And I have about 300 people that is in that
group. And I get over 400 emails on a weekly basis of people asking me to help them, begging me, please
help. No one will listen to me. I am 65 years old and as I walk here, up to this podium, Im in so much
Page 12 of 183
173

Page 695 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
134
132
132 of
of308
456
454
June
June 14, 2016
pain. I have burns all over my body. Theymy doctor I had treated with for 16 years, my legs swelled up
from the electric magnetic frequencies hitting me on my legshe told me to go to the hospital. And when I
went to the hospital they were supposed to put an IV in me. They sent me to the mental ward because
they said I did this to myself. I would never hurt me. I have been a victim since 2007. You cant see this
horrific electric hitting you. Electric is invisible. You take a remote control to turn your tv, turn on your
television. It hurts so bad. I want to thank you for opening your minds and your time today. I am a retired
legal investigator. I have asked all my friends, I have very prominent friends, to help me. They cant do
anything about this. It is way, way over our heads. They say its the shadow government. It is people that
cannot be touched. Please help us.
Beckles: Kim, next speaker.
Buckner: Hello, my name is Kimberly Buckner and I have been a targeted individual for a very long time.
The things that Ive experienced due to being targeted, they have been unreal. However, I can attest that
they are very real indeed. My life has been destroyed in every possible way and every day has been a
struggle for me. I am very grateful to be before you today due to Amy Andersons due diligence and to
everyone else involved. I thank you council members for giving us targeted individuals a chance to speak
and to be heard. And I pray that these atrocities will soon be brought to an end. But we need your help.
Thank you.
Beckles: Alex
Rafter: Good evening, my name is Alec Rafter. I am an NYU graduate and have spent much of my time
working in a financial holding company in San Francisco. I have been a targeted individual for eight years
six months. Im from Lafayette, California, which is in this county. I am here to support and corroborate
what these other speakers are trying to convey. This technology exists and is being used on a mass scale.
It is torturous, brutal and inhumane. It happens everywhere I go. People dont understand the capabilities
of this technology. The person I came with here tonight was being shocked and stabbed in this very room
with a directed energy weapon while waiting to speak with the council. My ears are getting frequency
tinnitus while I was sitting here waiting for you as well as technology called voice to skull Dr. Alan Frey.
Like I said, this happens everywhere I go in Northern and Southern California. Ive been tortured all day,
all night, minute after minute, year after year after year. We need your help and support to stop this, to
save us, and to prevent this from happening to others. Please support banning these so called spacedbased weapons. Thank you very much.
Beckles: Robert Swegan
Swegan: Good evening. My name is Robert Swegan. I live in Modesto California. Im here tonight after
being targeted for 12 years with direct energy weapons, voice to skull. I wake up in the middle of the
night in excruciating pain. Theres nobody I can call. Theres nobody to help me. You know, sometimes I
have suicidal idealization because theres no one to help. You know, Ive been diagnosed schizophrenic,
delusional, at 53 and 57 years old. Im a graduate of junior college with a degree in counseling and human
service. I commend you people for what youre doing here. I want toIm here to support my friends. And
I know this has been very difficult for me and my family. My familyI have 4 children. One is in prison
Page 13 of 183
173

Page 696 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
135
133
133 of
of308
456
454
June
June 14, 2016
right now. I suspect he was here for about 45 minutes. And others will not even talk to me. My familys
been fragmented. I dont tell anybody whats happening to me anymore. Its a dark secret with me. I
cannot explain to people whats happening. The police in Modesto are at least talking to me now. Theyre
not taking me down to the mental health facility. I thank you very much for listening to me.
Beckles: Marilyn Languist
Languist:
Good evening Mayor and Council Members. Marilyn Languist, Richmond resident. I want to
thank Ms Anderson for bringing this topic forward and for bringing so many speakers. I urge you to adopt
this resolution. As has been said, the original Space Preservation Act was originally introduced by
Congressman Cosenich, co-sponsored by Congresswoman Barbara Lee and Congressman Pete Stark of the
Bay Area. And this concept was also voted on and supported unanimously by the United Nations to
prohibit weaponization of space and spaced-based weapons. These are clearly not good for anyone on
earth and not good for anyone in Richmond. You have to be aware that there are a lot of exotic weapons
research programs going on. Some of them covert, some of them not covert. A former Richmond resident
sent me a lot of emails last year about a public comment period for allowing US military testing of directed
energy weapons in the Olympic peninsula in the state of Washington, which is of great concern. In terms
of the types of weapons that are affecting these individuals, before you judge the targeted individuals, I
would suggest that you listen to them, take the time to really listen deeply to their experience. Try to put
yourself in their shoes for a moment. If you can believe them, then please do what you can to support
them. If youre not sure, then I urge you to take the precautionary principle, when in doubt error on the
side of extra protection for those who are vulnerable. So please do adopt this resolution. Thank you.
Beckles: Sylvia Gray White
White: Good evening. My name is Sylvia Gray White, a very long time Richmond resident. Tonight Im so
thankful and happy that our city is looking up, waking up and standing up. Approval of this agenda item
will make an impact on the whole world and will help us to restore our mother earth and our health. The
heavy metal toxins falling down on us daily from the chem trails are done by our military without our
approval and knowledge. Lead is one of the many chemicals in the chem trails even though our
government banned it decades ago. Banned it from paint, toys, even bullets, and other manufacturing
processes. This toxin has really negatively impacted my life. Lead is very toxic and there are no safe
levels. It displaces the calcium in your bones among many other illnesses, particularly with children. The
level of lead in my body has drastically increased in the past 3 years. Ive gotta get the lead out. We need
to stop this constant daily abuse of our universal rights to life, liberty and the pursuit of happiness. If you
cant feel good, you cant live good. I am not the only one breathing this pollution. If you breathe, youre
breathing it too. We have rights. Stand up for them! Now in order to stand Ive got to use a cane. But I
still can stand and will stand up for whats right.
Beckles: Our last speaker is Elizabeth Adams.
Adams: First and foremost Id like to pass this cell phone around. This is what electronic burns look like.
This is my 6 year old grand-daughter who has been targeted since birth. So can I just walk around and
show this to you?
Page 14 of 183
173

Page 697 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
136
134
134 of
of308
456
454
Mayor: Give it to the clerk.

June
June 14, 2016
Adams: This was taken less than 30 days ago at Eden hospital. Thats when you hear of the victim speak
of being electronically burned. That is my 6 year old grand-daughter. I am 59 years old. I have 6
grandchildren and 2 great grandchildren. I first and foremost want to say that I thank God for every one
of you. And I mean literally from the bottom of my heart. I thank him for each one of you and I thank him
for the blessings that hes gonna bring your way just for addressing these issues. These issues are beyond
the average eye. The average eye cant even see it. So its not even worth even talking about in that
sense. I have sent each and every one of you information. Everything that I sent you is just what you
need to know. But theres one more thing left:
your local fusion center. You need to do some deep
research into your local fusion center. Just look it up on line. That is where you will find information, ill
activities of some sort, that is going on withinIm not going to say city government because I cant
pinpoint it. But you need to look into your local fusion center. Secondly, mental health of children(timer
beeping).May I finish just two minutes please?
Mayor: No, I think we need to give everybody the same amount of time. Thank you.
Adams: Okay, no problem.
Beckles: That was the last speaker.
Mayor: (lady asked to speak) Maam, you know, if you didnt sign up you cant speak. Okay, I have Vice
Mayor Meyers.
Vice Mayor:
I was just gonna briefly say that the weaponization of space as the history that was so
eloquently described by Council Member McLaughlin is something that I think is extremely immoral and we
should not be, as a nation, engaging in and so Im gonna support this resolution based on that.
Mayor: Do we have any other speakers? Okay, hearing none, do we have a motion?
Beckles: I can make a motion. I share that we adopt the resolution thats put before us.
Mayor: Motion of second?
Beckles: Pinplay has something
Mayor: Oh, Councilman Pinplay
Pinplay:
I just want to address for a second this whole idea about weaponization of space and there
seems to be this assumption that just because Ronald Reagan supported Star Wars, its automatically
become some unmitigated evil. The context in which it was considered a problem was simply because
there was this perception that Star Wars or any kind of strategic defense initiative could not be made
foolproof. And it could not be made foolproof because the opponent, particularly a very well-armed
opponent like the Soviet Union could launch like tens of thousands of dummy missiles at any one point
and so it would be almost impossible to intercept all of them and to distinguish the nuclear missiles from
the dummy missiles. And the understanding was that it would be that there could be a problem created
because based on the overestimation of the effectiveness of Star Wars, namely that America might think
that it was too effective and therefore, go for a first strike and knock out all the Soviet weapons. Or, on
the other hand, the Soviets might feel it was too effective and go for a preemptive strike beforehand. And
it was only in that specific cold war context that Star Wars was considered a horrible idea. Actually, Star
Page 15 of 183
173

Page 698 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
137
135
135 of
of308
456
454
June
June 14, 2016
Wars is not a particularly bad idea, the whole idea is that you can knock out someones weapons before
they enter your air space, in fact, long before they enter your air space. And this, for example, was
practiced more than 20 years ago, in the Gulf War, when the Patriot system modification of this was used
when the Patriot system knocked out some of the Iraqi missiles that were launched at Israel. And it is not
just a perfectly valid system, it is actually a particularly useful system, in the time that we have now
where there are nations that are not quite as well armed as the Soviet Union used to be in the 1980s.
Which may not have the capability to launch tremendous numbers of missiles at any one time. And, in
fact, this is a fairly useful system to have. And so this automatic knee jerk reaction that because Reagan
supported Star Wars and at the time it was considered a bad idea and so for that purpose it is considered
a bad idea forever, I just think this is a wrong understanding of the system. And I just wanted to mention
that.
Mayor: So we have Council Member McLaughlin next.
McLaughlin: So, I justthe reason I was interrupting because I dont think we should get into it. Thats
kind of way off base. I was just giving the history of this in general. I will say that there were some of us
in the 80s that were talking about a nuclear freeze like to stop the arms war rather than weapons in
space. You know, I think space should be for exploration and good things to learn, scientifically. Not for a
weapons trace.
Mayor: Wait, no, were not having anything from the audience. Council Member Martinez.
Martinez: Yes, just last week on 60 Minutes there was a special on the reintroduction to the arms war,
with people trying to develop missiles to take out communication satellites. But any kind of war effort is
wrong. And we need to do whatever we can to stop all war efforts. Now when I was in university in the
1980s for humanities class, I did a paper on a science fiction novel. What I actually did was, I took all of
the predictions in this science fiction novel, and then I went to magazines and newspapers, and I was
surprised to find that every single prediction in this science fiction novel, that was written 20 years earlier,
had already come true. And they were happening there, then, in 1980. So its easy for me to see that
things which are wrong can happen because we have the wrong mindset. We have the mindset which is a
war mindset and this proposition that was put forth by Cosenich was to change our attitudes towards one
of seeking peace, and thats why Im endorsing it.
Mayor: Okay, Vice Mayor.
Vice Mayor: Well, I want to say that I do think this debate is, it is on topic, because the debate on Star
Wars is sort of, was part of what initiated this. And what I would say, and its been said, that any sort of
in my viewthe idea that we dont have enough tools to kill each other here on earth and so that we need
to start doing it in space, that just is simply immoral. And you know, it may be that some wars are
unavoidable. That may be true. But whatever we can do to get our country to move away from that mind
set and move away from utilizing new methods of war, we should support. And so thats why I support this
resolution.
Mayor: Okay, if theres nobody else, lets vote. Wait. Council Member Pinplay.
Pinplay: So the motion before us, does that include things like chem trails and stuff, or no?
Page 16 of 183
173

Page 699 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
138
136
136 of
of308
456
454
June
June 14, 2016
Mayor: Well, let me, I think hes bringing up a good point, because, Im really confused. I think that the
resolution itself is very simple. It simply says, the city of Richmond thereby supports the Space
Preservation Act and companion Space Preservation Treaty to ensure that individuals will not be targets of
spaced-based weapons. So I see that. All the testimony Ive heard tonight is about targeted individuals.
And so, I mean, Im confused. Is this about spaced-based weapons or is it about targeted individuals? And
if individuals are targeted, whos targeting them and why? I just dont understand it.
Beckles: Its simple enough. Its saying that, on the thereforeas you read, we are supporting this Space
Preservation Act and companion Space Preservation Treaty and the reason were doing this is that
individuals will not be targets of spaced-based weapons, which is what theyre saying. All this stuff is high
technology, itsand sothats what were adopting here. And you know, whether you believe it or not, one
thing that was very clear, and Ive met with folks a lot around this issue, and some of them Im just
hearing tonight. And even the ones I heard tonight, just out of compassion for folks that are saying help
us, and us supporting this, by adopting this resolution, I think it sends out a message that, you know, we
sympathize with you, we support you, and the very least we can do is just pass this resolution to make
sure that you feel the support and love and sympathy that you deserve. Its simple, it reads right there
Mayor. Thats all were trying to pass. Whats there before you. Thats all were trying to pass. Dont
complicate it. Its simple, so vote it yes or no.
Mayor: I sympathize with everyone who is suffering some kind of affliction. But on the other hand, you
know, in 1967, the US adopted, or the President signed the treaty on the principles guarding the activities
of states in the exploration and use of outer space including the moon and other celestial bodies. So the
US government has acted on this, and they have, within that particular treaty, is a ban on using outer
space for military purposes. So, I just dont understand what were talking about. Are we talking about the
weaponization of space? Are we talking about chem trails? Are we talking about individuals who are being
targeted? If so, by whom and why? I mean, you know, Im just a dumb city council person and this is way,
way over my head. And I frankly think that its sort of way out of the purview of what this city council
could be taking up.
Weve got real problems here. Weve got potholed roads, weve got a budget thats out of balance, weve
got crime, weve got greenhouse gases. Weve got all these things to worry about and here Im being
asked to support a resolution that deals with things like chem trails and particle beams and plasmas and
mind control technologies. I just dont know enough about it. If I were an expert Id probably take a side,
but Im not. And so for that reason Im just not gonna support it. Maybe some time Ill learn more and be
more oriented
Beckles: Id like to call the questions.
Mayor: Council Member Bates
Bates: Well, it is confusing. Im gonna support the resolution for the simple reason that weve voted on
lot of dumber ideas than this resolution represents. And again, we know that we dont control the
universe, we dont control Congress. So this is the least of my worries. So, Im gonna support it. Now call
for the questions.
Mayor: Does anybody else want to talk about it? Okay, lets just vote.
Page 17 of 183
173

Page 700 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
139
137
137 of
of308
456
454
June
June 14, 2016
Beckles: Council Member Pinplay? No. The motion passes 5-2 with Council Member Pinplay voting no,
and Mayor Butt voting no.
Bates: One reason I voted for it was there wasnt one speaker in opposition of it.
Page 18 of 183
173
Richmond council passes resolution supporting ban on space-based wea...
1 of 1
http://richmondstandard.com/2015/05/richmond-council-passes-resolutio...

Page 701 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
140
138
138 of
of308
456
454

June
June 14, 2016
Facebook
Twitter
More
Page 19 of 183
173

6/5/2016 6:44 AM
1 of 1
http://www.eastbaytimes.com/portlet/article/html/fragments/print_article....

Page 702 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
141
139
139 of
of308
456
454

June
June 14, 2016
Richmond: Space weapons resolution prompts requests to

investigate
By Karina Ioffee kioffee@bayareanewsgroup.com
East Bay Times
Posted:Mon Jun 01 18:42:20 MDT 2015
RICHMOND -- A city resolution banning space weapons within city limits has prompted dozens of calls to the Richmond Police
Department in recent days to ask the agency to investigate the alleged use of chips, bugs and other devices for mind and body
control.
On May 19, the City Council approved a resolution supporting the Space Preservation Act and Space Preservation Treaty
permanently banning "space-based weapons," such as microchips planted in people's bodies and micro waves that supporters
believe are used by nefarious sources to harm them.
The resolution was written by Councilwoman Jovanka Beckles, who works as a mental health specialist for Contra Costa County,
and aimed at "making all Richmond residents feel safe," she said.
"I don't intend to ignore the concerns from residents who say they have been exposed to these attacks that have caused them great
emotional and bodily harm," Beckles said.
The fallout has prompted worries that Richmond, which is working hard to remold its image in recent years, will be dismissed as
slightly off by the news media and other municipalities.
" I am trying to figure out how we can use this newfound fame to help market Richmond, much as desolate eastern Nevada has
used the Extraterrestrial Highway to lure tourists to an otherwise deserted stretch of desert highway," joked Richmond Mayor Tom
Butt in a recent online posting.
But the issue actually started last June, when Richmond police Capt. Mark Gagan was asked by Beckles to meet with residents who
said they were being targeted by space technology. Eager to show the department was sensitive to residents' concerns, Gagan
agreed.
"My desire was how to better serve this population from a public safety standpoint," said Gagan, a 20-year veteran with the
department. "There are people who have a huge amount of stress, anxiety and fear. These issues have public safety implications
no matter how far-fetched they seem."
The meeting had the best of intentions. But it appears to have also motivated conspiracy theorists who began to see the city as an
ally. Gagan began receiving invitations to speak at conferences organized by the "targeted individuals" community, and a rumor
started that the city had a task force devoted to uncovering government conspiracies. One organization even gave Gagan a
"humanitarian award" for his work on the issue.
"People were thrilled that someone was finally listening to them," Gagan said.
Since that meeting, he estimates that he's received more than 100 calls from people from as far away as Ireland who say they want
Richmond police to investigate their particular situations. Gagan always takes the time to explain that the department looks at facts
and has so far found no evidence to support concerns raised by callers.
"We try to refocus the conversation, and if they are local, get them into a managed program of medication and supervision," Gagan
said.
Contact Karina Ioffee at 510-262-2726 or kioffee@bayareanewsgroup.com. Follow her at Twitter.com/kioffee
Page 20 of 183
173

6/5/2016 6:47 AM

Page 703 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
142
140
140 of
of308
456
454

June
June 14, 2016
Stan J. Caterbone
ADVANCED MEDIA GROUPFreedom From
Covert Harassment & Surveillance,

1250 Fremont Street

Lancaster, PA 17603
CORROBORATING EXPERT AND FORMER NSA WHISTLEBLOWER

KAREN STEWART
DISCLOSURE OF ELECTROGAGNETIC WEAPONS USED TO KILL CERTAIN
TARGETED INDIVIDUALS DURING APRIL 10, 2016 RADIO INTERVIEW
THE DISCLOSURE
Karen Stewart graduated from Florida State University in 1979 with a BS degree in German Language
and a minor or co-major equivalent in Fine Art. She worked for NSA (National Security Agency) from
1982 to 2010. Her resume will follow.
Her video interviews can be seen on the following YOUTUBE links:
Wheel of Freedom (WUA) 4/4/16 Ex-NSA Karen Stewart

https://www.youtube.com/watch?v=ExpCL27ft10
NSA whistle blower Karen Stewart exposes targeted Individuals, 9/11

https://www.youtube.com/watch?v=ravXai6nfMg
On March 9, 2016 I was detained and falsely imprisoned by no less than 8 NSA Security Police
on the barracks of the Headquarters of the NSA at Ft. Meade Maryland.
I was handcuffed, and
interrogated for over an hour, while my car was dog sniffed and searched. I was ordered to return to
Lancaster rather than continue on to Washington, D.C., and was ordered not to enter any federally
owned property again. The following is a video of my statement:
Statement and Video of False Imprisonment re Handcuffed and Interrogation for an hour at NSA
Page 21 of 183
173

Page 704 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
143
141
141 of
of308
456
454

June
June 14, 2016
Headquarters (National Security Agency at Ft. Meade, Maryland) by 8 NSA Police officers on March 9,
2015 Recorded on March 11, 2016
https://www.youtube.com/watch?v=FeXlaQn5Nhs
Karen Stewart's resume at the NSA is as follows: I Worked various projects over the years, not
just USSR/Russia, but various countries researching/reporting on foreign military status and alliances,
weapons development and proliferation, the Chernobyl disaster and aftermath, the fall of the Iron
Curtain
and
changing
relations
among
newly
liberated
countries,
economic
and
diplomatic
developments of certain target countries. I researched and wrote a series of intelligence reports in
support of Operation Iraqi Freedom that kept secret Russian countermeasures sold to Iraq from
wreaking havoc on the American invasion. This ultimately is what got me fired because I questioned
why my work was used to promote another employee who had no experience with but, was credited
with my work .
The following transcript of an interview by Karen Stewart in which she describes the lethal
electromagnetic weapons and her experience on being on the receiving end was taken from the article
titled NSA Whistleblower Comes Out of the Shadows Into the Light and can be found at:
http://canadafreepress.com/article/nsa-whistleblower-comes-out-of-the-shadows-intothe-light
The article was written by Sher Zieve -- Bio and Archives and published March 28, 2016. The byline is
as follows: In February, 2014 I published an interview of an NSA Whistleblower. This is a follow-up to
that column. Due to recent threats to her person and other exigent circumstances, the Whistleblower
has decided to come out of the shadows and into the light. I am honored that she again chose me to
write her story.
KAREN STEWART'S TRANSCRIPT

First of all, the case STEWART V. NSA is a righteous lawsuit, (brought in 2010) meaning it is a
clear case of employer abuse of power and position to an egregious and even premeditated criminal
level meant to circumvent whistleblower protection laws like the No Fear Act. Simply put, I asked the
NSA Inspector General (IG) to investigate why my award-winning intelligence report series supporting
Operation Iraqi Freedom (2003) was used to promote an entirely different woman twice (2004 & 2005)
one who had nothing to do with my reports whatsoever, and was a known incompetent, but had
methodically sexually compromised many of the male managers within the Weapons & Space (W&S)
Directorate. Instead of following correct procedure, the IG and NSA Security decided to cover up the
Page 22 of 183
173

Page 705 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
144
142
142 of
of308
456
454

June
June 14, 2016
infraction by attacking me. Threats were made to paint my complaint as paranoid and to fire me for a
non-existent mental illness if I did not drop my effort to get credit for and the promotion for my own
work, given to the wrong woman. These threats quickly took shape as false accusations against me by
the guilty personnel obviously coached by Security, manifested with stalking harassment masquerading
as an investigation by NSA Security goons from 2006-2009. In late 2010, despite all evidence
showing my innocence from ridiculous and impossible charges, I was fired by an NSA Kangaroo court
with a predetermined agenda. My EEOC appeal (lawsuit) had been accepted for adjudication and the
judge had ordered no adverse action until its adjudication but NSA ignored his orders.
I moved from Columbia, Maryland back to my familys hometown of Tallahassee, Florida in 2011.
All was quiet until February 2015 when I instructed the law firm I had hired to subpoena evidence from
the Maryland Department of Motor Vehicles identifying a burglar (a now retired NSA Executive) who had
broken into my home very shortly after I had tried to make my 2006 Inspector General request for an
investigation, and stolen extra house, car, and mail keys as well as illegally bugging (burst bug) our
home and phone/internet to facilitate further harassment and likely search for blackmail material (no
luck for them there).
After the subpoena, I began noticing Security types in Tallahassee following me and photostalking me by March/April. Their license plates suggested Naval Security Group from Pensacola and
NSA Security personnel from Georgia (Augusta) and Texas (San Antonio). A quick check with the Leon
County Sheriffs Department, specifically Duty Officer deputy Canon, confirmed that NSA also had
personnel land at a private airport and deputies had escorted them the the Phipps property north of
Lake Jackson (near where I now live) for a secret exercise, just before the second round of stalking
harassment began. The sequence of events seems to have been for NSA Security to contact the Naval
Security Group in Pensacola, Florida (Headquartered at Ft. Meade, Maryland along with NSA) to initially
stalk and photograph me under ridiculous false pretenses until NSA could send its own Security
personnel to Tallahassee. Once there, under guise of authority, it appears that NSA enlisted the help of
the Florida Department of Law Enforcement (FDLE) and its civilian group, InfraGard, made up of
civilians recruited from their Ride-Along programs. As usual, NSA personnel fabricated some big lie as
to why the civilians should actively and passively stalk and harass me, and despite quite obvious
questions about why laws and due process were to be completely suspended in my case, the group
eagerly jumped at the opportunity for hundreds to gang up on one person (for Federal money, I may
add).
Thus, under NSA tutelage and FDLE auspices, suddenly I was a cast-iron target, meaning
multiple people covered me wherever I was, whatever I did. Cars were even stationed near my home
overnight on rotating shifts, beeping to each other when changing shifts but also for my benefit. NSA
also sought out willing neighbors to augment their snooping and harassment efforts, which could be
anything from hosting an NSA Security goon for accessibility to my property, both home (to bug and
Page 23 of 183
173

Page 706 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
145
143
143 of
of308
456
454

June
June 14, 2016
monitor short-distance transmissions) and car (to install and switch out vehicle GPS trackers to
facilitate car stalking and impeding as harassment. ) Those were the active participants, others not
assigned to me on a certain shift were ordered to quickly text in to a special site the big bad threat to
report my location and time I was there. People even snooped in my shopping carts to be able to tattle
to someone about what I was doing, what I was buying. (God help us, she bought bananas!!! Save the
children!).
This was annoying enough but I tried to ignore it because I thought NSA once again was going
for the usual See, shes paranoid, reporting harassment every day now just dismiss her lawsuit!
But I did report acts of harassment that caused physical damage such as hit and run,
purposely sideswiping my car, (This is exatly what happened to the PETTITIONER on May 9,
2016 enroute to MEDEXPRESS for pain medications) and botching the placement/removal of
a GPS tracker under my rear spoiler that destroy my spoiler. (They feared my mechanic
would find their tracker so they botched its removal the night before my appointment). I
even made fun of my stalkers when I could, using my hobby art shop on a popular internet
site to create bumper magnets making fun of them. After all, they were mostly nave,
unsophisticated boobs who desperately imagined that they were little James Bonds and that
the greatest existential threat to their country was a woman waiting for her lawsuit to be
decided, living in Tallahassee, walking her dogs, visiting friends.
In late November 2015, however, NSA apparently decided that I was not sufficiently
being intimidated by their civilian confederacy of dunces to back off my lawsuit to recover
my stolen salary and stolen retirement at the appropriate pay level. In 2009 I had
researched gang-stalking and discovered it was a real and growing phenomenon, but when
electrical harassment was mentioned, I could not really grasp the concept and wondered
about its existence. But I was to find out first hand in November 2015 that it does exist and
is a horrific crime against humanity.
NSA and its operatives started using small, mobile devices called Directed Energy
Weapons (DEWs) against me and my family in the night. These mobile weapons emit
multiple types of electrical emanations from ultrasonic, to microwaves modulated to radio
frequencies, to other kinds of wave variations I cant say I understand yet. Now, with the
help of certain mercenary and morally depraved neighbors, the effort is almost 24/7 now
with the intention being torture and slow-kill. These types of weapons over a lengthy time,
cause cancer, autoimmune disease, heart attacks, seizures, strokes, etc. It is the perfect
stealth murder weapon for a corrupt government.
At this point, when we leave the house, a criminal base of stalkers has been enlisted
by NSA to follow us and aim the DEWs at us wherever feasible to increase exposure in order
Page 24 of 183
173

Page 707 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
146
144
144 of
of308
456
454

June
June 14, 2016
to speed up death, with the help of the InfraGard dimwits still texting in my location like
good little sheeple.
The Leon County Sheriffs Department as well as the Tallahassee Police Department
are dragging their feet, making excuses, denying any such thing exists, or insulting me when
I try to enlist their help to come up with a strategy to combat this new crime before I or
one of my family is dead. They cant quite grasp the fact that this is domestic terrorism and
nothing protects the police or any official from this new weapon held and wielded by
criminals. Yet, plenty of recruits in their ranks have experience using the mobile DEWs in
Iraq. It is very interesting to me that the Naval Security Group headquartered at Ft. Meade
with NSA, is also called the Silent Warriors because they specialize in the use of Directed
Energy Weapons. Im sure the Naval Security Group base in Pensacola has many on hand
and may have even gotten a request from NSA to borrow a few for their secret exercise in
Tallahassee.
Clearly, NSA is of the opinion that you do not have Constitutional Rights unless they
say you do. If they use this to get rid of an inconvenient lawsuit such as mine instead of
simply settling for a tenth of the cost of harassment, then they must feel confident they
can murder anyone, anywhere, for any reason and get away with itincluding any leader or
politician.
Page 25 of 183
173

Page 708 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
147
145
145 of
of308
456
454

June
June 14, 2016
There is no doubt that NSA is now run by sycophants and sociopaths
EXCLUSIVE: Former NSA Employee Speaks Out on its

Corruption Karen Stewart
By Sher Zieve -- Bio and Archives
February 20, 2014
3 Comments | Print Friendly | Subscribe | Email Us
At the very least, for the past few months to a year it has become increasingly evident thatalthough
not allmany agencies of the US Federal government have become increasingly dirty, perverse and
corrupt and require a deep and thorough cleaning.
The US Secret Service has previously been exposed as including claims of involvement with
prostitutes, leaking sensitive information, publishing pornography, sexual assault, illegal wiretaps,
improper use of weapons and drunken behavior and the IRS was caught and admitted to denying
Obamas political enemies (aka TEA Party, Christians, religious Jews, conservatives) their Constitutional
rights while allowing progressive groups (aka Liberals, Leftists, Marxists, Maoists, Socialists,
Communists) theirs. Andlove him, hate him or fall somewhere in-betweenEdward Snowden shone a
very bright light on the unconstitutional domestic mega-spying of one of these clandestine agencies
the National Security Agency. Thus far, under Obamas increasingly iron rule, few-to-no members of
these agencies have even been indicted by Congress for their blatant crimes against the American
people.
The NSA appears to have begun as a patriotic organization that was geared toward protecting the USA
and its citizens. Whether or not that was its original intended purpose is a subject for discussion and
speculation. However, portions of the NSA seem to have devolved into something very sinister. Todays
interview will concentrate on this agency.
NSA Analyst. Due to a number of substantive reasons, this former Analysts identity cannot be divulged
at this time and will be referred to as W. I have, however, confirmed this individuals prior employment
and credentials via a well-known NSA Whistleblower. The information disseminated to me, amongst
other things tells a sordid story of corruption and how employees are silenced into submissionvia fear
within the agency,
Page 26 of 183
173

Page 709 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
148
146
146 of
of308
456
454

June
June 14, 2016
The Interview
Sher:Thanks so much for being with me, today, in order to provide essential additional information to
the public on how many of their tax dollars are really being spent. You were employed by the NSA for
over two decades. Would you tell the readers what initially attracted you to the agency as well as how it
has deteriorated over time?
Karen Stewart: Like many people from families with a strong history of serving our country, coming
out of college, I looked to find a way to best utilize my particular interests and talents in service to my
fellow Americans. The mission of the NSA it seemed to me, was to stop threats coming to our shores.
Its charter clearly targeted foreign nationals on foreign soil who did or could intend us harm. That
appealed to me as a righteous endeavor and honorable tack for my life to take.
Sher: Youve shared with me how the NSA deals with its employees who bring legitimate complaints to
their superiors. How thoroughly intimidating and threatening are their behaviors toward those who balk
at their adverse treatment? Would you give a few examples?
Karen Stewart: Apparently the nature of NSA Security degenerated under General Michael Hayden,
the previous Director of NSA (DIRNSA), who promoted a very questionable mid-level Security manager
to a power position within Security. Hayden had originally been tasked to eviscerate NSA since a very
shallow and short-sighted Congress believed that the fall of the Iron Curtain meant no danger existed
anywhere anymore that required the existence of a robust NSA presence. There evolved, under him, a
gratuitously vicious bully mindset that employees were to be intimidated at any opportunity not only to
drive them out of NSA but to cut back on people reporting problems that made NSA look bad, especially
problems involving upper management.
Under Hayden and his successor, General Keith Alexander, the filing of complaints to or requests for
investigations by the NSA EEO or the OIG (Office of the Inspector General) were often inexplicably
blown off despite adequate evidence or the presence of willing witnesses. Then the person who had
filed the complaint would be subjected to an out of cycle reinvestigation interview with Security as
well as polygraph exam, wherein the tone of the Security person was not neutralas it should bebut,
hostile with far-fetched or even ridiculous non-issues presented as potentially problematic. This was a
Security shot across the bow to warn the person that he had crossed the line by filing the complaint. If
he pursued the complaint, Security would lean on his managers to heavily discourage him from doing
what he thought was proper and was indeed a protected action under the law. If he persisted, did his
own amateur investigation, or told coworkers about the situation, he might be called down to Security
multiple times and accused of being paranoid and delusional based on his complaint, and his job
threatened.
The worse the infraction reported, especially if a high level manager looked to be involved, the more
Page 27 of 183
173

Page 710 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
149
147
147 of
of308
456
454

June
June 14, 2016
severe the reaction by Security. In cases of egregious wrong-doing by a manager, Security would
review the personnel files, medical files, and financial statements to find anything they could use to
threaten or blackmail him with, or pretend to misinterpret some tidbit of information as something it
was not.
Some people were forced to sign admissions of guilt of preposterous misinterpretations of facts in order
to keep their jobs, thereby killing their credibility and complaint. When nothing was found in such files
that could be used, a false accusation of espionage or leaking classified materials ginned up by Security,
was used to justify a Security intrusion into the persons home to search for blackmail material, further
assess the interests and personality of the targeted individual (TI), and plant bugs and abscond with an
extra set of keys for further intrusions. The more the person objected to being bullied, the more heavyhanded Security became, insisting that hostility toward them indicated wrong-doing on the TIs part.
Thus the TI would become harried and harassed for a crime he never committed, if it ever
even was committed, and to repeated accusations by Security Psych services of a nonexistent mental illness, more than adequately supported by years of internal, psychological
evaluations stating he was mentally sound (Paranoia with delusions is rare and certainly
never occurs overnight, but that does not deter a Security psychologist attack dog, whose
favorite mode of attack employs reference to this malady).
The more a person stood his ground, the more personal it became to Security, which then
became dedicated to the personal destruction of the TI. Under the pretext of the fake
accusation of espionage or leaking classified information, Security would slander the
individual with his coworkers, work friends and managers to isolate him and apply yet more
pressure. Many backed away from supporting the TI in fear for their careers and maybe even
freedom. Certainly this sent a message to the workforce in the TIs area that NSA Security
was at its essence, a rogue, unaccountable and psychotic entity that was to be greatly
feared.
Once NSA Security had decided upon the removal of the TI for failing to be sufficiently
cowed, then false evidence was given to the FBI liaisons assigned to NSA. This would
engender a fraudulent FISA warrant, which loosed FBI surveillance and investigators upon
the person for a few weeks or months, further slandering him to his work and social circles
and thereby putting pressure on him by their constant presence. When the FBI would find no
basis for the accusation, they would drop the case and move on. However, at that point,
Security would send in their own personnel sans warrant, to overtly stalk and harass the TI ,
24/7.
In some instances, Security has even gone into the persons

neighborhood to recruit snitches and augment harassment with
Page 28 of 183
173

Page 711 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
150
148
148 of
of308
456
454

June
June 14, 2016
hostile civilians convinced the TI is an enemy of the state, based

on baseless Security slander.
Intrusions would be made into his home to remove gathered evidence or
move things around as a psychological ploy and his car would be secretly
GPSd to facilitate vehicular stalking and aggressive driving games. There
have even been reports of pet murders by poisoning as an escalation of the
harassment with the inferred threat that perhaps it could be the TIs child or
himself next. The harassment is essentially elevated until the TI either
breaks and assaults a harasser or complains to Security about the insane
and sadistic, not to mention criminal way in which he is being mistreated.
This is what Security planned for and is ready to jump on as their
springboard to terminating his employment.
His security clearance is immediately pulled, he is warehoused in a menial job until adequate paperwork
and a back-story can be fabricated or forged to falsely present a termination due to mental instability or
illness, and the person is fired. Of course there is an appeals process, but it is thoroughly corrupted. No
matter how much evidence supports the victim and how little supports NSA, NSA always wins these
cases where it is clear the person was targeted for dismissal. Of course, this does nothing but embolden
more degenerate or criminal behavior while making it clear that the person reporting evil will be
considered the problem, and that in reality no labor laws or whistle protection laws can actually protect
an NSA employee, because real watch dog entities dont exist within NSA and state and Federal
authorities routinely turn a blind eye to the reported abuses even as they become more criminal and
seditious.
I shake my head at sycophant, disingenuous politicians who claim Edward Snowden could have or
should have gone through proper internal authorities to report the abuses and criminal acts being
committed within NSA. Would that be to the thoroughly corrupted, attack dog-watch dog entities, or the
thoroughly oblivious or compromised politicians responsible for oversight who are in fact, in the NSAs
pocket due to bribery, blackmail or stupidity?
Sher: The NSA seems to suffer from the some of the same maladies as did the recent outing of the
Secret Service. Without becoming too specific, would you give us a general idea as to advancement for
sexual favors that have occurred within the agency? How defeating is that to employees who are simply
working to protect the country while their bosses are indulging in sexual liaisons with lower level
employees?
Karen Stewart: In my career, promotions were always hard to come by, meted out perhaps every
Page 29 of 183
173

Page 712 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
151
149
149 of
of308
456
454

June
June 14, 2016
five years if you were a good or exceptional worker, but male managers discovered that they held the
keys to paradise in regard to attractive or even acceptable women willing to take shortcuts. These
were the women who would make promotions in stunningly rapid succession with little to no
accomplishments - of their own, that is. While others killed themselves with years of grueling shift work
or even multiple dangerous foreign assignments only to find themselves evaluated as a 3.6 on a scale
of 5, when an attractive, morally loose recent college graduate would receive a 4.8 for essentially
alphabetizing a shelf of reference books her first 6 months on the job. This made many, many people
bitter and certainly sent the wrong signal to the hardest workers and the most talented. Though many
stopped being as dedicated to their jobs, others did indeed press ahead and worked tirelessly knowing
their reward was the mission accomplished and not likely appropriate recognition. Capable men
despaired of receiving deserved promotions and women almost feared being promoted for exceptional
work, fearing they would be assumed to be one of the typically incapable promotion bimbos among the
bloated management. Expertise and knowledge became commodities to guard and not share with new
workers, fearing you would not reap the benefits of your own work. This of course created a situation
where expertise and insight must be gained and regained from scratch, losing precious time training up
area or target experts to the detriment of the mission.
It was very discouraging to see immature or degenerate bosses spending their time flirting and chasing
skirts, the very same people who were charged with competently reviewing your work, (keeping
apprised of the big picture so people felt free to specialize their research), and whose responsibility it
was to accurately and honestly represent their people before promotion boards. But the atmosphere of
secrecy, the strict laws about divulging names of NSA employees or anything that occurred there,
emboldened certain men to believe that their wives and families would never know of their
indiscretions, and turned work time into play time for them. And now apparently young males are also
being pursued as sexual toys. One has to wonder what is being missed in the realm of highly perishable
intelligence leads by distracted managerial incompetents.
Sher: As an additional example of NSA intimidation, one of the things youd said may be shared is your
experience with the 3 Amigos. Would you tell us about them?
Karen Stewart:There were three eccentric looking older males who were often seen in the NSA OPS1
cafeteria together, whom we also got to know by word of mouth, as master electricians well-versed in
computer science. They were nicknamed by some in the analyst field as Rasputin, Santa, and Choo
Choo or the engineer, due to their highly unusual appearances and dress. One eye witness being
harassed on yet another NSA Security retaliatory witch hunt, reported seeing one of these men at her
home, on her property, when she discovered indications that her home had been broken into, her cable
box broken into, and her phone hacked, leaving tell-tale clicking sounds at regular intervals whenever
she used her phone. Any phone tap done by warrant is done at the carriers hub under their auspices
and will not click, only illegal hack jobs click.
She noted him not only as a trespasser being
Page 30 of 183
173

Page 713 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
152
150
150 of
of308
456
454

June
June 14, 2016
somewhere he should not have been, but recognized him by his highly unusual appearance from work.
When she attempted to look him up in the NSA data base by career specialty, she found that what
should have been his photo, which should have been a source of pride since he was of the rank to be a
Flag Badger (Manager whose rank is senior enough to garner a photo with the American flag in the
background), was instead a photo of a desert animal called a Meercat indicating that he wanted his
identity hidden from the general NSA population.
Sher: With regards to many who have said that the NSAs collection of meta-data on all forms of
communication between legal citizens of the USA is unconstitutional, also indicated is the fact that not
one terrorist act has been stopped by said collection. It appears good old-fashioned police work is what
still gets the perp. In your opinion, is this accurate?
Karen Stewart: I think it is indeed true that the meta data collection ruse within the USA distracts
from tried and true research and investigation, which the latter method apparently DID INDEED
uncover the 9/11 plot months before it happened, well in time to have prevented it, according to two
separate analysts with whom I have spoken, one just two days after 9/11 as he broke down and
sobbed his heart out, repeating We could have saved them! We could have saved them! But they
wouldnt let us report it!, and the other several years later, who maintained the same story of being
threatened and forbidden to report any warning about 9/11, then being harassed and fired for a nonexistent mentally illness. However, it is a good means to track your political enemies and detractors and
their affiliates within the US - for future reference? It would appear much more for the self-preservation
and expansion of NSA as the ubiquitous Orwellian Big Brother than for the protection of the USA. With
the power the NSA wields, it could easily influence border control issues and immigration issues to
make us not as susceptible to terrorist intrusions and infiltrations, but that would undermine their
power grab and expansion within the US, something never intended at NSAs creation - and for good
reason.
Sher:As a former long time employee of the NSA, what do you believeif anythingcan be done to
correct the problems within the agency?
Karen Stewart:There is no doubt that NSA is now run by those sycophants and sociopaths who are
the least desirable to have in any position of such sensitivity and trust and are purging NSA ranks of
people with integrity. Compromising activity that would rightfully cost you your clearance, is now
viewed as intrinsic perks of the job once you reach a certain pay grade. These lesser leaders have
turned NSA into an American Gestapo Wanna-Be agency. NSA lost its way with non-serious super grade
playboys not mature enough for the responsibility of the job of managing and directing NSA,
compounding the problem by promoting sycophants to protect their backs as well as lightweights with
whom to have sexcapades behind office doors, but in that group also has risen opportunistic
sociopaths and psychopaths attracted to more and more power, any way they can get it, and by
conniving and ruthlessness have blown past incompetent, distracted management to change the very
Page 31 of 183
173

Page 714 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
153
151
151 of
of308
456
454

June
June 14, 2016
nature of the NSA from watchman to the American people to jack booted prison guard.
If the Legislative Branch is possessed of anyone with the least bit of courage and common sense, they
would demand super clearances for those on the Intelligence Oversight Committees so that years or
decades of abusive behaviors, kingdom building, or even crimes can not continually be swept under the
rug by telling these particular politicians, You dont have the need to know, just trust us. Obviously,
they cannot be trusted. An appointment to that Committee would of course have to become much more
exclusive, requiring a thorough vetting as any job with a Top Secret clearance should. But to deal with
the toxic management at NSA now, I would require every Flag Badger and Security manager to account
for himself and what he adds to the mission. If he is pork, retire him or require him to laterally transfer
to another agency. Before that however, I would require that every single Flag Badger and every
Security group manager take a polygraph by non-NSA affiliated or non-NSA sympathetic sources to
account for the millions of dollars wasted on their vicious and illegal war on NSA employees who
dutifully report fraud, waste, abuse as well as sexual predation and treason. Those who are found to be
guilty of such things as falsifying accusations against innocent employees; fabricating false witnesses
and evidence; engaging in illegal acts of breaking and entering; falsifying FISA warrant justifications;
lying to the FBI about a targeted victims criminality; falsifying psychological assessments; subverting
lie detector exams by screaming at the targeted subject during or just before the exam to create false
impressions of guilt; hiding or destroying exonerating evidence supporting their victims claims;
intimidating or roughing up witnesses; coordinating or participating in criminal stalking and harassment
activities, illegal break-ins, illegal wire taps, organizing and paying civilian groups under the table to
augment harassment of targeted employees, and lastly, conspiring to effect or cover up any or all of
these actions. And any NSA employee in that group who pleads the 5th, should be fired and stripped of
his retirement since this type of betrayal rots a country from within. NSA must be recreated, and
returned to the stated task in their founding charter of focusing on foreign enemies overseas.
Sher: W, so much of the information youve provided is truly astounding! Thanks so much for being
with us today and I hope youll be available for another should ongoing events require one.
Click to view 3 Comments
Sher Zieve is an author and political commentator. Zieves op-ed columns are widely carried by multiple
internet journals and sites, and she also writes hard news. Her columns have also appeared in The
Oregon Herald, Dallas Times, Sacramento Sun, in international news publications, and on multiple
university websites. Sher is also a guest on multiple national radio shows.
Page 32 of 183
173

Page 715 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
154
152
152 of
of308
456
454

June
June 14, 2016
1NSA Whistleblower Comes Out of the Shadows Into the Light Karen Stewarty
By Sher Zieve -- Bio and Archives
March 28, 2016
0 Comments | Print Friendly | Subscribe | Email Us
AddThis Sharing Buttons

Share to FacebookShare to TwitterShare to PrintShare to EmailShare to PinterestMore AddThis Share
options
In February, 2014 I published an interview of an NSA Whistleblower. This is a follow-up to that column.
Due to recent threats to her person and other exigent circumstances, the Whistleblower has decided to
come out of the shadows and into the light. I am honored that she again chose me to write her story.
Her name is Karen Stewart Karen Stewart

BIO
Education
Freshman year - Schiller College, Strasbourg, Fr.

Sophomore - Senior years, graduated from Florida State University (79)
BS in German Language and a minor or co-major equivalent in fine art
Work History: 1982-2010 NSA (National Security Agency

Underwent initial retraining from 1982 - 83, on the job training to become a linguist in a needed foreign
language (chosen to train in depth in Russian since my college major, German was not in demand but I
had also studied Russian and French with good results).
Worked
various
projects
over
the
years,
not
just
USSR/Russia,
but
various
countries
researching/reporting on foreign military status and alliances, weapons development and proliferation,
the Chernobyl disaster and aftermath, the fall of the Iron Curtain and changing relations among newly
liberated countries, economic and diplomatic developments of certain target countries. I researched and
wrote a series of intelligence reports in support of Operation Iraqi Freedom that kept secret Russian
countermeasures sold to Iraq from wreaking havoc on the American invasion. This ultimately is what
got me fired because I questioned why my work was used to promote another employee who had no
experience with but, was credited with my work.
Note...Due to the Top Secret nature of the work, the above summary is slightly vague, by design.
Page 33 of 183
173

Page 716 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
155
153
153 of
of308
456
454

June
June 14, 2016
The Interview
Sher: Karen, thanks for taking the time to speak with me and its so good to have you back and this
time under your name! As a Whistleblower, what finally made you decide to come out from the
shadows?
Karen: I always intended to link my name with my story because it is a story that needs to be told, but
since I have a lawsuit against NSA (technically an appeal of an unlawful, employer action, i.e. my
termination at the 28 point year of my career for trying to request an investigation by the NSA
Inspector General), sitting under a gag order demanded by NSA, on the docket at the Equal
Employment Opportunity Commission (EEOC) in Baltimore, I could not do so without risking the
adjudication going against me for that reason alone. However, in 2015 NSA Security made the decision
to yet again engage in a massive slander campaign against me in my new location, thus breaking its
own gag order so I feel no compunction to be held to a standard required by the EEOC judge at NSAs
request that NSA itself clearly holds in utter contempt.
Sher: Since we last talked, a lot has happened with you. You have refused to drop your discrimination
lawsuit against the NSA and have shared with me that the agency has stepped up its efforts against
youpersonally.
Youre now being stalked by what appear to be NSA operatives. Is that correct? As you reported to me
they, also, seem to be using electronic emanation technology to both stop and damage you. I believe
former NSA employee and Whistleblower Russel Tice reported on this, also. This is really deep dark
side information. Would you tell the readers what theyre doing to you, [possibly] others and why?
Karen: First of all, the case STEWART V. NSA is a righteous lawsuit, (brought in 2010) meaning it is a
clear case of employer abuse of power and position to an egregious and even premeditated criminal
level meant to circumvent whistleblower protection laws like the No Fear Act. Simply put, I asked the
NSA Inspector General (IG) to investigate why my award-winning intelligence report series supporting
Operation Iraqi Freedom (2003) was used to promote an entirely different woman twice (2004 & 2005)
one who had nothing to do with my reports whatsoever, and was a known incompetent, but had
methodically sexually compromised many of the male managers within the Weapons & Space (W&S)
Directorate. Instead of following correct procedure, the IG and NSA Security decided to cover up the
infraction by attacking me. Threats were made to paint my complaint as paranoid and to fire me for a
non-existent mental illness if I did not drop my effort to get credit for and the promotion for my own
work, given to the wrong woman. These threats quickly took shape as false accusations against me by
the guilty personnel obviously coached by Security, manifested with stalking harassment masquerading
as an investigation by NSA Security goons from 2006-2009. In late 2010, despite all evidence
showing my innocence from ridiculous and impossible charges, I was fired by an NSA Kangaroo court
with a predetermined agenda. My EEOC appeal (lawsuit) had been accepted for adjudication and the
judge had ordered no adverse action until its adjudication but NSA ignored his orders.
Page 34 of 183
173

Page 717 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
156
154
154 of
of308
456
454

June
June 14, 2016
I moved from Columbia, Maryland back to my familys hometown of Tallahassee, Florida in 2011. All
was quiet until February 2015 when I instructed the law firm I had hired to subpoena evidence from the
Maryland Department of Motor Vehicles identifying a burglar (a now retired NSA Executive) who had
broken into my home very shortly after I had tried to make my 2006 Inspector General request for an
investigation, and stolen extra house, car, and mail keys as well as illegally bugging (burst bug) our
home and phone/internet to facilitate further harassment and likely search for blackmail material (no
luck for them there).
After the subpoena, I began noticing Security types in Tallahassee following me and photo-stalking me
by March/April. Their license plates suggested Naval Security Group from Pensacola and NSA Security
personnel from Georgia (Augusta) and Texas (San Antonio). A quick check with the Leon County
Sheriffs Department, specifically Duty Officer deputy Canon, confirmed that NSA also had personnel
land at a private airport and deputies had escorted them the the Phipps property north of Lake Jackson
(near where I now live) for a secret exercise, just before the second round of stalking harassment
began. The sequence of events seems to have been for NSA Security to contact the Naval Security
Group in Pensacola, Florida (Headquartered at Ft. Meade, Maryland along with NSA) to initially stalk
and photograph me under ridiculous false pretenses until NSA could send its own Security personnel to
Tallahassee. Once there, under guise of authority, it appears that NSA enlisted the help of the Florida
Department of Law Enforcement (FDLE) and its civilian group, InfraGard, made up of civilians
recruited from their Ride-Along programs. As usual, NSA personnel fabricated some big lie as to why
the civilians should actively and passively stalk and harass me, and despite quite obvious questions
about why laws and due process were to be completely suspended in my case, the group eagerly
jumped at the opportunity for hundreds to gang up on one person (for Federal money, I may add).
Thus, under NSA tutelage and FDLE auspices, suddenly I was a cast-iron target, meaning multiple
people covered me wherever I was, whatever I did. Cars were even stationed near my home overnight
on rotating shifts, beeping to each other when changing shifts but also for my benefit. NSA also sought
out willing neighbors to augment their snooping and harassment efforts, which could be anything from
hosting an NSA Security goon for accessibility to my property, both home (to bug and monitor shortdistance transmissions) and car (to install and switch out vehicle GPS trackers to facilitate car stalking
and impeding as harassment. ) Those were the active participants, others not assigned to me on a
certain shift were ordered to quickly text in to a special site the big bad threat to report my location
and time I was there. People even snooped in my shopping carts to be able to tattle to someone about
what I was doing, what I was buying. (God help us, she bought bananas!!! Save the children!).
This was annoying enough but I tried to ignore it because I thought NSA once again was going for the
usual See, shes paranoid, reporting harassment every day now just dismiss her lawsuit! But I did
report acts of harassment that caused physical damage such as hit and run, purposely sideswiping my
car, and botching the placement/removal of a GPS tracker under my rear spoiler that destroy my
spoiler. (They feared my mechanic would find their tracker so they botched its removal the night before
Page 35 of 183
173

Page 718 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
157
155
155 of
of308
456
454

June
June 14, 2016
my appointment). I even made fun of my stalkers when I could, using my hobby art shop on a popular
internet site to create bumper magnets making fun of them. After all, they were mostly nave,
unsophisticated boobs who desperately imagined that they were little James Bonds and that the
greatest existential threat to their country was a woman waiting for her lawsuit to be decided, living in
Tallahassee, walking her dogs, visiting friends.
In late November 2015, however, NSA apparently decided that I was not sufficiently
being intimidated by their civilian confederacy of dunces to back off my lawsuit to
recover my stolen salary and stolen retirement at the appropriate pay level. In 2009
I had researched gang-stalking and discovered it was a real and growing
phenomenon, but when electrical harassment was mentioned, I could not really
grasp the concept and wondered about its existence. But I was to find out first hand
in November 2015 that it does exist and is a horrific crime against humanity.
NSA and its operatives started using small, mobile devices called Directed Energy
Weapons (DEWs) against me and my family in the night. These mobile weapons
emit multiple types of electrical emanations from ultrasonic, to microwaves
modulated to radio frequencies, to other kinds of wave variations I cant say I
understand yet. Now, with the help of certain mercenary and morally depraved
neighbors, the effort is almost 24/7 now with the intention being torture and slowkill. These types of weapons over a lengthy time, cause cancer, autoimmune
disease, heart attacks, seizures, strokes, etc. It is the perfect stealth murder
weapon for a corrupt government. At this point, when we leave the house, a
criminal base of stalkers has been enlisted by NSA to follow us and aim the DEWs at
us wherever feasible to increase exposure in order to speed up death, with the help
of the InfraGard dimwits still texting in my location like good little sheeple.
The Leon County Sheriffs Department as well as the Tallahassee Police Department are dragging their
feet, making excuses, denying any such thing exists, or insulting me when I try to enlist their help to
come up with a strategy to combat this new crime before I or one of my family is dead. They cant
quite grasp the fact that this is domestic terrorism and nothing protects the police or any official from
this new weapon held and wielded by criminals. Yet, plenty of recruits in their ranks have experience
using the mobile DEWs in Iraq. It is very interesting to me that the Naval Security Group headquartered
at Ft. Meade with NSA, is also called the Silent Warriors because they specialize in the use of Directed
Energy Weapons. Im sure the Naval Security Group base in Pensacola has many on hand and may
have even gotten a request from NSA to borrow a few for their secret exercise in Tallahassee.
Clearly, NSA is of the opinion that you do not have Constitutional Rights unless they say you do. If they
Page 36 of 183
173

Page 719 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
158
156
156 of
of308
456
454

June
June 14, 2016
use this to get rid of an inconvenient lawsuit such as mine instead of simply settling for a tenth of the
cost of harassment, then they must feel confident they can murder anyone, anywhere, for any reason
and get away with itincluding any leader or politician.
Sher: Why in the world do you think the NSA simply didnt settle the suit? With all of the
documentation you have, it seems that they are guilty of the discrimination and could have spent far
less of the taxpayers money to simply pay you off and make it go away. They would, also, have
avoided this coming out into the open. Are they that arrogant and Narcissistic?
Karen: This has truly NEVER made any sense to me or any of my friends, even those who worked at
NSA. NSA could have investigated, claimed a mistake had been made and retroactively promoted me
without even addressing the unethical behavior of W&S personnel. Instead, the IG refused to
investigate, illegally of course, but I could not have made him do his job. Plus, the guilty were
instructed to blame me for what turned out to be the first leak by ex-NSA executive Thomas Drake,
despite the fact that I had no access to, knowledge of or training in the type of material he leaked
(computer technology) and he was identified as the source of that leak six months before I was fired.
The polygraph section of Security actively tried to sabotage my polygraph exams in response to the
false counter-accusation by inappropriately screaming and threatening me, making it impossible to pass
a polygraph, which ruined my first polygraph in this regard though I passed the next two of the three
given in reaction to the false accusation.
The EEOC is capped at $300,000 actual damages, no punitive allowed. My intention was to get the lost
difference in my wages as a GS-12 when I should have been a GS-14, and to get the appropriate level
of retirement. Yet, clearly, NSA has spent millions organizing and paying civilians (and greasing the
palms of crooked law enforcement) to harass, bully, intimidate,and quite obviously viciously slander
me.
Do they engage in such psychopathic behavior because they can? Because they simply have no real
oversight? The operational head of NSA Security is indeed rumored far and wide to be an actual
psychopath who is obsessed with paintings of Dantes Inferno.
A coworker who worked in NSA Human Resources says she remembered when the resumes of
inappropriate people (criminals, perverts, mentally unstable) were automatically thrown away but
suddenly when General Hayden, a former NSA Director, promoted this particular man, the resumes of
thieves, moral degenerates, etc., were then coveted by Security. She said that she was so upset that
she had to find a different job. I did read an opinion on the Anti-polygraph site that NSA Security
leadership, and hence all of Security in essence, could be said to suffer from Dark Triad personality
disorder, which is a dangerous combination of such things as (malignant) narcissism, sociopathy, etc.
Their egos are such that they are obsessed with winning at all costseven fighting to keep a known
false accusation from being proven false by their victim, because they exist in their own projected
narrative. They exist in their own lies and cannot stand being exposed. This means they follow their
own agendas. What is good for NSA Security leadership, even at the cost of NSA or the USA. Their
Page 37 of 183
173

Page 720 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
159
157
157 of
of308
456
454

June
June 14, 2016
allegiances are to themselves. This has made me wonder, of late, if the woman who Security protected
instead of reprimanding or firing for sexually compromising W&S management was not a Security plant,
meant to do just that. And, in so doing, was NSA Security procuring a means to blackmail these
managers for themselves or another entity, perhaps foreign?
Sher: You have multiple photos and even drawings youve made of you stalkers. Youve also indicated
to me that the NSA has been in touch with your local law enforcement. Said law enforcement is siding
with the NSA against youa private citizen. What do your attorneys have to say about these?
Karen: At the beginning of my search for a law firm to take my case, Melville Johnson PC informed me
that I had potentially two cases, in 2009, an employment law case and a criminal case. I could only
afford to pursue the employment case since I was facing illegal termination on false pretenses within a
few months. While my lawyers have recorded the information about the new assault campaign by NSA
in Florida, thus far their pleas with the EEOC for some kind of response because their client is now in
physical danger have been completely ignored.
What has been going on in Florida is entirely criminal and could be a separate lawsuit, to even include
law enforcement in regard to their depraved negligenceif not complicity. But, at the moment, I am
concerned with surviving the relentless Directed Energy Weapons assaults. If I do not, then my family
will have to consider a wrongful death lawsuit against NSA, FBI (that refuse to get involved because
NSA is involved), and the FDLE, the TPD and Leon County Sheriffs Department as well as certain
complicit neighbors accepting a new riding mower or new carpeting in exchange for helping NSA
murder an inconvenient person who actually thought she had any Constitutional, human, or Civil
Rights.
Sher: With regards to your lawsuit, what are your current plans?
Karen: Good question. Reporting and recording the new barrage of assaults has whittled deeply into
my retainer. This was hard enough to maintain after spending about $110,000, thus far, and often
countering ridiculous and frivolous legal shenanigans by NSA to waste my money. With an outrageously
unresponsive EEOC, which may indeed be a complete and obscene sham for show, one wonders why
continue with the pretense that we exist as a nation of laws? Clearly, we do not.
The government has no desire for a level playing field to impede its quest for complete tyranny. We are
now a nation of wolves and sheeple. Im sure that after getting wind of this article, NSA will come to
the EEOC with big crocodile tears claiming they need to win by default because I broke the gag order
after they themselves spent millions, bald-faced lying to thousands of civilians, law enforcement and
(apparently) the FBI about me, invoking National Security Letters to swear them to secrecy and to hide
the true nature of their faux secret exercise in Tallahasseei.e., enticing a foolish community to stalk,
harass and commit murder for Big Brother.
But, God forbid the victim would speak out!
It truly sickens me that I spent my career trying to protect and serve my fellow Americans when not
only my government but these unworthy mercenary, sociopaths have stabbed me in the back. Some of
Page 38 of 183
173

Page 721 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
160
158
158 of
of308
456
454

June
June 14, 2016
the stalkers have even been Iraqi War veteranssome of whom might not have returned alive without
my reports.
I cant think a lot about the lawsuit with each nocturnal assault leaving me wondering if I or one of my
family will not wake up tomorrow. Im sentenced to death for being a patriot. What a country. I read
Psalm 91 & 94 nightly, praying God will want to erase this growing evil from our country. But, I also
remember that Ruth Graham said a while ago, if God doesnt judge America, Hell have to apologize to
Sodom and Gomorrah.
Americans are just not the people they and we used to be and, therefore, our leaders are either
apathetic cowards who tolerate evil or potentially monsters like NSA Securitywho show that they can
be and are not responsible to anyone but themselves.
Is NSA Security even able to be reined in anymore? Or would any potential leader be found dead of a
microwave induced heart attack if he tried to? Someone ought to care but I may not be around long
enough to see it.
Sher: Thanks you so much for all youve done and I sincerely hope and pray youre wrong, Karen. Its
individuals like you who founded the United States of America on Godly principles and an unwavering
sense of ethics.
*Karen may be contacted for interviews at kams56@ME.com
Page 39 of 183
173

Page 722 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
161
159
159 of
of308
456
454

June
June 14, 2016
StanJ. Caterbone
Freedom From Covert Harassment &
Surveillance,
1250Fremont Street
Lancaster, PA 17603
717-669-2163
Greg Szymanskis Interview

With Julianne McKinney
Microwave Harassment and Mind Control
Transcribed for Advanced Media Group,
05/28/16
This interview contains information from Julianne McKinneys book Microwave Harassment and
Mind Control Experimentation, 1992, as well as current conditions world-wide. Years of
interviews turned Gregg Szymanski from skeptic to believer in the secret world of electronic
harassment, as harassment against Julianne McKinney has turned potentially lethal. They are
taking a stand to help TIs, Targeted Individuals, many civilians, escape this cruel harassment.
Julianne: Okay. I have seen evidence of a closed circuit TV and it seems to be some form of major
source of entertainment and perhaps instruction for the individuals participating in this harassment. I
dont know who runs it. I have seen aspects of that on a large screen TV across the street on which I
saw surveillance films of a TI being harassed, obviously, in an office environment. Gang stalked. Shows
brain scans and is otherwise a very sophisticated, sleek, communications operation. Why would it be
used? As I said either for entertainment, for creating a sense of unity, or for identifying persons, TIs,
who are to be harassed on the street. I mean, obviously you cant harass someone if you dont know
what that person looks like. So its a means of communicating to the perpetrators, perps, what the TI
looks like.
Page 40 of 183
173

Page 723 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
162
160
160 of
of308
456
454

June
June 14, 2016
TRANSCRIPT OF GREG SZYMANSKIS INTERVIEW WITH JULIANNE MCKINNEY

ON MICROWAVE HARASSMENT AND MIND CONTROL
Published May 28, 2016
Greg Szymanski:
(Also) I have a guest whos never given a radio interview before. Her name is
Julianne McKinney. For those of you who dont know who she is, she is an expert in electronic
harassment and surveillanceformer military background. And those of you who have followed this
story on my show, many may know who she is and the importance she has in this field.
Were just going to lay some very solid credibility to what weve been talking about. So this interviews
quite important and I want you to remember that, as we go along, shes a very, very well-read person.
Were gonna get to that in a minute. The problem on the use of electronic weaponry on a person was
when I was working in a law office. The law office I was working for severaloh a number of years ago,
the law office I worked for prided in taking cases that were difficult. And I listened to a person tell me
about the facts regarding the use of electronic weaponry. And I had a discussion with somebody else at
the law firm and we came to this conclusion causation causation causation Greg, remember that
element. Its going to be awfully difficult to link whats happening to the person. The injuries they were
alleging, to actually the person, or the defendants, that were doing it.
So it was a case, Ill be very honest with you, that I was very skeptical over. But, as a journalist, I
started to interview a number of people, and I would like to say that this issue, after a number of years,
has come up to one of the top of my list as a problem in this country.
I talked to hundreds of people all around the country that are experiencing things that are just
unbelievable. And from a standpoint of the law, you want to get justice for these people. You hate to
see their lives destroyed, and you hate to see what happens, to a person thats been harassed. But the
biggest problem is its very difficult to pinpoint whats going on.
I have a guest today who is an expert in this field. You, the public, may not know who she is. But those
of you who have been targeted and listen to my show know very well. Shes never been interviewed
before and I feel honored that shes here. Her name is Julianne McKinney. Shes had an extensive
career in the US Army as an Area Intelligence Case Officer till 1990.
Upon her return to civilian life Julianne became a member of the Association of National Security
Alumni. That is an organization of former intelligence officers dedicated to exposing excesses by the US
Intelligence Services. Julianne became the director of the Electronic Surveillance Project under their
auspices
as
such
she
authored
the
publication
Microwave
Harassment
and
Mind
Control
Experimentation in 1991. She kept that electronic surveillance project going for four years, funding it
with her own personal funds, obtained by her military benefits and pay.
Page 41 of 183
173

Page 724 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
163
161
161 of
of308
456
454

June
June 14, 2016
Julianne did not copy write her work and it is out in the public domain for the public good. Microwave
Harassment and Mind Control Experimentation, the public has taken her hard copy publication and
uploaded it to several thousand domain sites over the past 15 years. It is respected as one of the most
important publications on this subject. And with that, Id like to say hello, Ms. McKinney, how are you
today?
Julianne McKinney: Please dont call me Ms. McKinney (laugh).
Greg: Okay, can I say Julianne?
Julianne: Yes, Julianne.
Greg: Now, youre an expert in surveillance and electronic harassment. The first question I have is
that, in your observation, is there a wider scale of surveillance of average people, people with no threat
to national security, in your estimation?
Julianne: I would say that most of us targeted are not, and never have been, a threat. I think that
what happened initially, when these operations began probably 30 years, ago people were singled out,
perhaps, because of some affiliation, either direct or indirect, with the United States government, and
invited attention. But they were not singled out as being a threat; they were singled out as being
lucrative targets of experimentation.
In the past 15 years, since shutting down the Electronic Surveillance Project, primarily to seek
employment, which I did seek, and did obtain, I had occasion to observe many, many, many instances
of individuals in the corporate environment being singled out and targeted simply because they were
convenient targets of opportunity. And, I have to comment on something I heard you say
Greg: Okay
Julianne:
Early on you referred to the difficulty of establishing causation in order to pursue these
claims.
Greg: That, I might add, that was made is a legal sense, based on the fact that we were nave people,
not really understand I have to be honest with youI had not understood the problem back then,
and felt it would be a difficult problem, based on the fact of how the crime was committed and knowing
how to pin that crime on someone. Go ahead.
Julianne: I understand the legal implications, certainly. There is enough literature, on the internet and
elsewhere, that establishes the existence of these weapon systems. To pinpoint, for purposes of
prosecution, to pinpoint their existence would be difficult and the position I take is that rather than
pinpoint for prosecution purposes, easy enough to single them out by electronic means to destroy
them. But I guess thats taking the matter a little far left field.
I think, frankly, we still face, until congress establishes laws that forbid the use of these technologies
for involuntary experimental purposes, that were going to get absolutely nowhere in attempting to
prosecute.
Greg:
Okay, listen, I need to take a break Julianne. And well be back in three minutes on the
Investigative Journal.
Page 42 of 183
173

Page 725 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
164
162
162 of
of308
456
454

June
June 14, 2016
Julianne: Okay.
Greg:
Okay, back for the second half hour. My guest is Julianne McKinney. Shes an expert on
surveillance and electronic harassment. And Julianne, I gave you an introduction at the beginning of the
show.
Julianne: Yes
Greg:
A brief introduction. But I think our listeners would like to know your background and why
youre qualified to make these statements. I think its important.

Julianne: Okay.
Greg: If you could do that for us.
Julianne: Well, I would take exception to the term expert in these weapons systems.
Greg: Okay.
Julianne:
I certainly have had experience with them, having, for approximately the past 40 years,
been on the receiving end of this type of harassment. Expertise in surveillance comes with my
employment in the intelligence field. I understand what constitutes surveillance and am capable of
immediately spotting the surveillance and I can see, as in the case of gang stalking, a subject that you
have addressed on prior occasions. I can see those who I label as covert want-to-bes fumbling through
what they think are covert activities and Id find it really rather amusing if it werent so perverted in the
ultimate objective.
Im not certain what more I can add. I do have experience with these weapon systems. Ive had
sufficient opportunity over these past many years to observe the progressive threat of these
harassment operations. And Im talking specifically about electronic weapon systems.
Greg: Well, youve been a voice - I mean a strong voice - for warning people of these systems for at
least the past 10 years regarding the installation of specialized electronic equipment and utilities. What
are these electronics and what are their capabilities?
Julianne:
Their capabilities, generally, are to inflict pain in a highly focused fashion, and to alter
mental states. Certainly, when you have a frequency aimed at your brain, your mental functions tend to
alter. In amplified form, theyre sufficient, the frequencies are. They have the capacity to kill. Though
thats one reason the department of defense refers to them as less than lethal rather than nonlethal weapons. As a matter of fact, the Department of Defense has gone so far to eliminate them, to
remove them from the category of even less than lethal weapons to bury them in the category of
electronic weapons trying to make them a little bit blacker.
Greg:
Now is this protocol of surveillance and harassment seemingly patterned after a government
protocol now applied to the general civilian population?

Julianne:
Its difficult to pinpoint everything on the US government exclusively because these are
global operations.
Greg: Okay.
Julianne:
The pattern the protocols, are virtually identical on a global scale so someone is
Page 43 of 183
173

Page 726 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
165
163
163 of
of308
456
454

June
June 14, 2016
overseeing the entire activity. The government obviously is complicent because otherwise these
operations would not be allowed to exist. Why? Its hard to say. Whether its for testing electronic
weapon systems for future use under combat conditions or whether ultimately there's a holocaust. (nointelligible) Its hard to say.
Greg:
Well, you know what I find interesting.how people who arent aware of this problem cant
believe its happening to begin with. And I try to mentionI have run stories about the Duplessis
Orphans. Its a program thats been verified, that the government actually used money in Canada and
the United States to do medical testing on children, on adults. Ive talked to people on the POW issue,
one Dr. Joe Douglas, who has documented how, that our government has done allowed foreign
governments to do illegal experimentation on POWs. So why would people think that they wouldnt
allow it on just average citizens? Just in your mind. Do you have an answer for people?
Julianne: Why wouldnt they allow it?
Greg: Yeah, my thing is that they do it, theyre doing it. But some people that deny it cant believe
that our government would do something like this.
Julianne: I find, even among the community of, I hate using slang terms, but the term TI is common,
referring to targeted individuals. Those are people who know they are on the receiving end of electronic
weapon systems. And even amongst TIs, there is a perception in certain areas that our government
wouldnt do this; a case of not recognizing reality. First of all if this were not being done by our
government, congress would step in because of the hundreds of complaints they have received,
thousands of complaints, no doubt, over the past 10-15 years, from citizens who recognize whats going
on. Congress, back in the early 90s, late 80s, took the position that anyone complaining about these
systems were imagining things because they simply didnt exist. In two years, by 1992, they were off
the drawing boards, and in fact, being fielded and conveyed to law enforcement agencies.
Congress recognizes that these weapon systems exist and funds them, and knows, as a result of
appropriate briefings, what the bio-effects can be. Yet they have passed no legislation prohibiting their
use under unconstrained experimental circumstances.
Thats number 1. Number 2, given the nature, given the nature, given that the systems draw on
existing power grids, it would be necessary for the FCC at a minimum, and the Department of Energy,
as a minimum, give some oversight and control over what is going on. Though obviously, those with
Congress, the FDA and the Department of Energy, the FCC and the Department of Energy are
knowledgeable and yet unwilling to do anything about it. So, there is complicity, but the question is,
whos knitting, and submitting, the US government, allowing these operations to take place?
Greg: Now from your experience, how intense is this surveillance of targeted individuals? And tell us
about the ways that the targeted that this is accomplished.
Julianne: From what I have observed, first of all I should explain that the standard that I address this
in Microwave Harassment and Mind Control Experimentation, it was a pattern that was unfolding as I
was dealing with other targeted individuals whothat contacted me. It was a pattern of harassment
Page 44 of 183
173

Page 727 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
166
164
164 of
of308
456
454

June
June 14, 2016
which indicated that there had been some surveillance going on, some monitoring of their private lives.
There had been entry into their houses. There was systematic harassment. And then, ultimately, as part
of a softening up process, and then ultimately, electronic harassment, which followed; which would
include the inducement of auditory input, which is now being referred to as Z2K.
In answer to your question (laugh) Im not certain if I I think Im probably missing the point there,
but in order to target someone, it requires that that person be put under surveillance, so that their
personality traits, their capacity to inter- relate with people, their capacity for corruption or noncorruption, that seems to be a critical point. And even their religion factors into it.
Following a period of harassments, they are singled out for preliminary stages of harassment which
includes gang stalking, entry of their private homes or apartments, followed by gradually intensified
and ultimately extremely intensified electronic harassment. This is the pattern that has unfolder over
and over and over.
Greg:
And so, when you, I guess what Im getting atthats a very good answer. Youre seeing a
pattern amongst these individuals. I guessyeahis there any pattern about how they choose them?
Julianne: I cant speak for men. But it appears that quite a few of the women who have been singled
out appear to be somewhat, too independent; perhaps too intelligent. Tend to live alone or tend to
pursue professional careers. Theres a heavy predominance of those types of women in the TI
community, the community of targeted individuals. Men are in a smaller proportion and seem to be
those who have a propensity to fly off the handle. Have a sense of self-esteem and pride that seems to
invite targeting. And I did mention a curious predominance of a certain lack of religion amongst TIs, as
opposed to a certain predominance of a particular religion amongst those who are participating in these
operations.
Greg: Now you mentioned this was a global problem. Have you communicated with people from across
the Atlantic regarding whats going on in other countries? Is it similar to here?
Julianne:
Its virtually identical, virtually identical. When I was running the electronic surveillance
project I was in extensive correspondence with people overseas and patterns were the same. The
nature of the gang stalking and harassment were the same.
Greg: Now, when youre talking about specific numbers I know youreyouve been following this for
years and years and years. Is there any way that you can give our listeners a kind of an idea of how
wide spread this problem is in terms numbers in our country and compared to maybe overseas?
Julianne: I would say that the person who has realized what is going on is just a drop in a bucket. The
persons whom I have seen being targeted are completely unaware of whats happening. So those who
are complaining of this are, as I said, the tip of the iceberg. I would say this is very, very, widespread.
But I cannot under the circumstances come up with any figures. Many, many, many thousands, no
doubt, are involved. But I would say that the bulk of them are running to their doctors and taking
totally unnecessary prescription drugs to cure ailments that dont exist.
Gregg: I guess that you have to ask this question even though its very difficult to answer. And you
Page 45 of 183
173

Page 728 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
167
165
165 of
of308
456
454

June
June 14, 2016
mentioned, you said it earlier. But I really have to ask it because its on my mind and I know its always
in the back of everyones mind when they think of this problem. Why?? What is the major reason, I
mean, outside of just pure experimentation Im interested; for example, lets say that they have
targeted 100 people in Oklahoma. What do they, first of all, why are they doing it? Is it for, basically, a
blanket statement controlling the population? Orand, what do they do with this information once they
get it?
Julianne: I dont think they do anything with the information once they get it, other than to establish
a harassment protocol which will follow that targeted individual for the rest of his or her life. Why are
they doing it? I see a number of reasons. First, I dont know if youve done any research on the
phenomenon of capturing a percentage of the population in order to install a dictatorship. There is
always a percentage of the population, roughly 20% or so, that will buckle and throw whatever
constitutions might exist into the toilet and eagerly join the efforts at destroying the remainder of the
population.
Part of the problem or part of the objective they are seeking obviously is testing the latest and greatest
in electronic weaponry and other forms of technologies. A part of it is to control and choreograph those
who are involved in these harassment operations on the dispensing end. And it would appear that those
being targeted are simply objects who I see as ultimately being disposable. In other words, I think that
once full control is established over a major percentage of the population, and enough of the population
is silenced and unwilling to stick their necks out, that we inevitably would be heading toward a
holocaust.
Greg: The question, if I was, for example, lets say we have a person, who suspects, and lets just for
hypothetical purposes, say this person is being targeted, okay? Now, tell our listeners, because Ive
always wondered this myself, okay. Im sitting in my house and I see around me theres telephone
poles, there may be a tower in the distance that I dont see that handles the cell phones. Theres of
course a grid of electric going on around me. Ive talked to people and I try to say, how does this get
into your house? And I wanted to get your opinion, if a person is targeted, how basically are they
beginning to intrude their premises, and violate their constitutional rights, not only their rights ofnot
only trespassing on their property? Go ahead. How would that happen?
Julianne: Now, are you talking about, how would the frequencies impact upon them and how would
they first become aware of it? Or how would they first become aware of the fact that their privacy has
been violated?
Greg: Well no, I guess I didnt explain the question right. I wanted to know how they physically, are
doing it? I mean are they using a cell tower? Are they using a truck thats in the distance? How is this
being transmitted into the home to target the person and to use this weaponry on them, from your
experience?
Julianne: Well, first of all, in order to target a person you have to be able to see that person. And
while they may not be able to, they may, on entering the house, plant miniature cameras, miniature
Page 46 of 183
173

Page 729 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
168
166
166 of
of308
456
454

June
June 14, 2016
microphones, as a means of, for their monitoring a person. But that is not necessarily the means by
which they hone in on a person. There are plenty of technologies that allow for the imaging of a person
that might be sitting in a chair, as you mentioned you might be.
Using infrared imagery techniques, for example, they can capture your image by monitoring the
concentration of heat emanating from your body using certain acoustical frequencies, they can detect
mass. And using sophisticated computer software, they can convert those images to likenesses on
computers, which conceivably could be used in a software program that could be connected to an
electronic weapon system. And in that context I should point out that, while devices draw on the
existing power grid, and while theyyes indeed, they do involve microwave towers
Sounds like youve got a commercial coming on
Greg:
Yes we do, and thank you for making my job easier. Well be back in 3 minutes on the
Investigative Journal.
First, Ive put this in the top 3 of my stories that I believe are important, that the American people need
to deal with, because as Ms. McKinney, who is a, I consider her an expert. She would only say shes an
authority. But let me tell you, Julianne, you are an expert in this. The reasons could be, like she said at
thebefore we went into the break, and a total testing of our population to see, basically, perhaps
maybe there is a holocaust in the future or a dictatorship in the future. And they want to see how
people react to it. That may be a simplistic way to look at it. Not a simplistic way that Julianne looked at
it but my way of explaining it.
But lets get back to some of the things here, the last few minutes that are important. What can you tell
us, Julianne, about the microwave energy on citizens in terms of the existence of such a program and
the nuts and bolts of what they do?
Julianne:
Microwave energy is only one aspect of the entire electromagnetic frequency spectrum.
Microwaves can be lethal depending upon how theyre used. Obviously in order to achieve appropriate
effects on people, they have to be pulsed, because otherwise the individual would be cooked from the
inside out. The objective of using microwaves as opposed to other electromagnetic frequencies would
be to inflict extremes of pain to cause thermal heating. Thats a common complaint which leaves a hot
spot on the scull. Again, primarily, just to inflict extremes of pain. I was just wondering, we kind of
skipped over or didnt quite complete a preceding topic.
Greg: Oh, go ahead, go ahead. Youve got free reign.
Julianne:
You were talking about the use of the electrical grid throughout the country, the use of
microwave towers, the use of devices affixed to poles that are connected to power lines. But what
wasnt addressed, what you havent mentioned, is also that these weapon systems are used by
neighbors surrounding persons who have been singled out as targets of opportunity.
Greg: Are they solicited to do this or what?
Julianne: Thats something that Ive been pondering for some time. Again, what Ive noticed is, there
seems to be a predominant, particular religion that makes it particularly easy for them to cooperate.
Page 47 of 183
173

Page 730 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
169
167
167 of
of308
456
454

June
June 14, 2016
Greg: Well listen, lets talk about that after the break, a short break, and then Ive got something to,
some business I have to take care of for 3 4 minutes. Then well get back for our 2 nd hour with
Julianne McKinney. Well take some calls. Back in 2 minutes on the Investigative Journal.
(In this section there seemed to be jumping around, like maybe the video was edited or there was
some problem with the recording.)
by some of the Tis and thats Targeted Individuals.
That song rose to number one without any publicity on the internet. And that song called TI, well play
that again Dr. McKinney. I think it hits the nail on the head. I mean theres a lot of people out there
suffering. And I know youre one person, an authority in this field. And for my guests who are just
picking us up this hour, Dror excuse me, Julianne McKinney is a very highly regarded person in the
field of electronic weaponry, and surveillance in studying this issue. Shes a former area Intelligence
Case Officer until 1990 in the Army. And her credentials can be found, will be found, you can go to
RBNLive.com and go to my archives in the Investigative Journal and read about that. Shes well
qualified. Shes still with us this hour. And Dror excuse me, I keep calling you Dr. and you should be.
Julianne: (Laugh) Im not a Dr., thank you. Dr. Americus.
Greg: Dr. Americus. You know, thats funny. I have a doctorate in law. And nobody ever calls me that
and I hate being called that, a doctor. But Im interviewed on a Tehran TV station once every blue
moon, couple months, and they refer to me as Dr. Szymanski. And its nice to hear once in a while. Ill
be honest with you. Every two months is good enough. Otherwise they just call me the jerk on the
radio, which is better.
But, lets go from here. Youre adding such credibility to this story, adding credibility in my mind as I
speak. Because, Ive talked to hundreds of these people and was a doubting Thomas in the beginning. I
must mention that. I did not think it existed, and that was years ago. I thought people were either
insane, or crazy, or trying to get attention. But you know something? I will admit I was totally wrong
with that initialI guessthe look at the situation and have come around to fully believe in most of the
people I talk to and really sympathize with their suffering as I see their lives being ripped apart.
Are there any things you can dowere going to get into a few more things here as far as the technical
aspects of this but what can targeted individuals do to get some peace in their life? I mean thats one
thing theyre looking for. Is there anything they can do?
Julianne: (prolonged silence)
Greg: Difficult question there.
Julianne: Its very difficult to advise targeted individuals how to acquire peace. These frequencies can
be blocked or deflected. All of these frequencies I have found, some may contest this, but I have found
can beare vulnerable, and are subject to deflection. And the pain can be immediately (word unclear),
if not halted all together. Finding peace by writing to members of congress or to state legislators might
not be a better alternative because you will be treated as something worthy of the circular basket. They
just wont intervene. Writing to the various agencies and calling a meeting with them serves no useful
Page 48 of 183
173

Page 731 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
170
168
168 of
of308
456
454

June
June 14, 2016
purpose either because they will say there are no laws prohibiting these types of activities. They cant,
say for example, the FBIand I was given this statement on a number of occasions.there are no laws
prohibiting experimentation with these weapon systems. Youre talking to the wrong people.
So my advice would be to do what you can to secure your premises, because so long as your house is
or apartment is being entered, you are susceptible to, in addition to being targeted by electronic
weapons, there is a potential for having drugs put in your food. And Im not exaggerating there.
Greg: I had a few targeted individuals I talked to send me some questions that Id like to ask you.
Julianne: Certainly.
Greg: And the one was Are targeted individuals also broadcast around the country via closed circuit
TV? And, What purpose does this serve? Im fully in the dark on this question, but, go ahead.
Julianne: Okay. I have seen evidence of a closed circuit TV and it seems to be some form of
major source of entertainment and perhaps instruction for the individuals participating in
this harassment. I dont know who runs it. I have seen aspects of that on a large screen TV
across the street on which I saw surveillance films of a TI being harassed, obviously, in an
office environment. Gang stalked. Shows brain scans and is otherwise a very sophisticated,
sleek,
communications
operation.
Why
would
it
be
used?
As
said
either
for
entertainment, for creating a sense of unity, or for identifying persons, TIs, who are to be
harassed on the street. I mean, obviously you cant harass someone if you dont know what
that person looks like. So its a means of communicating to the perpetrators, perps, what the
TI looks like.
Greg: Okay, now, before I get to some more, I want to put out that call for people to call. I got a
couple emails. A lot of times Tis dont want to go public. And theyve sent me some emails. I want to
get to one in a minute. But one question I have for you is, how can people gather evidence to support
their beliefs that this is happening to them? Many people will say, well its only a lack of sleep. I mean,
you have a sleep disorder. Maybe theres a problem with your joints, I dont know. It could be anything
that the answers are when you suspect youre being targeted. What kind of evidence do you tell people
to gather to support their beliefs that this is actually happening to them.
Julianne:
Well, when youre gathering evidence, obviously you have an objective in mind and that
generally is legal. What you want to do with that evidence. Theres really nothing you can do with it. So
in the absence of that, the main thing is to try to protect yourself and to alleviate the pain that youre
experiencing. Collecting the evidence, if you were to go to, frankly, Id strongly recommend that you
keep your faculties together and avoid going to see psychiatrists and psychologists, because the pattern
that is evolving is that they are highly complicit of these operations.
And if you go to a medical doctor, you do not talk about it because medical doctors, many, are also
involved. What you do when you see a doctor is that you define your symptoms and get a very clear
statement that, well, we cant figure this out. Well, thats a clear indication that it is not indigenous,
its not part of your system. Its not coming from within you, so obviously something is happening from
Page 49 of 183
173

Page 732 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
171
169
169 of
of308
456
454

June
June 14, 2016
outside. If they prescribe drugs and yet cant find the ecology, the basis for your disease, dont take
those drugs.
Greg:
Now earlier we were talking about the fact that they may, whoevers doing this, youve
delineated, youve led a good course into whatyoure tracking these people. But what I was getting at,
we never got to the point where ifyou mentioned something about a religious group that may be
targeted. What did you mean by that?
Julianne: The way I dont.well let me put it this way. Im not out to start a religious war. I have
found over the years that the persons involved, both in gang stalking.Ive made it a point to get to
know these people. Ive had to necessarily. Im not the type to
Greg: Youre talking about the perpetrators or the targets?
Julianne: The perpetrators.
Greg: Okay
Julianne: As well as theIve been drawing distinctions. And what Ive found is that the perpetrators
appear to belong predominantly to one particular religion; whereas the targeted individuals do not
belong predominantly to that particular religion.
Greg: And what is the particular religion of the perpetrators?
Julianne:
Right. So, at this stage, again, Im not particularly enthused about the idea of starting a
religious war. And I have challenged other TIs to get out there and become acquainted with, and get to
know, the people who are harassing them, to draw those distinctions themselves, because Im not
going to be making brash claims. This is something Ive observed over the past 10 years.
Greg: Thats fair enough. And maybe, perhaps, I could talk to you about it just for my own knowledge
off the air.
Julianne: That would be fine.
Greg: And I will keep your name out of it at that point and let people know what the targeted group
may be and what the other group may be.
Julianne: There is a religious influence but thats not to say these people arent just being used as
puppets by some broader interest.
Greg: Very good point. Can you stick with us one more segment of 5 minutes?
Julianne: Okay.
Greg: Were interviewing Julianne McKinney, our last segment. Juliannes an authority in the use of
surveillance and electronic weaponry. And this is an email question, kind of a technical one from a TI.
Let me read this to you. Perhaps you can answer it. Are the protocols for each individual modified based
to custom tailor it for the specific targeted individual? And if so, how does this process work?
Julianne: Yes indeed they are modified. There is a basic protocol that the perpetrators begin with. But
the TI contributes to the modification. A good example of that would be, if someone. Im trying to
think of a good example. If the TI feels the need to cooperate, even in the most subtle fashion, with the
persons who are harassing him or her, he or she will modify his behavior, in pathlobean condition, which
Page 50 of 183
173

Page 733 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
172
170
170 of
of308
456
454

June
June 14, 2016
alters the protocol. Theyre constantly, targets are constantly monitored, and if they respond
emotionally to a particular trigger, that will be built into the protocol. If the target displays a certain
sense of guilt or embarrassment about a subject, that will be built into the protocol. Its an ongoing
process. And one thing I want to emphasize is no TI should look for a reason as to why this is going on.
Its a serious, serious mistake. I know I did that myself when they started on me and over the years I
came up with probably 6 different excuses.
Greg: Is it still going on with you?
Julianne: Oh yes. Not to the degree that it was before but certainly in very lethal form.
Greg: Now, how has this hampered your life?
Julianne: Its come close to being lethal on a number of occasions. I deal, I dealt with gang stalking
head on and I essentially put that to rest. I deal with.Ive developed a means for communicating with
perps directly and made them feel like the trailer trash that they are. So gang stalking is not one of
their favorite activities in my case. So the primary activity now is to see what I can survive in the way
of an induced brain aneurism or stroke or a heart attack.
Greg: I just had a caller who doesnt want to get on the air but wants to know, does moving help;
moving your location?
Julianne: Running, if youre talking about moving to a completely new location, no. This country is
wired to the hilt for immediate transfer. Your protocol follows you wherever you go so its a waste of
time. Moving about physically in place will not change anything. Other than, if you make a 180 degree
turn you will notice the targeting will suddenly stop because the weapon systems are programmed to
focus on a particular area of your anatomy. So if you turn, the targeting will suddenly end. If you turn
back itll hit you again.
Greg: Interesting. Now, going full circle in the last 2 minutes here, in 1991 you published Microwave
Harassment and Mind Control Experimentation. This has been passed around the internet and over
thousands of domain sites over the past 15 years. Can you tell us how someone can get ahold of this
publication to be informed?
Julianne: Its not copy-writed. All they need to do is plug in my last name, McKinney, and type in the
title Microwave Harassment and Mind Control Experimentation and innumerable sites will appear and
just read it from there. It will give you a good insight into what the pattern is when harassment begins.
Greg:
Now, let me just spell your name for people that are going to do that. Thats MCKINNEY
McKinney. And then its Microwave Harassment and Mind Control Experimentation for an authority in
the field.
I guess since 1981, have you seen.I guess a question I wanted to ask, from 2001, have you seen any,
from the time of 911, has there been an increase in the last 4or 5 years, with this type of, that youve
seen, in the number of people contacting you. Has it been more wide spread since 911?
Julianne: Not since 911. WhenI would say back in the early 90s Ive seen a tremendous expansion
of these activities since the early 1990s. And it has moved forward in consistent fashion. Its become
Page 51 of 183
173

Page 734 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
173
171
171 of
of308
456
454

June
June 14, 2016
ever more sophisticated and ever more wide spread. There was no sudden burst or flurry of activity
since 911.
Greg: And you have no help whatsoever with the political arena in this. Correct? Politicians will not
touch this with a 10 foot pole?
Julianne: Thats right. And even those who purport to be liberally inclined, and Im speaking about
members of the democratic party, will not touch it, because quote unquote, and they know, they know
whats going on. They dont they simply dont have the funds to be able to pursue it. All sorts of
humma humma excuses will be furnished for not pursuing something like this. Before you close.I hear
the music in the background.
Greg: We can stay another minute if you want.
Julianne: Okay.
Greg: Why dont you come back for 2 minutes on the other side of the break and then well finish up.
Okay?
Julianne: Okay.
Greg: Okay, back with Julianne McKinney and 3 minutes on the Investigative Journal. You wanted to
say something at the break.
Julianne: I did. I want to thank you very, very much for taking on this subject. There are so few in the
media, as a matter of fact, youre the only one I know of, who has the guts to address it.
Greg: And you know, it really doesnt just in defense of every other media person. I dont think its
guts, in a sense, maybe it is. I dont consider myself having guts in this issue. I consider it to be an
issue that you need to take time to understand it. And thats what I would recommend to the people in
the media that havent touched this issue. If it isnt being down right censored by someone above you,
at least take the time to talk, Ill spend time talking to you about it. Because it took me a little time to
figure it out. And, Ill tell you what, its people like you that need to be applauded because its your
efforts that are bringing this to the forefront. Youre laying the credibility on the line. But I thank you
anyway for your kind words.
And with that, I wanted to say goodbye to you. And were going to have to move on. And well have you
on again to talk about this. And thank you so much.
Julianne: And thank you so much.
Greg: And that was Julianne McKinney. And she is an authority in the use of electronic weaponry and
microwave weaponry and she was with us for the last hour and a half.
Page 52 of 183
173

Page 735 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
174
172
172 of
of308
456
454

June
June 14, 2016
Dr. Nick Begich Author and Expert Researcher

of Electromagnetic Weapons
Biography
Dr. Nick Begich is the eldest son of the late United States Congressman
from Alaska, Nick Begich Sr., and political activist Pegge Begich. He is well
known in Alaska for his own political activities. He was twice elected
President of both the Alaska Federation of Teachers and the Anchorage
Council of Education. He has been pursuing independent research in the
sciences and politics for most of his adult life. Begich received Doctor of
Medicine (Medicina Alternitiva), honoris causa, for independent work in
health and political science, from The Open International University for
Complementary Medicines, Colombo, Sri Lanka, in November 1994.
He co-authored with
Jeane Manning the
book Angels Don't Play This HAARP; Advances in
Tesla Technology. Begich has also authored Earth
Rising - The Revolution: Toward a Thousand
Years of Peace and and his latest book Earth
Rising II- The Betrayal of Science, Society and
the Soul both with the late James Roderick. His
latest work is Controlling the Human Mind - The
Technologies of Political Control or Tools for Peak
Performance. Begich has published articles in
science, politics and education and is a well
known lecturer, having presented throughout the
United States and in nineteen countries. He has been featured as a guest on thousands of radio
broadcasts reporting on his research activities including new technologies, health and earth science
related issues. He has also appeared on dozens of television documentaries and other programs
throughout the world including BBC-TV, CBC-TV, TeleMundo, and others.
Begich has served as an expert witness and speaker before the European Parliament. He has spoken on
various issues for groups representing citizen concerns, statesmen and elected officials, scientists and
others. He is the publisher and co-owner of Earthpulse Press. He served as Tribal Administrator/Village
Planner for the Chickaloon Village Council, a federally recognized American Indian Tribe of the
Athabascan Indian Nation for five years and served four years as the Executive Director of The Lay
Institute of Technology, Inc. a Texas non-profit corporation. Currently Begich consults for tribal
organizations, private corporations and others in a number of research areas.
Dr. Begich is a single person with five adult children, and four grandchildren.
Page 53 of 183
173

Page 736 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
175
173
173 of
of308
456
454
1
June
June 14, 2016
Covert Harassment Conference

1-2 October 2015, Berlin, Germany
2
3
Mind Control:
4
5
DR. NICK BEGICH

A Brave New World together with HAARP The Update
DR. BEGICH:
Hello, and thank you for being
here and thank you to Peter and the rest of the team for
putting this together.
8
9
Everyone hears me okay, yes?

Okay.
In the back?
Good.
10
All right.
I want to give a little bit of
11
background in terms of my interest in these areas.
12
those that don't know my family story, it really goes
13
back quite a ways.
14
For
My father was in the United States Congress in
15
the early 1970s during the Nixon Administration.
16
lost in a plane with Hale Boggs.
17
remember this if you've got a little bit of gray hair.
18
Hale Boggs was our House majority leader at the time,
19
one of the most powerful people in the United States
20
Congress.
21
strong dislike for J. Edgar Hoover, because he basically
22
read everybody's mail, tapped everybody's phones,
23
including the United States Congress, and then,
24
essentially, blackmailed political leaders to follow
25
whatever script he laid out.
Some of you may
He was also a Warren Commissioner.
Page 54 of 183
173
He was
He had a

Page 737 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
176
174
174 of
of308
456
454
2
June
June 14, 2016
Boggs was a pretty outspoken individual.
At
the time -- it was just before the second election of
Richard Nixon -- Boggs came to Alaska to work on my
father's campaign, which would have been his second term
in the United States Congress.
Boggs, before they flew out on October 16th,
three weeks before the second election of Richard Nixon,
began to talk about this scandal brewing in Washington,
DC.
In fact, that very scandal, had it unfolded a
10
little bit differently -- for those that remember, the
11
planes disappeared.
12
Three weeks later, Nixon's elected for his
13
second term.
14
the Watergate scandal broke.
15
office.
16
moved up again.
17
Rockefeller then slid into the Vice President's slot.
18
And then one of the old Manson women from the Charles
19
Manson days tried to assassinate Ford, which would have
20
put Rockefeller in the White House.
21
It wasn't too much long after that that
Ford moved up.
Agnew was thrown out of
Then Nixon resigned.
Ford
For those that don't remember,
What would have otherwise happened, most
22
likely, the election would have taken place.
23
would have won.
24
out at the same time.
25
controlled the Congress.
Nixon
Agnew and Nixon would have been thrown

The Democrats would have
The Speaker of the House would
Page 55 of 183
173

Page 738 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
177
175
175 of
of308
456
454
3
June
June 14, 2016
have elevated to the Presidency.
have been in control.
happened and history tells us a lot about what really
happened there.
The Democrats would
But the opposite, of course,
Twenty years later there was a report, an
investigative report by a publication called "Roll Call"
in Washington, DC.
these various Congressional deaths.
crashes are kind of the hazard of political leadership,
10
That report was looking into all of

You know, plane
it seems like.
11
But in researching that, what they found in the
12
FBI files were a couple of telexes -- this goes before
13
FAX machines -- and telexes coming from California into
14
Washington, DC reported that two people had been found
15
at a crash site.
16
the FBI to determine whether they were credible.
17
follow-up telex came through saying, yes, they were.
18
That plane was never recovered.
19
officially; yet 20 years later, we find out, in fact,
20
there were.
21
Those sources were later looked at by

A
There were no survivors
So I know about conspiracies.
Conspiracies are
22
conversations that happen in a room like this when
23
there's a bunch of people standing on the outside who
24
might not agree with us.
25
the political life, even at the highest levels, things
But the reality is, even in
Page 56 of 183
173

Page 739 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
178
176
176 of
of308
456
454
4
June
June 14, 2016
happen.
Maybe a few decades go by before the truth is finally
revealed.
Things happen that aren't easily explained.
So I have a strong motivation foundationally in
terms of how I approach controversial issues.
do it with fear.
years.
is the absolute adversary for getting anything
accomplished on this planet.
10
I don't
I've been doing this work for over 20
Fear isn't part of the equation.
In fact, that
My interest in these areas started with HAARP.
11
And how many in this room do not know anything about
12
HAARP?
13
Okay.
Well, that's a lot better than it used
14
to be.
15
Twenty years of this work and the work of others have
16
kind of brought this into the public.
17
All right.
It used to be the other way around.
So the first image -- I'm going to use HAARP as
18
sort of the backdrop as I move into the mind control,
19
mind effects-related technology.
20
in my part of the world.
21
know if -- maybe I've come the farthest for this
22
presentation.
23
appreciate the opportunity to inform people about this
24
subject.
25
This is just an image
I come from Alaska.
I don't
But I appreciate being here and I
So HAARP is a large array, a field of antennas
Page 57 of 183
173
5
June
June 14, 2016

Page 740 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
179
177
177 of
of308
456
454
in Alaska, currently 180 antennas.
They're
approximately 20 meters tall.
which you can see, which is the very top of these
antennas.
concentrate radiofrequency energy into a relatively
small space.
They have a cross dipole,
And what these are designed to do is focus or
If you think about the energy of a flashlight,
for instance, or a torch, as they say here in Europe, I
shine that against the wall, the beam starts out small,
10
and then it broadens as you get further away from the
11
source.
12
The same is true with radiofrequency energy.
13
You can think about it as an inverted funnel starting
14
here at the transmitter and then spreading out and
15
getting thinner and thinner, less dense, which is why
16
the further you get away from radio broadcast antennas,
17
the weaker and weaker the signal.
18
With HAARP, the opposite occurs.
They have
19
figured out a way through what's called cyclotron
20
resonance, which would be focusing or concentrating the
21
energy.
22
like sort of a cork-screwing kind of motion that got
23
smaller and smaller as you move further and further away
24
from the transmitter.
25
So if you could visualize it, it would look
So it concentrates that energy or focuses that
Page 58 of 183
173

Page 741 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
180
178
178 of
of308
456
454
6
June
June 14, 2016
energy so you can manipulate it in various ways.
the HAARP array, which was originally designed by a
gentleman, Bernard Eastlund, who's now deceased, was
intended to do a number of things as a weapons
application.
half the current size of the transmitter in Alaska.
can see the field of antennas.
90 antennas in the array.
9
10
And so
This is the earlier version when it was

You
In this case there were
And here's another image as they expanded the

array to 180.
11
And another image showing the array.
Now, they also upgraded the technology pretty
12
substantially over the years.
13
efficient.
14
much bigger effects.
15
So it became much more
So with a much smaller system you create
So what does it do?
Essentially, it's sending
16
energy or focusing energy up into an area known as the
17
ionosphere, which in this image in miles -- I apologize
18
for that -- is approximately 37 miles to 620 miles out
19
into space.
20
Now, this is a highly energized area.
If you
21
think about radiofrequency signals or shortwave signals,
22
they would come from the earth, they'd bounce off of us,
23
and then bounce back down to the earth to transmit over
24
large distances.
25
The ionosphere also is an area that can be
Page 59 of 183
173

Page 742 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
181
179
179 of
of308
456
454
7
June
June 14, 2016
disturbed by solar radiation, radiation from the sun.
When it becomes destabilized, it interferes with
terrestrial communications of every kind.
So part of the idea in this technology was to
learn how to stabilize the ionosphere during these
periods or deliberately disrupt the ionosphere to
interfere with communications on a global basis.
8
9
Now, what caught my interest when I first

looked at this issue of HAARP was a very short article
10
in a publication, an Australian publication, that talked
11
about this big system in Alaska.
12
Now, I come from a family that's pretty
13
politically engaged.
14
Congress, my younger brother just finished a term in the
15
United States Senate.
16
politics a very long time.
17
Besides my dad being in the
My family's been involved in
Alaska is a very big region, but we're a really
18
small population; 700,000 people in our entire region.
19
And when you think about big projects, you know, you
20
think you know something about them.
21
Well, I'm reading about this project in my
22
state in a journal in Australia and I'm going, you know,
23
why doesn't anybody know about this?
24
25
And so I decided I would go in and look into

this issue independently.
And I did.
Page 60 of 183
173
I picked up maybe

Page 743 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
182
180
180 of
of308
456
454
8
June
June 14, 2016
30 articles and papers, design specifications, some
things, and with friends encouraging me to publish, I
published the first article that I had written on HAARP
back in 1994.
So it's been a very long time ago.
What also caught my interest was the idea that
they were primarily utilizing, in some applications,
extremely low frequency signals or ELFs.
signals that can be biologically active, can affect us
as human beings and in very specific ways.
10
These are
And in particular, certain applications of the
11
technology -- and this gives you sort of a graphic
12
illustration of the focus.
13
were given to me by the inventor, Bernard Eastlund,
14
prior to his passing.
15
publications and in some of our work.
16
kind of a graphic showing the radiofrequency from the
17
array, moving up into the ionosphere and focusing that
18
energy.
19
These view graphs, actually,
And we utilized them in our

So this gives you
His initial concept was to create a global
20
shield, to be able to utilize the natural magnetic field
21
lines that surround the earth, be able to punch energy
22
into this and then create this kind of global shielding
23
effect.
24
piercing that energy would be disrupted, like
25
satellites, intercontinental ballistic missiles,
And the idea was that any electronic device
Page 61 of 183
173

Page 744 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
183
181
181 of
of308
456
454
9
June
June 14, 2016
virtually any electronic device that ran into this field
of energy that was being amplified would be destroyed.
Now, one of the other interesting parts of
this -- and this kind of shows that, again, utilizing
one of Eastlund's graphics.
line and then you see this cork-screwing energy going
around it.
southern polar regions into the northern polar regions.
And, in this case, they actually couple -- actually
10
utilize the energy on the ground to couple with the
11
natural energy, and then coming from the north to the
12
south, create this cork-screwing effect, which
13
accelerates the electrons and then creates this global
14
shield.
15
So you can see like a field
That energy naturally is occurring from the
Now, that was his initial concept.
And as a
16
concept, it caught the attention of a number of people
17
and eventually got funding from the Congress, initially
18
at 30 million, and over the last few decades now over
19
almost 300 million, which in dollars is not a lot of
20
money, but when you consider, this is sort of the
21
pinnacle of billions of dollars spent in ionosphere
22
research over many decades.
23
What caught my attention in terms of the
24
technology of Eastlund -- I'm going to skip some of
25
these that are not so relevant -- was the idea that you
Page 62 of 183
173

Page 745 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
184
182
182 of
of308
456
454
10
June
June 14, 2016
could manipulate the ionosphere -- and I'll use this as
a better example.
you could punch or pulse energy into the ionosphere --
so think about this energy going up and, like, a hammer
ringing a bell.
ionosphere itself vibrates and then it begins to send a
signal in the ELF range.
signal going up, punching the ionosphere, the ionosphere
which is energized then acts as a broadcast antenna in
So one of the thoughts was that if
Every time it hits that ionosphere, the
So you have a high frequency
10
the sky bringing back an ELF signal to the earth, and in
11
this case covering an entire hemisphere.
12
Now, ELF signals, extremely low frequency
13
signals, are very long wavelengths.
14
earth and sea.
15
submarines, as an example, the depth, because short
16
wavelengths won't penetrate the earth and sea.
17
also used for what's called earth-penetrating
18
tomography, which in simple language or by analogy would
19
be like x-raying the earth or looking into the earth for
20
underground structures.
21
They penetrate the
They're utilized for communication with
They're
But one of the side effects of ELF is the
22
entrainment effect on the human mind.
23
signals will lock onto in what's called a frequency
24
following response.
25
techniques to create a frequency following response.
Because ELF
And you can use a lot of different
Page 63 of 183
173

Page 746 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
185
183
183 of
of308
456
454
11
June
June 14, 2016
You can use flickering light, you can use binaural beat,
which I'll explain in a few minutes.
electromagnetic fields such as this, or even the power
grid itself can be modulated in such a way to create a
signal that the human body will join with, will couple
with, and begin to follow.
of energy to accomplish this.
You can use
It doesn't take a great deal
This is the one that triggered my real interest
in HAARP, because this is the one that everybody kind of
10
ignored and said, oh.
11
well, if ELF has a biological effect, it's a side
12
effect.
13
phrase earlier today.
14
believe that it's an intended consequence.
15
intended to grade populations in very specific ways.
16
In fact, the HAARP planners said,
It's an unintended consequence.
We heard that
But I don't believe that.
It's
Now, this book was mentioned by my friend
17
earlier today, "Between Two Ages", by Zbigniew
18
Brzezinski.
19
written, actually, in 1973, when Brzezinski was at
20
Columbia University.
21
Security Adviser to President Carter.
22
the time that Kissinger and he and others were starting
23
to think about the Trilateral Commission organizing this
24
think tank, so to speak.
25
And why this is an important book, it was
This is before he became National
Now, find this book.
Page 64 of 183
173
This is around
I really encourage you to

Page 747 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
186
184
184 of
of308
456
454
12
June
June 14, 2016
find this book and read it, because it is not a
prediction of what will come with technology.
blueprint, in fact.
It's the
You can read this.
When I first read it -- he writes in a pretty
convoluted style.
English to understand.
read it because he predicted the economic changes that
took place, the political changes that took place in the
world over the last 40 years with a great deal of
10
accuracy.
11
prediction.
12
It's a little difficult even in

But I really encourage you to
And some will say it really wasn't the

It was the plan.
If you look within this text between Pages 54
13
and 56, you'll see a section that's dedicated to the
14
kind of technologies we're talking about today, a mind
15
control technology.
16
guy named J. F. Gordon MacDonald.
17
geophysicist at UCL.
18
chapter in a book and the chapter was called, "How to
19
Wreck Your Environment", which this is before Earth Day,
20
okay, so he could get away with that.
21
that book was actually published.
22
caught Zbigniew Brzezinski's attention was, he said, if
23
we could ever figure out how to electronically stroke
24
the ionosphere in just the right way, we could return a
25
signal to the earth that would influence the behavior of
And what Zbigniew referenced was a

And he was a
He wrote a book -- or, actually, a
Page 65 of 183
173
It was 1969 when
But what he said that

Page 748 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
187
185
185 of
of308
456
454
13
June
June 14, 2016
people over huge geographic areas.
Now, that's a pretty profound thing.
But we
didn't have a way to stroke the ionosphere in 1969.
we did by the 1990s.
fact, the HAARP system that can accomplish this.
But
And that was, in fact, and is, in
So the idea was -- and it was kind of, in a
gross sort of way, primitive, if you will, but what the
intention was, was that if you could pulse the
ionosphere, return this ELF signal to the earth, you
10
could agitate the population in very specific ways.
11
could make them passive, less aggressive, or the
12
opposite by just amplifying that signal.
13
explain a little bit of that as we go on.
You
And I'll
14
The other person that comes out in the last
15
presentations, Jose Delgado, and this book he wrote,
16
"Physical Control of the Mind:
17
Society".
18
images that you saw in just this short video clip of
19
Delgado's work, there is a good section in this text as
20
well showing that.
21
Toward a Psychocivilized
And this is, again, a 1960s book.
Those
But in those days they used implants.
They had
22
to physically put something in the brain.
23
Delgado originally did -- he was actually educated in
24
electrophysiology at the University of Madrid.
25
graduated in 1950.
And what Jose
He
Electrophysiology, as a degree
Page 66 of 183
173

Page 749 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
188
186
186 of
of308
456
454
14
June
June 14, 2016
field, thinking about it in 1950, now 65 years ago, most
people don't even realize that's an area of higher
education today, much less that far back.
One of my mentors, Raul Makayla (phonetic), he
actually graduated University of Madrid in 1958, and his
area of interest was, essentially, the same, biomagnetic
and electric fields, effects on human physiology, and he
spent his career studying that.
Delgado, at Yale University, he initially was
10
mapping the brain of primates and humans by stimulating
11
various portions of the brain to figure out what was
12
responsible for what kind of activity.
13
began to utilize the implants in those dramatic ways in
14
those film clips with the charging bull and he throws
15
the switch and the bull stops, to demonstrate that you
16
could take a creature from passive to highly aggressive
17
to passive to highly aggressive, just like flipping on
18
and off the lights in your living room.
19
And then he
What Delgado discovered by the mid-'80s is that
20
you didn't need any implants.
You just needed to
21
manipulate the energy itself.
And you didn't need a
22
great deal of energy.
23
Now, we've heard -- I forget the amount of
24
energy surrounding us now.
25
believe it was 18 zeros after the one that we heard
Page 67 of 183
173
Was it a quintillion?

Page 750 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
189
187
187 of
of308
456
454
15
June
June 14, 2016
earlier.
radiofrequency energy alone, it was 200 million times
more around us every day than nature created in 1994.
Back when I wrote the HAARP book in '94, just
Now, when you think about it, what did Delgado
discover?
of energy in the natural background noise of the earth
was sufficient to manipulate the behavior of human
beings if you could hit the right frequencies, if you
could hit those window frequencies that stimulated that
10
He discovered that one-fiftieth of the amount
kind of activity.
11
Now, if you think about this -- again, by
12
analogy, think about dialing through the radio stations
13
on a radio.
14
noise, the static, you get no clear signal.
15
you have resonance between the transmitter and the
16
receiver, then you get a nice, clear signal.
17
The same is true in our physiology.
18
you're looking at stimulating or affecting a specific
19
element in the body, molecules in the body, cell
20
structures or organ structures or even the human mind,
21
it's about manipulating the underlying energy.
22
In between the stations you get the white

But when
Whether
When you think about medical science in terms
23
of how the fork in the road is and how this kind of
24
applies to why don't we know more about this today,
25
well, there's lots of literature now.
Page 68 of 183
173
25,000 sources, I

Page 751 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
190
188
188 of
of308
456
454
16
June
June 14, 2016
think we heard quoted earlier today.
25,000 sources
talking about the energy interactions with the human
body.
That is a lot of information.
But what happened in medical science?
A lot of
people that went into life sciences, they were really
good in the chemistry, a little weak in the math, so
they went to life sciences.
better in the math, they went to physics.
upon a time, these two came together and we got
People who were a little

And then once
10
biophysics, which is really the root of real health
11
science.
12
you've got to get to the energetic interactions that
13
create chemical reactions that then manifest in the
14
body.
15
If you really want to get to the meat of it,
And that's what we kind of miss in so much of
16
our medicine.
17
opposed to an electromagnetic model.
18
to World War II, that fork in the road was being
19
explored pretty aggressively, the energetic models.
20
they were somehow lost in that shuffle and we ended up
21
with the pharmaceutical industry, and the results of
22
that, I think we can all not be quite so proud of.
23
We followed a pharmaceutical model as

In the '30s, prior
But
In terms of where the technology is going and
24
where a lot of the science is going, it will be
25
electromedicine that cures most of what we call
Page 69 of 183
173

Page 752 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
191
189
189 of
of308
456
454
17
June
June 14, 2016
incurable.
debilitates human consciousness itself.
It will also be that which enhances or
Now, Jose Delgado, when he figured out that you
didn't need implants, you just need to manipulate the
energy itself, this became kind of the essence of sort
of where everything went from there.
But I want to roll back a little bit, a little
bit back in time, and talk more about the evolution of
mind control as technology starting with the work at
10
Harvard University of a gentleman, Estabrook, who was
11
working in the Harvard hypnotherapy labs in the 1920s.
12
You can look Estabrook up.
13
of Congress and you'll see his list of publications, and
14
I recommend that you do that.
15
Look him up at the Library
What he decided was that you could create what
16
we would call today a Manchurian candidate.
17
take certain individuals, put them in a very, very deep
18
state of hypnosis and then over a period of time train
19
them so they would be like this super spy that you could
20
send into another country and they'd hang out for a year
21
or two, but if they got captured, they wouldn't really
22
remember any of their former self, and then when they
23
came back, in this case, into the United States, that we
24
would then give them the appropriate suggestions and
25
then extract the intelligence from them.
Page 70 of 183
173
You could

Page 753 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
192
190
190 of
of308
456
454
18
June
June 14, 2016
And this is what Estabrook was working on.
By
the 1930s, a lot of his work was being classified and he
continued to work in this field up through the 1960s.
His last book -- and I always like to read the last
thing someone writes, you know, because it tells you a
lot about, sort of, the conclusions and there are things
that you might discard bits and pieces as science
enlightens you and your experience enlightens you.
what he talked about in that last book were the
10
experiments he was involved in using LSD and other
11
hallucinogenics in mind control, which he actually
12
talked about in a favorable sense.
13
And
And for those of you that remember, the CIA was
14
heavily involved in this in the 1960s and, in fact, the
15
whole area pre-1960s going back even to the Korean War,
16
which is sort of my next mark on the timeline.
17
The Korean War, we had prisoners, patriotic
18
young Americans come back from war and they're handing
19
out Communist leaflets on street corners, and the term
20
or the phrase brainwashing came into being.
21
where it came from.
22
after the Korean War.
23
That's
It came from that series of events
The idea of being able to manipulate people's
24
behavior and change them so profoundly became of
25
interest to the predecessor of the Central Intelligence
Page 71 of 183
173

Page 754 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
193
191
191 of
of308
456
454
19
June
June 14, 2016
Agency and then later the Central Intelligence Agency.
And what they looked at were lots of different ways to
manipulate human behavior.
Now, when I was researching my first book with
Jeane Manning, "Angels Don't Play This HAARP", I was
looking for a good source document that would speak to
this, because you always read about this in secondary,
tertiary sources.
surplus book room, and I'm telling this guy that I know,
And so I'm in a book room, a big
10
I really need this source.
11
conversation, I reach unconsciously behind me into a box
12
and I pull out this book.
13
And as I'm having this
This is a really interesting one.
This is
14
actually a presidential report.
15
was commissioned at the time, 1975, to look at the
16
abuses of the CIA.
17
Committee reports, which were Congressional hearings
18
that took place in the early '70s to investigate the
19
abuses of the Central Intelligence Agency, the kind of
20
abuses that we read about today, because nothing really
21
changed.
22
This is a report that
Now, this came out of the Church
Supposedly, this was to change things.

Now, what's in this report?
The LSD
23
experiments were in this report.
24
Intelligence Agency was domestically infiltrating civil
25
rights groups, antiwar groups, people that, essentially,
Page 72 of 183
173
The idea the Central

Page 755 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
194
192
192 of
of308
456
454
20
June
June 14, 2016
opposed the government within the United States, which
was not part of their mandate, in fact, was illegal.
The fact that they were reading people's mail, utilizing
unwitting victims and experiments for mind control.
of this came out in this report in 1975.
CIA continues to do it even to this day.
All
And yet, the
Think about the kinds of activities that have
been reported pretty widely over the last few years,
whether it's digging through garbage to blackmail other
10
diplomats, which is something our Intelligence community
11
does, whether it's to send pallet loads of money into
12
countries like we did in Afghanistan to bribe officials
13
as a way of doing business, or whether it's to
14
assassinate people with drones, kidnap people and
15
torture them.
16
Now, most of us don't know people like this,
17
but this is the government that I unfortunately have
18
guiding my country right now.
19
criminals.
20
couldn't happen here.
21
It's a government of
Now, people want to talk about, oh, this
It has happened here.
It's happened for
22
decades in the United States.
23
President's Commission touches the very tip of that
24
iceberg.
25
This report by the
This is another document.
Page 73 of 183
173
This is -- this guy,
21
June
June 14, 2016

Page 756 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
195
193
193 of
of308
456
454
Captain Tyler, he later became a colonel and retired.
He was involved in pretty much the sort of esoteric side
of some of the government research.
chapter out of this book is called, "Low-Intensity
Conflict and Modern Technology".
Maxwell Air Force Base in 1984.
about a large -- a variety of technologies.
8
9
This book -- this
It was prepared by
And it was talking
But in this particular one, if you look at,

certainly, the subject lines, you have stimulation of ,
10
bones* generation, healing of fractures, treatment of
11
disease, healing of wounds.
12
modification in animals.
13
that are listed here were kind of under the mysterious
14
category.
15
happening in 1984.
16
You look at behavior
You know, some of these things
They couldn't really explain what was
But the idea was to stimulate research in these
17
fields.
18
started to flow into these areas.
19
that came out in the 1980s as a result of some of this
20
was the Radiofrequency Dosimetry Handbook.
21
big, thick handbook.
22
of Utah under contract to the United States Air Force to
23
determine the radiofrequency dosages that were required
24
to override every vital organ of the human body, whether
25
it be the heart, the liver, the lungs, the kidneys, just
So a number of things happened.
A lot of money
One of the reports
It was a
It was produced by the University
Page 74 of 183
173
22
June
June 14, 2016

Page 757 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
196
194
194 of
of308
456
454
sort of preempt their natural function to be able to do
it remotely.
And the idea was to take that leap of
technology and begin to apply it into weapon systems.
Mind control.
you will remember this one.
Yeah, 2002.
about the ethics of mind control.
it exist or doesn't it exist?
"The Economist".
Cover story.
Some of
This is 2002, I believe.
And what this cover story was about was

Not saying, hey, does
It's just saying it's
10
here right now.
11
we should advance this technology, whether we should
12
limit this technology.
13
credible publication.
14
story.
15
We really need to be debating whether
"The Economist" is certainly a

Not too much happened from this
This is -- unfortunately, it's not showing up.
16
November -- you can get this one on my website.
17
give you my website, because this is a very important
18
document.
19
human experiments.
20
in history, that's like tomorrow and yesterday, right?
21
It's, like, now.
22
mind control experiments and who has the authority to
23
approve them.
24
approve them is under secretaries of the Navy in the
25
case of Navy Intelligence or Naval research.
I'll
The Navy set up a new set of regulations for

It was approved in 2006.
You know,
And in this they specifically call out
And the persons with the authority to
Page 75 of 183
173
23
June
June 14, 2016

Page 758 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
197
195
195 of
of308
456
454
Now, it's not just CIA.
Naval Intelligence
does this work.
non-lethal weapons that this falls under.
has the electromagnetic directorate, which is working in
an area called controlled effects, which deal, again,
with mind control and physiological effects on human
beings.
"Technology Horizons".
issue.
10
The Marines have a section on

The Air Force
In fact, they publish a publication called

I believe it's the June 2004
You can look it up.
The cover story is on
controlled effects.
11
Now, what are controlled effects?
The first
12
effect is attacking hardware; you know, like equipment,
13
like machines, to be able to interfere with the flow of
14
electrons through circuits to disrupt those machines to
15
operate.
16
history, but using energy itself to manipulate hardware.
17
Not using bombs and bullets and the things of
The second sort of level of controlled effects
18
talked about in that article is the idea of manipulating
19
the software, the systems that run those systems, so
20
that you can disrupt the software, then you disrupt the
21
hardware, and things collapse.
22
And the third leg of controlled effects is the
23
human operator.
24
article produced by the electromagnetic director of the
25
Air Force is that we can target or create the illusion
And what they say in this particular
Page 76 of 183
173

Page 759 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
198
196
196 of
of308
456
454
24
June
June 14, 2016
of all of the senses in the human body; sight, sound,
touch, taste, to give people complete memory sets,
complete experiential sets that you wouldn't be able to
distinguish the synthetic from the real.
Now, think about that for a moment.
What does
that do to court testimony in 20 years if this becomes
the norm?
post-traumatic stress syndrome folks, people coming back
from warfare.
They're now talking about using this for
This just sort of cleans up the garbage
10
of the mind and gets rid of that stress.
11
think that's a great idea.
12
the biggest mistake we could ever make.
13
whatever those servicemen and women were engaged in --
14
what used to happen in warfare -- what happened in World
15
War II when everybody came back, they said, I don't ever
16
want to see my children in these things, I don't want to
17
see my grandchildren in these things.
18
put down, not amplified.
19
Some people
Personally, I think that's

Because
Wars need to be
When you take the human factor out of warfare
20
and it becomes like a videogame, then our willingness to
21
withdraw from direct conflict no longer happens.
22
And think about where our military science has
23
gone.
24
publication.
25
in the early 1980s.
In fact, I want to mention another very important

It was produced by the US Army War College
It's called the "Revolution of
Page 77 of 183
173
25
June
June 14, 2016

Page 760 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
199
197
197 of
of308
456
454
Military Affairs and Conflict Short of War".
particular paper was talking about revolution of
military affairs.
And this
What is that exactly?
This is a leap as important as the introduction
of gunpowder in the middle ages in Europe, as important
as atomic weapons in the last century.
they characterize it.
where we move from ordinance, from bullets, bombs,
things that rip tissue and tear things up, to
And that's how
And what this is is the leap
10
electromagnetic weapon systems that keep sort of the
11
hardware intact, but debilitate the human operator to
12
the point of being combat ineffective.
13
enhance the possibilities within our own combatants
14
while degrading the abilities of others.
15
Or conversely,
There's simple ways that you can achieve this.
16
You can introduce to the battlefield certain elemental
17
compounds that in small background amounts would not be
18
considered dangerous.
19
example.
20
body to maintain thyroid function.
21
much iodine, you'll get poisoned.
22
get sick.
23
Let me give you iodine as an
We all need a certain amount of iodine in the
So what can you do?
But if you have too

You'll die.
You'll
You can send a signal in
24
that resonates the very same signal strength and
25
frequency as iodine, you can send that signal in and the
Page 78 of 183
173
26
June
June 14, 2016

Page 761 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
200
198
198 of
of308
456
454
body will begin to react as if its gotten this massive
load of iodine and show all the symptoms of iodine
poisoning.
You check the thyroid; check the blood, it's
not there.
Mystery illness.
Something as simple as that for manipulating
large populations, not necessarily with their consent
and not necessarily with clear knowledge, and nothing
shows up in the background that would say why this
poison actually exists that would account for this.
10
simple way.
11
One of the other ways that this technology can
12
be exploited is really quite simple.
13
article produced by "Parameters", which is a military
14
publication.
15
the -- I believe it was the Fall 1998, but you can look
16
up the article name called, "The Mind has no Firewall".
17
It's a very important article.
18
about all the various ways in which you could introduce
19
mind effects or mind control technologies using modern
20
technology today.
21
written in a military journal called "Orienteer"
22
published in what is now Russia.
23
"Parameters".
There was an
You can look it up.
It's
This article talked
And the original article was actually
What's interesting about this is it said you
24
could use any electromagnetic carrier, whether it be
25
radio, TV, the Internet, now cell phones; but,
Page 79 of 183
173

Page 762 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
201
199
199 of
of308
456
454
27
June
June 14, 2016
essentially, any of these carriers, you can modulate a
signal on them that will manipulate behavior of segments
of the population.
And the Russians demonstrated this in a couple
of different ways.
There was a program.
It was called
"Undercurrents".
Canadian Public Broadcasting System.
did two really interesting stories that I got to
participate in.
It aired in the CBC, which is the

"Undercurrents"
One was on HAARP and the other was on
10
mind control.
And on the mind control story that they
11
did -- this was a very popular program in Canada at the
12
time and this particular segment was their highest rated
13
that they had ever run.
14
who were involved in the "Star Wars" initiative during
15
the Reagan Administration that couldn't talk about what
16
they did in the White House, but they could talk about
17
what they observed in Russia.
And they had folks that came in
18
And one of the things that they talked about
19
was the idea that you could -- you could create, sort
20
of, this white noise and on this white noise carry a
21
signal.
22
cake.
23
these little cakes?
24
of Europe as well.
25
And so they put out this message, bring us

And Russians at tea time, you know, they eat
I guess you do that in other parts
And so at the appointed time they began to
Page 80 of 183
173
28
June
June 14, 2016

Page 763 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
202
200
200 of
of308
456
454
broadcast this.
and on the street were bringing cake into the meeting
room without really knowing why they were doing it.
They just felt like doing it.
what they were programmed to do.
And workers from within that building
Now, this goes back.
Well, that was, in fact,
We're talking about
15-year-old technology.
And when you think about sort
of where did it go from there, in 2006, there were a
couple contracts left by DARPA, which does research for
10
the defense industry in the United States.
And DARPA
11
used to be run by a guy named Tony Tether.
Tony Tether
12
was a good friend of Ben Eastlund's.
13
Now, what they were doing then was, they had
14
left two contracts to the University of California for
15
what's called electronic telepathy.
16
telepathy.
17
a distance by analyzing the emanations coming from this
18
area, being able to analyze that and determine and
19
interpret what it is.
20
contract was to create complex signals to see if you
21
could transfer that array, so to speak, of signals into
22
another person's consciousness and whether they would
23
perceive the same images.
24
25
Okay.
Electronic
The idea of reading another person's mind at
And then the other half of the
Now, there was work done by Elizabeth Rauscher

and her late husband, Bill Van Bise, in this very same
Page 81 of 183
173

Page 764 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
203
201
201 of
of308
456
454
29
June
June 14, 2016
area.
In fact, I have a copy of their unpublished paper
where they actually built an electronic circuit where
they could take a person in one room and a person in
another room, attach this person to that circuit and
this person to that circuit, and then, you know, the
psychic card where they show the triangles, the squares
and the circles and the little squiggly lines, a hundred
percent accurate with nine test subjects who had never
experienced consciously in any way any sense of
10
extrasensory perceptions or psychic perceptions.
11
did it with hardware, transferring thoughts from one to
12
the other.
13
They
Now -- which tells me it's probably a little
14
more simple than what DARPA's doing.
15
Eastlund was doing work on HAARP and he was doing other
16
work for DARPA at the time and we had talked about him
17
in our first publication, and then actually after
18
publication became friends, and Ben Eastlund's attitude
19
was, you know, some things just shouldn't be done.
20
one of the things that he had been working on was
21
whether modification technologies, which he was at that
22
time and when we first met, making that technology
23
available to the military.
24
us and others, he decided there's certain technologies
25
that are not safe in the hands of military.
Page 82 of 183
173
But when Ben
And
And after some dialogue with

Page 765 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
204
202
202 of
of308
456
454
30
June
June 14, 2016
At one point along the course I began doing
quite a bit of work on this whole mind effects issue.
And I caught the attention of a woman, Dorothy Lay.
Now, Dorothy is one of the heirs to the Lay, as in
Frito-Lay and PepsiCo Corporation.
family.
specifically as it applied to victims.
So a very wealthy
Dorothy was very interested in this technology
And so she approached me at one point and asked
if I would become a member of her board of directors for
10
a non-profit that she was setting up to deal with these
11
kinds of technologies.
12
whether I should tell you the rest of this story, and I
13
think I will, because why not?
14
And I've got to think about
So I have this thing, intuition.
All of us
15
have it.
16
do today.
17
listen, because when I really think about it, it's never
18
been wrong.
19
about it.
20
start acting on it.
21
I used to not pay as much attention to it as I

When my intuition tells me something, I
Neither has yours, if you really think

Or maybe you don't think about it and just
So my intuition said -- and this was a very
22
difficult time for me in 2002.
23
betrayed by a very good friend, economically was
24
bankrupt in the middle of this work, because I started
25
this work in '94.
In 2002, I had been
Economically was being crushed.
Page 83 of 183
173
And
31
June
June 14, 2016

Page 766 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
205
203
203 of
of308
456
454
at that point I was deciding whether I was going to stay
in this work at all.
And I'm going through a bunch of my files and I
see this file and it's marked Lay.
person had contacted us needing some information and we
provided it.
way we operated is, I sold books.
bought my books.
And I remember this
And we never charge for that.
I mean, the
And people like you
And they allowed me to do this work.
I didn't write for grants where somebody could
10
manipulate me and control me and tell me what to say.
11
didn't go out and find some publisher that would edit
12
out my work.
13
book.
14
that work by buying that book.
15
two and a half million dollars and I spent that two and
16
a half million dollars over 20 years doing what I'm
17
doing right now.
I risked my own money.
I published my
And then I asked people to help me by supporting
18
A VOICE:
19
(Applause.)
20
DR. BEGICH:
And I tell you, I made
Thank you.
And the whole idea was just to
21
educate.
22
reason I didn't was because I felt that that was putting
23
the cart before the horse.
24
people that the technology is real, that this could
25
really happen to people and from that foundation, and
I didn't deal with victims.
Page 84 of 183
173
Okay.
And the
We first need to educate
32
June
June 14, 2016

Page 767 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
206
204
204 of
of308
456
454
that became the foundation of my work in this.
So Dorothy calls me on the phone and she says,
will you be on my board?
an hour.
on your board.
And I talked to her for about
At the end of the hour, I said, no, I can't be
She said, well, why not?
I said, because my intuition is telling me I
really can't be on your board.
And she goes, well, I deserve more than that.
10
I said, okay.
I don't know your board members,
11
I don't know who your board is, but something in here is
12
saying there's a problem there and I don't want to be
13
associated with them.
14
(Applause.)
15
DR. BEGICH:
16
I got the call back.
17
you have millions.
18
what they say they're doing.
19
being done and find out for yourself.
20
diligence again.
21
So it was a couple of months later

Because I told her also, I said,
You have the ability.
And she did.
Go see if it's really
back and she said, you were right.
23
me a number of ways.
24
just me now and my attorney.
Do your due
A couple months later she came
22
25
Go research
They were defrauding
I've cleared out my board.
It's
Will you be on my board?
Now, bear in mind, I'm in a pretty desperate
Page 85 of 183
173
33
June
June 14, 2016

Page 768 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
207
205
205 of
of308
456
454
situation economically.
At the time I have five
children at home.
have an economy that I've got to manage.
Dorothy, no, I can't be on your board.
I've got people to take care of.

And I tell
She says, well, why not?
I said, well, I need to meet you first in
person, eyeball to eyeball.
for three days.
foundation.
I said, we're going to talk
We're not going to talk about your
I want to know everything I'm ever going to
10
read about you and your family in the newspaper.
11
you to have the same knowledge level of me.
12
to know what your world view is before I join with you
13
in achieving that world view, because you have the means
14
and I have the willingness if that world view is shared.
15
So we spent a few days.
I want
And I want
We decided that I
16
could do this.
17
And we put together, as her major effort was, a
18
conference on mind effects.
19
public.
20
bring some key people together to have a conversation
21
that would be open and free.
22
And for four years I worked with her.
But it wasn't open to the
It was closed to the public.
And it was to
And one of those people I invited was Ben
23
Eastlund, who by then I'd gotten to know, had watched
24
what he had done in terms of his career.
25
connected with DARPA at the time.
Page 86 of 183
173
He was well

Page 769 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
208
206
206 of
of308
456
454
34
June
June 14, 2016
And I called him and I said, you know, Ben,
would you consider participating in this conference?
And he said, you know, if you had asked me this
seven or eight years ago, on a scale of one to ten, ten
being the relevance and importance of this, and one
being irrelevant and unimportant, I would have given
this a one or a two.
time I talk to Tony Tether or others at DARPA, nobody's
laughing about mind control anymore and it's a nine or a
10
He goes, but -- he goes, every
ten and, yes, I'll participate in your conference.
11
The next person I asked was Garth Nicolson.
12
Does that name ring any bells for anybody?
13
Nicolson was a full professor, I believe it was Texas
14
A&M.
15
thousand medical students.
16
whistle on Gulf War Syndrome and testified in our
17
Congress six times before his wife was fired as a
18
molecular biologist from Texas A&M.
19
they couldn't fire him.
20
him, because he was one of the first courageously enough
21
to step up to the plate and complain about what had been
22
happening in the Gulf War; we depleted uranium and some
23
of the other technologies that were being applied there.
24
25
He taught medical students.
Okay.
Garth
He taught over a
He was the guy that blew the
And he was tenured;
But they definitely harassed
Well, the best thing that ever happened to him

was he got out of the university system.
Page 87 of 183
173
He formed a
35
June
June 14, 2016

Page 770 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
209
207
207 of
of308
456
454
nonprofit to deal with chronic disease.
somebody that I watched maintain his course under really
difficult circumstances.
conference.
And he was
So he was invited to that
I invited the daughter of my mentor, Raul
Makayla.
one of the boards in Russia that regulates medical
applications of lasers.
Quite brilliant.
10
She's an electrophysiologist.
She serves on
She's an electrophysiologist.
We invited her.
We invited Rosalie Bertell.
11
remember Rosalie Bertell?
12
passed.
13
physicist, biologist.
14
doctoral students at Berkeley.
15
It's kind of an odd combination.
16
statistician to go in to Bhopal for the World Health
17
Organization after that huge chemical disaster.
18
was considered one of the top people in the world for
19
dealing with victims of radiological experiments,
20
including electromagnetic radiation.
21
some of our work and added to it and published a book on
22
the HAARP system and its effect on human beings on this
23
sort of broad scale.
24
been through some really difficult times as well, rose
25
out of her own ashes and maintained her ethical
Okay.
Does anyone
Also deceased now.
A few.
Rosalie's
She was a mathematician,
She taught higher mathematics to

She was also a nun.
She was the lead
But she
She actually took
So we had invited Rosalie, who had
Page 88 of 183
173

Page 771 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
210
208
208 of
of308
456
454
36
June
June 14, 2016
platform.
The other person we invited was Alexander
Kaivarainen.
Does anybody recognize that name?
He was
the former head of the USSR Academy of Science
Biophysics Department for ten years.
area that really gets into the meat of what we're
talking about here today.
believe, is deceased now also.
guys, you know, they're a lot older than me and they
And this is the
Now, what got -- Alex, I

You know, all these
10
keep dying of old age.
11
science at a young age watching a demonstration of the
12
paranormal, ESP, telepathy, these kinds of things in
13
Russia when he was a teenager.
14
caught his interest.
15
But Alex got his stimulation in
And it just really
When I met Alex, he was in his 60s and he was
16
the brightest top five physicists on the planet,
17
recognized by institutions around the world.
18
he had determined is that there were rational reasons
19
for why these things manifested.
20
this conference and actually presented a paper giving
21
the mathematics and the physics that lends itself to
22
these extrasensory possibilities, these things that the
23
military now calls anomalous human capabilities.
24
used to call it extrasensory perception or ESP, but now
25
they give it a new name because there's a lot of
Page 89 of 183
173
And what
So he was invited to
We

Page 772 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
211
209
209 of
of308
456
454
37
June
June 14, 2016
connotations with that that kind of get you discredited
in certain segments of the scientific community.
So I want to talk -- roll back again a little
bit -- I want to talk about binaural beat, which I had
mentioned earlier in this presentation.
around a little bit.
not even use these things, but I think people feel more
comfortable using them.
And I jump
It's kind of my style.
The binaural beat.
I used to
We can't hear these really,
10
really low frequency signals, because the human ear
11
doesn't quite work that way.
12
the human ear won't hear.
Below a certain frequency,
13
Now, a gentleman by the name of Robert Monroe
14
developed a method using binaural beat where you could
15
send in a signal within the range of human hearing, say,
16
at 15,000 Hertz or pulses per second or cycles per
17
second, coming in one ear at, say, 15,000, another
18
signal coming in the other ear at, say, 15,007.
19
the cranium they will cancel each other out and leave a
20
beat frequency of seven, the difference between the two.
21
15,000, 15,007.
22
seven pulses per second, which happens to be in the
23
upper Theta range, and this is where the brain then
24
drives to.
25
Within
The beat frequency becomes seven Hertz,
At the same time that that occurs, you get a
Page 90 of 183
173

Page 773 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
212
210
210 of
of308
456
454
38
June
June 14, 2016
hemispheric balance, a distribution of energy across
both hemispheres of the brain, the analytical side and
the creative side and working together.
actually how human beings are supposed to function.
This is how young children predominantly function, with
more of a balance between the hemispheres, where the
energy is more balanced.
8
9
This is
And then we educate them.
And with young girls, who we say are more

intuitive and have this other operation of the brain,
10
and young boys are more analytical, and now we kind of
11
treat everybody the same so we kind of dumb them all
12
down to the same level.
13
children and you look at where their brain activity is
14
and between 3 and, say, 5 or 6 years old, they have
15
this predominant brain frequencies or a lot of Theta
16
brain frequencies coming in and then some ELF and then
17
higher frequency ranges.
18
But when you look at young
Now, what is Theta?
Theta states if we're in a
19
Theta state, we're kind of like in that dream-like state
20
between awake and asleep where you're consciously aware
21
of your dreams.
22
good deal of their time.
23
as we call it, are so active.
24
don't pay attention to that, don't pay attention to
25
that.
That's where 3 to 5 year olds spend a

That's why their imaginations,
And we keep saying, oh,
This was our first attempt to shut down the
Page 91 of 183
173
39
June
June 14, 2016

Page 774 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
213
211
211 of
of308
456
454
intuitive combinations of the way the brain is actually
supposed to work.
In fact, for those who have a Christian
background, you know Jesus Christ himself said, look at
the little children, watch what they do.
think I heard somebody say something about this earlier,
little children come to the table kind of innocent with
a view of the world that's quite different than the rest
of ours.
You know, I
But the brain activity of children is unique
10
and we begin to take that out of them in the structure
11
of the way we educate.
12
So what Robert Monroe -- he was actually a
13
radio engineer.
14
had this really weird experience.
15
body experience, that he had that kind of threw him.
16
You know, it didn't make any sense to him.
17
began -- he also noticed that in the background there
18
was this kind of noise that he perceived.
19
He owned a bunch of radio stations.
He
It's an OBE, an outer
So he
So he began to experiment and he created this
20
technique for binaural beat.
21
series.
22
binaural beat.
23
those US patents from 1994, and this is showing the
24
brain before the activity, before turning on the
25
Hemi-Sync, and this is after, showing a more even
He developed a whole
In fact, he actually got US patents on a

This is an image taken out of one of
Page 92 of 183
173
40
June
June 14, 2016

Page 775 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
214
212
212 of
of308
456
454
distribution in a more rhythmic pattern in the
brainwaves as you see in the upper right-hand corner.
Let me roll back again so you can kind of see
the comparison.
activities happening all through the brain, and then a
coherent signal creating a hemispheric balance and an
optimization of brain potential.
8
9
Normal brain, kind of disorganized
So what did he do with this?
He developed a
whole series of things; audio input technology,
10
essentially, to manipulate behavior, but where you're in
11
control of that manipulation.
12
smoking, you get his CD on quit smoking.
13
brain in such a way, becomes compelling, very affective.
14
So you want to quit

It affects the
Sleep disorders can be addressed in this way.
15
They have someone be able to relax, meditation,
16
concentration, accelerated learning.
17
things can be done.
18
over the course of many, many, many, many years, and now
19
his daughter doing the work of working with thousands of
20
people to determine which signals actually created which
21
effects and then developing technology that they could
22
place in the hands of individuals to make the choice on
23
how to use it.
24
25
A whole array of
And they did this by working with,
Now, that's kind of an interesting way of

looking at technology.
It was my area of interest, in
Page 93 of 183
173

Page 776 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
215
213
213 of
of308
456
454
41
June
June 14, 2016
the beginning of all of this work, was not looking for
the dark side of all of this, but in the mid-'80s I got
very interested in light and sound stimulation of the
brain that capitalized on sound signals and flickering
light for brain entrainment.
the brain will follow that external signal or what's
called FFR, frequency following response.
little energy.
Entrain the brain where
So very
Let me roll back to Delgado again.
10
One-fiftieth of the amount of energy the earth creates
11
is sufficient to move your brain into very specific
12
states.
13
just another technique for altering brain activity that
14
might be beneficial, but you're in control of it, not
15
somebody else.
16
Dialing that radio up, if you will.
This is
I'm going to skip some of these just because
17
they're not so relevant.
18
images and let me just go back into the whole dialogue
19
of this, mind effects.
20
And I'm going to close the
When I think about sort of where do we go with
21
this conference, when we put that conference together
22
with the Lay Institute, our purpose was to put together
23
these really good thinkers to try and see if we could
24
create a synergy between them.
25
And when I first got interested in doing
Page 94 of 183
173
42
June
June 14, 2016

Page 777 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
216
214
214 of
of308
456
454
something actively in science, it wasn't about HAARP and
it wasn't about mind control.
would play -- and I was working in a government office
at the time, and it was -- my friend said, you make your
living with your left foot.
living, but the rest of my creativity could be engaged
elsewhere and me working in bureaucracy was really a bad
match.
The role that I thought I
Because I could make my
But the point was, my youngest son, when I was
10
getting really frustrated with my work, said, change
11
channels.
12
You know, I'm thinking about this, because I
13
had just given him this discussion about creativity was
14
like changing the channels on the TV set, right, and so
15
he's feeding it back, time to change the channels, Dad.
16
So I thought about it.
And what I decided I
17
would do is -- I read independently in science over 20
18
years.
19
say, one guy in one branch of science.
20
if this person could ever meet that person, you could
21
really see something happen.
22
I had read some really compelling things from,

I thought, boy,
And the first paper I actually ever presented
23
in science, I was 19 and it was at another obscure
24
conference that I ended up in on biorhythm research.
25
And my paper was contrasting at that time the Soviet
Page 95 of 183
173

Page 778 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
217
215
215 of
of308
456
454
43
June
June 14, 2016
method of research versus the US method.
method was compartmentalization, separate.
distill things down to the smallest subspecialty and
then push these people into a corner and let them do
this bit of the research.
other people over here and ten other groups over there
and fifteen groups over there, and somewhere all of this
stuff comes together and it gets really sloppy.
It's sloppy because there's a lot of repetition; it's
10
Now, the US
You know,
And then you've got nine
Okay.
very expensive.
11
Now, the Russians, Soviets at the time, they
12
didn't have the money for that kind of research, to
13
spread it out that way, and they used a very different
14
method.
15
fields, even though they didn't seem like they should
16
connect.
17
together to develop science.
18
at the exposures that we had seen earlier, what are the
19
regulatory exposures of electromagnetic fields, the
20
Russians in the '90s and the '80s were a thousand times
21
more stringent than they were in the US.
22
They took experts from all of these different
They put them in the same room to work
Well, why was it?
That's why when you look
Because they had actually
23
made the observations that we hadn't made and actually
24
connected the dots in a way to say, hey, this is
25
dangerous.
That doesn't mean they followed their own
Page 96 of 183
173
44
June
June 14, 2016

Page 779 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
218
216
216 of
of308
456
454
regulations, because they probably didn't.
whatever was expeditious there.
recognized the physiological responses to
electromagnetic fields and the fact that you could
manipulate it.
They did
But at least they
What was discovered by a guy named Allan Frey,
he was looking at microwaves, and he discovered that
there's this flickering effect, but it only occurred
when you pulse-modulated the signal.
And if you look
10
at -- I heard earlier, it's always scalars.
11
scalars.
12
fields as we think about them.
13
It's not vectors.
It's always
It's not electromagnetic
But if you look at the ones that affect human
14
psychology and physiology, if you look at those signals,
15
they have a very quick rise time and a very fast drop.
16
They're like the punch, like punching that ionosphere to
17
create the ELF.
18
modulations on these other carriers are meant to trigger
19
that effect by you entraining to that pulse, that
20
firing, or some submodulation being carried on a general
21
carrier.
22
It's like those signals.
Those
Now, if you remember the first Gulf War, the
23
first Bush War, and you remember how the Iraqi Army just
24
sort of gave up.
25
just like school children on their first fire drill
The fourth largest Army in the world
Page 97 of 183
173

Page 780 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
219
217
217 of
of308
456
454
45
June
June 14, 2016
throwing their hands up and surrendering, you know,
thousands of guys to a few dozen.
Now, I speculated on this.
What was that about?

And then it was
Scottish media that later reported on this and said it
was Project Solo, which was a project operated by the
United States.
flying over the country at the time and it was taking
and piggybacking the signal on the radio broadcast going
into the region that were broadcasting the Muslim music
10
And what we did is we had this C-130
and prayers.
11
So all these guys are in their bunkers
12
listening to their favorite radio station.
Unbeknownst
13
to them, the subsignals being played on that broadcast
14
created anxiety, high levels of anxiety and fear.
15
then you watched this Army just collapse under this.
16
And that was kind of the -- in my view, the
And
17
first test of could you really do this, could you do it
18
in this adversarial environment.
19
And one of my friends joked, hey, it's the
20
perfect Republican weapon, right?
21
hardware in place, but totally wipe out the population.
22
Zbigniew Brzezinski said, in between two ways,
23
it doesn't matter if it's Republicans or Conservatives.
24
They just use different rationale for accomplishing
25
their political ends.
You can keep all the
On the conservative side, the
Page 98 of 183
173

Page 781 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
220
218
218 of
of308
456
454
46
June
June 14, 2016
Neocon side, it might be the fascination with gadgetry
and new technology, as Zbigniew Brzezinski said, and on
the liberal side it might be the idea that we're doing
this for your own good.
And we've all heard that before.
The government is here, right?
The fact of the matter is, when you start
thinking about mind control technologies as a concept,
the idea that someone believes that they can interfere
with your free will, this is something that most
10
religions in the world say God won't even do.
11
think this is their appropriate direction in technology,
12
to interfere with the way consciousness flows.
13
Yet, men
Now, think about for a moment what are the
14
things that -- what is the easiest way to manipulate
15
consciousness?
16
Create an environment of anxiety and fear.
17
happens at that point is you cannot reach your higher
18
states of consciousness.
19
The easiest way, the simplest way.

Because what
If you look at Monroe, rhythmic patterns in the
20
Hemi-Sync as an example, higher states of consciousness
21
are associated with those rhythmic patterns within the
22
brain; not that incoherent scattering of death and
23
information and energy.
24
25
So if you create a certain environment of fear

and anxiety and you look at an EEG monitor and the brain
Page 99 of 183
173

Page 782 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
221
219
219 of
of308
456
454
47
June
June 14, 2016
activity of an individual, you see it's kind of
scattered in patterns.
higher emotions; love, compassion.
rhythmic patterns.
One person is experiencing

You begin to see
Another simple way of seeing is something that
you can actually measure.
Take two people that are in
love and they -- you know the saying, and I looked into
her eyes, right?
another individual and hold that gaze, you'll begin to
If you actually gaze into the eyes of
10
mirror each other's brain activity in a pretty unique
11
way.
12
long enough.
Two people's breathing begins to
13
synchronize.
Their energy fields begin to synchronize.
Your breathing will even synchronize if you do it
14
And at the same time, their awareness, their
15
intuitions elevate and their rhythmic patterns in the
16
brain can be seen.
17
fear -- think about the advertising you see on
18
television.
19
breath is, you know?
20
uncomfortable.
21
If you can create an environment of
It's all about how you smell, how your

It's all these things to make you
Think about the 6:00 news.
Now, we heard
22
someone talk about the 6:00 news and how that kind of
23
works.
24
people sit down in front of the television set.
25
already fatigued.
You come home from a hard day at work.
Most
They're
They begin to watch the television.
Page 100 of 183

173
48
June
June 14, 2016

Page 783 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
222
220
220 of
of308
456
454
And then their spouse hollers, it's time for dinner;
it's time for dinner.
right?
they're in a light trance-like state.
How many of you've been there,
Nobody's listening.
No one's hearing.
Because
Now, if you look in a dark room -- the
television is here -- look behind you at the white wall
and look at the flicker rate.
coherent signal within a certain range through the optic
nerves, your brain will lock onto that signal.
If that flicker rate is a
If you
10
monitor the brain activity at that time, you'll drop
11
into this highly-suggestive state and now you listen to
12
the advertising.
13
Now, every school of psychology teaches
14
frequency following response today and that you can
15
create these kinds of effects.
16
advertising?
17
advertising works so well.
18
convincing and compelling.
19
Would they apply in
Of course they would.
That's why
It works because it's
When you look at the 6:00 news, would somebody
20
utilize that in broadcasting the news of the latest
21
propaganda from whatever source it's coming from?
22
would speculate -- today I would speculate and say yes.
23
When you think about how simple it is to create
24
that agitation.
25
University who published a paper in 1995 talking about
There was a person at Valencia
Page 101 of 183

173

Page 784 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
223
221
221 of
of308
456
454
49
June
June 14, 2016
this whole concept.
could create a complex signal, broadcast it out over a
large area that just created the sense that something's
not right.
And what he said back then was you
Unease.
And then you go watch the 6:00 news and they
indict some specific ethnic group, maybe it's Muslims,
and then a certain amount of that anger gets diverted
that way.
decided on the laser edge of populations, on majorities,
Well, in a day where a lot of things are
10
this is a very, very powerful tool and one quite simple
11
tool to apply in the modern world.
12
When you think about news feeds today, how much
13
is really investigative reporting and how much of it is
14
just spitting out somebody's press release, right?
15
little investigative reporting today because it's
16
expensive, because it's not immediate, and when you look
17
at the news media today, it's almost immediate and most
18
of it is just meant to entertain.
19
inform.
20
Very
It's not meant to
You know, freedom of the press, it used to have
21
something to do with keeping an informed public so we
22
could make good decisions and we could govern as a
23
public.
24
Say whatever you want, say it however you want, but
25
nobody takes responsibility and we have the neutered
Today we debate the media as freedom of speech.
Page 102 of 183

173

Page 785 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
224
222
222 of
of308
456
454
neutral news.
come on.
50
June
June 14, 2016
And if you really believe it's neutral,
Everybody who assigns a story to a reporter
knows that reporter's biased.
It comes out in the news and what gets published and
what doesn't.
the news?
up.
But no one has really taken it on as a topic and
10
The editors have bias.
How many stories about mind control hit
Occasionally.
The economists might pick it
Somebody might pick up a little bit, a piece of it.
consistently pursued it.
11
Yet, when you think about modern technology and
12
the resolution -- now, we've been talking about things
13
that have happened in the past, and somebody even
14
mentioned this, MK-ULTRA is a program -- you've heard it
15
alluded to.
16
subprojects under it.
17
That was the CIA's program.
It had 144
Most of the records surrounding that were
18
shredded by a guy named Gottlieb, who was responsible
19
for that at the Central Intelligence Agency during the
20
Church Committee hearings.
21
truth back then.
22
this, has become increasingly refined as our technology
23
has advanced.
24
25
We never really got the
But the resolution, the ability to do
When you think about technological advances,

one of the things I read says that technology from the
Page 103 of 183

173

Page 786 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
225
223
223 of
of308
456
454
51
June
June 14, 2016
invention of the wheel to where we are today, it doubles
about every nine to ten months.
Invention of the wheel to where we are today, ten months
from now we're going to double that, and then we're
going to keep doing that.
Wow.
Think about it.
It used to be every five years in the 1980s,
and it kept shrinking as our computing power increased
and our ability to manipulate large amounts of data
increased.
10
Now, a super computer, think about a super
11
computer.
12
was doing this work, about 280 teraflops a second, which
13
at that time would be like six billion people on the
14
planet with hand calculators doing a calculation every
15
60 seconds for 60 hours to do what that super computer
16
could do in a second.
17
A super computer will do somewhere, when I
Well, the next evolution -- some think it's
18
already here -- are the quantum computers.
19
the quantum computer do?
20
will do what a super computer does in a trillion years.
21
It's back to this analogy of how much EMF do we have out
22
there.
23
What will
A quantum computer in one hour
Well, think about the same kind of
24
amplification and computing power.
25
as a concept.
You look at privacy
It doesn't exist in the world today,
Page 104 of 183

173

Page 787 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
226
224
224 of
of308
456
454
52
June
June 14, 2016
right?
tracked, whether it's your GPS on your phone, whether
it's your phone conversations -- in the United States,
every piece of mail is photographed for who it went to
and who sent it.
Virtually everything about us is catalogued,
When you think about your telecommunications,
your Internet connections, Google, AT&T, Verizon, all of
them have violated the very essence of what personal
privacy is all about.
10
Because today, in the 21st Century, we need a
11
revolution, an evolution of what privacy is all about.
12
Because you, experiencing the victimization of this
13
technology, are the pinnacle of the abuse.
14
is subject to abuse of personal privacy.
15
But everyone
You used to think about it, it would start and
16
end in our physical doorway in our home.
17
in your home compared to what is in data banks stored on
18
every single human being in this room.
19
It has nothing
Now, people say, oh, don't worry about it.
20
don't have the ability to collect.
21
resolution to look into it.
22
that resolution.
23
computing first will be able to hack through every
24
security code for every system on the planet within
25
hours.
We
We don't have the
Quantum computers will give
Whichever government finds quantum
They'll be able to predict with so much accuracy
Page 105 of 183

173

Page 788 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
227
225
225 of
of308
456
454
53
June
June 14, 2016
by collecting all that data and analyzing that data, it
will almost seem a spiritual event.
But it will only be accurate up to a certain
point.
And over time that flaw will amplify to where it's big
flaws.
guide our world, to guide our ideas, our philosophy, and
how we pursue the world.
And then there will be a little bit of a flaw.
But we'll rely increasingly on these systems to
The Internet.
What people think about that is
10
the world wide mind of the 21st Century.
11
Public Broadcasting System, did a special called "The
12
World Wide Mind".
13
I say within 20 years or even now -- maybe it already
14
exists now -- but within 20 years that you'll be able to
15
connect the physical minds of all of the people on the
16
planet in a world wide mind.
17
PBS, our
And they say within 100 years -- and
Now, that might appeal to some.
It doesn't
18
really appeal to me from the standpoint of technology.
19
I think we already have that on a certain level.
20
think we already are connected on a certain level.
21
belief systems limit our ability to access that level,
22
but I believe it's here.
23
I
Our
And I've seen enough demonstrations of it.
You
24
know, all those scientists I had in that room for that
25
mind effects conference, the part that really blew me
Page 106 of 183

173

Page 789 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
228
226
226 of
of308
456
454
54
June
June 14, 2016
away that I didn't expect was what they really centered
on was the idea -- and this was Rosalie Bertell, the nun
and physicist, and she said that the next leap is going
to be the leap where we realize or we recognize or we
remember our extrasensory perceptions, our anonymous
capabilities as human beings and that becomes the next
evolution of the human kind.
8
9
And what suppresses that is fear and anxiety,

because you cannot reach those cases of consciousness as
10
long as you're in fear and anxiety.
And anyone who
11
purports or is a victim of these technologies, do you
12
have anxiety, do you have fear?
13
you have the ability to reach those higher states of
14
consciousness in that condition?
15
not possible.
Of course you do.
Do
It's physiologically
16
So when you think about entire populations,
17
whether it's religion injecting fear or whether it's
18
government injecting fear or as my friend used to say,
19
you know, the king keeps you poor and the church keeps
20
you dumb, kind of was the early idea when you think
21
about how things evolved in Europe several hundred years
22
ago.
23
When you think about modern technology on the
24
backdrop of that concept, what's changed?
25
changed.
It's just the same deal.
Page 107 of 183

173
Nothing's
You know, 6,000 wars

Page 790 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
229
227
227 of
of308
456
454
55
June
June 14, 2016
in 4,000 years, most of them over religion; let me give
you a clue, God doesn't need any help killing anybody.
God can probably do it himself or herself.
The fact of the matter is, the idea that people
would just be evil on -- and I think I heard earlier
today that the psychopaths are in the minority.
believe they are.
people, they're out there, but they're not this mass.
Most people do things because they believe they're
I think really evil-to-the-core
10
right, and then they want to impose their rightness on
11
other people.
12
And this is kind of a mistake and then we end
13
up in this conflict between ideas without being fair and
14
recognizing people's right to disagree.
15
said earlier, certain things you can't say in Germany.
16
Certain things you can't say in a movie theater, too.
17
You know, you can't yell fire.
18
sense.
19
And I heard it
Now, it makes good
You don't want to yell fire in a movie theater.

Some would say what we're doing here is yelling
20
fire in a movie theater because we're letting people
21
know what we know, what we've concluded from a good deal
22
of research.
23
You know, my books are written, every page at
24
the bottom of each page are the footnotes.
25
find that distracting.
Some of you
Personally, I want to know where
Page 108 of 183

173
56
June
June 14, 2016

Page 791 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
230
228
228 of
of308
456
454
the information came from as I'm reading it, not a week
later as I'm contemplating it.
source.
I want to know the
And so in the publications that I've written,
1600 source documents, reviews out of a matrix of a
hundred thousand that we had available to us, more or
less.
have made it into four books on technology dealing with
mind effects, dealing with HAARP, dealing with personal
20,000 have made it into my archives and 1600
10
privacy issues.
11
the last four years.
12
A lot of the things go unreleased in
You can look at my publications from 1999 and
13
2000, and you'll see the same things, because the old
14
literature showed enough to come to those conclusions.
15
When I testified in the European Parliament in
16
the '90s, at their invitation -- and this was another --
17
a good side story for technology.
18
name of Thomas Spencer, he was from the UK, he was a
19
Parliamentarian at the time, and he was the Chairman of
20
the Environmental Subcommittee of the European
21
Parliament.
22
given him the book on HAARP and he was very interested
23
in this.
24
I flew to Brussels and spent a few days with him talking
25
about the issue and brought with me a couple feet of
A gentleman by the
And he had contacted me.
So we had a conversation.
Page 109 of 183

173
Somebody had
And at my expense,

Page 792 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
231
229
229 of
of308
456
454
57
June
June 14, 2016
unclassified documents for his research team to take a
look at.
What happened then is he moved in the European
Parliament -- he was a Conservative, by the way, and he
moved into a Foreign Affairs Chairman, a very powerful
position, an ideal position for dealing with the things
that we were dealing with at the time.
8
9
So we -- at his invitation, I came over to

testify in front of the group on security and
10
disarmament in the European Parliament on HAARP and on
11
non-lethal weapons, the kinds of things we've been
12
talking about today, the manipulation of human beings.
13
Now, they do it a lot differently than we do it
14
in the US.
In the US, when you have public hearings,
15
the public actually gets to come.
16
Parliament, the public meeting is you have to have an
17
invitation to come.
18
know, I hadn't really thought much about that.
In the European
So that's kind of different.
You
19
And they also -- they can also do things behind
20
closed doors, which, you know, we theoretically can't do
21
in the United States.
22
the public invited or the media invited.
23
You can't have a meeting without
So what happened the night before the hearing
24
is the Committee met with myself, one of the other
25
people testifying, and a member of the press and we
Page 110 of 183

173

Page 793 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
232
230
230 of
of308
456
454
58
June
June 14, 2016
spent five and a half hours in a non-official meeting to
talk about these issues, so that when we actually gave
our testimony the following day, they would have
formulated a set of questions to give us the opportunity
to follow along.
because then they at least had a good base of knowledge.
So it was a great way to do it,
Now, in that private meeting we demonstrated a
technology using infrasound where you could transfer
sound through electrodes attached to the skin where you
10
would perceive that proverbial voice in the head.
11
demonstrated that to the Parliamentarians in that closed
12
session.
13
We
And then we went into the hearing the following
14
day.
15
her, testifying on our side.
16
the gentleman's name, but he was from a group called
17
GRIP in Brussels that does research on weapon systems
18
particularly and he had done his Master's thesis on
19
HAARP, and so he was there.
20
And it was Rosalie Bertell, which is where I met

It was -- I can't remember
We had someone from the International Red Cross
21
that had done work on non-lethal weapons and was a
22
specialist in this particular area.
23
there.
24
25
And then I was
We each got 15 minutes to present.
And then I
got an hour of questions from the committee in the open
Page 111 of 183

173

Page 794 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
233
231
231 of
of308
456
454
59
June
June 14, 2016
hearing where I had the opportunity to talk about some
of these things.
been this incident in Japan where children watching a
cartoon that had a certain flicker rate had caused over
700 children to go to the hospital with epileptic
seizures.
a problem, right?
to go into the hospital.
And right around that time there had
Now, remember, non-ionizing radiation is not

A flicker of the TV caused 700 kids
Now, some say that was by design.
Some say
10
that was by accident.
11
for talking about non-ionizing radiation in the European
12
Parliament because they had all read that story.
13
fresh.
14
But it was a perfect illustration
It was
The other thing demonstrating infrasound,
15
something that had never been demonstrated, to my
16
knowledge, in that type of a meeting, to show that you
17
could actually transfer sound without necessarily
18
involving the ears.
19
Now, there's another technology that was
20
advanced by a guy named Woody Norris -- he won the
21
Lemelson Prize at MIT for this particular technology,
22
and I believe the year was 2004.
23
Norris -- and his was using acoustic heterodyne where he
24
could send in two signals from two different sources,
25
point them at an individual in the crowd, and they would
Page 112 of 183

173
You can look up Woody

Page 795 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
234
232
232 of
of308
456
454
60
June
June 14, 2016
hear this voice in their head and nobody else would hear
it.
Well, he won a half a million dollars for that
prize, organized a company called ATCO.
them up.
technology to the military for perimeter protection.
You know, where they could have these sort of alarm
systems so when the protestors got too close they'd hear
these warning signs that nobody else was hearing.
10
They're a public company.
You can look
And he sold that
Now, you think about that for a moment.
11
Imagine -- this is why the European Parliament got
12
interested, because we used this illustration.
13
imagine a national leader standing up in front of a
14
group and all of a sudden they hear voices in their head
15
that nobody else hears.
16
right?
17
what that technology can do.
18
demonstration.
19
Now,
That's the end of that guy,
I mean, he's out of there.
And that's exactly
And that was one
Now, some have said that you can pulse modulate
20
on a single beam and create the same effect or utilize
21
something like HAARP, not so much for voice in the head,
22
but for certainly changing emotional state of large
23
segments of the population.
24
25
When we looked at all of this, we even looked

back -- you know, where else could this have been used?
Page 113 of 183

173

Page 796 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
235
233
233 of
of308
456
454
61
June
June 14, 2016
And there was a device in Vietnam called the Lida
machine, L-i-d-a.
named Ross Adey, who is, unfortunately, also deceased.
Ross Adey was brilliant and was utilized by the
government, by private sector as an expert in these
kinds of areas.
A guy who researched this was a guy
Well, he was asked to look at -- this
particular device had been captured during the Vietnam
War.
It was a Russian device.
And it created the
10
entrainment effect using flickering light and sound.
11
And they used it for interrogating prisoners by putting
12
them into that, like, trance-like state and then
13
extracting intelligence from them.
14
1960s.
15
Now, that's the
Again, this is low resolution, low technology.

As computing powers increased, as our knowledge
16
in human physiology has increased, as our knowledge of
17
the electromagnetic nature of human beings has
18
increased, the ability to manipulate large segments of
19
the population comes easily achieved, either as a side
20
effect or unfortunate disaster of our technology.
21
You mentioned Swiss Re, Swiss Re Insurance.
22
Swiss Re Insurance wrote a paper on Electrosmog.
23
believe it was 2002.
24
industry then, don't insure electromagnetic field
25
effects because it will result in a bigger lawsuit than
And they said to the insurance
Page 114 of 183

173

Page 797 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
236
234
234 of
of308
456
454
62
June
June 14, 2016
Firestone on their tires or the smoking industry,
because the knowledge is here and now and nobody insures
that risk.
Lloyd's of London insures anything, but they
won't insure that risk.
Nobody does.
Because insurance
companies don't like to lose money.
that.
before cell phones were invented, the University of
Washington had investigated those very same frequencies
It's as simple as
And yet the telecom industry on cell phones --
10
on chick embryo studies and determined they were
11
harmful.
12
Cell phones didn't exist then.

Then cell phones come out and everything's safe
13
all of a sudden.
14
says, now, wait a minute, we did all this research.
15
This is a dangerous thing.
16
a powerful adversary.
17
That same guy that did that research
But the telecom industry is
So it went to the Congress.
18
There was a guy in Florida.
19
controversy.
20
said, we need a study.
21
pay for the study.
22
study.
23
You remember this.
Brain cancer.
It ended up in the Congress.
Big
Congress
So the industry says, oh, we'll
They spend 25 million dollars on the
I can't remember the guy's name who did it, but
24
he eventually published a book because his findings
25
were, hey, this is dangerous.
Page 115 of 183

173
All right.
He issues his
63
June
June 14, 2016

Page 798 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
237
235
235 of
of308
456
454
report.
they got the 25 million into his queue.
it all on these projects.
himself.
5
6
They figured, hey, they got him.
You know,
He got to spend
He got to make some money
Hey, he's our man.

Well, he wasn't.
This guy actually had some
integrity, and I apologize for not recalling his name.
A VOICE:
DR. BEGICH:
A VOICE:
10
George Carlo.
Which one is it?
George Carlo.
DR. BEGICH:
George Carlo, that's correct.
And
11
he wrote a book called, "Cell Phones", a very important
12
book.
13
And when it comes to children, one of his
14
observations was -- he had the simple observation of
15
damage to skulls.
16
five-year-old, 400 percent more energy transfers to the
17
skull into the brain than an adult.
18
twelve-year-old, approximately 200 percent.
19
You know, you have a four-year-old, a
Ten-year-old,
This is one of the main reasons why you don't
20
want children using cell phones or, even worse, the
21
portable phone in the home because it's even less
22
efficient with the battery and the energy with even more
23
leakage.
24
phone today where you actually pick it up and talk into
25
it.
And what do we do?
Try and find a hard line
You can't even find them anymore.
Page 116 of 183

173
They're almost

Page 799 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
238
236
236 of
of308
456
454
64
June
June 14, 2016
impossible to find.
When you look at what we have learned about
human physiology and the effects of electromagnetic
fields on the human physiology, it is the revolution in
science that will collapse the pharmacuetical industry
one day.
recognize that the pea in the soup of electromagnetic
radiation has been the cause and the root to most of the
chronic disease we see on the planet today.
10
And one day we're going to wake up and
When you combine that with that concept that I
11
used, that example of iodine, everyone has a little bit,
12
now you have these complex interactions, 5,000 new
13
chemicals are introduced or compounds introduced to the
14
public every year without really any serious studies,
15
and then you add this on top of it, and now you have a
16
very toxic world.
17
manipulation from the propaganda of World War II to the
18
downloading of that.
19
achieve?
20
personnel with a download.
Blap.
21
years' worth of education.
Now, let's go on.
22
And then you take the technology of
What does the military hope to
They want to be able to train military
And now here's the thing.
23
kind of education.
24
programming.
25
thinking involved.
There's your 12
Think about that
No critical thinking involved.
It's like writing to a disk.

Who controls that?
Page 117 of 183

173
Just
No critical
Curriculum

Page 800 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
239
237
237 of
of308
456
454
65
June
June 14, 2016
controls the way in which our society goes.
risk.
This is the
What about evidence in courtrooms when you can
create a synthetic memory or wipe one out?
that do to a Democratic Republic or a Democracy where
people have the power?
us as we become increasingly transparent to governmental
agencies and they become increasingly opaque.
What does
That power has been taken from
It is the opposite of what should be occurring.
10
There shouldn't be a camera in every household.
11
should be a camera in every government office.
12
the technology's there.
13
and look at what our employees are doing, right?
14
Wouldn't you like to be able to dial up your
15
Congressional office and see that conversation they're
16
having in real time?
17
that?
18
There
Because
We should be able to dial in
And why shouldn't we be able to do
What do they have to hide?

You know, you think about government and you
19
start saying that and, you know, the only people
20
protected from that kind of intrusion in the US are
21
federal employees.
22
protection than the average citizen within the country
23
that I live in.
24
25
They have a higher level of
For what?
And when you think about government, everyone

points to the politician.
I can tell you, most
Page 118 of 183

173

Page 801 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
240
238
238 of
of308
456
454
66
June
June 14, 2016
politicians are ignorant.
parties in the United States the preference is to have
people that are -- they look like the news announcer,
but they couldn't think their way out of a phone booth,
right?
they couldn't think their way out of one.
want people that are smart enough to look good, but not
smart enough to think on their own.
politician for political parties, because they can be
10
In fact, most political
We don't even have a phone booth anymore, but

Because they
That's the ideal
told what to do.
11
Look at how much money is being spent in
12
political outcomes.
13
have pointed and looked at, like, Australia to mandatory
14
voting.
15
Huge amounts of money.
Some people
Everybody votes now.

Worst possible thing that you could ever do.
16
And here's why:
17
pulls the lever?
18
maybe 20 percent of the population votes, but at least
19
they're informed.
20
When the population doesn't vote, who

Those that are informed, right?
So
They've educated themselves.
If you force people to vote to keep their
21
driver's license, their medical benefits, or whatever
22
social programs you've got running and you say, you will
23
vote, now who decides what they vote on?
24
buy the 30-second or one-minute ad on TV that influences
25
them.
Whoever can
The moment they walk into the booth, they go, ah,
Page 119 of 183

173

Page 802 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
241
239
239 of
of308
456
454
and pull the lever.
A very dangerous situation.
67
June
June 14, 2016
Now we have a dangerous situation.
Democracy is something that each of us have to
claim internally.
The change that people are looking
for in this group happens by a change in consciousness,
by us recognizing what we are as human beings,
recognizing the potential that we have.
know what these government programs yielded?
points to the fear side of the equation.
Because you
Everybody
But what they
10
really discovered was that every single soul, every
11
human being has this anomalous capability.
12
Now, imagine if we could awaken those
13
capabilities, could you hide anything?
14
people could literally look into the mind of another
15
person, that makes a politician pretty vulnerable,
16
wouldn't it?
17
I mean, if
That is the next evolution that I believe is
18
happening and it's the only evolution, the only
19
revolution that can change the way things are.
20
starts with human consciousness.
21
believe to be right and true and beginning to act on it.
22
Not from a foundation of fear, but a foundation of
23
confidence.
24
25
It
It starts with what we
You know, somebody asked me once, what do you

think about faith?
I said, faith is what you know to be
Page 120 of 183

173

Page 803 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
242
240
240 of
of308
456
454
68
June
June 14, 2016
right and true and you step into it on the idea that you
can achieve it.
You believe it.
So many people I've seen in this work, they
keep jumping into things beyond their belief.
don't believe they can achieve it.
and they fail, and they keep failing.
are doing good work otherwise step back, do what you can
do with confidence, do what you can do with knowledge,
don't wait for a group to form.
They try it anyway

And people who
The group's already
10
here.
It's called the human race.
11
to be right and true.
12
up, learn from it, and move forward.
13
They
Act on what you know
If you make a mistake, clean it
When you look across this room and you look at
14
all these folks with a little bit of gray hair, and
15
you've got the gray hair not by all of those great
16
things that happened in your life, but by the real
17
disasters that happened in your life.
18
think about bad news is a stimulation for good news.
19
You know, you
People ask me, you know your father's
20
disappearance, disappeared off the face of the earth,
21
that must have been a horrible thing.
22
the time.
23
life because it altered my course.
24
25
Yeah, it was at
I consider it the most important event in my
The worst things in our lives alter our course,

change our direction, activate that higher potential
Page 121 of 183

173

Page 804 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
243
241
241 of
of308
456
454
69
June
June 14, 2016
that cause us to rise out of the ashes of our apathy and
our defeats and stand on our feet again and move
forward.
The pain that people experience today is the
catalyst for the solutions tomorrow, whether we like it
or not, whether it's falling down as a two-year-old or
standing up as an adult.
our ethics, on the basis of our values, and we
reinvigorate and let go of the fear and recognize what
If we stand up on the basis of
10
we are as creative beings, we have the potential to make
11
change.
12
And with that, I'll open it to questions.
13
(Applause.)
14
15
16
17
18
19
20
21
22
23
24
25
Page 122 of 183

173

Page 805 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
244
242
242 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
Page
123
10
18
7
11of
1of
of
1of
of
51
172
173
174
of
51
176
51
173
183
51
51

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
5, 2015
2016

Page 806 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
245
243
243 of
of308
456
454
"# $
%" "&##'(
#$
" "
*
#)
/ * .
.
/-
.
*
! #!" ! !
+
% &!
- / * )
0
) . ) 0
3
-
. /
-
9::;
0
)
)
*

June
June 14, 2016
'
,
)
0 )
*
- 0
0 . - 0
.
0
0 ) .
' -
* .
0
/
/+
1 ,
-
/
*
. /
5678
9::;
/ .1 0
0 )
/
)
/-
) -
* +
#-
!"
)
'
'
! # (
)
<
,,
!
344///
2
4
,!
6666666666666666666666666666666666666666666666666
7, , *
,
- ,
/ *
* 3
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
Page
Page
124
11
29
8
22
1of
2of
of
2of
1
of
51
172
173
174
of
51
176
50
51
173
183
51
51
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016

Page 807 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
246
244
244 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
Page
125
10
12
39
33
2of
3of
of
3of
of
51
172
of
51
173
174
176
50
51
173
183
51
51

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016

Page 808 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
247
245
245 of
of308
456
454

June
June 14, 2016
"
%
"
/
4 4 2 1
12! 1
"
'
"
& %
) '
$
!
)
($
!&
#
%
.
&"
&
+,
#
$
'
"
$ %"
+,
'
"%
$
$%
$%
)
)
"
"%
"
%&
)
#
"
&
'
$ ($ "
%
"
"& %
) "
""
"
%%
# & & &
) "
$
$
$ % )
$
#'
% )
&
% '"
&
"
$
"%
%%
'$
"
" !
+ % /
0$
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
Page
126
10
11
13
444
3of
4of
of
4of
of
51
of
51
172
173
174
176
50
51
173
183
51
51
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016

Page 809 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
248
246
246 of
of308
456
454
8 *
- =8 *
<
*+ ;
<
)=
@, #-
) .-
) . #
<
0
A,#-
) - - 0
0
.& !
#
5697 > - )
0
0
4
0
-
0
0
/ .C
0)
0
.
?)
0 .
? 0
-
.>
- 0
0
.
#-
- ) -
.
- 0
)
-
.
.
.
) -
3
.
<
/
0
)
/
00
/ )
0
-
) 0
)
- - )
2
.
-
0
0
)
0
+ ,
-
. .
0
.?
)
?- 0
$ 8 *
9
: *
0
/ )
0
/- 0 *
/ )
) )
)
)0
) .
4
* .
0
0
0
+D 5 :::,
0
0
)
) /
0
+ , /2
))
. .
0
0
0
)
)
#- "
-
) -
) - <
- B 0
/* .
-
/ -
. .
#
- <
.-
0
) -
.
.
/
- .- .
.
.- 0
" .
) )-
(
)
.-
0
0
-
*+ ;
9,
?
-
)
-
5, #)
-
#0
. >>>
&

June
June 14, 2016
*
-
/ .
0
/ )
4
. 0
)
E
EE
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
Page
Page
127
11
12
14
555
4of
5of
of
5of
2
of
51
of
51
172
173
174
176
50
51
173
183
51
51
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016

Page 810 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
249
247
247 of
of308
456
454
B
) ?
)
? 0
) 0
- /
.
/ - 0
. )?
)
B
) .- 0
/ - )
)
0
)
0
/ - ) - -
?
/
/
) -
)
)
? 0
00
)
)

June
June 14, 2016
/
0
.
) 0
- )
#-
. )?
) -
)
0 * . -
0
)
/) 0
. -
/ -
) -
00
) - -
0?
0
00
?
-
) F 0
0
-
#-
.
/ - 0
) .
)
00
) 0
)
-
- ? !
. -
/ -
00
00
? 00
?
) F0 *
/00
. .
0 0
) - .
-
0
)
- -
00
/- 00
.
-
0
8
+ , !
0
F0
00
) 0
.
-
0
)
/- -
/- ))
/-
/ / -
0
-
F0
0
.
-
.
)
F
.
.
*
/ -
0 *
) 0
-
.
-
0 /- - /
0
0
*
)
0
)
) F
) - ) /
)
)
0
)
? 0
/ -
.
-
)
)
)
) -
? 0
) /- -
?!
.
.
) 0
00
)
)
.
0
5:
) )
.
)
,
/- / )
0
-
? 00
) 0
))
/ /- / -
2
/
.
/- -
2
.
0
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
Page
Page
128
12
13
15
666
5of
6of
of
6of
3
of
51
of
51
172
173
174
176
50
51
173
183
51
51
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016

Page 811 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
250
248
248 of
of308
456
454
+ , !
0
/00
)
/-
)
0
0
.
) / *
.
+D 5 :::,
)
0
0
0
.
0
F C
+5, #0
) 0 0 * . -
- .
0 *
/ - -
0
0
- .
- #-
0 *
00
/ *
. 0
5: 0
0 * . 0
- / *
) 0
.
. . 0
-
+ ,
+ , + ,
3
.
. -
+ ,
+), )
+., B
0
-
) -
0
B
)
0
/-
)
+D5: :::,
) )
0
))
0
/
0 -
0
-
/ .
0
-
)
)
0
/-
)
-
0
-
00
0
00
)
-
/00
. / -
0 *
+ , + ,
0 ?
0
/-
+/ ) .
4
/ - 4
)
/
-
00
?
) F 0
* .
*+ /
0
00
-
0
. /
. 0
0
.
0 .
0
F 0
/ ) 3
+! B,
.
, .
* /
.
)
.
2
1
0 . .
.
+
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
Page
Page
129
13
14
16
777
6of
7of
of
7of
4
of
51
of
51
172
173
174
176
50
51
173
183
51
51
+
. 00
0 *
/- )
0
0
/ - /- 0 .
. . 0
2
. -
+ ,
)
0
/ - 9A=-
0
0
0 *
0
-
)
/
0
00
+9, #-
00
.
))
) -
+ ,
))
00
/-
00
)
0
0
)
0 *
-
/)
/ -
!
0
0 *

June
June 14, 2016
0
/ ) 3
+< B,
0
)
.
)
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016
0

Page 812 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
251
249
249 of
of308
456
454
0
0 / =
. )
=
0
.
0 .
.
)
0
. 0
0
)
.
)
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
Page
Page
130
14
15
17
888
7of
8of
of
8of
5
of
51
of
51
172
173
174
176
50
51
173
183
51
51

June
June 14, 2016
=
=
.
) ) 0
/
0
F
. - 0
.
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016

Page 813 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
252
250
250 of
of308
456
454

June
June 14, 2016
!
"
#
$
& #
'
"
"
# )
* ()+
"
,
/
."
1
!
#
%
3
"
)
. #
#
"
#
5%1%
%4
"
%/
"
-
%
#
,
0
%2
""
%4
"
"'
#
"
!"
"
0
!
()
6
&
%9
#
-4,
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
0
:
'
"
"
%
#
'
" #
"
"
%
# #
Page
Page
Page
Page
Page
Page
Page
Page
131
15
16
18
999
8of
9of
of
9of
8
of
51
of
51
172
173
174
176
50
51
173
183
51
51
()
# %
"
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016

Page 814 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
253
251
251 of
of308
456
454
.'
'

June
June 14, 2016
%
#
#
"
"
"
()
%'
;
"
%
<=
#
"
"
5%1%
9
"
"
!
@
()
"
"
%
(
(
!;
.
!
# %
,
-1
.
511
"
""
"
1
()
#
"
,
(
A 1
"
%
"
"
%
"
#
.
%
,
"
4
%-
.
%'
$
#
4
)
;
#
#
-4 ,
>?
#
5%1%
"
%B
"
#
5%1%
%
4
#
#
@
#
"
"
C%%
%.
)
"
'
-:
% -@ ;
%'
.)
"
%@
%4,
"
"
%.
D $
2
!
) $&
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
C%
Page
Page
Page
Page
Page
Page
Page
Page
132
10
16
17
19
10
10
910
10
of
of
of
9of
51
172
173
174
176
50
of
51
51
173
183
51
51
E
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016

Page 815 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
254
252
252 of
of308
456
454
!
)
"

June
June 14, 2016
& '(
*
+ &$ #
*
$'' ,&
./0 1/.2
" #
3
$*
) $
0
0
&
"$
)
**
! 34
0
3 "
0
# &
*
" "
"
& $
5 " )
&
'
$
)
# 3
$
"
.678
0
'
" "
)
&
) '
&
" '
$*0 3
0
& '
0
& '
) $
' &
$&
'
9$*
"
:
0 &0
' ;,
&
,
<
"
) $
,0
' =. >
"
'
"#
&
$
) 1/.2
& '
#
&
$
&
)
,#
&
24.;9&#9/12269
)
?
$
*$
) 3
&
3 '
!
&
)
!
&$
$
)
.29<;//
#& '
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
133
11
17
18
20
11
10
11
11
of
of
ofof
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
111
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 816 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
255
253
253 of
of308
456
454
!
'

June
June 14, 2016
" #$ $ %
)'
%)
&
%
*++
!
"
#
"
"
&
'
)' +
"# - /
*
2
5 #$ '
(922
(34
( 6
2
(
0
(
8 ' (
69
(
(
!
%
'
',%
/0
2'
" !
( )%
"
'
#%
'
'
,
%
2
*
'
+
0
(
'
, - .$
%
*
"
-
"% .
"## $"
%&
&
)
.
%
-
%' ( )*+*
+. *+ /
0! ) * . *++
0! ) . *++
0$
&
2
$
1
$
!%
!%$
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
134
12
18
19
21
12
11
12
12
of
of
ofof
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
212
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 817 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
256
254
254 of
of308
456
454

June
June 14, 2016
)( )*+,
)*+,
.
"%-
"
!
3
"
% )
)4
"
.
.
*+ /
3
"
3
$ -
/ 1
-" $%
1-"%
"
5"%"
5!
#' .
"&
5"
3
!
!%$
.
!
-""
).
)?
-""
#$ $
! !
5/# 4
5" ! #" /#
#"
)*+6
%!
# %
9!
"$'
%#"
4 -"9 %" 5"
%" 5%"" ?3@ A "# /
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
# 5
4%
5/%&
" / /
$9
/%! /
!" !"
5/%&
Page
Page
Page
Page
Page
Page
135
13
19
20
22
13
12
13
13
of
of
ofof
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
313
of
41
= 5
-"
& ! 10" / $
&"9/!/" !' 4/ 5 &/%"!
&
&"
&$"
4 #
"4
# $$"# "&
% 01"
5"
& !
9 <
5"
! %"
/# %/!
5" ! #"
4 - #"&
/#!
5" %' 4 # 9/ "&
&
2 4"."%
5" )*+6 2 -" #
5"
1/! #
1/! # 4 # 9/ "&
%/
+67*),,8 /
9 "% 9/ / $
1"&
; %/#&/! /
% #"!
) 1
) '
" 4 #
1-"%
5"
" $ $"& /
5"%"
; "
) 1
0$
/!5" "
"0 % 1"
5 4 9 1/ '
36**
/#
5)
!
)
"%-
4 % / $
+88+
! !
"
9 !
1 %&"% /
"!
10 /$
<
& 5" ! #" 4 # #

%
7$
/# %/!
"## ! %% - %
/!"
& 4 # 0%"#/&/ $ #/ !" / :# 9/ / $ /

"&
-'
# "%
"./&" !"
3 ;
" / /
9 % 5"
" )3 )*+,
%0 #
0$
&
"
A!
"
""9
"% 2 ! / $
%
!
.
)
) " *+ /.
'$
<
5!
0$
"
.
!
10
' %
" <
<(> (
<
)
3
""
"
<
"
"
%! ) !
0$
"
*+ +
.!
!%$
& )
) !
35
"
!%
)'
4/
35
6 !
"
*+ + ) '
"
"
"&/
&
!"&
"
&.
4 )
% )
&
" .
"
5"
" &
5 !
/1
00"
/%! / 1 ' %
"
/#
/!5" "
#
5"
10" "%
9 %
"
-" 9/ "& -' 5"

#
#"
B 45" 5"%
+,>
9%""
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 818 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
257
255
255 of
of308
456
454
/#
/!5" "
1-"%
% $%
5"% 5"% 2 -" #
%0 #
&$1"
"%-
)4 )
"
!
"/
0! )
!
%
<
!
!
"
5#
"
4 )
)
$ -
"
"
! ! .
C!
"
0$
) 5
D
B. *+ /
%
!%
.
!
! !
% #
"
"
<
"
& 9"&"%
0$
%
"
"
.4
3 5
%
)
#/
. *+ /. '
% $% 1 -
1"
0$
%
! /
5
%"
!/./

June
June 14, 2016
& 45" 5"%
$%
11 %'
"
<
" 4 )
"
"
EB++$++$
0! )
. *+ /
-""
. -""
"
!%.
!
%
"
! !
. *+ /
"
<
<
) 4
&
<
*/+
)
4
"
<
) '
<
"
(
.
> $
C!
/9+B
/$
%%
. &'
! $
"
"
"
0 ""
"
<
C!
/B .
) 0!
%
!%
*B. *+ /
.
"
#$ $ 4
%!
*+ /
"
"
0$
)9 9
! C
$
@
3 .
0$
!
3
"
4$
!
!
!%%
)%
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
"
"
! "
! !
35
"
'
"
.
4
"
"
)
$
F+* %
* !
' %
"
)
)
8%
<
0!
!%%
0$
Page
Page
Page
Page
Page
Page
136
14
20
21
23
14
13
14
14
of
of
ofof
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
414
of
41
& @
)
).
!
)%
'$
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 819 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
258
256
256 of
of308
456
454
%
" *+ /
0$
!
%
B$
0$
"
%
4$
0! ) *+. *++
"
'$ 4
%
. '$ $. "
"
4$
% !
)"
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
#$ $
>
! )
)$
. 0 $.
!
%
0$
"
(=5->( "
) "
"
.
.
"
%
"
"
4$
B+? $
"
> 6
3
4$
3
+?
"
!
"
3 )
%
%
4$
"6
/!
)
!
/&"
.
!
"

June
June 14, 2016
7
) " %% 8
) D/
4
3
) "
%
Page
Page
Page
Page
Page
Page
137
15
21
22
24
15
14
15
15
of
of
ofof
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
515
of
41
&
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 820 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
259
257
257 of
of308
456
454

June
June 14, 2016
2
0$
%!
""
F
"
1!
)
1
""
! $
"
$.
&1. <
.
! )
!
$
9
"
"
5"
1!
""
"
"
.
3
.&
"
7
/
"
)
%
&"%
&
"
"
)H
"
"
8 ** )
"
%
+? $ -
%
%!
$&
). %
0$
"
C "%%
'-'
"%/
7
%!
5/%& ?3%&@ %$"# "10

/.+++
% )
$
1"#
"
>
).
).
0$
8%
)H
9!%
!
%
>
*F.
)
%
0!
" ' "
6!
"
$.
'
"
"
0$
) .
!%
"
"
"
" !
%!
! )
)$
!%. <
' %
&
3 !
"
0$
** )
"!
G0
""
"
? "
>
$
"
%!
'"%
" <
. 4
&
! ) "<
.4
F
$
9
"
*$
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
138
16
22
23
25
16
15
16
16
of
of
ofof
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
616
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 821 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
260
258
258 of
of308
456
454
"
" %$" 2 D
)
"#. "
) "' "
-"%
--'
'
%!
""
#$ $ 4
'
,
'
"
"
" '
)
&"% 2 /$. "

'
J
"
. "
'
&
#$ $
&". "
#"05
!
%% %
%
.
. "
!
"E
"
#5. "
$

June
June 14, 2016
"
"
.
7
6 !
>
=
)
"
" = %
"
"
$
%
%& " C
"
!
!
-""
5
!
%& "
!
#$ $
& # %/"#.
!
!
&
$
"
"
#$ $
$
%
F
E
"
" 1
"
"
"4#C /
!/
/1"#
G
"
%
%
>
@ %%
"
"
"4# )*C)*
6!
)
! ) .
G
)
"
A$
""
"
'
!
"
"
4
)
1! "
!
.
)
$
-
0! )
*
) 0
"
% =
H
! )
"
0$
!
5
!
" <
3.
"!
&1. < $.
"
0$
?
$.
0
!
K
%
$
%
"%/
<
) 0
!
% .
1!
<
9
+9++ D <
E $ /
"%/
%
.
>+88*>**(6 <
% =
%
)
"
"
3.
4
?
9
$
0$
!
"
4
!
. 0
5
3.
)$
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
139
17
23
24
26
17
16
17
17
of
of
ofof
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
717
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 822 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
261
259
259 of
of308
456
454
June
June 14, 2016
%
.
"%/
9
+9++ D <
! )
!
"
4
.
5%/# 05"%
&"%5/
" 6
. #
K 5 ! 3 .
%
0
1!
$
*++/
%
#
%
&
% 4
' %
+/9 9**
#$ $ '
!
"
(
'
"
4
)
(=5->( $ <
! )4
. $ $.$
%
4
0
9
) 0
"%/
%
+9++ D <
%
%
<
3$
7%
0
)
"
1!
"
4
.
!
*++
) #$ $
>
>
""
!
.
H
)
H
H "
H "
!%
!
.
% $
)$
! H
%
H %!
!%
"
"
". !% !
C! )
$
8
%
% %!
"
"
"
9 !
"
"
!%
"
"
"
9!%,
)
%
) 0$
"
"
$
) "
$
$
)
(8
@
E7
%
"
)%
"
!%
"
"
%
"
). "
)
""
%
)
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
)
.
$
.
!)
)
"
C!
#$ $
G
"
" <
$.
"
)
"
Page
Page
Page
Page
Page
Page
140
18
24
25
27
18
17
18
18
of
of
ofof
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
818
of
41
!
%! !
$
.
! $
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 823 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
262
260
260 of
of308
456
454
) "
!
)
%
. "
C!
) .
"
*++/
) "
'!
>
"
$ 6
!
"
"!
"!
"
"
" %
% 8
"
"
)
>
" C!
$ 5
= %!
! %
3 )! %
0$
".
'
"4
$
"%00"
#"
" /
9 "%
-"%
9 )**F
"0 "1-"%
& 5" !" #"
B. *++/
3
#
.
%%
5
3 !% )
"
'
'
!
& 5 # -""
# !!"##9
9 )**F
9
3 !% )
-" !
"
$.
$ +/9
-' 0
5/%&
/%! /
"&
0$
"
4
%
5" #"! %/ '
"
"
& )
"
/99
& & " 0% !"##
0$
!
5"
9 ; # /!"
#
%
4/ 5&% 4
/ $ /
-# % ! /
) 4
5" ! #" 4/
.
!
$ +/9*F+/ $
"
!
"&
%%
<
& &"#/#
(=5->( $
# ?*(>66(6@ /
5/# ! #" /# # /
9 "./&" !"
&
*++/
**
'
#$ $
" ' "
0$
' %
) %
%
"
L 3
!%
"
2
)
"

June
June 14, 2016
) '
"
%
!
!
" !
C!
"
9 -
7
%
3
)
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
141
19
25
26
28
19
18
19
19
of
of
ofof
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
919
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 824 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
263
261
261 of
of308
456
454

June
June 14, 2016
D
-
"
$
!
7
"
+?
)%
#$ $
)H )
<
*++/$
!
&
<
"
< !
. !
"
! !
! !
)H
) "
9 !
!
"
A!
! .
(=5->( $ <
"
&
!
$ &
$.
"
"
+/9
9**
F)
#$ $
-""
"
"
"!
)?
)$
0$
0$
"
#$ $
"
"
) 4
! $
0$
%%
*DG
"
"
! )
!
""
)
!
#$ $ '
*++/
%
) 3
)
!
!
! !
% $
. =
) %
"
3
"
0$
"
.
""
M$
. % 3
%!
"!
5!
"
"
*++B
%
" *++
)H
&@ #< =
0$
H
! %
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
8
H
Page
Page
Page
Page
Page
Page
142
20
26
27
29
20
19
20
20
20
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
10
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 825 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
264
262
262 of
of308
456
454

June
June 14, 2016
2
" ) !
4
"
"
"
"%-
"
) "
" <
0$
).
3
,
5"%
1 "
!
"
7 %
%$.
3
$ 6
"
"
!%
&
!
&
$
%
5"%
1 "
"
%
5"%
7 %
5 1 # D
.
"
' "
! %
"
. 0 $.
8%
! %
' %
0$
)
H
)
"
. !
' =4
?
.
H ""
%
0$
" ' "

"
$ 6
" &@ #< = $
"
"
B+?
"
"
!
%
)
!
)
.
"
' %
< '
&
"
"
" &@ #< =
) '
'
"
%) %
>
&
5%
3 ) %
"
"
)
'
)
"
"
&
%'
3 )
". !""
)
"
3 )%
"%-
)3
)$
0 $.
"
"
$ 6
0$
"
"
". !""
!
"
!""
"%-
1/ ' 2/#
".
0$. 5 %
5"
"%-
!
)
"
% %
" &@ #< =
!
H
"
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
143
21
27
28
30
21
20
21
21
21
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
11
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 826 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
265
263
263 of
of308
456
454
"
"
"
"
)
1 "
"%-
"
"
<
"!
"
%)$ (
' %
)
0
" <
. 4
)
!%. <
" "
.
$
"
"
?
%
& @
&
).
"
%
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
0
)
) "
"
"
"
"
)0
"
"
%
"
).
-?5
! .
"
)$ L !
. *++
4$
8 B
!
#$ $
!
Page
Page
Page
Page
Page
Page
144
22
28
29
31
22
21
22
22
22
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
12
of
41
"
.
3
"
"
0 $. "
L 3
""
.
)4
. 0!
>
0!
<
"
"
$.
4$
" *+++$
" <
" *++ .
%%
"
>
0!
& )
&
* .
"
"
. 0 $.
"
" <
"
$. L !
"
)
"
! %
3 "
"
% $
"
M$
) "
&
"
%) (8%
! !
"
B+? .
<
. 0 $.
. 0 $.
-='(=
)
&
4$
"
. 0 $.
" E +$++$
!""
4$
&
E*++$++
!
43 .
.
"
"
$ 5
4$
" "
"
+? $ 6
. 0$
0!
%
!
<
) 0
"
).
"
>
#$ $
.
!
"
"
"
&@ #< = $
&
$ 5)
$ 6
DB
"
DF
%
%
) "
. %
)G
)
$ 6
>
5"%@
1!
G
%

June
June 14, 2016
),
"
!
E +.+++$++$
&
' )
$
6
!
3
%
$
"
%
" #$ $
:
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 827 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
266
264
264 of
of308
456
454
!
" )
"
; %
%
$
!
1 "
.
"%-
"
" ? %
0$
"
"
"
$
1!
? -""
8
"
<
"
"
"
' %
!
99
%
"
" 4
"!
8
6
0!
5%
"
"
/$
&
"
) 4
)
8
$ 4
. 4
"
$. +/9
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
3.
' 4
Page
Page
Page
Page
Page
Page
145
23
29
30
32
23
22
23
23
23
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
13
of
41
3 )
"!
" #
" 4
"
)
.
0$4$ &
"
&
"
"
.
%
' 4
9**
4$
"
4$
"
B$
'
!
&
"!
$ <
<
1!
A! )
'
(=5->(
"
7 %
$ 4 )
" $
"!
4$
"!
"
"
#< -> 5 >@

)
3 E *.+++ "
!
"
'
" ! %
3 )
"
! "
$
77
"
!
5"%@
"< '"
%
>
< 'M
) "
" ? %
"
"
"%-
5)
0$
!%
5 1 #
"
% )
!
. 4
! C
*$
3 )
"
" " ! % )
5
!
"
D.
"
""
! "
D.
<
*/.
!
0$
"'
"
4!
"
)1
) 1
&@ #< = $
"
"
+$
" !
< ' 8%
"
A!
"
5"%@
*F.

June
June 14, 2016
!
)"
?
*F*F >
0$
$
"
'
!
3.
43 .
"
"
&$ @
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 828 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
267
265
265 of
of308
456
454
@
.
8 !
" <
>
% %
"

June
June 14, 2016
!
" <
6
"%-
" /#
%"1
"
8
!
%
$ <
"
).
" ./"4"% ?
%
#$ $
8%
3 )
"
+$
M'
&
7!
!%. <
)
!
E*+.+++
"
"
5"
5 5/#
"
"
"
& 5" !%/1/
"./"4 5" 4 %& J "
"
M$
+ J .
) @
"
" 4
!%. <
$$
"
!%. <
) E ++.+++
!
$.
A! )$
%"! %&#
)"
%
A! 3 )
"
)
&
%%
"
>
"./"4
5" 3
5!
5"
%!
<
%
&
"&
) "
/!/&"
%
)4
' %
)
& )
"$
!
" <
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
. 4
"
"
0
Page
Page
Page
Page
Page
Page
146
24
30
31
33
24
23
24
24
24
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
14
of
41
!
"
,
!
0! )
<
"
) H
"
) >
%
)
"
"
%%
' %
H"
!
#B " ! B
)$
"! %&
#/
%
-%/!
6
%/1/
"
!
)
B &"
""
) (
#/
"
%%
""
. "
) 5
- *
,
" >
0$
!
)
)
3
"
%'
" !
5" 1"
0$
&
<
/.
$.
%
$
"
& 4
!
%
MH
).
8
&
%
"
0$
%%
0$
"!
&
"
*9 %
3$
0$
"
"
"
"
%!
"
!
"
" ! )
3
6
0$
" 4 ' / @.
!
!
" #
J . *++/
. *++
6
"
F+*
) 0$
!
0$
! !
"
)
%%
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 829 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
268
266
266 of
of308
456
454
%
%
" $
!
$
" <
. 4

June
June 14, 2016
%
"
*++
(=5->(
#$ $ '
"
"
'
"
2
4!
4
"
""
"
<
#$ $
"
"
<
)
++
)
"
F.+++
0$
!
D+.+++
'9=-&
"
0$
"
>
"
"" $
"
#$ $
"
"
&
"
!%.
4
<
-""
"
H' %
(
% H
"
"
H <
H <
"
"
)
0$
1 "
"%-
H <
!
%
H <
% H &
!
% )
1 "
"%-
<
(
.
"
4!
5"%.
!
% H
' "
" 1' 9
H <
! ) 1!
"
% H
-""
5"%.
% H &
% %
$.
>
. <
H <
H <
H =
!
(
'
"
8
&
!
% %
"
D
$
$"
% ,GG
1' -%
"
7
!%$
""
$
$
$
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
147
25
31
32
34
25
24
25
25
25
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
15
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 830 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
269
267
267 of
of308
456
454
2
PP
-""
#/ $
"1
9 "
"
"!%"
/K"& -' ! %0 %
-%
&! #
% "&
J "&/ 1J
"1
5/#
D2
"
# !
9 1 #
"E0"%/1"
#"!%" /." 9 % #
&% 1
" 5
/"4"%#
5" ".
/# /10 %
! 11"%!/
/"4"%

June
June 14, 2016
"
9 5/# 4%/ / $
1"%/!
& !"%
# 9 % %" &
'#/#
"!5
$/"# - %
9 5"
&
5" %"#
5/# 5 # %"!"
/ $
' -""
# #" #
#
& "E0"%
"!5
$ "#
"# /9/"&
"
/"4/ $ 5 # %"!"
" ,** ! 10
"0 % 1"
$/!
&.
#
!"1"
%'
5/# # 1"
"
%"
5/# /#
"9" #"
# !
5"
5 & %"! %&"&

4 #
'
/"#
& 1 % " 9 %"! # #
#"& /
' 8 )**F
# 4/ 5
"1
9 5" " &/ $
'
" "./#/
% &/
/."
5'#/!/#
'
, 0! ) * . *++
0$
&
1 !%
2
$
$
!%$
5" 9
4/ $ %"
$"% / #"%./!"7
$
!%$
%
$
$
$
G
!%+
$"
3$
G
$
$
G
$
$
$
G% " G
0
%,GG
$) ! ! $
G
!%
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
148
26
32
33
35
26
25
26
26
26
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
16
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 831 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
270
268
268 of
of308
456
454
"0 "1-"% ( )**8

June
June 14, 2016
0$
&
!%
*/+
<
.4
'
B+F
3=
6
4$-$ 5 8 +**
.D/*+
4
9 ++9/ 9/B
8 9 BB9DFF9D +
, " 2"
"
"7 #
."%
'
3.
&) %
&
! $ '
6
) !
)$
) !
3
9
!"L
%."/
'
! # "%
3.
) Q
'9=-&
."
$
3
*++/
%
$
4
$M
7
<
3
$
%
+?
%
)G
&
1 !%
!"
!
&
'9=-&
!%$
.
!
"
)$ 5
.
$
+?
K
!
A$
$
>
3
"
"
)
% )
"! "
"
"
"
<
"
"
3
"
B/
"6
)$ >
)
3
$
'
!
8$
<
!
"
! <
"
"
"
)
"
. "
"
&
"
"
"
!"
6
>
%
)
/ $
" )
)
8%
/K"&
+/
%$
<
"
9 %
!
$
$'
G
'
<
%
& G"%
<
"
<
)
!%
"
) " ! "!
"! $
. <
.
3
) !,
#' .
"
) )
$ =
<
"
3. C!
!
8% !
<
)$ M
% %
"
1 <9
#$ $ ' %
%
!
>
5
" 0!
!
"-
F .
#$ $
4
E 5
! $
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
149
27
33
34
36
27
26
27
27
27
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
17
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 832 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
271
269
269 of
of308
456
454
3
>
"
4
* "
). <
1 <9
!
"
.
"
$
)
!
"
)M
"
&
>
"
%
!
$<
%M$ 1
)M
%
>
! "
> $ *++B9
. =
?
)
A!
"
. %
%
"
9* B+ "
6$ 5!
M
"
!
'
<
"
"
" ) ! "
"
#$ $
"
&! 3
'
,++,++ ) !
=
"
<
>
>
. ?
) !
)
5
),
>
). "
#$ $
%
"
!
!
%
!
)
@
$
)
%
4
%
.
""
%
$ 1
)9
).
!
"
"
!
! ! $5
!
5 >
>
0 !
!
"
. 1
B
) F+.
3%
?
""
"" "
6$ 5!
! ) *+.
.
" =
"
"
). " "
!
%$
8
D$
?
%
%
>
%
"1
3
% C
$
!
6 % $
$
)
"
'
' %
& ) *F.
$R**S
)
.
)
'
)
$R*FS
4
%
>
"
> !
&
%.
!
I.
"
).
"
!
!
!
!
+? .
%%
"
%%
!
8%
!%
>
1
8
0
%%
#$ $ "
.
")
!
"
%
"
>
).
% )
""
"
8 !
!
%
$ M6
"
3
5!
. 5!
4
&
>
3
.
% )
! 9 ! $ $$$ 5!
.
%%
"
!
!
4
$ 5!
!
"
$
)
%
$
.
)
).
%
$
)
8
D. "
).
""
$M L !
$
3
?
).
& ) *F.
"
F/
"
) . "
.
%
!
9
R*DS
"
0
%
)
"
.M
.
!
G>
! !
)?
>
"
!
"
>
).
3
!
"
K
5 >
%
.
!
<
$ 0
.
& ) F. *++
)$ 6
"
"
"
)
%%
A$ -"
)$ <
$5!
' "
!
"
)
"
!
%
@ %%
)$
"&
"
8
1
%%
$ <
.
%
) = %!
"
1
"
A
)

June
June 14, 2016
'
)$
5
"
"
) = )
. "
>
). '
"
K
%%
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
.
%
"
Page
Page
Page
Page
Page
Page
150
28
34
35
37
28
27
28
28
28
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
18
of
41
>
!
) %
! )
"
) >
&
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 833 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
272
270
270 of
of308
456
454
M $ $ $ $
?
"
5
) = )
) 0
4
A!
% !
"
%%
<
% )
%%
)?$
!
5

June
June 14, 2016
.
"
"
" '
&
%)
5
B$
? "
D.
' "
)
M
$M )
8%
> .
"
1
6$ 5! . "
0
1!
.4
5
) = )
. "
K
&) "
.
! 4$
6 "
.
! 0$
1
>
). "
1
$ 5!
"
0
>
4
"
.
5
"
"
9
%
)
"
3
"
) = )
).
$
3%
)%
$
$M
,
"
!
'
.
."
"
"
'
"
K
>
$
)
>
'
"
.0$
. $
=
> )$
C!
> 8
0
1!
?
3
% $
=
. ( A$. " <
!
<
<
)? 1
! ) !
$
)
3
3 ) !
. )"
"
. " 4
0
%
$
7
>
).
0! )
)
"
4
)
(=5->( $ <
! "
(
"
$
*++B
%
%%
>
'
3$ 6
8%
!
"
.
%
"
)
"
1
6
!
)
!
$
!
)
$
!
5
% )"
+
D
/$
"
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
"
%
)?
4
"
"
!
""$
-%
' "
"
)
)
!
#$ $ '
)
"
)
""
<
?
"
"
%
3 %
)
' "
3
1
"
3 5 )
"
3
$
!
!
4" !
" ' "
3 !% )
"
.
%
)
)
!% "
)
"
"
3
)
!
!% C!
! .
)
&) "
4
"
0
%
1!
3
4
3
. 0
)
"
*. *++/ "
' 3
3
" *++/
) *
"
&
) &! ! .
)
. '$ 4
%
$
! !
*
"
' %
!
) 6
)
)
)
$
)
!
3
!%
"
$
! ) 4
. $ $.
> $ *++/9 9+*
'
" 4
)
$
$
$
)
%
*$ 6
%
%
"
0! )
)$
&
!
!
.
F.
3
$.
!
"
39 9%
Page
Page
Page
Page
Page
Page
151
29
35
36
38
29
28
29
29
29
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
19
of
41
>
.=
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 834 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
273
271
271 of
of308
456
454

June
June 14, 2016
0$
&
2
$
$
$
$"
$
$
%,GG
1
$
!%$
!%+
G
3$
!%
!%$
%
$
G
G
$) ! !
$
$
$
G
G%
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
"
0
!%
Page
Page
Page
Page
Page
Page
152
30
36
37
39
30
29
30
30
30
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
20
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 835 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
274
272
272 of
of308
456
454

June
June 14, 2016
! "
%& '
%
%
#$
"
" (
* '
"
&
$#
( -
&
'
* '
#
% ((
"
( ''
'
)( #""
"
'
''
"
''
( "
* !
'
&
%
! "
#$
'#
'
+ %
%&
% % $
'
&
( "
'
#'
'' '
'
%) *
'
+ '
+ '
%
)
<
'
%
#
$
% + $
"
#%
%
(
! &
''
'
&
'
"
&
"
%'
./05 *
#'
# %
)
*
#$
;'
'
::
7 '
)
'
+ $
#'
'
(
"#
'
'
%#
'' * #%
&
#$
::
!*
'
"
& '
'' * #%
&
'
* &
'
'
%#'
* ' '
'
;'
%
'%
( "
798 !
' (
'
* #%
'
''
%'
"
* !
% ) "
% ! * #%
#(("
! 2( "
#%
'
'!
&
''
# %
# '
"'
"
# % ! "
) *
' (
" '
"" %
%&
*',
'#
#
( ./01
& & %
7 "$
%$
#% '
'(
% "'
'
' &
' #
'
% " !
'
'
'
% "' 6
%
( ''
#$
# %
' &
"
#$
%'
% $
* !
'
% $ '
&
' )
"
'
* '
((
'
!
#$
% !%
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
" %$
#"
'
<
!
!"
"$ '
Page
Page
Page
Page
Page
Page
153
31
37
38
40
31
21
30
31
31
31
of
of
ofof
51
172
173
174
176
of
51
41
50
51
173
183
51
51
&
% (
!
" % '
'
" %
Tuesday,
Thursday,
Tuesday,
Saturday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
October
March
April
2016
June
15,
3/15/2016
2016
17,
10,
12,
15,
11,
5, 2015
2016

Page 836 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
275
273
273 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
154
32
38
39
41
32
31
32
32
32
of
of
ofof
51
172
173
174
176
of
51
50
51
173
183
51
51

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016

Page 837 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
276
274
274 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
155
33
39
40
42
33
32
33
33
33
of
of
ofof
51
172
173
174
176
of
51
50
51
173
183
51
51

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016

Page 838 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
277
275
275 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
156
34
40
41
43
34
33
34
34
34
of
of
ofof
51
172
173
174
176
of
51
50
51
173
183
51
51

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016

Page 839 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
278
276
276 of
of308
456
454
!
$%
'
"

June
June 14, 2016
&
( )!
*+ ,
-''.#!' /0 12. )!
/01- . !#!-/ 1
1!/
!1.230/. !/4 !45!/ .4 ".4-! #206)
5
!
)
5
71
'
!
#
&
!
+( $
'
"
$
,
.
2
7
0
6
9
:
;
,/
,,
,.
,2
%
()" *
&
"
'
)
"
'
!
4
)
)
4
)
.//0
1
.
2
- (
4
!
(0
3
( '' '
0
4
5
.//6 - &
, !
#
'
/
( (
&
!
*
5
!
&
((! ' 4
'
2
1
( "
.//6 ' 4
'
!
:
2
3 ( '
(
!
'
'
5
/
('
%
"
2
( '
(
%
.//: ' 4
'
5
( '
(
*
<
8
' 4
'
3
;
('
(
&
)
'
'
4
#
.//;
, !
#
!
3
< 2
3 ('
"
6
#
(
*
!
#
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
+ !!
- &
&
-&
&
, !
(
#
) 3
#
!)8
%
./,0
( '
(
#
./,0
5
# &
.//6
.//: ' 4
'
&
./,0
5
.//:
.//: ' 4
(
3
(
"
*
Page
Page
Page
Page
Page
Page
157
35
41
42
44
35
35
35
35
of
of
ofof
51
172
173
174
176
of
51
51
173
183
51
51
#
6
*
.//0
.//6
'
'
5
&
#
*
'
)=
.//; ' 4
( "
1
'
(
.//;
Tuesday,
Thursday,
Tuesday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
5, 2015
2016

Page 840 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
279
277
277 of
of308
456
454
,7 1#-& &
,0 '
4
4
'
,6
"
1
,9 0<;
,: &
3
8
='
&
< ('
2
"
3 ('
('
4
./,/ ' 4
< 3 ('
(#
(&
&
#
./,/ ' 4
1
>
(
1
&
$
'
.0 ./,/
#
&
)
( #
.6 ./,/
(%
+
*
(
<

June
June 14, 2016
& %
#1 #
$& &
'
*
./,/ '
&
!
' 4
4
.0 ./,/
#
!
'
&
1 5
5
$
&
"
!
1
$$ 5
=( $
: ./,0
%(
+
/
$, '
( *
.//,0
$> 3
./,0
( ''
'
%
4
$& 1
)
$% ?
$+ )
+
1
!
$*
'@
1
&
./,,
/0 ..::
!
"
*
,.0. 4
(/
'"
5
3
!8# (
+
&
0
>
./,0
3
( '
(
.2 ./,0
(
1
"
&
0
!
1
$A 6
&
'
&
'&
./,6
&
#
!
#
; ./,6
+
1!
$& 4
@ #
,0 ./,6
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Media
Caterbone
Transcripts
Group
For
Executive
Reconsideration
Executive
Executive
Summary
Summary
Summary
Page
Page
Page
Page
Page
158
36
42
43
45
36
3636
of
of
of51
172
173
174
176
of
51
51
173
183
51
Tuesday,
Tuesday,
Tuesday,
March
Tuesday,
Sunday,
March
15,
March
April
2016
June
15,
3/15/2016
2016
12,
15,
5, 2016

Page 841 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
280
278
278 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
159
37
43
44
46
37
36
37
37
37
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
27
of
41

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 842 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
281
279
279 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
160
38
44
45
47
38
37
38
38
38
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
28
of
41

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 843 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
282
280
280 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
161
39
45
46
48
39
38
39
39
39
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
29
of
41

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 844 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
283
281
281 of
of308
456
454
! "
"

June
June 14, 2016
$% &
!
" #
%
"&#
(
'
!
(
,
"
"
")
"
""
-
)
!
! "
!
'
%
" !
"
!
)
+
!
" *
"
"
,
,
,
*
%
*
(
%
!
/"0
1
1 ,
"
"
4
!
"
"
!
!
#
.
.
&,,0
%
1 ,
2"3
!
)
** ! "
&,,..$/
&,,
%
&,,
%
&
, "
"
00
"
!,
"
6
7
7 , !
&,,-
8,
:
(
$;$
"2
! " ,
, ,
** !
;
5
$
!
&,,@
,
.
&<;=
>
1
9
,
&,,=
$
,
>
A
1 B3
.+
&,,=
1 B3
2
>
%
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
162
40
46
47
49
40
39
40
40
40
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
30
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 845 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
284
282
282 of
of308
456
454
<
1
1
* "
!
"
C#
"$
"
<
*
&, ,
24
#9
; "
&,,@(&,,= A
3
24
5
!
%
&,,0 4
! %3
"
"
!
&,,
'
5

June
June 14, 2016
4
D
%
%
"
""
,! "
0 =
0 =9
9
00&9 00
:
9
&,,-
&, , $
!
%
!
D
%
%
=
F
!
))
+
/4
),
"
0 =
/
$
G
3
%
00
3
3
"
%#
$
$
&, ,
&,,4
!- "
.
&,,@
,
*
&,,<
E
&,,
-) !
/ 4
24
/
$
D
&, ,
D
$
&,,-
&,,0
%
D
!
D
D %
7F !
>
!
D
$
A
8F
$
%
;
D
.
%
&,,3
E
$
*
00=; 00
$
5
! 7
0 =
00
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
163
41
47
48
50
41
40
41
41
41
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
31
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 846 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
285
283
283 of
of308
456
454
)
A
24
$;$
00
(F
&
%
B
5
00 9
" * <
00=( 00 9
:#
> ) "" ""

$
;3
#, " !
&,,-
"
"
"
0 =
&, ,
/
.
$
B
3
3
=
0 =
) "
.
&,,1
0 =
24
" "
3
"
&,,@
" E
""
B
$
<
&,,1
.
&,,-
,-(&&
2

June
June 14, 2016
=
@,
"
&,
3
&,,!
&,,@
&,,@
0 =
@, 1
&,,@
9
!
@,
#" !,
0 =
" "1 ,
"
"*
":
" E
F
&,,-
!
B
/
!
"
00=( 00 9
B
:
9
$
'
.
&,,1
9
0 =
&, ,
/
.
00 9
/
&,,9
&,
( "
!
.
00
$
!
&, ,
F
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
3
7
8
!
&,,
&, ,
Page
Page
Page
Page
Page
Page
164
42
48
49
51
42
41
42
42
42
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
32
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 847 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
286
284
284 of
of308
456
454
&
, * "
&&
*#
"
&:
;!
&<
:
%
$
&, ,
$
&,,-
!-
,
5
%

June
June 14, 2016
"
>
$
$
< !-
24
? "
;
>
&,,0
B
&,,%
(
$
&, ,
&-
A
.+ $
&@
! :
&,,$
: , *
&, ,
* @
&,,@
"
E
3
&,,
"
&,,0
7 "!
7 "
0 =
*
&=
) "
":
)"
&,,@
"
&
&0
!
< ")
9 &,,@
9
&, ,
&,,
00
:,
!6
+
:
"
"
" .
9 &,,0
0 = "&#
, *
&,,@
/
" F
0 =
;A
0 =
F
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
0 =
Page
Page
Page
Page
Page
Page
165
43
49
50
52
43
42
43
43
43
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
33
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 848 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
287
285
285 of
of308
456
454
3
!
!
6
"
$
.
+
1
$
.
I $
$
!
$
+
#
'
.
00&
+$;F
&,;&,
F
00 !
D
3
"$
A
+
1
.
#
$
$
$
1

June
June 14, 2016
0 =
0 =
.
#
"2
J +
'
$ 24
1
"1E1# $
K
E
A
>
L
F
F
B
F
+
0=,K
A
$
$
1
+
3 >
1
$
>
B
!
3
F
1
00
) % 3
&,,-
!
>
! A !
00,K
1 B3
>
F
F
& 1
F
8
! 4
'
A
! 4
A
0=,K
F
00,K
0 ,K
0<,K
3
/
>
%
&,,
) %$
D 1
"
$
0 <9 F
0@,K
0@,K
$
2!
A? D!B
#
*
$
7
+
00
D 18
.
E
$
M 1
00= E
0 =
%
0 ,K
$
0 =
M
00
!
&,,9
(
9
!
1
,-(
$ !2B+EF2
(&&
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
166
44
50
51
53
44
43
44
44
44
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
34
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 849 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
288
286
286 of
of308
456
454

June
June 14, 2016
") !
"
7!
N
.
!
5
F
(
(
5
G
*
A'
, ?
*
? 1
!,
A
(
> "
!, '!
,
B
A
" " * #" !, " "
$C
* #" !, D
73
8
* 7
,
"
"
&
"
#
.
"
#(
5
7
9
'
5
%
7A
8 !
8 !
'
!
7D .2
O
% 8
'
7
'
(
(
%
%
4
K
K
M %
%
K
'
7E
(
8
"
%
'
%(
(
(
4
;
(
7
7
87
(
(
8
8
- 7 > !,
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
167
45
51
52
54
45
44
45
45
45
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
35
of
41
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 850 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
289
287
287 of
of308
456
454
June
June 14, 2016
!
* , "
1"
!
, *
1
3
@
E
!
DD
!
1
*
)) )
@
E
!
DD
B &. @
DD
B@
. DD
")
!
"
, " *"
*
(
!
")
"
"
B@
& DD
)
"
B@
. DD
)
*
, "
!
* 1
B@
& DD
)
!
* "
*
B@
$ DD
")
!
7
B@
DD 7
B@
E
DD
"! "
* *
. @
EB& DD
!
*
)
*
, "
. @
EB DD
")
!
*
1 ,!
, "
& @
& B DD 6, "
1
)
!
"
B@
DD 5
"
!
!
B@
& DD
1
"": !
B@
DD
)
1 , 1
"": !
B@
& DD >
"
1
"": !
B@
DD ' "
!
!
"
! * !
*
"
"
B@
)
B@
E DD
)
*
"E
!"
, "
"
1 ,"
DD
*)
PPPPPPP "
>7
%#
'?
Stan J. Caterbone
# PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
"
Stan J. Caterbone
# PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
"
June 19, 2015

PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
Pennsylvania
PPPPPPPPPPPPPPPPPPPPPPPPPP
$
Lancaster
PPPPPPPPPPPPPPPPPPPPPPPPPPPPP
19
PPPPPPP
15
June
PPPPPPPPPPPPPPPPPPPPPPP
&,PP
Stan J. Caterbone - I was a notary from '94-'98

PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
F
PPPPPPPPPPPPPPPPPPPPPP
SJC
I
.
I
&, ,
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
168
46
52
53
55
46
45
46
46
46
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
36
of
41
Don't Know When
24
$
$
Q &, , "!
I
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 851 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
290
288
288 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
169
47
53
54
56
47
46
47
47
47
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
37
of
41
Page 35 of 41

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,
06/10/2007

Page 852 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
291
289
289 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
170
48
54
55
57
48
47
48
48
48
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
38
of
41
Page 36 of 41

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,
06/10/2007

Page 853 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
292
290
290 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
171
49
55
56
58
49
48
49
49
49
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
39
of
41

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 854 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
293
291
291 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
172
50
56
57
59
50
49
50
50
50
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
40
of
41

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 855 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
294
292
292 of
of308
456
454
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
Page
Page
Page
Page
Page
Page
173
51
57
58
60
51
50
51
51
51
of
of
of
of
51
172
173
174
176
of
51
50
51
173
183
51
51
Page
41
of
41

June
June 14, 2016
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2015
2016
Saturday,
October
10,

Page 856 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
295
293
293 of
of308
456
454

June
June 14, 2016
"
!
#"
!
)
* ++
,*
+
+,$ !
$% &
+
%
$% &
$% &
1"&&$&&& !
. -
'
'
'
'
. '
$% &
'
'
+
'
!'
/
- ,
'
% *
%
*
%
.
'
'
2
'
3
5'
* % 6
7 %
%
%!
)
5 '
'
'
') %
%
6 %!
'
% :
'
'!'
*%
*
%
.
%
( 7
'*
= '
% !
.
%
(
%
.
; .*
/ '%
' ' 9!
'
<
=
4 '>
'
@#<
*
."
!
! ,
A41 ) $086B 9
'
!
*
%
C 1
C 1
)
!
& !
)D& $A
' %
'
'
2!
'!
* '
/
.,
B
B
: 0$0? $086B
*
=>8 4
.
B
C 1
.
+,0
'
!' ) '
,
*
*
*
'
!'
.
*
. .
*
.
' .
. *
' '!'
.*
'&
$ /
* $
' 0 '!'
*
$
' 0 '!'
1
0
'
** ' !
$% .
' %
' !
*
!'
'
*
'
'
' '(
)
'
% (
& !
. %
%
+ !' ,
%
/
1
8%
'
/ ' ,
%
%
6 %!
)
1
?
% %
$%
"#$ %&"'(
+ *
/
'
' A4 4 A1>
'!
' ) '
.
'
*
# %
' ' 8%
%.
'
' ) '
E
? '
*
'
'
.,
=
% !
.B
* '
'
**
'
%
'
'
.B
'
'
' A
%
%
'
%
'
*
'
B
B *
E
F
Affidavit
AFFIDAVIT
Mind Control
of Stan
of Transcripts
Stan
JJ.Caterbone
Caterbone
J. Caterbone
re
reState-of-Affairs
Current
re State-of-Affairs
State-of-Affairs
Page
Page
Page
Page
174
111of
of
of
of113
183
23
27
23
'
E
'F
'
Tuesday,
Sunday,
March
June22,
5, 2016

Page 857 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
296
294
294 of
of308
456
454

June
June 14, 2016
C 1
' %
'!
' ) ' ?
% !
'
' ' *
'
'
' '
#7 '
9=%
,
:
%
*
'
'
% 0
G 1
*
90 1
' '
.
0 2 !
% *
'
( ,
'
## : & *
.
*
'
' * '
' %
%
%
%
' *
*
' %
'
%
'
.
' =
H
%
* %
'
/
.
'
=
* % * ;
%
% % 1
'
*
%
* ;
'!
' ) ' ?
* %
'
A . * .
%
! ' *
1
>
1
.
1 . %'
'1
1 ! "&
. =%
,
* % 0 1
' I
'
*
Affidavit
AFFIDAVIT
Mind Control
of Stan
of Transcripts
Stan
JJ.Caterbone
Caterbone
J. Caterbone
re
reState-of-Affairs
Current
re State-of-Affairs
State-of-Affairs
Page
Page
Page
Page
175
222of
of
of
of113
183
23
27
23
.
'
'
Tuesday,
Sunday,
March
June22,
5, 2016

Page 858 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
297
295
295 of
of308
456
454

June
June 14, 2016
"
!
#"
%%$ %&"'
3 4
67
0 % !
% !
#7
'
* % ! .
#7 0
%
%
'
'*
'
' % 6
0
%
'
% !
*
'
' ' #*
% ' .
D %
8
'
%
0
' !
D %
. 0
2!
! "
!
'
%
'
%
*
. %
% J
D
G 1
% %
'
!
'
*
%
%
' *
'
'
/
' '
. J 0
0 1 %
'
* % 10
( ,
+
0
'
%
' %
' ' * %
' % '
*
/
'
'*
% &
1
' %
*
%
% .
%
.
% ' $% .
!
'
'
%
**
%
% .
! %
'
%
.!
- .
% %
$%
' *
%
%
% ; '
.
'
*
'
. %
' '
%
%
'
1
.
' . 0
%
4
6$
*
% &
$% ' 1
1
*
%
! !
% >
1
*
!
'
'
'
) %
'
%
. ## E
%
' *
%
## &
+
C '
+ H
*
' %
.
'
J
* %
*
'
% 4
%
/
J
'
' %
*
$%
'
'
%
%
.!
. ?
%
)/
%
' % %
* #
%
.
%
% * % * '
%
>
1
$
/
7
'
!
% >
+ H *
% * '
%
%
%
C '
*
, 1
)/
%
'
%
%
'
.
/
% '
$%
' ' @7 >
$% .
) %
' '!
0
.
* %
*
!
. %
*
%
C '
.
%
*
'
%
%%
' . %
' *
) %
1
.1
%
%
$
) !
/
*1
*
"
'
'
' .
%
.
$% >
'
G4
!
#
'
'
J? ' 8 ' , . J
'
' **
*
. **
*
% 0 % '
'
.
' **
! .
%'
% )85 6$
.
' %
%
.
'
%
* %
'
.
* % ! .
%
) %
). **
'
*
%
% %
'
'
%
*
%
%
0
%
.
%
% >
1
% * '
) . *
@ 0
% &
+
!
! '
' '
.
* '
%
/
*
*
.
'*
Affidavit
AFFIDAVIT
Mind Control
of Stan
of Transcripts
Stan
JJ.Caterbone
Caterbone
J. Caterbone
re
reState-of-Affairs
Current
re State-of-Affairs
State-of-Affairs
Page
Page
Page
Page
176
333of
of
of
of113
183
23
27
23
Tuesday,
Sunday,
March
June22,
5, 2016

Page 859 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
298
296
296 of
of308
456
454
' 0 *
'
% '
#7
. *
'
! J $%
* '
'
J'
% '
'
'
'
. ## E 0
*
% % ' %
*
1+A8)E %
' '
%
'
' '
'*
'
'
' $ . ,
!
' % *
'
* 6
K /
' !
'
'
% *
.
%
' % A018
%
.
.
%*
% J? ' 8 ' , . J
% '
LLLLLLLLLLLLLF FLLLLLLLLLLL
$
9
!
*** . +
+
.
/
%
0 %
*
!
#7 E %
#7 E
/
/
,
!
9
*
%
*#
'
'
' '

June
June 14, 2016
,
-
, +
-
- !!
,
1
..
+, 1
6
" @#B "
1
6
" #7@B
6
)+
B
+ ,1
6
7"
Affidavit
AFFIDAVIT
Mind Control
of Stan
of Transcripts
Stan
JJ.Caterbone
Caterbone
J. Caterbone
re
reState-of-Affairs
Current
re State-of-Affairs
State-of-Affairs
Page
Page
Page
Page
177
444of
of
of
of113
183
23
27
23
@ B
@"
# )+
B
"
"
#B
B
"@@ @
" 77B
"@
B
"
@#
Tuesday,
Sunday,
March
June22,
5, 2016

Page 860 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
299
297
297 of
of308
456
454
::
$
-"%;& :
9
,
/ + !
.!
).
C 1
'
0
*
'
.
$
"#'&<
3 #"#=>%'=;<;?
*
. *
% * *
% !
'.
' %
0 % !
*
B
%
% !
$ :
'
0 %
**
**
+
-
'
'
'
0% !
--
--
, +
+ @
8
.!
. %
'
--
,
* %
.
/ '
,
,
**
'
'
0 % !
$
$ 9
B
;
. / * ,
+$
5
:0 %
0
--
A 5
' %
'
' %
% !
' *
**
.
.
0 %
, +
!
*
'
' ) ' 1
'
''
*
' % %
+ 5
' %
+
. &
'
3 9
$ 9
'
%
'
--
''
'
. 9 '!'
C 1
**
**
-

June
June 14, 2016
'
.
!
/
'
0 %
%.
**
'
%
.
.%
. *
'
'
'
'
'
. *
0
.
'
Affidavit
AFFIDAVIT
Mind Control
of Stan
of Transcripts
Stan
JJ.Caterbone
Caterbone
J. Caterbone
re
reState-of-Affairs
Current
re State-of-Affairs
State-of-Affairs
Page
Page
Page
Page
178
555of
of
of
of113
183
23
27
23
Tuesday,
Sunday,
March
June22,
5, 2016

Page 861 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
300
298
298 of
of308
456
454
% !
!
*
' '
* 9
' '
. %
&
M >
'
'.
.*
'
*
'
%
F*
' ?
* !
'
!
'
'
% %
'.
'
'*B
+8+
1% *
* 1
.
" M
**
NC
'
'
! !
' !
'
'
$
'O
*
' %
&
'
.*
'
' !
'
'
'
%
.
!
*
'.
%
;
'
. 0 '
%
' *
'
'
* %
'
L' 'L;
&
* % &
+ *
'
" M
'
' $ *
' >
** ' !
! !
'
!
'
F' 'F'
* %
%
: *
!
'
**
''
0 %
9>> : >
'
'!'
% !
F'
3FF
0 '!'
'
%
.
*+ *
0 % !
&
A %
* %
'
'
' !
% >
4-
'
!
'
'
'

June
June 14, 2016
'
'
0
.
.%
%
% '
$%
* + *
+
*
% .
'
'
'
3
"<
"<
"<
5 9 /D $%
/ /
/ 99
"< "
-
'
'
.
"< %
'
'
% *
C 9
%
.
' '
. -
+ +
$%
%
'
;
:
:
! .
"< % "
! !
%
'
*
'
'
;
:
;
. 9
.
'
' %
4.
%.
/
. %
;
% %
;
'
. !
Affidavit
AFFIDAVIT
Mind Control
of Stan
of Transcripts
Stan
JJ.Caterbone
Caterbone
J. Caterbone
re
reState-of-Affairs
Current
re State-of-Affairs
State-of-Affairs
Page
Page
Page
Page
179
666of
of
of
of113
183
23
27
23
Tuesday,
Sunday,
March
June22,
5, 2016

Page 862 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
301
299
299 of
of308
456
454
"< % %
'
2!
'
'
'
'
% *

June
June 14, 2016
+ +
+ +1
'
* %
* %
%
"< % < B .
&
'
'
'
*
' >
'
A814+&A4
% *
'
>
% %
4-
+ +
'
'
'
'
'
/
.
' %
;
.
% %
+
*
*
%
0%
,
!!
!
,
% 0
HHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHH$
-
, +
- 9
,
-
. $ 6
,-
- 9
-,
6
*
*+
,,
,
-$
$
+ $
,
++
-- 2
2
,
. G HHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHH$ !
,
! , ,
G HHHHHHHHHHHHHHHHHHHHHHHHHHHHHH
,
'
- HHHHHHHHHHHHHH$ %&HHHH$
F!
./
'
%
--
,$ HHHHHHHHH
'
'!'
' 9 :
F+
.
, .
--
,
+
+ HHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHH
HHHHHHHHHHHHHHHHHHHHHHHHHHH
Affidavit
AFFIDAVIT
Mind Control
of Stan
of Transcripts
Stan
JJ.Caterbone
Caterbone
J. Caterbone
re
reState-of-Affairs
Current
re State-of-Affairs
State-of-Affairs
Page
Page
Page
Page
180
777of
of
of
of113
183
23
27
23
.. ,,
2!
Tuesday,
Sunday,
March
June22,
5, 2016
1 of 4

Page 863 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
302
300
300 of
of308
456
454
December 9, 2015

June
June 14, 2016
!
!
"
"#
$
%
'
&
)*$
"#
"#
&
,
-
"
.
$/
$
$
&
,
"#
"
45)4&
$
"
'
&
$
&
Affidavit
AFFIDAVIT
Mind Control
of Stan
of Transcripts
Stan
JJ.Caterbone
Caterbone
J. Caterbone
re
reState-of-Affairs
Current
re State-of-Affairs
State-of-Affairs
Page
Page
Page
Page
181
888of
of
of
of113
183
23
27
23
Tuesday,
Sunday,
March
June22,
5, 2016
3/22/2016 2:11 AM
2 of 4

Page 864 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
303
301
301 of
of308
456
454

June
June 14, 2016
"#
$
$
&
"#
8
&
)9*5$
"#
& :1
)9*5$
" &;
,
8
,
"#7
&
<
"
&
$
$
&
$
&3
"#
&
3
"#
&
3
$
&=
%
&
$
&
"#
1
&
#
&
3
"#
.
&
Affidavit
AFFIDAVIT
Mind Control
of Stan
of Transcripts
Stan
JJ.Caterbone
Caterbone
J. Caterbone
re
reState-of-Affairs
Current
re State-of-Affairs
State-of-Affairs
Page
Page
Page
Page
182
999of
of
of
of113
183
23
27
23
Tuesday,
Sunday,
March
June22,
5, 2016
3/22/2016 2:11 AM
3 of 4

Page 865 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
304
302
302 of
of308
456
454

June
June 14, 2016
&.
"# .
&
$1
"
$ >:
"#; .
&?
$"
&
&
>3
$? "
&>
&?
$
"#
&
$
&
&
$
$
$
&
&
'
&
&@
$
8
"
&
$
1
>
& #<
&
(
"#
,
&
8
+
3
&# &3
$# &6
&
+
'
&
#<
# &6
&
Affidavit
AFFIDAVIT
Mind Control
of Stan
of Transcripts
Stan
JJ.Caterbone
Caterbone
J. Caterbone
re
reState-of-Affairs
Current
re State-of-Affairs
State-of-Affairs
Page
Page
Page
Page
183
10
10
10of
of
of
of183
113
23
27
23
&
Tuesday,
Sunday,
March
June22,
5, 2016
3/22/2016 2:11 AM

Page 866 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
305
303
303 of
of308
456
454

June
June 14, 2016
Stan J. Caterbone

1250 Fremont Street

Lancaster, PA 17603
scaterbone@live.com
717-669-2163
April 20, 2016


Page 867 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
306
304
304 of
of308
456
454

June
June 14, 2016

Page 868 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
307
305
305 of
of308
456
454

June
June 14, 2016
William Bennett.

Page 869 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
308
306
306 of
of308
456
454

June
June 14, 2016
telecommunications.
Industrial Park.

Page 870 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
309
307
307 of
of308
456
454

June
June 14, 2016
compact disc.
million.

Page 871 of 2301
Letter to
LLetttteerr
Letter
toDave
Lambert
ttoo
Brown
D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
310
308
308 of
of308
456
454

June
June 14, 2016
1250 Fremont Street

Lancaster, PA 17603
scaterbone@live.com
717-669-2163
ACTIVE COURT CASES
search for lisa michelle lambert
A...872 of
http://nl.newsbank.com/nl-search/we/Archives?p_product=LC&p_...
Sunday JanuaryArchives
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
311
309 of
of 456
454
June 14, 2016
Local News & Sport s | Classifieds | Cust om er Care Cent er
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Lancast er Online Keyword
Go
3 4 8 a r t icle s m a t ching lisa m iche lle la m be r t AN D da t e ( 1 9 9 7 )

w e r e found.
Displaying 10 articles
Article 1 of 348, 1997365478
Published on Decem ber 31, 1997, I nt elligencer Journal ( Lancast er, PA)
LAMBERT'S LAWYER ASSAILS RULING

Lisa Michelle Lambert's attorney Tuesday denounced an appellate court's
decision to effectively reinstate his client's 1992 first-degree murder
conviction, saying he will do whatever he can "to get it undone.". Peter S.
Greenberg, a Philadelphia lawyer, spoke by telephone from Vermont, where
he's on vacation. It was Greenberg's first detailed remarks about Monday's
ruling by the U.S. Court of
Click for com plet e art icle, ( 797 words)
Article 2 of 348, 1997365331
Published on Decem ber 31, 1997, Lancast er New Era ( PA)
LAMBERT INVESTIGATORS WAITING, WONDERING

Lisa Michelle Lambert finds herself back in court and now her investigators
want their day there as well.. The prosecutors in her case have been under
investigation by state and federal officials since last spring. U.S. Judge
Stewart Dalzell ordered the investigation, after saying that prosecutors
tampered or hid evidence during their prosecution of Lambert. Now that a
panel of three federal judges has reinstated Lambert's conviction, some of
those prosecutors say they would like
Article 3 of 348, 1997364268
AUTHORS OF LAURIE BILL APPLAUD COURT RULING

Now that a federal appeals court has sided with its authors, it remains to be
seen whether the Laurie Bill is worth pursuing.. The pending legislation
seeks to limit the power of federal judges, keeping them from ever barring a
retrial on the state level, other than on constitutional grounds. Bill
Wichterman, chief of staff to U.S. Rep. Joseph Pitts, said the fate of the bill
depends on the reasons behind Monday's ruling by the U.S. Court of
Appeals, which vacated the decision by
Article 4 of 348, 1997364262
1 of 3
6/10/2006 8:31 AM
A...873 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
312
310 of
of 456
454
June 14, 2016
COUNTY RESIDENTS REACT TO LAMBERT RULING

A court's decision to overturn a federal judge's ruling that freed Lisa
Michelle Lambert was good news to most as word spread throughout the
county Monday afternoon.. "I think his decision to let her go was wrong,"
said Lisa Kemper of Lancaster. "She was guilty. Why would she be there
that day (at the murder scene) in the first place?" Finding people who
agreed with the U.S. Court of Appeal's action to throw
Article 5 of 348, 1997364269
APPEALS COURT SAYS DALZELL ERRED,

OVERTURNS RULING IN LAMBERT CASE //
PROSECUTORS CELEBRATE DECISION
The gloom that has hung over the Lancaster County District Attorney's
Office since the release of Lisa Michelle Lambert in April lifted Monday..
District Attorney Joseph C. Madenspacher, swamped in a sea of pink
message slips, sat at his desk and smiled for what he said felt like the first
time since Lambert was set free by U.S. District Judge Stewart Dalzell.
Dalzell's controversial decision was overturned Monday by the U.S. Court of
Appeals for the 3rd Circuit..
Article 6 of 348, 1997364279
LAMBERT CASE HAS FAR TO GO

The Lisa Michelle Lambert case is far from over.. Despite Monday's ruling
by a three-judge panel of the U.S. Court of Appeals for the 3rd Circuit Court
in Philadelphia, Lambert's claims of innocence and wrongful prosecution
could be tied up in state and federal courts for years to come. The following
is the best information available Monday on where the case goes now..
Brad Baldus, a 3rd Circuit court clerk, said Lambert's attorneys have 14
days from
Article 7 of 348, 1997364278

OVERTURNS RULING IN LAMBERT CASE
A federal appellate court Monday overturned a federal judge's decision to
free Lisa Michelle Lambert.. The court ordered Lambert to take her claims
of innocence and wrongful prosecution back to where she started: the state
courts, beginning with Lancaster County Court. A three-judge panel of the
U.S. Court of Appeals for the 3rd Circuit in Philadelphia wiped out an April
decision by U.S. District Judge Stewart Dalzell. He freed Lambert, who was
convicted in 1992 of first-degree
2 of 3
6/10/2006 8:31 AM
A...874 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
313
311 of
of 456
454
June 14, 2016

Article 8 of 348, 1997364277
CHRONOLOGY OF SHOW MURDER CASE

Show murder case chronology:. `Dec. 20, 1991 - Laurie Show, 16, found
dead in her East Lampeter home. `Dec. 21, 1991 - Tabitha Faith Buck, 17,
Lisa Michelle Lambert, 19, and Lawrence Yunkin, 20, are charged in the
killing.. `July 20-21, 1992 - Lambert is convicted of first-degree murder after
a two-week trial and later sentenced to life in prison.. `July 31, 1992 - Buck
agrees to be tried as adult, and the DA agrees not to seek death penalty..
Àug. 7, 1992 - Buck granted change of
Article 9 of 348, 1997364276
DECISION OF THE CIRCUIT COURT IN THE LAMBERT

CASE
Editor's note: The following is an edited version of the decision by U.S.
Court of Appeals for the Third Circuit in the Lisa Michelle Lambert case.
Most of what was deleted were case citations and discussion by the court in
support of its decision. An ellipsis (...) appears where substantive material
was dropped. Footnotes were moved to the point in the text where they
apply and were placed in parenthesis.. Filed December 29, 1997 UNITED
STATES COURT OF APPEALS FOR THE THIRD
Article 10 of 348, 1997364272
'ALL I WANT IS SOME CLOSURE TO THIS'

Though many had reason to celebrate the reversal of a federal judge's
decision to free Lisa Michelle Lambert, the ruling was especially sweet for
Hazel and John Show, the parents of 16-year-old murder victim Laurie
Show.. "The whole process has been so draining from the beginning to the
end," Mrs. Show said. "Now there's a joy at knowing we're back on the right
track." Mr. Show said,
[ View the next 10 items ]

Con t e n t m a y n ot be r e pu blish e d w it h ou t pe r m ission .
2004 Lancast er Newspapers

PO Box 1328, Lancast er PA 17608, ( 717) 291- 8811
Term s of Service Privacy Policy
3 of 3
6/10/2006 8:31 AM
A...875 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
314
312 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 11 of 348, 1997364275
APPEALING DECISION
In a narrow ruling to a complex case, the Third Circuit Court on Monday
found that Lisa Michelle Lambert failed to exhaust her murder conviction
appeals at the state level and that state, not federal, courts should therefore
hear her request for relief.. While the ruling does not directly address
Lambert's guilt or innocence, it documents procedural errors on the part of
Federal District Judge Stewart Dalzell, who freed Lambert in April after
ruling that she had been the victim
Article 12 of 348, 1997364209
FOR SHOWS, DA'S OFFICE, COURT'S RULING BRINGS

RELIEF
When John Show heard Monday that a federal appeals court was about to
announce a decision affecting Lisa Michelle Lambert's newfound freedom,
he paused.. "I was scared," Show said. "I didn't trust the system." That's
understandable.. Lambert had been convicted in Lancaster County Court of
stabbing Show's 16-year-old daughter Laurie to death in December 1991..
After a hearing in April,
Article 13 of 348, 1997364211
COUNTY MAY ASK PA. PROSECUTORS TO STEP IN

When Lisa Michelle Lambert's murder case eventually returns to a
courtroom, she could be prosecuted by the state Attorney General's office
and not by the Lancaster County District Attorney.. That possibility was
raised today by the county commissioners, who said that they are preparing
to ask state prosecutors to get involved in the case in the future. The
reason, the commissioners said, is because of claims raised during
Lambert's appeal before U.S.
Article 14 of 348, 1997364210
1 of 3
6/10/2006 8:32 AM
A...876 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
315
313 of
of 456
454
June 14, 2016
DA CONFIDENT LAMBERT WILL RETURN TO JAIL

County officials said today that they expect Lisa Michelle Lambert to be
returned to prison sometime in the next several months, in the wake of
Monday's federal court decision reinstating her conviction.. "I'm confident
she will go back to jail at some point," said Lancaster County District
Attorney Joseph C. Madenspacher. "As it stands right now, it's not a
question of if, but when." A federal appeals court
Article 15 of 348, 1997363267
THE YEAR IN QUOTES

January. "He has a nice round face and he's a good eater for me." Mrs.
Lenard Zimmerman, Ephrata, whose son, Leon, was 1997's first baby.. "Let
me say to the entire House that two years ago when I became the first
Republican speaker in 40 years, to the degree to which I was too brash, too
self-confident, or too pushy, I apologize. To whatever degree and in any
way that I brought controversy or inappropriate attention to the
Article 16 of 348, 1997363214
LISA LAMBERT'S PARENTS ANSWER NEW YORK

TIMES
Editor, New Era:. The following letter was sent to the New York Times, and
we are asking the Lancaster New Era also to print it: We are responding to
but a few of the statements in the New York Times article which appeared
in the Saturday, December 27, edition of Lancaster's Intelligencer Journal
and which was reported on by the Lancaster New Era, as well as
statements made elsewhere regarding the case involving our daughter, Lisa
Michelle Lambert. There are a number of points we
Article 17 of 348, 1997363191
COUNTY WINS LAMBERT APPEAL

PHILADELPHIA _ Lancaster County won its appeal today over a federal
judge's decision to free once-convicted murderer Lisa Michelle Lambert..
However, it was not immediately known if Lambert would be returned to
prison. The ruling by the 3rd Circuit Court, announced early this afternoon,
overturns a decision by U.S. Judge Stewart Dalzell in April in which he freed
Lambert, declaring her "actually innocent" of the murder of 16-year-old
Laurie Show.. In
Article 18 of 348, 1997362270
2 of 3
6/10/2006 8:32 AM
A...877 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
316
314 of
of 456
454
June 14, 2016
Published on Decem ber 28, 1997, Sunday News ( Lancast er, PA)
The following is a look back at local news events during the past week.
SUNDAY. Dec. 21 - Marilyn Porter, 58, Lancaster, was arrested and
charged with taking $9,000 in jewelry from one of her nursing patients.
MONDAY Dec. 22 - With the holiday shopping season winding down,
merchants said it has been a good, but not great, season. Many stores had
also started discounting over the last weekend.. A mix of snow, sleet and
freezing rain caused some traffic problems on back roads. TUESDAY.
Article 19 of 348, 1997362286
AN UNSETTLING YEAR
It was a year when many important things just didn't go according to plan.. If
a habeas corpus hearing had ended the way Lancaster Countians expected
it to, Lisa Michelle Lambert would still be in jail, still convicted of murdering
16-year-old Laurie Show. If city politics hadn't changed, Harrisburg Area
Community College would still be planning to move into the old Watt &
Shand building.. If, if, if ..... But because those best-laid plans went
Article 20 of 348, 1997361195
RETRIAL THREAT TERRIFIES LAMBERT

The possibility of being retried for the murder of Laurie Show terrifies Lisa
Michelle Lambert, The New York Times reported today.. In her first public
comments on her controversial case, Lambert wondered why Lancaster
County prosecutors are continuing to pursue her: "Why do they want to
keep doing this to me?" she asked.. The Times, in a lengthy page-one story,
describes how Lambert was freed in April by federal judge Stewart Dalzell
and how the rare case is
[ View the previous 10 items ][ View the next 10 items ]


3 of 3
6/10/2006 8:32 AM
A...878 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
317
315 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 21 of 348, 1997355339
SUNDAY. Dec. 14 - Edwin Morris, 84, was found dead in the basement of
his Salisbury Township home after fire destroyed the dwelling. He died of
smoke inhalation. Kerosene lanterns, the only source of artificial light in the
house, were blamed for the fire. MONDAY. Dec. 15 - Oprah! Television talk
show queen Oprah Winfrey was at the Landis Valley Museum to film scenes
for her new movie
Article 22 of 348, 1997355353
BOTTLE BILL HELPS IN RECYCLING AND DESERVES

SUPPORT
I am handling more bottles and cans in an incredibly expensive and
inefficient manner. Markets are flat. We pay to get rid of commingled cans,
jars and bottles. I have the cost of running two trucks and two crews five
days a week, which adds more cost to the operation.. A report in Recycling
Resource magazine (a recycling industry publication) reported the recycling
methods in all 50 states. Forty-three states that collected bottles and cans
through a hauler or municipal recycling method had
Article 23 of 348, 1997352309
DISTURBED BY MOVIE PROSPECT

To the Editor:. I, for one, do not want a movie made of Lisa Michelle
Lambert's life. The families involved in this tragedy have suffered enough.
Why can't the movie producers have sympathy for the families. Lisa
Michelle Lambert is not the victim. The movie producers are only interested
in making money off of other people's heartaches. Estell Haines Strasburg
Article 24 of 348, 1997352261
LAMBERT HELPS PHILA. LAWYERS HONOR
1 of 3
6/10/2006 8:33 AM
A...879 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
318
316 of
of 456
454
June 14, 2016
RAINVILLE
Christina Rainville was honored this week by her fellow young Philadelphia
attorneys for championing the freedom of Lancaster County's Lisa Michelle
Lambert.. And it was Lambert - once convicted of murder, now declared
free and actually innocent - who introduced Rainville at the annual banquet
for the Young Lawyers Division of the Philadelphia Bar Association on
Tuesday. Lambert was convicted of first-degree murder and sentenced to
life in prison for slitting the throat of
Article 25 of 348, 1997348360
A FALSE PREMISE
Too many Lancaster Countians must have been watching Oliver Stone
flicks.. Why else would folks believe that everyone is out to get us over the
Lisa Michelle Lambert case? The conspiracy theories started when federal
Judge Stewart Dalzell threw out Ms. Lambert's conviction for the 1991
murder of Laurie Show. They intensified when the Los Angeles Times ran a
series, republished in the Sunday News, on why the decision may tilt the
balance of power between federal and state
Article 26 of 348, 1997348361
LAMBERT: WE WILL NEVER KNOW THE TRUTH

With the news that a film company has bought the rights to the story of Lisa
Michelle Lambert, the conversation is once again all about the case that
seems to have carved a scar right across Lancaster County.. Around my
desk I can hear: She is guilty. She is not. The prosecutors are corrupt. Or
they are not. And the sudden hush that comes with the rare mention of
another name: Laurie Show. Last week, the talk turned to macabre humour.
Who will play whom in this upcoming movie, this story in
Article 27 of 348, 1997348339
SERVICE KEEPS MEMORIES ALIVE

John Show had been planning his sixth annual Remembrance Service at
Mellinger's Mennonite Church for several months.. He'd recently brought in
a Christmas tree and trimmed it with white lights and a red bow. His
girlfriend, Doris Knier, had written a program decorated with a drawing of a
dove.. Friends had contributed the slender white candles that would be
handed out to participants.. On Saturday night, it all came together better
than Show could have
Article 28 of 348, 1997345240
2 of 3
6/10/2006 8:33 AM
A...880 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
319
317 of
of 456
454
June 14, 2016
FIRM FORCED TO UNVEIL STUDY ON INCINERATOR

FIRE
After two men were killed in an explosion at the Lancaster County
incinerator in 1995, the company hired an independent firm to determine
what caused the blast so it would never happen again.. But now, defending
itself in a lawsuit from the family of one of the men, company officials have
balked at revealing the results of the study, saying it was done in
preparation of litigation. A Lancaster County judge isn't buying that. Last
week, he gave the Ogden Corporation 10 days to
Article 29 of 348, 1997344559
IS HIKE TOO HIGH?

If you're a homeowner caught up in the holiday shopping rush, here's a
sobering thought for you - better save a little, because in less than a month,
your county real estate tax bill may soar by nearly 30 percent.. If that
bothers you, then you might want to consider taking a little time tonight to let
the Lancaster County Commissioners know what you think about it. The
commissioners are holding a rare nighttime meeting at 7:30 at the
Lancaster Farm & Home
Article 30 of 348, 1997344423
THE COUNTY BUDGET IS SOLID, BUT IS EVERYTHING

NECESSARY?
Lancaster County officials have good reasons for boosting the 1998 budget
by 29 percent. Good reasons or not, it's still a 29 percent increase. It's still
going to cost the average homeowner an additional $70 to live in Lancaster
County next year.. County Commissioners say they are caught between
rising costs and declining revenues and have no choice but to raise taxes by
an exceptional amount. The facts seem to support that argument. But no
budget is entirely without


3 of 3
6/10/2006 8:33 AM
A...881 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
320
318 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 31 of 348, 1997344421
LAMBERT REMAINS GUILTY OF CRIME

Editor, New Era:. On Dec. 20, 1991, someone lured Hazel Show from her
home via a phone call, sending Mrs. Show on a "wild goose chase." When
she left the apartment, someone entered the home and attacked and fatally
wounded Mrs. Show's 16-year-old daughter, Laurie.. Who committed this
horrible crime? There are only three people with any connection to this
vicious act, and only two of these suspects have a clearcut motive for
committing such a heinous
Article 32 of 348, 1997341327
SUNDAY. Nov. 30 - Vandals worked their way through Lancaster Township
and the city, smashing about 20 car windows. Roger Lee Mattingly, 50,
Elkton, Md., was the second Maryland man arrested in the shooting death
of a Chester County woman, Anna Weaver, 77, and the wounding of her
son-in-law in an apparent burglary attempt at her East Nottingham
Township home the week before. MONDAY. Dec. 1 - Two officers who
settled
Article 33 of 348, 1997341345
PURSUIT OF JUSTICE IS COSTLY

Nearly $1 million and counting.. That's how much the Lisa Michelle Lambert
appeal has cost Lancaster County. And the price tag likely will increase..
The expensive appeal, which began when federal Judge Stewart Dalzell
agreed to hear Lambert's case last February, was a factor in the county's
recent decision to hike taxes by nearly 30 percent, according to county
officials.. It wasn't the only reason for the increase, but the unexpected
Article 34 of 348, 1997341353
REACTION TO SERIES ON LISA LAMBERT TRIAL
1 of 3
6/10/2006 8:34 AM
A...882 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
321
319 of
of 456
454
June 14, 2016
"Shame on you," the letter read.. Shame on us? All we had done was
publish, in two parts, a massive story on the Lisa Michelle Lambert case
which was written by a Los Angeles Times reporter.. It was perhaps the
most complete and incisive story anyone has written on the case. Although
we in the local media have long been covering the story day-by-day, we
never had the chance to - or never thought to - take a step back and see the
big picture in this way.. Perhaps
Article 35 of 348, 1997341324
CANDLES ILLUMINATE FAMILY MEMORIES

It began six years ago.. One man's effort to heal his own hurting heart and
the hearts of others. Now, John Show has organized the sixth
"Remembrance Service," a candlelight vigil to memorialize loved ones who
have died.. "I want people to know that this is for anybody - anybody - who
has lost somebody," Show said recently.. The service will be held at 7 p.m.
Saturday, Dec. 13, at Mellinger's Mennonite Church, 1916
Article 36 of 348, 1997340176
JUDGE DALZELL'S DECISION MIRRORS JUSTICE

A gross miscarriage of justice. This phrase has been used to describe the
April decision by Federal Judge Stewart Dalzell to free Lisa Michelle
Lambert from prison in the Laurie Show murder case. For the past eight
months, Dalzell has been berated by thousands of Lancaster County
residents. Much of this ranting, raving, and scalp-hunting is unfounded in
the belief that Dalzell unfairly condemned the conduct of Lancaster County
investigators during the case.. During Lambert's
Article 37 of 348, 1997340251
MOVIE VERSION
It should come as no surprise that Hollywood has stumbled onto the Lisa
Michelle Lambert story.. After all, some would say it is the stuff movies are
made of: An innocent girl from the wrong side of the tracks is railroaded into
a murder conviction by a narrow-minded community bent on avenging a
horrible crime.. In prison she is subjected to inhuman horrors and
degradations.. But in the end she is saved only by her own pluck and the
skill of an aggressive female lawyer able to convince
Article 38 of 348, 1997340175
JUSTICE MARRED BY JUDGES' DECISION
2 of 3
6/10/2006 8:34 AM
A...883 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
322
320 of
of 456
454
June 14, 2016
Justice has been compromised. Her character, once lustrous, is now

tarnished by the radical decisions made by the judges in the cases of Louise
Woodward and Lisa Michelle Lambert.. In both trials, these women were
charged with murder. Woodward's second-degree murder charge was
reduced to manslaughter and she is now free. Lambert's charge was of
first-degree murder; she is now free. The precedent set by these two judges
is not exemplary of justice.
Article 39 of 348, 1997339376
FILM STUDIO BUYS RIGHTS TO TELL LAMBERT

STORIES
Actor Will Smith and Universal Pictures in Hollywood plan to produce a
movie based on Lisa Michelle Lambert's murder conviction five years ago
and her dramatic release from jail in April.. The movie, if it's made, will be
based on a two-part series about the Lambert case that was published in
the Los Angeles Times in November. The series also appeared in the
Lancaster Sunday News. If the script follows the reporting, Lancaster
County isn't going to look as
Article 40 of 348, 1997332044
Published on Novem ber 28, 1997, Lancast er New Era ( PA)
DEFENSE LAWYERS ARE WRONG TO CHALLENGE

'LAURIE BILL'
Editor, New Era:. I am writing in response to the Pennsylvania Criminal
Defense Lawyers and their opposition to the "Laurie Bill." We need a bill like
this one and we need it now! We need to stop judges from having so much
power. Judge Dalzell had no right to set Lisa Michelle Lambert free saying
that she was innocent because she was framed by county prosecutors. As I
recall, Lambert admitted that she was in the Show apartment the day Laurie
died; that alone makes her


3 of 3
6/10/2006 8:34 AM
A...884 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
323
321 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 41 of 348, 1997327076
Published on Novem ber 23, 1997, Sunday News ( Lancast er, PA)
WGAL PROVIDES MEANINGFUL COVERAGE BEYOND

CRIME NEWS
This is in response to the Clyde conversation in the Sunday News Nov. 16..
As a local broadcaster, WGAL would never advocate anyone not
subscribing to or reading a daily newspaper. It is disturbing to us to learn
that fewer people are reading. But when you write about television's
limitations, you should not forget its advantages. When news happens,
television brings it to you almost instantly. Coverage of election returns,
life-threatening weather, earthquakes and other
Article 42 of 348, 1997326061
Published on Novem ber 22, 1997, I nt elligencer Journal ( Lancast er, PA)
STATE LAWYER GROUP DEFENDS DALZELL'S

RULING ON LAMBERT
Tough cases make bad laws.. So says the Pennsylvania Association of
Criminal Defense Lawyers (PACDL), which held a press conference Friday
to oppose a proposed bill which would limit the power of federal judges. The
so-called "Laurie Bill" was drafted in the wake of a federal judge's decision
to free Lisa Michelle Lambert, who was convicted in 1992 of killing
16-year-old Laurie Show. "We have found that when a piece of legislation is
proposed
Article 43 of 348, 1997325109
DEFENSE ATTORNEYS GROUP RAPS 'LAURIE BILL'

The Pennsylvania Association of Criminal Defense Lawyers has come out in
opposition to a federal bill introduced in September aimed at limiting the
power of federal judges.. The bill was drafted by Pennsylvania legislators in
reaction to a federal judge's decision to free Lisa Michelle Lambert, who
was convicted in 1992 of killing 16-year-old Laurie Show. The lawyers
organization, which is meeting this weekend in Lancaster County, is
scheduled to hold a press conference today at
1 of 3
6/10/2006 8:35 AM
A...885 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
324
322 of
of 456
454
June 14, 2016
Article 44 of 348, 1997322068

RAINVILLE AGAIN CLAIMS MCCRACKEN

CONVICTION IS UNJUST
Attorneys for Darrell McCracken continue to dispute prosecutors' claims
their client had the level of malice necessary for a murder conviction when
the truck he was driving killed a family of three.. In fact, McCracken's lead
attorney, Christiana Rainville of Philadelphia, now claims her client
"probably did not even cause the accident." Rainville's assertions were filed
Monday with the state Superior Court as McCracken attempts to
Article 45 of 348, 1997320082
AU PAIR AND LAMBERT: REMEMBER VICTIMS

Reading the stories, it was hard not to think about Lisa Michelle Lambert..
Yes, there are differences in the cases of Ms. Lambert, the then-19-year-old
Lancaster County woman convicted in 1992 of murdering 16-year-old Laurie
Show, and Louise Woodward, the 19-year-old British au pair convicted this
month of murdering 8-month-old Matthew Eappen in Massachusetts. In
both, though, a judge overruled a verdict and stunned the victim's family by
letting the defendant walk out of
Article 46 of 348, 1997311113
COUNTY COULD BE LOOKING AT BUDGET DEFICIT

Lancaster County Commissioners are struggling to narrow an $11.4 million
gap between projected expenditures and revenue as they work on the 1998
budget.. "The budget looks right now like a tax increase budget," Terry
Kauffman, chairman of the County Commissioners, said during a Thursday
work session. When county departments first submitted their individual
budgets for 1998, there was an $18.8 million deficit. That number was
lowered to $11.4 million after the
Article 47 of 348, 1997311094
COUNTY ASKS STATE SUPERIOR COURT TO UPHOLD

CASSEL CONVICTION
When Nathan Cassel and two of his friends sat outside 12-year-old Kenneth
Rodriguez Jr.'s home one February day in 1996, they were armed with
deadly weapons and a "coldness of heart," intending to exact revenge on
the boy's older brother.. Those facts alone, said Lancaster County
prosecutors, prove malice, the underpinning they needed to convict Cassel
and the others of third-degree murder for killing Kenneth on Feb. 28, 1996.
2 of 3
6/10/2006 8:35 AM
A...886 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
325
323 of
of 456
454
June 14, 2016
The facts also
Article 48 of 348, 1997310001
DA: LET CASSEL SENTENCE STAND

A Lancaster County jury's conviction and the judge's stiff sentence for a
man accused in the "horrendous violent crime" that claimed the life of a
12-year-old boy were correct, prosecutors insist.. Responding today to the
court appeal of Nathan D. Cassel, now 19, of Lititz, the county district
attorney's office asked state Superior Court to uphold the man's conviction
and sentence in the death of Kenneth Rodriguez Jr.
Article 49 of 348, 1997308083
SPECTER VOWS CONTINUED SUPPORT FOR 'LAURIE

BILL'
Under fire for a proposal to limit the power of federal judges in the wake of
the Lisa Michelle Lambert case, the three local congressmen who
introduced the bill now differ on whether it should move toward passage..
On Monday, New York Times columnist Anthony Lewis criticized the bill and
the congressmen who introduced it for launching an "assault" on the
independence of federal judges. Arlen Specter, an influential member of the
Senate Judiciary Committee, responded
Article 50 of 348, 1997306070
CATCHING UP ON THE NEWS

SUNDAY. Oct. 26 - Eleni Papadopoulos, 36, Lancaster, and her 15-year-old
son George, a 10th grader at Conestoga Valley, were killed in a traffic
accident on the Pennsylvania Turnpike in Chester County. The newly
refurbished McCaskey High School building was dedicated.. Charles H.
Turner, 65, was struck by a car as he tried to cross Route 30. The Elmer,
N.J., man died of injuries the next day. MONDAY. Oct. 27 - It


3 of 3
6/10/2006 8:35 AM
A...887 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
326
324 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 51 of 348, 1997305084
COUNTY CALLS MCCRACKEN APPEAL 'VICIOUS'

Lancaster County is asking the state to uphold Darrell McCracken's murder
conviction and reject his appeal as a "vicious and unjustified attack" on the
three people he was convicted of killing.. McCracken was sentenced in
February after a jury convicted him of third-degree murder and vehicular
homicide in the crash that killed Geoffrey Pywell, his wife, Susan
Davies-Pywell, and their son, Nathaniel Pywell, 11. The accident occurred in
September 1995, when
Article 52 of 348, 1997305015
DA OFFICE REFUTES APPEAL BY MCCRACKEN

Not only is Darrell McCracken guilty of murder, prosecutors say, but the
"sheer audacity" of his appeal is a "vicious and unjustified attack" on three
"innocent individuals: Geoffrey, Susan and young Nathaniel Pywell.".
McCracken, 33, of 623 Hilton Drive was convicted in a trial in January of
killing the Franklin & Marshall professor, his wife and their 11-year-old child
in a traffic accident in September
Article 53 of 348, 1997303093
Published on Oct ober 30, 1997, I nt elligencer Journal ( Lancast er, PA)
ANTI-JUDICIAL ACTIVISM EFFORT TOUTS LAMBERT

CASE
U.S. District Judge Stewart Dalzell's decision to free Lisa Michelle Lambert
has drawn the ire of a conservative special-interest group based in
Washington, D.C.. Under its Judicial Selection Monitoring Project, the Free
Congress Foundation's Center for Law and Democracy is circulating a
videotape denouncing judicial activism in the federal courts. And Judge
Dalzell and his decision to free Lambert are the group's prime targets..
"Judge
Article 54 of 348, 1997299065
1 of 3
6/10/2006 8:35 AM
A...888 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
327
325 of
of 456
454
June 14, 2016
Published on Oct ober 26, 1997, Sunday News ( Lancast er, PA)

SUNDAY. Oct. 19 - A bipartisan analysis of campaign pledge costs found
that Republican mayoral candidate Charlie Smithgall's campaign promises
could cost the city up to $28 million. Smithgall scoffed at the analysis. At a
forum on Tuesday, the race heated up further when McCaskey students
asked Lyons whether he had ever used drugs, and Lyons refused to
answer. Lyons accused the Smithgall campaign of being
Article 55 of 348, 1997296103
TWISTS, TURNS STILL AHEAD IN LAMBERT CASE

Following Tuesday's court hearing in Philadelphia, Lisa Michelle Lambert's
fate now rests in the hands of the U.S. Circuit Court of Appeals, a federal
court just a step below the U.S. Supreme Court.. Legal experts said
Wednesday that the impact of the court's eventual decision will be felt
nationwide. "It has monumental implications for criminal proceedings
throughout all 50 states," said Joseph Roda, a Lancaster lawyer who has
Article 56 of 348, 1997296110
CONFIDENT IN SYSTEM
We hope those who want Lisa Michelle Lambert to be returned to jail - or at
least face a new murder trial - do not become overly optimistic after
Tuesday's hearing before the U.S. 3rd Circuit Court of Appeals in
Philadelphia.. The best way to view the proceeding is as a sort of catharsis the first time the matter has been aired in a courtroom since Lambert was
freed last spring. It's something that community - riven by this case like no
other - needed. Yes, the
Article 57 of 348, 1997295181
JUDGES HAMMER LAMBERT'S ATTORNEY AT

APPEAL HEARING
PHILADELPHIA - An attorney for Lancaster County Tuesday urged three
federal appeals court judges to allow the state court system to decide if Lisa
Michelle Lambert should remain free or be retried for the 1991 murder of
Laurie Show.. Lambert was convicted of first-degree murder in 1992, but
her conviction was reversed last April by a federal judge. Lawyer Richard A.
Sprague argued that U.S. District Judge Stewart Dalzell trampled state and
federal laws by freeing Lambert from life
2 of 3
6/10/2006 8:35 AM
A...889 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
328
326 of
of 456
454
June 14, 2016
Article 58 of 348, 1997295049
Published on Oct ober 22, 1997, Lancast er New Era ( PA)
SHOWS, LOCAL LAWYERS UPBEAT AFTER HEARING

PHILADELPHIA - Cautious optimism.. That's the mood today among
Lancaster County officials and the parents of murdered teen-ager Laurie
Show, after a hearing Tuesday to determine the fate of the woman who has
become their nemesis. Lisa Michelle Lambert was convicted in county court
of Miss Show's murder in 1992. In April, U.S. District Judge Stewart Dalzell
overturned the conviction and freed Lambert.. The county appealed
Dalzell's decision. At
Article 59 of 348, 1997295050
LAMBERT INNOCENT? JUDGES ASK TOUGH

QUESTIONS ABOUT SLAYING
PHILADELPHIA - Lisa Michelle Lambert's fate is once again in judges'
hands.. This time, three federal circuit court judges will decide whether she
goes back to jail in the murder of 16-year-old Laurie Show or remains free.
One of the judges was especially brutal in questioning Lambert's attorney
during a hearing Tuesday held at the request of Lancaster County attorneys,
who are appealing Lambert's release in April.. "I started to
Article 60 of 348, 1997294081
LAMBERT APPEAL TO BE HEARD BY JUDICIARY

PANEL TODAY
Lancaster County's court appeal of Lisa Michelle Lambert's release from life
imprisonment will be heard this afternoon by a panel of three federal judges
in Philadelphia.. The hearing before a panel of U.S. Circuit Court of Appeals
judges will begin at 2 p.m. in the ceremonial courtroom on the first floor of
the U.S. Courthouse at 6th and Market streets. The hearing is open to the
public, but because of the interest in Lambert's case, seating will be


3 of 3
6/10/2006 8:35 AM
A...890 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
329
327 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 61 of 348, 1997293047
COUNTY TRIES TO RE-JAIL LAMBERT

After six months of preparation, Lancaster County's appeal of Lisa Michelle
Lambert's release from prison will finally be heard Tuesday in federal court..
Three judges from the U.S. Circuit Court of Appeals have allotted attorneys
on either side a maximum of 25 minutes to argue their case, with a promise
of not interrupting them only for the first 10 minutes. The hearing will be
held in the same ceremonial courtroom in Philadelphia where Lambert was
declared
Article 62 of 348, 1997285074

The following is a look back at local news events during the past week..
SUNDAY Oct. 5 - Thousands packed Long's Park to hear country music acts
at the WIOV/Turkey Hill Fall Music Fest.. `Bird-in-Hand firefighters and
neighbors helped to save the home of the Christ Beiler family on Miller Lane
after a fire started at 3 a.m.. `Warm, summer-like weather set in, with
temperatures rising well into the 80s.. MONDAY. Oct. 6 - Jurors heard from
the mother of victim Daryl
Article 63 of 348, 1997282104
LAWYERS CLAIM CASSEL TREATED UNFAIRLY AT

TRIAL RAINVILLE APPEALS CONVICTION
Attorneys for a Lancaster teen-ager convicted in the 1996 shooting death of
a 12-year-old Mary Street boy are appealing the conviction on the grounds
he was not given a fair trial.. The appeal was filed Tuesday in state Superior
Court on behalf of Nathan Cassel, 19, of Lititz, who was convicted with two
youths of killing Kenneth Rodriguez Jr. Feb. 28, 1996, as he stood at his
bedroom window. Philadelphia attorney Christina Rainville alleges
Lancaster County Judge Louis J. Farina erred in not
Article 64 of 348, 1997281071
1 of 3
6/10/2006 8:36 AM
A...891 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
330
328 of
of 456
454
June 14, 2016
LEWIS TO QUIT AS CITY GOP CHIEF

Alvin B. Lewis Jr. is stepping down as Lancaster city Republican chairman
sometime after the Nov. 4 election.. Lewis, who has led the city GOP since
1994, said he told other party leaders of his intentions last spring, but it
wasn't until last week that he informed rank and file committee people. He
said Tuesday that the demands of his legal practice prompted his decision..
"My practice was growing, and I had to make a decision between business
and the party and
Article 65 of 348, 1997281053
RAINVILLE HITS THE DEFENSE IN MARY ST. DEATH

TRIAL
A state court should overturn a Lititz teen's conviction for the murder of a
Mary Street boy due to insufficient evidence, errors by his trial attorney and
his overly heavy sentence, according to an appeal filed Tuesday.. Christina
Rainville, a Philadelphia attorney, entered the appeal in state Superior Court
on behalf of Nathan Cassel, 19, of Lititz. It is Rainville's third appeal of a
local murder case. "The record in this case is so devoid of
Article 66 of 348, 1997278069

SUNDAY. Sept. 28 - Gloria J. Hargis, 48, Ephrata, was killed in a two-car
crash at Clay and East Newport roads. MONDAY Sept. 29 - Commonwealth
Security Systems Inc., sold less than a year ago to Republic Industries, was
sold again to Ameritech. Commonwealth was founded by Patrick Egan, who
sold the company to Republic for $36.5 million in stock. TUESDAY. Sept. 30
- About 119,000 PP&L customers signed up
Article 67 of 348, 1997278085
37,000 AGREE WITH CRUSADE TO IMPEACH JUDGE

DALZELL
This is in response to the Sunday News editorial of Sept. 28, titled "The
wrong path," regarding John and Hazel Show's crusade to impeach Judge
Stewart Dalzell and to present a national petition for further legislation
regarding federal judges and their powers. The editor cannot endorse the
crusade; however, along with many congressmen, there are at least 37,000
individuals who wholeheartedly agree with this crusade, as evidenced by
the signed petitions..
2 of 3
6/10/2006 8:36 AM
A...892 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
331
329 of
of 456
454
June 14, 2016
Article 68 of 348, 1997275105

LAMBERT APPEAL COULD HINGE ON RECENT

RULING
Attorneys handling Lancaster County's appeal of Lisa Michelle Lambert's
release from life imprisonment believe a federal court ruling two weeks ago
in a Luzerne County murder case will be pivotal in helping their appeal.. The
three 3rd U.S. Circuit Court of Appeals judges assigned to hear the county's
appeal in Philadelphia on Oct. 21 on Tuesday asked lawyers for Lambert
and Lancaster County to submit written arguments comparing Lambert's
case
Article 69 of 348, 1997275060
MCCRACKEN TRIAL WAS UNFAIR, SAYS RAINVILLE

Daryl McCracken's trial just wasn't fair, his attorney maintains.. "No
reasonable juror would have convicted McCracken had the trial been fair,"
Christina Rainville wrote to the state Superior Court Wednesday. "This case
involves a tragic fatal accident which left three people dead. It is all the
more tragic because the aftermath of the accident was a prosecution of an
innocent man.". The worst of numerous offenses,
Article 70 of 348, 1997274042
3 JUDGES TO HEAR LAMBERT APPEAL

The panel of judges has been appointed. The time has been set.. About
three weeks from today, the lawyers in the Lisa Michelle Lambert case will
get exactly 15 minutes each to argue their positions before a federal
appeals court. The attorneys will appear at 2 p.m. Tuesday, Oct. 21, in the
federal courthouse in Philadelphia.. Hearing them will be a panel of three
judges: Carol Los Mansmann, 55, of Pittsburgh; Morton I. Greenberg, 64, of
Philadelphia; and Arthur R. Alarcon, 72, of


3 of 3
6/10/2006 8:36 AM
A...893 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
332
330 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 71 of 348, 1997274044

The lawyers arguing over Lisa Michelle Lambert's freedom may have just
been given a hint of what the three judges deciding the case want to hear..
Did Lambert exhaust all her appeals in Pennsylvania's courts before she
turned to a federal court judge for help? Last spring, U.S. District Judge
Stewart Dalzell freed Lambert from her life prison sentence for the murder
of 16-year-old Laurie Show of East Lampeter Twp.. In their appeal of that
decision, attorneys
Article 72 of 348, 1997271078
Published on Sept em ber 28, 1997, Sunday News ( Lancast er, PA)
THE WRONG PATH

No one, except another parent who has lost a child, can understand how
John and Hazel Show feel.. Like most other Lancaster Countians, we can
only sympathize with the Shows and their pain, these six years after the
horrible murder of their 16-year-old daughter Laurie. But we can't endorse
their crusade against the federal judge who freed Miss Show's convicted
murderer, Lisa Michelle Lambert, from jail.. The Shows want Judge Stewart
Dalzell to be impeached - removed
Article 73 of 348, 1997267138
Published on Sept em ber 24, 1997, I nt elligencer Journal ( Lancast er,
PA)
MYSTERIES WILL BE TOPIC OF 5 LECTURES

According to writer Neil Albert, mysteries are really morality plays.. "The
killer gets caught, he pays his price, society is safe and the world is okay,"
he said. Albert, an attorney with Zimmerman, Pfannebecker and Nuffort, is
the author of six detective thrillers featuring David Garrett, a disbarred
attorney, caught taking the bar exam for his wife.. The Unitarian Universalist
Center's Beacon Program of Leisure Learning will be featuring Neil Albert
Article 74 of 348, 1997267179
1 of 4
6/10/2006 8:38 AM
A...894 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
333
331 of
of 456
454
June 14, 2016
PA)
MU STUDENT REPUBLICANS ELECT OFFICERS

New officers have been elected to lead the Millersville University College
Republicans.. Kristin McGeary, sister of Jeff McGeary, last year's candidate
for chairman of the Pennsylvania College Republicans, was re-elected
chairman for the 1997-98 school year. Other offices are: James Senft, vice
chairman; Tara Tomlinson, secretary; and alumnus Dean Lee Evans, public
relations coordinator. James Jolly, history professor, is the academic
adviser.. The group's current
Article 75 of 348, 1997267033
Published on Sept em ber 24, 1997, Lancast er New Era ( PA)
PASS 'LAURIE BILL' TO CURB POWER OF FEDERAL

JUDICIARY
Some may consider the "Laurie Bill" a congressional attempt to subvert the
power of the federal judiciary. Count us among those who look at this
legislation as a simple effort to balance judicial activism with reasoned
regulation.. The bill, formally known as the Victim Protection Act, was
introduced last month in the Senate by Sen. Arlen Specter and in the House
by Reps. George Gekas and Joseph Pitts. The bill would prohibit federal
judges in most cases from barring
Article 76 of 348, 1997264062

SUNDAY Sept. 14 - A speeding car slammed into a buggy in West
Hempfield, injuring six members of the Melvin Petersheim family. The driver
drove away and then abandoned his car. Members of the family were
treated and released. On Monday, a Lebanon man called police and
admitted he was the driver.. MONDAY. Sept. 15 - The cameras began
rolling at Landis Valley Museum for two days of shooting on the movie
Article 77 of 348, 1997261094
PA)
SHOWS TAKE THEIR CASE TO CAPITOL

WASHINGTON - The parents of murder victim Laurie Show crisscrossed
Capitol Hill Wednesday, presenting 11 Pennsylvania legislators with
petitions asking them to probe the conduct of a federal judge and reform the
federal court system.. Wednesday marked the official kickoff of John and
Hazel Shows' national campaign to have U.S. District Judge Stewart Dalzell
impeached and to have legislation enacted curtailing the power of federal
judges. U.S. Sen. Arlen Specter and U.S. Reps.
2 of 4
6/10/2006 8:38 AM
A...895 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
334
332 of
of 456
454
June 14, 2016

Article 78 of 348, 1997261047
SHOWS TAKE FIGHT TO CONGRESS

WASHINGTON - Five months after their daughter's alleged killer was freed
from federal prison after an appeal, John and Hazel Show arrived here
Wednesday to ask 11 members of Congress for help.. Armed with petitions
containing the signatures of some 37,000 Lancaster County residents, the
Shows met all day with lawmakers to try to enlist support for their cause.
The petitions ask for the impeachment of the federal judge who freed the
alleged killer of their 16-year-old daughter,
Article 79 of 348, 1997257058

SUNDAY Sept. 7 - Elizabethtown police said the shooting deaths on
Saturday, Sept. 6, of Edward Brenner Jr., 52, and Michael C. MacDonald,
45, both of Elizabethtown, may have been a murder-suicide.. MONDAY.
Sept. 8 - Citing technical concerns, the Manor Township Planning
Commission voted 4-3 to reject Wal-Mart's revised plan for a superstore on
Centerville Road. The county planning commission will have
Article 80 of 348, 1997253192
PA)
RAINVILLE MAY BE IN TROUBLE AT HER OWN LAW

FIRM
Christina Rainville's legal work to free Lisa Michelle Lambert from life
imprisonment enraged many in Lancaster County.. And she didn't win many
fans here when she agreed to represent Darrell McCracken, who was
convicted of third-degree murder for causing a traffic accident that killed a
Franklin & Marshall College professor, his wife and their 11-year-old son.
Now it appears that her continued legal representation of Lambert and her
subsequent work on


3 of 4
6/10/2006 8:38 AM
A...896 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
335
333 of
of 456
454
June 14, 2016
4 of 4
6/10/2006 8:38 AM
A...897 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
336
334 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 81 of 348, 1997252024
MCCRACKEN EVIDENCE WAS 'RIGGED,' APPEAL

SAYS
Will Darrel McCracken walk out of prison a free man because of misconduct
by Lancaster County prosecutors?. He should, said McCracken's attorney,
Christina Rainville, because he was wrongly convicted by the prosecutors'
intentional "manipulation of the evidence." McCracken, 33, of 623 Hilton
Drive, was convicted of third-degree murder for a traffic accident that
claimed the life of Franklin & Marshall College professor Geoffrey
Article 82 of 348, 1997249070
Published on Sept em ber 6, 1997, I nt elligencer Journal ( Lancast er, PA)
PYWELLS BLAMED FOR OWN DEATHS IN

MCCRACKEN CASE
Attorneys representing Darrel McCracken in his appeal to have his
third-degree murder conviction overturned are claiming his victims' car was
going 99 miles per hour when it was struck by McCracken's truck.. In her
state Superior Court filing late Thursday, attorney Christina Rainville and
two colleagues claim a police report of the Sept. 3, 1995, accident clearly
states the car driven by Geoffrey Pywell was speeding before the collision
that night with McCracken at
Article 83 of 348, 1997248085
MCCRACKEN PASSENGER PLANS TO SUE

A passenger riding in a truck driven by Darryl McCracken the night he ran a
traffic light and killed a Lancaster family has filed notice that he plans to sue
McCracken, a fellow passenger and the dead family's estate.. George
Snook, 922 High St., through his Philadelphia attorney, Robert Land, filed
the notice, called a Writ of Summons, in Lancaster County Court on
Wednesday. The filing names as defendants McCracken, 623 Hilton Drive;
the second passenger, Archer Morgan III, 846
1 of 3
6/10/2006 8:39 AM
A...898 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
337
335 of
of 456
454
June 14, 2016
Article 84 of 348, 1997248090
ATTORNEYS BATTLE OVER MCCRACKEN EVIDENCE

A county judge Thursday ordered Darryl McCracken's trial attorney to turn
over all documents related to the case to the attorneys handling
McCracken's appeal of a third-degree murder conviction.. Judge Paul K.
Allison, acting on a motion filed by attorney Christina Rainville of
Philadelphia, gave Lancaster attorney Roy D. Shirk five days to comply with
his order. In her filing, Rainville, who gained notoriety here for winning the
freedom of Lisa Michelle Lambert, said
Article 85 of 348, 1997246029
MCCRACKEN APPEAL STALLS AS RAINVILLE VIEWS

DOCUMENTS
Darrel McCracken's appeal process has been delayed until his new
Philadelphia attorney can look at video tapes, documents and evidence
from his Lancaster County trial.. McCracken was convicted in January of
killing Franklin and Marshall College professor Geofffrey Pywell, Pywell's
wife, Susan Davies-Pywell, and their 11-year-old son, Nathaniel, in a traffic
accident in September 1995. A jury found McCracken guilty of third-degree
murder for intentionally not stopping
Article 86 of 348, 1997244100
PARENTS OF MURDERED TEEN-AGER LAUNCH

CRUSADE AGAINST JUDGE
EDITOR'S NOTE: This is the fourth in a series of articles on the Lisa
Michelle Lambert case and its implications. The occasional series will use
her overturned murder conviction as a touchstone to show how state and
federal courts work. Today's story focuses on Hazel and John Show, the
parents of murder victim Laurie Show, and their campaign to have U.S.
District Judge Stewart Dalzell impeached.. Hazel and John Show, a
divorced Lancaster County couple, have united to
Article 87 of 348, 1997237220
Published on August 25, 1997, Lancast er New Era ( PA)
MOUNTVILLE MAN LEADS YOUNG GOP

New officers have been elected to lead the Lancaster County Young
Republicans.. Serving as chairman is Bruce Gadbois of Mountville. Other
officers are Aaron Ranck, vice chairman; Karen Johnson, secretary; and
Dean Lee Evans, treasurer. The group's current activities include helping
the Lancaster mayoral campaign of Charlie Smithgall, the borough
councilcampaign of Gadbois, and the petition drive to oust the federal judge
who overturned the murder conviction of Lisa Michelle
2 of 3
6/10/2006 8:39 AM
A...899 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
338
336 of
of 456
454
June 14, 2016

Article 88 of 348, 1997236348
Published on August 24, 1997, Sunday News ( Lancast er, PA)
SCOTT OBERHOLTZER ENJOYS CALLING HIS OWN

SHOTS
Even as a kid, Scott K. Oberholtzer envisioned a call-your-own-shots type of
career.. "Originally," he says, "I wanted to be a research scientist." But law
was his strong suit. Since he started practicing in Lancaster 15 years ago,
Oberholtzer, the county's first assistant public defender, has handled four
death penalty cases and half a dozen more murder trials.. He has recently
become known as a legal analyst, offering his views
Article 89 of 348, 1997235143
RAINVILLE PARTNER (AND SPOUSE) TAKES LEAD

ROLE
When Lisa Michelle Lambert's case for freedom comes before a federal
appeals court in October, she'll have Philadelphia attorney Peter S.
Greenberg in her corner arguing her case.. Although attorney Christina
Rainville became known as the leader of the eight-member legal team that
won Lambert's release from a life prison sentence in April, Greenberg has
worked beside her from the start. Greenberg, 53, is a partner in the
200-member Philadelphia law firm of
Article 90 of 348, 1997231177
PHILA. ATTORNEY TO ARGUE LAMBERT APPEAL

A Philadelphia attorney will be arguing the county's appeal in the Lisa
Michelle Lambert case in federal court in October.. Richard A. Sprague, of
Sprague & Lewis, 116 E. King St., and Sprague & Sprague, Philadelphia, is
now preparing to argue the case before the 3rd U.S. Circuit Court of
Appeals in Philadelphia, said his local law partner Alvin B. Lewis Jr. The
court has tentatively marked Oct. 20 as the date it will listen to arguments
from attorneys on


3 of 3
6/10/2006 8:39 AM
A...900 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
339
337 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 91 of 348, 1997230276
Published on August 18, 1997, I nt elligencer Journal ( Lancast er, PA)
TAXPAYERS SHOULDN'T PAY COST OF LAWYERS

To the Editor: Why should the taxpayers in Lancaster County have the
burden to pay outrageous lawyer fees for the district attorneys and others
who created this problem with the Lisa Michelle Lambert case.. They are
the guilty ones who did unethical technicalities and are guilty in this
situation. The money should come out of their pockets and not out of the
pockets of the poor in Lancaster County. So now lawyers are getting rich at
the expense of Lancaster County citizens. Judge Dalzell did
Article 92 of 348, 1997229335

SUNDAY Aug. 10 - DeeDee Carolann Null, Lancaster, was killed when the
motorcycle on which she was a passenger crashed into a tree in Martic
Township. The 27-year-old was the mother of four children.. The highway
carnage continued Tuesday when Donald Dorwart, 42, Book Road, was
killed in an early-morning crash on Route 222 in Manheim Township that
closed the road for nearly five hours.. Eighteen hours later in West
Article 93 of 348, 1997227262
COURT TO CONSIDER STATES' ARGUMENTS IN

LAMBERT CASE
Lancaster County's bid to return Lisa Michelle Lambert to prison got a boost
Thursday when a federal appeals court agreed to allow six states to formally
support the county's challenge of her freedom.. The 3rd U.S. Court of
Appeals on Thursday permitted attorneys general from Pennsylvania,
Delaware, California, Oklahoma, Louisiana and South Carolina to make
legal arguments on behalf of the county's appeal of a judge's decision to
free Lambert
Article 94 of 348, 1997226306
1 of 3
6/10/2006 8:40 AM
A...901 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
340
338 of
of 456
454
June 14, 2016
MCCRACKEN RAISES MISCONDUCT ISSUE

The Philadelphia lawyer who helped Lisa Michelle Lambert win her freedom
said in court papers filed Wednesday that Darrell McCracken should be
released from jail for the same reason - prosecutorial misconduct.. Christina
Rainville, who is handling McCracken's court appeal, told the state Superior
Court that her client was denied a fair trial in Lancaster County Court earlier
this year. In the court filing, Rainville accuses county prosecutors of
misconduct; says
Article 95 of 348, 1997226254
COURT ACCEPTS STATES' BRIEF IN LAMBERT CASE

The federal judges who will decide whether Lisa Michelle Lambert remains
free have decided to accept a "friend of the court" brief filed by six attorneys
general in support of Lancaster County.. The news is a shot in the arm for
the county's appeal of a federal judge's decision to free Lambert and bar
efforts to retry her for the 1991 killing of a teen-age Lancaster girl. It means
the 3rd U.S. Circuit Court of Appeals will factor the
Article 96 of 348, 1997223332
TIME TO ALTER THE JUDICIAL SYSTEM IN US

To the Editor:. Dalzell does not walk with God. Your recent article on the
power that federal courts possess (Intell, Aug. 1) supports the key
ideological philosophy that drove Timothy McVey to kill 168 people. That is
that government is too big, too intrusive to the rights of law-abiding
Americans and downright dangerous. I do not support what McVey did, but
we tend to be shortsighted and one-sided in our views. We do not see why
McVey did what he did, we only saw the dead babies. At least
Article 97 of 348, 1997222311

SUNDAY Aug. 3 - PennDOT said it will meet with the prime contractor to
develop a plan to get the Route 30 widening project back on schedule..
`Fires destroyed the Instant Amish Photo Gallery in Intercourse and
damaged a home in Strasburg.. MONDAY. Aug. 4 - While their children
played outside their Mountville home, Charles and Lisa Mock argued inside.
Manor Township police said Charles then shot his wife with a
Article 98 of 348, 1997221193
2 of 3
6/10/2006 8:40 AM
A...902 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
341
339 of
of 456
454
June 14, 2016
DATE SET TO HEAR ARGUMENTS IN LAMBERT

APPEAL
A federal appellate court that will decide Lancaster County's appeal of Lisa
Michelle Lambert's freedom has tentatively scheduled time in late October
for lawyers to present verbal arguments in front of a panel of judges.. The
3rd U.S. Court of Appeals expects to hear from attorneys for the county and
Lambert in court on Tuesday, Oct. 21, said Brad Baldus, a circuit court law
clerk assigned to the Lambert case. Alvin B. Lewis Jr., a Lancaster lawyer
who represents the
Article 99 of 348, 1997221205
COUNTY'S BILLS IN LAMBERT CASE TOP $500,000

The cost of challenging Lisa Michelle Lambert's release has topped half a
million dollars and will rise considerably, according to the chairman of the
county commissioners.. Outside lawyers hired by Lancaster County have
submitted bills totaling $540,000 for legal work on the case, chairman Terry
Kauffman said. The money will come from taxpayers. So far, the county has
been able to pay the fees through belt-tightening rather than by dipping into
cash reserves. No county employees
Article 100 of 348, 1997220250
COUNTY APPEAL IN LAMBERT CASE SLATED FOR

OCT. 20
The federal appellate court has tentatively marked Oct. 20 as the date it will
listen to legal arguments from attorneys on either side of the Lisa Michelle
Lambert case.. Officials with the 3rd U.S. Circuit Court of Appeals said they
will reveal, 10 days before that date, the identity of the three federal judges
who will hear the arguments. Lancaster County began the appeal process
after U.S. Judge Stewart Dalzell freed Lambert in April and forbade
prosecutors from trying her again for the


3 of 3
6/10/2006 8:40 AM
A...903 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
342
340 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 101 of 348, 1997220256
WAS TRAFFIC LIGHT BROKEN DURING CRASH?

Just days after Darrel McCracken struck and killed a family of three at a city
intersection, the traffic light there malfunctioned.. City repairmen were
called out to repair the light twice on Sept. 8, 1995, five days after
McCracken struck a station wagon and killed Franklin and Marshall College
Professor Geoffrey Pywell, his wife, Susan Davies-Pywell, and their
11-year-old son, Nathaniel. In January, a jury found McCracken guilty of
third-degree murder. He was sentenced to 10 to 20 years
Article 102 of 348, 1997219246
6 STATES DEFEND FILING FOR LAMBERT

They want what is fair and they have the right to support the county in its
appeal of the freeing of Lisa Michelle Lambert.. So said the attorneys
general of six states Wednesday in an attempt to uphold their right to file a
"friend of the court brief" in the Lambert case. "Justice must be done to both
Lambert and the Commonwealth," the attorneys general stated in their
latest filing in the case.. Pa. Attorney General Mike Fisher and the
Article 103 of 348, 1997218429
NO MATTER WHAT, BUCK HELPED KILL LAURIE, DA

SAYS
Prosecutors are not admitting they made mistakes in the investigation of
16-year-old Laurie Show's murder.. But, even if they did, convicted killer
Tabitha Buck does not deserve another chance in court, the Lancaster
County District Attorney's office wrote recently. "Even if errors occurred,"
John A. Kenneff, first assistant district attorney, wrote in a new legal filing,
Buck does not deserve "relief" in the case,
Article 104 of 348, 1997217163
1 of 3
6/10/2006 8:41 AM
A...904 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
343
341 of
of 456
454
June 14, 2016
RENO: SENATE TOO SLOW IN OK OF JUDGES

From Staff and Wire Reports. Attorney General Janet Reno today accused
the Senate of an "unprecedented slowdown" in confirming President
Clinton's nominees for federal judgeships, saying the delay is harming the
justice system. "Surely the (Constitution's) framers did not intend Congress
to obstruct the appointment of much-needed judges, but rather simply to
ensure that well-qualified individuals were appointed to the federal
Article 105 of 348, 1997215338

SUNDAY July 27 - The death of Mark Groner, 25, a band instructor in
Hempfield schools, was reported. He was involved in a traffic accident
Friday and died Saturday.. MONDAY. July 28 - Traffic was snarled on Route
30 after a cement-mixing truck hit an overpass at rush hour, jamming
eastbound traffic for four hours.. Lancaster County planners, as expected,
turned down Wal-Mart's plan for a store on
Article 106 of 348, 1997214220
LAMBERT LAWYERS BLAST ATTEMPT TO APPEAL

STATE COURT'S DECISION
Lisa Michelle Lambert's lawyers blasted an attempt by six state attorneys
general to support Lancaster County's court appeal of Lambert's freedom,
urging a federal appeals court to disallow the states' effort.. Led by
Pennsylvania Attorney General Mike Fisher, attorneys general from
Delaware, Louisiana, South Carolina, Oklahoma and California asked the
3rd U.S. Circuit Court of Appeals to allow the group to support the county's
Article 107 of 348, 1997213301
FEDERAL JUDGES DON'T ANSWER TO PUBLIC

EDITOR'S NOTE: This is the third in a series of articles on the Lisa Michelle
Lambert case and its implications. The series will use her overturned murder
conviction as a touchstone to show how state and federal courts work.
Today's story focuses on the power of federal judges.. It's been said that
federal judges are the closest thing to God because they are not
accountable to anyone. Once the president appoints someone to the federal
bench,
Article 108 of 348, 1997213304
2 of 3
6/10/2006 8:41 AM
A...905 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
344
342 of
of 456
454
June 14, 2016
LEGISLATORS AIM TO CURB FEDERAL JUDGES'

POWER
WASHINGTON - A bill aimed at limiting the power of federal judges, which
was drafted in reaction to the Lisa Michelle Lambert case, isn't expected to
be considered by Congress until next year, the three legislators who
introduced it said Thursday.. U.S. Sen. Arlen Specter and U.S. Reps.
Joseph R. Pitts and George W. Gekas collaborated on the legislation, which
would prohibit federal judges in most cases from barring the retrial of a
person convicted in a state court. It will be
Article 109 of 348, 1997213306
A RATIONAL RESPONSE
Until now, the reaction to Judge Stewart Dalzell's decision to free Lisa
Michelle Lambert has produced much heat but little light.. With the
introduction of legislation aimed at curbing the power of federal judges, we
are beginning to see some light. U.S. Sen. Arlen Specter and U.S. Reps.
Joe Pitts and George Gekas unveiled the Victim Protection Act of 1997
Thursday, which is designed to prohibit federal judges in most cases from
barring the retrial of a person convicted in a
Article 110 of 348, 1997213253
ATTORNEYS FOR LAMBERT RIP STATES' FILING

Lisa Michelle Lambert's attorneys fired back Thursday at a brief attacking
Lambert's freedom filed by the state attorney general and supported by the
attorneys general of five other states.. Not only was the brief filed late,
Lambert's attorneys said, it is highly improper because the state has two
distinct conflicts of interest in the case. "This state, with all of its resources,
apparently will go to any length - lawful or unlawful, ethical


3 of 3
6/10/2006 8:41 AM
A...906 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
345
343 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 111 of 348, 1997212323
Published on July 31, 1997, I nt elligencer Journal ( Lancast er, PA)
BILL WOULD LIMIT POWER OF FEDERAL JUDGES

Sparked by a federal judge's decision to free Lisa Michelle Lambert, three
federal legislators will introduce legislation today that would limit the power
of federal judges.. U.S. Sen. Arlen Specter and U.S. Reps. Joseph R. Pitts
and George W. Gekas will unveil the Victim Protection Act of 1997 at 1:30
p.m., during a press conference on the east steps of the U.S. Capitol in
Washington, D.C. If the act passes the Senate and House of
Representatives and is eventually signed into
Article 112 of 348, 1997212280
Published on July 31, 1997, Lancast er New Era ( PA)
BILL TO LIMIT POWER OF FEDERAL JUDGES

UNVEILED
Local lawmakers were introducing legislation in Washington today "on
behalf of Laurie Show" that would limit the power of federal judges.. The
legislation would forbid federal judges from barring retrials of convicted
criminals - just like a Philadelphia federal judge did when he freed Lisa
Michelle Lambert in April. U.S. Reps. Joseph R. Pitts and George W.
Gekas, along with U.S. Sen. Arlen Specter, were to unveil the amendment
at a press conference..
Article 113 of 348, 1997211511
LAMBERT LAWYER FIRES OPENING ROUND IN

ANOTHER MURDER CASE
The same Philadelphia lawyer who helped Lisa Michelle Lambert win her
freedom maintains that a teen-ager convicted of killing a 12-year-old city
boy did not receive a fair trial in Lancaster County Court.. Christina Rainville
and her associate, James D. Crawford, are representing Nathan Cassel, a
19-year-old Warwick High School dropout who is serving a 15-to-40-year
prison sentence. Cassel was one of three teen-agers convicted of killing
Kenneth Rodriguez while he stood by a second-floor
1 of 3
6/10/2006 8:42 AM
A...907 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
346
344 of
of 456
454
June 14, 2016
Article 114 of 348, 1997210239

COURT SETS TIMES TO HEAR LAMBERT APPEAL

Michelle Lambert's freedom has tentatively scheduled time for attorneys to
present their arguments in front of a panel of judges.. The 3rd U.S. Circuit
Court of Appeals in Philadelphia has notified lawyers representing Lambert
and the county that oral arguments regarding the county's appeal will be
heard in court on one of five days in October or November. The possible
days are
Article 115 of 348, 1997208371
Published on July 27, 1997, Sunday News ( Lancast er, PA)

SUNDAY July 20 - The week opened with dry, hot weather continuing, but
then rain of up to a half-inch fell Monday night in scattered areas of the
county.. By early Wednesday, as remnants of Hurricane Danny stalled over
the area, the parched region got what it needed - a soaking rain. The rains
continued off and on through Thursday. In short order, the area went from a
drought watch to a flood watch; rains in some
Article 116 of 348, 1997207218
LATEST LAMBERT DISPUTE: LIES IN BUCK'S

TESTIMONY
Attorneys on both sides of Lisa Michelle Lambert's appeal have fired a
volley of new assaults at one another.. This time, the controversy centers on
Tabitha Buck, Lambert's accused conspirator in the murder of 16-year-old
Laurie Show in December 1991. Both Buck and Lambert, who were 17 and
19 respectively at the time of the murder, were convicted of killing the
Conestoga Valley High School sophomore and sentenced to life in prison.
In April, Lambert was freed after a
Article 117 of 348, 1997206240
SUBURB POLICEMAN FACES TRIAL ON CHILD

MORALS CHARGES
For years, beginning when the girl was about 8 years old, she watched
pornographic videos with him.. Then the man, an East Lampeter Township
police officer, began fondling her, the girl told a district justice today,
touching her body and bribing her to perform oral sex on him. Finally, they
had sexual intercourse.. She never told anyone, she testified.. Not her
2 of 3
6/10/2006 8:42 AM
A...908 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
347
345 of
of 456
454
June 14, 2016
mother. Not her closest friends.. Until she was told that the man, Robert S.
Reed, 38, of 314 Greenland Drive, had been
Article 118 of 348, 1997204477
ATTORNEYS HAGGLE ON BUCK DEPOSITION

Private attorneys handling Lancaster County's federal court appeal of Lisa
Michelle Lambert's freedom and Lambert's lawyers on Tuesday continued a
war of words over whether one sentence should be stricken from the court
record.. That sentence is: "Respondents (Lancaster County and the
Commonwealth of Pennsylvania) could just as easily ask this court to
supplement the record with the deposition testimony of one of Lambert's
Article 119 of 348, 1997204478
6 STATES WANT A SAY IN LAMBERT CASE

Six states have asked to intervene on behalf of Lancaster County's appeal
of Lisa Michelle Lambert's freedom.. The attorneys general from
Pennsylvania, Delaware, California, Louisiana, Oklahoma and South
Carolina have asked the 3rd U.S. Circuit Court of Appeals to let them
support the county's effort to retry Lambert for a 1991 murder. The states
joined Monday to file "friend of the court" legal papers supporting the
Article 120 of 348, 1997203184
PENNA., 5 OTHER STATES JOIN COUNTY IN LAMBERT

APPEAL
Lancaster County has six powerful, new "friends," who support its objection
to the freeing of Lisa Michelle Lambert.. They are the attorneys general
from Pennsylvania, California, Delaware, Louisiana, Oklahoma and South
Carolina. The six states joined in a "friend of the court" brief filed Monday on
behalf of Lancaster County in federal court in Philadelphia.. The states filed
the brief because they believe that the decision to free Lambert


3 of 3
6/10/2006 8:42 AM
A...909 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
348
346 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 121 of 348, 1997201311

SUNDAY July 13 _ Hot, humid weather settled over the area. On Monday,
the high at Millersville University's weather station was 95. Rainfall also
continued to be below normal, with July 1.75 inches under as of Monday..
By Tuesday, municipalities were asking residents to voluntarily limit their
use of water. By the end of the week, it was no longer voluntary in some
places.. Tuesday's
Article 122 of 348, 1997200275
PITTS SAYS ROUTE 23 STUDY WILL BE LAUNCHED

NEXT MONTH
A new $1.5 million study of what should be done to improve the Route 23
corridor between Lancaster and New Holland will begin next month and will
take 1 1/2 to 2 years to complete, U.S. Rep. Joseph R. Pitts announced
Friday.. Pitts made the announcement to about 40 people gathered for a
town meeting he held at New Holland Borough Hall. He said about $1.2
million for the study is coming from the federal government. The remainder
will come from the state and the county. The congressman said
Article 123 of 348, 1997198349
LAMBERT LAWYERS GET $252,000 IN LEGAL FEES

Lawyers who helped Lisa Michelle Lambert win her freedom have been
granted $252,000 in court-appointed legal fees.. The fees will be paid from
U.S. taxpayer money set aside for such purposes. U.S. District Judge
Stewart Dalzell, who overturned Lambert's first-degree murder conviction
and freed her in April from life in jail, recommended the fee payment for
attorney Christina Rainville and seven of her colleagues at the Philadelphia
law firm Schnader Harrison Segal &
Article 124 of 348, 1997198346
1 of 3
6/10/2006 8:42 AM
A...910 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
349
347 of
of 456
454
June 14, 2016
COUNTY LAWYERS MAKE FINAL APPEAL TO COURT

Lawyers representing Lancaster County Wednesday again asked a federal
appeals court to allow the retrial of Lisa Michelle Lambert for the 1991
murder of Laurie Show.. The county's lawyers, Richard A. Sprague in
Philadelphia and Alvin B. Lewis Jr. in Lancaster, made the request to the
3rd U.S. Court of Appeals in their final court papers before the court issues
a decision in this case. The appellate court has the option of allowing
attorneys on both sides of the Lambert case to
Article 125 of 348, 1997198296
LAMBERT'S ATTORNEYS AWARDED $252,000

Lawyers for Lancaster County probably will not appeal a judge's awarding
of $252,000 in legal fees to the defense attorneys who helped to free Lisa
Michelle Lambert.. The fees, which were awarded Wednesday, will be paid
in the next week to Christina Rainville and her colleagues at the
Philadelphia law firm of Schnader Harrison Segal & Lewis. The money will
come from federal taxpayers. Rainville and her colleagues helped Lambert
win her freedom in April in a hearing
Article 126 of 348, 1997198297
COUNTY APPEAL: LAMBERT LAWYERS

DISREGARDED FACTS
Lisa Michelle Lambert was convicted of murder by "overwhelming
evidence," Lancaster County lawyers charge, yet her attorneys "disregarded
the facts and disregarded the law" in the crusade to free their client.. In the
county's latest effort, filed late Wednesday, lawyers asked a federal appeals
court to reverse Judge Stewart Dalzell's decision to free Lambert. Or at
least, the county said, the court should order that she
Article 127 of 348, 1997194353

SUNDAY July 6 - Jose Berley, 24, of Columbia, died from wounds he
received when he was shot in the leg by a Columbia policeman on June 21.
State police investigated the shooting, which is now under review by the
Lancaster County District Attorney's office.. MONDAY. July 7 - A
200-year-old Manor Township barn owned by state Rep. John Barley and
his brother, Abe Barley, was destroyed by a two-alarm fire.
2 of 3
6/10/2006 8:42 AM
A...911 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
350
348 of
of 456
454
June 14, 2016
Article 128 of 348, 1997193220
ATTORNEYS NOW SEEKING $284,000 IN LAMBERT

FEES
Lawyers who helped Lisa Michelle Lambert win her freedom Thursday
made a formal request to a federal judge to be paid more than $280,000 in
taxpayer money for Lambert's legal fees.. Philadelphia attorney Christina
Rainville filed a fee voucher asking U.S. District Judge Stewart Dalzell to
approve payment of $283,988 in fees for 5,019 hours of legal work for
Lambert from Oct. 4, 1996, to April 21. It was on April 21 that Dalzell
overturned Lambert's murder conviction
Article 129 of 348, 1997191288
COUNTY LAWYERS WANT LONG CHAT WITH

JUDGES
Lawyers representing Lancaster County in its appeal of Lisa Michelle
Lambert's release from prison on Wednesday urged a federal appellate
court to schedule a longer-than-usual open court session so they can
verbally argue their points in front of a panel of judges.. The county's
lawyers, Richard A. Sprague in Philadelphia and Alvin B. Lewis Jr. in
Lancaster, asked the 3rd U.S. Circuit Court of Appeals to allow them 30
minutes to present their oral arguments. The
Article 130 of 348, 1997191289
FOLLOWING LAMBERT'S FOOTSTEPS

Tabitha F. Buck wants a judge to set her free and block authorities from
retrying her for the 1991 murder of Laurie Show.. Three months ago Lisa
Michelle Lambert, the other woman convicted in 1992 of killing Show, was
released from jail by a federal judge and cleared of the killing. The judge
barred county prosecutors from trying Lambert again for Show's murder.
Now Buck, using some of the information that transpired in the Lambert
hearing, has begun the same process that Lambert


3 of 3
6/10/2006 8:42 AM
A...912 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
351
349 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 131 of 348, 1997190405
TABITHA BUCK IS SEEKING FREEDOM IN SHOW

MURDER
Now, it's Tabitha Buck's turn.. Five years ago, she and Lisa Michelle
Lambert were sentenced to life in prison for murdering 16-year-old Laurie
Show. In April, a federal judge freed Lambert forever, saying Lancaster
County prosecutors fabricated evidence and lied to earn the conviction..
Now Buck is asking for her freedom, too.. Her reason? Prosecutorial
misconduct.. Buck claims county prosecutors tampered with or did not
disclose physical evidence and did
Article 132 of 348, 1997187345

MONDAY. June 30 - Armstrong World Industries and Worthington Industries
announced they will build a $9 million facility in Benton Harbor, Mich., to
build ceiling grids. The jobless rate for Lancaster County in May was
reported as 2.7 percent, the lowest in the state.. The Manheim Township
commissioners voted 3-1 for an intermunicipal agreement to allow the
building of Red Rose Commons, a large shopping center on the
Article 133 of 348, 1997187374
MYSTERY BOOK MAKES GOOD LISTENING AUDIO

REVIEW
"Alias Grace," by Margaret Atwood. Bantam Doubleday Dell Audio
Publishing, 360 minutes, $24.95.. I started listening to "Alias Grace" about
midway through the Lisa Michelle Lambert federal appeal hearing. And after
a while, the book gave me an eerie feeling - as if Margaret Atwood were
clairvoyant. In 1843, in a gentleman's home near Toronto, Canada, a
16-year-old Irish immigrant named Grace Marks is arrested for the murder
of her
1 of 3
6/10/2006 8:43 AM
A...913 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
352
350 of
of 456
454
June 14, 2016
Article 134 of 348, 1997184391

COUNTY APPEALS TO RAINVILLE

Contrary to rumors, the district attorney is not planning to hand over the
keys to Lancaster County Prison to Christina Rainville so she can release
whomever she feels is innocent - even though it might save taxpayers a
fortune in legal fees spent on appeals. If she wants to release any other
locally convicted prisoners, she'll have to work for it.. Rainville is the
Philadelphia attorney who successfully defended Lisa Michelle Lambert,
who had been convicted and imprisoned for
Article 135 of 348, 1997184335
LAMBERT TAKES AIM AT COUNTY

PHILADELPHIA _ Attorneys for Lisa Michelle Lambert continued to defend
their client's newfound innocence in a document filed in federal appeals
court Thursday.. In doing so, the lawyers hope to block Lancaster County's
ongoing attempt to have their client retried, or sent back to prison, for the
1991 murder of Laurie Show. This most recent motion was filed on
Lambert's behalf by Christina Rainville and her husband / partner, Peter
Greenberg, of the
Article 136 of 348, 1997184320
LAMBERT TO U.S. COURT: REJECT APPEAL

Lisa Michelle Lambert's freedom should not be revoked, her attorneys
maintain, because she has always been "absolutely truthful" in her account
of 16-year-old Laurie Show's murder.. That, combined with the "shocking
and unprecedented" misconduct of Lancaster County prosecutors, her
attorneys say, justified a federal judge's decision to free Lambert from a
sentence of life imprisonment. In addition,
Article 137 of 348, 1997183430
YOU HAD TO BE THERE TO CRITICIZE LAMBERT

HEARING
Editor, New Era:. There are people who have made opinions that Judge
Dalzell heard all the facts of the Laurie Show murder, then complied with
the law to warrant Lambert's release. Unless you sat in the courtroom during
Lambert's appeal hearing and noticed the judge's total disregard for our
entire case and the demeanor he had towards the prosecution and all
witnesses for the commonwealth, no one has the knowledge to make an
opinion about the way the case
2 of 3
6/10/2006 8:43 AM
A...914 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
353
351 of
of 456
454
June 14, 2016

Article 138 of 348, 1997181247
Published on June 30, 1997, I nt elligencer Journal ( Lancast er, PA)
LAMBERT BEAT INCREDIBLE ODDS TO WIN

FREEDOM
EDITOR'S NOTE: This is the second in a series of articles on the Lisa
Michelle Lambert case and its implications.. The series will use her
overturned murder conviction as a touchstone to show how state and
federal courts work. Today's article deals with the habeas corpus process
that led to Lambert's release and the uniqueness of her case. Other articles
will appear in the coming months.. Three strikes and you're out. On the
baseball field,
Article 139 of 348, 1997180361
Published on June 29, 1997, Sunday News ( Lancast er, PA)

SUNDAY. June 22 - It was learned that Chris Strader, 18, Annapolis, Md.,
was stricken and died Saturday, June 21, while bicycling in a race at Mount
Nebo. Cause of death was ruled a hemorrhage in the brain. Ralph M.
Barley, a retired attorney and civic leader, died at 85 on Saturday, June 21.
MONDAY. June 23 - Pressing its hostile effort to take over Domco Inc.,
Armstrong World Industries Inc. asked regulators in
Article 140 of 348, 1997178260
Published on June 27, 1997, Lancast er New Era ( PA)
SHOWS COLLECT 18,000 ANTI-JUDGE SIGNATURES

The count is at more than 18,000 and growing.. That's how many signatures
John and Hazel Show have collected on a petition seeking "corrective
action" against U.S. District Judge Stewart Dalzell, who freed Lisa Michelle
Lambert in April. Lambert had been convicted of the 1991 stabbing murder
of the Shows' 16-year-old daughter, Laurie, in East Lampeter Township.
Dalzell declared Lambert "actually innocent" and barred her


3 of 3
6/10/2006 8:43 AM
A...915 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
354
352 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 141 of 348, 1997175259
LAMBERT LAWYER TO HANDLE TEEN'S MURDER

APPEAL
The Philadelphia attorney who helped Lisa Michelle Lambert win her
freedom in April is handling the criminal appeal of another Lancaster County
person who was convicted of murder.. Lawyer Christina Rainville said
Monday she will enter her appearance Thursday in Pennsylvania Superior
Court to appeal the third-degree murder conviction of 19-year-old Nathan
Cassel of Lititz. Cassel, a Warwick High School dropout, was sentenced last
month in county court by Judge Louis J. Farina to 15 to 40
Article 142 of 348, 1997174250
RAINVILLE WILL HANDLE A 3RD LOCAL APPEAL

Lisa Michelle Lambert's attorney has taken on her third appeal of a
Lancaster County murder case.. Christina Rainville, who won freedom for
Lambert during a federal hearing in April, has been hired by one of the
families of three teens convicted of killing a 12-year-old Mary Street boy in
February 1996. Rainville, a Philadelphia attorney, is representing Nathan
Cassel of Lititz in his appeal of his third-degree murder conviction before
state Superior Court. She also is
Article 143 of 348, 1997173435
DETECTIVE NOVEL AUTHOR SOLVES A REAL-LIFE

MYSTERY
Not being who he once thought he was is no joke to Lancaster lawyer Neil
Albert.. After sleuthing worthy of his fictional character Dave Garrett, star of
his six detective thrillers, the novelist now knows several new things about
himself. Those things are tangled, inextricably, in the plot of his newest
Garrett novel, "Tangled in June." Raised Jewish, Albert now knows he's
probably not.. After 47 years of celebrating his birthday on May 12, he now
1 of 3
6/10/2006 8:45 AM
A...916 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
355
353 of
of 456
454
June 14, 2016
Article 144 of 348, 1997170309
ATTORNEYS: COUNTY OUT FOR REVENGE

Lisa Michelle Lambert's attorneys Wednesday accused Lancaster County of
seeking "revenge and retribution" when it asked a federal judge last week to
block their request for hundreds of thousands of dollars in legal fees..
Attorneys handling the county's appeal of a judge's decision to free Lambert
urged U.S. District Judge Stewart Dalzell to reject Lambert's lawyers'
request for $560,000. Because Lambert was
Article 145 of 348, 1997169569
SHOWS PLAN PUSH TO LIMIT POWER OF FEDERAL

JUDGES
Hazel and John Show will soon kick off a national campaign asking
Congress to pass legislation limiting the power of federal judges.. Mrs.
Show and her ex-husband are mounting the campaign in reaction to an
April decision by a federal judge in Philadelphia to free a woman who was
convicted in 1992 of killing their daughter, 16-year-old Laurie Show. "We
have to do everything possible to see that other criminals are not set free
because of one man's
Article 146 of 348, 1997167307
DEBATE RAGES ABOUT RAMIFICATIONS OF

LAMBERT DECISION
EDITOR'S NOTE: This is the first of a series of articles the Intelligencer
Journal will publish on the Lisa Michelle Lambert case and its implications..
The series will use the overturned murder verdict against Lambert as a
touchstone to show how the state and federal courts work.. More than just a
simple rehash of events and emotions, the series aims to use this historic
decision to educate Lancaster County citizens about the law, the courts and
the police and how they work
Article 147 of 348, 1997166386

SUNDAY. June 8 - Twenty-two students graduated from the Lancaster
County Academy at Park City Center. The school gives dropouts a second
chance to finish school. MONDAY June 9 - Armstrong World Industries
announced an unsolicited takeover bid for Domco Inc., a Quebec-based
flooring manufacturer that is in the process of being sold by its
French-based owner to a German floor manufacturer, Tarkett. Armstrong is
offering to
2 of 3
6/10/2006 8:45 AM
A...917 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
356
354 of
of 456
454
June 14, 2016

Article 148 of 348, 1997166390
'WE WERE FRAMED, SET US FREE'

They have been convicted of heinous crimes.. Their victims, according to
the court verdicts, are a mother, shot five times in the chest and abdomen.
Two tourists, struck and killed on Route 30. An elderly brother and sister,
left to starve to death on the living room floor of their home. But since Lisa
Michelle Lambert was set free, at least three convicted killers, and likely
more, have claimed that they, too, were the victims of a corrupt Lancaster
County judicial system.. On one hand,
Article 149 of 348, 1997165166
4,800 HOURS, 58 WITNESSES, A BIG BILL

Lisa Michelle Lambert's attorneys worked hard - that's apparent from the
4,800 hours they devoted to her case.. They were thorough - that's apparent
from the 58 witnesses they interviewed for Lambert's federal appeal hearing
in April. They were well-prepared - that's apparent from the thousands of
documents they copied, photographs they analyzed, legal points they cited
and experts they obtained.. But are those services worth
Article 150 of 348, 1997164290
COUNTY TRIES TO STOP LAMBERT'S LAWYERS

FROM COLLECTING FEES
Lawyers representing Lancaster County Thursday asked the federal judge
who freed Lisa Michelle Lambert to deny her attorneys' request for
$560,000 in legal fees. The county maintains Lambert's attorneys were
improperly appointed by the court.. The county's attorneys urged U.S.
District Judge Stewart Dalzell to allow the county to formally object in "the
interest of justice" to the bill for legal fees and expenses submitted by


3 of 3
6/10/2006 8:45 AM
A...918 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
357
355 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 151 of 348, 1997164232
RAINVILLE PICKED DESPITE NOT BEING ON COURT

LIST
Christina Rainville's name does not appear on a list of about 200 attorneys
approved to represent indigent clients in federal district court under the
Criminal Justice Act.. But District Judge Stewart Dalzell went outside the list
to appoint her and her Philadelphia law firm of Schnader Harrison Segal &
Lewis to represent Lisa Michelle Lambert in her recent federal hearing on
the 1991 murder of 16-year-old Laurie Show. He has that right, Lancaster
County's
Article 152 of 348, 1997160315
NEW TRIALS? UNCONSCIONABLE

To the Editor:. First Lisa Michelle Lambert and now Darrell E. McCracken!
(Attorney) Christina Rainville obviously has no conscience at all! These two
people were convicted of murder and Ms. Rainville feels the need to have
their convictions overturned, supposedly on technicalities. It seems to me
that Ms. Rainville could better serve her country by using her "name"
constructively. Maybe she could raise money for victims' rights or lead a
fight against
Article 153 of 348, 1997159342
LAPSES IN CASE AGAINST DRIVER? VEHICLES

INVOLVED IN MCCRACKEN CRASH THAT KILLED
FAMILY OF THREE WERE DESTROYED BEFORE
DEFENSE EXAMINED THEM.
It seems clear-cut.. Just after midnight on Sept. 3, 1995, Darrel McCracken
ran a red light in Lancaster, slammed into a car, and killed three people:
Franklin & Marshall College professor Geoffrey Pywell, his wife, Susan, and
their son, Nathaniel. In January, a jury found McCracken guilty of the worst
crime they could: third degree murder. They believed he ran a red light with
malice in his heart toward fellow human beings.. But the case may not be as
simple as it seems - at
1 of 3
6/10/2006 8:46 AM
A...919 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
358
356 of
of 456
454
June 14, 2016

Article 154 of 348, 1997159346

SUNDAY. June 1 - Larry Dean Mowrer, 36, Lititz, was arrested for strangling
and killing his former girlfriend, April Smith, 23, also of Lititz, with an
electrical cord in a Lititz garage. MONDAY June 2 - Racing to beat the
deadline, attorneys for Lancaster County filed a 70-page appeal to the 3rd
U.S. Circuit Court of Appeals to overrule the decision of Judge Stewart
Dalzell in freeing Lisa Michelle Lambert. The appeal
Article 155 of 348, 1997158217
COUNTY MAY CONTEST LAMBERT'S LEGAL FEES

Lancaster County officials on Friday said they are considering mounting a
challenge to legal costs Lisa Michelle Lambert's attorneys are trying to
recoup from the county.. Lambert's Philadelphia lawyers asked U.S. District
Judge Stewart Dalzell Thursday to permit them to be reimbursed up to
$560,000 in taxpayers money for representing Lambert through April 21, the
day Dalzell freed her from life in jail. In the alternative, the lawyers
requested reimbursement of at
Article 156 of 348, 1997158175
DOES 'PRO BONO' REALLY MEAN 'CHARGE

WHATEVER YOU LIKE'?
Our Latin teacher told us that "pro bono publico" meant "for the public
good.". Our dictionary says "pro bono" means "done or donated without
charge." So why are Lisa Michelle Lambert's lawyers asking the federal
court for legal fees ranging from $300,000 to $650,000 for a case they took
on a pro bon. o basis?. Not too many weeks ago, Lancastrians would have
been called cynics
Article 157 of 348, 1997157368
LAWYERS PUT LAMBERT BILL AT $650,000

Lisa Michelle Lambert's lawyers are asking for $650,000 in taxpayers
money to help offset their legal bill of $890,000 for representing Lisa
Michelle Lambert through April 21, the day she was freed.. Philadelphia
lawyers Christina Rainville and Peter S. Greenberg were appointed by
federal Judge Stewart Dalzell to represent Lambert. Their law firm took her
as a "pro bono" client, but the firm is entitled by law to recoup some of its
2 of 3
6/10/2006 8:46 AM
A...920 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
359
357 of
of 456
454
June 14, 2016
losses. The request was
Article 158 of 348, 1997157363
LAMBERT APPEAL GETS GREEN LIGHT FROM U.S.

COURT
Lancaster County learned Thursday that its appeal of a judge's decision to
free Lisa Michelle Lambert won't be dismissed before it is fully argued.. The
3rd U.S. Circuit of Appeals referred a motion by Lambert's attorneys to
dismiss the county's appeal to the "merits panel" of circuit judges, who won't
rule on it until after the appeal is litigated. Also, the court denied requests by
Lambert's
Article 159 of 348, 1997156396
LAMBERT'S LAWYERS RENEW ATTACK ON

COUNTY'S APPEAL
A phrase in the county's 70-page appeal of a federal judge's decision to free
Lisa Michelle Lambert has prompted her attorneys to again ask a U.S.
appeals court to dismiss the county's action.. Lambert's Philadelphia
attorneys told the 3rd U.S. Circuit of Appeals Tuesday that an admission in
the county's appeal "confirms beyond any possible argument" that it would
violate her constitutional protection against
Article 160 of 348, 1997156405
APPEALING APPEAL
At some point, we suspect, taxpayers will begin to squirm over the cost of
appealing U.S. District Judge Stewart Dalzell's decision to free Lisa Michelle
Lambert for the 1991 murder of Laurie Show.. For the moment, however,
the public appears to be largely behind the county's efforts to either jail or
retry Lambert - as well they should. The appeal, filed Monday in
Philadelphia, addresses major issues that were either ignored or overlooked
by Dalzell. It raises


3 of 3
6/10/2006 8:46 AM
A...921 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
360
358 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 161 of 348, 1997156331
LAMBERT'S LAWYERS' BILL MAY HIT $650,000

Lisa Michelle Lambert's attorneys are asking the federal court for legal fees
and costs ranging from $300,000 to $650,000 for their work leading to the
freeing of Lambert in April.. The court-appointed Philadelphia firm of
Schnader Harrison Segal & Lewis planned to file a motion for the funds
today. The firm took Lambert's federal appeal on a "pro bono" basis,
volunteering their time to the case, but the firm is entitled by law to
Article 162 of 348, 1997156342
SAVE DRUNK DRIVING CONVICTION

Editor, New Era:. First Lisa Michelle Lambert and now Darrell E.
McCracken! Defense attorney Christina Rainville obviously has no
conscience at all! These two people were convicted of murder and Ms.
Rainville feels the need to have their convictions overturned, supposedly on
technicalities. It seems to me that Ms. Rainville could better serve her
country by using her "name" constructively. Maybe she could raise money
for "victims'
Article 163 of 348, 1997155562
LAMBERT CASE COSTS MAY HIT $500,000

If the Lisa Michelle Lambert appeal goes all the way to the U.S. Supreme
Court, and officials believe it will, Lancaster County taxpayers could face up
to a half million dollars in legal fees, the chairman of the county
commissioners said Tuesday.. County Commissioner Terry L. Kauffman,
who chairs the county's governing triumvirate, said the county has already
received legal bills totaling over $100,000 for work done in preparing an
appeal to the 3rd Circuit Court of Appeals.
Article 164 of 348, 1997155533
1 of 3
6/10/2006 8:47 AM
A...922 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
361
359 of
of 456
454
June 14, 2016
COUNTY CLAIMS JUDGE ERRED IN FREEING

LAMBERT
(Editor's note: this is the full text of the main body of Lancaster County's
appeal to Judge Stewart Dalzell's decision in the Lisa Michelle Lambert
case. This text does not include footnotes that were part of the appeal brief.)
STATEMENT OF SUBJECT MATTER AND APPELLATE JURISDICTION.
On April 21, 1997, the United States District Court for the Eastern District of
Pennsylvania issued a final order granting a writ of habeas corpus to
Petitioner. Appeal was
Article 165 of 348, 1997155561
LOCAL ATTORNEYS EVALUATE APPEAL

Lancaster County's appeal of a court decision to free Lisa Michelle Lambert
zeroes in on two themes: A federal judge went too far by overturning her
murder conviction and blocking a retrial and Lambert's own testimony
makes her at least an accomplice to a killing.. Just before midnight Monday,
the county's attorneys, Alvin B. Lewis Jr. in Lancaster and Richard A.
Sprague in Philadelphia, filed the appeal with the 3rd U.S. Court of Appeals
in Philadelphia.
Article 166 of 348, 1997155419
ADDITIONAL TEXT FROM LAMBERT-CASE APPEAL

(Editor's note: This block of type was omitted in some editions of Tuesday's
New Era, through computer error, from the text of Lancaster County's
appeal of the Lisa Michelle Lambert decision. This type is the final section
of that appeal. The New Era apologizes for the omission.). A. The District
Court Erred In Addressing Lambert's Claims. In Wainright v. Sykes, 433
U.S. 72 (1972), the Court established the cause-and-prejudice test for
Article 167 of 348, 1997154300
COUNTY'S LAMBERT APPEAL TARGETS JUDGE

DALZELL
PHILADELPHIA - Lawyers representing Lancaster County late Monday
night appealed a federal judge's decision to free Lisa Michelle Lambert,
accusing the judge of making numerous errors during an April hearing in
which they claim he put county law enforcement officials on trial.. Barely
beating the court's midnight deadline, the county's lawyers urged the 3rd
U.S. Circuit Court of Appeals in Philadelphia to overrule Judge Stewart
Dalzell's
2 of 3
6/10/2006 8:47 AM
A...923 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
362
360 of
of 456
454
June 14, 2016
Article 168 of 348, 1997154252

HOLD ALL JUDGES ACCOUNTABLE

Editor, New Era:. I am writing in response to the outcome of the Lambert
case. In 1991 Lisa Michelle Lambert was convicted of the murder of Laurie
Show. The recent hearing of Lambert's appeal was presided over by the
"honorable" Judge Stewart Dalzell. The investigation in 1991 was shown to
be flawed by detective Ronald Savage who led a witness and tampered
with evidence in order to make the prosecution's case
Article 169 of 348, 1997154253
DECISION IN LAMBERT CASE MUST BE CLEAR AS

MCVEIGH'S
There was cause to worry about the jury's verdict in the Timothy McVeigh
trial. That so many Americans were concerned that McVeigh might
somehow avoid a guilty verdict speaks to the extent to which our justice
system has been threatened by misguided judgments, especially in the first
Simpson trial.. Clever lawyers and lenient judges have allowed some
defendants to get away with murder. Timothy McVeigh will never leave
prison following the jury's guilty verdicts on 11
Article 170 of 348, 1997154242
COUNTY STATES THE BASIS FOR AN APPEAL



3 of 3
6/10/2006 8:47 AM
A...924 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
363
361 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 171 of 348, 1997154249
COUNTY APPEAL CLAIMS JUDGE WAS HOSTILE AND

PREJUDICED
Citing a federal judge's offensive hostility and prejudice against Lancaster
County, attorneys have appealed to a higher court, arguing that the judge
freed a "properly convicted" murderer.. In a 70-page appeal filed minutes
before a midnight deadline Monday in Philadelphia, the county's lawyers
urged the 3rd U.S. Circuit Court of Appeals to overrule Judge Stewart
Dalzell's decision to free Lisa Michelle Lambert. The appeal refutes
Article 172 of 348, 1997153255
LAMBERT'S STORY IS EERIE MIRROR IMAGE OF

BUCK'S ACCOUNT
The stories were almost identical.. On the morning Laurie Show was
murdered - one young woman wildly attacked the 16-year-old girl, cutting
her hair, stabbing her repeatedly and slitting her throat. The assailant's
stunned accomplice stood by in shock, even as the victim reached out to
her, begging for help.. Lisa Michelle Lambert, now 24, said it was Tabitha
Buck who brutally attacked the Conestoga Valley High School sophomore..
Buck, now 23, said she didn't
Article 173 of 348, 1997153264
THE LAURIE SHOW MURDER: "...THAT'S NOT NOW IT

HAPPENED."
Editor's note: We've heard Lawrence Yunkin's side of the story - that he was
eating breakfast at McDonald's while Lisa Michelle Lambert and Tabitha
Buck killed Laurie Show. We've heard Lisa Lambert's side of the story - that
she tried to stop Tabitha Buck from killing Show. But the public has never
before heard a full account from the third person involved in the brutal
attack on the 16-year-old girl. In April, a select
1 of 3
6/10/2006 8:47 AM
A...925 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
364
362 of
of 456
454
June 14, 2016
Article 174 of 348, 1997153265
LAMBERT LIED 'OVER AND OVER,' APPEAL SAYS

A federal judge's order freeing Lisa Michelle Lambert "is akin to a
get-out-of-jail-free card in the game of Monopoly," according to Lancaster
County's appeal of the decision that will be filed today.. "But this is not a
game ... Laurie Show was the victim of a cruel torture murder and a person
convicted of her murder now walks free," the appeal states. The county is
appealing a federal judge's decision to
Article 175 of 348, 1997152412

SUNDAY. May 25 - People who had to cancel Memorial Day celebrations
didn't care much for it, but farmers were ecstatic about an all-day soaking
rain. The annual Smith Barney/Rotary International Cycling Festival did go
on in the downtown, with plenty of cyclists spilling on wet roads. MONDAY
May 26 - The sun did shine on Memorial Day as local communities honored
their war dead and others took to recreation
Article 176 of 348, 1997152518
THE PRETENDERS
Stand by your man, Tammy Wynette said.. She'd obviously never been to
East Lampeter Township. Even Ms. Wynette would have second thoughts
about sticking up for the East Lampeter police.. Township officials are
desperately following the song's advice, insisting that the string of
sensational allegations about their law enforcers - sexual misbehavior, rape,
corrupting a minor, perjury, tampering with evidence - is just, well, an image
problem.. What East Lampeter
Article 177 of 348, 1997151062
Published on May 31, 1997, I nt elligencer Journal ( Lancast er, PA)
LAMBERT ATTORNEY TO REPRESENT MCCRACKEN

IN MURDER APPEAL
freedom is representing another convicted murderer from Lancaster County:
Darrell E. McCracken.. Christina Rainville said Friday she and an associate
have been retained by McCracken's family to represent him on an appeal of
a third-degree murder conviction. McCracken was convicted in January of
killing Geoffrey Pywell, 42, his wife, Susan Davies-Pywell, 43, and their
11-year-old son, Nathaniel, when his pickup
2 of 3
6/10/2006 8:47 AM
A...926 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
365
363 of
of 456
454
June 14, 2016
Article 178 of 348, 1997150112

COUNTY FIGHTS FOR LAMBERT APPEAL

Attorneys for Lancaster County told a federal appeals court Thursday that
they have every right to appeal the release of Lisa Michelle Lambert. They
asked the court to deny a request by Lambert's attorneys to dismiss the
county's pending appeal, which is expected to be filed Monday.. Lambert's
attorneys launched a legal preemptive strike last week when they asked the
U.S. 3rd Circuit Court of Appeals to block the county's appeal of a federal
Article 179 of 348, 1997150100
COSTLY COUNSEL
The costs are beginning to mount.. Now the county has hired a second law
firm to handle fallout from the Lisa Michelle Lambert case. William Lamb, a
former Chester County district attorney and member of the West Chester
law firm of Lamb, Windle and McErlane, will represent Lancaster County
First Assistant District Attorney John A. Kenneff in a disciplinary
investigation being conducted by the state Supreme Court.. Documents
relating to Kenneff's prosecution of Lambert for the
Article 180 of 348, 1997149095
SUPREME COURT ARM OPENS KENNEFF PROBE

John A. Kenneff's handling of the criminal prosecution of Lisa Michelle
Lambert is now officially under investigation by an arm of the Pennsylvania
Supreme Court.. Kenneff, Lancaster County's first assistant district attorney,
said Wednesday that he has received an informal inquiry from the state
Supreme Court's Office of Disciplinary Council. The council requested
documents from Kenneff concerning the Lambert case, he said. "I intend to
fully


3 of 3
6/10/2006 8:47 AM
A...927 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
366
364 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 181 of 348, 1997149047
Published on May 29, 1997, Lancast er New Era ( PA)
SHOWS TO PRINT PETITION SEEKING OUSTER OF

JUDGE
The parents of murdered 16-year-old Laurie Show will seek public support
in their effort to oust a federal judge by publishing a petition in Lancaster
newspapers Friday.. Hazel and John Show want "corrective action" taken
against U.S. Judge Stewart Dalzell, who released Lisa Michelle Lambert
last month. Lambert, now 24, was convicted in Lancaster County Court of
first-degree murder in the case and sentenced to life in prison. Dalzell threw
out that conviction, saying
Article 182 of 348, 1997149051
JUDGE IS NOT A 'KING,' LAWYERS ARGUE IN

LAMBERT CASE APPEAL
Lancaster County has the right to ask a higher court to review a federal
judge's decision, its attorneys charged today, because the judge otherwise
"becomes a king.". Lancaster County's attorneys, in appealing last month's
decision by U.S. Judge Stewart Dalzell to release Lisa Michelle Lambert,
filed a motion before the U.S. 3rd Circuit Court of Appeals today citing legal
arguments as to why they deserve to be heard.
Article 183 of 348, 1997148041
COUNTY HIRES LAWYER TO AID KENNEFF ON

ETHICS CHARGES
First Assistant District Attorney John A. Kenneff now has a separate
attorney to represent him in the investigations spurred by the Lisa Michelle
Lambert case.. The county commissioners on Tuesday approved the hiring
of a West Chester law firm at $190 an hour to represent Kenneff, the lead
prosecutor in the case, before the state Disciplinary Board of the state
Supreme Court. Commissioners Chairman Terry Kauffman said today that
the county expects the firm of Lamb, Windle and McErlane will
1 of 3
6/10/2006 8:48 AM
A...928 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
367
365 of
of 456
454
June 14, 2016
Article 184 of 348, 1997146100

FAIR TRIAL A KEYSTONE OF OUR SYSTEM

To the Editor:. Let me get this straight: a Lancaster police officer in the
Rineer-Pasker case omitted from his report statements from one of the
defendants and also a witness, because he "didn't want to confuse the
issue." And District Attorney Joseph Madenspacher thinks this omission is a
"hyper-technicality"? I'm no cop, but even I know that police officers are
supposed to collect evidence, not begin doing the jobs of
Article 185 of 348, 1997145051
Published on May 25, 1997, Sunday News ( Lancast er, PA)

SUNDAY. May 18 - Six people - three men and three women - were
wounded after a shootout on South Duke Street following an argument and
fight at a dance. One was in critical condition. At the end of the week, police
were seeking David Lee Pilgrim, 23, who had been wounded, as the man
who fueled the fight. MONDAY May 19 - Michael R. Baksa, 42, was hired as
principal of Conestoga Valley High School, replacing Joseph E.
Article 186 of 348, 1997144083
COUNTY'S TAPE APPEAL IS REJECTED

A federal appeals court has ended the great debate over audio tapes of the
court hearing that freed Lisa Michelle Lambert from a life sentence for
murder.. The 3rd U.S. Circuit Court of Appeals Friday rejected a motion by
lawyers for Lancaster County to preserve tape recordings of the Lambert
hearing. The county claims the tapes would show a federal judge was
biased when he ruled Lambert should be freed. But in a one-page order, the
circuit court said the county "has made no
Article 187 of 348, 1997143113
LAMBERT SEEKING TO KO APPEAL BY COUNTY

Lisa Michelle Lambert's attorneys Thursday asked a federal appeals court to
reject a appeal by Lancaster County that, if approved, would reinstate her
murder conviction and send her back to jail.. The action took the form of a
sort of legal preemptive strike since the Lancaster County District Attorney's
office hasn't yet filed its formal appeal papers in the matter. Lawyers for the
county have told the U.S. 3rd Circut Court of Appeals court that they plan
2 of 3
6/10/2006 8:48 AM
A...929 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
368
366 of
of 456
454
June 14, 2016
Article 188 of 348, 1997143065

PETITION DRIVE, MAILING NEXT FOR THE SHOWS

Laurie Show's parents are wielding a pen to battle the freeing of the woman
they say killed their 16-year-old daughter.. Hazel and John Show are
handing out petitions and preparing a national mailing to elected officials,
including the president. Both the petitions and the mailing criticize the
recent ruling by U.S. District Judge Stewart Dalzell, who last month released
Lisa Michelle Lambert, 24, from her life sentence for the 1991 killing in East
Lampeter Township.. Both
Article 189 of 348, 1997142106
ATTORNEYS WANT COURT TO RESOLVE TAPE FLAP

Lawyers representing the Lancaster County District Attorney's office asked
a federal appeals court Wednesday to help them determine if audio tapes of
the hearing that led to Lisa Michelle Lambert's freedom still exist.. The
attorneys - Alvin B. Lewis Jr. of Lancaster and Richard A. Sprague of
Philadelphia - filed an emergency request with the 3rd U.S. Circuit Court of
Appeals in Philadelphia. They asked the court to order that any existing
tapes of
Article 190 of 348, 1997141194
COUNTY'S ATTORNEYS OUTLINE APPEAL OF

LAMBERT RULING
Attorneys representing the Lancaster County District Attorney's Office
outlined their appeal of a federal judge's decision to free Lisa Michelle
Lambert in court papers filed Tuesday.. The county's lawyers, Alvin B. Lewis
Jr. of Lancaster and Richard A. Sprague of Philadelphia, said the appeal
will emphasize evidence already on record that they say shows Lambert is
guilty of first-degree murder in the stabbing death of Laurie Show. The court
papers were


3 of 3
6/10/2006 8:48 AM
A...930 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
369
367 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 191 of 348, 1997141026
TECHNICAL POINTS FORM BASIS OF LAMBERT

APPEAL
Most of the issues raised by Lancaster attorneys in their appeal of Lisa
Michelle Lambert's release are legal technicalities.. But one key issue
stands out among the rest: Local attorneys maintain that Lambert is guilty of
first-degree murder in the stabbing death of 16-year-old Laurie Show in
December 1991.. The county's lawyers, Alvin B. Lewis Jr. of Lancaster and
Richard A. Sprague of Philadelphia, filed the statement of issues on
Tuesday with the 3rd U.S.
Article 192 of 348, 1997140098
LAMBERT JUDGE WANTS DECISION ON TAPES

REQUEST
The legal debate over audio tapes of Lisa Michelle Lambert's federal
appeals hearing in Philadelphia continued Monday.. U.S. District Judge
Stewart Dalzell, who overturned Lambert's first-degree murder conviction for
the 1991 stabbing death of Laurie Show, ordered lawyers representing the
Lancaster County District Attorney's Office to decide by May 27 whether
they will withdraw a motion seeking preservation of the tapes. Also, Dalzell
gave the
Article 193 of 348, 1997140034
COUNTY LAWYERS LIST 5 ISSUES FOR APPEAL OF

LAMBERT RULING
Lancaster County's lawyers have outlined the key issues on which they
intend to appeal the release of Lisa Michelle Lambert, who had been
convicted of murder.. The lawyers plan to present evidence that they say
proves Lambert is guilty of first-degree murder in the stabbing death of
16-year-old Laurie Show, not "actually innocent" of the crime as a federal
judge decreed last month, attorney Alvin B. Lewis Jr. said this morning.
Lewis listed five
1 of 3
6/10/2006 8:48 AM
A...931 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
370
368 of
of 456
454
June 14, 2016
Article 194 of 348, 1997139035

VOTE IN THE PRIMARY

Because of Lancaster County's lopsided Republican registration - there are
2 1/2 GOP registrants for every Democrat - primaries are critical for
Republicans in so-called "off-year" or "local" elections.. Most of the
Republicans who win Tuesday's primary will go on to win November's
election against outnumbered Democrats. In some cases, the Democratic
Party will not be running anyone in November, so this
Article 195 of 348, 1997139050
CLOSE RACES EXPECTED FOR MAYOR, JUDGE

To supporters of Leslie Gorbey, the race for county judge is about electing
the best-qualified of two politically similar candidates.. Backers of Melinda
Fisher Nowak say the race is a philosophical battle to elect the most
conservative of two equally qualified attorneys. To an academic analyst, it is
this year's version of a much-broader political struggle between Republican
conservatives and moderates.. "This election is this year's manifestation of
Article 196 of 348, 1997138068
EAST LAMPETER BLUES

Last week, East Lampeter Township police officer Robert Reed was
arrested and charged with sexually assaulting a 13-year-old girl under his
care.. But according to public records, this may not have been the first time
Reed has had sex with young girls or women through his job. And senior
members of the East Lampeter Police Department knew that Reed had a
history of questionable sexual conduct. According to testimony from Ronald
Savage, a former East Lampeter police sergeant, Reed was accused
Article 197 of 348, 1997138063

SUNDAY. May 11 - Troy David Ludwig, 29, Denver, died in Reading after he
was shot in the face the day before in what police said was an attempted
drug deal. Keith Allen Tyler, 30, of Reading was charged with homicide.
More than $100,000 was raised during Make-A-Wish Foundation's annual
truck convoy day. MONDAY. May 12 - Manheim Township commissioners
approved the building of an $18 million, 2,600-seat
2 of 3
6/10/2006 8:48 AM
A...932 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
371
369 of
of 456
454
June 14, 2016
Article 198 of 348, 1997137073

LAMBERT ATTORNEYS ON ATTACK

Lisa Michelle Lambert's attorneys said Friday that even if the judge who
freed their client from her murder sentence was rude to Lancaster County
prosecutors, that's not enough to reverse his decision.. Lambert's lawyers
Friday filed a response to a request by the county district attorney to turn
over audio tapes of a federal hearing in April that resulted in Lambert being
freed of a first-degree murder sentence. In their response, one of
Article 199 of 348, 1997136093
ANOTHER CASE THROWN OUT IN COUNTY COURT

The case against a city man charged after a brawl with two sheriff's
deputies was thrown out of court Thursday.. Lancaster County Judge
Lawrence F. Stengel dismissed two simple assault charges against Gary
William Dimitris, 37, of the 700 block of Columbia Avenue. Stengel cited
Pennsylvania's Rule 1100, which guarantees a speedy trial for anyone
accused of a crime. City police said Dimitris entered county offices at 40 E.
King St. on May 8, 1995, and fought with two
Article 200 of 348, 1997136094
POLICE OFFICER CHARGED WITH SEX ASSAULT

Criminal agents with the state attorney general's office Thursday arrested an
East Lampeter Township policeman for sexually assaulting a juvenile over a
four-year period.. Officer Robert Stanley Reed, 37, who is also under
investigation by the U.S. Attorney in Philadelphia for allegedly perjuring
himself last month at the Lisa Michelle Lambert federal court hearing, was
charged with allegedly sexually assaulting a young girl under his care at his
314 Greenland Drive home in East


3 of 3
6/10/2006 8:48 AM
A...933 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
372
370 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 201 of 348, 1997136042
EAST LAMPETER COP CHARGED WITH YOUNG GIRL'S

SEXUAL ASSAULT
An East Lampeter Township Police officer was charged Thursday with
sexually assaulting a young girl in his care from 1992 to 1996.. The state
Attorney General's office Thursday brought the charges against Robert
Stanley Reed, 37, of 314 Greenland Drive. His victim was between the ages
of 8 and 12 at the time of the assault, which allegedly included oral sex,
sexual intercourse and fondling.. Reed specifically was charged with one
count each of statutory rape, involuntary
Article 202 of 348, 1997134188
LAMBERT CASE CITED IN MISTRIAL HERE

The same mistake cited by a federal judge in his decision to free Lisa
Michelle Lambert last month has helped clear two Lancaster men of
criminal charges in Lancaster County Court.. County Judge Paul K. Allison
Tuesday declared a mistrial in the case of Larry Rineer and Charles Pasker,
saying prosecutors failed to turn over to their defense lawyers evidence in
the men's favor. Allison threw out aggravated assault, burglary and criminal
conspiracy charges against the men, who were
Article 203 of 348, 1997134002
POLICE CHIEF FEARS 'TREND' AFTER NEW MISTRIAL

DECLARED
Will the Lambert case haunt local police officers for years to come?. That
was the concern among police today after a county judge threw out a
burglary case and declared a mistrial Tuesday, saying prosecutors and city
police failed to turn over evidence to defense attorneys that favored the
defendants. In making the decision, Lancaster County Judge Paul K. Allison
referred to a federal judge's recent decision to free Lisa Michelle Lambert,
who had been convicted in the 1991
1 of 3
6/10/2006 8:50 AM
A...934 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
373
371 of
of 456
454
June 14, 2016
Article 204 of 348, 1997131071


SUNDAY. May 4 - According to a state report, Lancaster County public
schools had 1,302 incidents of violence in 1995-96, including three involving
firearms. MONDAY May 5 - Nathan Cassel, Eric Griffith and Luis Alicea,
three teens convicted in the shooting death of a 12-year-old boy, were each
sentenced to 15-40 years in prison. Alicea fired the shot.. W. Michael
Strube, 47, of West Hempfield Township, was indicted on
Article 205 of 348, 1997130088
LAMBERT WILL REMAIN FREE DURING APPEAL

A federal appeals court Friday denied a motion by the Lancaster County
district attorney to either send Lisa Michelle Lambert back to jail or place
her on bail while a judge's decision to free her is appealed.. The three
judges that make up the Third Circuit Court of Appeals said returning
Lambert to jail was not proper since "the commonwealth has not
demonstrated that it is likely to prevail on the merits of its appeal." Lambert,
24, had been serving a
Article 206 of 348, 1997127067
LAMBERT'S LAWYER QUESTIONS COUNTY'S HIRING

OF LAW FIRM
Lawyers for Lisa Michelle Lambert may ask an appellate court to disqualify
a Lancaster law firm hired by Lancaster County to help with the appeal of a
federal judge's decision to release Lambert from life in prison.. Christina
Rainville, one of Lambert's attorneys, said Tuesday she believes it's
improper under Pennsylvania law for the firm of Sprague and Lewis to help
the county district attorney's office with its appeal. The county should only
Article 207 of 348, 1997127028
LAMBERT LAWYERS OBJECT TO COUNTY HIRING

OUTSIDE ATTORNEYS
Lisa Michelle Lambert's attorneys are objecting to the county hiring outside
attorneys to help with the appeal of a federal judge's decision to release
Lambert from prison.. Christina Rainville said that she may ask an appelate
court to disqualify the attorneys. The county should only be able to ask the
state attorney general's office for help, she said. The attorney general's
office has also been enlisted by the county to help with the Lambert
2 of 3
6/10/2006 8:50 AM
A...935 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
374
372 of
of 456
454
June 14, 2016

Article 208 of 348, 1997126040
LAW FIRM BEGINS WORK ON APPEAL OF LAMBERT

CASE
Lisa Michelle Lambert "was and is guilty of murder," one of the new
attorneys handling the county's appeal of her release said today.. "I expect
to argue that forcefully," said Alvin B. Lewis Jr., who was hired Monday by
Lancaster County to handle the appeal of the Lambert case in federal court.
"The woman is guilty of murder and she's been convicted, and her
conviction has been sustained by all of the state
Article 209 of 348, 1997124087
WE DESERVE ACCOUNTABILITY
Now that the shock of the Lisa Michelle Lambert ruling has begun to wear
off, it's time to take a hard look at the charges leveled against Lancaster
County law enforcement by federal Judge Stewart Dalzell.. While some of
those hard looks will likely come from the U.S. attorney's office and the
state Judicial Conduct Board - Judge Dalzell has referred allegations of
prosecutorial wrongdoing to those agencies - that doesn't absolve county
and East Lampeter
Article 210 of 348, 1997124075
FOR LAMBERT INVESTIGATORS, THE HEAT IS ON

Two weeks ago, a federal judge found what he believed was evidence that
eight Lancaster County law enforcement officers are criminals.. Last week,
the U.S. Attorney in Philadelphia, in a tersely worded statement, said he will
begin a "preliminary investigation." Behind the legal words issued from the
22-story black glass federal courthouse in Philadelphia are these realities:.
This is the first time since 1978 the U.S. Attorney in Philadelphia has seen
fit to


3 of 3
6/10/2006 8:50 AM
A...936 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
375
373 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 211 of 348, 1997124086
WHAT'S NEXT FOR DALZELL - MANSON?

Well, now that U.S. District Judge Stewart Dalzell has decided to release
Lisa Michelle Lambert from jail, why stop at this case? Let's have him look
at the Charlie Manson trial for the murders of Sharon Tate and the other
victims. I recall it was proven that Old Charlie Boy was not even at the
murder scene but merely organized and recruited the killers.. Whatever
happened that day at Laurie Show's home resulted in her violent death. I
guess "accessory to
Article 212 of 348, 1997124062
SUNDAY. April 27 - Harry J. Shaub Jr., former president and general
manager of WGAL-TV, died unexpectedly. He held numerous community
leadership posts. MONDAY April 28 - Lancaster and city police officers
agreed on a new contract that would provide raises of 3, 2 1/2 and 3
percent for police over the next three years. Mayor Janice Stork said she
was pleased with the contract, which will allow the city to continue on its
Article 213 of 348, 1997122096
U.S. WILL PROBE LAMBERT CASE

The U.S. Attorney's Office in Philadelphia has launched a criminal
investigation into the actions of the Lancaster County law enforcement
officials who prosecuted Lisa Michelle Lambert.. Lancaster County officials
said they welcome the investigation and promised to cooperate fully. The
probe comes at the request of U.S. District Judge Stewart Dalzell, who last
week freed Lambert, 24, and overturned her conviction for the murder of
16-year-old Laurie Show. Dalzell also barred
Article 214 of 348, 1997122088
THE PROBE OPENS
1 of 3
6/10/2006 8:50 AM
A...937 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
376
374 of
of 456
454
June 14, 2016
The decision by the U.S. Attorney in Philadelphia to open a formal

investigation into the conduct of Lancaster County police and prosecutors
involved in the murder trial of Lisa Michelle Lambert is both expected and
welcome.. It's expected because U.S. District Judge Stewart Dalzell, in
freeing Lambert last month, leveled grave charges of perjury and
obstruction of justice against authorities here. It would have been difficult for
the U.S. Attorney to ignore Dalzell's
Article 215 of 348, 1997122033
MORE ATTORNEYS SOUGHT TO AID PROSECUTORS

HERE
Local prosecutors are preparing to bring in outside attorneys to help them
with their appeal of a judge's decision to free convicted murderer Lisa
Michelle Lambert.. In recent court documents, prosecutors indicated they
needed more time in meeting an upcoming filing deadline because they are
bringing in new attorneys to help with the appeal to the 3rd U.S. Circuit
Court of Appeals. District Attorney Joseph Madenspacher, who has been
handling the appeal, was out of town and could
Article 216 of 348, 1997122037
POLICE AND PROSECUTORS UNDERMINED LAMBERT

CASE
Editor, New Era:. I am writing in response to the many letters written
condemning the decision in the Lisa Michelle Lambert case. I do not claim
to know whether or not she is guilty, I was not there. What I do know is that
there have been some serious allogations made against the officers
involved in the investigation and the prosecutors in the original trial. I
beleive many of these charges have been proven, such as withholding
evidence and tampering with evidence submitted.. The letters
Article 217 of 348, 1997121130
JUDGES GATHER, BUT TALK AVOIDS DALZELL'S

RULING
The Lancaster Bar Association couldn't have picked a better time for a
public forum on the role of judges - the week after a federal judge jolted the
community by freeing convicted murderer Lisa Michelle Lambert.. The bar
association and Pennsylvania Conference of State Trial Judges assembled
six state and federal court judges Wednesday to explain the independence
and accountability of judges. Although the audience, mostly lawyers, came
hoping to hear the judges'
2 of 3
6/10/2006 8:50 AM
A...938 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
377
375 of
of 456
454
June 14, 2016
Article 218 of 348, 1997121124

WHERE IS JUSTICE?
To the Editor:. What is happening to justice in the U.S.A.? I was amazed
that Lisa Michelle Lambert was declared innocent of the murder by a
federal judge and released from prison.. Three people - Lambert, (Tabitha)
Buck and (Lawrence) Yunkin, first lured the mother away from the building,
then illegally entered the home of Laurie Show. Then they go into her home
carrying a deadly weapon. When they leave the room, Show is dead. They
they accuse each other of who did the murder.. It is
Article 219 of 348, 1997121067
PROBERS BROADEN PRELIMINARY LOOK AT

LAMBERT CASE
The U.S. Attorney's office announced today that it is broadening its
"preliminary investigation" into the actions of Lancaster County prosecutors
in the Lisa Michelle Lambert case.. "We are conducting a preliminary
investigation," U.S. Attorney Michael Stiles said this morning, based on U.S.
Judge Stewart Dalzell's recommendation when he released Lambert last
week. Previously, the U.S. Attorney's office
Article 220 of 348, 1997121068
PRICE TAG IN LAMBERT CASE: $34,500 AND STILL

GROWING
It cost the federal government at least $34,500 to hold the 15-day hearing
that led to the freedom of Lisa Michelle Lambert on April 21.. That
preliminary figure was announced today by Michael E. Kunz, clerk of court
for the U.S. District Court in Philadelphia, where the hearing was held
beginning March 31 before Judge Stewart Dalzell. But the costs could go
much higher after fees for Lambert's attorneys and expert witnesses are
added in. Those bills are still pending.. The


3 of 3
6/10/2006 8:50 AM
A...939 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
378
376 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 221 of 348, 1991203086
Published on April 30, 1997, Lancast er New Era ( PA)
DESPITE CHARGES, POLICE, PROSECUTORS STILL ON

JOB
Local police and prosecutors have resumed their normal routines, the week
after a convicted murderer was freed by a federal judge.. "We are not doing
anything differently," said East Lampeter Township Police Chief Dale
Jerchau. U.S. District Judge Stewart Dalzell released Lisa Michelle
Lambert, 24, from prison for the 1991 killing of 16-year-old Laurie Show in
East Lampeter Township. Dalzell said prosecutors lied about, concealed or
tampered with evidence in
Article 222 of 348, 1991181818
Published on April 28, 1997, I nt elligencer Journal ( Lancast er, PA)
OUR SICK SYSTEM

To the Editor:. How are we to fight crime when criminals are set free? When
are victims going to be given their constitutional rights?. Judge's rules are
overturned. In O. J. Simpson's trial the L.A. Police Department was put on
trial. In Lancaster, Pa., the police and district justice will suffer the same fate
as the L.A.P.D.. O. J. walks, Lisa Michelle Lambert walks and three people
are dead. What is happening to our judicial system? Ann Rimko New
Holland
Article 223 of 348, 1991181763
THE FACTS AND THE LAW LED THE JUDGE TO HIS

DECISION
Editor, New Era:. I commend your newspaper for printing the full text of
Judge Stewart Dalzell's Opinion in the case of Lisa Michelle Lambert. For all
who recognize how fragile is the grasp of the right to freedom anywhere in
the world, and even here, his opinion is not merely an explanation of why
one woman must be freed, but it is a call, particularly to the people of
Lancaster County, to examine the assumptions upon which their rights truly
rest. And more than that, it is a
1 of 3
6/10/2006 8:51 AM
A...940 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
379
377 of
of 456
454
June 14, 2016
Article 224 of 348, 1991173058

Published on April 27, 1997, Sunday News ( Lancast er, PA)
CAN LISA MICHELLE CARRY THE WEIGHT OF

BLOOD?
Editor's note: "In My Opinion" is a column of guest commentaries by Sunday
News readers on topical subjects. Send submissions to Helen Colwell
Adams, Sunday News, P.O. Box 1328, Lancaster, Pa. 17608-1328.
Commentaries will be published at the discretion of the editors.. The justice
system has failed. It has failed horribly, drowning in a sea of red-ink
technicalities and dying with the final slash of a federal judge's pen. Justice
has
Article 225 of 348, 1991173042
COURTING EXPERTS TO MAKE A CASE

The chance to help free a wrongly convicted woman came unexpectedly to
Dr. Charles Larson.. Larson had never given expert testimony in court. He'd
never heard of Lisa Michelle Lambert until he was contacted by her
attorney, Christina Rainville. But his expert testimony lent weight to Judge
Stewart Dalzell's decision last week to release Lambert from prison, where
she was serving a life sentence for the murder of Laurie Show.. Larson got
involved in the case by
Article 226 of 348, 1991173043
CORRECTIONS
The Sunday News, in a synopsis last Sunday of the Lisa Michelle Lambert
appeal, incorrectly reported that East Lampeter Township police officer
Robert Reed was one of the men identified as a rapist by Lambert.. If you
have a correction or clarification, call the responsible section editor, or
phone the news desk, 291-8788.
Article 227 of 348, 1991173046

MONDAY. April 21 - Lisa Michelle Lambert, convicted in 1992 of the murder
of 16-year-old Laurie Show and sentenced to life in prison, was freed by a
federal judge who said the trial "was corrupted from start to finish" and that
Lancaster County officials had engaged in "such gross prosecutorial
misconduct" that she cannot be retried. The judge also recommended that
members
2 of 3
6/10/2006 8:51 AM
A...941 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
380
378 of
of 456
454
June 14, 2016
Article 228 of 348, 1991173032

ATTORNEY TO TALK ON LAMBERT CASE

On Tuesday, April 29, Scott Oberholtzer, a local attorney, will speak to the
Lancaster Kiwanis Club about "The Trial of Lisa Michelle Lambert - What
Happened" at the club's weekly luncheon meeting at noon at Andy's
Catering, 1106 Millersville Pike.
Article 229 of 348, 1991173057
BLIND JUSTICE
"In the end, Laurie Show's murder ... wasn't just a story about a jealous
lover seeking revenge.. "It was about a town making a snap judgment
against the accused, Lisa Michelle Lambert, a woman whose friends even
considered "trailer trash.' About a police department going to great lengths
to pin the crime on her. About a prosecutor who, a judge said, bent the law
to win a first-degree murder conviction rather than
Article 230 of 348, 1991173044
JUDGE'S REBUKE STINGS COUNTY

It was a week of shattered beliefs.. Before Lisa Michelle Lambert's hearing
in federal court began, everything was neat and tidy. She was guilty of
murdering Laurie Show, and was sent to jail. Police and prosecutors were
heroes. Justice had been served. U.S. District Court Judge Stewart Dalzell
changed all that.. In a decision that shook Lancaster County to its roots,
Dalzell last Monday set Lambert free, declaring her innocent. But that was
hardly all.. In his 90-page


3 of 3
6/10/2006 8:51 AM
A...942 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
381
379 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 231 of 348, 1991161659
READERS OPPOSE DALZELL RULING

Intelligencer Journal staff report. Most Intell readers responding to this
week's People Poll disagreed with a federal judge's decision to free Lisa
Michelle Lambert. Yet a slimmer majority of readers think an investigation of
the prosecutors and police involved in the case is warranted. U.S. District
Judge Stewart Dalzell decided Monday to free Lambert and bar a retrial.
She had been serving life in prison for the 1991 murder of teen-ager Laurie
Show in her East
Article 232 of 348, 1991161612
EAST LAMPETER TOWNSHIP OFFICIALS SHOULD

INVESTIGATE
Editor, New Era:. I find it appalling that Lisa Michelle Lambert has been
released from prison. At the very minimum, there should be a retrial. It is
also obvious to me, however, that East Lampeter Township is more
interested in protecting its own than in protecting the community from the
unprofessional conduct of the police department. One of the police officers
has been suspended for the second time, for alleged sexual misconduct.
Why was he reinstated after the first incident? Is this the
Article 233 of 348, 1991151862
IN SHOW CASE, THE TRUTH KEEPS SLIPPING AWAY

I don't know if Lisa Michelle Lambert killed Laurie Show. What I do know,
from years of court reporting, is that getting at the truth is slippery business..
If the Rodney King case proved anything, it's that even a videotape offers
only a version of the truth. When U.S. District Judge Stewart Dalzell Monday
freed Lambert from a life sentence, he issued a 90-page explanation, an
"official" version of the truth.. According to this
Article 234 of 348, 1991151881
1 of 3
6/10/2006 8:52 AM
A...943 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
382
380 of
of 456
454
June 14, 2016
LAMBERT DECISION STILL ECHOES

Intelligencer Journal columnist Jeff Hawkes - who covered the murder trial
of Lisa Michelle Lambert five years ago - talks with the victim's mother,
Hazel Show, about the controversial case and a federal judge's decision to
free Lambert.. Mrs. Show tells Hawkes that Judge Stewart Dalzell
misunderstood her when she told him she now remembered seeing a car
leaving her condominium complex on the morning her daughter was killed.
And she fears the judge gave great weight
Article 235 of 348, 1991151820
PROSECUTORS HERE WON'T DISCUSS CASE

Lancaster County's top prosecutors in the Laurie Show murder case have
declined to be interviewed this week about their reaction to a federal judge's
decision to release Lisa Michelle Lambert.. District Attorney Joseph
Madenspacher has filed a notice of his intention to appeal U.S. Judge
Stewart Dalzell's decision with the 3rd Circuit Court of Appeals and said it
would be inappropriate to comment while the case is still pending. First
Assistant District
Article 236 of 348, 1991151822
DALZELL CALLED OUTSPOKEN AND DEMANDING

It was not the sort of exchange you'd hear in every courtroom.. U.S. District
Judge Stewart Dalzell was berating one of the county's top prosecutors,
John Kenneff, with a flurry of sarcasm. "The U.S. Constitution. The
Fourteenth Amendment. Due process of law. Ever hear of it, Mr. Kenneff?
That's what we're talking about here. Got it? Understand?" roared Dalzell.. It
was just one of numerous acidic salvos fired by
Article 237 of 348, 1991151819
'HE'S VERY MUCH A LAW-AND-ORDER PERSON'

Here's something that Lancaster Countians might find hard to swallow:. U.S.
District Judge Stewart Dalzell is known as a law-and-order guy. That's the
view of two Philadelphia attorneys who have practiced law in his courtroom
on numerous occasions.. Dalzell sparked outrage here by freeing convicted
murderer Lisa Michelle Lambert on Monday, declaring her innocent and
saying prosecutors denied her a fair trial.. "For him to have that kind of
reaction
Article 238 of 348, 1991151829
2 of 3
6/10/2006 8:52 AM
A...944 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
383
381 of
of 456
454
June 14, 2016
JUDGE DALZELL AND THE ATTORNEYS DID THEIR

JOB
Article 239 of 348, 1991151823
A NIGHTMARE: SIMPSON, RAMSEY, NOW LAMBERT

Editor, New Era:. I can't believe an accomplice to murder, Lisa Michelle
Lambert, was set free. She admitted being at the murder scene the day
Laurie Show was murdered! Oh, that's right, she tried to save Laurie's life,
that's how she got blood all over her. That's why she was there! She should
have stayed in prison to await a new trial, not be cut loose.. Why doesn't
Judge Dalzell let the woman-beater, Lawrence
Article 240 of 348, 1991151828
THE LESSON FOR CHILDREN IS: GET A GOOD

LAWYER
Editor, New Era:. I just received the news of Lisa Michelle Lambert's release
for the killing of Miss Show in '91. I am outraged that our justice system no
longer works for the victim but for the criminal. Since the O.J. trial, everyone
has gotton on the bandwagon and hired expensive lawyers to tear down the
evidence and make a mockery of our justice system. I am so fed up and
tired of the victim's loss of rights and the supposed rights of the criminals,


3 of 3
6/10/2006 8:52 AM
A...945 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
384
382 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 241 of 348, 1991142203
DO YOU AGREE WITH LAMBERT RULING?

U.S. Judge Stewart Dalzell freed Lisa Michelle Lambert for the murder of
Laurie Show and barred a retrial on the grounds that the prosecution
manipulated evidence and used perjured testimony to convict her.
Lancaster County District Attorney Joseph C. Madenspacher contends there
was no criminal wrongdoing on the part of the prosecution and has filed an
appeal to have the judge's ruling overturned.!6+. Do you agree or disagree
with Judge Dalzell's decision to free Lisa
Article 242 of 348, 1991142208
SHOWS CAN'T SUE LAMBERT OVER DEATH

Time has run out for the family of murder victim Laurie Show to bring a civil
lawsuit against Lisa Michelle Lambert, who was cleared of the killing by a
federal judge.. U.S. District Judge Stewart Dalzell freed Lambert Monday
from a life sentence, ruling that prosecutors framed her to get a conviction
during a non-jury trial in 1992. William Atlee, a veteran civil litigator in
Lancaster, said the two-year time limit has expired for the Shows to sue
Lambert for the wrongful death of their
Article 243 of 348, 1991142138
CORRECTIONS
Air Force Airman Michael D. Rosiere, son of Janice Rosiere, Old
Philadelphia Pike, recently graduated from basic training at Lackland Air
Force Base, San Antonio, Texas.. He is a 1996 graduate of Solanco High
School. Another serviceman's name was placed under his picture in
Tuesday's editions. The New Era regrets the error.. The New Era incorrectly
reported that East Lampeter Township Police Officer Robert Reed was one
of the men identified as a rapist by Lisa
Article 244 of 348, 1991133093
1 of 3
6/10/2006 8:53 AM
A...946 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
385
383 of
of 456
454
June 14, 2016
PROBES ARE IN ORDER

Although we disagree with U.S. District Court Judge Stewart Dalzell's
decision to free Lisa Michelle Lambert and bar her retrial for murder, a
reading of the judge's 90-page opinion should leave any Lancaster Countian
with questions about the activities of the district attorney's office and some
local police.. At this point these are just questions. As Dalzell said last week
- after he accused Ronald Savage, a current district justice and former East
Article 245 of 348, 1991133100
HAZEL SHOW WANTS FEDERAL JUDGE OFF BENCH

Hazel Show said Tuesday night she is mounting a public crusade to oust a
federal judge who freed a woman convicted in 1992 of murdering her
16-year-old daughter.. "We have to get this judge (U.S. District Judge
Stewart Dalzell) off the bench," Show said Tuesday night during a
telephone interview from her East Lampeter Township home. "There is not
one bit of justice in him." In another development, the office of the U.S.
Attorney said it will
Article 246 of 348, 1991132959
SHOWS PUSH TO OUST JUDGE FROM BENCH

Laurie Show's parents are turning their anger into action this week, trying to
remedy a judge's release of their daughter's convicted killer.. "I can't let this
die," Show's father, John, said today. "We have to keep it alive until
something happens. I don't want this to happen to anyone else down the
road." Among the actions being taken by Show and his ex-wife, Hazel, are
Article 247 of 348, 1991132951
JUDGE DALZELL'S ALLEGATIONS MUST BE

PUBLICLY ANSWERED
Federal Judge Stewart Dalzell has verbally whipped Lancaster County and
its justice system beyond the point of embarrassment. In unrestrained,
melodramatic pronouncements, he has portrayed the people of Lancaster
County as partners in a rush to judgment led by scheming, lying law
enforcers.. He points to the "solidarity and compassion" this community
showed to John and Hazel Show when their daughter Laurie was brutally
murdered. "But then what was a social
Article 248 of 348, 1991132949
2 of 3
6/10/2006 8:53 AM
A...947 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
386
384 of
of 456
454
June 14, 2016
LISA LAMBERT IS FREE BECAUSE OF U.S.

CONSTITUTION
Editor, New Era:. I'm writing about the Lisa Michelle Lambert case. After
comparing the reactions of lawyers with those of regular "folks," I came to
the conclusion that Lancaster Countians still don't get it. Prosecutorial and
police misconduct isn't just for the Rodney Kings and O.J. Simpsons of this
country. They aren't "L.A. and New York'' issues. They happen everywhere
and they
Article 249 of 348, 1991132960
NOW MIRACK FAMILY WONDERS: WAS OUR CASE

MISHANDLED?
As Laurie Show's family watched attorneys pick apart the police
investigation of her murder over the last three weeks, another family was
watching the proceedings with growing unease.. For Vince and Gerry
Mirack, the past several weeks have been an unsettling time. Their
daughter, Christy, 25, was murdered in her East Lampeter Township
townhouse a year and a day after Show's murder in her East Lampeter
condominium. East Lampeter police have never solved the school
Article 250 of 348, 1991122072
LAMBERT 'WILL NEVER STEP FOOT AGAIN' IN

COUNTY
PHILADELPHIA - Lisa Michelle Lambert "will never step foot again in
Lancaster County," her attorney predicted Monday, two hours after a federal
district court judge freed her from life imprisonment for a murder committed
six years ago.. It was a day filled with joy for Lambert and her family
Monday. For Laurie Show's family, it was a day filled with sorrow. Two
families brought together in a federal courtroom in Philadelphia because of
a tragedy five years


3 of 3
6/10/2006 8:53 AM
A...948 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
387
385 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 251 of 348, 1991122087
COUNTY COMMISSIONERS HAVE 'CONFIDENCE' IN

DA'S OFFICE
In the face of accusations of gross prosecutorial conduct in the handling of
the Lisa Michelle Lambert case, two of Lancaster County's three
commissioners said Monday they stand behind District Attorney Joseph
Madenspacher and his office.. Commissioner Ron Ford said he has "every
confidence in the legal justice system here in Lancaster County." Likewise,
Paul Thibault said he "has the highest regard for the people in our district
Article 252 of 348, 1991122070
'LISA LAMBERT SHOULD BE IMMEDIATELY

RELEASED'
This is the decision of U.S. District Court Judge Stewart Dalzell in the case
of Lisa Michelle Lambert as released by his office on Monday.. Lisa
Lambert has petitioned this Court for a writ of habeas corpus, alleging,
among other things, that she is actually innocent of the first degree murder
for which she was convicted in July of 1992, and that she was the victim of
wholesale prosecutorial misconduct in connection with the prosecution of
her case. As a result of her being raped by a
Article 253 of 348, 1991122071
A STARTLING OUTCOME, BUT ROOTED IN THE

CONSTITUTION, LAWYER SAYS
Back in 1993, a well-known defense attorney said the decision by Lisa
Michelle Lambert's attorney to pursue a non-jury trial here in Lancaster
made it "absolutely less likely" that there would be an appeal based on court
error.. But an appeal based on misconduct by the prosecutor? It was made,
and it succeeded in federal court Monday. And Lambert, the convicted
murderer of Laurie Show, has been set free.. "It's extremely
1 of 4
6/10/2006 8:54 AM
A...949 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
388
386 of
of 456
454
June 14, 2016
Article 254 of 348, 1991122084
MIXED MESSAGES
Judge Stewart Dalzell clearly intended to send a message when he freed
Lisa Michelle Lambert, who was serving a life sentence for the 1991 first
degree murder of Laurie Show. He claimed that the means - a trail of
evidence he said was tainted and compromised - did not justify the ends
(her conviction.). That said, the judge did no better. His means - freeing a
woman whose own testimony implicates her in the murder, and denying the
prosecution the opportunity to retry her - hardly justifies
Article 255 of 348, 1991122069
JUDGE WANTS PROBE OF PROSECUTORS AFTER

CLEARING LAMBERT OF MURDER / / DA WON'T QUIT,
VOWS TO APPEAL
KENNEFF. PHILADELPHIA - Stung by a federal judge's decision Monday to
free Lisa Michelle Lambert, Lancaster County District Attorney Joseph C.
Madenspacher said he would appeal the case today to the 3rd U.S. Circuit
Court of Appeals. Madenspacher told reporters part of his appeal will focus
on the judge's decision last week to release Lambert conditionally to her
attorneys before the state presented its case against her.. "We will take this
case as far
Article 256 of 348, 1991122073
SOME LOCAL LAWYERS EXPRESS OUTRAGE, OTHERS

PONDER THE FALLOUT
The shock had passed. By Monday evening, some local attorneys found
their feelings over the outright release of Lisa Michelle Lambert had turned
to plain anger.. Once a convicted killer, Lambert was now called "innocent"
by a federal judge. "It's outrageous," said Stephen R. Gibble, a lawyer who
formerly chaired the county GOP. "The whole thing is awful. To say there
won't be a new trial, that takes my breath
Article 257 of 348, 1991122074
AROUND EAST LAMPETER, ANGER AT JUDGE,

SYMPATHY FOR SHOWS
The decision to free Lisa Michelle Lambert, the convicted killer of
16-year-old Laurie Show, left many people with mixed emotions.. People
attending Monday's school board meeting at Conestoga Valley High School,
where Show, Lambert and co-defendant Tabitha Buck attended school,
agreed that justice was ill-served. But they say it's U.S. District Judge
2 of 4
6/10/2006 8:54 AM
A...950 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
389
387 of
of 456
454
June 14, 2016
Stewart Dazell who is at fault. While few wanted their names published,
many were quick to put their feelings on the
Article 258 of 348, 1991122075

CLEARING LAMBERT OF MURDER / / DALZELL
FORBIDS RETRIAL, CALLS FIRST TRIAL 'RIGGED'
PHILADELPHIA - Calling her a victim of corrupt prosecutors, a federal judge
Monday cleared Lisa Michelle Lambert of murder, barred a retrial and called
for an investigation of prosecutor John A. Kenneff, District Justice Ronald
W. Savage and six police officers.. "The fact is the commonwealth rigged
the proceedings in (Lambert's) trial to such an extent that it was a trial in
name only," said U.S. District Court Judge Stewart Dalzell, freeing Lambert
from
Article 259 of 348, 1991122005
LAMBERT TO 'MAKE UP LOST TIME WITH HER

FAMILY'
After 64 months in prison, Lisa Michelle Lambert walked away from a life
sentence and into the arms of the parents from whom she once rebelled..
Together, the family begins an uncertain future veiled in secrecy and laden
with fear of retribution from those angered by Lambert's freedom. The only
thing for sure, said the 24-year-old's attorney, is that Lisa Lambert "will
never set foot again in Lancaster County.". "I think
Article 260 of 348, 1991122007
LAWYERS EXPECT APPEAL WILL FAIL

"We've got to resign ourselves to the fact this girl is not going back to jail. ".
Those are the words of local defense attorney Robert Beyer, commenting
today on the Lisa Michelle Lambert case. U.S. District Court Judge Stewart
Dalzell released Lambert Monday from her lifetime prison sentence for the
1991 murder of Laurie Show and barred a retrial. Lancaster County District
Attorney Joseph C. Madenspacher is appealing the decisionl. "I

3 of 4
6/10/2006 8:54 AM
A...951 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
390
388 of
of 456
454
June 14, 2016
4 of 4
6/10/2006 8:54 AM
A...952 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
391
389 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 261 of 348, 1991122002
DALZELL CITES 25 CASES OF MISCONDUCT

Here is a list of 25 instances of misconduct Judge Stewart Dalzell alleges
that police and prosecutors committed.. Number 1-7 have to do with
perjured testimony. 1. They hid evidence that Lawrence Yunkin was seen
driving on Black Oak Drive near the Show condominium the morning of the
murder.. They didn't tell Lisa Michelle Lambert's attorney, Roy Shirk, about a
witness, Kathleen Bayan, who said she saw Yunkin and two women driving
away from the scene of the crime
Article 262 of 348, 1991122004
DA STARTS APPEAL, LISTS REASONS

Lancaster County District Attorney Joseph Madenspacher said he would file
an appeal today to fight a federal judge's decision to free convicted killer
Lisa Michelle Lambert.. "This case is not over by a long shot,"
Madenspacher said. The appeal being filed today is basically just a notice of
appeal, Madenspacher said. The detailed appeal will not be filed for
perhaps several weeks.. Madenspacher said some of the bases for the
appeal would include bias
Article 263 of 348, 1991122000
HOW COULD THIS HAPPEN IN THE IDYLLIC LAND OF

'WITNESS'?
In his 90-page decision, Judge Stewart Dalzell addressed the reaction of
Lancaster County to the Laurie Show murder case and the conviction of
Lisa Michelle Lambert. Here is what he said:. Why Did This Happen?
"Those who have read this sad history may well ask themselves, how could
a place idealized in Peter Weir's Witness become like the world in David
Lynch's Blue Velvet? Because it is so important to that community - and
indeed to many others - to
Article 264 of 348, 1991122013
1 of 3
6/10/2006 8:55 AM
A...953 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
392
390 of
of 456
454
June 14, 2016
IF LISA LAMBERT IS INNOCENT, WHAT ABOUT

THESE QUESTIONS?
After three weeks of stunning, grueling testimony in Lisa Michelle Lambert's
murder appeal hearing, this is what federal Judge Stewart Dalzell did:. He
heard and accepted nearly all of the arguments presented by Lambert's
Philadelphia lawyers. He rejected or ignored nearly all of the arguments and
evidence presented by Lambert's prosecutors.. As a result, he granted
Lambert her freedom and told the Lancaster County District Attorney's office
Article 265 of 348, 1991122006
NO TWP. PROBE OF 4 POLICE OFFICERS

East Lampeter Township won't conduct an internal investigation of its police
department or suspend four police officers accused of willfully mishandling
the Laurie Show murder investigation, township officials said today.. Police
Chief Dale E. Jerchau and Supervisor Chairman John W. Shertzer
defended the officers, whom they said are victims of a biased judge and
overzealous defense attorneys. "It's been a painful experience, to say the
least, but we do not
Article 266 of 348, 1991122012
COURTS AND LAWYERS ARE GOING TO RUIN THE

COUNTRY
Editor, New Era:. I guessed it was only a matter of time until Lisa Michelle
Lambert, a convicted murderess, walks among us completely free, having
the last laugh. We should have seen this kind of "justice" coming, after that
lunacy with O.J. Simpson's acquittal. Our courts seem to be becoming our
ruination, with lawyers playing chess games instead of practicing law.
Everyone has a book out - is Judge Dalzell's ready for print?. This girl is
Article 267 of 348, 1991111938
FEDERAL JUDGE WILL DECIDE LAMBERT'S FATE

TODAY
Federal Judge Stewart Dalzell will announce today whether convicted killer
Lisa Michelle Lambert gets a new trial for the 1991 stabbing death of
16-year-old Laurie Show or walks out of a Philadelphia courtroom a free
woman.. He could also uphold Lambert's first-degree murder conviction and
send her back to prison, but that appears unlikely. Dalzell appears to be
considering the first two options, and in either case it appears unlikely
Lambert will return to prison anytime soon.
2 of 3
6/10/2006 8:55 AM
A...954 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
393
391 of
of 456
454
June 14, 2016
Article 268 of 348, 1991111885

DA DEFENDS HANDLING OF MURDER CASE

Lancaster County District Attorney Joseph Madenspacher today continued
to defend the handling of the murder case against Lisa Michelle Lambert..
Moments after U.S. District Judge Steward Dalzell freed Lambert because
of prosecutorial misconduct in the investigation of the 1991 killing of Laurie
Show, Madenspacher said: "I think (Dalzell) characterized honest mistakes
and problems...into a set of misconduct that simply does not exist.".
Madenspacher also defended
Article 269 of 348, 1991111845
LAMBERT FREED
PHILADELPHIA _ Lisa Michelle Lambert walked out of a federal courtroom
a free woman today, released from a life sentence for the murder of
16-year-old Laurie Show.. "Lisa Lambert should be released and she shall
not be retried," said U.S. District Judge Stewart Dalzell. Dalzell's dramatic
decision was met by silence in the packed ceremonial courtroom in the
federal courthouse. Show's family got up and left the courtroom in a group
while the
Article 270 of 348, 1991111846
LEGAL SYSTEM 'BOGUS', COUNTIANS SAY

For a number of Lancastrians, the Lisa Michelle Lambert hearing has been
just another in a string of high-profile cases in which the guilty "can get
away with murder.". "O.J, the JonBenet case _ it's saying that people can
do anything they want," said Paul Kralicek, 58, of Lancaster, who works in
the Lancaster County Courthouse. Kralicek's opinion was shared by most
others who were surveyed here this morning, prior to


3 of 3
6/10/2006 8:55 AM
A...955 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
394
392 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 261 of 348, 1991122002

Article 262 of 348, 1991122004

Article 263 of 348, 1991122000

'WITNESS'?
Article 264 of 348, 1991122013
1 of 3
6/10/2006 8:56 AM
A...956 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
395
393 of
of 456
454
June 14, 2016

THESE QUESTIONS?
Article 265 of 348, 1991122006

Article 266 of 348, 1991122012

COUNTRY
Article 267 of 348, 1991111938

TODAY
2 of 3
6/10/2006 8:56 AM
A...957 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
396
394 of
of 456
454
June 14, 2016
Article 268 of 348, 1991111885


Article 269 of 348, 1991111845
LAMBERT FREED
while the
Article 270 of 348, 1991111846



3 of 3
6/10/2006 8:56 AM
A...958 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
397
395 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 271 of 348, 1991103147
LAURIE'S LOSS CHANGED LIFE OF BOYFRIEND

For more than five years, Brad Heisler has been the forgotten man.. He was
Laurie Show's boyfriend, a Conestoga Valley sophomore in the midst of a
typical teen-age relationship. Then, on Dec. 20, 1991, Show was beaten,
stabbed and left to die with a slit throat on her bedroom carpet. Heisler was
probably the second person to arrive at the scene of her murder, but what
he saw there is still in dispute.. His story of the murder and the toll it has
taken on his life has never
Article 272 of 348, 1991103142
RECAP OF A VERY DRAMATIC WEEK

Following is a synopsis of last week's events in the Lisa Michelle Lambert
murder appeal hearing in federal court in Philadelphia.. SUNDAY, APRIL
13: County officials announced that they had hired Lancaster attorneys Alvin
Lewis and Richard Sprague to represent county prosecutors, detectives and
others at the hearing. MONDAY, APRIL 14: Former state policeman John
Balshy testified that Laurie Show appeared to have written the initials "TB"
and
Article 273 of 348, 1991103148
TRYING TIMES
Balding on top but with long, flowing white hair in back, U.S. District Judge
Stewart Dalzell looks a little like Henry Fonda, and acts a lot like John
Wayne.. On Thursday, for example, when Lancaster District Attorney
Joseph Madenspacher asks him to reconsider his decision to release Lisa
Michelle Lambert to the custody of her lawyers, Madenspacher has barely
finished speaking before Dalzell brushes his concern aside with: "OK, that's
denied. What's
Article 274 of 348, 1991103150
1 of 3
6/10/2006 8:57 AM
A...959 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
398
396 of
of 456
454
June 14, 2016

MONDAY. April 14 - The federal appeal hearing for Lisa Michelle Lambert,
seeking a new trial or freedom on her conviction in the murder of Laurie
Show, restarted in Philadelphia. Lambert is serving a life sentence, along
with Tabitha Buck, while Lambert's boyfriend, Lawrence Yunkin, is serving
10-20 years as an accessory.. The case broke wide open Wednesday,
when the judge released Lambert into the custody
Article 275 of 348, 1991103143
ATTORNEYS FEEL PAIN OF THEIR COLLEAGUES

U.S. Judge Stewart Dalzell's harsh words about some of Lancaster's top
lawyers have reverberated through the legal circles here.. Lancaster's legal
community, about 650 lawyers strong, is small enough that many lawyers
know each other on a first-name basis. The men Dalzell has accused of
perjury, concealing evidence and obstruction of justice in the Lisa Michelle
Lambert murder investigation aren't just district attorneys and a district
Article 276 of 348, 1991103144
TRYING TIMES
On the stand, Ronald Savage absorbs verbal body blow after verbal body
blow from attorney Christina Rainville, who is accusing him of lying, of
withholding evidence, of trying to frame Lisa Michelle Lambert in the 1991
murder of Laurie Show.. Savage seems defenseless, answering nearly
every question with "I don't know," or "I can't recall." He is only emphatic
when Rainville directly accuses him of perjury.
Article 277 of 348, 1991103145
MRS. SHOW SAYS JUDGE WAS UNFAIR

Evil seemed to turn to good last week, and good to evil.. In a Philadelphia
house, a convicted killer ate pizza and listened to piano music, while the
people who carry the trust of the justice system on their shoulders went on
trial, and seemingly lost. Hazel Show is spending the weekend praying that
U.S. Judge Stewart Dalzell will order a new trial and not set Lisa Michelle
Lambert free.. "The transcripts of the last trial ... should give him the light of
Article 278 of 348, 1991091785
2 of 3
6/10/2006 8:57 AM
A...960 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
399
397 of
of 456
454
June 14, 2016
SHOW INSISTS LAURIE FINGERED LAMBERT

PHILADELPHIA - Hazel Show insisted Friday in federal court that her
daughter identified Lisa Michelle Lambert as her killer.. "I lifted her and saw
her throat was cut," Show said in testimony before U.S. District Judge
Stewart Dalzell, who is presiding at a hearing in which Lambert is seeking
freedom from a life sentence for killing Show's daughter. "I tried to keep her
together. I told her I am sorry and it was a setup," Show said.
Article 279 of 348, 1991091784
DA BACKS NEW TRIAL FOR LAMBERT

PHILADELPHIA - A lawyer for convicted murderer Lisa Michelle Lambert
urged a federal judge Friday to free her client permanently, but the
Lancaster County district attorney asked to be able to retry her on 1991
murder charges.. Christina Rainville, Lambert's lawyer, proclaimed in
closing remarks at her client's federal appeals hearing, "The truth is out.
Lisa Lambert is innocent, innocent of murder and innocent of conspiracy." A
hearing on
Article 280 of 348, 1991091737
SHOWS FEAR THE 'WORST' IN JUDGE'S RULING

PHILADELPHIA - In two days, a federal judge will decide whether Lisa
Michelle Lambert goes free or gets a new trial for the Dec. 20, 1991, murder
of 16-year-old Laurie Show.. John Show said today that he and his ex-wife,
Hazel, are almost certain that their daughter's convicted killer will be set free
on Monday. "I just felt all along that the judge has his mind made up," Show
said. "It's going to be a terrible


3 of 3
6/10/2006 8:57 AM
A...961 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
400
398 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 281 of 348, 1991091739
LAWYER: SHE'S INNOCENT

PHILADELPHIA - "Justice requires that Miss Lambert be released," a
Philadelphia attorney argued here Friday in federal court.. Christina
Rainville, a lawyer for Lisa Michelle Lambert, said Lancaster County
prosecutors convicted Lambert of the 1991 murder of Laurie Show by lying
and fabricating evidence. "The truth is out. Lisa Lambert is innocent.
Innocent of murder. Innocent of conspiracy," Rainville said in a closing
statement Friday
Article 282 of 348, 1991082170
LAMBERT CASE COULD IMPACT ON FUTURE

CANDIDACIES
The curious and bizarre court proceedings in Philadelphia that may yet
produce the release of convicted killer Lisa Michelle Lambert could also
produce some political detours among local Republican politicians, while
putting some others on the fast track to advancement.. There have already
been some speed bumps in the GOP's road this year. The Republican
committee people, impressed by his steadfast willingness to volunteer for
just about any task, endorsed Dennis E. Reinaker for
Article 283 of 348, 1991082177
DA ASKS JUDGE BE REMOVED FROM CASE

This is a slightly edited text of District Attorney Joseph Madenspacher's
motion asking that Judge Stewart Dalzell be removed from the Lambert
case.. Motion for Recusal of District Court Judge Stewart Dalzell Appellants,
Respondents below, respectfully move for Recusal of U.S. District Court
Judge Stewart Dalzell for the Eastern District of and in support thereof state
as follows:. 1. On April 2, 1997, during the direct testimony of Ronald
Barley, The Honorable Judge Stewart
Article 284 of 348, 1991082180
1 of 3
6/10/2006 8:58 AM
A...962 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
401
399 of
of 456
454
June 14, 2016
LAWYER ACCUSES SAVAGE OF TRYING TO FRAME

TEEN
PHILADELPHIA - An attorney seeking to free Lisa Michelle Lambert
accused District Justice Ronald W. Savage, chief investigator in Laurie
Show's murder, of trying to frame a teen-ager in the killing of a teacher a
year and a day after 16-year-old Show was stabbed to death.. Savage, who
also headed the investigation into the 1992 murder of teacher Christy
Mirack, came under fire again Thursday in a federal hearing where Lambert
is seeking freedom from her 1992 conviction in
Article 285 of 348, 1991082176
STATEMENT FROM LAMBERT LAWYERS

The following is a statement issued Wednesday by Peter Greenberg and
Christina Rainville, lawyers for Lisa Michelle Lambert.. We're shocked,
offended and indeed saddened by motions filed by the Commonwealth and
the attitudes expressed today. The evidence produced in this courtroom has
quite literally defied belief. None of us could imagine that in America in the
1990's a perversion of justice like this could have taken place and this
conduct has continued in the
Article 286 of 348, 1991082185
LAMBERT STAYS OUT OF PRISON

PHILADELPHIA - Convicted murderer Lisa Michelle Lambert beamed and
hugged her parents late Thursday afternoon after a prosecutor's bid to block
her conditional release was rejected by a federal appeals panel.. Acting
swiftly, a three-judge panel of the 3rd U.S. Circuit Court of Appeals upheld
U.S. District Judge Stewart Dalzell's decision Wednesday to release
Lambert to the custody of her attorneys while a hearing on alleged
misconduct by prosecutors continues. The
Article 287 of 348, 1991082119
COURTHOUSE BANS ARE PRECAUTION

Better safe than sorry, U.S. District Judge Stewart Dalzell believes.. His
unusual order on Wednesday - directing a prosecutor, police and others
who handled the Lisa Michelle Lambert murder case to stay out of the
courthouse and stay away from him, his family and his staff - is apparently
just a precaution. Courthouse personnel knew of no threats against the
Philadelphia judge, his family or his staff.. Dalzell is hearing a bid by
Lambert, convicted of the 1991 killing of East Lampeter
2 of 3
6/10/2006 8:58 AM
A...963 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
402
400 of
of 456
454
June 14, 2016
Article 288 of 348, 1991082117

NEXT: TABITHA BUCK'S APPEAL TO GO FEDERAL?

Lisa Michelle Lambert will not be the only defendant to seek a new trial, or
release from prison, as a result of alleged police and prosecutor
misconduct.. The attorney for co-defendant Tabitha Buck said today he will
use those same issues to seek to overturn her 1992 conviction of
participating in the stabbing death of teen-ager Laurie Show. "To the extent
that Tabitha Buck's case is similar to Lambert's case and Lambert's case is
tainted,
Article 289 of 348, 1991082118
RELAXED LAMBERT: 'CAN YOU TAKE ME TO

DISNEYLAND?'
Convicted murderer Lisa Michelle Lambert returned to court today, calm
and relaxed after a second day out of jail.. Dressed in a dark-green suit and
beige blouse, Lambert strolled casually to the defense table, talked briefly
with her attorneys and then walked unescorted through a rear door behind
the judge's bench. She returned a few minutes later to hear the first of five
witnesses whom Lancaster County District Attorney Joseph Madenspacher
intended to present in an effort to
Article 290 of 348, 1991082115
LAWYER SUGGESTS SAVAGE TRIED TO FRAME

WITNESS
District Justice Ronald W. Savage is conducting "business as usual" today
in his Leola office, after enduring days of accusations in Philadelphia's
federal court questioning his integrity and investigative skills.. In December
1991, Savage was an East Lampeter Township police sergeant leading the
investigation and police prosecution of Lisa Michelle Lambert for the murder
of 16-year-old Laurie Show. This week, as the convicted murderer seeks
her freedom in


3 of 3
6/10/2006 8:58 AM
A...964 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
403
401 of
of 456
454
June 14, 2016
Hom e
Feat ures
Weat her
Classifieds
Talk Back
Apart m ent s
Shopping
Special
Sect ions
Visit Lancast er
Travel
Personals
Archive
News
Local News
Top St ories
Sit e
Sit e Map
Keyword I ndex
RSS Feeds
Need A
WebSit e?
Cont act Us
Go

w e r e found.
Article 291 of 348, 1991082070
VICTIM'S MOTHER ACCUSES LAMBERT

PHILADELPHIA _ Laurie Show's mother took the stand today in a bid to
keep her daughter's convicted murderer, Lisa Michelle Lambert, in prison..
"Nothing has changed...Laurie told me that Michelle did it, and there's no
other truth than that," Hazel Show said today before she testified. Mrs.
Show is the key witness for Lambert's prosecutors, who are arguing to
refute Lambert's bid for freedom in a federal
Article 292 of 348, 1991072085
JUDGE RELEASES LAMBERT

PHILADELPHIA - A federal judge lambasted East Lampeter Township
District Justice Ronald Savage Wednesday for allegedly lying under oath on
the witness stand and obstructing justice in the Laurie Show murder case..
U.S. District Judge Stewart Dalzell told Lancaster County District Attorney
Joseph Madenspacher to contact the Pennsylvania Supreme Court and
insist on having Savage removed from the bench. Dalzell's remarks came
during a series of extraordinary events at a federal
Article 293 of 348, 1991072089
TRANSCRIPT OF HEARING
U.S. District Court Judge Stewart Dalzell's decision to conditionally release
Lisa Michelle Lambert came after an extraordinary hearing in the judge's
chambers Wednesday afternoon.. The session brought together the
Lancaster County district attorney and lawyers for Lambert and heard new
testimony from Hazel Show, the mother of murder victim Laurie Show. After
hearing what Mrs. Show had to say, Dalzell accused the chief police
prosecutor of the case, now a district
Article 294 of 348, 1991072088
1 of 3
6/10/2006 8:58 AM
A...965 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
404
402 of
of 456
454
June 14, 2016
JUDGE: 'I DON'T WANT HER TO GO BACK TO PRISON'

This is the transcript of a hearing in the chambers of U.S. District Judge
Stewart Dalzell held Wednesday afternoon. Participating were the judge
("The Court"); Joseph Madenspacher, Lancaster County district attorney;
Peter Greenberg, attorney for Lisa Michelle Lambert; Christina Rainville,
attorney for Lambert; Alvin Lewis, attorney for Lancaster County officials;
and Hazel Show, mother of murder victim Laurie Show.. AFTERNOON
SESSION (Reconvened in Chambersat 1:40
Article 295 of 348, 1991072086
LAMBERT CASE DEVELOPMENTS SHOCK LAWYERS

Local attorneys Wednesday expressed shock over the conditional release of
convicted killer Lisa Michelle Lambert.. And one attorney said Wednesday's
action is likely a prelude to Lambert's outright freedom. Scott Oberholtzer, a
defense attorney, said he would not be surprised if U.S. District Judge
Stewart Dalzell frees Lambert today. "For the judge to go ahead and let her
go ahead tonight, he must have made up his mind to do something,"
Article 296 of 348, 1991072087

This story was written by Intelligencer Journal reporter Paul Bomberger and
reported by Bomberger, Intelligencer Journal reporters Jennifer Kopf and
Jeff Hawkes and correspondent Lee Linder.. PHILADELPHIA - A federal
judge released Lisa Michelle Lambert to the custody of her lawyers
Wednesday afternoon, after the mother of murder victim Laurie Show
testified she had been instructed by police in 1992 to withhold crucial
evidence. Lambert celebrated her first night of freedom in six years
Article 297 of 348, 1991072035
'DAZED' LAMBERT AWAITS RULING ON FREEDOM,

TRIAL
Lisa Michelle Lambert spent her first night of freedom in 5 1/2 years sitting
in a Philadelphia townhouse, eating pizza and listening to piano music while
guarded by federal marshals.. Lambert was left "dazed" by the sudden turn
of events Wednesday, when a federal judge released her to the custody of
her attorneys after ruling that prosecutors violated her right to a fair trial.
Lambert, 24, had been in prison since her arrest the evening of Dec. 20,
1991 on charges
2 of 3
6/10/2006 8:58 AM
A...966 of
22, 2017
Page
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
405
403 of
of 456
454
June 14, 2016
Article 298 of 348, 1991072040
OTHERS MAY BE GUILTY, BUT LAMBERT IS NOT

INNOCENT
Lisa Michelle Lambert is not the victim.. The victim is 16-year-old Laurie
Show, in her grave. And Lambert is not innocent - how could she be?. A
county Commonwealth Court and a state Superior Court ruled she is not.
The state Supreme Court, after reviewing these decisions, refused to hear
her appeal.. Now, even with newly revealed evidence that supports her
claims, Lambert is still irrevocably involved in the events that led to Laurie
Show's murder.. These facts must
Article 299 of 348, 1991072032
MURDER VICTIM'S MOTHER SAYS SHE'S ALWAYS

TOLD TRUTH
The mother of murder victim Laurie Show is sticking by her court testimony,
which included statements that her dying daughter told her "Michelle did it.".
Hazel Show did not respond to interview requests today, in the wake of her
dramatic revelation Wednesday that she suddenly recalled that police told
her to withhold crucial evidence after the Dec. 20, 1991, murder. But
through a spokeswoman, Mrs. Show said today that she has always told the
truth about events
Article 300 of 348, 1991072034
EXPERT: JUDGE'S MOVE UNUSUAL, CLEARLY

ALLOWED
U.S. District Judge Stewart Dalzell's decision to release Lisa Michelle
Lambert is unusual but clearly allowed under federal law, a San Francisco
expert in such proceedings says.. Timothy J. Foley, a Harvard-educated
attorney who specializes in federal-release hearings, said Wednesday night
that a federal judge does have the right to free a defendant when he
believes the state court system has violated the individual's constitutional
rights to a fair trial.


3 of 3
6/10/2006 8:58 AM
Archives
search for isc AND date(all) Page 967 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
406
404 of
of 456
454
June 14, 2016
Car s | Jobs | Hom es | Cu st om er Car e Cen t er
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 4
Go
Lancast er Online Key w or d
1 4 9 a rt icles m a t ching isc AN D da t e( a ll) w ere found.

Article 11 of 149, 10224806
N ew spaper Advert isem ent s

Kat her ine Heigl Collect ion Now At
Unifor m Solut ions.
Pu blish ed on Jan u ar y 3 , 2 0 0 5 , Lan cast er New Er a Sant a's Spect acular Chr ist m as Sale At
( PA)
The Bedst ead.
Guerin 'home' to complete sentence

Former ISC chief will serve final months of his 1992
sentencing for directing illegal arms scams in home
confinement here.
M a rk et pla ce
Visit t he M ark et place

>>
Ce n t r a l
Ma r k e t Co n e
Li g h t # 3 9
Ol d e Mi l l
Li g h t i n g
$ 1 7 1 .0 0
Wom an ' s Min n et on k a

Pi l e - L i n e d M u l e S l i p p e r
# 3511
Co y o t e T r a i l s $ 2 8 .9 9
St er l i n g Si l v er
Wh it e Sat in
Ri n g - S i z e 9
$ 1 9 .9 9
S t e r l i n g S i l v e r Pi p e Cu t
S p i n n e r Ri n g - S i z e 1 4
$ 1 9 .9 9
In 1989, local business icon James H. Guerin moved from Lancaster to

Florida, defiant as a storm gathered around him.
Soon he'll come back under quieter conditions.
Guerin, 74, will return in late January to serve the last six months of his
1992 sentence for directing illegal schemes at his International Signal &
Control.
Guerin, who admitted running ISC's $1.14 billion fake-contract scam and
$50 million smuggling ring, will complete his sentence
Cl i c k f o r c o m p l e t e a r t i c l e , ( 1 3 6 9 w or d s)
Article 12 of 149, 10205546
Pu blish ed on Ju ly 6 , 2 0 0 4 , Lan cast er New Er a

( PA)
LGH in top 50 in 2 specialties

Hospital cited for care of heart and hormonal disorders in
new survey.
Lancaster General Hospital has been named one of the 50 best hospitals in
the country in two specialties, according to U.S. News and World Report's
15th annual "America's Best Hospitals" survey.
The hospital ranked 26th in the area of heart and heart surgery care and
34th in the area of hormonal disorders and endocrinology, according to the
rankings appearing in the July 12 issue.
Taking such things as reputation, mortality ratio, nursing
Cl i c k f o r c o m p l e t e a r t i c l e , ( 4 5 4 w or d s)
Article 13 of 149, 10204256
Published on June 2 6 , 2 0 0 4 , I nt elligencer Jour nal

( Lancast er , PA)
Thomas L. Flannery, Intell investigative reporter, dies at 56

Thomas L. Flannery, an award-winning Intelligencer Journal investigative
reporter, died unexpectedly Thursday night, just hours after filing what was
to be his last story for the newspaper. He was 56.
Flannery, of 10 Upper Green, was stricken ill at home and died of natural
causes at Lancaster General Hospital. Earlier in the day, he had covered a
court case.
A court reporter at the time of his death, Flannery began his journalism
career as an intern with the Intell in 1987 and joined
12/25/2007 10:16 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
407
405 of
of 456
454
June 14, 2016
Need a
Websit e?
Article 14 of 149, 10200504
Published on May 2 4 , 2 0 0 4 , I nt elligencer Jour nal

( Lancast er , PA)
Larry A. Schick, 62, engineer, CEO

Larry Allan Schick, 62, of 120 Buck Run Road, Conestoga, died Friday at
Essa Flory Hospice Center after a long illness.
He worked 17 years for the former International Signal and Control Inc. of
Lancaster and was chief executive officer of the former ISC Educational
Systems Inc.
A graduate of the University of Illinois with a degree in electrical
engineering, he received his master's degree from Florida Institute of
Technology.
Schick worked for the former Pan American
Article 15 of 149, 10168098
Published on August 3 , 2 0 0 3 , SUNDAY NEWS

( LANCASTER, PA.)
Local players help Keating's win state 'B' softball title

Several Lancaster County players helped Keating's Fitness Center of
Wilkes-Barre win the Class B Fast-Pitch Pennsylvania state championship
last weekend at Lebanon's Prescott Field.
Keating's was 4-0 in winning its third straight state championship.
They defeated Kreider & Flick of Bedford twice in the tournament, 9-5 in the
second game and 8-0 in the championship game.
Art Devoe of Wakefield and Dave Stokes of Holtwood
Article 16 of 149, 10151920
Published on Mar ch 20, 2003, I NTELLI GENCER

JOURNAL ( LANCASTER, PA.)
Helen L. Kiehl, 72, ISC Corp. retiree

Helen L. Kiehl, 72, of 411 Pheasant Ridge Circle, died Tuesday at Essa Flory
Hospice Center. She was under the care of a physician.
A retiree of the former International Signal & Control Corp., she previously
worked at the former L.P. Henderson Umbrella Factory.
Mrs. Kiehl was a member of Church of the Apostles United Church of Christ.
She enjoyed traveling, flowers and music.
Born in Lancaster, she was the daughter of the late Phillip and Pearl
Article 17 of 149, 10151776
Published on Mar ch 19, 2003, I NTELLI GENCER

Solomon Lasof, 85, RCA physicist

Solomon Lasof, 85, of Eden Road, formerly of Trenton, N.J., died Tuesday
at Lancaster General Hospital after a brief illness.
He worked 29 years as a physicist and engineer for the former RCA Corp.
He also worked for the former ISC/Ferranti Inc.
2 of 4
12/25/2007 10:16 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
408
406 of
of 456
454
June 14, 2016
Lasof graduated from Trenton High School, Cornell University and the
University of Pennsylvania.
An avid flyer, he was a member of the Aircraft Owners and Pilots
Association.
He also belonged to Phi Beta Kappa and the
Article 18 of 149, 10151866
Published on Mar ch 19, 2003, LANCASTER NEW

ERA ( LANCASTER, PA.)
Solomon Lasof, 85, RCA physicist

Solomon Lasof, 85, of Eden Road, formerly of Trenton, N.J., died Tuesday
at Lancaster General Hospital after a brief illness.
He worked 29 years as a physicist and engineer for the former RCA Corp.
He also worked for the former ISC/Ferranti Inc.
Lasof graduated from Trenton High School, Cornell University and the
University of Pennsylvania.
An avid flier, he was a member of the Aircraft Owners and Pilots
Association.
He also belonged to Phi Beta Kappa and the
Article 19 of 149, 10151142
Published on Mar ch 13, 2003, LANCASTER NEW

Sold cluster bombs

Editor, New Era:
The other morning I was in the barbershop and the guy in the next chair was
joking about his former employer, ISC. Someone mentioned Pakistan and
he said, "We used to sell them cluster bombs. We sold cluster bombs to all
those countries. Our motto was, "We sell third-rate weapons to
second-rate countries at first-rate prices."
Perhaps, if all previous administrations had focused a bit more on trying to
make the world safer
Article 20 of 149, 10149773
Published on Mar ch 2, 2003, SUNDAY NEWS

( LANCASTER, PA.)
In defense of Guerin
I read the editorial in Sunday's paper (Feb. 23) called "A tainted
nomination," and I think it's time to stand up and be counted in support of
Jim Guerin. I take issue with your first and second sentences --"Jim Guerin
had a talent for dirtying everything he touched. Especially reputations."
I was an employee of ISC for five years, managing the employee fitness
center, and Mr. Guerin impacted my life positively.
3 of 4
12/25/2007 10:16 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
409
407 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3
Article 131 of 149, 1996030196
Pu blish ed on Jan u ar y 3 0 , 1 9 9 6 , Lan cast er New

Er a ( PA)
FERRANTI SELLS LAST OF ITS BUSINESSES
Go

Sant a's Spect acular Chr ist m as Sale At
The Bedst ead.
M a rk et pla ce

>>
Ferranti International Inc. has sold the last of its 16 businesses in the United
States, completing the divestiture of its operating companies.
Lancaster-based Ferranti sold Mountain Optec Inc. of Boulder, Colo., to
Phillips Services Industries Inc. earlier this month. The price was not
disclosed, but it consists of an initial payment plus future payments based
on the firm's performance over the next two years.
Mountain Optec toughens or "ruggedizes"
Article 132 of 149, 1996020237
Wom an's
Min n et on k a
Pi l e - L i n e d
Mu l e Sl i p p er
# 3511
Co y o t e T r a i l s
$ 2 8 .9 9
O l d e M i l l H o u s e $ 0 .0 0
Pu blish ed on Jan u ar y 2 0 , 1 9 9 6 , I n t elligen cer

Jour nal ( Lancast er , PA)
DAVIS WON'T SEEK ENDORSEMENT

Edward A. Davis, a former Navy captain and Vietnam-era prisoner of war,
said Friday he won't seek the endorsement of Republican committee people
for the congressional seat being vacated by U.S. Rep. Robert S. Walker.
However, Davis said he still might run in the Republican primary.
Davis, 56, serves on the Penn Manor School Board and is facility manager
for Summit Aviation at the Lancaster Airport. He previously worked for
Ferranti International PLC and ISC Corp. Eight
K e y s Fi t n e s s
12- program
EK G
Re c u m b e n t
Ex e r c i s e B i k e
$ 3 0 4 .9 9
Si l v e r Ba l l a n d Ge m st o n e
B e a d Ea r r i n g s - o n y x
$ 2 3 .9 9
Article 133 of 149, 1995328030
Pu blish ed on Nov em ber 2 4 , 1 9 9 5 , Lan cast er New

Er a ( PA)
JAILED GUERIN ASKS TO COLLECT PENSION

James H. Guerin, who stole $189.9 million from Ferranti International,
believes he's entitled to his pension from the company too.
Now serving a 15-year sentence for his crimes, Guerin filed court papers
last month to initiate receipt of his $2,800-a-month pension. But Ferranti,
which has won court judgments against Guerin for the $189.9 million,
contends the pension payments should go to the company instead.
"We've collected something close to $3
Article 134 of 149, 1995313084
Pu blish ed on Nov em ber 9 , 1 9 9 5 , I n t elligen cer

JUDGE DISMISSES TAX EVASION CHARGES AGAINST

ISC'S JASIN
Acting on the recommendation of prosecutors, a federal judge dismissed tax
evasion and false filing charges against a former executive of International
12/25/2007 10:36 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
410
408 of
of 456
454
June 14, 2016
Need a
Websit e?
Signal & Control Corp.

Thomas P. Jasin, 50, of 2473 Butter Road, was indicted by a federal grand
jury in August on two counts of violating the U.S. Tax Code - one for filing a
false income tax return in 1988 and one for tax evasion for allegedly hiding
taxable income he and his wife, Mary Jane, earned in 1987. If federal
Article 135 of 149, 1995313031
Pu blish ed on Nov em ber 9 , 1 9 9 5 , Lan cast er New

Er a ( PA)
TAX CHARGES AGAINST EX-ISC EXEC DROPPED

A timing technicality has led to the dismissal of a pair of federal tax charges
against former ISC executive Thomas P. Jasin.
The tax evasion and false filing charges were thrown out Oct. 31 by U.S.
District Judge Franklin S. Van Antwerpen in Philadelphia. Federal
prosecutors thought they had secured a further extension of the six-year
statute of limitations for the case, according to a source familiar with the
proceeding.
But, due to an error in the paperwork, the extra extension was
Article 136 of 149, 1995286010
Pu blish ed on Oct ober 1 3 , 1 9 9 5 , Lan cast er New

Er a ( PA)
FERRANTI CLAIMS EXECUTIVE FRAUD

When ISC executive Thomas P. Jasin claimed on a 1988 expense account
that he took business prospects to hear the Orlando Symphony, two
problems arose.
There was no Orlando Symphony, and Jasin's $974 in receipts were for
weekend passes at Orlando's Disney World and meals at Epcot Center.
Discovery of such discrepancies led to the conclusion that Jasin embezzled
more than $350,000 from International Signal & Control and its successor,
Ferranti
Article 137 of 149, 1995223033
Pu blish ed on Au gu st 1 1 , 1 9 9 5 , Lan cast er New

Er a ( PA)
FORMER ISC EXEC INDICTED AGAIN

A former executive of International Signal & Control has been indicted
again, this time for allegedly cheating on his income taxes.
Thomas P. Jasin, who was convicted of smuggling conspiracy in December
1992, was accused Tuesday of two counts of tax wrongdoing. If convicted of
the tax violations, Jasin faces up to five years in prison, three years of
probation and a $250,000 fine.
He has been free on bail pending sentencing of his 1992 smuggling
conspiracy conviction, which
Article 138 of 149, 1995138100

( Lancast er , PA)
HARRY D. HEIST, 37, HAD WORKED AT ISC
2 of 3
12/25/2007 10:36 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
411
409 of
of 456
454
June 14, 2016
Harry D. Heist, 37, of 6726 Kings Highway South, Zionsville, Lehigh County,
died Tuesday at Lehigh Valley Hospital Center, Salisbury Township, as the
result of a motor vehicle accident.
Heist had worked for the former International Signal and Control Company,
Lancaster, for 14 years. At the time of his death he was employed as an
electrical maintenance technician by Luther Crest, Allentown.
Born in Allentown, he was a son of Floyd N. and Loretta E. Dunstan Heist of
Zionsville.
He
Article 139 of 149, 1995138025
Pu blish ed on May 1 8 , 1 9 9 5 , Lan cast er New Er a

( PA)
HARRY D. HEIST, 37, FORMER ISC EMPLOYEE

Harry D. Heist, 37, of 6726 Kings Highway South, Zionsville, Lehigh County,
died Tuesday at Lehigh Valley Hospital, Allentown.
He had been in the hospital since he was involved in a motor vehicle
accident in April, a family spokesman said. Heist had worked for the former
International Signal and Control, Lancaster, for 14 years.
At the time of his death he was employed as an electrical maintenance
technician by Luther Crest, Allentown.
Born in Allentown, he was a son of Floyd N. and
Article 140 of 149, 1995135098

( Lancast er , PA)
THEY FORMED A BUSINESS BOND WITH FRIENDSHIP

Growing up, Les Lipman was often benched for wreaking havoc at the pool
he belonged to, sometimes before he even got into the water.
"As soon as I walked in they'd say, "Hey, how are ya doing? Let's have a
seat," says Lipman. When he protested that he hadn't even done anything,
the lifeguards replied, "You will." That was the early 1970s. Today, Lipman is
a business partner with one of those
Cont ent m ay not be republished w it hout

perm ission.
2 0 0 4 - 2 0 0 7 La n ca st e r Ne w sp a p e r s
PO B o x 1 3 2 8 , L a n c a s t e r PA 1 7 6 0 8 , ( 7 1 7 ) 2 9 1 - 8 8 1 1
T e r m s o f S e r v i c e Pr i v a c y Po l i c y
3 of 3
12/25/2007 10:36 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
412
410 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3
Article 121 of 149, 1997044280
Pu blish ed on Febr u ar y 1 3 , 1 9 9 7 , Lan cast er New

Er a ( PA)
LATEST GUERIN CHAPTER: A FRAUDULENT DIVORCE?
Go

The Bedst ead.
M a rk et pla ce

>>
3 W a t t La r g e
Si l i co n e Bu l b
Ol d e Mi l l
L i g h t i n g $ 1 .6 5
Pe n n S t a t e T a i l g a t e G r i l l
Pr o p a n e
S t e r m e r B r o t h e r s $ 0 .0 0
James H. Guerin - admitted smuggler, tax cheat, money launderer and

phony-contract author - is being suspected of a new offense:
Fraudulent divorce. In the ongoing battle over who gets Guerin's
$2,700-a-month pension, the pension plan administrator says Guerin's
divorce might be an attempt to preserve the money for his ex-wife, Helen.
"The case is the latest installment in a 15-year fraud perpetrated by James
H. Guerin against his former employer,
Article 122 of 149, 1997032211
Pu blish ed on Febr u ar y 1 , 1 9 9 7 , Lan cast er New

Er a ( PA)
MAPMAKING FIRM MOVING TO ISC SITE

1 8 - k t . Go l d
Ver m eil
Ch a m p a g n e
CZ D a n g l e
GeoSystems Global Corp. will occupy the vacant 62,000-square-foot,
Neck lace- 1 8 k t .
one-story office building this May, said David R. Bowen, corporate
Go l d o v e r SS
manager of human resources and facilities. GeoSystems will vacate its
Ch a m p a g n e
leased 25,000-square-foot office at 53 W. James St., where 60 employees
CZ D a n g l e
work, and its leased 22,000-square-foot office at 227 Granite Run Drive,
Neck lace
where 85
$ 3 9 .9 9
A city-based mapmaking firm will move into the former headquarters of
International Signal & Control outside Mountville.
1 4 - k t . Ye l l o w G o l d
Fa s h i o n R i n g - S i z e 8
$ 1 9 9 .9 9
Article 123 of 149, 1996358068
Published on Decem ber 2 3 , 1 9 9 6 , I nt elligencer

MURIEL R. HORTON, 60, RETIRED SECRETARY

Muriel R. "Midge" Horton, 60, of 509 Koser Road, Lititz, died at home
Saturday after a long illness.
She was the wife of Bruce R. Horton. They observed their 40th anniversary
in July. Born in Patton, Maine, she was the daughter of Virginia Kennedy
Glidden of Lancaster and the late Chester Glidden.
She worked as a receptionist for the former International Signal and Control
Corp. for 17 years, retiring in 1993.
Mrs. Horton was past treasurer of the ISC Credit
Article 124 of 149, 1996356037
Pu blish ed on Decem ber 2 1 , 1 9 9 6 , Lan cast er New

Er a ( PA)
WHY IS ISC EXEC STILL NOT IN JAIL?

PHILADELPHIA - Former ISC executive Thomas P. Jasin could have
12/25/2007 10:35 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
413
411 of
of 456
454
June 14, 2016
Need a
Websit e?
completed almost all of his prison term by now.

Instead, four years after a jury found him guilty of conspiring to smuggle
arms to South Africa, the Manheim Township resident has yet to start it.
Jasin, 51, who faces a five-year sentence, remains free on $100,000 bail
while a federal judge weighs his 1993 request to see classified Central
Intelligence Agency documents.
The secret documents are believed to answer the largest
Article 125 of 149, 1996284014

Er a ( PA)
MACHINE FIRM BUYS EX-FERRANTI SITE, WILL

EXPAND
Timothy N. Reist had been pondering for a long time whether to go into
business for himself.
Then his employer, Bulova Technologies, nudged him into a decision - by
laying him off after eight years on the job. Reist, a machinist, opted to
start his own company. Now, five years later, it seems that he made a
wise choice.
Reist and his wife, Joanne, have bought a Mountville area building so they
can expand their firm, Reist Precision Machine.
They bought a 3,500-square-foot building
Article 126 of 149, 1996261179
Pu blish ed on Sept em ber 1 7 , 1 9 9 6 , I n t elligen cer

RICHARD HOFFMAN, 73, WAS ISC RETIREE

Former Lancaster resident Richard E. "Dick" Hoffman, 73, of 8351-B S.W.
93rd Lane, Ocala, Fla., died Saturday at Lancaster General Hospital.
An employee at RCA and International Signal & Control, Hoffman retired in
1987 and moved to Ocala. He and his wife of 52 years, Dorothy J. Stuart
Hoffman, were formerly of 362 Ruth Ridge Drive.
Born in Steelton, he was the son of the late Clark and Carrie Hoffman. A
graduate of Steelton High School, he earned his
Article 127 of 149, 1996139081
Pu blish ed on May 1 8 , 1 9 9 6 , Lan cast er New Er a

( PA)
10 NEW ERA STAFFERS HONORED

Ten Lancaster New Era staff members were honored today for excellence
in journalism in statewide newspaper award ceremonies in State College.
A team of reporters took a first place prize in the New Era's division in the
Keystone Press Awards, sponsored by the Pennsylvania Society of
Newspaper Editors. The top honor was for best deadline news reporting for
coverage of the February 1995 fire at Reifsnyder's music store on South
Queen Street.
The Keystone awards
2 of 3
12/25/2007 10:35 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
414
412 of
of 456
454
June 14, 2016
Article 128 of 149, 1996119194
Pu blish ed on Apr il 2 8 , 1 9 9 6 , Su n day New s

( Lancast er , PA)
BOMBS WITH OUR NAMES ON THEM

In remote areas of Laos, villagers sometimes plant herbs in shell casings
left over from the Vietnam War.
Some of the casings still have manufacturer's tags on them, said Titus
Peachey, of Lancaster. Brush the dirt away and you will find the names of
American towns and companies. "It was always for me a feeling of sadness
to see my own country represented in that way."
Part of a worldwide campaign to ban land mines and other anti-personnel
bombs,
Article 129 of 149, 1996081169
Pu blish ed on Mar ch 2 1 , 1 9 9 6 , Lan cast er New Er a

( PA)
FEDS SEEK MENTAL TEST FOR LIPKA

PHILADELPHIA - A federal prosecutor wants accused spy Robert Stephan
Lipka to undergo a psychiatric examination.
Assistant U.S. Attorney Barbara J. Cohan asked a federal judge today to
order tests to establish that the Manor Township man is competent to stand
trial. Also today, an FBI agent disclosed that Lipka once claimed to have
laundered money for Oliver L. North and James H. Guerin, and to have
seen evidence that Richard M. Nixon was a Soviet spy.
In her court filing, Cohan noted
Article 130 of 149, 1996032198
Pu blish ed on Febr u ar y 1 , 1 9 9 6 , I n t elligen cer

FERRANTI SELLS OFF LAST U.S. BUSINESS

Ferranti International Inc. has sold the last of its 16 businesses in the United
States, completing the divestiture of its operating companies.
Lancaster-based Ferranti sold Mountain Optec Inc. of Boulder, Colo., to
Phillips Services Industries Inc. A price was not disclosed, but it consists of
an initial payment plus future payments based on the firm's performance
over the next two years.
Mountain Optec toughens optical disk drives that gather, store and play data,
so they

perm ission.
3 of 3
12/25/2007 10:35 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
415
413 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Article 111 of 149, 1991203248
Published on Apr il 30, 1997, I nt elligencer Jour nal

( Lancast er , PA)
WHAT IS AMERICA COMING TO?
Go

The Bedst ead.
M a rk et pla ce

>>
Am im oc
Pa p o o s e
Deer sk in
Mo ccasi n
Men ' s & La d i es
# 51023
$ 6 9 .0 0
R e a l M e n Fr y T u r k e y s
Ap r on
To the Editor:
What is our United States coming to! Michelle Lambert and O. J. Simpson
are both murderers, but are free. Robert Clyde Ivy and Jim Guerin are
architects of a $1.14 billion scam at ISC to put Ferranti International out of
business and put thousands of honest workers out of jobs. Ivy got six
months in jail and six months of home detention. Guerin got 15 years in
prison for one of the worst U.S. financial crimes ever committed in this
country. Our president is in a scandal every
Article 112 of 149, 1991132950
Pu blish ed on Apr il 2 3 , 1 9 9 7 , Lan cast er New Er a

( PA)
IT'S NOT JUST LAMBERT, CRIMINALS AREN'T

PUNISHED
Editor, New Era:
14- kt . Whit e
What is our United States coming to!!! Michelle Lambert and O.J. Simpson
Go l d 3 / 4 - ct .
are both murderers, but are free. Robert Clyde Ivy and Jim Guerin are
Diam ond
architects of a $1.14 billion scam at ISC to put Ferranti International out of
T h r e e Ro w
business and put thousands of honest workers out of jobs. What did they get
Fl e x i b l e
in prison? Clyde Ivy got six months in jail and six months of home
Wedding
detention. Guerin got 15 years in prison for one of the worst U.S. financial
Ban d - size 7
crimes ever committed in this
$ 5 6 9 .9 9
D i a m o n d Pi n k
T o u r m a l i n e Pe n d a n t
$ 9 6 .9 9
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 4
Article 113 of 149, 1990962489
Pu blish ed on Apr il 6 , 1 9 9 7 , Su n day New s

( Lancast er , PA)
EX-ISC EXEC, IN MAKING A DEAL, ADMITS

SMUGGLING TO S. AFRICA
In what may be the final chapter of the long-running ISC court case, a
former ISC top executive, Robert Clyde Ivy, admitted in federal court
Friday that he smuggled arms to South Africa.
Facing 52 counts of corporate crime and the potential of 515 years in prison
and a $44 million dollar fine, Ivy opted for a plea bargain with federal
prosecutors after a series of setbacks in his defense. Prosecutors agreed
to lessen the charges to one count of smuggling conspiracy in exchange for
Article 114 of 149, 1990951690
Pu blish ed on Apr il 5 , 1 9 9 7 , Lan cast er New Er a

( PA)
EX-ISC EXEC PLEADS GUILTY TO SMUGGLING
12/25/2007 10:34 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
416
414 of
of 456
454
June 14, 2016
Need a
Websit e?
Robert Clyde Ivy, the former top ISC executive who eluded trial for 5 1/2
years, admitted in federal court Friday that he smuggled arms to South
Africa.
The Lancaster resident pleaded guilty to one count of smuggling conspiracy,
bringing the prosecution of one of America's largest corporate crimes nearly
to a close. Of 20 companies and individuals indicted in the ISC case in
October 1991, Ivy faced the most charges - 52 counts, posing up to 515
years in prison and a $44 million
Article 115 of 149, 1997066321
Published on Mar ch 7 , 1 9 9 7 , I nt elligencer Jour nal

( Lancast er , PA)
RUTH FRIEDEL, 67, LIVED IN LANCASTER

Ruth N. Friedel, 67, of 761 Stoney Battery Road, died Thursday from injuries
sustained in a car crash, according to Lancaster County coroner Dr. Barry
Walp.
She was found in cardiac arrest following a five-vehicle accident along
Rohrerstown Road late Wednesday night. Born in Lancaster, she was a
daughter of the late Jack and Naomi G. Erb Patterson.
A lifelong resident of the Lancaster area, she had attended McCaskey High
School.
She had worked at Willow Valley Market as a deli clerk
Article 116 of 149, 1997066248
Pu blish ed on Mar ch 7 , 1 9 9 7 , Lan cast er New Er a

( PA)
RUTH N. FRIEDEL, 67, WAS DELI CLERK

Ruth N. Friedel, 67, of 761 Stoney Battery Road, died unexpectedly
Thursday.
An autopsy has been ordered. Mrs. Friedel was found in cardiac arrest
following a five-vehicle accident along Rohrerstown Road late Wednesday
night. Born in Lancaster, she was a daughter of the late Jack and Naomi G.
Erb Patterson.
A lifelong resident of the Lancaster area, she had attended McCaskey High
School.
She had worked at Willow Valley Market as a deli clerk for two years and,
prior to that, at ISC
Article 117 of 149, 1997059329
Pu blish ed on Febr u ar y 2 8 , 1 9 9 7 , I n t elligen cer

JUDGE FINES THREE FIRMS TIED TO ISC

PHILADELPHIA - Three South African companies that were part of an
international arms smuggling operation masterminded by International Signal
& Control were fined a total of $12.5 million Thursday.
The plea agreement in federal court here is another sign that the Republic of
South Africa and the United States are taking positive steps toward
normalizing relations. Both governments have sought for the past five
years to resolve charges of arms smuggling brought by the U.S.
2 of 4
12/25/2007 10:34 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
417
415 of
of 456
454
June 14, 2016
Article 118 of 149, 1997059266

Er a ( PA)
FEDS ADD MUSCLE IN LEGAL FIGHT AGAINST

FORMER ISC EXEC
PHILADELPHIA - When South Africa went shopping for high-tech arms in
the 1980s, former ISC executive Robert Clyde Ivy was virtually a
Wal-Mart of weaponry, federal prosecutors allege.
The Lancaster resident helped smuggle into South Africa dozens of kinds of
sophisticated electronic parts for the country's fighter aircraft, helicopters,
missiles and artillery shells, they say. Now, following events here
Thursday, federal prosecutors hoping to convict Ivy of smuggling,
securities
Article 119 of 149, 1997058304

Er a ( PA)
ISC PARTNERS ENTER PLEAS ON SMUGGLING

PHILADELPHIA - International Signal & Control's corporate arms smuggling
partners in South Africa finally came to justice here today.
More than five years after their indictment, three South African weapons
companies appeared in U.S. District Court this morning on charges they
participated in the $50 million scheme. One company pleaded guilty and two
pleaded no contest.
The three firms agreed to pay a total of $12.5 million in fines.
As part of a plea
Article 120 of 149, 1997045298

GUERIN ACCUSED OF GETTING FRAUDULENT

DIVORCE
Imprisoned arms smuggler James H. Guerin has apparently come up with a
new scam while spending his 15 years behind bars.
This time, a fraudulent divorce to ensure his ex-wife, Helen, gets his
disputed $2,700-a-month pension, said the pension plan's administrator and
former Guerin employee, James P. Shinehouse. "The case is the latest
installment in a 15-year fraud perpetrated by James H. Guerin against his
former employer, Ferranti International Inc.,"

perm ission.
3 of 4
12/25/2007 10:34 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
418
416 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3
Article 101 of 149, 1998198117
Published on July 17, 1998, I nt elligencer Jour nal

( Lancast er , PA)
FORMER ISC EXECUTIVE GETS 2 YEARS IN PRISON
Go

The Bedst ead.
M a rk et pla ce

>>
PHILADELPHIA - After waiting almost six years to be sentenced, a former

executive with International Signal & Control Corp. was allowed to remain
free when a federal judge finally meted out his punishment Thursday.
U.S District Judge Jan E. DuBois, after listening to hours of impassioned
remarks from Thomas P. Jasin's defense attorney, departed from the
federal sentencing guidelines mandating five years in prison and sentenced
the Manheim Township man to two years in
" B o r d e r Cr o s s i n g "
Wall Scon ce 2 7
St ain less St eel Kn if e w it h
Ol d e Mi l l
Sh eat h
L i g h t i n g $ 6 0 .0 0
Co y o t e T r a i l s $ 1 2 .5 0
Article 102 of 149, 1998198035
Pu blish ed on Ju ly 1 7 , 1 9 9 8 , Lan cast er New Er a

( PA)
JUDGE GIVES FORMER ISC EXEC A BREAK

PHILADELPHIA - For eight hours here Thursday, federal judge Jan E.
DuBois sounded like he'd throw the book at Thomas P. Jasin.
As defense attorneys raised argument after argument for leniency, time
and again DuBois agreed with prosecutors in rejecting them. Until the ninth
hour came.
S u u n t o Cr o s s
Sp or t s Hear t
Ra t e W a t c h
$ 1 2 0 .9 9
St er lin g Silv er Hoop

Fa s h i o n Ea r r i n g s
$ 1 7 .9 9
Instead of sentencing the former ISC executive to five years in prison, as

prescribed by federal sentencing guidelines, DuBois used his discretion to
sentence Jasin to two years.
DuBois then
Article 103 of 149, 1998197101

( Lancast er , PA)
FORMER ISC EXEC FACES SENTENCING TODAY

A former executive of International Signal & Control Corp. who was
convicted in December 1992 of conspiring to smuggle arms to South
Africa will finally be sentenced today in a Philadelphia federal courtroom.
Thomas P. Jasin, 53, of 2473 Butter Road, faces a five-year prison
sentence mandated by federal sentencing guidelines when he appears
before U.S. District Judge Jan E. DuBois at 10 a.m. Jasin's crimes were
discovered during a federal investigation into
Article 104 of 149, 1998197001

( PA)
FORMER ISC EXEC BEING SENTENCED

PHILADELPHIA - It's been nearly seven years since Thomas P. Jasin was
indicted in the International Signal & Control case.
12/25/2007 10:33 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
419
417 of
of 456
454
June 14, 2016
Need a
Websit e?
It's been 5 1/2 years since a federal court jury convicted him of conspiring
to help ISC smuggle weapons to South Africa. Now, a baffling series of
delays apparently has run its course.
The Lancaster man was scheduled to be sentenced in federal court here
today. He faces up to five years in prison and a $250,000 fine.
Jasin,
Article 105 of 149, 1998175132

( Lancast er , PA)
ACME NAMED AS TENANT FOR HUGE E. COCALICO

WAREHOUSE COMPLEX
The developer of a massive food distribution center has finally revealed
who will occupy the East Cocalico complex: Acme Markets.
Thomas D. Smithgall, director of development for the real estate arm of
High Industries Inc., announced Tuesday that American Stores Co., the Salt
Lake City-based owner of Acme Markets, bought the land in the Turnpike
21 Business Park. It's been two years since "Project 264" hit the drawing
board, and as expected with
Article 106 of 149, 1998109071
Pu blish ed on Apr il 1 9 , 1 9 9 8 , Su n day New s

( Lancast er , PA)
MONDAY
April 13 - In the ongoing story of Lisa Michelle Lambert and her quest to be
released from prison and from her murder conviction in the death of Laurie
Show, Lambert's attorneys argued that they should be paid out-of-pocket
expenses by Lancaster County. They said the cost could be more than
$100,000. Tuesday, Judge Lawrence Stengel modified his gag order to
allow relatives and witnesses to talk to the
Article 107 of 149, 1998107114

( Lancast er , PA)
FEDERAL JUDGE AGREES TO HEAR GUERIN APPEAL

A federal judge has agreed to hold a hearing concerning former Lancaster
businessman James H. Guerin's contention that he was ineffectively
represented when he pleaded guilty in 1991 to a number of crimes, including
money laundering and illegal arms sales.
Guerin, 68, is currently serving a 15-year prison sentence in a federal
prison in Florida. He was once one of Lancaster County's most prominent
philanthropists and business leaders. The hearing will be held
Article 108 of 149, 1998015016

Er a ( PA)
W. HEMPFIELD WAREHOUSE A TALL ORDER

A Lancaster company plans to develop a $3.2 million warehouse and
2 of 3
12/25/2007 10:33 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
420
418 of
of 456
454
June 14, 2016
distribution center at the Ferranti International Inc. campus in West
Hempfield Township.
D. Kasun Associates has purchased 10 acres at Hempland Road from
Ferranti for $562,500. Kasun's company, Kasun Development Corp.,
intends to build a 140,000-square-foot warehouse on the tract, according to
Vice President Lee Kasun. The structure will have 30-foot-high ceilings to
allow for tall storage space.
Article 109 of 149, 1997225504
Pu blish ed on Au gu st 1 3 , 1 9 9 7 , I n t elligen cer

GUERIN ASKS JUDGE TO FREE HIM FROM JAIL

Former Lancaster businessman James H. Guerin - who is serving a 15-year
prison sentence after pleading guilty in 1991 to a number of crimes,
including money laundering and illegal arms sales - has asked a federal
judge to free him.
Guerin, 67, who is incarcerated in a federal prison in Florida, was once one
of Lancaster County's most prominent philanthropists and business leaders.
Guerin's motion before Chief U.S. Judge Louis C. Bechtle accuses Joseph
Tate, his
Article 110 of 149, 1997155392
Pu blish ed on Ju n e 4 , 1 9 9 7 , Lan cast er New Er a

( PA)
THEY OVERCOME OBSTACLES TO WIN CHAMBER

AWARDS
Susan E. Savage and Shaun Balani can tell you about surprises on the
route to success.
Savage, now president of Abel/Savage Marketing and Communications Inc.,
discovered she was pregnant shortly before she started her freshman year
at Franklin and Marshall College. Balani, president of Travel Time Travel
Agency Inc., said a business broker stole his family's savings while helping
him look for a company to buy.
On Thursday, the two will receive awards from The Lancaster

perm ission.
3 of 3
12/25/2007 10:33 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
421
419 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3
Article 91 of 149, 1998261094

GUERIN REVISITED
Go

The Bedst ead.
M a rk et pla ce
Visit t he
M ark et place > >
Six years ago the attorney for James H. Guerin called his client "the
embodiment of the American dream and the American tragedy."
As Guerin was about to be sentenced for fraud, money laundering and illegal
arms sales, Joseph A. Tate spoke of Guerin's "zeal" to expand his
Lancaster-based company, his many philanthropic works in the community,
his deep spiritual beliefs and his loving family. "We ask you to fashion a
Go l f B a l l s
Po r c e l a i n Fe a t h e r
L a n c a s t e r O n l i n e Je w e l r y " H a l f W o l f Fa c e "
$ 1 3 .3 0
Co y o t e T r a i l s $ 1 8 .0 0
Article 92 of 149, 1998260097

GUERIN: LAWYERS BROKE PROMISES

PHILADELPHIA - James H. Guerin took the witness stand in a federal
courtroom Wednesday and admitted that he lied to his defense attorneys
one or two times from 1989 to 1991.
1 4 - k t . Ye l l o w
Go l d He a r t
Pe n d a n t
$ 7 8 .9 9
1 4 k t W h i t e Go l d 3 / 8 - ct
D i a m o n d a n d Ci t r i n e
Ea r r i n g s
$ 2 7 0 .9 9
Guerin, 68, also told Assistant U.S. Attorney Robert E. Goldman that there
were six times when the government "showed me a conflict" in information
he provided as part of a plea agreement he signed in 1992. Wednesday
marked the second and final day of a hearing before U.S. Magistrate Judge
Diane
Article 93 of 149, 1998260035
Pu blish ed on Sept em ber 1 7 , 1 9 9 8 , Lan cast er

New Er a ( PA)
GUERIN CLAIMS HE WAS DECEIVED BY ATTORNEY

PHILADELPHIA - Deceit is what landed former Lancaster businessman
James H. Guerin in federal prison for 15 years.
Now a federal judge will decide in the coming weeks whether Guerin is using
his old tactic to try to get out. Guerin, the founder of now-defunct
International Signal & Control, testified for two hours here Wednesday,
concluding a two-day hearing on his bid for a reduced sentence.
At issue was essentially just one thing:
Whether Guerin was truthfully
Article 94 of 149, 1998259163

EX-ATTORNEYS CALL GUERIN A HABITUAL LIAR
12/25/2007 10:32 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
422
420 of
of 456
454
June 14, 2016
Need a
Websit e?
PHILADELPHIA - Two of James H. Guerin's former attorneys testified

Tuesday that their ex-client was just what federal prosecutors have called
him for nearly 10 years: a habitual liar.
Philadelphia attorneys Joseph A. Tate and Stephen D. Brown testified in
federal court that Guerin told one lie after another to federal prosecutors
probing criminal wrongdoing within his Lancaster-based defense contracting
firm, International Signal & Control Corp. The attorneys said
Article 95 of 149, 1998259035

New Er a ( PA)
FORMER ATTORNEY TESTIFIES GUERIN LIED TO

GOVERNMENT, DEFENSE TEAM
PHILADELPHIA - Former Lancaster businessman James H. Guerin never
grasped a simple concept, his ex-attorney testified here Tuesday:
Honesty is the best policy. In a remarkable three hours in federal court,
Joseph A. Tate said his one-time client frequently lied not only to
government investigators, but to his own defense attorneys as well.
"Jim and I had a falling out over my view that, very often, Jim would rewrite
history," said Tate.
Tate's
Article 96 of 149, 1998258077

GUERIN CLAIMS ATTORNEY WAS INCOMPETENT

Former Lancaster businessman James H. Guerin will be back in federal
court today to try to convince a judge his attorney was ineffective in 1991
when Guerin pleaded guilty to fraud, money laundering and illegal arms
sales.
The 68-year-old Guerin, once one of Lancaster County's most prominent
philanthropists and business leaders, is serving a 15-year sentence in
Florida. Guerin was the founder of International Signal & Control Corp.,
which employed 1,800 people in
Article 97 of 149, 1998258002

New Er a ( PA)
GUERIN WANTS JAIL SENTENCE REDUCED

PHILADELPHIA - The last time James H. Guerin appeared in federal court
here, he was dispatched with a 15-year prison sentence.
Today, six years into that sentence, the former Lancaster businessman
came back to argue that his penalty was too harsh. Guerin's request to be
resentenced was getting under way at presstime. He was expected to
testify at length in the courtroom of U.S. Magistrate Judge Diane M. Welsh.
The founder of the now-defunct International Signal &
Article 98 of 149, 1998248062
2 of 3
12/25/2007 10:32 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
423
421 of
of 456
454
June 14, 2016
Pu blish ed on Sept em ber 5 , 1 9 9 8 , I n t elligen cer
JOSEPH F. MICKOSEFF, 44, WAS ASSEMBLER

Joseph F. Mickoseff, 44, of 6088 Sundra Circle, East Petersburg, died
Thursday afternoon at home after a lengthy illness.
He was an assembler of automatic machines for the last three years at
Synergistech, Lewisberry. From 1983 to 1995, he worked for the former
ISC Corp., Lancaster, as a tool maker. A 1972 graduate of Nativity High
School, Pottsville, he earned an associate's degree in art from Penn State
University and an associate's degree from Williamsport Area
Article 99 of 149, 1998199066

( Lancast er , PA)
PAULINE BEAM, 79, WAS ISC EMPLOYEE

Pauline A. Beam, 79, of 1726 Sammar Road, died Thursday evening at
Lancaster General Hospital of natural causes.
She worked at International Signal Control from 1980 to 1990, when she
retired. She previously worked for the former Schick Inc., Lancaster, for 24
years. She was of the Protestant faith.
Born in West Earl Township, she was the daughter of the late Frank and
Mary Gamber Adams.
She was the wife of Lester J. Beam, who died in 1989.
Surviving are a grandson, Shawn Beam
Article 100 of 149, 1998199013

( PA)
PAULINE A. BEAM, 79, ISC RETIREE

She worked at International Signal and Control from 1980 to 1990, when she
retired. She previously worked for the former Schick Inc. for 24 years. Born
in West Earl Township, she was the daughter of the late Frank and Mary
Gamber Adams.
Surviving are a grandson and a sister, Anna G. Sweigart of Ephrata.
She was

perm ission.
3 of 3
12/25/2007 10:32 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
424
422 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3
Article 91 of 149, 1998261094

GUERIN REVISITED
Go

The Bedst ead.
M a rk et pla ce
Visit t he
M ark et place > >
Six years ago the attorney for James H. Guerin called his client "the
embodiment of the American dream and the American tragedy."
As Guerin was about to be sentenced for fraud, money laundering and illegal
arms sales, Joseph A. Tate spoke of Guerin's "zeal" to expand his
Lancaster-based company, his many philanthropic works in the community,
his deep spiritual beliefs and his loving family. "We ask you to fashion a
Go l f B a l l s
Po r c e l a i n Fe a t h e r
L a n c a s t e r O n l i n e Je w e l r y " H a l f W o l f Fa c e "
$ 1 3 .3 0
Co y o t e T r a i l s $ 1 8 .0 0
Article 92 of 149, 1998260097

GUERIN: LAWYERS BROKE PROMISES

PHILADELPHIA - James H. Guerin took the witness stand in a federal
courtroom Wednesday and admitted that he lied to his defense attorneys
one or two times from 1989 to 1991.
1 4 - k t . Ye l l o w
Go l d He a r t
Pe n d a n t
$ 7 8 .9 9
1 4 k t W h i t e Go l d 3 / 8 - ct
D i a m o n d a n d Ci t r i n e
Ea r r i n g s
$ 2 7 0 .9 9
Guerin, 68, also told Assistant U.S. Attorney Robert E. Goldman that there
were six times when the government "showed me a conflict" in information
he provided as part of a plea agreement he signed in 1992. Wednesday
marked the second and final day of a hearing before U.S. Magistrate Judge
Diane
Article 93 of 149, 1998260035

New Er a ( PA)
GUERIN CLAIMS HE WAS DECEIVED BY ATTORNEY

PHILADELPHIA - Deceit is what landed former Lancaster businessman
James H. Guerin in federal prison for 15 years.
Now a federal judge will decide in the coming weeks whether Guerin is using
his old tactic to try to get out. Guerin, the founder of now-defunct
International Signal & Control, testified for two hours here Wednesday,
concluding a two-day hearing on his bid for a reduced sentence.
At issue was essentially just one thing:
Whether Guerin was truthfully
Article 94 of 149, 1998259163

EX-ATTORNEYS CALL GUERIN A HABITUAL LIAR
12/25/2007 10:31 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
425
423 of
of 456
454
June 14, 2016
Need a
Websit e?
PHILADELPHIA - Two of James H. Guerin's former attorneys testified

Tuesday that their ex-client was just what federal prosecutors have called
him for nearly 10 years: a habitual liar.
Philadelphia attorneys Joseph A. Tate and Stephen D. Brown testified in
federal court that Guerin told one lie after another to federal prosecutors
probing criminal wrongdoing within his Lancaster-based defense contracting
firm, International Signal & Control Corp. The attorneys said
Article 95 of 149, 1998259035

New Er a ( PA)
FORMER ATTORNEY TESTIFIES GUERIN LIED TO

GOVERNMENT, DEFENSE TEAM
PHILADELPHIA - Former Lancaster businessman James H. Guerin never
grasped a simple concept, his ex-attorney testified here Tuesday:
Honesty is the best policy. In a remarkable three hours in federal court,
Joseph A. Tate said his one-time client frequently lied not only to
government investigators, but to his own defense attorneys as well.
"Jim and I had a falling out over my view that, very often, Jim would rewrite
history," said Tate.
Tate's
Article 96 of 149, 1998258077

GUERIN CLAIMS ATTORNEY WAS INCOMPETENT

Former Lancaster businessman James H. Guerin will be back in federal
court today to try to convince a judge his attorney was ineffective in 1991
when Guerin pleaded guilty to fraud, money laundering and illegal arms
sales.
The 68-year-old Guerin, once one of Lancaster County's most prominent
philanthropists and business leaders, is serving a 15-year sentence in
Florida. Guerin was the founder of International Signal & Control Corp.,
which employed 1,800 people in
Article 97 of 149, 1998258002

New Er a ( PA)
GUERIN WANTS JAIL SENTENCE REDUCED

PHILADELPHIA - The last time James H. Guerin appeared in federal court
here, he was dispatched with a 15-year prison sentence.
Today, six years into that sentence, the former Lancaster businessman
came back to argue that his penalty was too harsh. Guerin's request to be
resentenced was getting under way at presstime. He was expected to
testify at length in the courtroom of U.S. Magistrate Judge Diane M. Welsh.
The founder of the now-defunct International Signal &
Article 98 of 149, 1998248062
2 of 3
12/25/2007 10:31 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
426
424 of
of 456
454
June 14, 2016
Pu blish ed on Sept em ber 5 , 1 9 9 8 , I n t elligen cer
JOSEPH F. MICKOSEFF, 44, WAS ASSEMBLER

Joseph F. Mickoseff, 44, of 6088 Sundra Circle, East Petersburg, died
Thursday afternoon at home after a lengthy illness.
He was an assembler of automatic machines for the last three years at
Synergistech, Lewisberry. From 1983 to 1995, he worked for the former
ISC Corp., Lancaster, as a tool maker. A 1972 graduate of Nativity High
School, Pottsville, he earned an associate's degree in art from Penn State
University and an associate's degree from Williamsport Area
Article 99 of 149, 1998199066

( Lancast er , PA)
PAULINE BEAM, 79, WAS ISC EMPLOYEE

She worked at International Signal Control from 1980 to 1990, when she
retired. She previously worked for the former Schick Inc., Lancaster, for 24
years. She was of the Protestant faith.
Born in West Earl Township, she was the daughter of the late Frank and
Mary Gamber Adams.
Surviving are a grandson, Shawn Beam
Article 100 of 149, 1998199013

( PA)
PAULINE A. BEAM, 79, ISC RETIREE

She worked at International Signal and Control from 1980 to 1990, when she
retired. She previously worked for the former Schick Inc. for 24 years. Born
in West Earl Township, she was the daughter of the late Frank and Mary
Gamber Adams.
Surviving are a grandson and a sister, Anna G. Sweigart of Ephrata.
She was

perm ission.
3 of 3
12/25/2007 10:31 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
427
425 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os

The Bedst ead.
Article 81 of 149, 1998289083
Pu blish ed on Oct ober 1 6 , 1 9 9 8 , I n t elligen cer

Go
FINAL SENTENCES MARK END OF ISC PROBES,

PROSECUTIONS

M a rk et pla ce
Visit t he
M ark et place > >
Thursday marked the end of 10 years of criminal probes and prosecutions of

employees of defunct Lancaster defense contractor International Signal &
Control Corp.
U.S. District Judge Jan E. DuBois sentenced the last two of six former ISC
employees who pleaded guilty to helping ISC founder James H. Guerin
smuggle arms to South Africa during the 1980s and/or mastermind a $1.14
billion fraud that destroyed a British defense contractor. Robert Resch, now
living in California, was
La n ca st e r
New sp ap er s
Lo g o Hat
La n ca st e r On l i n e
$ 8 .1 5
" Am er i ca n Tr a d i t i o n "
St e e l Kn i f e Gi f t Bo x e d
Co y o t e T r a i l s $ 7 .9 9
1 4 - k t . Ye l l o w
Go l d Ho o p
Ea r r i n g s
$ 6 9 .9 9
St er l i n g Si l v er Sp r i n g
Fl o w e r A n k l e t
$ 1 9 .9 9
Article 82 of 149, 1998289028

Er a ( PA)
TWO MORE DEFENDANTS SENTENCED IN ISC CASE

A federal judge explained Thursday why it took so long to give such short
sentences to six defendants in the International Signal & Control fraud and
smuggling case.
U.S. District Judge Jan E. DuBois in Philadelphia made the comments while
sentencing the last of the six to come before him this week - seven years
after their 1991 indicments. Anthony J. Stagg of Fountain Hills, Ariz., was
sentenced to three months of home confinement, three years probation and
ordered to pay
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3
Article 83 of 149, 1998288093

TWO MORE SENTENCED IN ISC CASE

A Marticville man will spend the next three months confined to his home for
his role in illegal arms sales to South Africa by a former Lancaster defense
contractor.
Terrance P. Faulds, a former procurement specialist for International Signal
& Control Corp., was sentenced Wednesday to three months of confinement
and three years' probation by U.S. District Judge Jan E. DuBois. Also
sentenced Wednesday was Gerald Schuler of New York, who operated a
freight-forwarding
Article 84 of 149, 1998288029

Er a ( PA)
2 MORE ISC WEAPONS SMUGGLERS SENTENCED

Two key players in International Signal & Control's smuggling operation were
12/25/2007 10:29 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
428
426 of
of 456
454
June 14, 2016
Need a
Websit e?
sentenced Wednesday for their roles in the scheme.

Terrance P. Faulds of Pequea was sentenced to three months of home
confinement and three years of probation. Gerald E. Schuler of West Islip,
N.Y., was sentenced to three months in jail and three months of home
confinement. He also was fined $3,500.
Both were sentenced in Philadelphia federal court by U.S. District Judge
Jan E. DuBois,
Article 85 of 149, 1998287167

GUERIN'S APPEAL IS REBUFFED BY JUDGE

Calling him "deceitful," a federal judge has recommended that former
Lancaster businessman James H. Guerin's request for a reduction in his
15-year prison sentence be denied.
Magistrate Judge Diane M. Welsh has forwarded her 25-page opinion,
issued Thursday, to Chief U.S. District Judge Louis C. Bechtel in
Philadelphia for final disposition. It was Bechtel who sentenced Guerin in
1992, after the former Lancaster business icon pleaded guilty to money
Article 86 of 149, 1998287174

ISC EXECUTIVES SENTENCED

Two former employees of now-defunct International Signal & Control Corp.
were sentenced Tuesday in a Philadelphia federal court room.
Wayne K. Radcliffe of Holtwood was sentenced by U.S. District Judge Jan
E. DuBois to six months in prison, followed by three months of house arrest.
He was also fined $7,500. Robert L. Shireman, a West Virginia resident who
was the Lancaster defense contractor's chief financial officer, was
sentenced to house arrest for six months,
Article 87 of 149, 1998287023

Er a ( PA)
2 FORMER ISC EXECUTIVES SENTENCED FOR THEIR

ROLES
Two former executives at International Signal & Control were sentenced
Tuesday for their roles in the company's massive fraud and smuggling
schemes.
Lancaster resident Wayne K. Radcliffe received six months in prison, three
years probation and a $7,500 fine, a federal prosecutor said. Former
Marietta-area resident Robert L. Shireman received six months of home
confinement, three years probation and a $7,500 fine, according to the
prosecutor.
Assistant U.S.
Article 88 of 149, 1998286072
2 of 3
12/25/2007 10:29 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
429
427 of
of 456
454
June 14, 2016
SIX EX-ISC OFFICIALS TO BE SENTENCED

After a seven-year wait, six former employees of the defunct Lancaster
defense contracting firm International Signal & Control Corp. will be
sentenced this week in a Philadelphia federal court room.
All have pleaded guilty to various roles in ISC's elaborate arms-smuggling
operation and/or to aiding ISC founder James H. Guerin in masterminding a
$1.14 billion fraud against former British defense giant Ferranti International
plc. And, according to court documents, all
Article 89 of 149, 1998270014
Pu blish ed on Sept em ber 2 7 , 1 9 9 8 , Su n day New s

( Lancast er , PA)
PAYING THE PRICE

Jim Guerin belongs in jail.
And since the federal judge in charge of his case isn't named Stewart
Dalzell, there's a chance he'll stay there. Mr. Guerin, the fallen angel of the
Lancaster County business community, is busy trying to persuade Judge
Louis Bechtle that his 15-year sentence for fraud, illegal weapons sales and
money laundering ought to be overturned. He was ill-served, Mr. Guerin
argues, by his own lawyers, who were in collusion with federal
Article 90 of 149, 1998263083
Pu blish ed on Sept em ber 2 0 , 1 9 9 8 , Su n day New s

( Lancast er , PA)

SUNDAY Sept. 13 - Fires continued to burn around the Pinnacle Overlook in
southern Lancaster County, but firefighters had them contained. Eight
firefighters were treated for exhaustion. The fires were brought under control
Monday.
`Police in West Virginia arrested John Dennis Grubb, who is wanted for 27
bank robberies in 10 states, including the Fulton Bank branch on Fruitville
Pike in Manheim Township. The break

perm ission.
3 of 3
12/25/2007 10:29 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
430
428 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Feat u r es
Article 71 of 149, 1999158117
Published on June 7 , 1 9 9 9 , I nt elligencer Jour nal

( Lancast er , PA)
Henning Webb Prentis built Armstrong Cork Co. into a leading national
industry, then became a crusader for the free enterprise system. Ideas he
advanced 60 years ago still echo in the speeches of today's political and
business leaders.
Guy Graybill Diehm took

Willow
Fl u s h m o u n t
# 78.5
Ol d e Mi l l
Li g h t i n g
$ 2 6 0 .0 0
La n ca st e r Ne w sp a p e r s
Lo g o Hat
L a n c a s t e r O n l i n e $ 8 .1 5
Article 72 of 149, 1999158118

( Lancast er , PA)
2 LEGENDS HELP SHAPE COUNTY IN 1930S GUY

GRAYBILL DIEHM WAS GOP'S LAST POLITICAL BOSS
They came to power in the 1930s, and their vision of how business and
government should function played no small role in defining how Lancaster
County viewed itself - not just in those years but for decades afterward.
Je w e l e d H e a r t
1 4 k t W h i t e Go l d Ov e r
D a n g l e Cu r v e d
S t e r l i n g S i l v e r Ri n g
Bar b ell- Dar k
( o p t i o n ) - Li g h t Bl u e / Si ze
Blu e
8
$ 2 1 .9 9
$ 1 8 .9 9
business leaders.
Cu st om er
Service
2 LEGENDS HELPED SHAPE COUNTY IN 1930S
Sit e Map
Keyword
I ndex
RSS Feeds

The Bedst ead.
Guy Graybill Diehm tood
Liv e Suppor t
Sit e

2 LEGENDS HELPED SHAPE COUNTY IN 1930S
M a rk et pla ce
>>
HENNING WEBB PRENTIS JR. ARGUED AGAINST NEW
DEAL
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
1 of 4
Go
Article 73 of 149, 1999158006

( Lancast er , PA)
business leaders.
Guy Graybill Diehm took
Article 74 of 149, 1999157001
12/25/2007 10:28 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
431
429 of
of 456
454
June 14, 2016
Need a
Websit e?
Pu blish ed on Ju n e 6 , 1 9 9 9 , Su n day New s

( Lancast er , PA)
NATION GETS A NEW DEAL LANCASTER COUNTY

WATCHED AS THE DEPRESSION GRIPPED COUNTRY,
HOPING IT WOULD ESCAPE. IT DIDN'T. BUT THE 1930S
WERE ALSO A TIME TO BUILD HERE.
The stock market had crashed two months before, but as far as Lancaster
was concerned on New Year's Day 1930, the collapse of prices on Wall
Street had no more significance than a penny nail falling on a stable floor.
Lancaster was growing as fast as it ever had, expanding its links to east
and west, erecting new public buildings, easily taking care of its poor. As the
decade opened, Lancaster County residents had no premonition that the
worst economic period in American history
Article 75 of 149, 1999104273

( Lancast er , PA)
ISC CREDITORS FILE SUIT AGAINST WIDOW OF

MONEY-LAUNDERER
The wife of a former employee of defunct Lancaster defense contractor
International Signal & Control Corp. has been sued in county court for
allegedly keeping $1.1 million her late husband was laundering for ISC
founder James H. Guerin.
Helen W. Snyder of McMinnville, Ore., stands accused of helping her
husband, Harley, move money from four Panamanian front companies,
and one U.S. firm, through Swiss banks and Farmers First Bank of Lititz
into accounts controlled by their
Article 76 of 149, 1999104106

( Lancast er , PA)
ISC CREDITORS FILE SUIT AGAINST WIDOW OF

MONEY-LAUNDERER
The wife of a former employee of defunct Lancaster defense contractor
International Signal & Control Corp. has been sued in county court for
allegedly keeping $1.1 million her late husband was laundering for ISC
founder James H. Guerin.
Helen W. Snyder of McMinnville, Ore., stands accused of helping her
husband, Harley, move money from four Panamanian front companies,
and one U.S. firm, through Swiss banks and Farmers First Bank of Lititz
into accounts controlled by their
Article 77 of 149, 1999079092

( PA)
LET ME SCHOOL YOU ON SLANG

Yo, are you stoked? I am. Let me school you about slang.
Check it out, G. By reading this week's column, you'll know the phat 4-1-1
so you won't be 4-0-4. No one will call you old skool. You'll be da bomb! So,
just kick it and chill while I floss. CONFUSED? ME TOO.
2 of 4
12/25/2007 10:28 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
432
430 of
of 456
454
June 14, 2016
Most people over the age of 25 couldn't decipher my opening paragraphs. I
didn't know what the words meant either - that is, until I asked several of my
Article 78 of 149, 1999022081

JUDGE REJECTS GUERIN'S BID FOR FREEDOM, LESS

JAIL TIME
Former Lancaster businessman James H. Guerin's bid for freedom or a
reduced sentence has been denied by a federal judge.
Chief U.S. District Judge Louis C. Bechtle Dec. 29 upheld the October
recommendation of a lower court judge who said Guerin's request for some
form of relief should be denied. "This should be the end of litigation with Mr.
Guerin," said Assistant U.S. Attorney Robert E. Goldman, who prosecuted
Guerin.
Article 79 of 149, 1999019070

HAROLD MCCURDY, 82, ISC MACHINIST

Harold W. McCurdy, 82, of 670 Gentry Drive, died Monday morning at Shady
Grove Adventist Hospital, Gaithersburg, Md., after a lengthy illness.
A graduate of Stevens Trade School, he was a retired machinist with
International Signal and Control Corp. He was a U.S. Army veteran of World
War II.
McCurdy was a member of First United Methodist Church, Lancaster, and
Masonic Lodge 43 Free & Accepted Masons.
Born in Pottstown, he was the son of the late Harry and Bertha Summons
Article 80 of 149, 1998291062
Pu blish ed on Oct ober 1 8 , 1 9 9 8 , Su n day New s

( Lancast er , PA)

SUNDAY
Oct. 11 - A seven-hour standoff with police ended when 18-year-old Shane
Sweigart surrendered in Brownstown. Apparently drunk, Brown had called
911, saying he wanted to kill people. MONDAY Oct. 12 - The shutdown of
Fruitville Pike to remove the eastbound Route 30 bridge was postponed by
PennDOT when the contractor changed demolition plans.
Ìt was announced that "The Friends of the Rocky Springs

perm ission.
3 of 4
12/25/2007 10:28 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
433
431 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3
Article 61 of 149, 1999362111

Er a ( PA)
A LOOK BACK AT LANCASTER COUNTY
Go

The Bedst ead.
M a rk et pla ce

>>
Pu n c h e d
Va n i t y Li g h t
# 301
Ol d e Mi l l
Li g h t i n g
$ 1 4 0 .0 0
Go l f B a l l s
L a n c a s t e r O n l i n e $ 1 3 .3 0
A "House of Horrors" in southern Lancaster County? A murderer who blows

up his victims or a con-artist who pulls off an international scheme?
What are the most sensational crimes that happened in Lancaster County
during the past 100 years? Were they the crimes involving brave
policemen who died fighting murderers, bank robbers or gangsters? Or the
innocent young victims who sparked massive manhunts?
Edward Gibbs, the capital murder case from Franklin
Article 62 of 149, 1999313086

FROM THE GO-GO '80S, PRIDE AND A STEEP FALL

The saga of International Signal & Control Corp. founder James H. Guerin -his meteoric rise to international prominence and final fall from grace -Tr a d i t i o n a l
shocked and polarized people from Pennsylvania to Great Britain and
1 4 - k t . Go l d &
beyond as it unfolded in the late 1980s.
3 / 4 - ca r a t TW
Pr i n c e s s
To many, he seemed the American dream incarnate. For more than 10
Diam ond
years, Guerin was lauded internationally for his business success and his
B a n d - Ye l l o w
philanthropy. He credited his success to old-fashioned American values:
Go l d Si ze 8
risk, hard
$ 5 4 9 .9 9
D i a b e t i c B r u i s e Re l i e f
$ 1 9 .9 9
Article 63 of 149, 1999313118

FROM THE GO-GO '80S, PRIDE AND A STEEP FALL

The saga of International Signal & Control Corp. founder James H. Guerin -his meteoric rise to international prominence and final fall from grace -shocked and polarized people from Pennsylvania to Great Britain and
beyond as it unfolded in the late 1980s.
To many, he seemed the American dream incarnate. For more than 10
years, Guerin was lauded internationally for his business success and his
philanthropy. He credited his success to old-fashioned American values:
risk, hard
Article 64 of 149, 1999284057

PATSY ROSCHEL, 69, ISC CORP. SOLDERER

Patsy J. Roschel, 69, of 214 Greyfield Drive, died Saturday morning at
Lancaster General Hospital following a lengthy illness.
12/25/2007 10:26 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
434
432 of
of 456
454
June 14, 2016
Need a
Websit e?
Mrs. Roschel was employed at the former Schick Inc. for 25 years, where
she had been a group leader in the shipping and receiving department. She
later worked at the former ISC Corp. as a first-class government-certified
solderer, retiring in 1990 after nine years.
She was of the Protestant faith.
Born in Lancaster, she was the daughter of the late Frank K.
Article 65 of 149, 1999239032

Er a ( PA)
LAST ISC PARCEL IS SOLD FOR $3.5 MILLION

The last portion of the suburban campus where International Signal & Control
collapsed will be revived by Clipper Magazine Inc.
The magazine's owners have bought the 28-acre property off Donnerville
Road from ISC successor Ferranti International Inc. for $3.5 million.
Following renovations, the local Clipper staff of 250 employees will move in
December to 3725 Electronics Way from its current headquarters at 1650
Manheim Pike.
"We're
Article 66 of 149, 1999234005
Pu blish ed on Au gu st 2 2 , 1 9 9 9 , Su n day New s

( Lancast er , PA)
ISC EXEC MUST DO TIME -- 2 YEARS THOMAS JASIN

APPEAL TURNED DOWN. HE IS ONE OF LAST FROM
ARMS SCANDAL TO HAVE CASE RESOLVED.
Seven years after he was convicted of selling military technology to the
South African government, a Manheim Township man must begin serving
his 2-year prison term.
Thomas P. Jasin, of the 2400 block of Butter Road, former president of ISC
Technologies Inc. - part of the the now-defunct International Signal & Control
Corp. - had appealed his 1992 conviction on conspiring to violate the Arms
Export Control Act and the Comprehensive Anti-Apartheid Act. ISC folded
in 1989.
Article 67 of 149, 1999227028
Pu blish ed on Au gu st 1 5 , 1 9 9 9 , Su n day New s

( Lancast er , PA)
M.L. HIEPLER, 72 RETIRED FROM ISC

Margaret L. Hiepler, 72, of 440 E. Grant St., died Friday afternoon at her
daughter's home in Quarryville after a brief illness.
Born in Lancaster, she was the daughter of the late William and Pearl
Halderman Mentzer. She was the widow of Cornelius F. Hiepler, who died in
December 1992.
She retired from the International Signal Control in Lancaster, where she
worked as a supervisor of inspectors for 15 years.
She was of the Methodist faith.
She was a member of
2 of 3
12/25/2007 10:26 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
435
433 of
of 456
454
June 14, 2016
Article 68 of 149, 1999178030
Pu blish ed on Ju n e 2 7 , 1 9 9 9 , Su n day New s

( Lancast er , PA)
GUERIN FILES NEW MOTION FOR RELEASE

Jailed Lancaster businessman James H. Guerin filed a new motion for his
release with the 3rd U.S. Circuit Court of Appeals on June 11, reiterating his
claim that his former attorney misled him into pleading guilty.
Guerin, 69, who founded the now-defunct International Signal & Control here,
was sentenced to 15 years in prison in 1992 after he confessed to
masterminding ISC's $1.14 billion fake-contract scheme and $50 million
smuggling operation. Assistant U.S.
Article 69 of 149, 1999177054
Pu blish ed on Ju n e 2 6 , 1 9 9 9 , Lan cast er New Er a

( PA)
GUERIN APPEALS TO 3RD CIRCUIT SAYS WAS MISLED

BY COUNSEL IN GUILTY PLEA
Jailed businessman James H. Guerin spent the past two years failing to
convince a federal judge to free him.
Now the former Lancastrian is trying to persuade the 3rd U.S. Circuit Court
of Appeals to let him go, by reiterating his claim that his former attorney
misled him into pleading guilty. Guerin, who founded now-defunct
International Signal & Control here, filed a notice that he was appealing to
the 3rd Circuit on June 11, two days after his 69th birthday.
In 1992,
Article 70 of 149, 1999159011

( Lancast er , PA)
1930S WEREN'T ALL DEPRESSING COUNTY GRAPPLED

WITH MANY ISSUES
While most Americans remember the 1930s as the era of the Great
Depression, life in Lancaster or any other U.S. community was far richer
and more complex than the hardships of that economic catastrophe.
Amidst the financial turmoil, Lancaster County residents built the core of
the county's public works - bridges, water and sewer lines, an airport and
bus system. They grappled with legal and moral issues - the return of
drunken driving after the repeal of Prohibition, the

perm ission.
3 of 3
12/25/2007 10:26 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
436
434 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3
Article 51 of 149, 2000071143

( PA)
FERRANTI SAYS 'CUT!' TO HOLLYWOOD TIES
Go

The Bedst ead.
M a rk et pla ce

>>
Pe n n S t a t e
Pa w
St er m er
B r o t h e r s $ 1 1 .9 9
Go l f B a l l s
L a n c a s t e r O n l i n e $ 1 3 .3 0
1 0 k t Ye l l o w
Go l d 1 / 4 - ct
Diam ond
Th r ee st o n e
Ri n g - 5 . 5
$ 1 1 3 .9 9
St er l i n g Si l v er Sk u l l s
$ 1 9 .9 9
Ferranti International Inc. has hit the "eject" button on its Los Angeles
television and movie studio.
Lancaster-based Ferranti agreed Thursday to sell the 36-acre property to a
Dallas-based real estate development firm, Trammell Crow Co., for $23
million. So the place that was graced by Dustin Hoffman, Clint Eastwood,
Robert DeNiro and other stars will become an office and light-industry
park.
"The studio business is now over," said James
Article 52 of 149, 2000071047

( PA)

park.
Article 53 of 149, 2000071166

( PA)

park.
Article 54 of 149, 2000007087
Published on Januar y 7 , 2 0 0 0 , I nt elligencer

SEVEN YEARS AFTER CONVICTION, FEDS WANT

JASIN BEHIND BARS
12/25/2007 10:24 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
437
435 of
of 456
454
June 14, 2016
Need a
Websit e?
Seven years after his conviction, former ISC executive Thomas P. Jasin
has yet to spend a day in prison. Federal prosecutors want that to change.
Jasin, 54, of 2473 Butter Road, was among 20 individuals and companies
indicted in 1991 for their roles in ISC's $1.14 billion contract fraud and $50
million smuggling scheme. Jasin was convicted in late 1992 of conspiracy
to smuggle weapons to South Africa. By now he could have served his
entire two-year prison sentence 3 times. But
Article 55 of 149, 2000007133

SEVEN YEARS AFTER CONVICTION, FEDS WANT

JASIN BEHIND BARS
Seven years after his conviction, former ISC executive Thomas P. Jasin
has yet to spend a day in prison. Federal prosecutors want that to change.
Jasin, 54, of 2473 Butter Road, was among 20 individuals and companies
indicted in 1991 for their roles in ISC's $1.14 billion contract fraud and $50
million smuggling scheme. Jasin was convicted in late 1992 of conspiracy
to smuggle weapons to South Africa. By now he could have served his
entire two-year prison sentence 3 times. But
Article 56 of 149, 2000006127
Pu blish ed on Jan u ar y 6 , 2 0 0 0 , Lan cast er New Er a

( PA)
PRISON FOR JASIN IN 2000?

By now, former ISC executive Thomas P. Jasin could have served his
entire prison sentence 3 times.
But Jasin, who was convicted in December 1992 of conspiracy to smuggle
weapons to South Africa, has yet to start the two-year sentence he
received in July 1998. Wednesday, in a pair of court filings, federal
prosecutors renewed their efforts to get a federal judge to order the
Lancaster man to report to prison immediately.
"Over seven years since conviction, 17 months after
Article 57 of 149, 2000006050

( PA)
PRISON FOR JASIN IN 2000?

By now, former ISC executive Thomas P. Jasin could have served his
entire prison sentence 3 times.
But Jasin, who was convicted in December 1992 of conspiracy to smuggle
weapons to South Africa, has yet to start the two-year sentence he
received in July 1998. Wednesday, in a pair of court filings, federal
prosecutors renewed their efforts to get a federal judge to order the
Lancaster man to report to prison immediately.
"Over seven years since conviction, 17 months after
Article 58 of 149, 2000003093
2 of 3
12/25/2007 10:24 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
438
436 of
of 456
454
June 14, 2016
THE TOP 10 BUSINESS STORIES OF THE 1990S

It's been a decade of extremes in Lancaster County's financial arena. A
recession ushered in the 1990s. The economy recovered, and the decade
ended with the longest stretch of prosperity in 30 years. The Internet gained
mainstream acceptance for much more than surfing in cyberspace.
In between the recession and the online boom, we've experienced a new
era of shopping with the opening of "big box" retailers, the transformation of
Article 59 of 149, 2000003129

THE TOP 10 BUSINESS STORIES OF THE 1990S

It's been a decade of extremes in Lancaster County's financial arena. A
recession ushered in the 1990s. The economy recovered, and the decade
ended with the longest stretch of prosperity in 30 years. The Internet gained
mainstream acceptance for much more than surfing in cyberspace.
In between the recession and the online boom, we've experienced a new
era of shopping with the opening of "big box" retailers, the transformation of
Article 60 of 149, 1999362044

Er a ( PA)
BRUTAL KILLINGS, COMPLEX SCAMS MOST

SENSATIONAL
A "House of Horrors" in southern Lancaster County? A murderer who blows
up his victims or a con-artist who pulls off an international scheme?
What are the most sensational crimes that happened in Lancaster County
during the past 100 years? Were they the crimes involving brave
policemen who died fighting murderers, bank robbers or gangsters? Or the
innocent young victims who sparked massive manhunts?
Edward Gibbs, the capital murder case from Franklin

perm ission.
3 of 3
12/25/2007 10:24 AM
Archives
search for isc AND date(all) Page 1000 of
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
439
437 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Article 41 of 149, 2000341190
Pu blish ed on Decem ber 6 , 2 0 0 0 , Lan cast er New

Er a ( PA)
ISC EXEC ORDERED TO PRISON FOR 2ND TIME
Go

The Bedst ead.
M a rk et pla ce

>>
Min n et on k a
Sh eep sk in
An k le Boot
# 3451
$ 6 4 .9 9
Z i p p o Lo g o Li g h t er s Mp l
Sw ar ov sk i
Pu r p l e Cr y s t a l
Ri n g - S i z e 5 Sm all
$ 3 7 .9 9
Co l u m b i a S p o r t s w e a r
Cr o o k e d B u t t e Lu m b a r
Pa c k - C a r b o n
$ 2 1 .9 9
After eluding jail for eight years, convicted smuggling conspirator Thomas
P. Jasin has been ordered for the second time to begin serving his
sentence.
Jasin, the former International Signal & Control executive, was ordered to
report to a yet-to-be-selected federal prison by Tuesday to start his
two-year sentence. The Manheim Township resident has avoided jail longer
than any convicted felon in memory.
Jasin, 54, of 2473 Butter Road, was convicted by a federal court jury in
Article 42 of 149, 2000298106

Er a ( PA)
SCHREIBER IS NAMED EDITOR OF NEW ERA

Ernest J. Schreiber will become editor of the Lancaster New Era effective
Saturday, it was announced by John M. Buckwalter, president of Lancaster
Newspapers Inc.
Schreiber, who is now the New Era staff editor, succeeds Robert J. Kozak,
who is retiring after a 44-year career at Lancaster Newspapers. Other staff
promotions include:
`Peter C. Mekeel will become managing editor of the New Era, a newly
created position. He is now the paper's news editor.
`Randall L.
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3
Article 43 of 149, 2000276105
Pu blish ed on Oct ober 2 , 2 0 0 0 , I n t elligen cer

LET JIM GUERIN ALONE, HE HAS NOTHING LEFT

To the Editor:
So, when is the Lancaster press going to allow Jim Guerin an opportunity to
address the spurious claims made in your reports? News flash, y'all -- this
rotten carcass is now 10 years old and there's nothing left to feed on. All
you are doing is giving false hope to the remaining corporate parasites at
Ferranti/ISC who are squandering remaining stockholder wealth in an
attempt to justify a rather pointless existence. As a former ISC employee
who felt
Article 44 of 149, 2000266072

JOHN BRUBAKER, CONTRACT ADMINISTRATOR
12/25/2007 10:22 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
440
438 of
of 456
454
June 14, 2016
Need a
Websit e?
John "Jack" W. Brubaker, 62, of 12 Willis Lane, died Thursday morning at

Essa Flory Hospice Center after a brief illness.
Brubaker was a contract administrator for the former GEC Marconi, the
former Ferranti, the former ISC, Bulova Technologies, the former General
Defense in York and Hamilton Technology. He also was a private pilot, a
former emergency medical technician for East Lampeter Ambulance
Association and a former paramedic for Ephrata Community Hospital.
Article 45 of 149, 2000238102

Er a ( PA)
TREASURE HUNT: FERRANTI SEEKING GUERIN

MONEY
Two decades ago, International Signal & Control's James H. Guerin was
creating his own kind of "friends and family" plan.
But Guerin was not striving to save money on his long-distance bill. He was
sending stolen money long distances, allegedly to save it for his friends,
his family and himself. As the 70-year-old former Lancaster businessman
sits in jail now, however, he denies he "parked" money.
Meanwhile, his
Article 46 of 149, 2000238037

Er a ( PA)

MONEY
Meanwhile, his
Article 47 of 149, 2000221038
Pu blish ed on Au gu st 8 , 2 0 0 0 , I n t elligen cer

THOMAS WHITE, 46, SERVICE TECHNICIAN

Thomas L. White, 46, of 3229 Maplecrest Terrace, died Sunday at Lancaster
Regional Medical Center. He had been ill with cancer for a year, according
to a family spokesman.
White was a service technician with Terminex International for three years,
until late July. He was a technician for the former ISC/Ferranti Corp. from
1979 to 1995. A U.S. Navy veteran, he served from 1974 to 1978 aboard
the aircraft carrier USS Kennedy as a third class aviation fire control
technician with squadron VA
Article 48 of 149, 2000216111
2 of 3
12/25/2007 10:22 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
441
439 of
of 456
454
June 14, 2016
FEDS SEIZE $1.2 MILLION HIDDEN BY GUERIN

PHILADELPHIA -- Federal prosecutors have seized about $1.2 million in
cash belonging to former Lancaster County businessman James H. Guerin
that was hidden in an off-shore bank account.
According to court documents, the government seized $1,190,930.57 from
an account at Kleinword Benson/Dresdner Bank Group, which is based in
Gurnsay, one of the Channel Islands in the English Channel. The money
was being held by a Guerin associate for the former Lancaster man's use
after he
Article 49 of 149, 2000216089


after he
Article 50 of 149, 2000172011

( PA)
MEKEEL NAMED NEW ERA BUSINESS EDITOR

Tim Mekeel, New Era staff writer, has been appointed business editor of the
New Era, effective June 19.
Mekeel joined the New Era in 1977 as a general assignment and sports
reporter. He became a full-time business reporter in 1979. A graduate of
Hempfield High School and Penn State University, Mekeel is 44 and
resides at 313 Rhoda Drive.
His wife, Alison, is an adjunct instructor of voice at Elizabethtown College
and a music associate at First Presbyterian Church. They have a son,

perm ission.
3 of 3
12/25/2007 10:22 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
442
440 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Article 41 of 149, 2000341190

Er a ( PA)
Go

The Bedst ead.
M a rk et pla ce

>>
Min n et on k a
Sh eep sk in
An k le Boot
# 3451
$ 6 4 .9 9
Z i p p o Lo g o Li g h t er s Mp l
Sw ar ov sk i
Pu r p l e Cr y s t a l
Ri n g - S i z e 5 Sm all
$ 3 7 .9 9
Co l u m b i a S p o r t s w e a r
Cr o o k e d B u t t e Lu m b a r
Pa c k - C a r b o n
$ 2 1 .9 9
sentence.
Article 42 of 149, 2000298106

Er a ( PA)
SCHREIBER IS NAMED EDITOR OF NEW ERA

Ernest J. Schreiber will become editor of the Lancaster New Era effective
Saturday, it was announced by John M. Buckwalter, president of Lancaster
Newspapers Inc.
Schreiber, who is now the New Era staff editor, succeeds Robert J. Kozak,
who is retiring after a 44-year career at Lancaster Newspapers. Other staff
promotions include:
`Peter C. Mekeel will become managing editor of the New Era, a newly
created position. He is now the paper's news editor.
`Randall L.
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3
Article 43 of 149, 2000276105
Pu blish ed on Oct ober 2 , 2 0 0 0 , I n t elligen cer

LET JIM GUERIN ALONE, HE HAS NOTHING LEFT

To the Editor:
So, when is the Lancaster press going to allow Jim Guerin an opportunity to
address the spurious claims made in your reports? News flash, y'all -- this
rotten carcass is now 10 years old and there's nothing left to feed on. All
you are doing is giving false hope to the remaining corporate parasites at
Ferranti/ISC who are squandering remaining stockholder wealth in an
attempt to justify a rather pointless existence. As a former ISC employee
who felt
Article 44 of 149, 2000266072

JOHN BRUBAKER, CONTRACT ADMINISTRATOR
12/25/2007 10:21 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
443
441 of
of 456
454
June 14, 2016
Need a
Websit e?
John "Jack" W. Brubaker, 62, of 12 Willis Lane, died Thursday morning at

Essa Flory Hospice Center after a brief illness.
Brubaker was a contract administrator for the former GEC Marconi, the
former Ferranti, the former ISC, Bulova Technologies, the former General
Defense in York and Hamilton Technology. He also was a private pilot, a
former emergency medical technician for East Lampeter Ambulance
Association and a former paramedic for Ephrata Community Hospital.
Article 45 of 149, 2000238102

Er a ( PA)

MONEY
Meanwhile, his
Article 46 of 149, 2000238037

Er a ( PA)

MONEY
Meanwhile, his
Article 47 of 149, 2000221038

THOMAS WHITE, 46, SERVICE TECHNICIAN

Thomas L. White, 46, of 3229 Maplecrest Terrace, died Sunday at Lancaster
Regional Medical Center. He had been ill with cancer for a year, according
to a family spokesman.
White was a service technician with Terminex International for three years,
until late July. He was a technician for the former ISC/Ferranti Corp. from
1979 to 1995. A U.S. Navy veteran, he served from 1974 to 1978 aboard
the aircraft carrier USS Kennedy as a third class aviation fire control
technician with squadron VA
Article 48 of 149, 2000216111
2 of 3
12/25/2007 10:21 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
444
442 of
of 456
454
June 14, 2016

after he
Article 49 of 149, 2000216089


after he
Article 50 of 149, 2000172011

( PA)
MEKEEL NAMED NEW ERA BUSINESS EDITOR

Tim Mekeel, New Era staff writer, has been appointed business editor of the
New Era, effective June 19.
Mekeel joined the New Era in 1977 as a general assignment and sports
reporter. He became a full-time business reporter in 1979. A graduate of
Hempfield High School and Penn State University, Mekeel is 44 and
resides at 313 Rhoda Drive.
His wife, Alison, is an adjunct instructor of voice at Elizabethtown College
and a music associate at First Presbyterian Church. They have a son,

perm ission.
3 of 3
12/25/2007 10:21 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
445
443 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Article 31 of 149, 2001154125
Pu blish ed on Ju n e 3 , 2 0 0 1 , Su n day New s

( Lancast er , PA)
CARL DREYER, FORMER EXECUTIVE
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3

The Bedst ead.
M a rk et pla ce
Visit t he
M ark et place > >
Carl H. Dreyer, 71, of 1061 Stillwood Circle, Lititz, died unexpectedly Friday
at Lancaster Regional Medical Center.
He and his wife, Lucy M. Collins Dreyer, celebrated 45 years of marriage on
May 27. Dreyer retired in 1988 as vice president of ad ministration for
International Signal and Control. Prior to joining ISC, he worked at Hamilton
Watch Co. in the quality control management area. He was a former
member of Lancaster West Rotary Club; the board of directors of the Urban
Go l f B a l l s
League of
La n ca st e r On l i n e
$ 1 3 .3 0
O l d e M i l l H o u s e $ 0 .0 0
Article 32 of 149, 2001152059

( Lancast er , PA)
Double- j ew eled
Cu r v e d
Bar b ell- Dk .
Estil L. Vandament, 62, of 1995 Mine Road, Paradise, died unexpectedly of
Blu e 7 / 1 6
natural causes Tuesday at Lancaster General Hospital.
$ 1 4 .9 9
Vandament was a consultant for various engineering firms, including RCA
Corp., Bendix, Burroughs, GE and ISC/Ferranti Inc. He successfully
implemented many International Standards Organization systems in the
quality engineering industry. He served four years in the U.S. Navy
aboard USS Des Moines' "Daisy Mae." He completed his
ESTIL VANDAMENT, 62, WAS CONSULTANT
1 4 - k t W h i t e Go l d 3 / 8 - ct
TD W D i a m o n d Ru b y
Ri n g
$ 3 3 9 .9 9
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Go
Article 33 of 149, 2000350095

LANCASTER PROJECT KEEPS CHRISTMAS MEALS

COMING
It can come without ribbons. It can come without tags. It can come without
packages, boxes or bags. And amid all the noise, noise, noise, noise, Tom
Fasnacht still knows that the spirit of Christmas does not have to come
from a store.
He and a small army of others are again helping to spread the word. On
Dec. 23, for the 14th time in as many years, hundreds of full hands will
reach out to even more empty ones and offer food to fill their tables and
good wishes to fill their hearts.
The
Article 34 of 149, 2000348135

JASIN GOES TO JAIL IN SCHUYLKILL CO.
12/25/2007 10:20 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
446
444 of
of 456
454
June 14, 2016
Need a
Websit e?
Thomas P. Jasin, the last executive from defunct International Signal &
Control Corp. facing a federal prison sentence, is behind bars.
Jasin, 54, of 2473 Butter Road, reported to the Federal Correctional
Institution Schuylkill in Minersville about 3 p.m. Tuesday to begin serving a
2-year sentence, Assistant U.S. Attorney David Hall said. "He was, of
course, late," Hall said. "But, in Mr. Jasin's case, better late than
Article 35 of 149, 2000348184

JASIN GOES TO JAIL IN SCHUYLKILL CO.

Thomas P. Jasin, the last executive from defunct International Signal &
Control Corp. facing a federal prison sentence, is behind bars.
Jasin, 54, of 2473 Butter Road, reported to the Federal Correctional
Institution Schuylkill in Minersville about 3 p.m. Tuesday to begin serving a
2-year sentence, Assistant U.S. Attorney David Hall said. "He was, of
course, late," Hall said. "But, in Mr. Jasin's case, better late than
Article 36 of 149, 2000344033
Published on Decem ber 9 , 2 0 0 0 , I nt elligencer

VICTOR FREY, 84, ELECTRONICS TECHNICIAN

Victor H. Frey, 84, of 106 South Trails End Court, formerly of River Road,
Conestoga, died Friday at Mennonite Home after a brief illness.
Frey was an electronics technician for the former Bendix Co., York, for 20
years. He last worked at ISC, retiring in 1982. He also worked for the
railroad, Armstrong World Industries Inc., and Safe Harbor Power Corp. A
U.S. Army veteran, he served during World War II.
Frey was a member of Green Hill United Methodist Church, Conestoga, the
former
Article 37 of 149, 2000341150

PATRICIA HEINLEY, ISC LINE SUPERVISOR

Patricia J. Heinley, 63, of 2294 Albern Blvd., died of natural causes Tuesday
at Essa Flory Hospice Center.
Mrs. Heinley was a line supervisor for the former International Signal Corp.
She was a member of Ross Street United Methodist Church.
She enjoyed crocheting, camping, bowling and vacationing in Atlantic City,
Delaware Park and Branson, Mo.
Born in England, she was the daughter of the late William J. and Gwendolyn
Stone White.
She was married 47 years in June to Donald E.
Article 38 of 149, 2000341222
2 of 3
12/25/2007 10:20 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
447
445 of
of 456
454
June 14, 2016
ISC EXEC ORDERED TO REPORT TO JAIL

Thomas P. Jasin, the former International Signal & Control Corp. executive
convicted in 1992 of conspiracy to smuggle missiles to the Republic of
South Africa in the mid-1980s, has a date with the jailer.
Jasin, 54, of 2473 Butter Road, was ordered to report to a yet-to-be-named
federal prison no later than 2 p.m. on Dec. 12 to begin serving the 2-year
sentence handed down by U.S. District Judge Jan E. DuBois in July 1998. If
a prison has not been assigned by that date, Jasin
Article 39 of 149, 2000341176

ISC EXEC ORDERED TO REPORT TO JAIL

Thomas P. Jasin, the former International Signal & Control Corp. executive
convicted in 1992 of conspiracy to smuggle missiles to the Republic of
South Africa in the mid-1980s, has a date with the jailer.
Jasin, 54, of 2473 Butter Road, was ordered to report to a yet-to-be-named
federal prison no later than 2 p.m. on Dec. 12 to begin serving the 2-year
sentence handed down by U.S. District Judge Jan E. DuBois in July 1998. If
a prison has not been assigned by that date, Jasin
Article 40 of 149, 2000341023

Er a ( PA)

sentence.

perm ission.
3 of 3
12/25/2007 10:20 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
448
446 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3
Article 21 of 149, 10149395

The Bedst ead.
Published on Febr uar y 2 7 , 2 0 0 3 , LANCASTER NEW


Keith Martin: Poor choice for key post
Go
M a rk et pla ce

>>
Min n et on k a
S h e e p s k i n Pu g
Boot s 9 " & 1 4 "
# 3571
$ 9 8 .9 9
R e a l M e n Fr y T u r k e y s
Ap r on
Improving security at home has been the nation's priority since Sept. 11,
2001. To coordinate the effort, President Bush created a new Department of
Homeland Security which has undertaken the most extensive
reorganization of the federal government in half a century.
The president chose Tom Ridge to lead that department because, among
other qualifications, Pennsylvania's former governor has military
experience and a strong record of leadership in Congress and the
Article 22 of 149, 10149296
Published on Febr uar y 2 6 , 2 0 0 3 , LANCASTER NEW

Martin supporter says background is not a problem

The state Senator who first recommended that Gov. Ed Rendell appoint
Keith Martin as director of homeland security said he knew beforehand about
1 4 - k t Ye l l o w
the former anchorman's abrupt departure from WGAL-TV in 1990.
Go l d . 4 7 - ct
Diam ond
And he had no problem with it.
Th r ee St o n e
"I knew the reason he left WGAL. There was no charge ever filed against
Ri n g - S i z e 8
him," Senate Minority Leader Robert J. Mellow, a Democrat from
$ 4 3 9 .9 9
Lackawanna County, said in an interview with the New Era today.
1 4 - k t . W h i t e Go l d 1 - ct .
TW D i a m o n d Cu l t u r e d
Fr e s h w a t e r Pe a r l
Neck lace
$ 7 9 5 .9 9
Article 23 of 149, 10148931
Published on Febr uar y 2 3 , 2 0 0 3 , SUNDAY NEWS

( LANCASTER, PA.)
A tainted nomination
Jim Guerin had a talent for dirtying everything he touched. Especially
reputations.
The Guerin touch is resurfacing now in the oddest way, in the nomination of
former WGAL-TV news anchor Keith Martin to be the state's homeland
security director.
Gen. Martin, as the administration calls the retired Army National Guard
brigadier general, got soon-to-be-governor Ed Rendell's attention during a
campaign debate; Martin was the anchor at northeastern
Article 24 of 149, 10148155
Published on Febr uar y 1 7 , 2 0 0 3 , I NTELLI GENCER

Good and bad choices

As Gov. Ed Rendell goes about filling the major posts in his administration,
he has made some good selections -- Lancaster schools superintendent
Vicki Phillips to be state secretary of education, for one -- and, well, some
12/25/2007 10:19 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
449
447 of
of 456
454
June 14, 2016
Need a
Websit e?
apparent less-good ones.

In particular, there's Benjamin Ramos, a former state legislator and deputy
mayor of Philadelphia under Rendell. Ramos has been picked to be
Pennsylvania's secretary of state and is currently serving in the post on an
Article 25 of 149, 10147814
Published on Febr uar y 1 4 , 2 0 0 3 , I NTELLI GENCER

Ex-WGAL anchor gets state post

Keith Martin is new security director
A former news anchor for a Lancaster television station has been named
the state's new homeland security director.
Gov. Ed Rendell on Thursday picked Keith Martin, a former WGAL-TV
newsman, to head the Pennsylvania Department of Homeland Security.
Martin, a retired brigadier general with the 28th Division, Pennsylvania Army
National Guard, has worked as a television news anchor for 30 years,
including 10 years at WGAL, where he was managing editor and senior news
Article 26 of 149, 10129788
Pu blish ed on Sept em ber 1 3 , 2 0 0 2 ,

I NTELLI GENCER JOURNAL ( LANCASTER, PA.)
M. Joyce Beaner, 70, ISC assembler

M. Joyce Beaner, 70, of 21 S. Ann St., died unexpectedly of natural causes
Wednesday at Community Hospital of Lancaster.
Mrs. Beaner was an assembler for Sechan Electronics for the last seven
years. She previously was an assembler for the former ISC/Ferranti for 25
years.
She was a graduate of the former Sacred Heart Academy.
Born in Lancaster, she was the daughter of the late Louis Carello and Ada
Witmer Steinruck.
Her husband, Donald C. Beaner, died in
Article 27 of 149, 2001288116

Er a ( PA)
IU 13 LEASES SPACE ON MANHEIM PIKE

Lancaster-Lebanon Intermediate Unit 13 has expanded and consolidated
some of its operations by leasing space on Manheim Pike.
IU 13 has leased 41,000 square feet at 1650 Manheim Pike, most recently
home to Clipper Magazine Inc. The remaining 3,000 square feet there
continue to be leased by Gannett Flemming Inc. About 175 IU 13
employees now work in the Manheim Pike building, near Delp Road, said
spokeswoman Marci Davis.
Through its five-year lease, IU 13 has consolidated nearly all of
Article 28 of 149, 2001288038
2 of 3
12/25/2007 10:19 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
450
448 of
of 456
454
June 14, 2016
Er a ( PA)
IU 13 LEASES SPACE ON MANHEIM PIKE

Lancaster-Lebanon Intermediate Unit 13 has expanded andconsolidated
some of its operations by leasing space on ManheimPike. IU 13 has leased
41,000 square feet at 1650 Manheim Pike, most recently home to Clipper
Magazine Inc. The remaining 3,000 square feet there continue to be leased
by Gannett Flemming Inc. About 175 IU 13 employees now work in the
Manheim Pike building, near Delp Road, said spokeswoman Marci Davis.
Through its five-year lease, IU 13 has consolidated nearly all of its
Article 29 of 149, 2001222084

FORMER ISC EXEC JASIN BACK IN COURT, SEEKING

NEW TRIAL
PHILADELPHIA -- Thomas P. Jasin, the former International Signal &
Control Corp. executive who eluded prison longer than any convicted felon
in U.S. history, wants a new trial, claiming his attorney was ineffective.
Jasin, 55, was convicted in 1993 of conspiracy to smuggle South
African-made missiles destined for the People's Republic of China. But it
took seven years before Jasin saw the inside of a jail cell as he flooded the
courts with appeals of his conviction,
Article 30 of 149, 2001222123

FORMER ISC EXEC JASIN BACK IN COURT, SEEKING

NEW TRIAL // CLAIMS ATTORNEY WAS INEFFECTIVE
DURING '93 TRIAL
PHILADELPHIA -- Thomas P. Jasin, the former International Signal &
Control Corp. executive who eluded prison longer than any convicted felon
in U.S. history, wants a new trial, claiming his attorney was ineffective.
Jasin, 55, was convicted in 1993 of conspiracy to smuggle South
African-made missiles destined for the People's Republic of China. But it
took seven years before Jasin saw the inside of a jail cell as he flooded the
courts with appeals of his conviction,

perm ission.
3 of 3
12/25/2007 10:19 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
451
449 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 4

Article 1 of 149, 677490000000.961155
Published on Mar ch 9 , 2 0 0 7 , I nt elligencer Jour nal

( Lancast er , PA)
Robert E. Meck
Go

The Bedst ead.
M a rk et pla ce

>>
Robert E. Meck, 72, of Manor Twp., passed away Tuesday, March 6, 2007 at
Lancaster Regional Medical Center. He was born September 9, 1934 in
Lancaster, son of the late Paul and Mae Meck. He was a Navy veteran of
the Korean War and also served in the Air Force. He retired as an engineer
from ISC. He is survived by his loving wife of 20 years, Lillie E. Meck; two
children, Valerie Shirley and Robert K.; three step-children, Jeff and Frank
Rietschey, and Susan Perugini; brother, Paul; three
Article 2 of 149, 677490000000.904095
Pu blish ed on Oct ober 1 5 , 2 0 0 6 , Su n day New s

( Lancast er , PA)
Ce n t r a l
Ma r k e t Co n e
Li g h t # 3 9
Ol d e Mi l l
Li g h t i n g
$ 1 7 1 .0 0
Wom an ' s Min n et on k a

Pi l e - L i n e d M u l e S l i p p e r
# 3511
Co y o t e T r a i l s $ 2 8 .9 9
Robert C. "Clyde" Ivy

Robert C. "Clyde" Ivy, 76, formerly of 3318 Cochran Dr., Lancaster,
passed away Wednesday at Moravian Manor in Lititz. He was the husband of
Irene Bundas Ivy, with whom he celebrated 48 years of marriage, this past
St er l i n g Si l v er
February 28th. Born in Vicksburg, Mississippi, Clyde was the son of the late
Wh it e Sat in
William and Wilma Henry Ivy. An electrical engineer, Clyde had worked for
Ri n g - S i z e 9
ISC- Ferranti PLC of Lancaster, for 12 years, until his retirement in 1989.
$ 1 9 .9 9
Prior to this he had worked in
S t e r l i n g S i l v e r Pi p e Cu t
$ 1 9 .9 9
Article 3 of 149, 677490000000.877572

Volleyball Kelly Dobosh and Heather Kirkwood (Solanco) played on the
team that finished third at the East Zone Beach Volleyball Championship
held at Dorchester State Beach in Ocean City, Md.
Basketball
The following girls captured a bronze medal for the Blue Mountain Scholastic
team at the Keystone Games: Ashley Sharpe (Manheim Township), Danielle
Busansky (Penn Manor), Gabrielle Hondros (Ephrata), Angie Rapchinski
(Lititz Christian), Jes Zimmerman (Cocalico), Lillian Snyder
Article 4 of 149, 677490000000.851561

( Lancast er , PA)
Herley chairman steps down

Blatt resigns days after indictment for alleged $3.1 million fraudPATRICK
BURNS Lee N. Blatt has resigned as chairman of Herley Industries Inc., just
48 hours after federal prosecutors charged he and the company defrauded
the U.S. military of millions of dollars, the company reported Friday.
The resignation coincided with the Lancaster-based Herley's regularly
scheduled board of directors meeting Thursday, during which it filed a
quarterly report to the Securities and Exchange
12/25/2007 10:17 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
452
450 of
of 456
454
June 14, 2016
Need a
Websit e?
Article 5 of 149, 783332

( PA)
Eras past This week in Lancaster County history

Summaries of local news stories from the pages of the Lancaster New Era
appear in this space each Monday.
They are researched and compiled by New Era staffer Tim Buckwalter.
Full versions are available on microfilm at the Lancaster County Library,
125 N.
Duke St.
PILOTS RETURN: Two Lancaster County pilots returned to a joyous
welcome at Lancaster Airport after being held for several weeks in the
Philippines.
They had been flying explosives to Malaysia for Lancaster-based
Article 6 of 149, 780487

Who's News
American Home Bank has hired Bradford M. La Salle as senior vice
president of wholesale and correspondent lending. His duties will include
overseeing the newly created correspondent lending division, serving the
construction-to-permanent mortgage market. La Salle, of Buffalo, N.Y.,
previously was employed as an assistant vice president at M&T Mortgage.
He is a graduate of SUNY-Buffalo.
Wachovia has hired Mary Lou Forrey as a vice president and senior
relationship manager in its
Article 7 of 149, 10230508
Pu blish ed on Febr u ar y 2 7 , 2 0 0 5 , Su n day New s

( Lancast er , PA)
Jasin's new job is out of this world

Former ISC exec heads NASA Lunar Robotics program,
studies ways to make moon surface livable for humans.
Thomas Jasin has gone from legal trouble and public scrutiny into a career
any young explorer would envy.
The former International Signal & Control Corp. executive is now head of
the Lunar Robotic Program for NASA. His directive is to bring science
fiction and reality together for the next generation.
During a telephone conversation last week from his Washington, D.C.,
office, Jasin said his new charge is not only exciting, it's opening the way
for our children
Article 8 of 149, 10229012
2 of 4
12/25/2007 10:17 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
453
451 of
of 456
454
June 14, 2016
Pu blish ed on Febr u ar y 1 3 , 2 0 0 5 , Su n day New s
( Lancast er , PA)
He lands on feet in post at NASA

Jailed in ISC scandal, Thomas Jasin saw indictment
dropped. Local ex-congressman said he's well-qualified.
Thomas Jasin worked his way up the corporate ladder to become an
executive with International Signal & Control Corp.
When the company, sinking in a mire of fake contracts and weapons
smuggling, went belly up in 1991, he went with it.
He was convicted in 1992 of conspiracy to smuggle South African-made
missiles destined for the People's Republic of China.
Years of court battles found him incarcerated before he won an appeal from
the federal government in
Article 9 of 149, 10228971

Er a ( PA)
Freed from jail, he lands with NASA

Manheim Twp. resident Thomas Jasin, who spent 18
months in prison before a conviction for conspiring to
smuggle weapons was overturned, now has a top job with
NASA.
From a federal prison to a federal payroll.
From a confined space to outer space.
From fighting a prosecutor's motion to fulfilling a presidential mandate.
The life of Manheim Township resident Thomas P. Jasin has taken an
incredible turn in the past four years.
Jailed in 2000 for conspiring to evade the arms embargo against South
Africa, Jasin's conviction eventually was overturned by the trial judge, who
found that Jasin's attorney provided
Article 10 of 149, 10225298
Pu blish ed on Jan u ar y 9 , 2 0 0 5 , Su n day New s

( Lancast er , PA)

SUNDAY
Jan. 2 - Richard M. Scott, a World War II fighter pilot and a former mayor of
Lancaster, died at 86. Scott was shot down in combat and escaped from a
German prisoner of war camp. He led the move to bring minor-league
baseball back to Lancaster. A memorial service Thursday was attended by
hundreds.
MONDAY
Jan. 3 - James H. Guerin, sentenced in 1992 for his admission that he ran a
$1.14 billion contract scam and $50 million smuggling ring involving his
business, ISC, and its
3 of 4
12/25/2007 10:17 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
454
452 of
of 456
454
June 14, 2016
Home
News
Weat her
Spor t s
Blogs
Business
Ent ert ainm ent
Technology
Healt h
Ar chives
La Voz
Hispana
Ser v ices
Classifieds
Cars
Realt y
Wizard
Apar t m ent s
Shopping
Personals
Com m unity
Visit
Lan cast er
My
Headlines
Talk back
eEdit ions
Phot os
Article 141 of 149, 1995126035
Pu blish ed on May 6 , 1 9 9 5 , Lan cast er New Er a

( PA)
Go
LATEST GUERIN ALLEGATION: SECRET $350,000

KICKBACK

The Bedst ead.
M a rk et pla ce

>>
James H. Guerin paid a secret $350,000 kickback to the company that sold
its Marquardt division to his International Signal & Control, court papers
allege.
A lawsuit filed in California Superior Court alleges that Guerin paid the
kickback out of a Swiss bank account opened by one of his front companies.
The kickback allegedly was sent by wire transfer to the bank account of CCI
Ol d e Mi l l
Corp. in September 1983, 20 days after CCI sold its Marquardt division to
H o u s e $ 0 .0 0
Guerin's
La n ca st e r Ne w sp a p e r s
Lo g o Hat
L a n c a s t e r O n l i n e $ 8 .1 5
Article 142 of 149, 1995083055

( PA)
MORE TO THE ISC SCULPTURE STORY

Editor, New Era:
Re: "Sculpture paid for with fraud money removed at Ferranti," New Era,
March 18, p. B-16. Two reactions to the referenced article:
Je t Pi l o t
La d i e s GTR
Li f e Ve st - Si ze
M Blu e
$ 3 6 .9 9
Fr e s h w a t e r Pe a r l L a r i a t
N e c k l a c e - 1 0 - k t . Ye l l o w
G o l d Pe a r l L a r i a t - s t y l e
Neck lace
$ 3 7 .9 9
First, the headline "Sculpture paid for with fraud money..." is based in
questionable logic. ISC's position was the result of fraudulent activities.
Much of its cash flow was a result of that position. Fraud taints everything,
so was it all "fraud money"?
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Cu st om er
Service
Subscribe
Car e Cent er
Place an Ad
Advert ising
Cont act Us
Liv e Suppor t
Sit e
Sit e Map
Keyword
I ndex
RSS Feeds
1 of 3
Article 143 of 149, 1995077004

( PA)
SCULPTURE PAID FOR WITH FRAUD MONEY

REMOVED AT FERRANTI
When James H. Guerin commissioned a sculpture for his company
headquarters, he wanted it to represent International Signal & Control's
evolution.
"It shows where we started and where we're headed," said Guerin in 1988
when the copper, chrome and stainless-steel artwork was assembled.
Indeed it does, though not the way Guerin envisioned.
The abstract piece was removed from its granite pedestals Wednesday,
symbolizing the demise
Article 144 of 149, 1995056010

Er a ( PA)
GUERIN ORDERED TO PAY FERRANTI
12/25/2007 10:39 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
455
453 of
of 456
454
June 14, 2016
Need a
Websit e?
A federal appeals court has ruled that James H. Guerin, who is paying his
debt to society, also owes a $189.9 million debt to Ferranti International.
The 64-year-old founder of International Signal & Control is serving a
15-year sentence for orchestrating fraud and smuggling schemes at the
company. Ferranti, which acquired Guerin's ISC and became the major
victim of his fraud, sued Guerin in England in 1989.
Ferranti sought $189.9 million because that was the net
Article 145 of 149, 1995055103

GUERIN SAID BACK IN AREA FOR GRAND JURY

TESTIMONY
Federal inmate and former Lancaster industrialist James H. Guerin arrived
in the Philadelphia area this week to testify before a new federal grand
jury, sources said.
The grand jury has reportedly been formed to gather new information for the
government's ongoing investigation of the global financial fraud, money
laundering and arms smuggling scheme carried out within International
Signal & Control Corp. of Lancaster and later Great Britain's Ferranti
Article 146 of 149, 1995041109

FIRM'S CLOSING WAS OWN DOING

To the Editor:
In reading your article on the closing of Marconi Technologies, I must say I
was quite dismayed. I have worked for this firm for 17seventeen years. I
have already been through the ISC/Jim Guerin/Ferranti saga. Now at a time
when we find out that our days are numbered we once again have to share
that billing with Jim Guerin and Ferranti. Quite frankly I'm sick of them!
Yes, the "breaking point" for Marconi was loosing the Martin Marietta
Article 147 of 149, 1995040069
Pu blish ed on Febr u ar y 9 , 1 9 9 5 , I n t elligen cer

MARCONI TECHNOLOGIES SHUTTING ITS DOORS

The announcement Wednesday that Marconi Technologies Inc. is stopping
military parts production in East Hempfield Township in June means the
story of the rise and fall of former Lancaster businessman James H. Guerin
has finally ended.
Marconi Technologies was the last manufacturing leftover in Lancaster of
the once-robust defense contractor Guerin founded - International Signal &
Control Corp. When Guerin merged ISC with Great Britain's Ferranti
International plc in
Article 148 of 149, 1995040023
2 of 3
12/25/2007 10:39 AM
Archives
Sunday January
22, 2017
2301
LLetttteerr
Letter
to Lambert
ttoo D Laavme
Author Dave
bBerrotw
Brown
Anuthor Dave
Pager
Page
Brown
456
454 of
of 456
454
June 14, 2016
Pu blish ed on Febr u ar y 9 , 1 9 9 5 , Lan cast er New
Er a ( PA)
MARCONI TO SHUT PRODUCTION HERE, IDLE 65

WORKERS
Marconi Technologies Inc. said Wednesday it would shut down its printed
circuit board manufacturing here, idling 65 workers.
The announcement signals the demise of what once was the showpiece
business of James H. Guerin's International Signal & Control. Marconi
president Scott Griffiths said the closing was triggered by the loss of a $23
million add-on contract for the U.S. Navy's "vertical launch system."
For nearly 10 years,
Article 149 of 149, 1995030025

Er a ( PA)
EMTROL LEAVING CITY'S SOUTHEAST FOR OLD ISC

HEADQUARTERS
Emtrol Inc., part of Lancaster city's southeast community for 15 years, is
moving to the suburbs.
Emtrol last week signed a lease-purchase agreement for 3050 Hempland
Road, along the Route 30 Bypass in East Hempfield Township. The building
once was the headquarters of International Signal & Control, when founder
James H. Guerin was launching his fraud and smuggling schemes.
Emtrol, a maker of industrial controls, plans to move from its 123 Locust
St. building in
[ View the previous 10 items ]

perm ission.
3 of 3
12/25/2007 10:39 AM
Page 1018 of 2301
Stan J. Caterbone
MOVANT
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
717-459-7588 Fax
August 19, 2015
LISA MICHELLE LAMBERT & STAN J. CATERBONE
Both victims of PROSECUTORIAL MISCONDUCT By a Criminal Enterprise

ATTACHED IS MY 1998 AFFIDAVIT TO THE HONORABLE STEWART DALZALL,
U.S. DISTRIT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA
The following is a copy of the 1998 AFFIDAVIT to Judge Dalzall. The original file is
the original complaint filed on May 16, 2005 for Case No. 05-2288 in the U.S. District
Court for the Eastern District of Pennsylvania; however the document is not viewable
on the U.S. District Court Court Filing System. I do not know why.
The affidavit
was delivered on a CD-ROM to an Inbox outside the chambers of Judge Stewart

Dalzall. Back at that time the public could access the halls of the chambers to U.S.
District Judges in Philadelphia, Pennsylvania.
Also attached is the DOCKET for Lisa Michelle Lambert's 2014 Habeus Corpus
which I am a party, as being named the MOVANT on June 23, 2015 with the filing of
my AMICUS.
Given the preponderance of evidence associated with this affidavit, the

courts must conclude that In The United States District Court For The Eastern
District of Pennsylvania, Federal Judge Stuart Dalzalls findings of April 14, 1997,
in the Lisa Lambert case identifying acts of Prosecutorial Misconduct, now, by
virtue of this affidavit, now discloses evidence of a bona fide pattern of
prosecutorial misconduct, in the Commonwealth of Pennsylvania and in the
County of Lancaster. Criminal law must now determine if these disclosures would
warrant investigations of a possible criminal enterprise.
Page 1019 of 2301
Page 2
This affidavit is of material interest to the Lambert case, for the very fact
that this affidavit compromises the very same integrity of the court, which would
tip the scales of justice even further from the peoples deserving rights.. In the
truthfulness of this affidavit, The Commonwealth must concede Lisa Michelle
Lambert to balance the scales of justice, which no other act could accomplish.
The Commonwealth must yield the criminal culpability of Lisa Michelle Lambert
to the superior matter of restoring the integrity to the courts; by its own
admission of wrongdoing, assuring the peoples of its commitment to administer
equalities of justice, not inequalities of justice. Balancing the scales of justice.
Anything less, would take the full scope of jurisdiction out of the boundaries of
our laws, negating our democracy and impugning the Constitution of the United
States. The plaintiff must be restored to whole.
I was not defending the criminal culpability of Lisa Michelle Lambert, but
rather assaulting the judicial integrity of the Lancaster County Judicial System,
from first-hand experience; and making the point that such conduct eludes every
major stakeholder from the truth and justice prosecution and defense alike.
Respectfully,
Stan J. Caterbone
United States District Court Eastern District of Pennsylvania
https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?121153035547044-L_1_0-1
Page 1020 of 2301

CLOSED,HABEAS,A/R

Eastern District of Pennsylvania (Allentown)
CIVIL DOCKET FOR CASE #: 5:14-cv-02559-PD
LAMBERT v. BISSONETTE et al
Assigned to: HONORABLE PAUL S. DIAMOND
Cause: 28:2254 Petition for Writ of Habeas Corpus (State)
Date Filed: 05/02/2014

Date Terminated: 05/22/2014
Jury Demand: None
Nature of Suit: 530 Habeas Corpus: (General)
Jurisdiction: Federal Question
Petitioner
represented by JEREMY H.G. IBRAHIM

LAW OFFICES OF JEREMY H. GONZALEZ IBRAHIM
P.O. BOX 1025
CHADDS FORD, PA 19317
215-568-1943
Email: jeremyibrahim.esq@verizon.net
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
V.
Respondent
LYNN BISSONETTE
SUPERINTENDENT, MCI-FRAMINGHAM
Respondent
THE DISTRICT ATTORNEY OF LANCASTER
Respondent
THE ATTORNEY GENERAL OF PENNSYLVANIA
V.
Movant
AND ADVANCED MEDIA GROUP
1 of 2
represented by STANLEY J. CATERBONE

1250 FREMONT STREET
LANCASTER, PA 17603
PRO SE
Date Filed
# Docket Text
05/02/2014
1 PETITION FOR WRIT OF HABEAS CORPUS (Filing fee $ 5 receipt number 100526.), filed by LISA MICHELLE LAMBERT.
(Attachments: # 1 Civil Cover Sheet)(ks, ) (Entered: 05/05/2014)
05/22/2014
2 CJA 20 APPIONTMENT OF ATTORNEY JEREMY H.G. IBRAHIM for LISA MICHELLE LAMBERT. SIGNED BY HONORABLE
PAUL S. DIAMOND ON 5/22/14. 5/22/14 ENTERED AND COPIES E-MAILED.(jpd) (Entered: 05/22/2014)
05/22/2014
3 ORDER THAT JEREMY IBRAHIM, ESQ., IS APPOINTED AS PETITIONER'S COUNSEL. ACCORDINGLY HER HABEAS
PETITION IS DISMISSED WITHOUT PREJUDICE TO PETITIONER'S RIGHT TO FILE A COUNSELED MOTION FOR RELIEF.
COUNSEL SHOULD BE PREPARED TO ADDRESS WHETHER PETITIONER MUST SEEK PERMISSION FROM THE COURT
OF APPEALS BEFORE FILING A SECOND OR SUCCESSIVE HABEAS PETITION. SIGNED BY HONORABLE PAUL S.
DIAMOND ON 5/22/14. 5/23/14 ENTERED AND COPIES MAILED TO PRO SE PETITIONER AND E-MAILED. (jpd) (Entered:
05/23/2014)
06/23/2015
4 BRIEF ON BEHALF OF AMICI CURIAE STANLEY J. CANTERBONE AND ADVANCED MEDIA GROUP IN SUPPORT OF
LISA MICHELLE LAMBERT'S HABEAU CORPUS, CERTIFICATE OF SERVICE.(jpd) (Entered: 06/25/2015)
07/06/2015
5 STATEMENT OF MOVANT STANLEY J. CATERBONE. (jpd, ) (Entered: 07/07/2015)
08/14/2015
6 LETTER FROM STAN J. CATERBONE DATED 8/7/15 ADDRESSED TO THE HONORABLE JUDGE J. CURTIS JOYNER AND
THE HONORABLE JUDGE PAUL S. DIAMOND RE: ELECTRONIC CASE FILING PRIVILEGES. (jpd) (Entered: 08/14/2015)
8/19/2015 1:16 AM
Page 1021 of 2301
PACER Service Center

Transaction Receipt
08/19/2015 01:14:50
PACER Login: am6446:3514696:0 Client Code:
Description:
Docket Report
Billable Pages: 2
2 of 2
Search Criteria: 5:14-cv-02559-PD

Cost:
0.20
8/19/2015 1:16 AM
Page 1022 of 2301
advantage for lack of legal training. "The right of self-representation is not a license to abuse
the dignity of the courtroom. Neither is it a license not to comply with relevant rules of
procedural and substantive law." Faretta v. California, 422 U.S. 806,834 n. 46,95 S.Ct.
2525,2541 n. 46,45 L.Ed.2d 562 (1975).
In the instant case, Plaintiff has no greater right to be heard than he would have if he were
represented by counsel. As a pro se litigant, Plaintiff, in essence, stands in the place of an
attorney. Plaintiffs request for an ex parte meeting with the Court in this case violates Rule
3.5(a) of the Rules of Professional Conduct because it is clear that Plaintiff seeks to influence
the Court with his version of events, without providing defense counsel any opportunity to
respond.' Since an ex parte meeting with the Court would violate the Rules of Professional
Conduct and provide Plaintiff an unfair advantage over Defendants, Plaintiffs request for
such a meeting should be refused.
HISTORICAL BACKGROUND
The following is copy of an Affidavit that was filed on January 31, 1998 in the chambers of
Honorable Stewart Dalzell in a desperate attempt for due process of the issues contained
herein. In November of 1997 the PLAINTIFF sought the counsel of Ms. Christina Rainville
while employed by the firm of Schnader, Harrison, Segal and Lewis. This was the last
attempt by the PLAINTIFF of seeking competent legal counsel. Ms. Rainville acknowledged
and communicated to the PLAINTIFF that the firm had barred her from representing any
additional clients from Lancaster County shortly after the PLAINTIFFs solicitation; which she
had plenty of solicitations from other potential Lancaster County clients. In the document
titled Plaintiff Finding of Facts it is clearly documented that the PLAINTIFF did attempt to
solicit and retain several competent lawyers since 1987, all of who displayed conflicts of
interests, and some went so far as to violate rules of ethics concerning client/attorney
privilege. PLAINTIFFs filing as Pro Se Litigant was the only alternative available that would
protect and preserve the PLAINTIFFs legal standing and right to due process. The following
excerpt from the Affidavit will demonstrate to the court a factual account of the events that
precluded and provided the Plaintiff the legal standing to file the original complaint on May
16, 2005.
Confidential
Page 2
6/12/2006
Page 1023 of 2301
AFFIDAVIT OF 1998 TO HONORABLE JUDGE STEWART DALZELL
I, Stanley J. Caterbone being duly sworn according to law, make the following affidavit
concerning the years during which I was maliciously and purposefully mentally abused,
subjected to a massive array of prosecutorial misconduct, while enduring an exhaustive
fight for the sovereignty of my constitutional rights, shareholder rights, civil liberties, and
right of due access to the law. I will detail a deliberate attempt on my life, in 1991, exhibiting
the dire consequences of this complaint. These allegations are substantiated through a
preponderance of evidence including but not limited to over 10,000 documents, over 50
hours of recorded conversations, transcripts, and archived on several digital mediums. A
Findings of Facts is attached herewith providing merits and the facts pertaining to this
affidavit.
These issues and incidents identified herein have attempted to conceal my
disclosures of International Signal & Control, Plc. However, the merits of the violations
contained in this affidavit will be proven incidental to the existence of any conspiracy.
The plaintiff protests the courts for all remedial actions mandated by law.
Financial
considerations would exceed $1 million.

These violations began on June 23, 1987 while I was a resident and business owner in
Lancaster County, Pennsylvania, and have continued to the present. These issues are a
direct consequence of my public disclosure of fraud within International Signal & Control,
Plc., of County of Lancaster, Pennsylvania, which were in compliance with federal and state
statutes governing my shareholder rights granted in 1983, when I purchased my interests in
International Signal & Control., Plc.. I will also prove intentional undo influence against
family and friends towards compromising the credibility of myself, with malicious and selfserving accusations of insanity. I conclude that the courts must provide me with fair
access to the law, and most certainly, the process must void any technical
deficiencies found in this filing as being material to the conclusions. Such arrogance
by the Courts would only challenge the judicial integrity of our Constitution.
Confidential
Page 3
6/12/2006
Page 1024 of 2301
1. The activities contained herein may raise the argument of fair disclosure regarding the
scope of law pertaining to issues and activities compromising the National Security of the
United States. The Plaintiff will successfully argue that due to the criminal record of
International Signal & Control, including the illegal transfer of arms and technologies to an
end user Iraq, the laws of disclosure must be forfeited by virtue that said activities posed
a direct compromise to the National Security of the United States.; the plaintiff will argue
that his public allegations of misconduct within the operations of International Signal &
Control, Plc., as early as June of 1987 ;demonstrated actions were proven to protect the
National Security of the United States..
The activities of International Signal & Control,
Pls., placed American troops in harms way. The plaintiffs actions should have taken the
American troops out of harms way causing the activities of the International Signal &
Control, Plc., to cease and desist. .
All activities contained herein have greatly compromised the National Security of the
United States, and the laws of jurist prudence must apply towards the Plaintiffs intent and
motive of protecting the rights of his fellow citizens. Had the plaintiff been protected
under the law, and subsequently had the law enforcement community of the
Commonwealth of Pennsylvania, and the County of Lancaster administer justice, United
States troops may have been taken out of harms way, as a direct result of ceasing the
operations of International Signal & Control, Plc., in as early as 1987.
2. The plaintiff will successfully prove that the following activities and the prosecutorial
misconduct were directed at intimidating the plaintiff from continuing his public
disclosures regarding illegal activities within International Signal & Control, Plc,. On June
23, 1998, International Signal & Control, Plc was negotiating for the $1.14 billion merger
with Ferranti International, of England.
Such disclosures threatened the integrity of
International Signal & Controls organization, and Mr. James Guerin himself, ,
consequently resulting in adverse financial considerations to all parties if such disclosures
provided any reason to question the integrity of the transaction, which later became the
central criminal activity in the in The United States District Court For The Eastern District
Of Pennsylvania.
Confidential
Page 4
6/12/2006
Page 1025 of 2301
3. The plaintiff will prove that undo influence was also responsible for the adverse
consequences and fabricated demise of his business enterprises and personal holdings.
The dire consequences of the plaintiffs failed business dealings will demonstrate and
substantiate financial incentive and motive.
Defendants responsible for administering
undo influence and interference in the plaintiffs business and commercial enterprises had
financial interests. The Commonwealth of Pennsylvania as a taxing authority, Lancaster
County had a great investment whos demise would facilitate grave consequences to its
economic development. .
Commonwealth National Bank (Mellon) would have less
competition in the mortgage banking business and other financial services, violating the
lender liability laws. The Steinman Enterprises, Inc., would loose a pioneer in the
information technologies industries, and would protect the public domain from truthful
disclosure. The plaintiff will also provide significant evidence of said perpetrators violating
common laws governing intellectual property rights.
4. Given the plaintiffs continued and obstructed right to due process of the law, beginning in
June of 1987 and continuing to the present, the plaintiff must be given fair access to the
law with the opportunity for any and all remedial actions required under the federal and
state statutes. The plaintiff will successfully argue his rights to the courts to rightfully
claim civil actions with regards to the totality of these activities, so described in the
following Findings of Facts, regardless of any statute of limitations. Given the plaintiffs
genuine efforts for due process has been inherently and maliciously obstructed, the
courts must provide the opportunity for any and all remedial actions deserving to the
plaintiff.
5. Under current laws, the plaintiffs intellectual capacity has been exploited as means of
discrediting the plaintiffs disclosures and obstructing the plaintiffs right to due process of
the law.
The plaintiff has always had the proper rights under federal and state laws to
enter into contract. The logic and reason towards the plaintiffs activities and actions are
a matter of record, demonstrated in the Findings of Facts, contained herein..
The plaintiff will argue and successfully prove that the inherent emotional consequences
to all of the activities contained herein have resulted in Post Traumatic Stress Syndrome.
Confidential
Page 5
6/12/2006
Page 1026 of 2301
The evidence of the stress subjected to the plaintiff, will prove to be the direct result of the
activities contained herein, rather than the exhibited behavior of any mental deficiency the
plaintiff may or may not have. The courts must provide for the proper interpretations of all
laws, irrespective of the plaintiffs alleged intellectual capacity. The plaintiff successfully
argue that his mental capacity is of very little legal consequence, if any; other than in its
malicious representations used to diminish the credibility of the plaintiff.
6. The plaintiff will demonstrate that the following incidents of illegal prosecutions were
purposefully directed at intimidating the plaintiff from further public disclosure into the
activities of International Signal & Control, Plc., consequently obstructing the plaintiffs
access to due process of the law. Due to the fact that these activities to which the
plaintiffs perpetrators were protecting were illegal activities, the RICO statutes would
apply.
To this day, the plaintiff has never been convicted of any crime with the exception of 2
speeding tickets. The following report identifies 34 instances of prosecutorial misconduct
during the prosecutions and activities beginning on June 23, 1987 and continuing to
today.
7) Given the preponderance of evidence associated with this affidavit, the courts must
conclude that In The United States District Court For The Eastern District of
Pennsylvania, Federal Judge Stuart Dalzalls findings of April 14, 1997, in the Lisa
Lambert case identifying acts of Prosecutorial Misconduct, now, by virtue of this affidavit,
now discloses evidence of a bona fide pattern of prosecutorial misconduct, in the
Commonwealth of Pennsylvania and in the County of Lancaster. Criminal law must now
determine if these disclosures would warrant investigations of a possible criminal
enterprise. This affidavit is of material interest to the Lambert case, for the very fact that
this affidavit compromises the very same integrity of the court, which would tip the scales
of justice even further from the peoples deserving rights..
In the truthfulness of this affidavit, The Commonwealth must concede Lisa Michelle
Lambert to balance the scales of justice, which no other act could accomplish. The
Confidential
Page 6
6/12/2006
Page 1027 of 2301
Commonwealth must yield the criminal culpability of Lisa Michelle Lambert to the superior
matter of restoring the integrity to the courts; by its own admission of wrongdoing,
assuring the peoples of its commitment to administer equalities of justice, not inequalities
of justice. Balancing the scales of justice. Anything less, would take the full scope of
jurisdiction out of the boundaries of our laws, negating our democracy and impugning the
Constitution of the United States. The plaintiff must be restored to whole.
I was not defending the criminal culpability of Lisa Michelle Lambert, but rather assaulting
the judicial integrity of the Lancaster County Judicial System, from first-hand experience;
and making the point that such conduct eludes every major stakeholder from the truth
and justice prosecution and defense alike.
Confidential
Page 7
6/12/2006
Page 1028 of 2301
January January
Sunday
22, 201722, 2017

Page
Page1029
27 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 4 of 91
January January
Sunday
22, 201722, 2017

Page
Page1030
28 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
AFFIDAVIT OR DECLARATION
IN SUPPORT OF MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS
I, STANLEY J. CATERBONE, Pro Se , am the petitioner in the above-entitled case. In support of
my motion to proceed in forma pauperis, I state that because of my poverty I am unable to pay
the costs of this case or to give security therefor; and I believe I am entitled to redress.
1. For both you and your spouse estimate the average amount of money received from each of
the following sources during the past 12 months. Adjust any amount that was received
weekly, biweekly, quarterly, semiannually, or annually to show the monthly rate. Use gross
amounts, that is, amounts before any deductions for taxes or otherwise.
Income source
Average monthly amount during

the past 12 months
Amount expected
next month
You
Spouse
You
Spouse
Employment
Self-employment
Income from real property

(such as rental income)
Interest and dividends
Gifts
Alimony
Child Support
Retirement (such as social

security, pensions,
annuities, insurance)
Disability (such as social

$ 1,357.00
security, insurance payments)
Unemployment payments
Public-assistance
(such as welfare)
Other (specify):
Total monthly income:
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
1,357.00
Page 5
2 of 91
45
62
70
88
1,357.00
1,357.00
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1031
29 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
2. List your employment history for the past two years, most recent rst. (Gross monthly pay
is before taxes or other deductions.)
Employer
Address
Dates of
Employment
Gross monthly pay

$
$
$
3. List your spouses employment history for the past two years, most recent employer rst.
(Gross monthly pay is before taxes or other deductions.)
Employer
Address
Dates of
Employment
Gross monthly pay

$
$
$
4. How much cash do you and your spouse have? $

Below, state any money you or your spouse have in bank accounts or in any other nancial
institution.
Financial institution
Type of account
Members1st
TD Ameritrade
Checking
Money Market
Amount you have

$ 1,000.00
$ 12,000.00
$
Amount your spouse has

$
$
$
5. List the assets, and their values, which you own or your spouse owns. Do not list clothing
and ordinary household furnishings.
X Home
D
Value 25% of 80,000.00
D Other real estate

Value
D Motor Vehicle #1
Year, make & model
Value
D Motor Vehicle #2
Year, make & model
Value
D Other assets
Description
Value
997,000 Shares of NON-MARKETABLE Stock in Advanced Media Group, Ltd.,
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 6
3 of 91
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1032
30 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 7 of 91
January January
Sunday
22, 201722, 2017

Page
Page1033
31 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
You
Transportation (not including motor vehicle payments)
Recreation, entertainment, newspapers, magazines, etc.
Your spouse
100.00
200.00
$
$
Insurance (not deducted from wages or included in mortgage payments)

48.00
Homeowners or renters
Life
Health
Motor Vehicle
Other:
Office/Computer/Copying/Printing/Postage
300.00
Taxes (not deducted from wages or included in mortgage payments)

$
Motor Vehicle
Credit card(s)
Department store(s)
Other:
Alimony, maintenance, and support paid to others
Regular expenses for operation of business, profession,
or farm (attach detailed statement)
Other (specify):
500.00
2,658.00
(specify):
Installment payments
Home Improvement
Total monthly expenses:
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 8
5 of 91
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1034
32 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 9 of 91
January January
Sunday
22, 201722, 2017

Page
Page1035
33 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
No.
IN THE
PETITIONER
(Your Name)
vs.
Superintendent Framingham MCI, et al
RESPONDENT(S)
ON PETITION FOR A WRIT OF CERTIORARI TO
U.S. THIRD CIRCUIT COURT OF APPEALS
(NAME OF COURT THAT LAST RULED ON MERITS OF YOUR CASE)
PETITION FOR WRIT OF CERTIORARI
(Your Name)
1250 Fremont Street
(Address)
Lancaster, PA 17603
(City, State, Zip Code)

(717) 669-2163
(Phone Number)
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page
Page10
7 of
of88
45
62
70
91
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1036
34 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
QUESTION(S) PRESENTED
July 18, 2016 C.A. 16-1149 ORDER Present Chargaras, Jordan, and Venaskie [The foregoing motion for reconsideration of the Clerk's Order is construed as a motion to review
that order and is denied as meritless. The Clerk has the authority under 3d Cir. LAR 3.3 and Misc.
107.1(a) to dismiss an appeal for failure to satisfy the fee requirement.
Appellant received
written notice of the need to take care of his fee obligation, and he failed to respond with either
payment of the fees or a motion seeking leave to proceed in forma pauperis (IFP). Appellant's
contention that he is being unjustly taxed twice for the same appeal is erroneous Appellant
incurred a fee obligation by filling a notice of appeal. See Fed. R. App. P. 3(e) (Upon filing a
notice of appeal, the appellant must pay the district clerk all required fees.).
He filed two
separate appeals (C.A. Nos. 15-3400 and 16-1149), and he incurred two fee obligations.
Moreover, we note that appellant suffered no monetary loss for his appeal at C.A. No. 15-3400 as
the Court granted his motion to voluntarily withdraw that appeal before his IFP motion was
considered or any fee remitted.
Even if we were to liberally construe appellant's filing as a motion to reopen, we would
deny it. Pursuant to 3d Cir. L.A.R Misc. 107.2(a), a motion to set aside an order of dismissal for
failure to prosecute must be filed within 10 days from the date of dismissal and must be justified
by a showing of good cause.
Appellant's motion was not submitted until March 15, 2016 a
month after the dismissal order was entered. As such, his motion is clearly untimely. Additionally
the Appellant has failed to provide to the court an excuse for his untimely filing.
He simply
asserts that he wants the Court to do what it has already declined to do, that is reopen C.A. 153400. Accordingly, given appellant's dilatoriness and his failure to establish good cause for the
untimely filing, reopening is not warranted. By The Court.]
WHY DID THE COURT FAIL TO COMPLY WITH OR CONSIDER DOCKET ENTRY NO.
DECEMBER 31, 2015 - THE LETTER TO THE COURT REQUESTING TO RESCIND THE
MOTION TO DISMISS?
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page
Page11
8 of
of88
45
62
70
91
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1037
35 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 12 of 91
January January
Sunday
22, 201722, 2017

Page
Page1038
36 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
TABLE OF CONTENTS
12
OPINIONS BELOW ........................................................................................................ 1
13
JURISDICTION...................................................................................................................
CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED .................................

14
STATEMENT OF THE CASE ............................................................................................
24
REASONS FOR GRANTING THE WRIT ..........................................................................
26
CONCLUSION....................................................................................................................
27
INDEX TO APPENDICES
APPENDIX A .............................................................................................................. 36
APPENDIX B ............................................................................................................... 41
APPENDIX C .............................................................................................................. 43
APPENDIX D .............................................................................................................. 47
APPENDIX E .............................................................................................................. 55
APPENDIX F .............................................................................................................. 60
APPENDIX G .............................................................................................................. 64
APPENDIX H .............................................................................................................. 71
APPENDIX I ............................................................................................................... 73
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 13
12 of 91
10
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1039
37 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
TABLE OF AUTHORITIES CITED
CASES
PAGE NUMBER
Pointer v. Texas, 380 U.S. 400, 85 S.Ct. 1065, 13 L.Ed.2d 923 (1965);
Appendix B -
STATUTES AND RULES
OTHER
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 14
13 of 91
11
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1040
38 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
IN THE

Petitioner respectfully prays that a writ of certiorari issue to review the judgment below.
OPINIONS BELOW
[X] For cases from federal courts:
The opinion of the United States court of appeals appears at Appendix
the petition and is
to
[ X] reported at U.S.C.A. THIRD CIRCUIT 16-1149 July 18, 2016

; or,
[ ] has been designated for publication but is not yet reported; or,
[ ] is unpublished.
The opinion of the United States district court appears at Appendix
the petition and is
to
[ ] reported at
; or,
[ ] is unpublished.
[ ] For cases from state courts:
The opinion of the highest state court to review the merits appears at
Appendix
to the petition and is
[ ] reported at
; or,
[ ] is unpublished.
The opinion of the
appears at Appendix
court
[ ] reported at
; or,
[ ] is unpublished.
1.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 15
14 of 91
12
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1041
39 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
JURISDICTION
[ X] For cases from federal courts:

The date on which the United States Court of Appeals decided my case
was June 15, 2016
.
[ ] No petition for rehearing was timely led in my case.
[ ] A timely petition for rehearing was denied by the United States Court of
Appeals on the following date: July 18, 2015
, and a copy of the
A
order denying rehearing appears at Appendix
.
[ ] An extension of time to le the petition for a writ of certiorari was granted
to and including
(date) on
(date)
in Application No.
A
.
The jurisdiction of this Court is invoked under 28 U. S. C. 1254(1).

The date on which the highest state court decided my case was
A copy of that decision appears at Appendix
.
[ ] A timely petition for rehearing was thereafter denied on the following date:
, and a copy of the order denying rehearing
appears at Appendix
.
to and including
(date) on
(date) in
Application No.
A
.
The jurisdiction of this Court is invoked under 28 U. S. C. 1257(a).
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 16
15 of 91
13
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1042
40 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
CONSTITUTIONAL AND STATUTORY PROVISIONS INVOLVED
Pointer v. Texas, 380 U.S. 400 (1965)
Supreme Court of the United States

Filed: April 5th, 1965
Precedential Status: Precedential
Citations: 380 U.S. 400, 85 S. Ct. 1065, 13 L. Ed. 2d 923, 1965 U.S. LEXIS 1481
Docket Number: 577
Supreme Court Database ID: 1964-069
Judges: Black
Nature of suit: Unknown
380 U.S. 400 (1965)
POINTER
v.
TEXAS.
No. 577.
Supreme Court of United States.
Argued March 15, 1965.
Decided April 5, 1965.
CERTIORARI TO THE COURT OF CRIMINAL APPEALS OF TEXAS.
Orville A. Harlan, by appointment of the Court, 379 U.S. 911, argued the cause and filed a brief
for petitioner.
Gilbert J. Pena, Assistant Attorney General of Texas, argued the cause for respondent. With him
on the brief were Waggoner Carr, Attorney General of Texas, Hawthorne Phillips, First Assistant
Attorney General, Stanton Stone, Executive Assistant Attorney General, and Howard M. Fender
and Allo B. Crow, Jr., Assistant Attorneys General.
MR. JUSTICE BLACK delivered the opinion of the Court.
The Sixth Amendment provides in part that:
"In all criminal prosecutions, the accused shall enjoy the right . . . to be confronted
with the witnesses *401 against him . . . and to have the Assistance of Counsel for his
defence."
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 17
14 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1043
41 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Two years ago in Gideon v. Wainwright, 372 U.S. 335, we held that the Fourteenth Amendment
makes the Sixth Amendment's guarantee of right to counsel obligatory upon the States. The
question we find necessary to decide in this case is whether the Amendment's guarantee of a
defendant's right "to be confronted with the witnesses against him," which has been held to
include the right to cross-examine those witnesses, is also made applicable to the States by the
Fourteenth Amendment.
The petitioner Pointer and one Dillard were arrested in Texas and taken before a state judge for a
preliminary hearing (in Texas called the "examining trial") on a charge of having robbed Kenneth
W. Phillips of $375 "by assault, or violence, or by putting in fear of life or bodily injury," in
violation of Texas Penal Code Art. 1408. At this hearing an Assistant District Attorney conducted
the prosecution and examined witnesses, but neither of the defendants, both of whom were
laymen, had a lawyer. Phillips as chief witness for the State gave his version of the alleged
robbery in detail, identifying petitioner as the man who had robbed him at gunpoint. Apparently
Dillard tried to cross-examine Phillips but Pointer did not, although Pointer was said to have tried
to cross-examine some other witnesses at the hearing. Petitioner was subsequently indicted on a
charge of having committed the robbery. Some time before the trial was held, Phillips moved to
California. After putting in evidence to show that Phillips had moved and did not intend to return
to Texas, the State at the trial offered the transcript of Phillips' testimony given at the preliminary
hearing as evidence against petitioner. Petitioner's counsel immediately objected to introduction of
the transcript, stating, "Your Honor, we will object to that, as it is a denial of the confrontment of
the witnesses against the Defendant." *402 Similar objections were repeatedly made by
petitioner's counsel but were overruled by the trial judge, apparently in part because, as the judge
viewed it, petitioner had been present at the preliminary hearing and therefore had been
"accorded the opportunity of cross examining the witnesses there against him." The Texas Court
of Criminal Appeals, the highest state court to which the case could be taken, affirmed petitioner's
conviction, rejecting his contention that use of the transcript to convict him denied him rights
guaranteed by the Sixth and Fourteenth Amendments. 375 S.W.2d 293. We granted certiorari to
consider the important constitutional question the case involves. 379 U.S. 815.
In this Court we do not find it necessary to decide one aspect of the question petitioner raises,
that is, whether failure to appoint counsel to represent him at the preliminary hearing
unconstitutionally denied him the assistance of counsel within the meaning of Gideon v.
Wainwright, supra. In making that argument petitioner relies mainly on White v. Maryland, 373
U.S. 59, in which this Court reversed a conviction based in part upon evidence that the defendant
had pleaded guilty to the crime at a preliminary hearing where he was without counsel. Since the
preliminary hearing there, as in Hamilton v. Alabama, 368 U.S. 52, was one in which pleas to the
charge could be made, we held in White as in Hamilton that a preliminary proceeding of that
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 18
15 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1044
42 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
nature was so critical a stage in the prosecution that a defendant at that point was entitled to
counsel. But the State informs us that at a Texas preliminary hearing, such as is involved here,
pleas of guilty are not guilty are not accepted and that the judge decides only whether the
accused should be bound over to the grand jury and if so whether he should be admitted to bail.
Because of these significant differences in the procedures of the respective States, we cannot say
that the White case is necessarily controlling *403 as to the right to counsel. Whether there might
be other circumstances making this Texas preliminary hearing so critical to the defendant as to
call for appointment of counsel at that stage we need not decide on this record, and that question
we reserve. In this case the objections and arguments in the trial court as well as the arguments
in the Court of Criminal Appeals and before us make it clear that petitioner's objection is based
not so much on the fact that he had no lawyer when Phillips made his statement at the
preliminary hearing, as on the fact that use of the transcript of that statement at the trial denied
petitioner any opportunity to have the benefit of counsel's cross-examination of the principal
witness against him. It is that latter question which we decide here.
I.
The Sixth Amendment is a part of what is called our Bill of Rights. In Gideon v. Wainwright, supra,
in which this Court held that the Sixth Amendment's right to the assistance of counsel is
obligatory upon the States, we did so on the ground that "a provision of the Bill of Rights which is
`fundamental and essential to a fair trial' is made obligatory upon the States by the Fourteenth
Amendment." 372 U. S., at 342. And last Term in Malloy v. Hogan, 378 U.S. 1, in holding that the
Fifth Amendment's guarantee against self-incrimination was made applicable to the States by the
Fourteenth, we reiterated the holding of Gideon that the Sixth Amendment's right-to-counsel
guarantee is " à fundamental right, essential to a fair trial,' " and "thus was made obligatory on
the States by the Fourteenth Amendment." 378 U. S., at 6. See also Murphy v. Waterfront
Comm'n, 378 U.S. 52. We hold today that the Sixth Amendment's right of an accused to confront
the witnesses against him is likewise a fundamental right and is made obligatory on the States by
the Fourteenth Amendment.
*404 It cannot seriously be doubted at this late date that the right of cross-examination is
included in the right of an accused in a criminal case to confront the witnesses against him. And
probably no one, certainly no one experienced in the trial of lawsuits, would deny the value of
cross-examination in exposing falsehood and bringing out the truth in the trial of a criminal case.
See, e. g., 5 Wigmore, Evidence 1367 (3d ed. 1940). The fact that this right appears in the
Sixth Amendment of our Bill of Rights reflects the belief of the Framers of those liberties and
safeguards that confrontation was a fundamental right essential to a fair trial in a criminal
prosecution. Moreover, the decisions of this Court and other courts [*] throughout the years have
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 19
16 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1045
43 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
constantly emphasized the necessity for cross-examination as a protection for defendants in

criminal cases. This Court in Kirby v. United States, 174 U.S. 47, 55, 56, referred to the right of
confrontation as "[o]ne of the fundamental guarantees of life and liberty," and "a right long
deemed so essential for the due protection of life and liberty that it is guarded against legislative
and judicial action by provisions in the Constitution of the United States and in the constitutions of
most if not of all the States composing the Union." Mr. Justice Stone, writing for the Court in
Alford v. United States, 282 U.S. 687, 692, declared that the right of cross-examination is "one of
the safeguards essential to a fair trial." And in speaking of confrontation and cross-examination
this Court said in Greene v. McElroy, 360 U.S. 474:
"They have ancient roots. They find expression in the Sixth Amendment which provides
that in all *405 criminal cases the accused shall enjoy the right `to be confronted with
the witnesses against him.' This Court has been zealous to protect these rights from
erosion." 360 U. S., at 496-497 (footnote omitted).
There are few subjects, perhaps, upon which this Court and other courts have been more nearly
unanimous than in their expressions of belief that the right of confrontation and cross-examination
is an essential and fundamental requirement for the kind of fair trial which is this country's
constitutional goal. Indeed, we have expressly declared that to deprive an accused of the right to
cross-examine the witnesses against him is a denial of the Fourteenth Amendment's guarantee of
due process of law. In In re Oliver, 333 U.S. 257, this Court said:
"A person's right to reasonable notice of a charge against him, and an opportunity to
be heard in his defensea right to his day in courtare basic in our system of
jurisprudence; and these rights include, as a minimum, a right to examine the
witnesses against him, to offer testimony, and to be represented by counsel." 333 U.
S., at 273 (footnote omitted).
And earlier this Term in Turner v. Louisiana, 379 U.S. 466, 472-473, we held:
"In the constitutional sense, trial by jury in a criminal case necessarily implies at the
very least that the èvidence developed' against a defendant shall come from the
witness stand in a public courtroom where there is full judicial protection of the
defendant's right of confrontation, of cross-examination, and of counsel."
Compare Willner v. Committee on Character & Fitness, 373 U.S. 96, 103-104.
*406 We are aware that some cases, particularly West v. Louisiana, 194 U.S. 258, 264, have
stated that the Sixth Amendment's right of confrontation does not apply to trials in state courts,
on the ground that the entire Sixth Amendment does not so apply. See also Stein v. New York,
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 20
17 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1046
44 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
346 U.S. 156, 195-196. But of course since Gideon v. Wainwright, supra, it no longer can broadly
be said that the Sixth Amendment does not apply to state courts. And as this Court said in Malloy
v. Hogan, supra, "The Court has not hesitated to re-examine past decisions according the
Fourteenth Amendment a less central role in the preservation of basic liberties than that which
was contemplated by its Framers when they added the Amendment to our constitutional scheme."
378 U. S., at 5. In the light of Gideon, Malloy, and other cases cited in those opinions holding
various provisions of the Bill of Rights applicable to the States by virtue of the Fourteenth
Amendment, the statements made in West and similar cases generally declaring that the Sixth
Amendment does not apply to the States can no longer be regarded as the law. We hold that
petitioner was entitled to be tried in accordance with the protection of the confrontation guarantee
of the Sixth Amendment, and that that guarantee, like the right against compelled selfincrimination, is "to be enforced against the States under the Fourteenth Amendment according to
the same standards that protect those personal rights against federal encroachment." Malloy v.
Hogan, supra, 378 U. S., at 10.
II.
Under this Court's prior decisions, the Sixth Amendment's guarantee of confrontation and crossexamination was unquestionably denied petitioner in this case. As has been pointed out, a major
reason underlying the *407 constitutional confrontation rule is to give a defendant charged with
crime an opportunity to cross-examine the witnesses against him. See, e. g., Dowdell v. United
States, 221 U.S. 325, 330; Motes v. United States, 178 U.S. 458, 474; Kirby v. United States, 174
U.S. 47, 55-56; Mattox v. United States, 156 U.S. 237, 242-243. Cf. Hopt v. Utah, 110 U.S. 574,
581; Queen v. Hepburn, 7 Cranch 290, 295. This Court has recognized the admissibility against an
accused of dying declarations, Mattox v. United States, 146 U.S. 140, 151, and of testimony of a
deceased witness who has testified at a former trial, Mattox v. United States, 156 U.S. 237, 240244. See also Dowdell v. United States, supra, 221 U. S., at 330; Kirby v. United States, supra,
174 U. S., at 61. Nothing we hold here is to the contrary. The case before us would be quite a
different one had Phillips' statement been taken at a full-fledged hearing at which petitioner had
been represented by counsel who had been given a complete and adequate opportunity to crossexamine. Compare Motes v. United States, supra, 178 U. S., at 474. There are other analogous
situations which might not fall within the scope of the constitutional rule requiring confrontation of
witnesses. The case before us, however, does not present any situation like those mentioned
above or others analogous to them. Because the transcript of Phillips' statement offered against
petitioner at his trial had not been taken at a time and under circumstances affording petitioner
through counsel an adequate opportunity to cross-examine Phillips, its introduction in a federal
court in a criminal case against Pointer would have amounted to denial of the privilege of
confrontation guaranteed by the Sixth Amendment. Since we hold that the right of an accused to
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 21
18 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1047
45 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
be confronted with the witnesses against him must be determined by the same standards whether
the right is denied in a federal or state proceeding, *408 it follows that use of the transcript to
convict petitioner denied him a constitutional right, and that his conviction must be reversed.
Reversed and remanded.
MR. JUSTICE HARLAN, concurring in the result.
I agree that in the circumstances the admission of the statement in question deprived the
petitioner of a right of "confrontation" assured by the Fourteenth Amendment. I cannot subscribe,
however, to the constitutional reasoning of the Court.
The Court holds that the right of confrontation guaranteed by the Sixth Amendment in federal
criminal trials is carried into state criminal cases by the Fourteenth Amendment. This is another
step in the onward march of the long-since discredited "incorporation" doctrine (see, e. g.,
Fairman, Does the Fourteenth Amendment Incorporate the Bill of Rights? The Original
Understanding, 2 Stan. L. Rev. 5 (1949); Frankfurter, Memorandum on "Incorporation" of the Bill
of Rights Into the Due Process Clause of the Fourteenth Amendment, 78 Harv. L. Rev. 746
(1965)), which for some reason that I have not yet been able to fathom has come into the
sunlight in recent years. See, e. g., Mapp v. Ohio, 367 U.S. 643; Ker v. California, 374 U.S. 23;
Malloy v. Hogan, 378 U.S. 1.
For me this state judgment must be reversed because a right of confrontation is "implicit in the
concept of ordered liberty," Palko v. Connecticut, 302 U.S. 319, 325, reflected in the Due Process
Clause of the Fourteenth Amendment independently of the Sixth.
While either of these constitutional approaches brings one to the same end result in this particular
case, there is a basic difference between the two in the kind of future constitutional development
they portend. The concept of Fourteenth Amendment due process embodied in Palko *409 and a
host of other thoughtful past decisions now rapidly falling into discard, recognizes that our
Constitution tolerates, indeed encourages, differences between the methods used to effectuate
legitimate federal and state concerns, subject to the requirements of fundamental fairness
"implicit in the concept of ordered liberty." The philosophy of "incorporation," on the other hand,
subordinates all such state differences to the particular requirements of the Federal Bill of Rights
(but see Ker v. California, supra, at 34) and increasingly subjects state legal processes to
enveloping federal judicial authority. "Selective" incorporation or "absorption" amounts to little
more than a diluted form of the full incorporation theory. Whereas it rejects full incorporation
because of recognition that not all of the guarantees of the Bill of Rights should be deemed
"fundamental," it at the same time ignores the possibility that not all phases of any given
guaranty described in the Bill of Rights are necessarily fundamental.
It is too often forgotten in these times that the American federal system is itself constitutionally
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 22
19 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1048
46 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
ordained, that it embodies values profoundly making for lasting liberties in this country, and that
its legitimate requirements demand continuing solid recognition in all phases of the work of this
Court. The "incorporation" doctrines, whether full blown or selective, are both historically and
constitutionally unsound and incompatible with the maintenance of our federal system on even
course.
MR. JUSTICE STEWART, concurring in the result.
I join in the judgment reversing this conviction, for the reason that the petitioner was denied the
opportunity to cross-examine, through counsel, the chief witness for the prosecution. But I do not
join in the Court's pronouncement which makes "the Sixth Amendment's right of an accused to
confront the witnesses against him . . . obligatory *410 on the States." That questionable tour de
force seems to me entirely unnecessary to the decision of this case, which I think is directly
controlled by the Fourteenth Amendment's guarantee that no State shall "deprive any person of
life, liberty, or property, without due process of law."
The right of defense counsel in a criminal case to cross-examine the prosecutor's living witnesses
is "[o]ne of the fundamental guarantees of life and liberty,"[1] and "one of the safeguards
essential to a fair trial."[2] It is, I think, as indispensable an ingredient as the "right to be tried in
a courtroom presided over by a judge."[3] Indeed, this Court has said so this very Term. Turner v.
Louisiana, 379 U.S. 466, 472-473.[4]
Here that right was completely denied. Therefore, as the Court correctly points out, we need not
consider the case which could be presented if Phillips' statement had been taken at a hearing at
which the petitioner's counsel was given a full opportunity to cross-examine. See West v.
Louisiana, 194 U.S. 258.
MR. JUSTICE GOLDBERG, concurring.
I agree with the holding of the Court that "the Sixth Amendment's right of an accused to confront
the witnesses against him is . . . a fundamental right and is made obligatory on the States by the
Fourteenth Amendment." Ante, at 403. I therefore join in the opinion and judgment of the Court.
My Brother HARLAN, while agreeing with the result reached by the Court, deplores the Court's
*411 reasoning as "another step in the onward march of the long-since discredited ìncorporation'
doctrine," ante, at 408. Since I was not on the Court when the incorporation issue was joined, see
Adamson v. California, 332 U.S. 46, I deem it appropriate to set forth briefly my view on this
subject.
I need not recapitulate the arguments for or against incorporation whether "total" or "selective."
They have been set forth adequately elsewhere.[1] My Brother BLACK'S view of incorporation has
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 23
20 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1049
47 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
never commanded a majority of the Court, though in Adamson it was assented to by four Justices.
The Court in its decisions has followed a course whereby certain guarantees "have been taken
over from the earlier articles of the federal bill of rights and brought within the Fourteenth
Amendment," Palko v. Connecticut, 302 U.S. 319, 326, by a process which might aptly be
described as "a process of absorption." Ibid. See Cohen v. Hurley, 366 U.S. 117, 154 (dissenting
opinion of MR. JUSTICE BRENNAN); Brennan, The Bill of Rights and the States, 36 N. Y. U. L. Rev.
761 (1961). Thus the Court has held that the Fourteenth *412 Amendment guarantees against
infringement by the States the liberties of the First Amendment,[2] the Fourth Amendment,[3]
the Just Compensation Clause of the Fifth Amendment,[4] the Fifth Amendment's privilege against
self-incrimination,[5] the Eighth Amendment's prohibition of cruel and unusual punishments,[6]
and the Sixth Amendment's guarantee of the assistance of counsel for an accused in a criminal
prosecution.[7]
With all deference to my Brother HARLAN, I cannot agree that this process has "come into the
sunlight in recent years." Ante, at 408. Rather, I believe that it has its origins at least as far back
as Twining v. New Jersey, 211 U.S. 78, 99, where the Court stated that "it is possible that some of
the personal rights safeguarded by the first eight Amendments against National action may also
be safeguarded against state action, because a denial of them would be a denial of due process of
law. Chicago, Burlington & Quincy Railroad v. Chicago, 166 U.S. 226." This passage and the
authority cited make clear that what is protected by the Fourteenth Amendment are "rights,"
which apply in every case, not solely in those cases where it seems "fair" to a majority of the
Court to afford the protection. Later cases reaffirm that the process of "absorption" is one of
extending "rights." See Ker v. California, 374 U.S. 23; Malloy v. Hogan, 378 U.S. 1, and cases
cited by MR. JUSTICE BRENNAN in his dissenting opinion in Cohen v. Hurley, supra, at 156. I
agree with these decisions, as is apparent from my votes in *413 Gideon v. Wainwright, 372 U.S.
335; Malloy v. Hogan, supra, and Murphy v. Waterfront Comm'n, 378 U.S. 52, and my concurring
opinion in New York Times Co. v. Sullivan, 376 U.S. 254, 297, and I subscribe to the process by
which fundamental guarantees of the Bill of Rights are absorbed by the Fourteenth Amendment
and thereby applied to the States.
Furthermore, I do not agree with my Brother HARLAN that once a provision of the Bill of Rights
has been held applicable to the States by the Fourteenth Amendment, it does not apply to the
States in full strength. Such a view would have the Fourteenth Amendment apply to the States
"only a `watered-down, subjective version of the individual guarantees of the Bill of Rights.' "
Malloy v. Hogan, supra, at 10-11. It would allow the States greater latitude than the Federal
Government to abridge concededly fundamental liberties protected by the Constitution. While I
quite agree with Mr. Justice Brandeis that "[i]t is one of the happy incidents of the federal system
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 24
21 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1050
48 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
that a . . . State may . . . serve as a laboratory; and try novel social and economic experiments,"
New State Ice Co. v. Liebmann, 285 U.S. 262, 280, 311 (dissenting opinion), I do not believe that
this includes the power to experiment with the fundamental liberties of citizens safeguarded by
the Bill of Rights. My Brother HARLAN'S view would also require this Court to make the extremely
subjective and excessively discretionary determination as to whether a practice, forbidden the
Federal Government by a fundamental constitutional guarantee, is, as viewed in the factual
circumstances surrounding each individual case, sufficiently repugnant to the notion of due
process as to be forbidden the States.
Finally, I do not see that my Brother HARLAN'S view would further any legitimate interests of
federalism. It would require this Court to intervene in the state judicial process with considerable
lack of predictability and with *414 a consequent likelihood of considerable friction. This is well
illustrated by the difficulties which were faced and were articulated by the state courts attempting
to apply this Court's now discarded rule of Betts v. Brady, 316 U.S. 455. See Green, The Bill of
Rights, the Fourteenth Amendment and the Supreme Court, 46 Mich. L. Rev. 869, 897-898. These
difficulties led the Attorneys General of 22 States to urge that this Court overrule Betts v. Brady
and apply fully the Sixth Amendment's guarantee of right to counsel to the States through the
Fourteenth Amendment. See Gideon v. Wainwright, supra, at 336. And, to deny to the States the
power to impair a fundamental constitutional right is not to increase federal power, but, rather, to
limit the power of both federal and state governments in favor of safeguarding the fundamental
rights and liberties of the individual. In my view this promotes rather than undermines the basic
policy of avoiding excess concentration of power in government, federal or state, which underlines
our concepts of federalism.
I adhere to and support the process of absorption by means of which the Court holds that certain
fundamental guarantees of the Bill of Rights are made obligatory on the States through the
Fourteenth Amendment. Although, as this case illustrates, there are differences among members
of the Court as to the theory by which the Fourteenth Amendment protects the fundamental
liberties of individual citizens, it is noteworthy that there is a large area of agreement, both here
and in other cases, that certain basic rights are fundamentalnot to be denied the individual by
either the state or federal governments under the Constitution. See, e. g., Cantwell v.
Connecticut, 310 U.S. 296; NAACP v. Alabama ex rel. Patterson, 357 U.S. 449; Gideon v.
Wainwright, supra; New York Times Co. v. Sullivan, supra; Turner v. Louisiana, 379 U.S. 466.
NOTES
[*] See state and English cases collected in 5 Wigmore, Evidence 1367, 1395 (3d ed. 1940).
State constitutional and statutory provisions similar to the Sixth Amendment are collected in 5
Wigmore, supra, 1397, n. 1.
[1] Kirby v. United States, 174 U.S. 47, 55.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 25
22 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1051
49 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
[2] Alford v. United States, 282 U.S. 687, 692.

[3] Rideau v. Louisiana, 373 U.S. 723, 727.
[4] See also In re Murchison, 349 U.S. 133, where the Court said that "due process requires as a
minimum that an accused be given a public trial after reasonable notice of the charges, have a
right to examine witness against him, call witnesses on his own behalf, and be represented by
counsel." 349 U. S., at 134.
[1] See Adamson v. California, supra, at 59 (concurring opinion of Mr. Justice Frankfurter); id., at
68 (dissenting opinion of MR. JUSTICE BLACK); Malloy v. Hogan, 378 U.S. 1; id., at 14 (dissenting
opinion of MR. JUSTICE HARLAN); Gideon v. Wainwright, 372 U.S. 335, 345 (concurring opinion of
MR. JUSTICE DOUGLAS); id., at 349 (concurring opinion of MR. JUSTICE HARLAN); Poe v. Ullman,
367 U.S. 497, 509 (dissenting opinion of MR. JUSTICE DOUGLAS); Frankfurter, Memorandum on
"Incorporation" of the Bill of Rights Into the Due Process Clause of the Fourteenth Amendment, 78
Harv. L. Rev. 746; Black, The Bill of Rights, 35 N. Y. U. L. Rev. 865 (1960); Brennan, The Bill of
Rights and the States, 36 N. Y. U. L. Rev. 761 (1961); Fairman, Does the Fourteenth Amendment
Incorporate the Bill of Rights? The Original Understanding, 2 Stan. L. Rev. 5 (1949); Green, The
Bill of Rights, the Fourteenth Amendment and the Supreme Court, 46 Mich. L. Rev. 869 (1948);
Henkin, "Selective Incorporation" in the Fourteenth Amendment, 73 Yale L. J. 74 (1963).
[2] See, e. g., Gitlow v. New York, 268 U.S. 652, 666; De Jonge v. Oregon, 299 U.S. 353, 364;
Cantwell v. Connecticut, 310 U.S. 296, 303; Louisiana ex rel. Gremillion v. NAACP, 366 U.S. 293,
296; New York Times Co. v. Sullivan, 376 U.S. 254.
[3] See Wolf v. Colorado, 338 U.S. 25; Mapp v. Ohio, 367 U.S. 643.
[4] Chicago, B. & Q. R. Co. v. Chicago, 166 U.S. 226.
[5] Malloy v. Hogan, 378 U.S. 1.
[6] Robinson v. California, 370 U.S. 660.
[7] Gideon v. Wainwright, 372 U.S. 335.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 26
23 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1052
50 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
STATEMENT OF THE CASE

On June 23, 2015 APPELLANT, Stanley J. Caterbone, filed an Amicus Curei Brief in the U.S.
District Court Case No. 14-02559 in PETITIONER LISA MICHELLE LAMBERT'S HABEUS CORPUS,
which was originally filed on May 14, 2014. On September 2, 2015 APPELLANT filed a MOTION
FOR SUMMARY JUDGEMENT.
On September 14, 2015 U.S. District Judge Paul S. Diamond
ORDERED that Mr. Caterbones Motions for Summary Judgment (Doc. Nos. 8, 9) and
Motions to File Exhibits or Statements (Doc. Nos. 10, 11, 12, 14) are DENIED as
frivolous. It is FURTHER ORDERED that Stanley J. Caterbone may no longer submit
filingswhether electronic or in paper formatin the above-captioned case. The Clerk
shall not docket any such filings without my approval.
On September 30, 2015 APPELLANT filed an APPEAL to U.S.C.A. To the Third Circuit Case
No. 15-3400. On November 24, 2015 Stanley J. Caterbone FILED a Motion for a 30 Day Extension
of Time, which was GRANTED. On December 14, 2015 Stanley J. Caterbone FILED a LETTER to
the Clerk requesting to WITHDRAW appeal no. 15-3400 in the Third Circuit due among other
things the APPELLANT'S computer was taken by the GEEK SQUAD, whom refused to return it. On
December 17, 2015 APPELLANT FILED a LETTER to the Clerk CLARIFYING the Withdraw as a
MOTION to WITHDRAW WITHOUT PREJUDICE.
On December 31, 2015 Stanley J. Caterbone
FILED a LETTER to the COURT RESCINDING his MOTION TO WITHDRAW.1

On January 12, 2016 FISHER, JORDAN and VANASKIE, Circuit Judges, ISSUED AN ORDER
in Case No. 15-3400 MOTION TO WITHDRAW GRANTED.2 On January 12, 2016 FISHER, JORDAN
and VANASKIE, Circuit Judges, ISSUED AN ORDER in Case No. 15-3400 MOTION TO WITHDRAW
GRANTED.3 On January 13, 2016 Stanley J. Caterbone FILED a MOTION TO REINSTATE the Appeal
in the Third Circuit.
On January 15, 2016 (FISHER, JORDAN and VANASKIE, Circuit Judges
ISSUED AN ORDER DENIED MOTION TO REINSTATE the Appeal in the Third Circuit. On January
17, 2015 in the United States District Court for the Eastern District of Pennsylvania in Case No.
14-02559 APPELLANT FILED a NOTICE OF APPEAL and U.S District Court, 14-02559, January 17,
2015 in the United States District Court for the Eastern District of Pennsylvania in Case No. 1402559 Clerk's Notice to USCA re 25 Notice of Appeal : (jpd, ) (Entered: 01/20/2016). On January
1
The Letter to Rescind was either hidden from FISHER, JORDAN and VANASKIE or FISHER, JORDAN and VANASKIE
ignored the Letter to Rescind. This would have preserved the entire Record of Case No. 15-3400 including EXHIBITS,
MOTIONS, ETC.,.
2
This DELETED AND REMOVED FROM THE PUBLIC DOMAIN and from DELIBERATIONS the entire the Record of Case No.
15-3400 including EXHIBITS, MOTIONS, ETC., which SUPPORTS AND PROVIDES EVIDENCE FOR AFFIRMATION OF THE
MOTION FOR SUMMARY JUDGEMENT in Case No. 14-02559 and a FAVORABLE Ruling in the U.S. Third Circuit Court of
Appeals for the Complainant, and Pro Se Appellant.
3
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 27
24 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1053
51 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
22, 2016 in the U.S. THIRD CIRCUIT Clerk Issues New Docket No. 16-1149.
On February 16, 2016 the Clerk ORDERED the APPEAL dismissed due to F.R.A.P. (3) a and
FRAP 3.3 and Misc 107.1(a) for failure to pay the filing fee for the Notice of Appeal. On March 15,
2016 APPELLANT filed a Motion for Reconsideration and finally on July 28, 2016 Judges Chargaras,
Jordan, and Venaskie ORDERED The foregoing motion for reconsideration of the Clerk's
Order is construed as a motion to review that order and is denied as meritless.
The
Clerk has the authority under 3d Cir. LAR 3.3 and Misc. 107.1(a) to dismiss an appeal
for failure to satisfy the fee requirement.
It is clear that the omission for considerations the Letter of December 31, 2015 instructing
the COURTS to rescind the Motion to Withdraw was a clear violation of APPELLANT'S right to due
process and right to appeal that set in motion filings and decisions which should be considered as
MOOT to the original APPEAL. The APPELLANT wishes the COURT to reverse this obstruction of
justice.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 28
25 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1054
52 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
REASONS FOR GRANTING THE PETITION

It is clear that the omission for considerations of the Letter of December 31, 2015
instructing the COURTS to rescind the Motion to Withdraw was a clear violation of APPELLANT'S
right to due process and right to appeal that set in motion filings and decisions which should be
considered as MOOT to the original APPEAL. The APPELLANT wishes the COURT to reverse this
obstruction of justice.
unprecedented case starting; with the original HABEUS CORPUS written and filed by PETITIONER
Lisa Michelle Lambert in 1997, the findings of U.S. District Judge Stewert Dalzall's that this case
contained one of the worst cases of prosecutorial misconduct in the English speaking language
and releasing Lisa Michelle Lambert from prison;
wrongdoings in this case.
and ultimately the contamination of
This again is another case of JUDICIAL MISCONDUCT and
PROSECUTORIAL MISCONDUCT at the WORST or a case of ERRORS and OMMISSIONS at best

regarding the adjudication of the APPELLANT'S original Amicus Curie Brief and Motion for
Summary Judgment in PETITIONER'S Lisa Michelle Lambert's Habeus Corpus of May of 2014.
This case was of national importance and received national attention immediately following
the findings of U.S. District Judge Stewert Dalzall and the release of Lisa Michelle Lambert from
prison in 1997.
A&E TV did a documentary, which aired on national television titled American
Justice: A Teenage Murder Mystery and also sells the DVD online today. See Appendix H. The LA
Times published a 3-part series beginning on November 10, 1997 by Journalist Barry Seigel. See
Appendix I.
It is in the public's best interest to restore integrity to the COURTS and to the Prosecutors
and Judges and the COURTS that are honest and fair;
and provide the means to which Lisa
Michelle Lambert's meritorious plight for RELIEF and RELEASE from Prison can then be
accomplished, as it should.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 29
26 of 91
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1055
53 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 30 of 91
January January
Sunday
22, 201722, 2017

Page
Page1056
54 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 31 of 91
January January
Sunday
22, 201722, 2017

Page
Page1057
55 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
PROOF OF SERVICE
Mr. Craig Stedman,

Lancaster County District Attorney
50 N. Duke Street
Lancaster, PA 17602
Mr. XXXXXXXXX
Doug Behmer,Bruce Beemer
Pennsylvania State Attorney General
Ibrahim, Jeremy
Ibrahim Jeremy Attorney
1700 Race St
Phone: (215) 568-1943
Lisa Michelle Lambert /Superintendant
MCI - Framingham
P.O. Box 9007
xxxxxxxxxxxxxxxxxxxxxx
xx 01704
Framingham,
PA
The Honorable Paul S. Diamond

U.S. District Court for the Eastern District of Pennsylvania
601 Market Street
xxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxx
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 32
29 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1058
56 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
October 2015
OFFICE OF THE CLERK
WASHINGTON, D. C. 20543
GUIDE FOR PROSPECTIVE INDIGENT PETITIONERS FOR WRITS OF
CERTIORARI
I. Introduction
These instructions and forms are designed to assist petitioners who are proceeding in
forma pauperis and without the assistance of counsel. A copy of the Rules of the
Supreme Court, which establish the procedures that must be followed, is also enclosed.
Be sure to read the following Rules carefully:
Rules 10-14 (Petitioning for certiorari)
Rule 29 (Filing and service on opposing party or counsel)
Rule 30 (Computation and extension of time)
Rules 33.2 and 34 (Preparing pleadings on 812 x 11 inch paper)
Rule 39 (Proceedings in forma pauperis)
II. Nature of Supreme Court Review

It is important to note that review in this Court by means of a writ of certiorari is not
a matter of right, but of judicial discretion. The primary concern of the Supreme
Court is not to correct errors in lower court decisions, but to decide cases presenting
issues of importance beyond the particular facts and parties involved. The Court
grants and hears argument in only about 1% of the cases that are led each Term.
The vast majority of petitions are simply denied by the Court without comment or
explanation. The denial of a petition for a writ of certiorari signies only that the
Court has chosen not to accept the case for review and does not express the Courts
view of the merits of the case.
Every petitioner for a writ of certiorari is advised to read carefully the Considerations
Governing Review on Certiorari set forth in Rule 10. Important considerations for
accepting a case for review include the existence of a conict between the decision of
which review is sought and a decision of another appellate court on the same issue.
An important function of the Supreme Court is to resolve disagreements among lower
courts about specic legal questions. Another consideration is the importance to the
public of the issue.
III. The Time for Filing
You must le your petition for a writ of certiorari within 90 days from the date of the
entry of the nal judgment in the United States court of appeals or highest state
appellate court or 90 days from the denial of a timely led petition for rehearing. The
issuance of a mandate or remittitur after judgment has been entered has no bearing
on the computation of time and does not extend the time for ling. See Rules 13.1 and
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 33
21 of 91
29
30
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1059
57 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
13.3. Filing in the Supreme Court means the actual receipt of documents by the Clerk;
or their deposit in the United States mail, with rst-class postage prepaid, on or before
the nal date allowed for ling; or their delivery to a third-party commercial carrier,
on or before the nal date allowed for ling, for delivery to the Clerk within 3 calendar
days. See Rule 29.2.
IV. What To File
Unless you are an inmate conned in an institution and not represented by counsel,
le:
An original and ten copies of a motion for leave to proceed in forma pauperis and
an original and 10 copies of an afdavit or declaration in support thereof. See Rule 39.
An original and 10 copies of a petition for a writ of certiorari with an appendix
consisting of a copy of the judgment or decree you are asking this Court to review
including any order on rehearing, and copies of any opinions or orders by any courts or
administrative agencies that have previously considered your case. See Rule 14.1(i).
One afdavit or declaration showing that all opposing parties or their counsel have
been served with a copy of the papers led in this Court. See Rule 29.
If you are an inmate conned in an institution and not represented by counsel, you need
le only the original of the motion for leave to proceed in forma pauperis, afdavit or
declaration when needed in support of the motion for leave to proceed in forma pau
peris, the petition for a writ of certiorari, and proof of service.
If the court below appointed counsel in the current proceeding, no afdavit or declara
tion is required, but the motion should cite the provision of law under which counsel
was appointed, or a copy of the order of appointment should be appended to the motion.
See Rule 39.1.
The attached forms may be used for the original motion, afdavit or declaration, and
petition, and should be stapled together in that order. The proof of service should be
included as a detached sheet, and the form provided may be used.
V. Page Limitation
The petition for a writ of certiorari may not exceed 40 pages excluding the pages that
precede Page 1 of the form. The documents required to be contained in the appendix
to the petition do not count toward the page limit. See Rule 33.2(b).
VI. Method of Filing

All documents to be led in this Court must be addressed to the Clerk, Supreme Court
of the United States, Washington, D. C. 20543 and must be served on opposing parties
or their counsel in accordance with Rule 29.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 34
22 of 91
30
31
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1060
58 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
INSTRUCTIONS FOR COMPLETING FORMS
I.
Motion for Leave to Proceed In Forma Pauperis - Rule 39

A. On the form provided for the motion for leave to proceed in forma pauperis,
leave the case number blank. The number will be assigned by the Clerk when
the case is docketed.
B. On the line in the case caption for petitioner, type your name. As a pro
se petitioner, you may represent only yourself. On the line for respondent,
type the name of the opposing party in the lower court. If there are multiple
respondents, enter the rst respondent, as the name appeared on the lower court
decision, followed by et al. to indicate that there are other respondents. The
additional parties must be listed in the LIST OF PARTIES section of the
petition.
C. If the lower courts in your case granted you leave to proceed in forma pau
peris, check the appropriate space and indicate the court or courts that allowed
you to proceed in forma pauperis. If none of the lower courts granted you
leave to proceed in forma pauperis, check the block that so indicates.
D. Sign the motion on the signature line.
II. Afdavit or Declaration in Support of Motion for Leave to Proceed In Forma

Pauperis
On the form provided, answer fully each of the questions. If the answer to a question
is 0, none, or not applicable (N/A), enter that response. If you need more space
to answer a question or to explain your answer, attach a separate sheet of paper,
identied with your name and the question number. Unless each question is fully
answered, the Clerk will not accept the petition. The form must either be notarized
or be in the form of a declaration. See 28 U. S. C. 1746.
III. Cover Page - Rule 34
When you complete the form for the cover page:
A. Leave case number blank. The number will be assigned by the Clerk when
B. Complete the case caption as you did on the motion for leave to proceed in
forma pauperis.
C. List the court from which the action is brought on the line following the
words on petition for a writ of certiorari to. If your case is from a state court,
enter the name of the court that last addressed the merits of the case. For
example, if the highest state court denied discretionary review, and the state
court of appeals afrmed the decision of the trial court, the state court of
appeals should be listed. If your case is federal, the United States court of
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 35
23 of 91
31
32
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1061
59 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
appeals that decided your case will always be listed here.

D. Enter your name, address, and telephone number in the appropriate spaces.
IV. Question(s) Presented
On the page provided, enter the question or questions that you wish the Court to
review. The questions must be concise. Questions presented in cases accepted for
review are usually no longer than two or three sentences. The purpose of the question
presented is to assist the Court in selecting cases. State the issue you wish the Court
to decide clearly and without unnecessary detail.
V. List of Parties
On the page provided, check either the box indicating that the names of all parties
appear in the caption of the case on the cover page or the box indicating that there are
additional parties. If there are additional parties, list them. Rule 12.6 states that all
parties to the proceeding whose judgment is sought to be reviewed shall be deemed
parties in this Court, and that all parties other than petitioner shall be respondents.
The court whose judgment you seek to have this Court review is not a party.
VI. Table of Contents
On the page provided, list the page numbers on which the required portions of the
petition appear. Number the pages consecutively, beginning with the Opinions
Below page as page 1.
VII. Index of Appendices
List the description of each document that is included in the appendix beside the appro
priate appendix letter. Mark the bottom of the rst page of each appendix with the
appropriate designation, e.g., Appendix A. See Rule 14.1 pertaining to the items to
be included in the appendix.
A. Federal Courts
If you are asking the Court to review a decision of a federal court, the decision
of the United States court of appeals should be designated Appendix A.
Appendix A should be followed by the decision of the United States District
Court and the ndings and recommendations of the United States magistrate
judge, if there were any. If the United States court of appeals denied a timely
led petition for rehearing, a copy of that order should be appended next. If
you are seeking review of a decision in a habeas corpus case, and the decision of
either the United States District Court or the United States Court of Appeals
makes reference to a state court decision in which you were a party, a copy of
the state court decision must be included in the appendix.
B. State Courts
If you are asking the Court to review a decision of a state court, the decision of
which review is sought should be designated Appendix A. Appendix A should
be followed by the decision of the lower court or agency that was reviewed in
the decision designated Appendix A. If the highest court of the state in which a
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 36
24 of 91
32
33
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1062
60 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
decision could be had denied discretionary review, a copy of that order should
follow. If an order denying a timely led petition for rehearing starts the run
ning of the time for ling a petition for a writ of certiorari pursuant to Rule 13.3,
a copy of the order should be appended next.
As an example, if the state trial court ruled against you, the intermediate court
of appeals afrmed the decision of the trial court, the state supreme court denied
discretionary review and then denied a timely petition for rehearing, the appen
dices should appear in the following order:
Appendix A Decision of State Court of Appeals
Appendix B Decision of State Trial Court
Appendix C Decision of State Supreme Court Denying Review
Appendix D Order of State Supreme Court Denying Rehearing
VIII. Table of Authorities

On the page provided, list the cases, statutes, treatises, and articles that you reference
in your petition, and the page number of your petition where each authority appears.
IX. Opinions Below
In the space provided, indicate whether the opinions of the lower courts in your case
have been published, and if so, the citation for the opinion below. For example, opin
ions of the United States courts of appeals are published in the Federal Reporter. If
the opinion in your case appears at page 100 of volume 30 of the Federal Reporter,
Third Series, indicate that the opinion is reported at 30 F. 3d 100. If the opinion has
been designated for publication but has not yet been published, check the appropriate
space. Also indicate where in the appendix each decision, reported or unreported,
appears.
X. Jurisdiction
The purpose of the jurisdiction section of the petition is to establish the statutory
source for the Courts jurisdiction and the dates that determine whether the petition
is timely led. The form sets out the pertinent statutes for federal and state cases.
You need provide only the dates of the lower court decisions that establish the timeli
ness of the petition for a writ of certiorari. If an extension of time within which to
le the petition for a writ of certiorari was granted, you must provide the requested
information pertaining to the extension. If you seek to have the Court review a deci
sion of a state court, you must provide the date the highest state court decided your
case, either by ruling on the merits or denying discretionary review.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 37
25 of 91
33
34
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1063
61 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
XI. Constitutional and Statutory Provisions Involved

Set out verbatim the constitutional provisions, treaties, statutes, ordinances and regu
lations involved in the case. If the provisions involved are lengthy, provide their cita
tion and indicate where in the Appendix to the petition the text of the provisions
appears.
XII. Statement of the Case
Provide a concise statement of the case containing the facts material to the consider
ation of the question(s) presented; you should summarize the relevant facts of the case
and the proceedings that took place in the lower courts. You may need to attach
additional pages, but the statement should be concise and limited to the relevant facts
of the case.
XIII. Reasons for Granting the Petition
The purpose of this section of the petition is to explain to the Court why it should
grant certiorari. It is important to read Rule 10 and address what compelling reasons
exist for the exercise of the Courts discretionary jurisdiction. Try to show not only
why the decision of the lower court may be erroneous, but the national importance of
having the Supreme Court decide the question involved. It is important to show
whether the decision of the court that decided your case is in conict with the decisions
of another appellate court; the importance of the case not only to you but to others
similarly situated; and the ways the decision of the lower court in your case was errone
ous. You will need to attach additional pages, but the reasons should be as concise as
possible, consistent with the purpose of this section of the petition.
XIV. Conclusion
Enter your name and the date that you submit the petition.
XV. Proof of Service
You must serve a copy of your petition on counsel for respondent(s) as required by
Rule 29. If you serve the petition by rst-class mail or by third-party commercial
carrier, you may use the enclosed proof of service form. If the United States or any
department, ofce, agency, ofcer, or employee thereof is a party, you must serve the
Solicitor General of the United States, Room 5614, Department of Justice, 950 Pennsyl
vania Ave., N.W., Washington, D. C. 205300001. The lower courts that ruled on your
case are not parties and need not be served with a copy of the petition. The proof of
service may be in the form of a declaration pursuant to 28 U. S. C. 1746.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 38
26 of 91
34
35
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1064
62 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX A
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 39
36 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1065
63 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
COPY
Page 40
27 of 91
35
37
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1066
64 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 41
28 of 91
36
38
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1067
65 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 42
29 of 91
37
39
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1068
66 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 43
30 of 91
38
40
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1069
67 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX B
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 44
41 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
15-3400
January January
Sunday
22,Case:
201722,
2017
Document:
003112168218
Page:
1 StanDate
Filed:
12/31/2015
REQUEST
FOR
COMMUTATION
Page
Page1070
68 ofof1299
2301
OF
THE SENTENCE
J. Caterbone
OF
LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
December 31, 2015

To:
United States Third Circuit Court of Appeals

Clerk of Courts
Re:
Case No. 15-3400 Lambert Appeal

Motion to Dismiss of December 14, 2015
RESCIND MOTION TO DISMISS
Dear Clerk of Court:

Unfortunately there have been many developments regarding my issues in
the courts, including the Lancaster County Court of Common Pleas, the Pennsylvania
Superior Court, the U.S. District Court for the Eastern District of Pennsylvania, and of
course the U.S.C.A.
There have also been a fluid and horrendous amount of
computer and electronic hacking attacks upon my electronics, including my

computers. Since I filed my motion to dismiss there have also been developments in
the Pennsylvania Attorney General Kathleen Kane scandal that directly involves
myself and my issues. In addition, on Wednesday, December 30, 2015 I was able to
take back possession of my new Lenovo Laptop and have been able to file
electronically in the ECF system.
IMPORTANT
Accordingly, I wish to rescind my MOTION TO DISMISS and would ask that if
you require a Motion to contact me as soon as possible.
/S/
Stan J. Caterbone, Pro Se APPELLANT
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 45
31 of 91
39
42
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1071
69 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX C
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 46
43 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1072
70 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 47
32 of 91
40
44
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1073
71 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 48
33 of 91
41
45
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1074
72 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 49
34 of 91
42
46
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1075
73 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX D
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 50
47 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1076
74 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 51
35 of 91
43
48
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1077
75 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 52
36 of 91
44
49
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1078
76 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 53
37 of 91
45
50
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1079
77 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 54
38 of 91
46
51
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1080
78 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 55
39 of 91
47
52
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1081
79 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 56
40 of 91
48
53
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1082
80 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 57
41 of 91
49
54
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1083
81 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX E
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 58
55 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1084
82 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 59
42 of 91
50
56
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1085
83 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 60
43 of 91
51
57
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1086
84 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 61
44 of 91
52
58
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1087
85 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 62
45 of 91
53
59
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1088
86 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX F
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 63
60 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
Case
Document
15
Filed
Page
1 of
3
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Page
Page1089
87 ofof
1299
2301
OF
THE 09/14/15
SENTENCE
Stan J. Caterbone
OF LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA
LISA MICHELLE LAMBERT,
Petitioner,
v.
LYNN BISSONETTE, et al.,
Respondents.
:
:
:
:
:
:
:
:
Civ. No. 14-2559
ORDER
I previously dismissed Petitioners pro se motion for habeas relief so that she could file a
counseled motion.
(Doc. No. 3.)
She has not yet done so.
On June 23, 2015, Stanley
Caterbonewho has nothing to do with Petitioner, her motion, or this casefiled a pro se
amicus brief in support of the dismissed motion. (Doc. No. 4.) Caterbone neither sought leave
to file, nor indicated that he had received the Parties consent to file an amicus brief. Fed. R.
Civ. P. 29(a).
The amicus briefalthough providing some arguments in apparent support of the
dismissed motionessentially focuses on the damages Caterbone allegedly suffered from his
years of torture as a victim of U.S. Sponsored Mind Control or as a victim of gang-stalking or
organized stalking by more than 100 people. (Doc. No. 4 at 7, 9). He also includes a lengthy
discussion of the perplexing question of Stan Caterbones intelligence, or lack thereof, and his
work on a digital movie that is directly responsible for the development of the internet.
(Id. at 16-26). In addition, he details thirty governmental attempts at mind control, including:
1) Blanketing my dwelling and surroundings with electromagnetic energy; 2) Invading my
thoughts via remote sensing technologies; and 3) Making me mentally hear others voices
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 64
54 of 91
61
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Case
Document
15
Filed
Page
2 of
3
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Page
Page1090
88 ofof
1299
2301
OF
THE 09/14/15
SENTENCE
Stan J. Caterbone
OF LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
through the microwave hearing effect. (Id. at 27-30.)

Caterbones involvement in the matter did not end with his amicus brief. On July 6,
2015, he filed with this Court an email that he had sent to the Lancaster Police, asserting that he
has synthetic telepathy. (Doc. No. 5.) On September 2 and 3, 2015, Caterbone moved for
summary judgment. (Doc. Nos. 8, 9.) On September 3, 2015, he moved to file a copy of his
motion for reconsideration of the denial of his petition to proceed in forma pauperis in
Pennsylvania state court, (which had been dismissed as frivolous). (Doc. No. 10.)
On
September 9, 2015, he also moved to file: 1) an email exchange with the subject Muslims Using
My Situation to Fight Against the USA; 2) a Wikipedia article on Entrapment; and 3) an
exhibit of billing statements of his estimated fees for his 2007 work on wholly unrelated federal
and state court cases. (Doc. Nos. 11, 12, 14.)
On September 9, 2015, Caterbone called my
Chambers, demanding to speak with me, and then abruptly hung up.
I have already denied Caterbones request to file documents electronically. (Doc. No. 9.)
He has nonetheless continued to submit filings that have nothing to do with this case.
Page 2 of 3
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 65
55 of 91
62
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Case
Document
15
Filed
Page
3 of
3
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Page
Page1091
89 ofof
1299
2301
OF
THE 09/14/15
SENTENCE
Stan J. Caterbone
OF LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
AND NOW, this 11th day of September, 2015, it is hereby ORDERED that Mr.
Caterbones Motions for Summary Judgment (Doc. Nos. 8, 9) and Motions to File Exhibits or
Statements (Doc. Nos. 10, 11, 12, 14) are DENIED as frivolous. It is FURTHER ORDERED
that Stanley J. Caterbone may no longer submit filingswhether electronic or in paper format
in the above-captioned case. The Clerk shall not docket any such filings without my approval.
AND IT IS SO ORDERED.
/s/ Paul S. Diamond

_________________________
Paul S. Diamond, J.
September 11, 2015
Page 3 of 3
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 66
56 of 91
63
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1092
90 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX G
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 67
64 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
Document
92301
Filed
Page
1 ofLAMBERT
6
Sunday
January January
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1093
91 ofof1299
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
UNITED STATES DISlf"RICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLNAIA
\
Petitioner
v.
LYNN BISSONETTE, SUPERINTENDENT,
MCI-FRAMINGHAM,
and
CRAIG STEDMAN, THE DISTRICT ATfORNEY OF LANCASTER
and
KATHLEEN KANE, THE ATfORNEY GENERAL OF PENNSYLVANIA,
Respondents
Civ. No. 5:14-cv-02559-PD
S 17=n
F uu~t:
lY
SEP - 3 2D15
MICHAELE. KUNZ, Clerk
By
Dep. Clerk
MOTION TO FILE SUMMARY JUDGEMENT
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 the following Motion for Summary Judgement according to rule 56
which reads:
"Rule 56. Summary Judgment
(a) MOTION FOR SUMMARY JUDGMENT OR PARTIAL SUMMARY JUDGMENT. A party may move for
summary judgment, identifying each claim or defense-or the part of each claim or defense-on which
summary judgment is sought. The court shall grant summary judgment if the movant shows that there
is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of
law. The court should state on the record the reasons for granting or denying the motion.
(b) TIME TO FILE A MOTION. Unless a different time is set by local rule or the court orders otherwise,
a party may file a motion for summary judgment at any time until 30 days after the close of all discovery,
II
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 68
57 of 91
65
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Document
92301
Filed
Page
2 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1094
92 ofof1299
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
MOTION FOR SUMMARY JUDGEMNT
Given the preponderance of evidence associated with the MOVANT'S AMICUS and STATEMENTS,
the courts must conclude that In The United States District Court For The Eastern District of Pennsylvania, Federal Judge Stuart Dalzall's findings of April 14, 1997, in the Lisa Lambert case identifying acts
of prosecutorial Misconduct, now, by virtue of the MOVANT'S AMICUS and STATEMENTS, now discloses
evidence of a bona fide pattern of prosecutorial misconduct, in the Commonwealth of Pennsylvania and
in the County of Lancaster.
Criminal law may determine if these disclosures would warrant investigations of a possible criminal enterprise. The MOVANT'S AMICUS and STATEMENTS is of material interest to the Habeus Corpus
filed by Lisa Michelle Lambert in May of 2014, for the very fact that this MOVANT'S AMICUS and
STATEMENTS compromises the very same integrity of the court, which would tip the scales of justice
even further from the peoples deserving rights.
In the truthfulness of MOVANT'S AMICUS and STATEMENTS, The Commonwealth must concede
and immediately release Lisa Michelle Lambert from incarceration in order to balance the scales of justice, which no other act could accomplish. The Commonwealth must yield the criminal culpability of
Lisa Michelle Lambert to the superior matter of restoring the integrity to the courts; by it's own admission of wrongdoing, assuring the peoples of it's commitment to administer equalities of justice, not inequalities of justice, balancing the scales of justice. Anything less, would take the full scope of jurisdiction out of the boundaries of our laws, negating our democracy and impugning the Constitution of the
United States.
In addition the MOVANT must be restored to whole by administering SUMMARY JUDGEMENTS in
cases 05-2288; 06-4650; and all other cases filed by the MOVANT in this court. SUMMARY JUDGEMENTS must also be administered in Case No. 08-13373 in the Lancaster Court of Common Pleas, and
other cases filed by the MOVANT in that said court.
2
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 69
58 of 91
66
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Document
92301
Filed
Page
3 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1095
93 ofof1299
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
"I, Stanley J. Caterbone being duly sworn according to law, make the following affidavit concerning the years during which I was maliciously and purposefully mentally abused, subjected to a
massive array of prosecutorial misconduct, while enduring an exhaustive fight for the sovereignty of
my constitutional rights, shareholder rights, civil liberties, and right of due access to the law. I will detail a deliberate attempt on my life, in 1991, exhibiting the dire consequences of this complaint. These
allegations are substantiated through a preponderance of evidence including but not limited to over
10,000 documents, over 50 hours of recorded conversations, transcripts, and archived on several digital mediums. A "Findings of Facts" is attached herewith providing merits and the facts pertaining to
this affidavit. These issues and incidents identified herein have attempted to conceal my disclosures of
International Signal & Control, Pie. However, the merits of the violations contained in this affidavit will
be proven incidental to the existence of any conspiracy.
The plaintiff protests the courts for all remedial actions mandated by law. Financial considerations would exceed $1 million. These violations began on June 23, 1987 while I was a resident and
business owner in Lancaster County, Pennsylvania, and have continued to the present. These issues
are a direct consequence of my public disclosure of fraud within International Signal & Control, Pie., of
County of Lancaster, Pennsylvania, which were in compliance with federal and state statutes governing
my shareholder rights granted in 1983, when I purchased my interests in International Signal & Control., Pie.. I will also prove intentional undo influence against family and friends towards compromising
the credibility of myself, with malicious and self serving accusations of "insanity". I conclude that the
courts must provide me with fair access to the law, and most certainly, the process must void any
technical deficiencies found in this filing as being material to the conclusions. Such arrogance by the
Courts would only challenge the judicial integrity of our Constitution."1. The activities contained herein
may raise the argument of fair disclosure regarding the scope of law pertaining to issues and activities
compromising the National Security of the United States. The Plaintiff will successfully argue that due
to the criminal record of International Signal & Control, including the illegal transfer of arms and technologies to an end user Iraq, the laws of disclosure must be forfeited by virtue that "said activities
posed a direct compromise to the National Security of the United States".; the plaintiff will argue that
his public allegations of misconduct within the operations of International Signal & Control, Pie., as
early as June of 1987 ;demonstrated actions were proven to protect the National Security of the United
States .. The activities of International Signal & Control,
Pl~.,
placed American troops in harms way. The
plaintiff's actions should have taken the American troops out of harms way causing the activities of the
International Signal & Control, Pie., to cease and desist.
All activities contained herein have greatly
compromised the National Security of the United States, and the laws of jurist prudence must apply towards the Plaintiff's intent and motive of protecting the rights of his fellow citizens. Had the plaintiff
been protected under the law, and subsequently had the law enforcement community of the Commonwealth of Pennsylvania, and the County of Lancaster administer justice, United States troops may have
3
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 70
59 of 91
67
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
,jl
Document
92301
Filed
Page
4 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1096
94 ofof1299
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
'
been taken out of harms way, as a direct result of ceasing the operations of International Signal &
Control, Pie., in as early as 1987.
2. The plaintiff will successfully prove that the following activities and the prosecutorial misconduct were directed at intimidating the plaintiff from continuing his public disclosures regarding illegal
activities within International Signal & Control, Pie,. On June 23, 1998, International Signal & Control,
Pie was negotiating for the $1.14 billion merger with Ferranti International, of England. Such disclosures threatened the integrity of International Signal & Control's organization, and Mr. James Guerin
himself, consequently resulting in adverse financial considerations to all parties if such disclosures provided any reason to question the integrity of the transaction, which later became the central criminal
activity in the in The United States District Court For The Eastern District Of Pennsylvania.
3. The plaintiff will prove that undo influence was also responsible for the adverse consequences
and fabricated demise of his business enterprises and personal holdings. The dire consequences of the
plaintiff's failed business dealings will demonstrate and substantiate financial incentive and motive. Defendants responsible for administering undo influence and interference in the plaintiff's business and
commercial enterprises had financial interests. The Commonwealth of Pennsylvania as a taxing authority, Lancaster County had a great investment who's demise would facilitate grave consequences to it's
economic development.. Commonwealth National Bank (Mellon) would have less competition in the
mortgage banking business and other financial services, violating the lender liability laws. The Steinman Enterprise's, Inc., would loose a pioneer in the information technologies industries, and would
protect the public domain from truthful disclosure. The plaintiff will also provide significant evidence -of
4. Given the plaintiff's continued and obstructed right to due process of the law, beginning in June of
I
1987 and continuing to the present, the plaintiff must be given fair access to the law with the opportunity for any and all remedial actions required under the federal and state statutes. The plaintiff will
successfully argue his rights to the courts to rightfully claim civil actions with regards to the totality of
these activities, so described in the following "Findings of Facts", regardless of any statute of limitations. Given the plaintiff's genuine efforts for due process has been inherently and maliciously obstructed, the courts must provide the opportunity for any and all remedial actions deserving to the
plaintiff.
5. Under current laws, the plaintiff's intellectual capacity has been exploited as means of discrediting the plaintiff's disclosures and obstructing the plaintiff's right to due process of the law. The
plaintiff has always had the proper rights under federal and state laws to enter into contract. The logic
and reason towards the plaintiff's activities and actions are a matter of record, demonstrated in the
"Findings of Facts", contained herein .. The plaintiff will argue and successfully prove that the inherent
emotional consequences to all of the activities contained herein have resulted in Post Traumatic Stress
4
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 71
60 of 91
68
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Document
92301
Filed
Page
5 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1097
95 ofof1299
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Syndrome. The evidence of the stress subjected to the plaintiff, will prove to be the direct result of the
activities contained herein, rather than the exhibited behavior of any mental deficiency the plaintiff
may or may not have. The courts must provide for the proper interpretations of all laws, irrespective of
the plaintiff's alleged intellectual capacity. The plaintiff successfully argue that his "mental capacity" is
of very little legal consequence, if any; other than in it's malicious representations used to diminish the
credibility of the plaintiff.
6. The plaintiff will demonstrate that the following incidents of illegal prosecutions were purposefully directed at intimidating the plaintiff from further public disclosure into the activities of International Signal & Control, Pie., consequently obstructing the plaintiff's access to due process of the law.
Due to the fact that these activities to which the plaintiff's perpetrators were protecting were illegal activities, the RICO statutes would apply. To this day, the plaintiff has never been convicted of any crime
with the exception of 2 speeding tickets. The following report identifies 34 instances of prosecutorial
misconduct during the prosecutions and activities beginning on June 23, 1987 and continuing to today.
7) Given the preponderance of evidence associated with this affidavit, the courts must conclude
that In The United States District Court For The Eastern District of Pennsylvania, Federal Judge Stuart
Dalzall's findings of April 14, 1997, in the Lisa Lambert case identifying acts of prosecutorial Misconduct, now, by virtue of this affidavit, now discloses evidence of a bona fide pattern of prosecutorial
misconduct, in the Commonwealth of Pennsylvania and in the County of Lancaster. Criminal law must
now determine if these disclosures would warrant investigations of a possible criminal enterprise. This
affidavit is of material interest to the Lambert case, for the very fact that this affidavit compromises
the very same integrity of the court, which would tip the scales of justice even further from the peoples deserving rights .. In the truthfulness of this affidavit, The Commonwealth must concede Lisa
Michelle Lambert to balance the scales of justice, which no other act could accomplish. Commonwealth
must yield the criminal culpability of Lisa Michelle Lambert to the superior matter of restoring the integrity to the courts; by it's own admission of wrongdoing, assuring the peoples of it's commitment to
administer equalities of justice, not inequalities of justice. Balancing the scales of justice. Anything
less, would take the full scope of jurisdiction out of the boundaries of our laws, negating our democracy and impugning the Constitution of the United States. The plaintiff must be restored to whole."
5
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 72
61 of 91
69
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
.#
Document
92301
Filed
Page
6 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1098
96 ofof1299
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Date: September 2, 2015
scaterbone@live.com
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
6
Page 73
62 of 91
70
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1099
97 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX H
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 74
71 of 91
88
Wednesday
Wednesday
November
October 12,
15, 2016
A Teenage Murder Mystery DVD
1 of 2
January January
Sunday
22, 201722, 2017
http://store.aetv.com/html/product/index.jhtml?id=75922
Page
Page1100
98 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Visit AETV.com
VIEW CART: 0 ITEMS | CHECKOUT | MY ACCOUNT | HELP
SEARCH:
SHOP BY SUBJECT
Exclusively at
The A&E Store
American Justice: A Teenage Murder Mystery DVD
Hollywood DVDs - NEW!

A&E Original Movies on DVD
Only available on DVD
New Releases from A&E

Availability: Product will ship on
06/11/07, why?
Discount DVDs & More

SHOP BY SHOW
Ships to U.S. and Canada

1 DVD(s) / 50 Minutes
Closed Captioning: No
Criss Angel: Mindfreak DVDs

Dog The Bounty Hunter DVDs
Driving Force DVDs
Get $1 Shipping on
your entire order!
$24.95
Intervention DVDs
Qty: 1
Gift Finder
Toys & Games
Gift Certificates
DVDs en Espaol
Closed Caption
Catalog Request
Other customers also liked...
Child's Play,
Deadly Play
DVD
American
Justice set DVD
$59.95
$24.95
Murder In A
College Town
DVD
$24.95
PRODUCT DETAIL:
-->
It is one of the more extraordinary cases ever tried in Pennsylvania, not because of the crime,
which was certainly heinous, but for what has come afterwards. One woman has been convicted
twice, by the same judge, of the same crime, and has gone to jail twice.
AMERICAN JUSTICE recounts every step of the strange journey of Lisa Michelle Lambert in this
gripping program. Hear from Hazel Snow, the victim's mother, who says her daughter whispered
"Michelle did it" as she lay dying in her arms with a slit throat and a rope around her neck.
Examine the conflicting testimony that Lisa and her two codefendants have given. And unravel the
bizarre web of legal decisions that have made this case into one of the most complicated in the
history of Pennsylvania.
Featuring interviews with the prosecutors who tried the case, the Attorney General of
Pennsylvania, friends of the victim and Lisa herself, this is a fascinating look at a case that may
yet have surprises in store.
This DVD is one of the many titles in our DVD Library and is created in the DVD+R format.
This disc does not feature menu pages or special features like standard DVDs, simply the high
quality programming you've come to expect from us. Click here for more details.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 75
72 of 91
88
Page 1 of 4
Wednesday
Wednesday
November
October 12,
15, 2016
05.28.2007
5/28/2007 3:35 PM
January January
Sunday
22, 201722, 2017

Page
Page1101
99 ofof1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX I
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 76
73 of 91
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1102
100 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Commonwealth of Pennsylvania v. Lisa Michelle Lambert

A Bitter Lesson for Lancaster County; Judge says Pennsylvania community 'lost
its soul' in push to convict woman of murder.
Residents claim he, not they, are mocking justice.
Right or wrong, his ruling challenges U.S. court system's balance of power.
[Home Edition]
BARRY SIEGEL.
Los Angeles Times

Los Angeles, Calif.: Nov 10, 1997. pg. 1
By midmorning on the first day of Lisa Michelle Lambert's federal habeas corpus hearing, U.S. District
Judge Stewart Dalzell already could be seen displaying alarm over what he was hearing. From the lawyers'
briefs alone, he'd read enough to persuade him to grant Lisa's request for this uncommon federal review
of a state murder conviction. He'd read enough to suspect that just possibly, Lisa Lambert, although
sentenced to life without parole, hadn't killed Laurie Show over a teenage romantic rivalry. He'd read
enough to surmise that just maybe, Lisa's boyfriend,
Lawrence "Butch" Yunkin, along with a girl named Tabitha Buck, had killed Laurie. Now, he was listening
to evidence that served only to deepen his concerns regarding Lancaster County's prosecution of Lisa. It
was March 31. Computers, boxes of documents and piles of papers filled the small hearing room on the
fifth floor of the federal courthouse in downtown Philadelphia. Lisa's parents sat in the first row, Laurie
Show's behind them. Reporters and court personnel occupied the jury box. On the stand, an expert
witness for Lisa's side, Northwestern University speech professor Charles Larson, was testifying.
Contrary to the autopsy report, Larson believed--as did three emergency medical technicians and the
Philadelphia medical examiner--that Laurie Show's left carotid artery had been severed by whoever
slashed her throat. This, he explained, left her unable to say "Michelle did it," as Laurie's mother, Hazel,
had claimed. Her vocal tract was "destroyed," her left brain hemisphere "dying." She was "totally
incapable of speech."
How, asked Lisa's attorney, Christina Rainville, could two doctors have signed an autopsy report saying
that the carotid arteries weren't "involved"?
Those two doctors were both Lancaster County physicians, one the part-time coroner, the other an earnose-and-throat specialist. "I don't think they were telling the truth," Larson replied. Dalzell peered over
gold wire-rimmed bifocals at the witness.
"Oh," he said. "Well, OK."
That this hearing was even being held appalled most in Lancaster County, about 75 miles west of
Philadelphia. In the 1991 killing of Laurie Show, Lisa had already been found guilty of first-degree murder,
Tabitha Buck of second-degree, Butch Yunkin of third-degree.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 77
74 of 91
88
Page 1 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1103
101 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Now here was Lisa, claiming her innocence, claiming all sorts of prosecutorial abuse. Now here was Lisa,
For Lisa to cast herself as an innocent victim was maddening enough. For a federal judge to take her
seriously was unimaginable. Yet that was just what was happening in this Philadelphia courtroom.
The second day of the hearing found Dalzell puzzling over two quite different versions of a videotaped
police search of the Susquehanna River. The one initially provided by the Lancaster County district
attorney, eight minutes long, had no soundtrack, and no images of police finding a pink bag Lisa said
she'd thrown there. The second, obtained through discovery only after Rainville realized she'd been sent
an edited tape, was four minutes longer. It had sound. It also had an officer kicking at a pink bag while
another asked, "What do you got, a bag?"
After watching these tapes, Dalzell removed his glasses and rubbed his eyes, something he'd do more
than once during the three-week hearing. He studied Lisa, also something he'd do more than once,
especially in the hearing's early days. Lisa, sobbing off and on, was staring down at the table where she
sat, bent over, her hands between her legs. Dalzell looked as if he were trying to fathom her character.
The third day found Dalzell puzzling over Lisa's initial statement to the police. He listened to East
Lampeter Police Det. Raymond Solt try to reconcile the typewritten first page, where Lisa says she wore
her own clothes at the murder scene, and a handwritten last page where Lisa says she wore Butch's
sweatpants. He listened to Solt explain how he destroyed all his notes from the interview. By the time Solt
stepped down, the judge was referring openly to "Ms. Lambert's alleged statement."
With Det. Ronald Barley on the stand later that afternoon, Dalzell grew even more openly dissatisfied.
Barley was a well-regarded detective in Lancaster County. A "very thorough investigator" is how Ted
Darcus, chairman of Lancaster's City Council, considered him. Barley "dealt well with people in our
community accused of crimes." Yet this wasn't apparent to Dalzell.
Barley, being questioned about the taped interview he helped conduct with Butch Yunkin--a tape full of
laughter, clicks and obvious gaps--kept waffling so much that Dalzell finally snapped: "Answer her
question! Yes or no?" Rather than heed the suggestion, Barley grew even more evasive. Asked about a
critical spot where the recorder clicked off, he denied even being in the interview room at that moment.
Dalzell had heard enough.
He called a recess and ordered all the lawyers into his chambers. "I want to know what is going on here,"
he told Lancaster County Dist. Atty. Joseph Madenspacher. "I'm hearing perjured testimony. . . . As we
had with Det. Solt, {Barley} is contradicting his own statement. . . . My patience has just run out. . . . I'm
afraid the commonwealth is allowing perjured testimony in federal court. . . . I'm being lied to. . . . This
man gives me the unbelievably fantastic statement that suddenly he 'evaporated.' It's totally incredible,
and I'm afraid I'm going to have to refer this, if this keeps up, to the United States attorney. . . ."
Madenspacher shifted uneasily. This hadn't been his case to try. He'd left the prosecution to his seasoned
first assistant, John Kenneff. "I understand what the court is saying . . .," he replied. "I don't know what
I'm going to do, but I'm going to do something."
Little changed, though, when Barley resumed the stand. He didn't recall his colleague, Det. Ronald "Slick"
Savage, turning the tape recorder on and off. He destroyed his notes after taking Butch's statement.
"You knew . . . because you took the statement?" the judge asked later. "Or did you disappear for that
part? . . . Oh, do you have that ability to appear and disappear at will?"
By the time Barley tried to explain how he "completely forgot" they'd found a pink bag during the river
search--a pink bag that Lisa told them contained Butch Yunkin's bloodied sneakers--Dalzell was beside
himself. It helped his mood little when, with Barley still on the stand, Rainville moments later played the
segment of unedited videotape that showed an officer kicking the pink bag, then waving the camera off.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 78
75 of 91
88
Page 2 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1104
102 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE

Dalzell again peered over his eyeglasses. "Who were you waving to? The record should reflect that the
witness definitely waved directly at the camera. What in the world were you doing, if you weren't waving
to the camera?"
Defendant Alleges Gang Rape On the seventh day, Dalzell began to hear Lisa Lambert's story of being
gang-raped by three policemen six months before Show's murder.
Lisa--her extravagant eye makeup toned down but still too thick for Rainville's taste--had started
testifying the previous day.
Now she described being stalked by an officer named Robin Weaver, of vainly calling his police chief to
complain, of receiving threatening calls after the alleged attack. She explained how fear had kept her from
telling this story before. Finally, she explained why she now was willing to talk.
In a deposition given to Lisa's attorneys before the hearing, Weaver, without being asked, had referred to
the gang- rape accusation. He thought Lisa had cited it in her habeas petition, but she had not. The
charge had never been raised publicly. To Lisa, Weaver's comment, therefore, provided independent proof
of her claim: "There is no way that he could have ever known about that unless he was there and he did
it. It was not raised in the petition."
"That is true, your honor," said Rainville, who had been appointed by the judge to represent Lisa on a probono basis.
Dalzell again had heard enough: "We'll take another recess. . . . I want {Weaver} here this afternoon, and
I don't want anyone to say a word about what has come up here. If he resists, please tell me. I will have
the marshal arrest him, OK?"
Moments later, Dalzell learned that prosecutor John Kenneff already had discussed the rape allegation
with Weaver.
The judge's budding animosity toward Kenneff was palpable. The prosecutor had not yet appeared before
him, but the residue of his work at the Lambert trial was everywhere.
"I'm going to direct that Mr. Kenneff have no further contact with any witness in this case. . . ," Dalzell
declared. "And he might want to consult with counsel. . . . I'm going to want to hear about this, because
in the context of this case, Mr. Kenneff, God help untruths" being aimed at our police, urged East
Lampeter Supervisor Chairman John Shertzer. Don't "rush to judgment." It's "unfortunate that so much is
being made of such insignificant points."
In his opening statement at the hearing, Madenspacher, the district attorney, had allowed that the
investigation hadn't been "perfect," that maybe they'd been a little "careless," maybe a little "sloppy."
Others, though, refused even to acknowledge that much. All sorts of citizens instead continued to offer
glowing tributes to the police and prosecutors.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 79
76 of 91
88
Page 3 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1105
103 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
No one official drew more accolades than did John Kenneff. He is a big, heavyset man with a full, broad
Irish face. Growing up in Lancaster County, Kenneff was considered a fine schoolboy, a high achiever. Not
Harvard-level material, but his college, Villanova University, was nonetheless a good school. Not as good
as the University of Pennsylvania, but the next step.
He'd come back after law school, opened a private practice, worked his way up through the D.A.'s office.
He came to all the Fourth of July picnics; he brought his family, he brought his dog. He was known as a
committed, persistent prosecutor, one of the fairest and most reasonable in the county.
Even the defense attorneys who went up against him said as much. Even they called him a decent, honest
guy. To Terry Kauffman, a dairy farmer and chairman of the board of county commissioners, that
particularly carried a lot of weight: "A lot of people I know here, from both sides of the aisle, say he's the
best. I know them, and I've known Jack Kenneff for years. I don't know Stewart Dalzell."
Darcus--the chairman of the Lancaster City Council, a black man from West Virginia who followed a Boys'
Club job to Lancaster 30 years ago and happily settled--believed he possessed an especially close take on
John Kenneff's character. They'd been involved together in a "Weed and Seed" anti-crime development
program in Lancaster's minority community. So Darcus saw Kenneff not just as a prosecutor, but a
community leader. Also as a father: Kenneff's children went to the same Catholic school as Darcus' son.
"I've seen how he cares about people," Darcus said. "I've seen him deal with people in my community.
I've seen him go beyond what was needed. Knowing Jack Kenneff, I just can't picture this man doing what
the judge says. I wonder how that judge sleeps at night."
Denials From the Prosecutor No, John Kenneff insisted. No, he didn't think Butch Yunkin's sweatpants
were a critical issue at the murder trial. No, he had no recollection of looking at the sweatpants the state
put into evidence.
It was April 15, the hearing's 11th day. Kenneff had taken the witness stand soon after court convened.
Questioning him was Peter Greenberg, Rainville's husband, a partner at their law firm and one of
Philadelphia's most-accomplished litigators.
At the trial, the state's theory of the murder had Lisa wearing Butch's extra-large men's sweatpants,
found full of blood in a dumpster after the attack. Trial judge Lawrence F. Stengel accepted this theory
and thought it significant. So Kenneff's answers now caused Dalzell to lean forward.
"Did you make a conscious judgment at trial as to who was wearing the clothing that you put into
evidence?" Greenberg asked.
Dalzell interrupted: "I don't think that's the question he asked you. And I think you ought to listen more
carefully to Mr. Greenberg's questions because I don't think you're answering them. . . . That question can
be answered yes or no."
So it went through much of the morning. Lancaster County citizens were right: Dalzell by then couldn't
hide his dismay for their assistant district attorney. The moments when the judge removed his glasses and
rubbed his eyes were adding up.
For 10 days he'd been exposed to an ever-more disturbing portrait of how Kenneff had prosecuted Lisa
Lambert. He'd listenedto the pathologist Isidore Mihalakis--a defense witness at Lisa's murder trial-describe private conversations with Kenneff that Dalzell thought constituted witness-tampering. He'd
heard how authorities had concealed critical testimony by Hazel Show's neighbor Kathleen Bayan. He'd
been presented evidence that convinced him the state had "lost" an earring of Butch's found on the
victim's body. He'd been presented evidence that convinced him the state had edited critical video and
audiotapes.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 80
77 of 91
88
Page 4 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1106
104 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE

This time, Greenberg snapped before the judge could: "You've been in this business long enough to know
that when I ask a question you're supposed to answer it?"
Dalzell joined in now: "It would be nice if you would do that. . . . I want to warn you, sir, that, if you don't
do that, you are going to put me into a position where this will have to get unpleasant. Do you understand
that? . . . The record should reflect that you have been consistently unresponsive to the questions. . . . "
Greenberg turned back to the matter of Butch's sweatpants. Now, Kenneff has even resisted saying he
based the case on the theory that Lisa wore Butch's clothing. He no longer, in fact, was sure whether the
sweatpants were Butch's.
The pair he'd produced for the habeas hearing, after all, were much smaller than men's extra-large. "The
sweatpants would have looked ridiculous if worn by 6-foot-1-inch-tall Butch," Kenneff had argued in a
written response just before the hearing.
"You are the same person . . . " Greenberg asked, "saying that the sweatpants would have looked
ridiculous on Butch, who put Butch on to testify in Lisa's trial . . . that they were his sweatpants, these
very same sweatpants that would have looked ridiculous on him?"
"Correct."
"Correct."
Greenberg erupted: "Do you think this is some kind of game? . . . Do you realize that there is a human
being sitting here who is in jail serving a life sentence based on the evidence you put on . . . that you are
now disowning. . . . Not only are you disowning it, you are committing perjury. . . . Are you sure it is Miss
Lambert who is a dangerous person in this courtroom?"
Handling of Letter Infuriated Judge In the end, the commonwealth's handling of the controversial 29
Question Letter was what most inflamed Dalzell.
Lisa had written Butch from jail, asking a series of questions. The answers Butch had scrawled under each
question, the judge felt, left no doubt that he was the murderer of Laurie, and that his accomplice was
Tabitha Buck. That the letter was authentic seemed equally certain to Dalzell: Both the state and defense
experts had affirmed there'd been no alteration.
Yet, Kenneff--after stipulating to the experts' opinions--had let Butch testify at Lambert's trial that the
questions were altered.
That the prosecutor knew his witness was committing perjury appeared obvious to Dalzell. At Butch's
plea-bargain hearing after Lisa's conviction, Kenneff wanted to revoke their deal precisely because of this
perjury.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 81
78 of 91
88
Page 5 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1107
105 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Experts had reviewed the 29 Questions Letter and Butch's trial testimony, Kenneff told the judge at that
Oct. 10, 1992, hearing.
"They advised us that his testimony . . . regarding that {letter} that was false . . . . It is our opinion that
he testified falsely . . . on that basis we feel we are entitled to withdraw from the original plea
agreement."
There just was no ambiguity, Dalzell felt: Kenneff knew that Butch committed perjury on a material issue,
regarding a document that established Lisa's innocence.
Under such circumstances, Dalzell believed Kenneff had an unambiguous ethical obligation to take
remedial action with the court that convicted Lambert. The Pennsylvania Rule of Professional Conduct was
clear about this: "A lawyer shall not knowingly . . . offer evidence that the lawyer knows to be false. If a
lawyer has offered material evidence and comes to know of its falsity, the lawyer shall take reasonable
remedial steps."
Yet far from complying with this rule, it looked to Dalzell as if Kenneff had encouraged Judge Stengel to
accept Butch's perjured testimony. "I think he's just like any other witness," Kenneff told Stengel when
Lisa's attorney moved for a mistrial based on Butch's perjury. "You can believe some of it, all of it, or
none."
It was worse than that, in Dalzell's eyes. For, after obtaining a conviction based partly on this perjured
testimony, Kenneff had coolly proceeded to seek the death penalty for Lisa Lambert.
Now, remarkably, Kenneff at this habeas hearing--and in written responses that looked to Dalzell to be
blatantly false--was back to arguing that some of the 29 questions had been initially written in pencil, then
altered. In other words, Kenneff, before Dalzell, was defending testimony by Butch that he had told two
other judges was a lie.
"Well, your honor," Kenneff responded. "I think I still feel the same way about the 29 questions. . . . That
there is some type of tampering with it. . . . "
"No, no, no, sir," Dalzell interrupted. "I am going to jump in here. You said in your answer to me that
there was pencil. And you have testified under oath here that your expert and the defense expert said
there was no graphite. . . . "
Dalzell spoke over him: "I want to warn you, sir, you are under oath, and you are subject to the rules of
professional responsibility. . . . Do you retract that statement that you signed . . . as to pencil? Yes or
no?"
The climax came minutes later, when Greenberg began listing all the pieces of evidence that the district
attorney's office kept from Roy Shirk, Lisa's attorney at her trial. What if Shirk had the names of the
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 82
79 of 91
88
Page 6 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1108
106 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
emergency medical technicians? What if he knew the police had found a pink bag? What if he had the
unedited river-search video? What if he knew a neighbor had seen Butch at the crime scene?
That's as far as he got. Dalzell exploded: "No. Excuse me. We're talking here--let me just make something
clear to you. We're talking here about something called the United States Constitution, and in particular
the 14th Amendment thereof, which has a clause in it that refers to due process of law.
OK? Have you heard of that?"
"Yes sir."
"That's what we're talking about. . . . So we're not talking about the Pennsylvania Rules of Criminal
Procedure. We're talking about due process of law here. . . . That's what we're talking about here. You got
it? Do you understand?"
Biggest Drama Begins to Unfold As it happened, the confrontation between Dalzell and Kenneff was
neither the most dramatic nor revealing sequence to occur on this 12th day of Lisa's habeas hearing. The
event that would eclipse it began only after Kenneff left the witness stand, and court adjourned for lunch.
Madenspacher, walking toward his hotel, bumped into Hazel Show's brother, who reported that his sister
needed to talk to him.
Back at the Holiday Inn in downtown Philadelphia, where both were staying, Madenspacher walked up to
Show's room.
During the hearing that morning, she'd suddenly recalled the morning of the murder: As she drove up
Black Oak Road to her condo, on her way to find Laurie's body, a brownish-colored car passed, heading
out of the condo complex. It was Butch's car.
She looked at Butch. There was recognition on his face. He pushed down someone with blond hair. There
was also a third person in the back seat, with black hair.
She'd told this to Det. Ron Savage back then. Savage had come to her house saying one of her neighbors
had seen Butch's car leave the complex. She'd started to say she had too. Savage had stopped her, told
her not to dwell on that. They had so many witnesses saying Butch wasn't there. Besides, this neighbor
lady was kind of disturbed anyhow. Probably wouldn't be a reliable witness. We were better to go with
Butch not being there.
Hazel was sobbing harder now. She'd forgotten about it, she told Madenspacher. She'd put it aside. Until
now.
Madenspacher was reeling. Hazel's story fit exactly with testimony given by that "neighbor lady," Kathleen
Bayan, on the hearing's fourth day. Testimony that Hazel hadn't heard because she'd left the courtroom
early that day. Testimony that had never been produced at Lisa's murder trial. Testimony that Kenneff
knew about back then but had never shared with Lambert's attorney. Testimony that Savage had tried to
water down while taking Bayan's initial statement, then dismissed as coming from a woman with "an
emotional problem."
Hazel's story also fit perfectly with something else: Lisa Lambert's testimony at her trial. There she'd told
of driving by Hazel Show, of Butch saying, "Oh . . . it's Hazel," of Butch pushing her head down.
Madenspacher pondered. If true, it seemed to him that this story knocked out the underlying theory of the
trial, which was that Butch wasn't at the condo. It didn't mean Butch was actually inside; it didn't clear
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 83
80 of 91
88
Page 7 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1109
107 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Lisa; it could be explained. But it was a new story. It changed the theory of the case. Madenspacher felt
as if he were slipping into shock.
Madenspacher had no choice: He had to get this to the judge. He couldn't suppress it. The only question
was, when and how? It was going to come out anyway, Madenspacher figured. So let's get the bad news
over with.
The conference in Dalzell's chambers began at 1:40 p.m. that day. Present were the judge, the lawyers
for all sides, Hazel Show and Lisa Lambert.
Hazel Show told her story
courtroom today, I realized
condominium complex. . . .
about it until I was sitting in
again, this time before a court reporter: Well, when I was sitting in the
that I had seen Lawrence's {Butch's} car with passengers drive out of our
Det. Savage said that I wasn't to dwell on it. . . . I never thought anymore
there. . . . It all just came back.

To Dalzell, this revelation was the final straw. Throughout Lisa's trial the state had been at pains to keep
Butch as far from the Show condo as possible. No doubt that was why the state had never disclosed
anything about Hazel's report or Bayan.
To Dalzell, it wasn't just that Hazel's and Bayan's accounts were consistent with Lisa's testimony at trial
five years ago: Just about everything being revealed at this hearing was consistent with Lisa's testimony
back then.
From all he'd heard, Dalzell now believed that the commonwealth's misconduct had been so substantive, it
had undermined the state court's ability to find the truth. He believed the commonwealth had committed
at least 25 separate instances of prosecutorial misconduct--all constitutional violations, all violations of the
norms of a civilized society.
It seemed clear to him that Laurie Show did not say "Michelle did it." It seemed clear that Butch, in the 29
Questions Letter, confessed to the murder. It seemed clear Lisa didn't wear Butch's sweatpants on the
morning of the murder. It seemed clear the police had fabricated Lisa's initial statement.
Worse yet, in Dalzell's view, the commonwealth still hadn't stopped its treachery. At this habeas hearing
the state had produced not the extra-large sweatpants of Butch's from the original trial, but a smaller
girl's pair. The commonwealth, Dalzell believed, had perpetrated a fraud on the federal court; the
commonwealth had swapped evidence.
At least six state witnesses, by Dalzell's count, had perjured themselves before him. One, Ron Savage-now an elected district justice in Lancaster County--likely obstructed justice. And now this: now Hazel's
revelation, right before his eyes. Hazel had every reason to want Lisa's petition denied; Hazel sincerely
believed Lambert did it. Yet still she'd felt compelled to tell this story. Dalzell had never seen a more
courageous act.
"Well," the judge told those gathered in his chambers. "Now we come to the question of relief. Does the
commonwealth intend to defend this case?"
The Lancaster County district attorney had been looking uncomfortable in recent days. Nothing he'd heard
rose to the level of conscious misconduct or obstruction, he kept insisting. But he had to admit, it hadn't
been a perfect trial or investigation. He wished certain things had been done differently.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 84
81 of 91
88
Page 8 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1110
108 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
In Lancaster County, then as now, there were many who wanted their district attorney to fight ferociously.
There were many who wanted their district attorney to defend their honor, to insist they'd done nothing
wrong, to match Lisa's lawyers blow for blow.
Yet, Madenspacher, at this moment, wasn't sure what should be done. Everything, he would say later, was
"spinning in my mind." It was "awful tough" operating away from the office. It "would have been nice" to
have known everything from the start.
"Now, obviously . . . " he finally told the judge. "There is some relief that is justified in this particular case.
. . ."
That was all Dalzell needed; he now had the commonwealth's assent. The state hadn't even put on its
case yet, but he meant to get Lisa out of prison. He also meant to get Savage off the bench forever; he
didn't see how Savage could hear cases anymore, and he planned to tell the Pennsylvania Supreme Court
just that.
"You can make a choice overnight," Dalzell advised the district attorney, "whether you want to defend this
case, put on your own witnesses. In the meantime, I'm going to release Ms. Lambert into some agreedupon custody. . . . Because it's quite clear now that the petitioner is entitled to relief, the only question is
how much."
"I can tell you, Mr. Madenspacher, that I've thought about nothing else but this case for over three weeks,
and in my experience, sir, and I invite you to disabuse me of this at oral argument, I want you and I want
the Schnader firm to look for any case in any jurisdiction in the English-speaking world where there has
been as much prosecutorial misconduct, because I haven't found it. .
Stunned Response in Lancaster County In bars and cafes, street corners and living rooms, the citizens of
Lancaster County gasped at the news of Lisa's release. Their district attorney may not have seen reason to
object, but they did. Most sounded stunned; many sounded enraged. One man, at 8 a.m. on the morning
after her release, anonymously called in a phone threat to the Lancaster Sunday News, saying he would
Maybe there were "mistakes," the more rational by now were willing to allow. Maybe there was "sloppy"
police work. Maybe Lisa even deserves a new trial. Nothing more than that, though. Certainly not her
freedom. She was there, she was an accomplice, she was a co-conspirator. Give her a new trial, remand it
elsewhere even. But don't just let her go. You can't just let her go.
"Lambert is not innocent--how could she be?" the Lancaster New Era editorialized the day after Hazel
Show's revelation. " . . .
even with newly revealed evidence that supports her claims, Lambert is still irrevocably involved in the
events that lead to Laurie Show's murder. These facts must not be drowned out by the explosive
revelations at Lambert's federal appeals hearing. . . . "
As it happened, these thoughts exactly echoed those offered by Judge Stengel, who'd presided at Lisa's
murder trial. "Even if Lambert's story at trial was completely credible," Stengel had declared in his written
opinions, "she would still be an accomplice to the crime of murder. . . . The single most important fact on
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 85
82 of 91
88
Page 9 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1111
109 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
the issue of guilt is whether Ms. Lambert was present in the Show condominium at the time of the killing.
By her own admission, she was present. . . . "
On the proceeding's final day, when Madenspacher in his closing argument spoke of Lambert being guilty
at least as an accomplice or conspirator, Dalzell waved him off. "She wasn't charged with conspiracy was
she?" he declared. "She was charged with first-degree murder. So the only issue before me is actual
innocence of first-degree murder. That is what she was convicted of."
In fact, the law is murky on this point. Lisa was actually charged with criminal homicide, which in
Pennsylvania encompasses all degrees of murder. How her conviction for first-degree murder affects her
exposure to lesser murder charges is a matter for debate.
So, Madenspacher tried to argue: "What I am saying here is that charged with criminal homicide, she
could be found guilty of murder in the first degree . . . or she could have been found guilty of second
degree . . . or she could be found guilty of third degree."
That didn't sway Dalzell: "But if one took her testimony, she said that she did everything possible to deescalate what spun out of control. . . . By her own testimony she exited when it started spinning out of
control. So therefore, it was not 'reasonably foreseeable' from her point of view, so the argument would
go."
Dalzell had good reason for not wishing to bother further with this issue. By then--after 14 days of
testimony covering 3,225 pages of transcript--the judge wasn't thinking only about Lisa's conduct at the
Show condo. He was thinking about the 14th Amendment of the Constitution, and the role of a federal
habeas corpus in upholding the unalienable right of due process.
Among other historic cases, Dalzell's mind was on a 1973 opinion by then-Justice William H. Rehnquist, in
United States vs. Russell. There, Rehnquist predicted that "we may some day be presented with a
situation in which the conduct of law enforcement agents is so outrageous that due process principles
would absolutely bar the government from invoking the judicial processes to obtain a conviction."
While presiding at a habeas hearing, he reminded himself, he effectively sat as a court of equity--a court
operating under a system of law designed to protect rights and deliver remedial justice. He recalled the
ancient maxim that "equity delights to do justice, and not by halves." To give Lisa full relief, it seemed to
him imperative that he do nothing to benefit or empower those who had wronged her.
He would not just release Lisa, Dalzell decided. An outrageous violation of due process required even more
severe sanction. He would bar the state from ever retrying her. He would strip the state of its natural right
to adjudicate a murder committed within its boundaries.
He wrote his 90-page opinion over the weekend, after court adjourned at 4:10 p.m. on Friday, April 18.
Before a packed courtroom late the following Monday morning, he declared Lisa "by clear and convincing
evidence" to be "actually innocent of first-degree murder."
"If Lisa Lambert's is not the 'situation' to which Chief Justice Rehnquist referred, then there is no
prosecutorial malfeasance outrageous enough to bar a reprosecution. . . ." he proclaimed. "We have now
concluded that Ms. Lambert has presented an extraordinary, indeed, it appears, unprecedented case. We
therefore hold that the writ should issue, that Lisa Lambert should be immediately released, and that she
should not be retried."
In scorching language, Dalzell explained just why: "We have found that virtually all of the evidence which
the commonwealth used to convict Lisa Lambert of first-degree murder was either perjured, altered or
fabricated. Such total contempt for due process of law demands serious sanctions. The question we must
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 86
83 of 91
88
Page 10 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1112
110 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
now answer is whether . . . the commonwealth is entitled to get another try at convicting Lisa Lambert
and sending her to prison for the rest of her life. . . . In short, the question is whether we may accept a
promise from anyone on behalf of the commonwealth that a trial will be fair 'next time.' "
"We hold that the due process clause of the 14th Amendment bars the commonwealth from invoking
judicial or any other proceedings against Lisa Lambert for the murder of Laurie Show. . . . Equitable
considerations preclude our leaving the decision whether to retry Lisa Lambert in the hands of those who
created this gross injustice. . . . "
As far as legal researchers could tell, there was an accepted basis, but no exact precedent for a federal
judge in Dalzell's situation to take such action. Dalzell did not stop there.
He was, he announced in his opinion, going to refer the matter of Kenneff's "blatantly unethical and
unconstitutional" actions to the Pennsylvania Disciplinary Board. He also was going to refer the whole
Lambert prosecution to the U.S. attorney for investigation of "possible witness intimidation, apparent
perjury by at least five witnesses in a federal proceeding, and possible violations of the federal criminal
civil rights laws."
Still, Dalzell wasn't finished. He felt compelled, in the two final pages of his opinion, to address the
question of just why all this had happened in Lancaster County.
"Those who have read this sad history," he wrote, "may well ask themselves, 'How could a place idealized
in Peter Weir's'Witness' become like the world in David Lynch's 'Blue Velvet'?' Because it is so important to
that community and indeed tomany others to prevent a recurrence of this nightmare, we offer a few
reflections on the record."
Laurie Show's grandfather, Dalzell pointed out, was, in the 1980s, the coroner of Lancaster County. Her
mother was "a paragon of morality" who kept "a picture-perfect home." By contrast, Lisa Lambert was "as
though delivered from Central Casting for the part of villainess." By the testimony of even those who loved
her, "she was at the time literally 'trailer trash.' " The community "thus closed ranks behind the good
family Show and exacted instant revenge against this supposed villainess." Almost immediately after "the
snap judgment" was made, law enforcement officials uncovered "inconvenient facts," but soon "discovered
a balm for these evidentiary bruises, Lawrence Yunkin." Thus "Lancaster's best made a pact with
Lancaster's worst to convict the 'trailer trash' of first-degree murder."
Dalzell's parting words: "In making a pact with this devil, Lancaster County made a Faustian bargain. It
lost its soul and it almost executed an innocent, abused woman. Its legal edifice now in ashes, we can
only hope for a 'Witness'-like barn-raising of the temple of justice."
Uprising Began With Calls, Letters The uprising in Lancaster County in the wake of Dalzell's ruling began
first with the usual letters to editors and calls to radio talk shows.
The legal system is a "crock of crap." How could Dalzell destroy the reputation of "honorable and decent
people" for the purpose of freeing a "cold-blooded killer?" What kind of justice do we have?
Soon enough, such talk escalated. All sorts of theories about Dalzell's motives began circulating.
Something's been going on behind the scenes, it was suggested. Something behind what Dalzell did,
something we don't know about.
Ted Byrne, the conservative radio talk show host in Lancaster County, pored through Dalzell's decisions in
a law library. Then, seeking hidden connections, he analyzed the activities of the attorneys at Dalzell's old
law firm and Rainville's firm.
It was considered significant that Dalzell and Greenberg, 30 years before, had been classmates at the
University of Pennsylvania. Some talk had it that they were old pals. Some talk had it that Dalzell had
handed the Lambert case to his own "carefully assembled defense team."
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 87
84 of 91
88
Page 11 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1113
111 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Had Dalzell reached the end of a career path? Had he felt unfulfilled? Had he wondered how he might
become an appellate judge? Had he seen a challenge to the controversial habeas corpus situation as a
means to garner attention?
For that matter, how did the Lambert case get to Dalzell in the first place? Had not Dalzell displayed an
excessive personal interest in Lisa in his chambers? Was it possible that they had a relationship?
"We must begin to think who it was that had to gain from this travesty of justice other than Lambert,"
suggested one citizen in a letter to the editor. "My vote goes to Judge Stewart Dalzell. It would appear
that it is an appropriate time for this newspaper to dig very deep into the archives of the noteworthy
judge to determine what it was or who it was that set him on his grudge mission to 'punish' the county for
sins of the past committed against him."
Such comments reflected as much bewilderment as paranoia. They came from a citizenry who well knew
Lisa Lambert, and well knew those who had prosecuted her. Yet rarely did anyone, amid all the outpouring
of emotion and speculation, feel inclined to discuss the particulars of the Lambert case as revealed in
Dalzell's courtroom.
More common was East Lampeter Supervisor Chairman John Shertzer's response. "There were a lot of
false accusations throughout the trial. . . . We never had the opportunity to address those," Shertzer told
a reporter, before confessing that he, in fact, couldn't address them: "There are some things about this
that I don't have a lot of background in. But I just know these people. . . . They were treated very
abusively on the stand by Lambert's attorneys as well as the judge."
Lancaster's citizens were struggling to hold together a way of viewing their world. Even those willing to
acknowledge certain blemishes in that world--even those willing to acknowledge official wrongdoing in the
Lambert case--found themselves laboring to understand what Dalzell had done. No matter what was
revealed in a Philadelphia courtroom, no matter what Lancaster authorities did or failed to do, it seemed
incomprehensible that Dalzell would let Lisa Lambert walk free, without at least a retrial.
Not even Lisa's parents had hoped for that back when their daughter's appeals first started. Their dream,
Leonard Lambert told a reporter then, was that Lisa receive "a level of punishment that's not greater than
what's deserved. . . . It's a known fact that she was there. But something could argue that maybe she
doesn't deserve more than aggravated assault or third-degree murder."
Dalzell went too far, even the more reasonable in Lancaster County now declared. He was a disgrace to
the legal profession.
Hazel Show, more than anyone, sounded the clarion. "Thank you for listening to me," she'd told Dalzell on
the hearing's last day. "My parents brought me up to be truthful, and I believe in God. . . . So it is up to
me to tell the truth." Yet soon after, whether out of confusion or regret at what she'd wrought, Show
began to backtrack and revise.
Never in her "wildest dreams," she declared, had she thought her story would free Lisa. All her story
proved was that she got home just as the killers left, in time to hear her daughter's dying declaration. But
the judge "didn't want to hear that." The judge "wouldn't let me say that."
No matter that Madenspacher insisted Hazel never mentioned this notion to him in their hotel meeting. No
matter that she never mentioned this notion while on the witness stand on the hearing's last day. It now
became her constant refrain. "We have to get this judge off the bench," she began declaring publicly.
"There is not one bit of justice in him."
They began first with a petition drive. Hazel's ex-husband, John Show, drew it up, calling for Congress to
"investigate" Dalzell and take "corrective action," including impeachment. Show's girlfriend took it to her
beauty shop, where customers clamored to sign it. Local businesses started stocking piles on their front
counters. Volunteers called for extra copies, carried them door to door, offered them at yard sales. One
couple outside a Kmart parking lot on a hot Sunday collected more than 500 signatures.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 88
85 of 91
88
Page 12 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1114
112 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
On the morning after an ad for the petition appeared in the Lancaster newspapers, John Show walked to
his mailbox and found 300 envelopes. By mid-September, he had 37,000 signatures.
Then came Hazel Show's 10-page "Citizens Action Report," the keystone of her newly launched national
campaign seeking to reform the entire federal judiciary. Now the Shows wanted, among a host of items,
to bar federal judges from banning retrials, to fix stricter guidelines for appointing federal judges, to limit
federal judges' terms in office. Hazel Show's words and image soon became ubiquitous in Lancaster
County.
Television provided one forum, both local talk shows and the national tabloids. Politicians provided
another. The Washington-based Judicial Selection Monitoring Project, an arch-conservative organization
seeking to block the appointment of what it calls "activist liberal judges," featured both Shows in a 15minute videotape that lambasted Dalzell and misidentified him as a Clinton appointee.
The Shows, accompanied by 16 friends and relatives, took their campaign to Washington on Sept. 17,
where Pennsylvania Sen. Arlen Specter, along with Reps. Joseph R. Pitts and George W. Gekas, accepted
cartloads of petitions. The lawmakers, weeks before, had introduced legislation that would severely
restrict federal judges' power to bar retrials during habeas proceedings--a bill specifically designed to
reverse Dalzell's decision. Now, to the Shows, Specter agreed to call it the "Laurie Bill" and promised them
a Senate Judiciary Committee hearing. Wherever they went, the Shows were applauded and courted.
Argument That Judge Brought It on Himself It can fairly be argued that Dalzell brought some of this on
himself. He may have overly embraced Lisa Lambert's account of events, and unduly diminished her role.
He may not have needed to rough up witnesses in his courtroom as much as he did. He certainly need not
have painted Lancaster County with such a broad brush at the end of his opinion.
How could he claim to know this county, his critics asked. How could he claim to know our citizens? How
could he say such things about us?
Yet, valid as such claims may be, it most likely will be Dalzell who leaves a lasting impact, not those
fueling the backlash against him.
Whether right or wrong, whether he operated entirely within his bounds, a federal judge consumed by
moral outrage has, as he intended, sent a message. The idea behind Lisa Lambert's outright release was
not, finally, to let a guilty person go free. It was to let the powers of the state know they can't violate
bedrock principles of the Constitution and get away with it.
They haven't.
In early May, the U.S. attorney's office in Philadelphia, responding to Dalzell's referral, announced it had
launched a criminal investigation into those who investigated and prosecuted Lisa Lambert. Aiding them
will be the FBI and the Justice Department's civil rights division. They will focus on John Kenneff and
seven police officers, among them Ronald Savage, Ronald Barley, Robin Weaver and Raymond Solt.
Days later, the U.S. 3rd Circuit Court of Appeals, in refusing Lancaster County's motion for a temporary
stay of Dalzell's order, said "the commonwealth has not demonstrated that it is likely to prevail on the
merits of its appeal. . . . We remind the commonwealth that Judge Dalzell's factual findings are based on
his view of the credibility of the witnesses and testimony. . . .
In that written opinion, the appellate panel also chastised the commonwealth for calling Lisa Lambert a
"convicted killer" in its brief. She "no longer has that status," the 3rd Circuit reminded. "Indeed, that
description is inflammatory and inappropriate, given {Dalzell's} findings of actual innocence. . . . "
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 89
86 of 91
88
Page 13 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1115
113 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
What remains to be seen is whether Dalzell will ultimately be allowed his unprecedented involvement in a
state's sovereign affairs. At the habeas hearing's end, Lancaster County hired its own high-powered
Pennsylvania law firm, Sprague & Lewis, known for its political connections, particularly to the Republican
Party. On Oct. 21, when lawyers for both sides argued the merits of the county's appeal before a 3rd
Circuit panel, the appellate judges grilled them on a critical question: Did Lisa Lambert exhaust all her
appeals in Pennsylvania's courts before turning to a federal judge for help?
This issue, rather than any question of Lisa's innocence or a prosecutor's malfeasance, is what presently
fuels a nationwide debate in the legal community and beyond. Elemental principles of law and government
in this country normally restrain federal intrusion until a state has heard all claims, and has been given
the chance to correct its own errors. Just weeks ago, a 3rd Circuit panel--saying "we are sensitive to the
independence of the Pennsylvania courts and of that state's sovereignty"denied another convict's habeas
petition because he hadn't exhausted his state appeals.
Dalzell, in his opinion, recognized these principles, then essentially dismissed them. The Pennsylvania
General Assembly, he pointed out, amended its statutes in 1995 to exclude "actual innocence" as a basis
for certain appeals. By doing so, Dalzell declared, Pennsylvania, in effect, relinquished its jurisdiction over
claims such as Lisa Lambert's, and placed them "squarely into the federal forum." And even if
Pennsylvania were willing to consider some of Lambert's claims, Dalzell added, "we find that the state
proceedings that would follow if we dismissed this action are ineffective to protect the rights of Ms.
Lambert."
By thus declaring his utter distrust in Pennsylvania's ability to deliver justice, Dalzell has challenged the
fundamental balance ofpower between state and federal courts that governs the judicial system. This is
why five state attorneys generalincluding California's--have joined Pennsylvania in an amicus brief that
talks of the Dalzell ruling's "potential to seriously weaken, if not to dismantle entirely, the system for
litigating habeas actions." This is why law-and-order-minded national politicians have their knives out for
Dalzell. This is why Lisa Lambert's federal hearing promises to be one of the most carefully reviewed cases
in criminal law for a long time to come.
This is also why Dalzell's actions will leave a legacy no matter what the outcome of the present appeals.
His ruling may or may not stand, his ruling may or may not establish a formal precedent, but--by granting
a hearing and allowing widespread discovery--Dalzell has required that attention be paid to what
happened in a Lancaster County courtroom in the summer of 1992. He's shown why the federal habeas
corpus action is essential to the integrity of the judicial system.
Dalzell has also set a moral, if not legal, example. Rulings in one case often affect other rulings. One
judge's decision shapes not just the outcome of a particular case, but also the character of justice. What
he doesn't allow, others likewise forbid.
In mid-May, in Lancaster County court, Lisa Lambert's original trial lawyer, Roy Shirk, serving as defense
attorney in a routine burglary case, rose to ask for a mistrial. As in the Lambert case, he argued,
prosecutors in this one had failed to turn over exculpatory evidence to the defense. Shirk most likely
meant only to put this commonplace claim into the record for later review, but Judge Paul K. Allison, to
the lawyers' astonishment, promptly granted his request.
PHOTO: Lisa Michelle Lambert walks ahead of lawyers, Peter Greenberg and Christina Rainville, to court
hearing.;
PHOTOGRAPHER: Associated Press;
PHOTO: Lancaster County Dist. Atty. Joseph Madenspacher talks to news media after judge ruled Lisa
Michelle Lambert innocent of charges.;
PHOTO: Hazel Show, left, stands in bedroom where daughter, Laurie, was murdered.;
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 90
87 of 91
88
Page 14 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1116
114 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
PHOTO: Laurie's father,

John Show, above, hugs woman identified as his girlfriend, after judge ruled Lisa Michelle Lambert
innocent.;
PHOTO: U.S. District Judge Stewart Dalzell was assigned the writ of habeas corpus that
set him on a course to freeing Lisa Michelle Lambert.;
PHOTOGRAPHER: Associated Press
Reproduced with permission of the copyright owner. Further reproduction or distribution is prohibited
without permission.
Subjects: Judicial reviews, Acquittals & mistrials, Murders & murder attempts, Prosecutions, Series &
special reports
Locations: Lancaster County Pennsylvania
People: Lambert, Lisa, Show, Laurie
Dateline: LANCASTER, Pa.
Section: PART-A; National Desk
ISSN/ISBN: 04583035
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 91
88 of 91
88
Page 15 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1117
115 of
of1299
2301
P
usps.com
Flat Rate Env
062S0000000314
Click-N-Ship
Mailed from 17603
9405 5036 9930 0427 6970 66 0064 5000 0022 0500

$6.45
US POSTAGE
11/16/2016
0006
C000
PRIORITY MAIL 2-DAY
STAN CATERBONE
AMG
1250 FREMONT ST
SHIP
TO: BARACH OBAMA

THE WHITE HOUSE
USPS TRACKING #
9405 5036 9930 0427 6970 66
Cut on dotted line.
Instructions
USPS TRACKING # :


the package.
9405 5036 9930 0427 6970 66

Trans. #:
Print Date:
Ship Date:
Expected
Delivery Date:
From:
To:
389217451
11/16/2016
11/16/2016

Total
$6.45
$6.45
11/18/2016
STAN CATERBONE
AMG
1250 FREMONT ST
BARACH OBAMA
THE WHITE HOUSE
* Retail Pricing Priority Mail rates apply. There is no fee for USPS Tracking service
on Priority Mail service with use of this electronic rate shipping label. Refunds for
unused postage paid labels can be requested online 30 days from the print date.
January January
Sunday
22, 201722, 2017
Page
Page1118
116 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1119
117 of
of1299
2301
Search - Supreme Court of the United States
1 of 2
January January
Sunday
22, 201722, 2017
https://www.supremecourt.gov/search.aspx?filename=/docketfiles/16-68...
Page
Page1120
118 of
of1299
2301
1/10/2017 5:14 PM
2 of 2
January January
Sunday
22, 201722, 2017
Page
Page1121
119 of
of1299
2301
1/10/2017 5:14 PM
January January
Sunday
22, 201722, 2017
Page
Page1122
120 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1123
121 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1124
122 of
of1299
2301

scaterbone@live.com
717-669-2163
1250 Fremont Street
Lancaster, PA 17603
OFFICE OF THE CIRCUIT EXECUTIVE
UNITED STATES THIRD CIRCUIT
_______________________________________________________________________________
In the Matter of Complaint Filed
Under U.S.C 28 351 et. Seq.
J.C. No. 03-16-90005
:
:
Stanley J. Caterbone, Pro Se
:
PETITIONER and MOVANT
:
PETITION FOR REVIEW
I Stanley J. Caterbone, MOVANT, and appearing Pro Se, do hereby on this 16 th day of March
2016 file a MOTION FOR RECONSIDERATION to the OPINION AND MEMORANDUM of February
25, 2016.
Date: March 16, 2016
Office of
Of the
TheCircuit
CircuitExecutive
Executive- Petition For Review
Stanley J. Caterbone, Pro Se PETITIONER

1250 Fremont Street
Lancaster, PA 17603
(717)-669-2163
scaterbone@live.com
Page
Page
Page111of
of
of65
69
1
January January
Sunday
22, 201722, 2017
Page
Page1125
123 of
of1299
2301
BACKGROUND OF CASE
To clarify for the COURTS on December 14, 2015 Stanley J. Caterbone filed a letter to the
Clerk requesting to WITHDRAW appeal no. 15-3400 in the Third Circuit.
Then on December 17,
2015 Stanley J. Caterbone filed a letter to the Clerk CLARIFYING the Withdraw as a MOTION to
WITHDRAW WITHOUT PREJUDICE. On December 31, 2015 Stanley J. Caterbone filed a letter
to the COURT RESCINDING his MOTION TO WITHDRAW.
On January 12, 2016 FISHER,
JORDAN and VANASKIE, Circuit Judges, Ruled Case No. 15-3400 MOTION TO WITHDRAW
GRANTED. On January 13, 2016 Stanley J. Caterbone filed a MOTION TO REINSTATE the Appeal in
the Third Circuit. On January 15, 2016 (FISHER, JORDAN and VANASKIE, Circuit Judges DENIED
MOTION TO REINSTATE the Appeal in the Third Circuit. And on January 15, 2016 Stanley J.
Caterbone filed a MOTION TO RECUSE Third Circuit Judge Michael Fisher for Conflict of Interest in
the Lisa Michelle Lambert Case. On February 16, 2016 this case was DISMISSED for failing to file
the appropriate filing fee. An Appeal was filed in U.S. District Court and the Clerk of Court Instituted
Case No. 16-1149.
SEQUENCE OF EVENTS
1. 15-3400, Third Circuit Court of Appeals, November 24, 2015 Stanley J. Caterbone
FILED a Motion for a 30 Day Extension of Time.
2. Order granted.
3. 15-3400, December 14, 2015 Stanley J. Caterbone FILED a LETTER to the Clerk
requesting to WITHDRAW appeal no. 15-3400 in the Third Circuit.
4. 15-3400, December 17, 2015 Stanley J. Caterbone FILED a LETTER to the Clerk
CLARIFYING the Withdraw as a MOTION to WITHDRAW WITHOUT PREJUDICE.
5.
15-3400, December 31, 2015 Stanley J. Caterbone FILED a LETTER to the COURT
RESCINDING his MOTION TO WITHDRAW.1
6.
15-3400, January 12, 2016 FISHER, JORDAN and VANASKIE, Circuit Judges, ISSUED AN
ORDER in Case No. 15-3400 MOTION TO WITHDRAW GRANTED.2
7. 15-3400, January 13, 2016 Stanley J. Caterbone FILED a MOTION TO REINSTATE the
Appeal in the Third Circuit.
8. 15-3400, January 15, 2016 (FISHER, JORDAN and VANASKIE, Circuit Judges ISSUED AN
ORDER DENIED MOTION TO REINSTATE the Appeal in the Third Circuit.
9. 15-3400, January 15, 2016 Stanley J. Caterbone FILED a MOTION TO RECUSE Third
Circuit Judge Michael Fisher for Conflict of Interest in the Lisa Michelle Lambert Case due to a
1The Letter to Rescind was either hidden from FISHER, JORDAN and VANASKIE or FISHER, JORDAN and
VANASKIE ignored the Letter to Rescind. This would have preserved the entire Record of Case No. 15-3400
including EXHIBITS, MOTIONS, ETC.,.
2This DELETED AND REMOVED FROM THE PUBLIC DOMAIN and from DELIBERATIONS the entire the Record of
Case No. 15-3400 including EXHIBITS, MOTIONS, ETC., which SUPPORTS AND PROVIDES EVIDENCE FOR
AFFIRMATION OF THE MOTION FOR SUMMARY JUDGEMENT in Case No. 14-02559 and a FAVORABLE Ruling in
the U.S. Third Circuit Court of Appeals for the Complainant, and Pro Se Appellant.
Office of
Of the
TheCircuit
CircuitExecutive
Page
Page
Page222of
of
of65
69
2
January January
Sunday
22, 201722, 2017
Page
Page1126
124 of
of1299
2301
conflict of interest since Michael Fisher was acting Attorney General of Pennsylvania and
Superior to Christy Fawcett who PROSECUTED Lisa Michelle Lambert's PRCA Hearing before
Lancaster County Court of Common Pleas Judge Lawrence Stengel in 1998.
10. U.S District Court, 14-02559, January 17, 2015 in the United States District Court for
the Eastern District of Pennsylvania in Case No. 14-02559 Stanley J. Caterbone FILED a
NOTICE OF APPEAL.
11. U.S District Court, 14-02559, January 17, 2015 in the United States District Court for
the Eastern District of Pennsylvania in Case No. 14-02559 Clerk's Notice to USCA re 25
Notice of Appeal : (jpd, ) (Entered: 01/20/2016)
12. 15-3400, January 12, 2016 FISHER, JORDAN and VANASKIE, Circuit Judges, ISSUED AN
ORDER in Case No. 15-3400 DISMISS MOTION TO RECUSE JUDGE FISHER as moot
due to ORDER GRANTING MOTION TO WITHDRAW.3
13. 6-1149, January 22, 2016 in the U.S. THIRD CIRCUIT Clerk Issues New Docket No.
16-1149
ARGUMENT IN SUPPORT OF THE PETION FOR REVIEW
Judge Michael Fisher, Former Prosecutor for the Lambert Case

Judge Michael Fisher did preside in the ORDER of January 12, 2016. On January 14 th via an
email from Attorney and Co-Author Dave Brown, I was alerted to the fact that the FISHER in the
curium of judges was that of the same Micheal Fisher that was the Pennsylvania Attorney General
during the second prosecution of Lisa Michelle Lambert in the Lancaster County Court of Common
Pleas. In his email Attorney Dave Brown wrote the following:
Sorry to hear it. Its amazing that Mike Fisher was the lead Third Circuit Judge who granted
the motion to dismiss. He should have recused himself from any case involving Lisa because when
he was A.G., he filed a flurry of baseless recusal motions which culminated in Dalzell recusing
himself in January 2012. As we describe in the book, it was dirty politics. At the end of your e-mail,
you state: I am not going to let you [suggesting me] get away with this. You mean that you wont
let them Judge Diamond, Third Circuit get away with this Good idea filing the motion to reinstate
your appeal. Hey, were eager to see how Judge Diamond rules on the Application Pro Hac Vice for
California lawyer Brian Claypool to get involved in Lisas case. You keep an eye on the docket more
regularly than I do. Can you let me know if you see an Order from Diamond granting or denying
Brians Application? Thanks.
THE
CLERK
OF
COURT,
MAYBE
PURPOSEFULLY
COMPLETELY
IGNORED
15-3400,
December 31, 2015 Stanley J. Caterbone FILED a LETTER to the COURT RESCINDING his
MOTION TO WITHDRAW. In addition the docketing of Case No. 16-1149 completed erased the
3This ORDER was a Complete and Total Disregard to the Law and Highly prejudicial.
Office of
Of the
TheCircuit
CircuitExecutive
Executive- Petition For Review Page
Page
Page333of
of
of65
69
3
January January
Sunday
22, 201722, 2017
Page
Page1127
125 of
of1299
2301
record on appeal by vacating all docket entries in case no. 15-3400, which placed the PETITIONER,
Stanley J. Caterbone and the PETITIONER, Lisa Michelle Lambert in a a compromising situation by
having to restate the entire record of case no. 15-3400 in order to effectively fight for the deserved
freedom from the original Habeus Corpus filed in May of 2014. In addition the DISMISSAL violates
Stanley J. Caterbone's civil rights and fair access to the law as well as serves as a means of denying
Lisa Michelle Lambert's Habeus Corpus case. Also the Dismissal of 15-3400 conveniently oppresses
Stanley J. Caterbone's Motion For Summary Judgments in both federal and state courts as outlined
in his MOTION FOR SUMMARY JUDGEMENT in case no. 14-02259; In addition the MOVANT must
be restored to whole by administering SUMMARY JUDGEMENTS in cases 05-2288; 064650; and all other cases filed by the MOVANT in this court.
SUMMARY JUDGEMENTS
must also be administered in Case No. 08-13373 in the Lancaster Court of Common Pleas,
and other cases filed by the MOVANT in that said court. This alone would provide many
defendants with UNJUST ENRICHMENT, which is defined by the following:
UNJUST ENRICHMENT (Wikipedia, The Free Dictionary by FARLEX) - A general
equitable principle that no person should be allowed to profit at another's expense without making
restitution for the reasonable value of any property, services, or other benefits that have been
unfairly received and retained. Although the unjust enrichment doctrine is sometimes referred to as
a quasi-contractual remedy, unjust enrichment is not based on an express contract. Instead,
litigants normally resort to the remedy of unjust enrichment when they have no written or verbal
contract to support their claim for relief. In such instances litigants ask a court to find a contractual
relationship that is implied in law, a fictitious relationship created by courts to do justice in a
particular case.
Unjust enrichment has three elements. First, the plaintiff must have provided the defendant
with something of value while expecting compensation in return. Second, the defendant must have
acknowledged, accepted, and benefited from whatever the plaintiff provided. Third, the plaintiff
must show that it would be inequitable or Unconscionable for the defendant to enjoy the benefit of
the plaintiff's actions without paying for it. A court will closely examine the facts of each case before
awarding this remedy and will deny claims for unjust enrichment that frustrate public policy or
violate the law.
In some circumstances unjust enrichment is the appropriate remedy when a formally
executed agreement has been ruled unenforceable due to incapacity, mistake, impossibility of
performance, or the Statute of Frauds. In certain states, for example, contracts with minors are
Voidable at the minor's discretion because persons under the age of majority are deemed legally
incapable of entering into contracts. But if the minor has received a benefit from the other party's
performance before nullifying the contract, the law of unjust enrichment will require the minor to
pay for the fair market value of the benefit received. If the adult used duress or Undue Influence to
induce the minor to enter the contract, however, the court will deny recovery in unjust enrichment
because the adult lacked "clean hands."
Office of
Of the
TheCircuit
CircuitExecutive
Page
Page
Page444of
of
of65
69
4
January January
Sunday
22, 201722, 2017
Page
Page1128
126 of
of1299
2301
In other circumstances unjust enrichment is the appropriate remedy for parties who have
entered a legally enforceable contract, but where performance by one party exceeds the precise
requirements of the agreement. For example, suppose a homeowner and a builder have entered
into a legally binding contract under which the builder is to construct a two-car garage. One day the
owner returns to her residence and discovers that in addition to constructing a two-car garage, the
builder has paved the driveway. The owner says nothing about the driveway but later refuses to
compensate the builder for the paving job. The builder has a claim for unjust enrichment in an
amount representing the reasonable value of the labor and materials used in paving the driveway.
Suppose, instead, that after completing half the job, the builder tells the owner that he cannot finish
the garage as originally agreed, but that he wants to be paid for the work he has done. The owner
balks at this demand, arguing that the builder has breached his contractual obligations and is
entitled to nothing. A minority of jurisdictions would allow the builder to recover the reasonable
value of his services, minus any damages suffered by the owner as a result of the breach.
A majority of jurisdictions, however, adhere to the rule that a party who fails to perform contractual
obligations has no remedy regardless of the amount of hardship he might endure.
The doctrine of unjust enrichment also governs many situations where the litigants have no
contractual relationship. For example, the law finds an implied promise to pay for emergency
medical treatment that is neither requested nor consented to by a patient. In some jurisdictions the
law finds an implied promise to pay for life-saving medical treatment even when a patient objects to
receiving it. The law also requires parents to reimburse a person who voluntarily supplies
necessaries such as food, shelter, and clothing to their children. As these examples demonstrate,
unjust enrichment is a flexible remedy that allows courts great latitude in shifting the gains and
losses between the parties as Equity, fairness, and justice dictate.
U.S. District Court The Honorable Judge Paul Diamond

On June 23, 2015, the PETITIONER, was listed on the Lisa Michelle Lambert Habeus Corpus Case,
No. 14-2559, filed in the U.S. District Court for the Eastern District of Pennsylvania, as the MOVANT,
as depicted in the caption as stated v. Movant, STANLEY J. CATERBONE AND ADVANCED MEDIA
GROUP represented by STANLEY J. CATERBONE, PRO SE, 1250 FREMONT STREET LANCASTER,
PA 17603. See Attached.
On or about the week of June 29, 2015 the PETITIONER did in fact communicate with Mr.
Jeremy H.G. Ibrahim, Sr., Esq, appointed counsel on May 22, 2014, via a telephone conversation in
which Mr. Ibrahim stated I am very busy and will be in court in Delaware this week and will be in
touch with you later.
Office of
Of the
TheCircuit
CircuitExecutive
Page
Page
Page555of
of
of65
69
5
January January
Sunday
22, 201722, 2017
Page
Page1129
127 of
of1299
2301
On July 9, 2015 the PETITIONER, did receive an email from Mr. Jeremy H.G. Ibrahim, Sr.,
Esq, the appointed counsel as of the May 22, 2014, for Petitioner Lisa Michelle Lambert, U.S. District
Court Case No. 14-2559,
stated the following:
Kindly remove my email address. Your emails are harassing and causing distress. This
a
cease
and
desist
notice.
refer
you
to
18
USC
2261
and
PA
Code:
http://www.legis.state.pa.us/WU01/LI/LI/CT/HTM/18/00.027.009.000..HTM I will
file
a police report shortly in my township. Jeremy H. Gonzalez Ibrahim, Esq. USNA
Blue &
Gold Officer.
As filed and recorded in the ORDER of September 14, 2015 Judge Paul Diamond declared the
following:
I previously dismissed Petitioners pro se motion for habeas relief so that she could file
counseled motion. (Doc. No. 3.) She has not yet done so. On June 23, 2015, Stanley
Caterbone
who has nothing to do with Petitioner, her motion, or this casefiled a pro se amicus brief in
support of the dismissed motion. (Doc. No. 4.) Caterbone neither sought leave to file, nor indicated
that he had received the Parties consent to file an amicus brief. Fed. R. Civ. P. 29(a) The amicus
briefalthough providing some arguments in apparent support of the dismissed motionessentially
focuses on the
U.S.
damages Caterbone allegedly suffered from his years of torture as a victim of
Sponsored Mind Control or as a victim of gang-stalking or organized stalking by more than
100 people. (Doc. No. 4 at 7, 9). He also includes a lengthy discussion of the
question of Stan Caterbones intelligence, or lack thereof, and his work on
is directly responsible for the development of the internet. (Id.
details thirty governmental attempts at mind control,
surroundings with electromagnetic energy;
perplexing
a digital movie that
at 16-26). In addition, he
including: 1) Blanketing my dwelling and
2) Invading my thoughts via remote sensing
technologies; and 3) Making me mentally hear others voices through the microwave hearing
effect. (Id. at 27-30.)
brief. On July 6,
Caterbones involvement in the matter did not end with his amicus
2015, he filed with this Court an email that he had sent to the Lancaster
Police, asserting that he has synthetic telepathy. (Doc. No. 5.) On September 2 and 3, 2015,
Caterbone moved for summary judgment. (Doc. Nos. 8, 9.) On September 3, 2015, he moved to
file a copy of his motion for reconsideration of the denial of his petition to proceed in forma pauperis
in Pennsylvania state court, (which had been dismissed as frivolous). (Doc. No. 10.) On
September 9, 2015, he also moved to file: 1) an email
exchange with the subject Muslims Using
My Situation to Fight Against the USA; 2) a Wikipedia article on Entrapment; and 3) an exhibit of
billing statements of his estimated fees for his 2007 work on wholly unrelated federal and state
court cases.
(Doc. Nos. 11, 12, 14.) On September 9, 2015, Caterbone called my Chambers,
demanding to speak with me, and then abruptly hung up. I have already denied Caterbones
Office of
Of the
TheCircuit
CircuitExecutive
Page
Page
Page666of
of
of65
69
6
January January
Sunday
22, 201722, 2017
Page
Page1130
128 of
of1299
2301
request to file documents electronically. (Doc. No. 9.) He has nonetheless continued to submit
filings that have nothing to do with this case.
The above ORDER and declarations by Judge Paul Diamond fail to mention the fact that the
declarations made by the PETITIONER, in his amicus, were for the sole purpose of providing to the
Court as much factual information and background information as possible with regards to the
PETITIONER's legal odyssey in the federal court system since filing Case No. 05-2288 on May 16,
2005.
The PETITIONER has submitted volumes of evidence surrounding the massive efforts of
Judges, Prosecutors, Friends, Relatives, Professional Colleagues, the Media, and Law Enforcement
to discredit the PETITIONER since the June 23, 1987 meeting with ISC Executive Larry Resch. In
addition with regards to the subject of U.S. Sponsored Mind Control, the PETITIONER has been
collecting Social Security Disability Benefits since April of 2008 for symptoms and illnesses related to
the same. The Social Security Administration, in it's award letter of August of 2009, declared the
PETITIONER mentally disabled as of December of 2005, the time in which the PETITIONER declared
under oath of law, as to the time when the PETITIONER become a victim of full-time, 24/7 synthetic
telepathy. The PETITIONER can prove the preceding by virtue of the fact that there was no medical
reports from any doctors or psychiatric professionals submitted during the application for benefits
process, and the Social Security Administration refused to grant the PETITIONER a psychiatric
evaluation. Also, the PETITIONER filed a Motion for a Hearing on October 26, 2015 to provide this
Court with expert testimony proving the same.
Clearly Judge Paul Diamond has continued that effort, demonstrated by his lack of attention
to the arguments made in the PETITIONER's amicus as to the merits and legal standing of the
PETITIONER with regards to the question of being the MOVANT in this case.
There is some indication that both Judge Paul Diamond and Mr. Jeremy H.G. Ibrahim, Sr.,
Esq, are colluding to discredit the PETITIONER, Stanley J. Caterbone, and possibly derail the
PETITIONER, Lisa Michelle Lambert's efforts at relief and release from incarceration as stated in her
pro se Habeus Corpus of May 2, 2014. There seems to be no reasonable explanation at the lack of
movement in the case from May, of 2014 until the day of June 23, 2015, some 14 months later,
when the PETITIONER, Stanley J. Caterbone, was listed as the MOVANT.
This theory was first
considered back in June of 2015 by the PETITIONER, Stanley J. Caterbone.

The PETITIONER'S claim of the value of the PETITIONER's litigation of up to $50 million
dollars as stated in the U.S. Bankruptcy Case No. 05-23059 is alone sufficient evidence to call into
question the Judiciary of the LAMBERT proceedings regarding Pro Se Litigant Stanley J. Cateronbe.
I do 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 my
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.
Office of
Of the
TheCircuit
CircuitExecutive
Page
Page
Page777of
of
of65
69
7
January January
Sunday
22, 201722, 2017
Page
Page1131
129 of
of1299
2301
TARGETED INDIVIDUAL
DEFINITION
Targeted Individual is a person who has been singled out by a criminal syndicate called
"Organized Gang Stalking." The targeted individual is under 24 hour surveillance and is stalked by
large groups of various criminals. The new technologies have brought about the possibility of this
crime. All of the wireless devices can be hacked and tracked. The criminals carry non lethal weapons
in their cars and use them against the Targeted Individual. The weapons are both easy to buy or
easy to make. They use lasers, dazzlers, hand held microwave, x ray devices, plasma beams, and
other directed energy weapons. The stalkers are working full time to discredit the victims of this
crime and to insinuate they are mentally ill to silence the victims. There are now so many victims
that the crime is no longer being denied. Even the Department of Justice has verified the fact that
group stalking is on a significant rise with a government survey. In a 2009 DOJ study verified there
were a total 3,398,630 reported victims of stalking. Out of the total number of stalking victims 13.1
% documented that they had at least 3 or more stalkers. A quick average of the figures (441,821
victims had 3 or more stalkers) (200,000 victims had more stalkers than they could count) The
Targeted Individuals are now raising awareness to this crime by educating the public with websites,
books,videos, and blogs.
COMES NOW, Stanley J. Caterbone, herein known as the PETITIONER, appearing pro se
and APPELLANT in U.S.C.A Case No. 15-3400, is resident of 1250 Fremont Street, Lancaster,
County of Lancaster, State of Pennsylvania and who makes this his statement and General
Affidavit upon oath and affirmation of belief and personal knowledge that the following matters,
facts and things set forth are true and correct to the best of his knowledge:
The document titled the Advanced Media Group Press Release re Stalking Legislation With
Executive Summary November 17, 2015 containing 41 pages is a true and authentic document
with true and correct affidavits. The statements and declarations contained in the affidavits as they
pertain to the PETITIONER are his sworn testimony to the best of his knowledge. The PETITIONER
did prepare a list of persons who have identified themselves as such during telepathic
communications during the past 10 years, in or about the year 2010.
The list was written on a
yellow legal pad and has not been located or found. It is the belief of the PETITIONER that the list
was stolen or relocated to a place where it will not be found. Without spending too much time, the
PETITIONER will list some of those persons; Sheryl Crow, Jenifer Aniston, Erin Burnette, Agents
of the Central Intelligence Agency (3 or 4), an Officer of the National Security Agency, or NSA (65
and was retiring to Chesapeake Bay), black females (2 or 3), Timothy McViegh, Linda Davis Vega,
Valarie Plume, female Lancaster City Police Officer, Federal Agent, and handlers of the program.
The PETITIONER has made a relentless effort to identity and confirm such persons, however after
conducting research and listening to other qualified experts, the PETITIONER no longer believes it
is possible to identify or discredit the persons on the other side of telepathic communications.
Office of
Of the
TheCircuit
CircuitExecutive
Page
Page
Page888of
of
of65
69
8
January January
Sunday
22, 201722, 2017
Page
Page1132
130 of
of1299
2301
REQUEST FOR HEARING AND ORAL ARGUMENTS

Perhaps the best way to inform the courts of the targeted individual situation as it relates to
me, Stanley J. Caterbone is to provide you with copy of the text of my request for a Hearing before
the U.S. Third Circuit to provide testimony to substantiate my claims. Please review the following:
START[I hereby on this
26th
day of October, 2015, request a Hearing before the U.S. Third
Circuit Court of Appeals to provide expert testimony from expert witnesses that are known to have
substantiated the claims of the existence of U.S. Sponsored Mind Control Technologies and to have
the same such experts make a determination by interview or review of the court record the claims
by the APPELLANT, Stanley J. Caterbone as to his claims of his own victimization's and accounts of
being a Targeted Individual subjected to those same said technologies. The following is an exerpt
from the ORDER by the Honorable Judge Paul S. Diamond on September 11, 2015:
'The amicus briefalthough providing some arguments in apparent support of the

dismissed motionessentially focuses on the damages Caterbone allegedly suffered from
his years of torture as a victim of U.S. Sponsored Mind Control or as a victim of gangstalking or organized stalking by more than 100 people. (Doc. No. 4 at 7, 9). He also
includes a lengthy discussion of the perplexing question of Stan Caterbones intelligence,
or lack thereof, and his work on a digital movie that is directly responsible for the
development of the internet. (Id. at 16-26). In addition, he details thirty governmental
attempts at mind control, including: 1) Blanketing my dwelling and surroundings with
electromagnetic energy; 2) Invading my thoughts via remote sensing technologies;
and 3) Making me mentally hear others voices through the microwave hearing effect.
(Id. at 27-30.)'
It is clear that the intentions of the Honorable Judge Paul S. Diamond was only to discredit
the APPELLANT and prejudice the Court.
explanation.
There would appear to be no other reasonable
The APPELLANT has explained in his Notice of Appeal the reason for providing the
Courts with that specific information. The APPELLANT has argued the following in his NOTICE OF
APPEAL:
Clearly the Honorable Judge Paul S. Diamond had intentions other than that of fair
and equitable jurist prudence regarding this case. The MOVANT, Stan J. Caterbone, has
been fighting for his reputation, his integrity, his intellectual property, his personal property, his basic human rights, and most importantly his constitutional rights in this court
for the past ten (10) years as pro se. The MOVANT had made a bona fide attempt to pro vide as much factual background to the Honorable Judge Diamond as humanly possible in
Office of
Of the
TheCircuit
CircuitExecutive
Page
Page
Page999of
of
of65
69
9
January January
Sunday
22, 201722, 2017
Page
Page1133
131 of
of1299
2301
as an efficient manner as possible so as not to clutter the courts and the dockets. You
must remember the MOVANT has the burden of articulating to the COURTS a 30 plus year
legal quagmire. See Case No. 07-4474 in the Third Circuit Court of Appeals.
Attached is the document titled Stan Caterbone and Advanced Media Group Present the ISC
Story as it relates to U.S. Sponsored Mind Control and the Federal False Claims Act October 25,
2015 which will provide the Court with the evidence of linkage of the Federal False Claims Act
violations of International Signal and Control, PLC., or ISC and U.S. Sponsored Mind Control through
the Board of Directors member Adm. Bobby Ray Inman.
Bobby Ray Inman's Wikipedia page states:

He served as Director of Naval Intelligence from September 1974 to July 1976, then moved
to the Defense Intelligence Agency where he served as Vice Director until 1977. He next became the
Director of the National Security Agency. Inman held this post until 1981. His last major position
was as the Deputy Director of Central Intelligence, a post he held from February 12, 1981 to June
10, 1982. Inman has been influential in various advisory roles. Notably, he chaired a commission
on improving security at U.S. foreign installations after the Marine barracks bombing and the April
1983 US Embassy bombing in Beirut, Lebanon. The commission's report has been influential in
setting security design standards for U.S. Embassies. After retirement from the Navy, he was
Chairman and Chief Executive Officer of the Microelectronics and Computer Technology Corporation
(MCC) in Austin, Texas for four years and Chairman, President and Chief Executive Officer of
Westmark Systems, Inc., a privately owned electronics industry holding company for three years.
Admiral Inman also served as Chairman of the Federal Reserve Bank of Dallas from 1987 through
1990. Admiral Inmans primary activity since 1990 has been investing in start-up technology
companies, where he is a Managing Director of Gefinor Ventures and Limestone Ventures. He is a
member of the Board of Directors of Massey Energy Company and of several privately held
companies. He serves as a Trustee of the American Assembly and the California Institute of
Technology. He is an elected Fellow of the National Academy of Public Administration.
President
Clinton nominated him as Secretary of Defense, but he withdrew his nomination (see below).
Inman also was on the board of SAIC.[1] Since 2001, Inman has held the LBJ Centennial Chair in
National Policy at The University of Texas at Austin Lyndon B. Johnson School of Public Affairs, and
in 2005 and again in 2009 was the school's interim dean.[2] Inman graduated from Texas with a
bachelor's in history in 1950. Inman has also served on the Board of Directors of the Council on
Foreign Relations, Dell Computer, SBC Corporation (now AT&T)[3] and Massey Energy. In 2011 he
became head of the board of directors of Xe Services, formerly Erik Prince's Blackwater and now
known as Academi.[4] As of 2013, he sits on the Board of Directors of Academi.[5] Nomination for
Secretary of Defense Inman was announced as President Bill Clinton's choice to succeed Les Aspin
as Secretary of Defense on December 16, 1993, initially receiving broad bipartisan support. He
Office of
Of the
TheCircuit
CircuitExecutive
Page
Page 10
10 of
of 10
65
69
January January
Sunday
22, 201722, 2017
Page
Page1134
132 of
of1299
2301
accepted the post at first, but withdrew his nomination during a press conference on January 18,
1994.[6]
International Signal and Control (ISC) Scandal In 1994, after Bobby Ray Inman
requested to be withdrawn from consideration as Defense Secretary, his critics speculated that the
decision was motivated by a desire to conceal his links to ISC. Inman was a member of the board of
directors of the company, which was allegedly either negligent or approved illegal exports.[5]
Originally called ESI (Electronic Systems International), the company manufactured sub-assemblies
for the AGM-45 Shrike and RIM-7 Sea Sparrow missiles in 1974, and just after the Vietnam war
which was part of a standard arms contract for the US defense administration (DCAS). The company
also had a commercial repair facility of two meter portable amateur ("ham") radios from a company
in New Jersey called Clegg,[2] and manufactured communications helmet radios for firemen, and
electronic outdoor bug zappers. ISC was involved in two major indiscretions, for which CEO James
Guerin received a 15-year prison sentence: It defrauded and caused the collapse of the British
company Ferranti, which acquired it in 1987.[3] It exported classified military technology to South
Africa, which was then forwarded to third countries, notably Iraq. From 1984 to 1988, ISC sent
South Africa more than $30 million in military-related equipment, including telemetry tracking
antennae to collect data from missiles in flight, gyroscopes for guidance systems, and photoimaging film readers, all of which would form the "backbone" of a medium-range missile system.
Some of this technology was reportedly transferred to Iraq.[7] Another link to Iraq was the supply
of the specifications for the Mk 20 Rockeye II cluster bomb through Chilean defence company Carlos
Cardoen, which was able to build an almost identical weapon that was subsequently used against
coalition forces in the Persian Gulf War of JanuaryFebruary 1991.[8]
The controlling document is titled Brief History Of MK-Ultra and Bobby Ray Inman Link to
Mind Control by Thomas Porter in 1996 which states the following under Players in the Mind Control
sphere
S.A.I.C.
arrangements,
involvement
via their
in
'Cognitive
1993
American
Parapsychological
Sciences Laboratory'. Science
Association
Applications
meeting
International
Corporation is a big time defense contractor, has held the largest number of research contracts of
any defense contractor. Bobby Ray Inman is on its board of directors, among others.
The following is a list of the experts the APPELLANT wishes to subpoena to this court, either
in person or by way of notarized affidavits:
1. FREEDOM FROM COVERT HARASSMENT AND SURVEILLANCE (FFCHS), Human

Rights Organization, I have been a member since 2009 and have recently served on the
OUTREACH COMMITTEE. FFCHS was formed to address these atrocities and seek justice for
those who are victims of harassment group activities which stem from corrupt elements of
the US military intelligence and the US investigative agencies, certain defense contractors,
corporations, as well as individuals and teams of private citizens. The Church Committee
Office of
Of the
TheCircuit
CircuitExecutive
Page
Page 11
11 of
of 11
65
69
January January
Sunday
22, 201722, 2017
Page
Page1135
133 of
of1299
2301
investigation and hearings of 1975 revealed the existence of secret mind control
experimentation programs being conducted by the CIA. After the hearings, the CIA officially
abandoned these programs. However, whistleblower reports state otherwise and the
corroborating accounts of thousands of victims indicate the illegal, non-consensual research
continued unabated. The findings of Church Committee Reports revealed widespread privacy
rights abuses in the actions of the CIA, FBI, and NSA which ultimately , were not adequately
addressed. And nowadays, because of the secrecy and lack of congressional oversight during
the intervening decades, the research and development of mind control and surveillance
technologies have advanced far beyond what most Americans would imagine.
2. Julianne McKinney, former intelligence officer for the U.S. Army, Julianne McKinney,
Director. Electronic Surveillance Project. Association of National Security Alumni. And auther
of MICROWAVE HARASSMENT AND MIND-CONTROL EXPERIMENTATION WHITHER THE KGB?
Juleanne McKinney's Interview in 2007 on Youtube is one of the best on the subject.
3. Dr. Nick Begich, PhD., has spent countless hours being interviewed and has made
numerous presentations on the subject of Mind Control. Dr. Nick Begich is the eldest son of
the late United States Congressman from Alaska, Nick Begich Sr., and political activist Pegge
Begich. He is well known in Alaska for his own political activities. He was twice elected
President of both the Alaska Federation of Teachers and the Anchorage Council of Education.
He has been pursuing independent research in the sciences and politics for most of his adult
life. Begich received Doctor of Medicine (Medicina Alternitiva), honoris causa, for independent
work
in
health
and
political
science,
from
The
Open
International
Complementary Medicines, Colombo, Sri Lanka, in November 1994.
University
for
He co-authored with
Jeane Manning the book Angels Don't Play This HAARP; Advances in Tesla Technology.
Begich has also authored Earth Rising - The Revolution: Toward a Thousand Years of Peace
and and his latest book Earth Rising II- The Betrayal of Science, Society and the Soul both
with the late James Roderick. His latest work is Controlling the Human Mind - The
Technologies of Political Control or Tools for Peak Performance. Begich has published articles
in science, politics and education and is a well known lecturer, having presented throughout
the United States and in nineteen countries. He has been featured as a guest on thousands
of radio broadcasts reporting on his research activities including new technologies, health
and earth science related issues. He has also appeared on dozens of television
documentaries and other programs throughout the world including BBC-TV, CBC-TV,
TeleMundo, and others.
4. Dr. John Hall M.D. , Author of the book Satellite Weapons in America, Activist, and
Interviewee on several national broadcast tv, radio, and internet shows. A New Breed:
Satellite Terrorism in America. Dr. Hall's narration is based on true-life events and what
you'll find will open your eyes to a completely new form of terrorism. Dr. Hall has treated
numerous patients who have complained about voices in their heads, eventually being driven
Office of
Of the
TheCircuit
CircuitExecutive
Page
Page 12
12 of
of 12
65
69
January January
Sunday
22, 201722, 2017
Page
Page1136
134 of
of1299
2301
to a form of serious psychosis. In his book, he describes his relationship with his significant
other, Mallory, a young, attractive woman with a bright future. Upon beginning a new
profession, Mallory was suddenly struck down by explainable happenings: mind control,
surveillance, stalking, and rape. Hall and others sacrificed themselves and their careers to
bring her nightmare to an end. Our government satellite surveillance systems are a new way
for criminals to gain possession not only of our financial lives, but our most precious
resource: Our minds. What can we do and who are these individuals who are trying to
control the way the think, feel, act and what we do?
5. Cheryl Welsh, of Mind Justice, A human rights group working for the rights and
protections of mental integrity and freedom from new technologies and weapons which
target the mind and nervous system. The Mind Control Debate is Over. What Next? by Cheryl
Welsh, director, Mind Justice, February 2008. An Adobe Reader pdf Version is available
(143k).
In Contravention of Conventional Wisdom, CIA no touch torture (also available as a pdf)
makes sense out of mind control allegations, by Cheryl Welsh January 2008. The similarities
are striking, as if a government manual for mind control targeting has been found. Now
studies of allegations have a scientific framework from which to begin. Cheryl Welsh was
invited to speak about mind control allegations at a recent workshop on ethics and
interrogations by the workshop director, Jean Maria Arrigo PhD. Dr. Arrigo commented on
this article. Jean Maria Arrigo, PhD, is an independent social psychologist and oral historian
whose work gives moral voice to military and intelligence professionals. See, for example,
Arrigo, J.M & Wagner, R. (2007). Torture Is for Amateurs: A Meeting of Psychologists and
Military Interrogators. [Special issue]. Peace and Conflict, 11 (4).
6. Dr. Terry Robertson, M.D."Electromagnetic Frequency Research" - Dr. Terry Robertson
Dr. Robertson is a board certified anesthesiologist and Chairman of the Medical Committee
for Freedom From Covert Harassment and Stalking (FFCHS). FFCHS is an advocacy and
support group for targeted individuals. One of its goals is to educate the public about
directed energy technologies that can interact with human organisms causing injury to
organ systems and influence psychological behavior. A statement by Dr. Robertson on
directed energy weapons is posted at www.gunsandbutter.org. More information at
www.freedomfchs.com.
7. Missouri Representative Jim Guest, is a former aerospace engineer, and current
farmer, small business owner, and former Republican member of the Missouri House of
Representatives from District 5. Founder of L.A.R.I. (Legislators Against Real ID) and The
Committee for America's Freedom, to pass legislation in every state to repeal the Real ID. He
was born in King City, and graduated from King City R-I High School in 1958. He then
received a B.S. degree in mechanical engineering from University of MissouriRolla, in 1962,
and a master's degree in engineering management in 1970 from the same school. From
Office of
Of the
TheCircuit
CircuitExecutive
Page
Page 13
13 of
of 13
65
69
January January
Sunday
22, 201722, 2017
Page
Page1137
135 of
of1299
2301
1962 through 1974, he worked as an aerospace engineer in California and St. Louis,
Missouri. Jim Guest aired the Jim Guest Show on internet radio and held a weekly talkshow
with interviews on the subject matter. Jim Guest also had written extensively and lobbied
for the legislative reform of the VERI chips and related technologies. He is responsible for
sharing his legislation with the Targeted Individual Community in hope of others helping to
pass Anti-Organized Stalking and Electromagnetic Harassment laws in their respective
states.
The APPELLANT would like the Court to consider providing the APPELLANT with sufficient
time to identify the whereabouts and time to contact the above named witnesses prior to the
November 9, 2015 date for arguments regarding the Summary Panel.]END
Date: March 16, 2016
Stanley J. Caterbone, Pro Se PETITIONER

1250 Fremont Street
Lancaster, PA 17603
(717)-669-2163
scaterbone@live.com
ACTIVE COURT CASES

Lancaster County Court of Common Pleas Case No. 08-13373; 15-10167; 06-03349, CI-0603401
Office of
Of the
TheCircuit
CircuitExecutive
Page
Page 14
14 of
of 14
65
69
January January
Sunday
22, 201722, 2017
Page
Page1138
136 of
of1299
2301
Office of the Circuit Executive - Petition For Review
Page
Page 15
15 of
of 15
69
January January
Sunday
22, 201722, 2017
Page
Page1139
137 of
of1299
2301
Page
Page 16
16 of
of 16
69
January January
Sunday
22, 201722, 2017
Page
Page1140
138 of
of1299
2301
Page
Page 17
17 of
of 17
69
January January
Sunday
22, 201722, 2017
Page
Page1141
139 of
of1299
2301
Page
Page 18
18 of
of 18
69
January January
Sunday
22, 201722, 2017
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review
Page
Page1142
140 of
of1299
2301
Page
Page
Page
Page
Page
Page
1119
1of
1of
1
ofof
51
51
of
51
51
69
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
17, 2016
15,
16,
2015
January January
Sunday
22, 201722, 2017
Page
Page1143
141 of
of1299
2301

scaterbone@live.com
https://www.scribd.com/stan5j.5caterbone
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
(717)669-2163
PRESS RELEASE
Saturday, July 4, 2015
Lancaster, Pennsylvania, Advanced Media Group and Stan J. Caterbone Proposed ORGANIZED
STALKING AND DIRECTED ENERGY WEAPONS HARASSMENT BILL to Pennsylvania House of
Representative Mike Sturla (Lancaster, Pennsylvania) and City of Lancaster Mayor Richard Gray.
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.
Stan J. Caterbone has been a victim of organized stalking since 1987 and a victim of electronic and
direct energy weapons since 2005. He has also been telepathic since 2005. Stan J. Caterbone will
help introduce measures that also pertain to remote viewing; mental telepathy and synthetic
telepathy in more detail. Personal accounts of his pain and torture are also filed in various United
States federal and state courts.
We are urging you to contact your local representatives and support our efforts to pass this
legislation. Below you will find the listings of Pennsylvania State Representatives.
For More Information Please Contact Us At: scaterbone@live.com and visit our library of
documents at https://www.scribd.com/stan5j.5caterbone
_________________________________________________
The draft of the legislation can be found on the following page:
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review
Page
Page
Page
Page
Page
Page
Page
2220
1of
2
2of
2
ofof
151
51
of
50
51
51
69
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review
Page
Page1144
142 of
of1299
2301
Page
Page
Page
Page
Page
Page
3321
2of
3
3of
3
ofof
51
51
of
50
51
51
69
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Page
Page1145
143 of
of1299
2301
Capitol Office
State Capitol
Jefferson City Mo.
573-751-0246
District Office
Second Street
King City Mo.
660-535-6664
May 21, 2009

To Whom It May Concern,
This letter is to ask for your help for the many constituents in our country who are being affected unjustly
by electronic weapons torture and covert harassment groups. Serious privacy rights violation and physical
injuries have been caused by the activities of these groups and their use of so-called non-lethal weapons on
men, women, and even children.
I am asking you to play a role in helping these victims and also stopping the massive movement in the use
of Veri-chip and RFID technologies in tracking Americans.
Long before Veri-chip was known we were testing these devices on Americans, many without their
knowledge or consent.
There are new revelations of the cancer risk besides the privacy and human rights problems with the use of
Veri-chip and RF signals.
I am asking for your help in stopping these abuses and aiding those already affected.
Sincerely,
Rep. Jim Guest
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review
Page
Page
Page
Page
Page
Page
4422
3of
4
4of
4
ofof
51
51
of
50
51
51
69
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Page
Page1146
144 of
of1299
2301
Organized Stalking and Directed Energy Devices and Weapons Bill
Section 1. Short Title This bill may be cited as the Organized Stalking and Directed Energy Devices and Weapons
Bill
Section 2. Findings and Purpose
A) Findings
1) The constitution guarantees the right of the people to be secure in their person. The Declaration
of Independence asserts as self-evident that all men have certain inalienable rights and that among
these are life, liberty, and the pursuit of happiness.
2) As Supreme Court Justice Louis Brandeis wrote in 1928, the framers of the Constitution sought
"to protect Americans in their beliefs, their thoughts, their emotions, and their sensations." It is for
this reason that they established, as against the government, the right to be let alone as "the most
comprehensive of rights and the right most valued by civilized men.
3) The first principle of the Nuremberg Code states that with respect to human research, the
voluntary consent of the human subject is absolutely essential. The Nuremberg Code further
asserts that such consent must be competent, informed, and comprehending.
4)There are current regulations implementing the obligations of the United States to adhere to
Article 3 of the United Nations Convention Against Torture and other Forms of Cruel, Inhumane or
Degrading Treatment including all terms that are Subject to any reservations, understandings,
declarations, and provisions contained in the United States Senate resolution of ratification of the
Convention.
B) Purpose
To establish regulations and penalties for those who use any type of electronic frequency devices,
directed energy devices, implants, surveillance technology, and directed energy weapon to
purposefully cause any of the following: stalking, harassing, mental or physical harm, injury,
harmful surveillance, torture, diseases, and death to any United States citizen.
Section 3. Organized Stalking
If two or more persons willfully, maliciously, and repeatedly follow or willfully and maliciously
harass another person and who make a credible threat with the intent to place that person in
reasonable fear for his or her safety, or the safety of his or her immediate family, they are guilty of
the crime of organized stalking, punishable by imprisonment in a county jail for not more than one
year, or by not more than one thousand dollars ($ 1,000), or by both that fine and imprisonment,
or by imprisonment in a federal prison.
If two or more persons violate subdivision (a) when there is a temporary restraining order,
injunction, or any other court order in effect prohibiting the behavior described in subdivision (a)
against the same party, they shall be punished by imprisonment in the state prison for two, three,
or four years.
For the purposes of this section, "harass" means engages in a knowing and willful course of
conduct directed at a specific person that seriously alarms, annoys, torments, or terrorizes the
person, or damages his personal property or possessions and that serves no legitimate purpose. *
**
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review
Page
Page
Page
Page
Page
Page
Page
5523
4of
5
5of
5
ofof
251
51
of
50
51
51
69
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Page
Page1147
145 of
of1299
2301
For the purposes of this section, "course of conduct" means two or more acts occurring over a
period of time, however short, evidencing a continuity of purpose. Constitutionally protected
activity is not included within the meaning of "course of conduct."
For the purposes of this section, "credible threat" means a verbal or written threat, including that
performed through the use of an electronic communication device, or a threat implied by a pattern
of conduct or a combination of verbal, written, or electronically communicated statements and
conduct, made with the intent to place the person that is the target of the threat in reasonable fear
for his or her safety or the safety of his or her family, or personal property or possessions and
made with the apparent ability to carry out the threat so as to cause the person who is the target
of the threat to reasonably fear for his or her safety or the safety of his or her family or personal
property or possessions. It is not necessary to prove that the defendant had the intent to actually
carry out the threat. The present incarceration of a person making the threat shall not be a bar to
prosecution under this section. Constitutionally protected activity is not included within the
meaning of "credible threat."
For purposes of this section, the term "electronic communication device" includes, but is not limited
to, telephones, cellular phones, computers, video recorders, fax machines, pagers or synthetic
telepathy devices.
The sentencing court also shall consider issuing an order restraining the defendant from any
contact with the victim, that may be valid for up to 10 years, as determined by the court. It is the
intent of the Legislature that the length of any restraining order be based upon the seriousness of
the facts before the court, the probability of future violations, and the safety of the victim and his
or her immediate family.
For purposes of this section, "immediate family" means any spouse, parent, child, any person
related by consanguinity or affinity within the second degree, or any other person who regularly
resides in the household, or who, within the prior six months, regularly resided in the household.
Section 4. Punishment for threats
Any person or persons who willfully threatens to commit a crime which will result in death or great
bodily injury to another person, with the specific intent that the statement, made verbally, in
writing, or by means of an electronic communication device, is to be taken as a threat, even if
there is no intent of actually carrying it out, which, on its face and under the circumstances in
which it is made, is so unequivocal, unconditional, immediate, and specific as to convey to the
person threatened, a gravity of purpose and an immediate prospect of execution of the threat, and
thereby causes that person reasonably to be in sustained fear for his or her own safety or for his or
her immediate family's safety, shall be punished by imprisonment in a federal prison not to exceed
one year..
For the purposes of this section, "immediate family" means any spouse, whether by marriage or
not, parent, child, any person related by consanguinity or affinity within the second degree, or any
other person who regularly resides in the household, or who, within the prior six months, regularly
resided in the household.
"Electronic communication device" includes, but is not limited to, telephones, cellular telephones,
computers, video recorders, fax machines, pagers or synthetic telepathy devices
Obscene, threatening or annoying communication
(a) Every person or persons who, with intent to annoy, telephones or makes constant contact by
means of an electronic communication device with another and addresses to or about the other
person any obscene language or addresses to the other person any threat to inflict injury to the
person or any member of his or her family, or any property or personal possessions is guilty of a
misdemeanor. Nothing in this subdivision shall apply to telephone calls or electronic contacts made
in good faith.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review
Page
Page
Page
Page
Page
Page
Page
6624
5of
6
6of
6
ofof
351
51
of
50
51
51
69
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Page
Page1148
146 of
of1299
2301
(b) Every person or persons who makes repeated telephone calls or makes repeated contact by
means of an electronic communication device with intent to annoy another person at his or her
residence, is, whether or not conversation ensues from making the telephone call or electronic
contact, is guilty of a misdemeanor. Nothing in this subdivision shall apply to telephone calls or
electronic contacts made in good faith.
(c)
Every person or persons who makes repeated telephone calls or makes repeated contact by
means of an electronic communication device with the intent to annoy another person at his or her
place of work is guilty of a misdemeanor punishable by a fine of not more than one thousand
dollars ($ 1,000), or by imprisonment in a federal prison for not more than one year, or by both
that fine and imprisonment. Nothing in this subdivision shall apply to telephone calls or electronic
contacts made in good faith. This subdivision applies only if one or both of the following
circumstances exist:
(1) There is a temporary restraining order, an injunction, or any other court order, or any
combination of these court orders, in effect prohibiting the behavior described in this section.
(2) The person or persons makes repeated telephone calls or makes repeated contact by means of
an electronic communication device with the intent to annoy another person at his or her place of
work, totaling more than 10 times in a 24-hour period, whether or not conversation ensues from
making the telephone call or electronic contact, and the repeated telephone calls or electronic
contacts are made to the workplace of an adult or fully emancipated minor who is a spouse, former
spouse, cohabitant, former cohabitant, or person with whom the person has a child or has had a
dating or engagement relationship or is having a dating or engagement relationship.
(d) Any offense committed by use of a telephone may be deemed to have been committed where
the telephone call or calls were made or received. Any offense committed by use of an electronic
communication device or medium, including the Internet, may be deemed to have been committed
when the electronic communication or communications were originally sent or first viewed by the
recipient.
(e) Subdivision (a), (b), or (c) is violated when the person acting with intent to annoy makes a
telephone call requesting a return call and performs the acts prohibited under subdivision (a), (b),
or (c) upon receiving the return call.
(f) If probation is granted, or the execution or imposition of sentence is suspended, for any person
or persons convicted under this section, the court may order as a condition of probation that the
person participate in counseling.
(g) For purposes of this section, the term "electronic communication device" includes, but is not
limited to, telephones, cellular phones, computers, video recorders, fax machines, pagers or
synthetic telepathy devices.
Section 5. Assault and battery with an electronic or directed energy weapon

Any person or persons who in the course of organized stalking and harassment, commits an assault
upon the person of another with an unauthorized directed energy weapon shall be punished by
imprisonment in a federal prison for two, three, or four years or by a fine not exceeding ten
thousand dollars ($10,000).
For the purposes of this section the term directed energy weapon is defined as any device that
directs a source of energy (including molecular or atomic energy, subatomic particle beams,
electromagnetic radiation, plasma, or extremely low frequency (ELF) or ultra low frequency (ULF)
energy radiation) against a person or any other unacknowledged or as yet undeveloped means of
inflicting death or injury; or damaging or destroying, a person (or the biological life, bodily health,
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
Page
7725
6of
7
7of
7
ofof
451
51
of
50
51
51
69
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Page
Page1149
147 of
of1299
2301
mental health, or physical and economic well-being of a person via land-based, sea-based, or
space-based systems using radiation, electromagnetic, psychotronic, sonic, laser, or other energies
directed at individual persons or targeted populations for the purpose of information war, mood
management, or mind control of such persons or populations; or by expelling chemical or biological
agents in the vicinity of a person.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review
Page
Page
Page
Page
Page
Page
Page
8826
7of
8
8of
8
ofof
551
51
of
50
51
51
69
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Page
Page1150
148 of
of1299
2301
Richmond council passes resolution

supporting ban on space-based
weapons
May 20, 2015

FacebookTwitterMore
9 comments
The Richmond City Council passed a resolution Tuesday supporting a ban on space-based
weapons after a lengthy discussion over whether individuals are being psychologically
and physically harmed by exotic government-patented attacks from high in the sky.
Councilmember Jovanka Beckles, a member of the Richmond Progressive Alliance (RPA),
introduced the resolution, saying it begins to address concerns of a Richmond resident
who claims shes been targeted by remote transmission from space-based weaponry.
Others claiming to have suffered physical and psychological attacks traveled from around
the country to speak at Tuesdays council meeting. One speaker claimed to have been
zapped multiple times right before his testimony at council.
The resolution supports the Space Preservation Act and Space Preservation Treaty
permanently banning space-based weapons, even though the legislation first introduced
by Rep. Dennis Kucinich in 2001 has never gained traction in Congress. It appears that
Richmond is the first municipality in the U.S. to take up this lofty issue in more than a
decade. In 2002, the City of Berkeley passed a similar resolution supporting the ban.
Conspiracy theorists believe the resolution is a step toward ensuring secret weaponry
such as chemtrails, which are trails left in the sky by high-flying aircraft that supposedly
emit a chemical or biological agent, can no longer target unwitting citizens. For RPA
members on the council, the resolution is also an anti-war initiative.
RPA members on council, Gayle McLaughlin and Eduardo Martinez, also voted in favor of
the resolution. Vice Mayor Jael Myrick and Councilmember Nat Bates were the final two
yes votes, although Bates claimed he was confused by the discussion.
Im going to support the resolution for the simple reason that we have voted on a lot of
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review
Page
Page
Page
Page
Page
Page
Page
9927
8of
9
9of
9
ofof
851
51
of
50
51
51
69
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Page
Page1151
149 of
of1299
2301
dumb ideas, Bates said.

Mayor Tom Butt voted no, saying he believes the conspiracy theory behind space-based
weapons is above the heads of city leaders and has taken time away from more pressing
city matters such as the budget deficit, potholes, and crime. Butt has complained in the
past about the RPA attempting to hijack council sessions to push a radical agenda
regardless of whether the issues are important to Richmond residents.
The mayor also pointed to a signed 1967 treaty banning the militarization of space.
The other dissenting vote came from Councilmember Vinay Pimple, who pointed out that
supporting a limitation on the ability of the U.S. to defend against attacks from longrange missiles might not be wise.
Pimple disputed what he called knee-jerk reactions from RPA members who depicted
President Ronald Reagans proposed space-based anti-missile program of 1983, known as
the Star Wars initiative, as inherently evil. The Cold War initiative was intended to
defend against USSR missiles during the Cold War and was shelved not for the projects
moral ambiguity but its perceived effectiveness, Pimple said.
The idea behind Star Wars, Pimple said, is you can knock out someones weapons long
before they enter your air space. The U.S. used Patriot missiles to knock out Iraqi Scuds
targeting Israel and Saudi Arabia, he added.
RPA members, however, argued that this issue is not just about war but about the
individuals in the U.S. who believe governments are using futuristic weapons in space for
the purpose of inflicting pain and mind control. Martinez argued that they may very well
be telling the truth. He recalled a science fiction novel he wrote a paper on during college
that predicted truths 20 years in advance.
Its easy for me to see that things which are wrong can happen because we have the
wrong mindset, Martinez said.
Myrick said he supported the resolution because he doesnt support war.
The weaponization of spaceis something I think is extremely immoral and we should
not be as a nation engaging in, Myrick said. Maybe some wars are unavoidable, that
may be true. But whatever we can do to get our country away from that mindset..thats
why I support this resolution.
Amy Lee Anderson, a targeted individual who brought the matter to Beckles attention,
was thankful that the council took up the issue.
No where in the United States, no targeted individual can get this support, Anderson
said. We just needed one person, one city. Because of that, you all our heroes. We are
dying within because the technology is so sophisticated. Its hard for someone who has
no experience to fathom it, its so sophisticated.
Related posts:
1. Richmond councilmember pushes city resolution banning exotic space-based

weapons
2. Dirty bomb drill in Richmond alarms conspiracy theorists, including Alex Jones
Comments
1. Cmon Richmond Standard.your bias is showing!

Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
Page
Page
10
10
10
28
910
10
of
of
of
of
9of
51
51
of
50
51
69
51
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Page
Page1152
150 of
of1299
2301
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
October 10, 2015
Federal Whistleblower
and
Targeted Individual (Victim)
of U.S. Sponsored Mind Control
Executive Summary
Updated on October 10, 2015
I remain,
Stan J. Caterbone
PRIVILEGED AND CONFIDENTIAL: Stan J. Caterbone, Pro Se Litigant, and the Advanced Media
Group are victims of U.S. Sponsored Mind Control and has been engaged in litigation in both
Federal and State courts seeking financial remedies and a resolution of his Civil Liberties and
his Constitutional Rights. In 1987 Stan J. Caterbone, while managing the financial firm the he
founded, Financial Management Group, Ltd., Stan J. Caterbone became a Federal Whistleblower
when, as a shareholder, he claimed fraud and misconduct within the international arms dealer
and local start-up International Signal & Control, Plc., Some 4 years later ISC was indicted and
plead guilty to the 3rd largest fraud in U.S. history, some $1 Billion and selling arms to Irag via
South Africa. In June of 2015 Stan J. Caterbone became the Movant in the U.S. District Court
for the Eastern District of Pennsylvania case No. 5:14-cv-02559-PD for the Habeus Corpus
Petition of Lisa Michelle Lambert. The case is now before the U.S. Third Circuit Court of
Appeals, Case No. 15-3400.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
11
11
10
11
29
11
of
of
of
of
of
51
51
of
50
51
69
51
51
Page
111
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1153
151 of
of1299
2301

&
STAN J. CATERBONE
EXECUTIVE SUMMARY
copyright 2009
Ya know what, I am beginning to analyze this War on Terror and am having difficulty understanding
it all. To me the most effective fundamental fight against Extreme Terrorism is to reduce the motive; or the
Hatred Against America. No one seems to talk about that subject. How do we reduce that Hatred Towards
America and the West?
See, from my perspective, my situation is very disturbing. I mean we have the United States Torturing Me, a
U.S. Citizen for no good or valid reason. I have warned EVERYONE about using my situation to feed this
HATRED towards America.
Low and behold a week or so ago I have had several Muslims sign up as Followers to my
www.scribd.com/amgroup01 online webspace, which I use to post documents. The following being the most
There have also been several Muslim individuals who signed up as followers around the same time, a week
or so ago. They have also signed up as followers on my www.twitter.com/StanCaterbone webspace.
You must understand, I am a VERY Patriotic Person and live a very patriotic life - I believe in the
U.S. Constitution and Our Founding Father's vision for America; I support Our Military and our
Troops; I believe in the Rule of Law; I am a Practicing Catholic, and have been my whole life; I
Believe in the TRUTH; I believe in Right v. Wrong; Good v. Evil; and finally I believe in God. What
do you believe in?
Posted on the Yahoo Fulton Bank Stock Message Board, January 7, 2010
Date Updated:
October 10, 2015
Date Completed:
Date Initiated:
July 28, 2009

July 8, 2009
Stan J. Caterbone
scaterbone@live.com
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
12
12
11
12
30
12
of
of
of
of
of
51
51
of
50
51
69
51
51
Page
212
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1154
152 of
of1299
2301
UDATE OF SEPTEMBER 27, 2015

In 2015 Stan J. Caterbone and Advanced Media Group had to again return to local,
state, and federal courts. Again the obstruction of due process, the local gang stalking, torture,
trespass, thefts, and the like began in earnest.
From the fabricated Petition for Involuntary
Psychiatric Commitment of April 2010 by Detective Clark Bearinger, until January of 2015, Stan J.
Caterbone and Advanced Media Group had been in seclusion and in a state of rehabilitation and
rest due to the forced medication by Fairmount Behavioral Hospital and Dr. Silvia Gratz.
The
psychotropic drugs reduce your motor skills and put you in an extreme state of confusion.
By
the
end
of
the
summer
of
2010
every
social
media
site,
including
the
www.amgglobalentertainmentgroup.com website was taken off-line due to the intimidation and

coercion by Detective Clark Bearinger.
In May Stan J. Caterbone had again endured the Attacks and Torture from the
employees of the Lancaster County Courthouse, and the Lancaster County Government Building.
Then soon after the Residents of Lancaster County engaged in a massive Organized Stalking
Campaign. In addition an extreme Computer Hacking Campaign was initiated and executed in
an effort to again SILENCE Stan J. Caterbone and Advanced Media Group.
And Again, the
Lancaster City Police Department took the lead role. As usual Stan J. Caterbone summoned state
and federal authorities for help and assistance, including direct communications with the White
House, the Federal Bureau of Investigation, the Pennsylvania Attorney General's Office and
Kathleen Kane, The Pennsylvania State Police, the Pennsylvania General Assembly, several U.S.
Congressmen, and of course the Lancaster County District Attorney's Office.
Since August 1,
2015 the Geek Squad had performed diagnostics and repairs six (6) times due to computer
hacking. On at least 2 occasions the entire hard drive had to be wiped clean and restored.
On June 23, 2015 Stan J. Caterbone was named MOVANT in the 2014 Habeus
Corpus Petition by Lisa Michelle Lambert, Case No. 14:02559 in the U.S. District Court
for the Eastern District of Pennsylvania after filing an Amicus on the case. Judge Paul
Diamond was presiding since it's filing in 2014. However, the Petition was not able to
be granted and the case was stalled on jurisdictional law based on new and compelling
evidence, or lack there of.
The Amicus was filed to cure that deficiency with direct
witness corroboration to the Prosecutorial Misconduct and Innocence of Lisa Michelle

Lambert.
In fact a working theory was filed that suggested that the East Lampeter
Police Department engaged in a strategy of Entrapment that lead to the unfortunate

murder in 1991. This, would of course, allow a wrongful death claim to be filed by the
Show family. The case is now before the Third Circuit Court of Appeals, Case No. 153400. There are three (3) questions that the Third Circuit may rule on; whether to free
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
13
13
12
13
31
13
of
of
of
of
of
51
51
of
50
51
69
51
51
Page
313
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1155
153 of
of1299
2301
Lisa Michelle Lambert, or grant her her Habeus Corpus, and whether to grant Summary
Judgment to Stan J. Caterbone in all civil actions in both state and federal courts.
Two weeks later, on July 9, 2015, Detective Clark Bearinger filed another fabricated
Petition for Involuntary Psychiatric Commitment. And again Stan J. Caterbone endured 7 days in
the Fairmount Behavioral Hospital in Philadelphia.
However, this time there was
no
MANDATORY Treatment Program Ordered by the Lancaster County Court of Common Pleas.
So Stan J. Caterbone continued filing in the courts for assistance and resolution. In August, in a
desperate attempt to stop the local torture campaign, another Emergency Injunction was filed in
the Lancaster County Court of Common Pleas. On August 6, 2015 Stan J. Caterbone went so far
as to undertake a Professional Polygraph Test administered by Bonnie Lee of Polygraph Solutions
of West Chester, Pennsylvania. The test ended up being 4 grueling hours of torture and a scam of
$600.00.
On July 9th , 2015 a Private Criminal Complaint was filed against Detective Clark Bearinger,
Officer Williams, Officer Binderup, and 2 unidentified patrolman.
The Complaint contained
allegations of torture and abuse at every moment of contact.
The Lancaster City Police
Department were so desperate for retaliation from the Amicus filing in the Lisa Michelle Lambert
case, that they actually broke the door in of 1250 Fremont Street in order to execute the
fabricated 302 petition. The Complaint was denied by the Lancaster County District Attorney on
August 8th . The Complaint is now under a Petition for Review by the Lancaster County Court of
Common Pleas.
On August 17, 2015 another Emergency Injunction for Relief was filed in the Lancaster
County Court of Common Pleas, Case No. 15-06985. The Injunction was heard by Judge Jeffrey
Wright, who dismissed it as frivolous. An appeal, MD 1561, is pending in the Superior Court of
Pennsylvania.
In addition, by September 26, 2015 Stan J. Caterbone had been granted Electronic Filing
Privileges in the local, state, and federal courts. This should alleviate the fraud and abuses of the
U.S. Postal Service and the computer hackers.
In 2015 Stan J. Caterbone identifies a trend that suggests that the Lancaster County
community-at-large was subject to either community targeting or community hypnosis.
The
community targeting theory is supported by experts Jullianne McKinney, Cheryl Welsh, and Dr.
John Hall. The community hypnosis theory is supported by direct personal relationships with the
Amazing Kreskin, Samuel P. Caterbone and Stan J. Caterbone.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
14
14
13
14
32
14
of
of
of
of
of
51
51
of
50
51
69
51
51
Page
414
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1156
154 of
of1299
2301
In September of 2015 Stan J. Caterbone begins to digitize a library of approximately 45

audio cassette tapes from his father, Samuel P. Caterbone. The tapes range in date from 1971 to
1996. The tapes prove an identical targeting campaign against both Samuel P. Caterbone and
Stan J. Caterbone.
In addition the tapes confirm that Steven P. Caterbone, brother of Stan J.
Caterbone, was most likely a target dating back to the early 1960's. In addition, the death of
Samuel P. Caterbone on July 20, 2001 was confirmed to be that of murder, not natural causes.
In the early 1990's Dr. Phillip Caterbone, brother, had been solicited by the National
Institute of Health, or NIH in Washington, D.C., for a fellowship to research and catalog a study to
find a genetic marker for depression in the CATERBONE family.
Phil interviewed all living
descendants and relatives of my father, Samuel P. Caterbone, Jr., and took blood samples. I am
alleging that this was a deliberate act to continue the cover story of mental illness to distract and
provide plausible deniability for any linkage to U.S. Sponsored Mind Control.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
15
15
14
15
33
15
of
of
of
of
of
51
51
of
50
51
69
51
51
Page
515
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1157
155 of
of1299
2301
HISTORY
In 1987 Stan J. Caterbone went public with allegations of fraud within International Signal
and Control, or ISC as they were commonly referred.
After discussions with ISC and United
Chem Con officials (an ISC/James Guerin straw company), and as a shareholder of record since
1983 of ISC, Stan J. Caterbone had a meeting with an ISC executive on June 23, 1987, which
resulted in a 22 year legal odyssey. The discussions involved a joint venture with his company,
Financial Management Group, Ltd., or FMG, Ltd., but ended in disclosure of his recent public
allegations of fraud. Four years later, ISC founder and chairman James Guerin, and other officials
and companies pleaded guilty to a $1 Billion Dollar Fraud and export violations including the
selling of arms through South Africa to Iraq and Sadaam Hussein.
However, money, power,
influence and public corruption had been used to cover-up the activities and Federal False Claims
Act violations of Stan J. Caterbone for the next eighteen years. There ensued a total blockade of
all United States Courts for all redress and remedy available in accordance with federal, state, and
local laws.
This included recovery of his business interests; intellectual property; real estate;
personal and business real property; his unblemished and impressive reputation; and his most
valuable asset - the ability to produce income. This might be legally referred to as the Right-ToWork under federal statutes.
Notwithstanding, Stan J. Caterbone has never made a bad
investment or developed a business that did not make a profit over the next 22 years.
This
includes two real estate properties that were illegally seized through foreclosure proceedings.
Since 1987 Stan J. Caterbone has been a prisoner and enemy of the state.
ISC was a
Department of Defense (DOD) Contractor and a partner with United States Intelligence Agencies
since it's beginings in the early 1970's. One of it's first contracts was Project X with the National
Security Agency or NSA of Ft. Meade, Maryland.
In summary, the following are facts and part of the public record regarding
SIGNAL & CONTROL OR ISC:
INTERNATIONAL
Once the third (3rd) largest employer in the County of Lancaster, Pennsylvania, with
over 5,000 employees.
James Guerin, founder and CEO was once the largest philanthropist to charitable
organizations in the County of Lancaster, Pennsylvania.
The ISC/Ferranti Scandal was the third (3) largest white-collar fraud within the United
States as of 1992.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
16
16
15
16
34
16
of
of
of
of
of
51
51
of
50
51
69
51
51
Page
616
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1158
156 of
of1299
2301
The following are some of the public officials and politicians associated with ISC:
George H.W. Bush, former U.S. President, and Director of the Central Intelligence
Agency (CIA).
Robert Gates, former Director of the Central Intelligence Agency (CIA) and current
Secretary of Defense.
Bobby Ray Inman, former Board of Directors if ISC, former Director of the NSA, and
currently associated and directly involved with Mind Control Research organizations.
Alexander Haig, former U.S. Secretary of State, and ISC lobbyist and Board of
Directors?
Joseph McDade, former Pennsylvania House of Representative and Chair of the

Appropriations Committee who was later investigated for the United Chem Con
scandal.
Carlos Cardoen/Cardoen Industries, a joint venture partner with ISC and arms
merchant for the cluster bomb who eventually sold to Iraq and other Middle Eastern
Countries under U.S. sanctions.
ISC was credited with the design of the cluster bomb, and has patents filed in the U.S.
Patent Office.
In 1987 ISC completed the merger with the 3rd largest defense contractor of Great
Britain, Ferranti International; who paid $1 billion dollars for ISC and all of it's
subsidiaries.
ABC News/Financial Times aired 3 episodes on ABC Nightline with Ted Koppel
regarding the ISC/CIA defense weapons; technologies; and cluster bombs to Iraq
story and lead into the allegations that then nominee for the Director of CIA Robert
Gates was involved with ISC and the selling of arms to Iraq.
ABC News 20/20 aired a story on the ISC/CIA efforts to sell cluster bombs to Saadam
Hussein and Iraq on February 1, 1991 days after the start of the Persian Gulf War I,
with the initial bombing raid destroying a cluster bomb factory built in Iraq by
Carlos Cardoen.
On July 1st and 2nd of 1987 Stan J. Caterbone solicited the legal counsel of Lancaster
Attorney Joseph Roda for counsel regarding, FMG, Ltd., International Signal &
Control (ISC); Commonwealth Bank, etc., and was billed for his services. Joseph
Roda did absolutely nothing but refute Stan J. Caterbone's claims and would not
believe him.
In Clark v. Guerin (CI-1990-0074 Lancaster County Court of Common Pleas),

Lancaster Attorney Joseph Roda represented William Clark, ISC's in-house legal
counsel, and never mentioned any conflict to Stan J. Caterbone in 1987.
In Clark v. Guerin (CI-1990-0074 Lancaster County Court of Common Pleas), James

Guerin deposited $1.75 million dollars into an escrow account at Fulton Bank,
Lancaster, County.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
17
17
16
17
35
17
of
of
of
of
of
51
51
of
50
51
69
51
51
Page
717
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1159
157 of
of1299
2301

Christopher Underhill of Harman, Underhill & Brubaker, represented James
Guerin. In 2005 Christopher Underhill represented the Manheim Township Police
Department (05-cv-2288 U.S. District Court for the Eastern District of
Pennsylvania) CATERBONE v. Lancaster County Prison, et. al.,.

Philadelphia Attorney Joseph Tate represented James Guerin and ISC, and in 2007
Joseph Tate represented Scooter Libby during his federal prosecution by U.S.
Special Prosecutor Fitzpatrick.
THE MANIFEST OF A COVER-UP

Not only did the allegations of fraud within ISC have to be silenced at a time when merger
negotiations were ongoing with Ferranti, but all of the fraud; extortion; public corruption;
burglaries; civil rights violations; anti-trust and intellectual property right violations; lender
liability torts; false arrests; false imprisonments; as well as other civil and criminal activities had
to be covered up and buried in bureaucratic red tape.
uncovered and discovered to this day.
Information and findings are still being
Contrary to popular belief, up until 1996 a grand jury
investigation into ISC was still ongoing. It is not known whether it has closed or not. All of these
activates constitute a RICO crime due to the pattern and organization of the perpetrators. The
pattern and source of the activities can be traced back to 1987, with subgroups changing over
time, but still engaging in the same practices. The following plan of action was followed in order
to perpetrate the cover-up:
Totally discredit Stan(ley) J. Caterbone and any and all allegations in every way
possible.
Fabricate a history of mental illness.

Fabricate a criminal record.
Attach his character and honesty with rumors and propaganda.
Extort and maintain his net worth to $ zero or load him with debts.
Keep him out of any profession and or occupation when and where possible.
Totally isolate him and disenfranchise him from his friends, colleagues, and family
into a life of solitaire.
Somehow persuade the community of Lancaster County to buy into this plan of
action through money, favors, etc.,
Always keep attorneys and anyone remotely involved with the legal community
away at times when efforts for justice are pursued.
When attempts to enter the U.S. legal system arise, isolate, harass, and extort
any monies and/or possessions of value.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
18
18
17
18
36
18
of
of
of
of
of
51
51
of
50
51
69
51
51
Page
818
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1160
158 of
of1299
2301
Change the history of events and the truth.

THE COURTS AND THE UNITED STATES LEGAL SYSTEM
For 18 years, (from 1987 until 2005) it has always been fairly easy to keep these issues
from court dockets and judges.
During these years Stan J. Caterbone had solicited at least
twenty attorneys, some from large firms with national recognition in their respective fields of
specialties. Attorneys from New York City to Santa Barbara and San Diego California were visited
and consulted as well as a group of ex FBI agents who specialized in white collar crime that are
now globally recognized. However, the money and influence of persons and entities that wanted
these issues silence always prevailed. The issues were so complex and convoluted, and involved
such high profile politicians and U.S. agencies, it was far easier to state that there was no case, or
their were no claims that would result in remedy or redress. Between the Republican Party and
the Department of Defense, the CIA and the NSA, there was not an attorney that could not be
influenced. The obstruction of justice and due process in this case is most likely unprecedented in
nature and in malice.
However in 2005 that all changed when Stan J. Caterbone appeared as a pro se litigant
representing himself, without any counsel, in the United States District Court for the Eastern
District of Pennsylvania in CATERBONE v. The Lancaster County Prison, et. al., or case no. 05-cv2288.
This case is still not settled and has been withdrawn by plaintiff Stan J.
Caterbone in October of 2008 after a successful ruling in the U.S. Third Circuit Court of
Appeals (07-4474) in September of 2008. The case will be continued upon the security
of evidence and the cease and desist of obstruction of justice and due process. On May
16, 2005 at the Federal Courthouse in Philadelphia, Stan J. Caterbone filed the case under seal.
One week later in the United States Bankruptcy Court for Eastern Pennsylvania in Reading,
Pennsylvania, again appearing as pro se, Stan J. Caterbone filed a petition for protection under
the Chapter 11 Bankruptcy Code, in case no. 05-23059.
These acts of entering the United States legal system with these issues triggered yet
another round of attempts to keep these cases from the courts and judges - Organized Stalking
with Directed Energy Devices and Weapons, built on a foundation of mental telepathy or total
Mind Control.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
19
19
18
19
37
19
of
of
of
of
of
51
51
of
50
51
69
51
51
Page
919
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1161
159 of
of1299
2301
REMOTE VIEWING; ORGANIZED STALKING; DIRECTED ENERGY DEVICES AND

WEAPONS.
within ISC. This organized stalking and harassment was enough to drive an ordinary person to
suicide. As far back as the late 1980's Stan J. Caterbone knew that his mind was being read, or
"remotely viewed". This was verified and confirmed when information only known to him, and
never written, spoken, or typed, was repeated by others. In 1998, while soliciting the counsel of
Philadelphia attorney Christina Rainville, (Rainville represented Lisa Michelle Lambert in the Laurie
Show murder case), someone introduced the term remote viewing through an email. That was
the last time it was an issue until 2005. The term was researched, but that was the extent of the
topic.
Remote Viewers may have attempted to connect in a more direct and continuous way
without success.
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 Stan J. Caterbone with mental telepathy. The
main difference opposed to most other victims of this technology is that Stan J. Caterbone is
connected 24/7 with a person who declares that she is Interscope recording artist Sheryl Crow of
Kennett Missouri. Stan J. Caterbone has spent 3 years trying to validate and confirm this person
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.
See attached documents for
more information.
In 2006 or the beginning of 2007 Stan J. Caterbone began his extensive research into
mental telepathy; mind control technologies; remote viewing; and the CIA mind control program
labeled MK ULTRA and it's subprograms.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
20
20
19
20
38
20
20
of
of
of
of
51
51
of
50
51
69
51
51
Page
10
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1162
160 of
of1299
2301
FAMILY HISTORY
If you listen to the propaganda machine and the community of Lancaster County,
Pennsylvania, including professionals, the family history of Stan J. Caterbone goes something like
the following:
Father, Samuel Caterbone, Jr., Schizophrenic who ran out on his family
because of nervous breakdowns while trying to run a small dry cleaning
business.
He traveled the world looking for the Blessed Mother Mary and
Space Aliens. He ended up living in government subsidized housing broke

and with a severe mental illness.
Brother, Samuel A. Caterbone, suffered from the very same illness has his
father, Schizophrenia, who finally killed himself trying to live in California.
Brother, Thomas W. Caterbone, suffered from the very same mental illness as
his brother, Stan J., Bipolar Mood Disorder, who ran a lawn business and
finally committed suicide at an early age.
Stan J. Caterbone, suffered from Bipolar Mood Disorder, or Manic Depression and
had a nervous breakdown in 1987 trying to compete in the financial services
industry. When he has his nervous breakdowns, he always threatens to sue
everyone in court and is deeply paranoid in thinking the whole world is
against him. He always spends all of his money during his fits of mania and
has delusions about his success as a businessman.
The Family History was formulated back in the 1960's when Samuel Caterbone, Jr.,
father of Stan J. Caterbone, became engaged in a black budget mind control program that began
during his service in the United States Navy as a radioman and air gunner.
Samuel Caterbone,
Jr., was most likely a direct product of MK ULTRA or one of it's subprograms. His brother, Samuel
A. Caterbone, was most likely part of the LSD experiments of MK ULTRA. Stan J. Caterbone is
most likely part of a program sponsored by the Department of Defense Agencies, such as DARPA
or the Defense Intelligence Agency (DIA). The facts of Stan J. Caterbone's intimate discussions
with both his father and brother over the years before they died, the totality of documents that
were preserved in their estate, including service records; letters; official court papers; high school
documents; and the like - all will prove that they were in fact part of MK ULTRA or one of it's
subprograms.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
21
21
20
21
39
21
21
of
of
of
of
51
51
of
50
51
69
51
51
Page
11
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1163
161 of
of1299
2301
The following are the facts and the real record of the family history:
Samuel P. Caterbone, Jr., (Father) served in the Navy from 1943 to 1946 and
graduated with honors from Air Gunners School in Jacksonville, Florida. He was an exceptional
student/athlete while attending Lancaster Catholic High School, participating in the band as well
as sports. He was also his senior class secretary/treasurer. After the Navy, he went on to build a
successful dry cleaning business, which he is credited with inventing a filtration system for the
solvents.
He also developed a very good investment in real estate along the Manheim Pike,
owning several properties. By his own writings and from his personal accounts to me, he was
definitely a remote viewer or data miner for some U.S. Agency with telepathic abilities.
His
viewing is documented to have begun back in the early 1970's. He also suffered from organized
stalking, and was considered an enemy and prisoner of the state. Back in the 1960's, he was a
world traveler, this is documented by his passports. Samuel P. Caterbone, Jr., may have been a
covert carrier for someone in intelligence. Samuel P. Caterbone, Jr., had his mental health history
laced with electro shock therapy. Electro Shock Therapy Experiments is another subprogram of
MK ULTRA. In addition, and especially disturbing is his criminal record with the Lancaster City
Police Department and the Lancaster County Court of Common Pleas.
In 1973 Samuel P.
Caterbone, Jr. was convicted of forging a 2 checks from the Caterbone Cleaners, Inc., checking
account.
The one check to Joe the Motorists Store at the Manor Shopping Center was never
entered into evidence, it was for a total of $70.00. The other check was made out to Lancaster
Attorney James Coho for $200.00 with "divorce proceedings" written in the memo. This was his
only criminal record. Samuel P. Caterbone, Jr., was sentenced to one year probation by President
Judge William Johnstone.
However, on August 29, 1973 after nine months, Judge Johnstone
wrote an ORDER releasing him from probation and ordering him to "leave the vicinity of the
County of Lancaster, Pennsylvania". The President Judge of Lancaster County Court of Common
Pleas literally threw my father out of Lancaster County for forging 2 checks from his own
corporation. In 1987 I was arrested for stealing my own files from my own company, Financial
Management Group, Ltd., You can research the life of Candy Jones and Kate O'Brien to learn more
on this topic. Samuel Caterbone, Jr., has left enough writings and documentation to know that his
life fits the model for targeted individuals, complete with economic ruin, isolation, disenfranchised
from family and friends, and of course a fabricated mental illness history. You can view most of
his record online.
On or about May 18, 2001 Samuel P. Caterbone Jr., finally received an
inheritance from his mother's (Mary Caterbone) estate.
The check was for some $70,000.00.
The estate was probated in November of 2000. Some two weeks later, on Memorial Day Weekend
of 2001, he had called me to come to New York City to help care for him.
He was in perfect
health until this time. In a matter of six (6) weeks he had succumbed to lung cancer. As per
Julianne McKinney,
former intelligence officer for the U.S. Army and victim activist of U.S.
Sponsored Mind Control, the weapons are lethal enough to kill and the one thing that I worry
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
22
22
21
22
40
22
22
of
of
of
of
51
51
of
50
51
69
51
51
Page
12
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1164
162 of
of1299
2301
about is that of dying of cancer (paraphrase). There is no doubt now that my father's death was
a murder, not natural.
Samuel A. Caterbone, (Brother) served in the United States Air Force in 1968 to 1970.
In 1991, Stan J. Caterbone accused the United States Government of using his brother, Samuel
A. Caterbone for part of the LSD experiments on mind control, or MK ULTRA. A notarized letter of
October 23, 1991 was sent certified mail to the California Attorney General on the subject matter,
with a return letter from the California Attorney General on January 14, 1992.
By his own
admission before his death, Samuel A. Caterbone disclosed to Stan J. Caterbone of the "bad LSD"
trips while in the Air Force. Since his death of December 25, 1984, Stan J. Caterbone and others
questioned the classification of suicide, and made allegations of foul play that was ultimately
responsible for his death. Finally in a meeting in Santa Barbara, California with the Santa Barbara
Public Guardian's Office, an office admitted that the death was more likely due to foul plan than
suicide.
Samuel A. Caterbone was also an exceptional student and athlete while attending
Lancaster Catholic High School.
After playing varsity football as a sophomore, he had an
unfortunate accident while deer hunting the following November.
While in the woods in
Bellefonte, Pennsylvania, his hunting pants caught fire trying to stay warm.
It left him in the
Lancaster General Hospital for months, going through painful skin grafts and isolation.
hunting accident interrupted his athletic career and scared his legs for life.
The
The Schizophrenia
diagnosis was a combination of LSD flashbacks and organized stalking and harassment.
Thomas P. Caterbone, (Brother) had an unfortunate transaction at Fulton Bank that set
a course of action that resulted in a suicide. Although diagnosed with Bipolar Disease and Manic
Depression -- embezzled and extorted monies were most likely the reason for his suicide in 1996.
Fulton Bank was involved in a fraud that took $72,000 from a real estate settlement closing and
lead to his total financial ruin and collapse in June of 1995. The funds were never recovered and
Fulton Bank is a defendant for a wrongful death claim in the United States District Court for the
Eastern District of Pennsylvania in CATERBONE v. Lancaster County Prison, et. al., 05-cv-2288.
FULTON BANK triggered a severe and lethal death blow to Thomas P. Caterbone, and as of this
day has refused to acknowledge any wrongdoing or remorse. Thomas P. Caterbone was also an
exceptional athlete. Playing for Lancaster Catholic High School, Franklin and Marshall College, the
Harrisburg Patriots, and even the Philadelphia Eagles. Tom also coached football at J.P. McCaskey
and Franklin and Marshall College.
Thomas P. Caterbone had a very successful lawn and
landscaping business before joining forces with John DePatto of United Financial Services and
selling residential mortgages.
John DePatto was the former head of Parent Bank, owned by
James Guerin and ISC. Parent Bank, owned by ISC also foreclosed on 2323 New Danville Pike,
Conestoga, Pennsylvania in 1988, which was owned by Stan J. Caterbone. Thousands of dollars
of equity was extorted in the process, despite still being short sold for a profit to Mr. Keith
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
23
23
22
23
41
23
23
of
of
of
of
51
51
of
50
51
69
51
51
Page
13
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1165
163 of
of1299
2301
Kirchner, an executive of Lancaster Newspapers and former graduate of Lancaster Catholic High
School.
Stan J. Caterbone is a remote viewer (at least one way in), is telepathic, and a
federal whistleblower with an exceptional entrepreneurial record in spite of all of his adversaries
and their assaults. In spite of the U.S. Sponsored mind control and torture, he has endured and
will prevail. Legally, Stan J. Caterbone has been able to preserve his claims, and progress his
legal challenges and claims through both the federal and state court system appearing pro se,
without the aid or expense of additional legal counsel. Some of his claims and briefs will most
likely be landmark decisions in years to come. Stan J. Caterbone was a 2-Sport MVP at Lancaster
Catholic High School, in both football and track. Stan J. Caterbone never received less than a B
grade in his four years of high school and had an 87+ average. Stan J. Caterbone excelled in
computer technologies, taking his first full term course in 1975, while in high school and
continuing into college at Millersville University, graduating with a degree in business
administration in 1980.
Stan J. Caterbone excelled profoundly at building his companies, first
beginning with Financial Management Group, Ltd., then working with Tony Bongiovi of Power
Station Studios and the "Digital Movie"; then building Advanced Media Group, Ltd..
Over the
years, despite the illegal seizures and foreclosures, Stan J. Caterbone has amassed a portfolio of
impressive real estate deals that have always paid off in profits, no matter how or when they
were sold.
The same was true of his businesses.
Financial Management Group, Ltd., was a
$20,000 dollar investment in 1986 and was still sold for approximately $100,000 two years later,
despite the false arrests and the extortion of most of it's real value and equity.
The mental health history and the criminal records were completely fabricated, and a
close review and investigation into the actual court records and hospital records can prove that in
very short fashion.
There are TWO (2) ways to quickly dispute the Mental Health History and
Record:
One - Review the word "Delusional; delusions; etc.,;
every instance of the word
used by mental health professionals, and the false reports by friends and family were associated
with facts, and matters of the official record, the complete opposite of the meaning of the word
"delusional". And they still exist to this very day.
Two - Review the 3 Fabricated Suicide Allegations of the following dates: August
10(?), 1987 at Burdette Tomlin Hospital (Cape May County New Jersey); February 18th(?), 2005
by Kerry Egan and the Southern Regional Police Department; and July 19, 2009 for the 302
Commitment by the Lancaster City Police Department at Lancaster General Hospital.
The Criminal Record is very similar, since 1987 Stanley J. Caterbone has had 31 false
arrests; formal charges and convictions dismissed prior to court proceedings or won on summary
appeals in the County of Lancaster, Pennsylvania; most of which Stan J. Caterbone appearing as
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
24
24
23
24
42
24
24
of
of
of
of
51
51
of
50
51
69
51
51
Page
14
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1166
164 of
of1299
2301
pro se (representing himself). These have resulted in civil complaints filed in 2008 in CATERBONE
v. The County of Lancaster, Pennsylvania in U.S. District Court for the Eastern District of
Pennsylvania.
THE PUBLIC RECORD

The Public Record is comprised of court filings and exhibits in U.S. Federal Courts;
Pennsylvania State Courts; and the Lancaster County Court of Common Pleas. In all some 40,000
pages of documents are now filed and electronically scanned or microfilmed in prothonotary
offices. In addition in both the U.S. Federal Courts and the Lancaster County Court of Common
Pleas there are more than 11 hours of audio recordings; some 3,000 scanned images; and
several video broadcasts of the ISC News broadcasts all stored on a CD-ROM and filed as an
exhibit to some of the law suits filed by Stan J. Caterbone and Advanced Media Group, as
plaintiffs. Stan J. Caterbone has over 100 court docket sheet numbers in federal, state, and local
courts.
There are also Pennsylvania Unemployment Compensation records; Department of Welfare

and Lancaster County Assistance Office records; Local Real Estate Tax records; Lancaster County
Tax Assessment records; Social Security Administration Benefits records; Lancaster Catholic High
School transcripts; Millersville University transcripts; all for Stan J. Caterbone, in addition to his
court filings.
For Samuel A. Caterbone, my brother, there are United States Air Force service
records; Lancaster Catholic High School transcripts; Millersville University transcripts; Social
Security Administration records; Santa Barbara County Guardian and Public Defender records;
and papers and documents persevered from his estate.
For Samuel P. Caterbone, my father, there are United States Naval records, Lancaster
Catholic High School transcripts; Social Security Administration records; Lancaster County
Assistance Office records; Local Real Estate Tax records; Lancaster County Tax Assessment
records; Samuel Caterbone Cleaners, Inc., corporate records; Real Estate Deeds and Mortgages;
Lancaster County Court of Common Pleas civil and criminal records; and of course papers and
documents persevered from his estate
PUBLIC WEBSITE ADDRESSES OF INTEREST:

www.freedomffchs.com
https://www.scribd.com
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
25
25
24
25
43
25
25
of
of
of
of
51
51
of
50
51
69
51
51
Page
15
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1167
165 of
of1299
2301
DOCUMENTS ATTACHED FOR REVIEW

** It is important to note that as of this writing, Remote Viewing has recently
been commercialized by corporate America, and certain Fortune 500 companies are
using Remote Viewers as consultants for trend analysis and market forecasts. This is
often the evolution of most technologies born out of the U.S. Department of Defense.
Top Secret experiments and the resulting technological advancements can stay
secretive for so long.
This has recently been used in a NBC story of the Television
drama "Medium" this last season.
On July 9, 2008 I had recorded an AM radio live
broadcast on WHAN Coast to Coast with a guest that was one of the leading Physicist
turned Remote Viewer and expert that testified to this same notion.
Dated: July 28, 2009

Stan J. Caterbone
scaterbone@live.com
The following are no longer in service:
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
26
26
25
26
44
26
26
of
of
of
of
51
51
of
50
51
69
51
51
Page
16
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1168
166 of
of1299
2301
September 7, 2009
Stan J. Caterbone
Advance Media Group
1250 Fremont Street
Derrick Robinson
P.O. Box 9022
Phone 1-800-571-5618
Fax 1-866-433-4170
email: info@freedomfchs.com
Re: Is County of Lancaster, Pennsylvania Ground Zero for Organized Stalking and
Covert Surveillance?
Derrick,
My pleasure. Derrick, I was trying to get group rates at our new Lancaster Convention Center
Marriot Hotel last week, just as a little fact finding mission. I have a theory that I would like to
send your way. I thought it would be very fruitful to bring some TI's together for a conference,
unless you think the exposure would be harmful.
I believe that they try new models for harassment; organized stalking and surveillance on me
here in Lancaster. Remember, Lancaster is now one of the most "Watched Communities" in the
country. "With those cameras, the Safety Coalition will operate and monitor 165 cameras across
Lancaster City making Lancaster the most watched city of its size in the nation." See article
attached, Watching you: City to add 105 more cameras.
I believe that Lancaster may be ground zero for some of the models of organized stalking and
harassment that we TI's experience and wanted to get some reaction from Lancaster. Some
history on the Lancaster Convention Center. Dale High of High Industries is the lead partner in our
new convention center/hotel. It is first class all the way. Now in the late 1980's I was a joint
venture partner with Dale High in American Helix Technology Company/Advanced Media Group.
American Helix was a cd manufacturer and I and my company Advanced Media Group was the
CD-ROM division of American Helix. I was one of a handful of CD-ROM manufacturers in the
domestic United States back then. Also in 2005 I filed a civil action against the lead hotel, the
Eden Resort Inn, for trying to block the development and building of the Hotel/Convention Center,
see
attached.
Now, some history about Lancaster and the intelligence community. Back in the 1980's there were
several defense contractors located in Lancaster, the main being International Signal & Control,
which I, of course, blew the whistle on a billion dollar fraud and arms to Iraq.
Click here for an overview of ISC.
Click here to see the Lancaster Newspapers Archives regarding International Signal & Control, or
ISC.
Click here to view the live video of the WGAL-TV News Broadcast of October 31, 1991 the evening
of the ISC indictments. The U.S. Department of Justice and other U.S. Agencies held a Press
Conference in the Philadelphia Federal Courthouse to announce the indictments and $ Billion
Dollar Fraud.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
27
27
26
27
45
27
27
of
of
of
of
51
51
of
50
51
69
51
51
Page
17
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1169
167 of
of1299
2301
Click here for Part 2 of the WGAL-TV 8 Broadcast.

Now politically, Lancaster is and has always been predominately Republican. Lancaster is one of
the oldest cities in the country and our courthouse was one of the first in this country. Lancaster
has one of the oldest fraternities of the Masons. Lancaster and the George W.Bush administration
has a close and very "interesting relationship". George H. Bush had a very close relationship with
ISC, and of course the NSA and CIA all had a very "close" relationship with International Signal &
Control, or ISC. The following are some transcripts for Ted Koppel and ABC News Nightline
regarding ISC and Arms to Iraq and the intelligence community. The transcripts are contained in
my Amicus for Case No. 2006-cv-2160 filed in the Eastern District of Michigan, Southern Division.
Now, Robert Gates, presently the Secretary of the United States Defense Department, and his
relationship to Lancaster. First of all, the attached video is the authentic transcript of Robert
Gates' confirmation hearing in September of 1991 for the Director of the Central Intelligence
Agency (CIA). If you fast forward to approximately 9:00:00 you will see the back and forth
questions from Senator Murkowski to Robert Gates regarding the allegations by several members
of the U.S. Senate Select Committee on Intelligence regarding his alleged involvement with ISC
and the Arms deals with Carlos Cardoen and the shipping of cluster bombs through South Africa
and on to Iraq. Of course, he denied all of the allegations.
Robert Gates also has relatives that live in Lancaster County, if fact he attended a wedding here a
few months ago, on May 3, 2009 at St. John Neuman Catholic Church in Manhiem Township,
Lancaster County. His wife has a niece that lives in Manheim Township.
Now, I'll give you the ABC News Nightline May 23, 1991 excerpt regarding ISC and the NSA,
National Security Agency:
"It all started legally, if covertly, back in 1974. That's when the National Security Agency, a supersecret U.S. Intelligence unit asked ISC to help complete project X, a chain of electronic listening
posts based at South Africa's Simonstown Naval Station. South Africa was using these posts to
follow Soviet submarine traffic off of the Cape of Good Hope. To ensure secrecy, ISC and the NSA
made sure shipments could not be tracked back to them. They created a company called Gamma
Systems Associates. In fact, this company was nothing more than a post office box at John F.
Kennedy Airport. Gamma was a cut-out. ... But this sanctioned covert operation was stopped in
1977 when President Carter, a strong opponent of South Africa's apartheid regime, told U.S. firms
to stop any military-related business with Pretoria. But ISC continue shipping electronics, some
civilian, some military, to South Africa. The in the early 1980's, South Africa began to intensify its
efforts at ballistic missile development. For ISC, that was a golden opportunity because on of its
top executives was a man named Clyde Ivey, an American electronics expert who has been the
father of South Africa's missile program. Ivey had extraordinary contacts in the nations defense
structure. Begining in 1984, federal investigators say, senior ISC exeutives, including Ivey, began
regular contacts with CIA officials." You can read the rest. The entire transcript of the May 23,
1991 ABC News/Nightline broadcast.
Now remember, George H. Bush was director of CIA. "He served in this role for 357 days, from
January 30, 1976 to January 20, 1977.[22] The CIA had been rocked by a series of revelations,
including those based on investigations by Senator Frank Church's Committee regarding illegal
and unauthorized activities by the CIA, and Bush was credited with helping to restore the
agency's morale.[23] In his capacity as DCI, Bush gave national security briefings to Jimmy
Carter both as a Presidential candidate and as President-elect, and discussed the possibility of
remaining in that position in a Carter administration[24] but it was not to be," according to
Wikipedia.
Now, lets get to Bobby Ray Inman, former Navy, Director of the National Security Agency (NSA),
former Director of International Signal & Control (ISC), and currently part of the Mind Control
industry. The following appears on the Welcome page of my website:
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
28
28
27
28
46
28
28
of
of
of
of
51
51
of
50
51
69
51
51
Page
18
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1170
168 of
of1299
2301
"S.A.I.C. involvement in 1993 American Para psychological Association meeting arrangements, via
their 'Cognitive Sciences Laboratory'. Science Applications International Corporation is a big time
defense contractor, has held the largest number of research contracts of any defense contractor.
Bobby Ray Inman (ISC Board of Directors) is on its board of directors, among others."
by John Porter, CIA Program on Mind Control copyright 1996. In 1994, after Bobby Ray Inman
requested to be withdrawn from consideration as Bill Clinton's first Defense Secretary, his critics
speculated that the decision was motivated by a desire to conceal his links to ISC. Inman was a
member of the so-called "shadow board" of the company which was allegedly either negligent or
approved the exports." by Wikipedia on International Signal and Control, (ISC).
Now, lets list the former Navy personnel:
George H. Bush, former President of the United States, former Director of CIA.
James Guerin, President and Founder of International Signal & Control.
Bobby Ray Inman, former Director of the National Security Agency (NSA) and Director of
International Signal & Control, (ISC).
My father, Samuel P. Cateronne, Jr.
His father, Samuel J. Caterbone, Sr.
George Noory, of Coast to Coast Radio (just anecdotal, nothing assumed or alleged).
George W. Bush flew with the Navy.
James Cross
I will Finish later and add more.
Next we get to Jim Guerin's attorney back in 1989 through at least 1992. His name was Joseph
Tate, of Philadelpha. This link will take you to a document regarding Joseph Tate, James Guerin
and Joseph Roda, Esq., of Lancaster, my former attorney who said I fabricated everything back in
1987. The document contains a letter of September 12, 2005 from Special Prosecutor Patrick
Fitzgerald regarding Scooter Libby, Former Vice President Dick Cheney's Chief of Staff. the letter
involves Scooter Libby's Grand Jury Indictment for leaking Covert CIA Operative Valerie Plame
and eventually outing her.
Now in Austin Texas in July of 2005 I was detained by 2 Agents from The Defense Intelligence
Agency. I was merely visiting a Military Museum, that had old and vintage helicopters and
airplanes. near where my brother, Dr. Phillip Caterbone lived. I was visiting on my way to
California. While inside the museum 2 Agents from the Department of Defense Defense
Intelligence Agency escorted me outside to my Honda Oddesey and interrogated me making me
confirm that I was visiting and staying with my brother. They caused a problem for my brother's
Medical Practice by shaking up one of his secretaries. The reviewed my court documents for
CATERBONE v. Lancaster County Prison, et. al., Case No. 2005-cv-0288 filed in the U.S. District
Court for the Eastern District of Pennsylvania. The demanded that I stay off all military bases
before releasing me.
In 2006 I was telepathic with an older NSA executive on many occasions who wanted to meet me
at the Clipper Stadium who told me he wanted to rent a facility in Lancaster for a training
exercise. I told him to to and see Dale High and the High Group for space at the Greenfield
Industrial Park. He said he was retiring and that our discussions were keeping him a few weeks
longer than expected. We had intimate discussions of my history and the Chesapeake Bay Area.
We also discussed Sheryl Crow, and he told me his wife was a fan. I turned him on to her new
album, Wildflower, and he said she liked it. We had to disengage because he was being harassed
by other telepathic assailants.
My former secretary (Susan Bare) at Pflumm Contractors, Inc., where I was controller and was
hired to rescue the company from near bankruptcy in 1993, told me that her husband, Ross Bare,
who grew up just some 10 or so doors from me, worked for the NSA. She disclosed this soon
after I hired her in 1994 or 1995.
I will finish later and add to this allegation. This is a work-in-progress.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
29
29
28
29
47
29
29
of
of
of
of
51
51
of
50
51
69
51
51
Page
19
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1171
169 of
of1299
2301
Stan J. Caterbone
scaterbone@live.com
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
30
30
29
30
48
30
30
of
of
of
of
51
51
of
50
51
69
51
51
Page
20
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1172
170 of
of1299
2301
AFFIDAVIT
BE IT ACKNOWLEDGED, that Stanley J. Caterbone, Financial Management Group, Ltd.,
FMG Advisory, and and all affiliates, Pro Financial Group, Ltd., Advanced Media Group, Advanced
Media Group, Ltd., Global Entertainment Group, Ltd., Power Productions I, Radio Science
Laboratories, Ltd., of Lancaster County, Pennsylvania, the undersigned deponent, being of legal
age, does hereby depose and say under oath as follows:
I am now convinced that the situation surrounding my litigation and all factors attributed
to my financial and professional demise bore out of the fact that my Father, Samuel P. Caterbone
was a victim of U.S. Sponsored Mind Control, in the truest sense of the words.
The
whistleblowing activities of 1987 either were a coincidence or I was set up in the very beginning
by Pennsylvania State Senator Gibson Armstrong (former stock broker) in 1983 when he solicited
me to purchase the ISC stock. The preceding would have been the perfect cover story for my
demise; that I was involved in a fraud. Following this analysis would lead one to conclude that
the collateral damage from the activities of my financial ruin always left my fellow businesses in
financial ruin, for example Robert Kauffman and Michael Hartlett, partners, and the shareholders
and affiliated professionals of Financial Management Group, Ltd., Tony Bongiovi and Power Station
Studios, Jim and Lynn Cross as Cross Microwave Consultants, Dave Dering, Scott Robertson, and
James Boyer as American Helix/High Industries, Ralph Mazzochi and Gallo Rosa Restaurant;
Pflumm Contractors, Inc., Mike Caterbone's AIM Wholesaler's Business, Dr. Phillip Caterbone, D.O.
And associated Primary Care Practices of Austin, Texas, Sam Lombardo and Ralph Mazzochi as
S.N. Lombardo Associates for Lancaster Avenue Project, Sheryl Crow Singer Songwriter, my
immediate family, friends, and relatives.
Following this analysis would lead one to concur that the legal and financial remedies
would only be reconciled by the above named parties enjoining my civil litigation. This AFFIDAVIT
is to be considered a legal and binding document to accomplish that remedy.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
31
31
21
30
31
49
31
31
of
of
of
of
of
51
51
of
41
50
51
69
51
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Saturday,
Friday,
Tuesday,
March
March
December
15,
October
March
2016
15,
3/15/2016
2016
10,
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Page
Page1173
171 of
of1299
2301
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
32
32
31
32
50
32
32
of
of
of
of
of
51
51
of
50
51
69
51
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Page
Page1174
172 of
of1299
2301
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
33
33
32
33
51
33
33
of
of
of
of
of
51
51
of
50
51
69
51
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Page
Page1175
173 of
of1299
2301
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
34
34
33
34
52
34
34
of
of
of
of
of
51
51
of
50
51
69
51
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2016
January January
Sunday
22, 201722, 2017
Page
Page1176
174 of
of1299
2301
scaterbone@live.com
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603

December 6, 2015
Work-In-Progress

Snyder, LLC, No Formal Notice, allowed to reenter in 2015.
Police in 2006, No Formal Notice, allowed to reenter in 2015.
Geesey, in 2008, No Formal Notice, allowed to enter in 2015.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
35
35
35
53
35
35
of
of
of
of
of
51
51
of
51
69
51
51
Tuesday,
Thursday,
Tuesday,
Wednesday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
17, 2016
15,
16,
2015
January January
Sunday
22, 201722, 2017
Page
Page1177
175 of
of1299
2301

Formal Notice
Officer.
19.Lancaster General Hospital, Gary S. Gehman, MD, May 25, 2010, for recording Dr. Brian
Sullivan of Abbeyville Family Health re U.S. Sponsored Mind Control and posting on my
Wordpress Blog.
20.Tobias Frog Restaurant and Bar, August 8, 2015 by Owner of Establishment, reason
was for complaining of harassment and stalking.
21. Millersville University, July 9, 2015, served notice by Millersville University Police
Chief Pete Anders, for negotiating a civil rights complaint with Assistant to the President,
Debra Hoeckler
22.Village Nightclub, July of 20015, by George..........., Owner, tried to enter several times,
with no reason and no written notice.
23.Lucky Dog Bar, August of 2015, met Abby and Keagan Pflumm outside, went inside and
was told by bartender to leave and not come back.
24.Barley Snyder, LLC Lancaster Office, receptionist Ms. Woods refused to let me
communicate with Attorney George Werner, who in 2011 entered appearance in 05-2288
for Fulton Bank in U.S. District Court.
25.Wennerstrom Property Management Company, June 2015, went to complain
regarding harassment, threats, etc., at 1252 Fremont Street and told to leave building.
26.Pennsylvania Liquor Control Board, Northwest Office Building, November 23, 2015,
Harrisburg, PA, Delivered COMPLAINT re Bars and Restaurants in Lancaster engaged in
Discrimination, Stalking, Harassment, Assaults, etc., Would not allow access to Legal
Counsel, and female who took complaint would not provide ID.
27.Southeast Medical Facilities and Brightside Church Office, February 2016, Would not
issue pain medication and filed a Private Criminal Complaint with the Lancaster County
District Attorney, no opinion as of yet.
28.U.S. Federal Facilities per the National Security Agency Interrogation of March 9, 2016
at the NSA Headquarters in Ft. Meade, Maryland. Handcuffed and Interrogated for over an
hour and finally let go and told not to continue on to Washington, D.C. And said I was no
longer permitted to visit any U.S. Federal Facilities.
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Media
Caterbone
Circuit
Group
Executive
Executive
Executive
Executive
Summary
- Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
36
36
36
5436
of
of
of
of51
51
of
51
6951
Tuesday,
Tuesday,
Wednesday,
Tuesday,
March
March
15,
March
2016
15,
3/15/2016
2016
15, 2016
16,
January January
Sunday
22, 201722, 2017
Page
Page1178
176 of
of1299
2301
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
37
37
36
37
55
37
37
of
of
of
of
51
51
of
50
51
69
51
51
Page
27
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1179
177 of
of1299
2301
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
38
38
37
38
56
38
38
of
of
of
of
51
51
of
50
51
69
51
51
Page
28
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1180
178 of
of1299
2301
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
39
39
38
39
57
39
39
of
of
of
of
51
51
of
50
51
69
51
51
Page
29
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
! "
Page
Page1181
179 of
of1299
2301
"
$% &
!
" #
%
"&#
(
'
!
(
,
"
"
")
"
""
-
)
!
! "
!
'
%
" !
"
!
)
+
!
" *
"
"
,
,
,
*
%
*
(
%
!
/"0
1
1 ,
"
"
4
!
"
"
!
!
#
.
.
&,,0
%
1 ,
2"3
!
)
** ! "
&,,..$/
&,,
%
&,,
%
&
, "
"
00
"
!,
"
6
7
7 , !
&,,-
8,
:
(
$;$
"2
! " ,
, ,
** !
;
5
$
!
&,,@
,
.
&<;=
>
1
9
,
&,,=
$
,
>
A
1 B3
.+
&,,=
1 B3
2
>
%
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
40
40
39
40
58
40
40
of
of
of
of
51
51
of
50
51
69
51
51
Page
30
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
<
Page
Page1182
180 of
of1299
2301
1
1
* "
!
"
C#
"$
"
<
*
&, ,
24
#9
; "
&,,@(&,,= A
3
24
5
!
%
&,,0 4
! %3
"
"
!
&,,
%
!
4
'
5
4
D
%
%
"
""
,! "
0 =
0 =9
9
00&9 00
:
9
&,,-
&, , $
!
%
!
D
%
%
=
F
!
))
+
/4
),
"
0 =
/
$
G
3
%
00
3
3
"
%#
$
$
&, ,
&,,4
!- "
.
&,,@
,
*
&,,<
E
&,,
-) !
/ 4
24
/
$
D
&, ,
D
$
&,,-
&,,0
%
D
!
D
D %
7F !
>
!
D
$
A
8F
$
%
;
D
.
%
&,,3
E
$
*
00=; 00
$
5
! 7
0 =
00
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
41
41
40
41
59
41
41
of
of
of
of
51
51
of
50
51
69
51
51
Page
31
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
)
A
Page
Page1183
181 of
of1299
2301
24
$;$
00
(F
&
%
B
5
00 9
" * <
00=( 00 9
:#
> ) "" ""

$
;3
#, " !
&,,-
"
"
"
0 =
&, ,
/
.
$
B
3
3
=
0 =
) "
.
&,,1
0 =
24
" "
3
"
&,,@
" E
""
B
$
<
&,,1
.
&,,-
,-(&&
2
=
@,
"
&,
3
&,,!
&,,@
&,,@
0 =
@, 1
&,,@
9
!
@,
#" !,
0 =
" "1 ,
"
"*
":
" E
F
&,,-
!
B
/
!
"
00=( 00 9
B
:
9
$
'
.
&,,1
9
0 =
&, ,
/
.
00 9
/
&,,9
&,
( "
!
.
00
$
!
&, ,
F
3
7
8
!
&,,
&, ,
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
42
42
41
42
60
42
42
of
of
of
of
51
51
of
50
51
69
51
51
Page
32
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
&
, * "
&&
*#
Page
Page1184
182 of
of1299
2301
"
&:
;!
&<
:
%
$
&, ,
$
&,,-
!-
,
5
%
"
>
$
$
< !-
24
? "
;
>
&,,0
B
&,,%
(
$
&, ,
&-
A
.+ $
&@
! :
&,,$
: , *
&, ,
* @
&,,@
"
E
3
&,,
"
&,,0
7 "!
7 "
0 =
*
&=
) "
":
)"
&,,@
"
&
&0
!
< ")
+
9 &,,@
:
9
&, ,
&,,
00
:,
!6
"
"
" .
9 &,,0
0 = "&#
, *
&,,@
/
" F
0 =
;A
0 =
F
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
43
43
42
43
61
43
43
of
of
of
of
51
51
of
50
51
69
51
51
Page
33
of
41
0 =
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1185
183 of
of1299
2301
!
3
"
$
+
0 =
I $
$
0 =
"2
'
+$;F
D
"$
&,;&,
3
A
00
'
$ 24
"1E1# $
K
E
A
00&
>
L
F
F
B
F
+
0=,K
A
$
$
1
+
>
1
$
>
B
!
3
F
1
00
) % 3
&,,-
!
>
! A !
00,K
1 B3
>
F
F
& 1
F
8
! 4
'
A
! 4
A
0=,K
F
00,K
0 ,K
0<,K
3
/
>
%
&,,
) %$
0@,K
0@,K
$
2!
A
D 1
"
$
0 <9 F
4
A? D!B
#
*
$
7
+
00
D 18
.
E
$
M 1
00= E
0 =
%
0 ,K
$
0 =
M
00
!
&,,9
(
9
!
1
,-(
$ !2B+EF2
(&&
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
44
44
43
44
62
44
44
of
of
of
of
51
51
of
50
51
69
51
51
Page
34
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1186
184 of
of1299
2301
") !
"
7!
N
.
!
5
F
(
(
5
G
*
A'
, ?
*
? 1
!,
A
(
> "
!, '!
,
B
A
" " * #" !, " "
$C
* #" !, D
73
8
* 7
,
"
"
&
"
#
.
"
#(
5
7
9
'
5
%
7A
8 !
8 !
'
!
7D .2
O
% 8
'
7
'
(
(
%
%
4
K
K
M %
%
K
'
7E
(
8
"
%
'
%(
(
(
4
;
(
7
7
87
(
(
8
8
- 7 > !,
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
45
45
44
45
63
45
45
of
of
of
of
51
51
of
50
51
69
51
51
Page
35
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1187
185 of
of1299
2301
* , "
!
B
B
B
B
B
B
B
B
.
.
&
B
B
B
B
B
@
E
@
E
&. @
DD
@
. DD
"
@
& DD
@
. DD
@
& DD
@
$ DD
@
DD
@
E
DD
@
EB& DD
@
EB DD
@
& B DD
@
DD
@
& DD
@
DD
@
& DD
@
DD
B@
)
B@
DD
!
!
))
1"
)
*
!
")
1
3
1
"
)
)
, "
*"
"
, "
!
*
"
")
"
7
"!
"
*
!
*
")
!
6, "
1
5
)
>
' "
*
, "
1 ,!
, "
)
!
"
"
!
!
1
"": !
1 , 1
"": !
"
1
"": !
!
"
! * !
)
*
"E
DD
")
E DD
%
,
!
!"
, "
"
"
"
1 ,"
DD
*)
PPPPPPP "
>7
%#
'?
Stan J. Caterbone
"
Stan J. Caterbone
"
June 19, 2015

Pennsylvania
$
Lancaster
19
PPPPPPP
15
June
&,PP

F
SJC
I
.
I
&, ,
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
46
46
45
46
64
46
46
of
of
of
of
51
51
of
50
51
69
51
51
Page
36
of
41
Don't Know When
24
$
$
Q &, , "!
I
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1188
186 of
of1299
2301
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
47
47
46
47
65
47
47
of
of
of
of
51
51
of
50
51
69
51
51
Page
37
of
41
Page 35 of 41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
06/10/2007
January January
Sunday
22, 201722, 2017
Page
Page1189
187 of
of1299
2301
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
48
48
47
48
66
48
48
of
of
of
of
51
51
of
50
51
69
51
51
Page
38
of
41
Page 36 of 41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
06/10/2007
January January
Sunday
22, 201722, 2017
Page
Page1190
188 of
of1299
2301
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
49
49
48
49
67
49
49
of
of
of
of
51
51
of
50
51
69
51
51
Page
39
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1191
189 of
of1299
2301
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
50
50
49
50
68
50
50
of
of
of
of
51
51
of
50
51
69
51
51
Page
40
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page
Page1192
190 of
of1299
2301
Advanced
Stan
Office
Stan
J.ofCaterbone
J.
the
Medi
Media
Caterbone
Circuit
Group
Grop
Group
Executive
Executive
Executive
Press
PressSummary
Executive
Release
-Release
Petition
Summary
Summary
For Review Page
Page
Page
Page
Page
Page
51
51
50
51
69
51
51
of
of
of
of
51
51
of
50
51
69
51
51
Page
41
of
41
Tuesday,
Thursday,
Tuesday,
Wednesday,
Friday,
Tuesday,
March
March
December
15,
March
2016
15,
3/15/2016
2016
11,
17, 2015
15,
16,
2015
2016
Saturday,
October
10,
5:15-cv-03984-JCJ
9:51 A.M. January
Sunday
January
22, 2017Case
22, 2017
Document
52
Filed 05/17/16
Page 1 ofLAMBERT
105
Page
Page1193
191 of
of1299
2301
Stan J. Caterbone
CASE FILE
Appeal Docket Sheet
Superior Court of Pennsylvania
Docket Number: 1164 EDA 2016

Page 1 of 3
May 17, 2016
CAPTION
v.
Kathleen Granahan Kane
Appellant
CASE INFORMATION
Initiating Document:
Notice of Appeal
Case Status:
Active
Case Processing Status:
April 21, 2016
Awaiting Original Record
Journal Number:
Case Category:
Criminal
Case Type(s):
Criminal Conspiracy
Other
Perjury
CONSOLIDATED CASES
RELATED CASES
Docket No / Reason
Type
1166 EDA 2016

Same Issue(s)
Related
SCHEDULED EVENT
Next Event Type: Receive Docketing Statement

Next Event Type: Original Record Received
Next Event Due Date: May 5, 2016

Next Event Due Date: June 20, 2016
COUNSEL INFORMATION
Appellant
Kane, Kathleen Granahan
Pro Se:
No
IFP Status:
No
Attorney:
Minora, Amil Michael
Minora, Minora, Colbassani, Krowiak, Mattioli & Munley
Law Firm:
Address:
700 Vine St.
Scranton, PA 18510
Phone No:
(570) 961-1616
Fax No: (570) 963-1691
Attorney:
Address:
Phone No:
Attorney:
Address:
Shargel, Gerald L.
Winston & Strawn, LLP
200 Park Avenue
New York, NY 10166
(212) 294-2637
Fax No: (212) 294-4700
Kramer, Ross Mitchell

WINSTON & STRAWN LLP
200 Park Avenue
New York, NY 10166
Neither the Appellate Courts nor the Administrative Office of Pennsylvania Courts assumes any liability
for inaccurate or delayed data, errors or omissions on the docket sheets.
5:15-cv-03984-JCJ
9:51 A.M. January
Sunday
January
22, 2017Case
22, 2017
Document
52
Filed 05/17/16
Page 2 ofLAMBERT
105
Page
Page1194
192 of
of1299
2301
Stan J. Caterbone
CASE FILE
Appeal Docket Sheet

Page 2 of 3
May 17, 2016
COUNSEL INFORMATION
Appellant
Pro Se:
No
IFP Status:
No
Attorney:
Farber, Seth C.
Winston & Strawn, L.L.P.
Law Firm:
Address:
200 Park Avenue
New York, NY 10166
Phone No:
(212) 294-6700
Fax No:
Amicus
Caterbone, Stan J.
Pro Se:
Yes
IFP Status:
Pro Se:
Stan J. Caterbone
Address:
1250 Street
Lancaster, PA 17603
Phone No:
(717) 669-2163
Fax No:
Appellee
Pro Se:
No
IFP Status:
Attorney:
Steele, Kevin R.
Address:
Montgomery County District Attorney's Office
PO Box 311
Norristown, PA 19404-0311
Phone No:
(610) 278-3098
Fax No:
Attorney:
Law Firm:
Address:
Phone No:
Falin, Robert Martin

Montgomery County District Attorney's Office
P.O. Box 311
Norristown, PA 19404
(610) 278-3102
Fax No: (610) 278-3841
FEE INFORMATION
Fee Dt
Fee Name
04/21/2016
Notice of Appeal
Fee Amt Receipt Dt

85.50 04/21/2016
Receipt No
Receipt Amt
2016-SPR-E-000686
AGENCY/TRIAL COURT INFORMATION
Court Below:
County:
Order Appealed From:
Documents Received:
Order Type:
OTN(s):
Montgomery County Court of Common Pleas

Montgomery
Division:
March 28, 2016
Judicial District:
April 21, 2016
Notice of Appeal Filed:
Order Entered
T6863802
Lower Ct Docket No(s):
CP-46-CR-0006239-2015
Lower Ct Judge(s):
Demchick-Alloy, Wendy
Judge
Montgomery County Criminal Division

38
April 20, 2016
85.50
5:15-cv-03984-JCJ
9:51 A.M. January
Sunday
January
22, 2017Case
22, 2017
Document
52
Filed 05/17/16
Page 3 ofLAMBERT
105
Page
Page1195
193 of
of1299
2301
Stan J. Caterbone
CASE FILE
Appeal Docket Sheet

Page 3 of 3
May 17, 2016
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
April 21, 2016
Notice of Appeal Docketed
April 21, 2016
Participant Type
Filed By
Appellant
Docketing Statement Exited (Criminal)

May 2, 2016
May 5, 2016
Application to Quash Appeal

Appellee
Amicus
Caterbone, Stan J.
Amicus
Caterbone, Stan J.
Other
Document Name: EOA pro se amicus

May 5, 2016
Answer to Application to Quash Appeal
Document Name: pro se answer to quash
5:15-cv-03984-JCJ
January January
Sunday
22, 2017Case
22, 2017
Document
52
Filed 05/17/16
Page 4 ofLAMBERT
105
Page
Page1196
194 of
of1299
2301
Stan J. Caterbone
CASE FILE

Freedom From Covert Harassment and Surveillance, Registered in the State of Pennsylvania
1250 Fremont Street
Lancaster, PA 17603
IN THE SUPERIOR COURT OF PENNSYLVANIA

EASTERN DISTRICT
IN RE:
Case NO. 1164 EDA 2016
Montgomery Court Case No.

Docket No. 8423-15
:
COMMONWEALTH OF PENNSYLVANIA :
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
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. 8423-15
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 affirmance 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.
Superior Court 1164 EDA 2016
Page 1 of 2
Tuesday, May 3, 2016
5:15-cv-03984-JCJ
January January
Sunday
22, 2017Case
22, 2017
Document
52
Filed 05/17/16
Page 5 ofLAMBERT
105
Page
Page1197
195 of
of1299
2301
Stan J. Caterbone
CASE FILE
(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 affirmance 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 affirmance 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.
Date: May 3, 2016
Superior Court 1164 EDA 2016
_____
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
(717) 669-2163
Page 2 of 2
Tuesday, May 3, 2016
5:15-cv-03984-JCJ
January January
Sunday
22, 2017Case
22, 2017
Document
52
Filed 05/17/16
Page 6 ofLAMBERT
105
Page
Page1198
196 of
of1299
2301
Stan J. Caterbone
CASE FILE

Freedom From Covert Harassment and Surveillance, Registered in the State of Pennsylvania
1250 Fremont Street
Lancaster, PA 17603
IN THE SUPERIOR COURT OF PENNSYLVANIA

EASTERN DISTRICT
IN RE:
Case NO. 1164 EDA 2016
Montgomery Court Case No.

Docket No. 8423-15:
COMMONWEALTH OF PENNSYLVANIA :
v.
KATHLEEN KANE
AMICUS CURIAE IN SUPPORT OF KATHLEEN KANE'S (ATTORNEY GENERAL)

MOTION TO QUASH BASED ON SELECTIVE AND VINDICTIVE PROSECUTION
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
Superior Court 1164 Amicus re Kathleen Kane
Page 1 of 48
Thursday, April 28, 2016
5:15-cv-03984-JCJ
January January
Sunday
22, 2017Case
22, 2017
Document
52
Filed 05/17/16
Page 7 ofLAMBERT
105
Page
Page1199
197 of
of1299
2301
Stan J. Caterbone
CASE FILE
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-TheCIA-by-Stan-Caterbone-091125-169.html
In addition the MOVANT wrote to the ATTORNEY GENERAL on November 12, 2015 and
stated the following Back in 1998 I had a meeting with an NSA (National Security
Agency, Ft. Meade, Md) operative in a parking lot of a former car dealer in York, PA. I
had just attended a job fair and he approached me as I was about to get into my car.
He introduced himself as being from the NSA and I questioned him about why they
would not leave me alone. His response was "It is not US (NSA) it's the Good Ole
Boys". I also have a huge problem with modified, stolen, and planted documents. We
parted ways in an amicable fashion.
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 2 of 48
Thursday,
Thursday,April
April 28, 2016
5:15-cv-03984-JCJ
January January
Sunday
22, 2017Case
22, 2017
Document
52
Filed 05/17/16
Page 8 ofLAMBERT
105
Page
Page1200
198 of
of1299
2301
Stan J. Caterbone
CASE FILE
The ATTORNEY GENERAL returned a letter the following day that stated Dear Mr.
Caterbone, Thank You for your correspondence to the Office of Attorney General, we
will keep your information in our files. These are attached as EXHIBITS.
Date: April 28, 2016
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
/S/
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
(717) 669-2163
Page 3 of 48
Thursday,
Thursday,April
April 28, 2016
5:15-cv-03984-JCJ
January January
Sunday
22, 2017Case
22, 2017
Document
52
Filed 05/17/16
Page 9 ofLAMBERT
105
Page
Page1201
199 of
of1299
2301
Stan J. Caterbone
CASE FILE
___________________________________________________
HAD LANCASTER COUNTY (Pennsylvania) LOST IT'S SOVEREIGNTY BEFORE IT LOST
IT'S SOUL?1
"Each time a man stands up for an ideal, or acts to improve the lot of others, or
strikes out against injustice, he sends forth a tiny ripple of hope. And crossing each
other from a million different centers of energy and daring, those ripples build a
current which can sweep down the mightiest walls of oppression.".
by Robert F Kennedy
In 1987 This Plaintiff (Stan J. Caterbone) Had Unjustly Lost His Freedoms, His Rights, And His
The following report (most identities purposely omitted from this version) is an amazingly true
and factual account of an extraordinarily bizarre tragedy that has turned one man's life into an
eleven (11)2 year free fall into "Dante's Hell".
On the surface, this is a story of a victim (Stan J. Caterbone) struggling to seek the truth, but
in reality, the evidence will conclude that this is a victim, literally, held hostage by virtue of his
truth. Later, the preponderance of evidence that Stan Caterbone has amassed and his
obsession for meticulously documenting his ordeal might seem eccentric, yet his demonstrated
ability to react to events before they unfold appears mystical. And this was his manner in which
he tactfully defended and protected his life. It is these actions that have painted the landscape
with a dire vengeance for his ruin. His actions will ultimately serve to protect, preserve, and
foster the truth of his story, incriminating the culpability of his many perpetrators, while at the
same time being twisted and tainted in a relentless manner to attack his credibility.
This is a story of a human being endearing for his rights, living in fear of his life, and the
remedial actions required for the truth to set him free. A victim (Stan J. Caterbone) forever
believing in his accomplishments and his visions, yet forced to adhere to a life of their
diversions. Fatefully, ten years after being taken as a "political hostage", with the aid of
numerous arrests and false imprisonment's conveniently falling short convictions, a Federal
Judge, Judge Stuart Dalzall, of the Eastern District Court of Pennsylvania, opened a "Pandora's
Box" into the true colors of the inner workings and politics of ultra conservative Lancaster
County, Pennsylvania, a supposedly "God's" country. His findings reeled a dramatic and
emotional response from the Lancaster County community that was akin to the assassination of
1
2
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 4 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 10 of
105
Page
Page1202
200 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
JFK. A community where "obstructions of justice" strikes a startling and stark contrast to the
image it so desperately embraces. A community proud of it's "tough on crime" judges, a
community of "plain folks" and Amish, and a community settled in a beautiful landscape
abundant in an agricultural bounty. This is not a community of compromising integrity. Or so it
has been perceived.
Judge Dalzall's extremely controversial findings were responsible for Pennsylvania's own
crafting of the "Laurie Bill", the retaliation by the Commonwealth of Pennsylvania intended to
curb the Federal Courts interference within the respective state's own jurisdictions and
proceedings. Or was it a political maneuver to close the lid on "Pandora's Box"? The
Pennsylvania Attorney General and the Lancaster County District Attorney have both thrown all
their might and all their muscle at turning the tides of Judge Dalzall's findings. This story and
Stan Caterbone's rights have been violated and abused by some of the very same principals
that were responsible for Judge Dalzall's unsettling revelations. Lancaster County prosecutors
were found to have engaged in one of the grossest acts of prosecutorial misconduct "found in
the English speaking language", which allegedly occurred in this now famous Lisa Michelle
Lambert case, a murder trial which began in the summer of 1992. Subsequently, it is now in
the midst of a treacherous appeal process convened by Judge Dalzall. And if so, by fate, in
Philadelphia, Pennsylvania; the home of the "Freedom Fighters".
It is this public disclosure, that casts a new light and sudden hope for freedom into Stan
Caterbone's unbelievable and horrid story, that begun just four years prior to the murder of
Laurie Show. It is the decisive similarities of how both victims were subjected to a very
calculated and politically motivated attempts to "frame" and "fabricate circumstances" to obtain
the results that justified the means for illicit self-serving interests. This very same conduct,
committed by public servants, elected and enlisted to enforce the law, to which Judge Dalzell
found so appalling. Conduct, which violated the very same rights their respective offices are
commissioned to protect. Conduct, which strikes the meaning of "We The People" from our
nation's very own Constitution.
Fortunately, Stan Caterbone's story is laced with a thread of faith, a faith in God. And because
of his faith, Stan Caterbone will forever regard Lisa Michelle Lambert 3 and Laurie Show as his
little "Angels of Justice", a Godsend. An answer to his many prayers, that for the first time in
ten years provided a small glimmer of hope, and a few moments of solitude that have
materially justified his own tragic experience. The realization that the truth is that much more
believable because of the trials and tribulations of Lisa Michelle Lambert. Unfortunately, this
revelation came at the unfortunate and untimely death of Laurie. However, it just may be God's
intentions of a Higher Purpose.
3
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 5 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 11 of
105
Page
Page1203
201 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
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!
AT ISSUE
The central issue in this story is a cover up, a cover up of mass proportions, and of perplexing
design, with national consequences. The fact of the matter is that this cover up has had
ramifications throughout this world; specifically the Middle East The cover up would be
emphatically unbelievable without the wealth of evidence, especially the recorded conversations
with Pennsylvania officials. A cover up that permeates from what will later emerge as the 4th
largest financial fraud (Billion Dollars) in the history of the United States coupled with the
covert sales of arms to Iraq. And five years after this cover up began, these same munitions
were used against our own troops in the Persian Gulf War. And of course, there are admitted
ties to the Central Intelligence Agency (CIA) and the National Security Agency (NSA).. And this
cover up and story, which began in June of 1987, in Lancaster County, preceded criminal
indictments by the United States Attorney General, the Federal Bureau of Investigation (FBI),
the Internal Revenue Service (IRS), the Department of Justice and Commerce, and more. A
vast array of criminal activities conspired from the ultra conservative Lancaster County, where
God is supposedly supreme, and it's hard line approach to crime is said to be preeminent. In
June of 1987, Lancaster County was immersed in a dynamic twist of fate, with a host of players
which may never be fully identified.
The irony of this story is how Lancaster County manages the disclosure of the very same
criminal activities that this story proves that it condoned, prior to the intervention of federal
authorities. It most dramatically will prove the nature of it's integrity, or lack thereof.
International Signal & Control, (ISC) is the controversial player in this web of conspiracy. In
1987, ISC was the third largest employer in Lancaster County, a non-discrete defense
contractor. In all due respect to our beloved country, this report is in no way challenging the
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 6 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 12 of
105
Page
Page1204
202 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
policies or the activities of the Department of Defense, or the vast agencies of the "Intelligence
Community", especially the CIA or the NSA (National Security Advisory). with regards to ISC's
foreign dealings. Trying to protect the world of malicious and evil empires is a process which
never ends, and whose players are constantly changing. And our respective intelligence
agencies are continually challenged with the task of trying to make a difference, in accordance
with protecting our national security. Unfortunately, given the nature of their discrete activities,
and given the CIA's history of avoiding congressional approval in certain situations, our current
laws are void of effectively dealing with the peripheral catastrophes of such activities that
inherently
transpire.
The
CIA
remains
immune,
while
everyone
outside
suffers
the
consequences.
The fact that the CIA, or anyone of the other intelligence community, may have been involved,
does not grant a blanket of immunity over activities which were not material to protecting our
national security. If a company provides a service to anyone in the intelligence community, our
constitution, our laws, and it's respective commercial regulatory authorities, must still have the
full sense of their jurisdiction. The intelligence community may not have the right of
intervention into the commercial enterprise, or organization, circumventing the rights of its
employees, shareholders, creditors, and customers. No United States law or statute suggests
that there is any involuntary mandate that requires any of the preceding to compromise his or
her interests in the respective enterprise for the sake of national security, or the respective
intelligence agency. There must be considerations paid to all involved for those rights and
interests that compromise such a relationship. Otherwise, the CIA could effectively gain control
of any domestic corporation it so desires, without ever owning one share of its outstanding
stock, simply by enlisting its product or services for the sake of national security. The CIA
requires a formal vehicle to enlist the aid of our domestic commercial enterprises. ISC is a
proven and unfortunate example of that.
Stan Caterbone was a shareholder of record of International Signal & Control (ISC) for the
previous four years prior to when this tragic ordeal began. Stan Caterbone was to purchase the
stock from now Republican Pennsylvania Senator Gib Armstrong, who was in the brokerage
business at the time and selling ISC stock. The stock was sold over the London Securities
Exchange, supposedly for reasons to suppress information. Stan Caterbone was interested in
the stock because of his appetite for technology, and was more curious about the business of
ISC, than anything. In fact, Stan Caterbone had never made any inference to any of the illicit
dealings with Iraq. However, the perpetrators of this story, attempt to hide behind a vale of
"national security," in an effort to find legal immunity from all wrongdoing. In accordance, the
record will prove that this is merely a smoke screen used to intimidate and obstruct Stan
Caterbone's access for due process of the law.
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 7 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 13 of
105
Page
Page1205
203 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
The trials and tribulations of Stan Caterbone are unprecedented in terms of emotional and
psychological duress, fortunately his indestructible faith in God, and his enduring belief in
himself and the truth, endures his life. There was one attempt on the his life, days within the
public disclosure of the CIA's involvement with the local Lancaster County defense contractor
(ISC), which Ted Kopel reported on ABC News Nightline, on May 23, 1991, 4 years after the
initial cover up began. This story will depict a series of systematic and strategic offensive
attacks upon Stan Caterbone and his businesses that will result failed business enterprises, and
a Hollywood motion picture, deserted. An impeccable professional reputation and a flawless
credit rating purposely sabotaged. Financial opportunities, that in 1987, were almost impossible
to extrapolate, Vast financial opportunities and aspirations forever a part of history. This
horrendous Crime was perpetrated for the interest of a cover up, further protecting the corrupt
enterprises of Lancaster County's International Signal & Control (ISC). A quest for justice that
polarized every relationship Stan Caterbone maintained, in Lancaster County and beyond,
including friends and family. This story demonstrates a methodology of his perpetrators for
keeping Stan Caterbone "quarantined" from justice and public disclosure, through a malicious
means of "credibility" proponents, and horrendously deceptive tactics. Financial motives
prominently displayed in the hands of all of the perpetrators, which absolves the burden for a
traditional conspiracy.
The emotional response to the truth of this story is compelling, to say the least. Subsequently,
the startling keen sense of perception that Stan Caterbone had demonstrated is even more
intriguing. It is this extraordinary quality that is responsible for saving his life, while yet at the
same time providing his perpetrators with an alibi and a vehicle for discrediting his startling
allegations and his story. This story embellishes a dichotomy of perception that had Hollywood
producers from his film project call his work genius, while his perpetrators from the Lancaster
County Community conveniently and maliciously labeling him as "insane" and "emotionally
disturbed."
THE LANDSCAPE
The perplexing question of Stan Caterbone's intelligence, or lack thereof, is best analyzed as a
question of perception. However it terms of the legal consequences of the activities contained
herein, they are of little if any relevancy. The fact of the matter is that the "mental deficiencies"
have very little relevancy to this story, other than serving as a means to discredit Stan
Caterbone, a vehicle to facilitate the cover up, and a blanket of immunity for all of the
perpetrators.
The heart of Stan Caterbone's legal dogma is best described as follows: If a person, is
perceived to have a "mental deficiency"; yet whose actions and decisions are always proven to
be instinctually and amazingly prudent, always abiding within the law, and in the best interest
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 8 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 14 of
105
Page
Page1206
204 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
of his affairs, what rights and protection do the laws afford him from persons abusing that
perception, in order to yield political and financial rewards, as a direct consequence of his
demise? Furthermore, how does the law protect his rights, if any and all malicious acts against
Stan Caterbone, are constantly and immediately disregarded because he is perceived to not to
be "credible"? As this story unfolds, these questions will become even more troubling and
appalling. Although Stan Caterbone could never describe the pain of his trauma, he would often
say that the closest situation that may compare is that of a woman being continuously raped,
night after night, helplessly praying for relief, struggling to free herself from her captor, all with
no avail. He would call it as being "brain f------".
Stan Caterbone, coming from the lower middle class of Lancaster City, was only 29 years old
when this tragedy began. Coming from a broken home, he was the third of six boys. While at a
very young age, he would help his mother run a dry cleaning business, in an amazing similarity
like Lisa Michelle Lambert, he had also nursed his mother during bouts of depression. While in
high school, he was nursing his mother's depression, while at same time tending to his older
brothers bouts of schizophrenia. Stan Caterbone had learned to listen to the obscenities of
mental illness since he was a child. He learned to fill the shoes of his absent father in helping
his mother raise his three younger brothers.. Stan Caterbone was often called the "little old
man" because of his extraordinary maturity as a child. Stan Caterbone was determined to
break the "barrier" of the "Good Ole Boy's" club or the power elite, and had always felt a sense
of compassion for those less fortunate, and those neglected by those of material means, the
oppressed and impoverished. He had an undivided aspiration to someday make a difference to
those that could not help themselves, especially his older brother. Through his ingenious,
resourceful, and honest business approach, he was relentlessly growing his business and their
respective missions, in constant reminder of his oppression. His in depth understanding of
computer technology and his vision were his most powerful allies. Always pushing the envelope
for advanced technologies and seeking solutions for the most efficient means of his operations..
He knew that every break was going to be few and far between, he dedication himself to his
work, and married his business affairs, always embracing his projects with a passion.
In 1986, after serving on the Board of Directors for the Central Pennsylvania Chapter of
International Association of Financial Planners (IAFP), Stan Caterbone had made a large
contribution to increasing its membership and it's awareness among local professionals, as it's
vice president. In an effort to promote the organization, Stan Caterbone solicited a nationally
recognized and prominent financial planner from Washington, D.C., to be a headline speaker at
a dinner meeting. Ms. Alexandra Armstrong, one of the most nationally recognized financial
planners, often headlined in Money Magazine, attracted 100 industry professionals to the
Treadway Resort Inn. The attendance was unprecedented for the local IAFP chapter. The IAFP
is the authoring organization for certification as a financial planner. It was through the direct
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 9 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 15 of
105
Page
Page1207
205 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
conversations with Ms. Armstrong regarding his ideas and her experience, that inspired Stan
Caterbone to pursue his ambitions of growing his own financial firm, which he began in the
following months.
Disgruntled with the conflicts of interest and the lack of incentive for various professionals to
work together in managing one's wealth, a process which lacked efficiency, this entrepreneur
founded the firm Financial Management Group, Ltd., or FMG as it was often called. The firm
was to incorporate a "one-stop-shopping" strategy and incorporate financial services, legal,
accounting, tax preparation, real estate, insurance, mortgage banking, and estate services all
in one firm, all residing in one location, all taking advantage of the synergistic approach toward
managing wealth. And to provide the professionals long term security and equity participation,
all participants were encouraged to purchase stock in the company. This was a new and
innovative approach that attracted a lot of attention from investors and clients, but also came a
lot of nervous twitches from competitors, especially in conservative Lancaster County.
Stan Caterbone began recruiting professionals from all of the other firms, with great success.
He had enlisted two partners whom he had worked with at IDS/American Express, to carry out
his mission, which he began after extensive market studies and his early version of the
company, Pro Financial Group, Ltd., His two partners had followed Stan Caterbone to an
independent broker dealer in Atlanta, named Financial Services Corporation, where Ms.
Alexandra Armstrong was associated, and encouraged Stan Caterbone to visit, during their
discussion after dinner. Within one year, by June of 1987, the firm had invested over $40
million for respective clients.
The company had developed satellite offices throughout Pennsylvania and in several other
states, through his unique design. This firm was causing the other financial services companies
and the local banks in Lancaster County a run for their money. The firm had built a new 20,000
square foot office building just a few miles north of the city. The firm was attracting clients,
associates, and nervous attention from, well just about everybody. Considering the capabilities,
legal, real estate, insurance, financial services, accounting, FMG was making as many enemies
as it was making friends. And Stan Caterbone always believed in the premise that it's always
better to have people talking about you, regardless of the matter, than to have no one notice
you. And they were talking. Stan Caterbone was only in his late twenties when he started this
organization,. He held several positions; he was Executive Vice President and Secretary of
Financial Management Group Ltd, and President of FMG, Advisory, Inc., which was one of the
many subsidiaries parent company owned. Stan Caterbone acted as the architect and legal
administrator of the organization, in addition to building his own financial planning clients. He
filed all of the articles of incorporation in the Commonwealth of Pennsylvania and submitted all
of the tedious and rigorous filings necessary for the Pennsylvania Securities Commission, which
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 10 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 16 of
105
Page
Page1208
206 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
were very demanding considering Stan Caterbone, was selling stock of his company to his
associates and investors. Stan Caterbone and his associates had also attracted some very
prominent Lancastrians's to invest in his venture, coming from various professional circles, all
infatuated with this extraordinary and intriguing concept of this young victim (Stan J.
Caterbone). All had seen it's potential for success and financial reward.
Many of his friends were involved, and in Lancaster, everyone knows everybody, so it seams..
And everyone talks, gossip is as common as jogging. This exaggerated trait of Lancaster
County, will later to come back to haunt Stan Caterbone, in a way that is most sickening. In a
way that will parallel the attitudes and sentiments in the Lisa Michelle Lambert story.
In 1987, his business affairs were reaching a point of incredible success. In fact, most of his
family and friends, have always questioned the merits of their legitimacy. He always conducted
his affairs with the presumption that time could not afford the opportunity to complete his
agenda, while at the same time disclosing his business affairs to persons that were not directly
involved.. Accomplishing his mission was first and foremost. But in Lancaster County, that was
difficult. Lancastrians's have a notion to fear what they don't know, and will always believe
what they think they know, regardless of its merits. In Lancaster County new ideas are
shunned unless coming from their own, and their own ideas are often kept close at bay,
inhibiting progress and stymieing learning. By June of 1987, a majority of his business affairs
were conducted out of the grasp of Lancaster County, his unknown activities made others
curious, especially in Lancaster County, where the blessing of the power elite was essential for
success. But, deep down inside, he knew he could never be accepted, because he did not
descend from a family of "social grace". This fueled his aspirations for success even further,
committed to prove that intelligence was innate and learned, not a direct correlation to material
wealth or social grace.
An elder attorney, Mr. Kenellm Shirk, a very respected and prominent older Lancaster attorney,
who was part of the status quo, provided one of his most cherished testimonials to his concept,
his reputation, and his mission. Mr. Shirk had petitioned the Pennsylvania Bar Association, after
meeting with Stan Caterbone, to obtain their blessing and their knowledge of any laws which
would forbid his firm to provide a satellite office in the headquarters of Financial Management
Group, Ltd., (FMG) Mr. Shirks firm was to provide a partner, and estate services to the clients
of FMG. The Pennsylvania Bar provided a lengthy recommendation that did not prohibit a
relationship, although cautioned it to proceed with careful review. The fact that the very young
and unknown Stan Caterbone could attract an elder, conservative Lancaster County attorney to
associate with his firm was an encouraging sign of respect. Ironically, Mr. Shirk is the father of
Roy Shirk Jr., Lisa Michelle Lambert's first attorney who represented her during trial of 1992,
the proceeding which was the center of Judge Dalzall's controversial and appalling findings.
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 11 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 17 of
105
Page
Page1209
207 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan Caterbone prided himself on his entrepreneurship, and after building the foundation for
FMG, he set out to take advantage of its resources and it's synergism.
By June of 1987, Stan Caterbone had developed a fairly substantial mortgage banking
relationship with a Houston, Texas banker. That operation was capable of providing lending to
potential developers and businesses in the range of $ 3 million to $100 million. And the lending
packages were as competitive if not more competitive than the local lending institutions of
Lancaster County, capable with even higher lending limits. In a matter of months of securing
this relationship, Stan Caterbone and his partner were evaluating deals from Pennsylvania, New
Jersey, New York, Florida, and as far away as California.
There was a uniqueness to his capabilities that was very appealing to potential borrowers.
Because of the vast array of services of FMG, potential developers had the opportunity to
obtain both debt and equity financing through his companies. In plain terms, most shopping
centers raised capital by raising funds through investors coupled with a mortgage. This gave
potential developers one place to "take down the deal" rather than dealing with many other
professionals at the same time. It was a much more efficient process for all. Stan Caterbone
was capable of providing a mortgage, while at the same time selling shares in a shopping
center through it's vast client base of investors at FMG. This also gave Stan Caterbone a
formidable presence into the venture capital markets, by way of his strong ability to raise
capital through his vast portfolio of clients of FMG. And this was a rarity that developers and
investors loved. Investors were attracted because they could invest in equity type real estate
projects with real sense of knowing the developer, or "kicking the bricks" of the project. This
was far different than investing in a nationally syndicated project, with properties scattered all
over the country, and with developers that they did not know. The synergistic approach to his
organization began paying dividends by developing other peripheral markets and businesses.
Given the complex nature of Stan Caterbone's design of FMG, internal struggles within the
organization readily became the challenge. Orchestrating the relationships among all of the
different professionals, and trying to adhere to the interests of the clients, the professionals
and of the firm, FMG, managing the daily activities required immense thought and prudence on
the part of the principals. Of, course, Stan Caterbone assumed honesty and integrity to be a
given. And for most it was. However there were times when the senior partner engaged in
tactical rights of power.
In the later part of 1986, after Stan Caterbone had developed FMG to the point where it's
future was on stable grounds, his two partners conveniently attempted to circumvent his
position and regain control of his stock and the firm. In fact, after Stan Caterbone refused to
collaborate on a scheme to "set up" his other partner, the remaining two partners began to
attempt to regain Stan Caterbone's control. Through intimidating techniques, the partners
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 12 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 18 of
105
Page
Page1210
208 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
began to attack his presence. Stan Caterbone became agitated, especially because he played
the lead role and was responsible for the formation of the company, methodically designing and
developing its foundation, with great success. And now after the company was beyond it's point
of greatest risk, due to in large part Stan Caterbone's efforts, the other two partners wanted to
take advantage of his work, and "take the cream of the pie" for their own financial gain. It was
a difficult task to carry out because Stan Caterbone was the most respected of all three
partners, consistently keeping their respective policies in the best interest of the firm and of the
other associates and stockholders. In fact, most feared that the loss of control of Stan
Caterbone would ultimately lead to adverse consequences. However the two partners trued
unsuccessfully to weaken his position, and when that didn't work, they focused on weakening
Stan Caterbone, via intimidation and humiliation The coup and hostile environment caused a
state of depression for Stan Caterbone, although he kept to his daily duties and responsibilities,
accordingly, he called a client and friend who was a psychiatrist, whom he trusted and
respected. It was easy access to a professional, yet on a very informal basis. Because Stan
Caterbone had a family history of "mental deficiencies", he wanted to seek the proper help.
The psychiatrist had diagnosed Stan Caterbone as having Bi Polar Mood disorder. The
psychiatrist had quickly discounted any correlation between the current state of affairs, and his
partner's abuse. The psychiatrist rationale was that "because the startup of the company was
so successful in such a short period of time" , and his demonstrated intelligence and creativity,
Stan Caterbone must have been in a state of mania, and of course now, was subsiding in a
state of depression, the typical cycle for manic depressants. Stan Caterbone complied with the
psychiatrist. And after refusing to sell out to his partners, vowed to regain his business and
rescind any efforts to give up his claim to his accomplishments. The depression soon faded.
Stan Caterbone never disclosed the fact that he had sought help to anyone other than family
members. This coup lead to Stan Caterbone's aggressive approach to grow the business, and to
posture himself in projects that would ultimately remain in his control, out of the influence of
his partners. Particularly of most interest was saving the mortgage banking activities and the
digital movie, which he did successfully, but apparently too successfully.
THE "DIGITAL MOVIE"
Through an act of fate, in February of 1987, Stan Caterbone found himself in a meeting with
Tony Bongiovi at Power Station studios. Through one of his partners, he reluctantly traveled to
New York to consider financing a motion picture. Stan Caterbone's own lack tolerance for the
risk associated with film investments was overshadowed by the opportunity to visit a recording
studio. Although his associate was a friend of Tony's, he was not familiar with his
accomplishments, or his work, so he thought. If nothing else, it was a weekend away from
Lancaster, and a chance to visit the Big Apple. Intriguingly, he found more than he had ever
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 13 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 19 of
105
Page
Page1211
209 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
imagined on that weekend excursion. Tony Bongiovi, a musical genius, who's credits include
one of the most recognized recording studios in the country, Power Station Studios. Tony
Bongiov produced the sound track for "Star Wars", and is responsible for the format of one of
the most successful recording artist of the 80's, Jon "Bon Jovi", his cousin. Power Station has
recorded the albums for some of the most influential artists of all time, including Diana Ross,
Madonna, The Rolling Stones, Steve Winwood, Bruce Springsteen, etc., Tony, an eccentric
genius, of Italian decent, had many talents, from music to aerospace engineering. Stan
Caterbone's associate's sister met Tony while he flew his plane into Lancaster's airport for
repairs. They dated for some time and Stan Caterbone's associate and Tony became friends,
which led Stan Caterbone to Tony's Power Station Studios.
Tony was looking to finance his new project, which was to be the first digital movie. And, given
Stan Caterbone's extreme appetite for technologies, coupled with his amazing sense of
perception, he dramatically recognized the future evolution for the technical merits of delivering
digital video and digital audio entertainment to the mass markets. By June of 1987, Stan
Caterbone was positioned as the Executive Producer, collaborating with Flatbush Films of
Hollywood California, the movie producers, entrusted with the mission of finding investors to
provide funding for the "first digital movie", and to manage the ensuing business elements it
required.
The movie was to be shot "on-location" at the Jersey shore points, mostly in Wildwood. Tony
strategically envisioned making a movie in the horror genre. There were several specific
reasons that supported this strategy. First, he determined that it was the least expensive
format to produce, we all estimated a budget of $4 million for the production and post
production. Secondly, the horror genre would compliment a very intense sound track. The
sound track was important to enhance the new digital format, and also provide the means to
introduce a new band that he had been grooming in his studio for the past several years,
"French Lick", his predecessor to "Bon Jovi". There had been bad blood between Tony and his
cousin "Bon Jovi", which resulted in legal disputes pertaining to Tony's financial interests in
Jon's success. It was an unfortunate situation considering Tony's father and Jon's father were
brothers living in the same area. It was a subject that Tony never wanted to discuss, except for
his contributions toward Jon's career.
If by another act of fate, Stan Caterbone had the privilege of meeting one of the many
superstars while working at Power Station studios. While growing up, at an early age, Stan
Caterbone would sneak up into the bedroom of his oldest brother, and start up his old General
Electric stereo phonograph and listen to his favorite album - Diana Ross and the Supremes. It
was a passion and a ritual that provided an early infatuation to music, and to Diana Ross. Stan
Caterbone was only 10 or 11 years old. And at this early age, he noticed and listened to the
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 14 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 20 of
105
Page
Page1212
210 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
annoying hiss, that conventional hiss that always seemed to overshadow the music, whether
played on an album, on the radio, 8-track tape, or cassette.
And in a mystical twist of fate, while engrossed in a project dedicated to delivering music
without that hiss (digital) - Stan Caterbone opened the door to the recording suite to pack his
bags for the journey back to Lancaster; - and there she sat, with a glowing array of beauty,
more beautiful than any picture could ever tell, Ms. Diana Ross. She was pregnant and in the
middle of a recording session, for a new album. Her assistant quickly demanded, in a stern and
protective voice, that we leave, and Stan Caterbone and his associate replied "this is our
makeshift bedroom, we are just gathering our belongings". Stan Caterbone walked toward
Diana Ross, who was seated near his bag, and she asked "and who are you?", Stan Caterbone
calmly replied his name and absorbed as much of her beauty as his eyes could behold before
walking out the door. The room that was his bedroom the nigh before, and suddenly transfixed
into the recording suite of Diana Ross, thinking back some twenty years earlier, one of the
many gifts that God would bestow upon him. A living memorial and reminder to his older
brother, who died on Christmas day of 1985, his best friend who taught him two of his greater
pleasures in life, Diana Ross, and listening to music. He prayed that his brother was watching
from above.
And so, the digital movie project that Stan Caterbone had embraced in 1987 had personal
significance, and he never ever doubted his instincts regarding the technical merits of the
project. Stan Caterbone's perception that the entertainment industry would deliver full length
motion pictures in a truly digital medium will later become a truly remarkable vision.
The technical merits of this project and at this particular time with respect to Stan Caterbone's
extreme sense of perception require analysis. To truly understand this time perception, some of
the attributes of digital technologies need to be fully understood. In 1987, Compact DISC (CD)
technology was only now being introduced to the commercial markets. Stan Caterbone's own
crafting of his joint venture proposals, dominated by the term "digital movie", is in itself some
4 or 5 years away. In 1987, there was very little use of the term "digital", with the exception of
research and development engineers. Stan Caterbone will, throughout the documentation of
this story, will have preceded a terminology that has literally become the root of most
technological advancements in the computer and telecommunications industries of our present
day, 10 years after Stan Caterbone's vision. Today, "digital" is found to be part of or referred to
in just about every product available in the commercial markets.
During May of 1987, Stan Caterbone had created a joint venture proposal for SONY
Entertainment, Inc., for the digital movie. After weeks of researching the current state-ofaffairs within SONY, and after his proposal was completed, SONY publicly announced their
desire to open the markets for new and emerging technologies on the cover of TIME magazine,
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 15 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 21 of
105
Page
Page1213
211 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
another demonstrated sense of perception. It was this proposal, when delivered to one of the
Hollywood producers in Santa Monica, California, after reading a draft of the proposal she said
"you are a genius". The proposal was introduced to Tony Bongiovi at the Wildwood Boardwalk,
where many of scenes were to be shot, and he approved of the proposal and thought that it
had great merits. Tony, who wanted very to do with the business elements of his project, gave
Stan Caterbone complete authority to secure the financing of the project, with a salary as
Executive Producer, and a percentage of the profits on the back end.
After review of Stan Caterbone's research and proposal's, his vision and his passion,
unfortunately without his efforts, has come to be known as Direct Satellite System, or DSS,
which is Sony's satellite entertainment system (TV), delivering digital audio and digital video
entertainment. That technology is fast eroding at the cable industry. Stan Caterbone had his
patent research center around the PSDMS system, the Power Station Digital Movie System. And
that was in 1987, some seven years before SONY delivered his dreams. Later Stan Caterbone
would also accurately predict that the 90's would become the "Information Age" because of the
direct contributions and advancements of "digital technologies", which is directly responsible for
the development of the "INTERNET".
Stan Caterbone's obsession with his "digital movie" has proven to be one of his most
remarkable demonstrations of his keen sense of perception.
The author admitted in an affidavit in 1998 that he did not know the criminal culpability of Lisa
Michelle Lambert, and further argues that it was because of the prosecutorial misconduct and
the erroneous handling of the crime scene that the truth evaded both the prosecution and the
defense as to who actually killed Laurie Show.
_________________________________________________
Date: April 28, 2016
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
/S/
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
(717) 669-2163
Page 16 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 22 of
105
Page
Page1214
212 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
EXHIBIT
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 17 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 23 of
105
Page
Page1215
213 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
November 12, 2015

Ms. Kathleen Kane
2015.
amicable fashion.
717-669-2163
Stan J. Caterbone
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 18 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 24 of
105
Page
Page1216
214 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 19 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 25 of
105
Page
Page1217
215 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 20 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 26 of
105
Page
Page1218
216 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
EXHIBIT
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 21 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 27 of
105
Page
Page1219
217 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan J. Caterbone

1250 Fremont Street

Lancaster, PA 17603
scaterbone@live.com
717-669-2163
April 20, 2016

Stan J. Caterbone/Advanced
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page22
1 of 48
6
Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 28 of
105
Page
Page1220
218 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page23
2 of 48
6
Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 29 of
105
Page
Page1221
219 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
William Bennett.
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page24
3 of 48
6
Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 30 of
105
Page
Page1222
220 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
telecommunications.
Industrial Park.
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page25
4 of 48
6
Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 31 of
105
Page
Page1223
221 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
compact disc.
million.
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page26
5 of 48
6
Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 32 of
105
Page
Page1224
222 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
1250 Fremont Street

Lancaster, PA 17603
scaterbone@live.com
717-669-2163
ACTIVE COURT CASES

Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page27
6 of 48
6
Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 33 of
105
Page
Page1225
223 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
EXHIBIT
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 28 of 48
Thursday,
Thursday,April
April 28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 34 of
105
Page
Page1226
224 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan J. Caterbone

1250 Fremont Street

Lancaster, PA 17603
scaterbone@live.com
717-669-2163
April 16, 2016
My Story of Victimization for Derrick Robinson's Document to the FBI

In 1987 I 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 I am connected 24/7 with the same person who declares
telepathically she is a known celebrity. Over the course of 10 years I have 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.
I have 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.
Stan J. Caterbone
Superior
Superior
Court
CourtNo.
1164
8423-15
Story
Amicus
and
Amicus
Evidence
re Kathleen
of Kane
a TI
Targeted
Page
Page
Individual
291of
of48
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 35 of
105
Page
Page1227
225 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
In 2015 I filed an amicus curie on behalf of Lisa Michelle Lambert who was convicted in 1992 of
the murder of Laurie Show, both of Lancaster, Pennsylvania. I currently am in litigation in the U.S. Third
In 2009 I Proposed an ORGANIZED STALKING AND DIRECTED ENERGY WEAPONS HARASSMENT
BILL to Pennsylvania House of Representative Mike Sturla (Lancaster, Pennsylvania) and City of
Lancaster Mayor Richard Gray in 2009. The draft legislation is the work of Missouri House of
Representative Jim Guest, who has been working on helping victims of these horrendous crimes for
years. The bill will provide protections to individuals who are being harassed, stalked, harmed by
surveillance, and assaulted; as well as protections to keep individuals from becoming human research
subjects, tortured, and killed by electronic frequency devices, directed energy devices, implants, and
directed energy weapons. I again reintroduced the bill to the Pennsylvania General Assembly in 2015
and frequented the Pennsylvania Capitol trying to find support and a sponsor; which I still do to this
day.
In 2005 I, as a Pro Se Litigant filed several civil actions as Plaintiffs in the United
States District Court for the Eastern District of Pennsylvania, the United States Third District
Commonwealth Court of Pennsylvania, The Court of Common Pleas of Lancaster County,
Pennsylvania. These litigations included violations of intellectual property rights, anti-trust
violations, and interference of contracts relating to several business interests, harassment,
extortion, fraud, etc.,. . Central to this litigation is the Digital Movie, Digital Technologies,
Financial Management Group, Ltd,/FMG Advisory, Ltd., and its affiliated businesses along
with a Federal False Claims Act or Federal Whistleblowers Act regarding the firm of
International Signal and Control, Plc., (ISC) the $1Billion Dollar Fraud and the Export
violations of selling arms to South Africa and Iraq. This litigation dates back to 1987. In
1987 I microfiched some 10,000 pages of documents that prove this story without any doubt.
I also have recorded conversations of persons and government officials.
1250 Fremont Street

Lancaster, PA 17603
scaterbone@live.com
717-669-2163
ACTIVE COURT CASES
Stan J. Caterbone
Superior
Superior
Court
CourtNo.
1164
8423-15
Story
Amicus
and
Amicus
Evidence
re Kathleen
of Kane
a TI
Targeted
Page
Page
Individual
302of
of48
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
Stan J. Caterbone Affidavit
Document
Filed 05/17/16
Page 36 of
105
Page
Page1228
226 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3113of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
Document
Filed 05/17/16
Page 37 of
105
Page
Page1229
227 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3224of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
Document
Filed 05/17/16
Page 38 of
105
Page
Page1230
228 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3335of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
! "
"
Document
Filed 05/17/16
Page 39 of
105
Page
Page1231
229 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
$% &
!
" #
%
"&#
(
'
!
(
,
"
"
")
"
""
-
)
!
! "
!
'
%
" !
"
!
)
+
!
" *
"
"
,
,
,
*
%
*
(
%
!
/"0
1
1 ,
"
"
4
!
"
"
!
!
#
.
.
&,,0
%
1 ,
2"3
!
)
** ! "
&,,..$/
&,,
%
&,,
%
&
, "
"
00
"
!,
"
6
7
7 , !
&,,-
8,
:
(
$;$
"2
! " ,
, ,
** !
;
5
$
!
&,,@
,
.
&<;=
>
1
9
,
&,,=
$
,
>
A
1 B3
.+
&,,=
1 B3
2
>
%
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3446of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
<
1
1
* "
!
"
C#
"$
"
<
*
&, ,
24
#9
; "
&,,@(&,,= A
3
24
5
!
%
&,,0 4
! %3
"
"
!
&,,
%
!
4
'
5
Document
Filed 05/17/16
Page 40 of
105
Page
Page1232
230 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
4
D
%
%
"
""
,! "
0 =
0 =9
9
00&9 00
:
9
&,,-
&, , $
!
%
!
D
%
%
=
F
!
))
+
/4
),
"
0 =
/
$
G
3
%
00
3
3
"
%#
$
$
&, ,
&,,4
!- "
.
&,,@
,
*
&,,<
E
&,,
-) !
/ 4
24
/
$
D
&, ,
D
$
&,,-
&,,0
%
D
!
D
D %
7F !
>
!
D
$
A
8F
$
%
;
D
.
%
&,,3
E
$
*
00=; 00
$
5
! 7
0 =
00
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3557of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
F
)
A
Document
Filed 05/17/16
Page 41 of
105
Page
Page1233
231 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
24
$;$
00
(F
&
%
B
5
00 9
" * <
00=( 00 9
:#
> ) "" ""

$
;3
#, " !
&,,-
"
"
"
0 =
&, ,
/
.
$
B
3
3
=
0 =
) "
.
&,,1
0 =
24
" "
3
"
&,,@
" E
""
B
$
<
&,,1
.
&,,-
,-(&&
2
=
@,
"
&,
3
&,,!
&,,@
&,,@
0 =
@, 1
&,,@
9
!
@,
#" !,
0 =
" "1 ,
"
"*
":
" E
F
&,,-
!
B
/
!
"
00=( 00 9
B
:
9
$
'
.
&,,1
9
0 =
&, ,
/
.
00 9
/
&,,9
&,
( "
!
.
00
$
!
&, ,
F
3
7
8
!
&,,
&, ,
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3668of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
&
, * "
&&
*#
"
&:
;!
&<
:
%
$
&, ,
Document
Filed 05/17/16
Page 42 of
105
Page
Page1234
232 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
$
&,,-
!-
,
5
%
"
>
$
$
< !-
24
? "
;
>
&,,0
B
&,,%
(
$
&, ,
&-
A
.+ $
&@
! :
&,,$
: , *
&, ,
* @
&,,@
"
E
3
&,,
"
&,,0
7 "!
7 "
0 =
*
&=
) "
":
)"
&,,@
"
&
&0
!
< ")
+
9 &,,@
:
9
&, ,
&,,
00
:,
!6
"
"
" .
9 &,,0
0 = "&#
, *
&,,@
/
" F
0 =
;A
0 =
F
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3779of
of
of48
27
29
0 =
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
3
!
"
$
+
1
$
Document
Filed 05/17/16
Page 43 of
105
Page
Page1235
233 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
!
$
.
0 =
.
I $
!
0 =
.
$
"2
'
+$;F
D
"$
&,;&,
3
A
00
'
$ 24
"1E1# $
K
E
A
00&
>
L
F
F
B
F
+
0=,K
A
$
$
1
+
>
1
$
>
B
!
3
F
1
00
) % 3
&,,-
!
>
! A !
00,K
1 B3
>
F
F
& 1
F
8
! 4
'
A
! 4
A
0=,K
F
00,K
0 ,K
0<,K
3
/
>
%
&,,
) %$
0@,K
0@,K
$
2!
A
D 1
"
$
0 <9 F
4
A? D!B
#
*
$
7
+
00
D 18
.
E
$
M 1
00= E
0 =
%
0 ,K
$
0 =
M
00
!
&,,9
(
9
!
1
,-(
$ !2B+EF2
(&&
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
38
10
8 of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
Document
Filed 05/17/16
Page 44 of
105
Page
Page1236
234 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
#
") !
"
7!
N
.
!
5
F
(
(
5
G
*
A'
, ?
*
? 1
!,
A
(
> "
!, '!
,
B
A
" " * #" !, " "
$C
* #" !, D
73
8
* 7
,
"
"
&
"
#
.
"
#(
5
7
9
'
5
%
7A
8 !
8 !
'
!
7D .2
O
% 8
'
7
'
(
(
%
%
4
K
K
M %
%
K
'
7E
(
8
"
%
'
%(
(
(
4
;
(
7
7
87
(
(
8
8
- 7 > !,
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
39
11
9 of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ Document
Filed 05/17/16
Page 45 of
105
Sunday January
January
22, 2017
22, 2017
Page
Page1237
235 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
!
* , "
1"
!
, *
1
3
@
E
!
DD
!
1
*
)) )
@
E
!
DD
B &. @
DD
B@
. DD
")
!
"
, " *"
*
(
!
")
"
"
B@
& DD
)
"
B@
. DD
)
*
, "
!
* 1
B@
& DD
)
!
* "
*
B@
$ DD
")
!
7
B@
DD 7
B@
E
DD
"! "
* *
. @
EB& DD
!
*
)
*
, "
. @
EB DD
")
!
*
1 ,!
, "
& @
& B DD 6, "
1
)
!
"
B@
DD 5
"
!
!
B@
& DD
1
"": !
B@
DD
)
1 , 1
"": !
B@
& DD >
"
1
"": !
B@
DD ' "
!
!
"
! * ! *
"
"
B@
)
B@
E DD
)
*
"E
!"
, "
"
1 ,"
DD
*)
PPPPPPP "
>7
%#
'?
Stan J. Caterbone
"
Stan J. Caterbone
"
June 19, 2015

Pennsylvania
$
Lancaster
19
PPPPPPP
15
June
&,PP

F
SJC
I
.
I
&, ,
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
40
10
12of
of
of48
27
29
Don't Know When
24
$
$
Q &, , "!
I
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
Stan J. Caterbone
Samuel
P. Caterbone
Affidavit
Jr., (Father) Affidavit
Document
Filed 05/17/16
Page 46 of
105
Page
Page1238
236 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
41
11
13of
of
of48
27
29
Page 35 of 41
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
06/10/2007
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
Samuel P. Caterbone Jr., (Father) Affidavit
Document
Filed 05/17/16
Page 47 of
105
Page
Page1239
237 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
42
12
14of
of
of48
27
29
Page 36 of 41
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
06/10/2007
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
Sammy Caterbone (Brother) Affidavit
Document
Filed 05/17/16
Page 48 of
105
Page
Page1240
238 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
43
13
15of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
Document
Filed 05/17/16
Page 49 of
105
Page
Page1241
239 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
44
14
16of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
Sunday January
January
22, 2017
22, 2017
Document
Filed 05/17/16
Page 50 of
105
Page
Page1242
240 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
45
15
17of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 51 of
105
Page
Page1243
241 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
September 25, 2009
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
46
16
18of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 52 of
105
Page
Page1244
242 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
47
17
19of
of
of48
27
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
What is CCHR?
1 of 2
http://www.cchr.org/about-us/what-is-cchr.html
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
ABOUT US
VIDEOS
Document
Filed 05/17/16
Page 53 of
105
Page
Page1245
243 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
TRUTH ABOUT PSYCHIATRY
ALTERNATIVES
TAKE ACTION
ORDER
The Citizens Commission on

Human Rights was originally
formed in 1969 as a global
watchdog committed to
investigating and exposing human
rights violations in the field of
mental health. From its
headquarters in Los Angeles,
CCHR coordinates activities
amongst its chapters around the
world.
HOME ABOUT US WHAT IS CCHR?

SUBSCRIBE
TO CCHR NEWS
< ;
WHAT IS THE CITIZENS COMMISSION ON HUMAN

RIGHTS?
! !"
#'
FREE INFORMATION KIT

AND DVD
$$!##!
($
))
* #
!
(
Restoring Human Rights and
Dignity to the Field of Mental
Health
'#/
, #!
About Us
Accomplishments
Message from the President
Board of Advisors
)#+
'
'#/
) . )! ! / (
'!
# % ##
#!
(
//
))
! (
$ !
$( )
!
! ! #!
'
!#
)!
!
(
#!# (
))
#+
'
.
,! #
')
!
$ !
#
! (
&
! (
))
#+
0 '#/
* !
, #
.! !
)+
!. #
'
#
' )! !
#+
!#)
)
.
))/ '
.!#
.
$
# /
')
#+ )
!# # *
!#
!
(
/$
!#
!# #+ ) */
!
! ))/ ! (
( 1#/
#
#!
6# 7
#+
( ##
!#9 2 '
#!
# ))
!#0# (
$
* /
'! !
!#
# 5
'! !
3'
#!
0!
) ( 4 !#
+ % & ))
( #
# ( * '#/
!# #+ '#/
!# (
.! *+ %7&
# !,
'
$
#
# ) )/
!.!)
!#
))
)8
0
*
$ , #!.
+*
# / #
!# #
)/ #0 !(
% &
)!
)
)# (
,)
, !
#+ # !
!# * ,#!
# #
)3
# $
( ##!
!.!
#*
!# #+
!" !
$ ) !,!))!
0
$
(!
#+ !
## '
') (
,! )
' !
#+ ,
What is CCHR?
'
)!
$
( #
' !
, #! !
)
#+ # !
(! $
!#0# ( '#/
'
+ ( )) ! (
)+ !.!)
! 3'
#+
#!#+
!$ *
!
! #
$$!##!
,/
# # ) )/ #
)# !
)! !
)!$!
!. #
#!
,/
Order a Free
Citizens Commission on
Human Rights Information Kit
" #"
( ))
+,
!
$ #
& !#
) )
( ##!
/ ( '#/
#2
# !''
'
+!
#%
- ) *# '
#)
)
! !$
)) . !) ,) $
)'!
!. '
(! )
$
#!,) (
$ !
()!
, !
%2&
$( )
Leadership
#*
CCHR Financials
Mental Health Declaration
! (
$ !
$!
#(
( )) ! (
!
# *!
'#/
. #
#
!
!
!
(! )
($
# #
# ! 0
'!
)
+
' ,)! !
0
!# !
! (
CCHR
CHAPTERS WORLDWIDE
(
!
: #
Psychiatry: An Industry of
Death Museum
CCHR Global Locator
!# #'! !
$ !
'
* '
#!
(!
$/
!" !
*!
*!
+ ! !#
Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
48
18
20of
of
of48
27
29
.!
#+ ,)
#+
*#+ $
) ;'
#
' ,)!
,)
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
11/6/2015 12:42 AM
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 54 of
105
Page
Page1246
244 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 55 of
105
Page
Page1247
245 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 56 of
105
Page
Page1248
246 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 57 of
105
Page
Page1249
247 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 58 of
105
Page
Page1250
248 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 59 of
105
Page
Page1251
249 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 60 of
105
Page
Page1252
250 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 61 of
105
Page
Page1253
251 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 62 of
105
Page
Page1254
252 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 63 of
105
Page
Page1255
253 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 64 of
105
Page
Page1256
254 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 65 of
105
Page
Page1257
255 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 66 of
105
Page
Page1258
256 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 67 of
105
Page
Page1259
257 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 68 of
105
Page
Page1260
258 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 69 of
105
Page
Page1261
259 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 70 of
105
Page
Page1262
260 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 71 of
105
Page
Page1263
261 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 72 of
105
Page
Page1264
262 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 73 of
105
Page
Page1265
263 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 74 of
105
Page
Page1266
264 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 75 of
105
Page
Page1267
265 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 76 of
105
Page
Page1268
266 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 77 of
105
Page
Page1269
267 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 78 of
105
Page
Page1270
268 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 79 of
105
Page
Page1271
269 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 80 of
105
Page
Page1272
270 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 81 of
105
Page
Page1273
271 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 82 of
105
Page
Page1274
272 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 83 of
105
Page
Page1275
273 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 84 of
105
Page
Page1276
274 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 85 of
105
Page
Page1277
275 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 86 of
105
Page
Page1278
276 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 87 of
105
Page
Page1279
277 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 88 of
105
Page
Page1280
278 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 89 of
105
Page
Page1281
279 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 90 of
105
Page
Page1282
280 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 91 of
105
Page
Page1283
281 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 92 of
105
Page
Page1284
282 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 93 of
105
Page
Page1285
283 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 94 of
105
Page
Page1286
284 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 95 of
105
Page
Page1287
285 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 96 of
105
Page
Page1288
286 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 97 of
105
Page
Page1289
287 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 98 of
105
Page
Page1290
288 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
Page 99 of
105
Page
Page1291
289 52
of
of1299
2301
Stan J. Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
100 LAMBERT
of 105
Page
Page1292
29052
of
of1299
2301
Stan J. Page
Caterbone
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
101 LAMBERT
of 105 CASE FILE
Page
Page1293
29152
of
of1299
2301
Stan J. Page
Caterbone
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
102 LAMBERT
of 105
Page
Page1294
29252
of
of1299
2301
Stan J. Page
Caterbone
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
103 of
105
Page
Page1295
29352
of
of1299
2301
Stan J.Page
Caterbone
LAMBERT
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
104 LAMBERT
of 105
Page
Page1296
29452
of
of1299
2301
Stan J. Page
Caterbone
CASE FILE
Case
5:15-cv-03984-JCJ
January January
Sunday
22, 2017
22, 2017
Document
Filed 05/17/16
105 LAMBERT
of 105 CASE FILE
Page
Page1297
29552
of
of1299
2301
Stan J. Page
Caterbone
January January
Sunday
22, 201722, 2017
Page
Page1298
296 of
of1299
2301

mailto:amgroup01@msn.com
717.427-1621 Fax
1250 Fremont Street
Lancaster, PA 17603
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION
__________________________________________________________________________
American Civil Liberties Union, American

Civil Liberties Union Foundation;
American Civil Liberties Union of
Michigan; Council on American-Islamic
Relations; Counsel on American-Islamic
Relations Michigan; Greenpeace, Inc.;
National Association of Criminal Defense
Lawyers; James Bamford; Larry Diamond;
Christopher Hitchens; Tara McKelvey; and
Barnett R. Rubin,
Plaintiffs
v.
National Security Agency/
Central Security Service, and Lieutenant
General Keith B. Alexander, in his
official capacity as Director of the National
Security Agency and Chief of the Central
Security Service,
Defendants
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
Case No. 2006-cv-2095

Case No. 2006-cv-2140
Honorable Anna Diggs Taylor
__________________________________________________________________________________
BRIEF ON BEHALF OF AMICI CURIAE STANLEY J. CATERBONE

and ADVANCED MEDIA GROUP
IN SUPPORT OF PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT
_________/s/_______________
Date: February 20, 2007
Stanley J. Caterbone, Pro Se Litigant

220 Stone Hill Road
Conestoga, PA 174516
717-427-1821 facsimile
amgroup01@msn.com
Page 1 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1299
297 of
of1299
2301
__________________________________________________________________
TABLE OF CONTENTS
_____________________________________________________________
I.
STATEMENT OF INTEREST OF AMICUS CURIAE ......................3
II.
BRIEF IN SUPPORT OF AMICI CURIAE STANLEY J. CATERBONE AND

ADVANCED MEDIA ..5
III.
ARGUMENT 21
Page 2 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1300
298 of
of1299
2301
__________________________________________________________________
STATEMENT OF INTEREST OF AMICUS CURIAE
__________________________________________________________________
Stanley J. Caterbone is a private citizen and the majority shareholder of the United States
incorporated business Advanced Media Group.
Stanley J. Caterbone was a whistle-blower and
shareholder in 1987 involving the United States Defense Contractor International Signal & Control,
Plc., known as ISC. In 1992, International Signal & Control was indicted and found guilty of among
other things a Billion Dollar Fraud and export violations concerning illegally shipping cluster bomb
technologies, missile defense systems, and other defense systems to foreign interests including South
Africa, Iraq and Saddam Hussein. Cluster bombs and related technologies are known to have been
exported to Iraq by the Chilean Arms Dealer Carlos Cardoen, a joint venture partner of International
Signal & Control.
The Central Intelligence Agency is confirmed to have been involved in a covert
program to arm Iraq during the 1980s with close ties to International Signal & Control, which
allegedly included the help of the National Security Agency, a former end user of International Signal &
Control technologies under the early 1980s program Project X. A Presidential Finding in 1984 by the
Bush Administration was executed to implement the program of arming Saddam Hussein and Iraq with
the cluster bomb technologies. Serious allegations of these programs were the focus of investigations
that included the knowledge and supervision of then appointed nominee for the Director of Central
Intelligence Agency, Robert M. Gates.
Since 1987, Stanley J. Caterbone has been the victim of vast civil conspiracy that started in
1987 to cover-up allegations of fraud within International Signal & Control during the negotiations and
merger of International Signal & Control and Ferranti International of England. Stanley J. Caterbone
alleges that warrantless surveillance was used to obstruct justice and moot his constitutional rights in
an effort to divert attention away from his allegations of fraud within International Signal & Control
back in 1987, and afterwards to the present as a means to deny his access to the courts for remedy
and relief, and Federal False Claims Act violations. The business of Advanced Media Group has been
greatly compromised and intellectual property stolen during the late 1980s and early 1990s that
included information technology contracts with the United States Government.
In January of 2006, Stanley J. Caterbone was detained at every airport security check point,
which was during a policy of random checks, and taken out of line during travel from Philadelphia,
Pennsylvania, to Houston, Texas, and on to Puerto Vallarta, Mexico. At the Houston Airport, Stanley J.
Caterbone was falsely accused of carrying plastics explosives and taken to an interview room by
Homeland Security officials. Stanley J. Caterbone was also detained for three days in Mexico, and was
not provided with an opportunity to gain access to a flight out of the country by Mexican Officials.
Page 3 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1301
299 of
of1299
2301
The interest of amicus in this case is ensuring that constitutional rights of private citizens are
not compromised and justice subverted through information obtained from warrantless surveillance
upon which there is no just cause for any allegations or association with terrorism. Whistle-Blowers
are inherently supportive of a system of checks and balances within our government that go beyond
our constitutional doctrines regarding the same.
Whistle-Blowers ensure that the rule of law is
universally applied to all government officials in all branches of government. The Federal False Claims
Act and its provisions protect individuals from abuse of power, while providing relief and remedies for
those that were wronged and those that had the courage to cite a wrong.
It is too easy for present and future administrations to abuse their power and utilize
warrantless surveillance as a means of subverting and obstructing justice for those that are engaged in
Whistle-Blowing cases that concern National Security.
Without the proper oversight and judicial
review, a Whistle Blower can be place on terrorist lists for malicious reasons without the knowledge or
just cause. This is in direct conflict with keeping our democracy free of corruption while adhering to
the spirit of the constitution in the manner our founding fathers envisioned.
Page 4 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1302
300 of
of1299
2301
__________________________________________________________________________
BRIEF IN SUPPORT OF AMICUS CURIAE
__________________________________________________________________
Background Information: The following transcripts from National Broadcast Television, ABC News
Nightline and ABC News 20/20; provide material information as to the activities of International Signal
& Control and the importance of these matters with regard to National Security.
ABC NEWS 20/20 FEBRUARY 1, 1991
[Lynn Sherr ABC News 20/20 Correspondent] This is the story of how this deadly weapon,
designed for the U.S. military made its way form this country to Iraq. And how American Soldiers may
face the devastation of a cluster bomb if a ground war breaks out in the Persian Gulf. Federal Officials
believe Saddam Hussein got his arsenal thru a lethal combination bureaucratic foul ups in the U.S.
Government and simple greed.
Here is how the cluster bomb works. An artillery shell, an airplane, or a rocket launcher sends the
bombs toward their targets.
Each bomb carries hundreds of smaller bomlets, something like hand
grenades. Cluster bombs can be used against ground troops or tanks, and can even scatter mines to
lie dormant for days. The bombs can spray thousands of pounds of sharp objects pins or even razor
blades. The shrapnel can rip through anyone or anything in its way, causing massive casualty among
civilians or ground troops.
You can see the destruction in these buildings in Lebanon after a cluster
bomb attack.
How did Iraq obtain the cluster bombs and the ability to make their own? It was incredibly simple.
Investigators believe it started with International Signal & Control, A government contractor with
5,000 employees based in Pennsylvania, which build key components of cluster bombs in a subsidiary
in California. 20/20 has learned Federal Investigators believe ISC provided the technology, that is the
plans, to this man, Carlos Cardoen, Chilean arms dealer.
Authorities believe he used the plans to
build the cluster bombs in Chile, then he shipped them to Iraq.

Whats wrong with all this?
If the cluster bomb technology actually left the county, that is illegal
without U.S. Government permission, investigators say ISC never got. It is also illegal for a foreigner,
like Cardoen, to take the plans out of the United States without a license, which sources tell us, he
never obtained. The man who opened the door to Iraq for Cardoen, was this man Nasser Bedouin. He
is a Lebanese born middleman for Cardoen who is based in the United States. Bedouin traveled often
to Bagdad, and arranged for sale cluster bombs and other military hardware to Saddam Husseins
army. In his first television interview, he told us about the business of dealing in deadly weapons.
Page 5 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1303
301 of
of1299
2301
[Nasser Bedouin, Arms Dealer] I can sell you a knife to peel an apple, if you cut someones
throat, thats your business. Weapons do not kill, who behind them kill.
[Lynn Sherr ABC News 20/20 Correspondent] With slick promotional videos, Cardoen marketed
his arms throughout the world. Arab countries were favorite customers.
[Cardoen Marketing Video] Each one of the bomblets of the cluster bomb is multi purpose and
contains an incendiary, anti personnel and anti armor detection.
[Lynn Sherr ABC News 20/20 Correspondent] This letter from Cardoen authorizes Bedouin to
sell cluster bombs to Saddam Hussein during his war with Iran.
This letter says Cardoens company is
willing to take its share in helping Iraq in its time of need. We can provide you with our cluster bombs
at the lowest possible price. According to these contracts the sale of cluster bombs to Iraq was an
extremely lucrative business. February 24, 2984 3,000 cluster bombs sent to Saddam Husseins army
worth $21 million dollars.
dollars.
A few months later, another 3,000 cluster bombs, another $21 million
The supply of cluster bombs eventually totaled more than $400 million dollars.
In fact,
Bedouin is suing his former boss for commission payments.

According to Bedouin, Cardoen not only sold the bombs produce in Chile to Saddam Hussein, he
actually set up a factory near Bagdad.
bombs.
So the Iraq President could mass-produce his own cluster
That was one of the first attacks by the military when the attack began.
Its unknown
whether that plant is totally out of commission.

[Nasser Bedouin, Arms Dealer] He set up a factory to manufacture the cluster bomb. Um, ah
later stage for the fuses. And this is a complete project. I mean its completer from raw material to
finished product. Because the purpose in Iraq is to have control over the weaponry they have put in
their strategy.
[Lynn Sherr ABC News 20/20 Correspondent] Federal Investigators are now trying to bring
Carlos Cardoen to justice.
But why didnt they find out about him sooner? He has been selling cluster
bombs to Iraq for nearly a decade. The U.S. Patent Office knew about Cardoen back in 1986. But
they didnt tell anyone else in the Federal Government about them. In a move that went apparently
unchecked in the highest levels of the government, Cardoen applied for his own patent for cluster
bombs in 1986. Based on some changes on previous designs, he received the patent two years later.
Getting the Patent is not illegal. But at a time when U.S. shipments of arms to Chile were banned, as
to all sales to Iraq, Why didnt the Patent Office raise any questions why was this foreigner dealing in
U.S. arms?
Page 6 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1304
302 of
of1299
2301
Experts say bureaucratic infighting regularly causes such lapses.
The Departments of Commerce,
State, and Defense, are supposed to control arms sales, and communicate with one another.
[Anthony Cordazman, Correspondent] - Even today, the same squabbling goes on, every day
within the Commerce, State, and Defense. The Administration can never agree on what
kinds of laws
can be passed to correct this.

[Lynn Sherr ABC News 20/20 Correspondent] Carlos Cardoen denied our requests to speak on
camera. In an interview last year, he denied he did anything wrong.
[Carlos Cardoen, Chilean Arms Dealer] - And as long as a human being is an animal that needs to
defend himself, weapons are going to exist. I think that is wrong.
As a human being I believe that
weapons are wrong. But they are a fact. And we have to live with facts.
The former head of ISC, James Guerin, who dealt with Chilean, said he did not provide anything to Cardoen to build
weapons. But Nasser Bedouin tells a different story.
[Nasser Bedouin, Arms Dealer] I believe that Dr. Carlos Cardoen got the plans to build the
cluster bombs from the United States.
[Lynn Sherr ABC News 20/20 Correspondent] Questions about the cluster bombs come at a
time when questions are being focused on how so many American designed weapons got into the
hands of Saddam Hussein. Senator John McCain.
[Senator John McCain] Theres not just one Saddam Hussein on this globe. Theres lots and lots
of them who at this time as we speak are acquiring technologies to give them the capabilities of
weapons of mass destruction because its a way of gaining victory on the cheap.
[Lynn Sherr ABC News 20/20 Correspondent] McCain has introduced legislation that would
severely penalize and company or countries that would sell weapons illegally or harbor arms dealers.
[Senator John McCain] To provide many of the kinds of weapons that we have today to many
nations, which are clearly offensive in nature, and are clearly far exceed their requirements to defend
themselves, is frankly unconscionable and must be brought to a stop.
[Lynn Sherr, ABC News 20/20 Correspondent] Basically what you are saying is hit them in the
pocketbook.
Page 7 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1305
303 of
of1299
2301
[Senator John McCain] Hit them in the pocketbook and public exposure. No corporation or nation
likes to be branded as a nation that is involved in this illicit trafficking.
[Lynn Sherr ABC News 20/20 Correspondent] But public exposure and pressure will not shield
American Soldiers. If Saddam Hussein uses the cluster bombs he already has.
[Senator John McCain] And if there is one good thing that has come out of this Persian Gulf war
its to dramatically heighten the awareness of the people of the world to the American people of how
dangerous this proliferation of weapons of mass destruction can be.
[Hugh Downs, ABC News 20/20 Correspondent] God those things are vicious. Have there been
any indictments yet Lynn?
[Lynn Sherr ABC News 20/20 Correspondent] Ah, no Hugh, no indictments yet.
Carlos
Cardoen has not been indicted, even though Federal Agents raided his headquarters office in Miami.
And U.S. Customs people took a number of documents, but no indictments yet, but there are
investigations going on.
[Hugh Downs, ABC News 20/20 Correspondent] If these things are dropped from airplanes,
and we have air supremacy, as it now has been said by our leaders, is there that much to worry about
for our troops?
[Lynn Sherr ABC News 20/20 Correspondent] Were told yes, because you dont need to an
airplane to a cluster bomb, they can also be used on rocket launchers and on unguided missiles, both
of which Iraq has. And incidentally, we talked about that bomb factory, even if it was badly damaged,
the cluster bomb factory he already has, were told in three to six months it can be operational again,
and anyway he likely has a big stockpile.
[Hugh Downs, ABC News 20/20 Correspondent] We of course, have these weapons also, and I
understand they are called something different?
[Lynn Sherr ABC News 20/20 Correspondent] Yes, if youre listening to a Pentagon Briefing,
dont listen for the term cluster bomb, there calling them Aerial Denial Weapons.
[Hugh Downs, ABC News 20/20 Correspondent] Thank you Lynn.
END
Page 8 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1306
304 of
of1299
2301
ABC News Nightline - September 12, 1991

[Ted Koppel] incidentally the function of the senior review panel is to advise one man, the director
of central intelligence. And at least part of the period in question there was an acting director of the
CIA Robert Gates. Well attempt to pull some of these threads together when we come back.
Commercial Break
[Ted Koppel] When all is said and done, why should your or your representatives in Congress care,
eventually after all President Bush spoke and acted against Sadaam Hussein more forcefully than
anyone could have expected.
[Former President George H. Bush Speech] Were dealing with Hitler revisited, a totalitarianism,
a brutality, that is neglect and unprecedented in modern times.
[Vidoe-Gary Milhollin, Director, The Wisconsin Project] The more we gave Sadaam, the more
dangerous he got. And ultimately we had to go to war to destroy what we sold him.
[Ted Koppel] But its not a question of holding the Bush or Reagan Administrations to account for
having made mistakes with regards to their policies toward Iraq The issue is how those policies were
implemented.
As we reported over the past few months, The Atlanta Branch of an Italian Bank, BNL, was able to
funnel $Billions, some of it in U.S. Credits to Iraqs Military Procurement
Network.
The U.S.
Government knew, and turned a blind eye. Sophisticated Military Technology was illegally transferred
from a major U.S. company in Lancaster, Pennsylvania (International Signal & Control),
to South
Africa, and Chile, and from there onto Iraq. The Iraqi borne designer of a chemicals weapons plant in
Lybia, set up shop in Florida, producing and shipping to Iraq chemical weapon components. The CIA,
FBI, and other U.S. agencies were made aware of the operation and did nothing to prevent it.
During the 1980s and into the 90s senior officials of both the Bush and Reagan Administration
encouraged the privatization of foreign policy, certainly towards Iran and Iraq. The policy may have
had merit - but there werent willing or in some instances werent successful in fighting it out in Capital
Hill so they found other ways. They made a mockery of the Export Control System, and they found
ways of encouraging foreign governments to do what our laws prohibited. They even knew or if not
were guilty of the grossest incompetence that U. S. companies were collaborating with foreign Arms
merchants in the illegal transfer of American Technology that helped Sadaam Hussein build is
formidable arsenal.
Page 9 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1307
305 of
of1299
2301
This week, the CIA again told ABC News Nightline that our allegations over the past few months
regarding covert operations to supply Iraq with U.S. Arms and weapons technologies simply were not
true.
The CIAs Inspector General said a statement from the Agency [On Screen] - Has found to factual
support whatsoever for such an operation or for the involvement of Mr. Gates.
[Ted Koppel] At least one member of the Senate Intelligence Committee, Bill Bradley of New
Jersey, feels that there may be reason to doubt both those claims, and hell raise the issues next week
during the Gates Confirmation Hearings, next week.
The CIA also told us that its Inspector General has found no evidence of any off-the-books illegal
activity.
But the CIA concedes, off-the-books activities, are not documented.
Precisely so that
deniability can be preserved.

One thing is undeniable, this gun sight video of a stealth fighter bomber from the 32nd Tactical Fighter
Wing, last February attacking a bomb factory, on the outskirts of Bagdad U.S. Technology in the air,
destroying U.S. Technology on the Ground. The factory was built by Carlos Cardoen.
For all of us here at ABC News, Good night.
END
Page 10 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1308
306 of
of1299
2301
ABC News Nightline - July 1991

[Ted Koppel] Carlos Cardoens role in shipping arms to Iraq has been known for years.
His
connection with Robert Gates has not. By the mid 1980s Cardoen was the largest private supplier of
weapons to Iraq.
In all he has believed to ship a half billion dollars worth of arms and advanced
technologies to Bagdad.
At a factory 500 miles north of Santiago, Cardoen produced tens of
thousands of bombs and other equipment, absolutely essentially to Iraq during its eight year war with
Iran.
The material would be loaded aboard regular Iraqi airway flights flown from Santiago to Bagdad.
Cardoen did not simply ship weapons, he set up entire factories capable of producing bombs and other
explosives the components would be shipped from all over the world and then assembled in Iraq. One
of those factories turned out Cluster Bombs.
As we first reported on the 24th of May, much of the sophisticated military technology that Cardoen
was shipping to Iraq came from the United States. This company in sleepy Lancaster, Pennsylvania, is
believed to be the source for some of the Cluster Bomb technology. But there was more.
Nasser
Bedouin is also an arms dealer. He acted as a middleman between Carlos Cardoen and Iraq.
[Nasser Bedouin on Video] I am aware of Carlos Cardoen getting some type of technology from
the air fuel bomb from the United States. I believe Iraq has a viable fuel air explosive.
[Ted Koppel] These explosives are designed to explode just above ground level like miniature
atomic bombs, literally sucking all available oxygen out of the air. It is clear that Carlos Cardoens
special relationship with the United States was not known by all Departments. When the Commerce
Department inquired about that relationship in early 1987, it received a cable from the U.S.
Ambassador to Chile saying although Cardoen is involved with the sale of armaments, and he has
made his fortune from it, he is considered to be a responsible recipient of U.S. products. In fact by
1987, the covert relationship between the CIA and Cardoen was already well established.
In 1983 the Reagan Administration had become alarmed at how poorly the Iraqi military was doing
against Iran. A decision was made at the highest level of Government to begin helping Iraq.
Indeed ABC News has learned only today, that around that time, in 1983 Ronald Reagan issued a
highly classified Presidential Finding stating that it was important to the National Interests that arms
and technical assistance be covertly funneled to Iraq
and with the help of the CIA.
More on the
significance of that Presidential Finding in a moment.
Page 11 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1309
307 of
of1299
2301
What it unleashed was a flood of US help to Iraq. A former CIA operative who was involved in the
program has told us of a series of covert operations, in which loads of 727s were flown into Iraq. On
one such mission in 1987 our source tells us he accompanied a planeload of Soviet built one hundred
twenty-two missiles.
The Soviet equipment was shipped because it would be compatible with what
the Iraqis already had. By 1987, there was at least one such flight a week into Bagdad.
Our former CIA source recalls bringing in $100 dollar bills in a bowling bag, they would also carry
whiskey, cartons of cigarettes and copies of Penthouse magazines to speed up the unloading process,
which usually took place at night.
Once the White House has authorized the Covert Assistance
Program to Iraq, the CIA took over. In effect the former CIA operative told us the covert operation
amounted to here is what we want you to do, and we really dont want to know too much about how
you do it.
Our source tells us that he has at least one meeting in 1986 in Florida between Robert Gates and
Carlos Cardoen, the Chilean Arms Dealer. Other sources have told us of other such meetings. Here in
the United States and in Europe. Which brings us to an unsolicited statement that was telephoned in
to Nightline from the Central Intelligence Agency almost a month ago on June 17th. Allegations, the
statement read that Robert Gates facilitated illegal shipments to Iraq during the 1980s are totally
without basis. Since we had never requested a statement of Mr. Gates, we didnt know quite what to
make of it at the time. But then today we learned of that Presidential Finding, authorizing the Covert
shipment of arms to Iraq.
It would be true then that Robert Gates did not facilitate illegal shipments to Iraq, under the
Presidential Finding, the shipments would have been quite legal.
But during this last set of
confirmation hearings, back in 1987, Robert Gates assured the Senate Confirmation Committee that he
would always keep the Committee current on ongoing covert operations. Indeed the CIA is supposed
to provide the Intelligence Committee with quarterly reports. According to well-informed sources on
the Committee it has had no briefings on the Covert arms pipeline to Iraq.
That, said one Senator on
the Committee would be a total breach of trust. What would it do to the Gates Nomination? I asked.
It would probably be enough said the Senator, to derail the Nomination.
Again, an excerpt from Mr. Gates Testimony before the Senate Intelligence Committee in 1987:
[Robert Gates 1987 on video] If you cannot have a system in which you can have some
confidence between A the branches of government, and confidence between the senior officials of the
Government, A that they abide by the rules, and B that they will deal with one another honestly, then
I think the system begins to collapse.
Page 12 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1310
308 of
of1299
2301
[Ted Koppel] Late this evening, the Whitehouse communicated its response to the charges
contained in this report, the Whole story is unfounded. There were never any sales; covert or overt
to Iraq or Iran through a third country. And Mr. Gates never met with Carlos Cardoen.
Well be back with more, in a moment.
[Ted Koppel] For the viewers, this is Alan Freidman, New York Correspondent for the Financial
Times of London, and a member of the team investigating Robert Gates. Alan Id like to begin by
repeating a statement, and let me put my specs on for a moment, the White House. This story is
unfounded and there were never any sales covert or overt to Iraq or Iran through a third country. And
Mr. Gates never met with Carlos Cardoen.
Ah, ah a fairly carefully drafted statement one would think.
[Alan Friedman, New York Correspondent for the Financial Times of London] Yes Ted, I
think that is right, I would agree with the statement that there were never any sales Iraq through a
third party.
Indeed what we found was that some of the cluster bomb technology and fuel air
technology was given smuggled down to Chile, for use that were used and made and shipped on
through to Iraq.
In terms of the um statement by the White House that there were never any
meetings between Mr. Gates and Mr. Cardoen, we have a number of sources, some of them personally
involved in these operations, one of them who was personally and physically an eye witness present at
a meeting, in Florida, with Mr. Gates and Mr. Cardoen in 1986. And who was told my Mr. Gates, about
other meetings that he had with Mr. Cardoen.
[Ted Koppel] Now Congressman Gejdenson, I realized that we sort of unleashed an awful lot of
material on you today, but to what degree does this fit in with those thousands of documents that you
subpoenaed with the information that you have?
[House Representative Sam Gejdenson of the House Foreign Affairs Committee] Well we
just got the documents after a several month battle with the Administration to pry them loose and it
took the vote of a subpoena by the subcommittee to start the flow of those documents, but its
certainly consistent with the information that we got with Committee staffs with some of those people
that said they were at those meetings, ah as well. I think that the important thing to remember here
is that the United States in 1982 under the Reagan Administration took Iraq off the terrorist list at a
time when some of the worst terrorist of the world were being harbored by Saddam Hussein, and we
suddenly changed our policy and continued to keep Iraq off the terrorist list, enabling the export of
dual use, ah items that can be used for dual use from the United States to Iraq, as well as these sales
that went indirectly to Iraq.
Page 13 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1311
309 of
of1299
2301
So, all through a time when they were harboring terrorists, and they killed 5,000 Kurds in 1988, and
as recent as six days before the invasion of Kuwait, when I and several members of Congress, tried to
stop the subsidy of grain sales to Iraq, the Bush Administration continued to impose any sanctions
against Iraq.
[Ted Koppel] Well of course theres a huge difference between grain sales and the shipment of
entire plants for the building of a cluster bomb factory.
[House Representative Sam Gejdenson of the House Foreign Affairs Committee] Except for
what I think you find is that a pattern by both the Bush and Reagan Administrations to trying to assist
Saddam Hussein. What we found at one Hearing was a document from the State Department, ah that
said that the United States was ready to sell weapons to Iraq as long as they were for the personal
protection of Saddam Hussein. A policy that ignored all the outrages, a policy that ignored I think the
intent of the Congress and the American People. And that the allegations that weve gotten from a
number of sources seem to be consistent with that. The United States did everything it could under
the Reagan and Bush Administrations to assist Saddam Hussein.
[Ted Koppel] Alan, I know that one of the things that we discovered in our investigations was and
Id like you to elaborate on it a little bit was that frequently there was Federal Agencies, Law
Enforcement Agencies that was trying to uncover what was going on we found that they were stymied
at every turn. Can you talk about a that a little bit?.
[Alan Friedman, New York Correspondent for the Financial Times of London] Yes I think
that if we look back at other discoveries that we made, you can say that when we found ISC, the
company in Lancaster, Pennsylvania, that was, that had cluster bomb technology, shipped down to
Chile that was part of this covert operation for Iraq, we found that the CIA had detailed knowledge
over a period of 4 years of all sorts of shipments from ISC to South Africa, some of which were later
trans shipped to Iraq, we found that Federal Law Enforcement Officers and Agencies were unable to do
anything about it because they just werent told. Likewise, we were just told of the case that the man
that built the Rapta Chemical Weapons plant in Libya, who ah, even though the CIA were tracking him
very carefully here in the United States, was allowed to build a chemical weapons plant here in Florida,
and shipped dangerous cyanide with the help of CIA Contract Shippers to Iraq.
All of these things
were going on and the investigators seem unable to do anything about any of these things. We seem
to have part of the Government trying to investigate, and part of the Government trying to ship.
[Ted Koppel] Congressman Gejdenson Id like to get your reaction to that and see if your
experiences have been similar in some of the findings that ah or some of the conclusions that you
have reached, but well take a break first and be back in just a moment.
Page 14 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1312
310 of
of1299
2301
[House Representative Sam Gejdenson of the House Foreign Affairs Committee] Well we
saw it ah from across all of the agencies. We had Dennis Kloskey who was then in charge of export
licensing at Commerce testify before our committee in April that he suggested to Mr. Gates and others
that ah meetings at White House to stop the export of dangerous technologies to Iraq. The following
day ah Mr. Kloskey resigned from the Government.
We were told by Mr. Kloskey that the White
House, the people in that room representing the President argued for a policy that assisted Saddam
Hussein in getting dual use technologies. We had Congressman Rose who I know has been on your
show testifying about the grain sales being tied up with funding weapons to Iraq as well. So across
the government, this thing went on. Its hard to believe that somebody like Mr. Gates in his position
didnt know about it.
[Ted Koppel] We are suggesting a lot more that he knew about it. Were suggesting that he was
actively involved in it let me just pass on a little information that we have gathered today, having to
do with the Confirmation Hearings and was told earlier this afternoon. Alan Fryers, Senior Officer with
the CIA and Clair George are not likely to be testifying voluntarily, indeed Alan Fryers said he will not
be testifying before the Senate Intelligence Committee.
The White House, as we have all heard
throughout the day is putting on some pressure to get those Hearings underway before the August
recess, August 2nd, of course, the Senate goes into recess. Ah, and there are indications now that a
week from Monday, indeed the Hearings will begin, Mr. Gates will be asked to testify at that time, but
Ive been also told that there is no way that the Hearing will no way be completed before the August
recess.
And that Mr. Gates will be told that he will be recalled again
after other witnesses have
testified, after the August recess. So these Hearing now, are destined to go into September.
[House Representative Sam Gejdenson of the House Foreign Affairs Committee] I think that
is terribly important, because we have to what we have to remember here, unlike other appointees of
the President, what the head of the CIA does is not transparent. If youre the Secretary of Housing,
like Jack Kemp is, and I disagree with one of his programs, not only do I know about it, but the
average citizen knows about what Jack Kemps doing. Sometimes you agree with it and sometimes
you disagree with him. In the case of the Director of the CIA, as is clear from repeated experiences,
often times even the people in Congress were suppose to know about these activities are not
informed. This has to do with National Security the standard ought not be somebody that can get by
the Hearing process with White House pressure. The White House ought to be with us on this one, we
ought to make sure that we have someone fully discloses what is going on to the appropriate
committees and to Congress. Not someone involved in Iran Contra and not someone who hasnt told
the entire truth. And not someone who is in question about these activities. This has to be a definitive
decision by the Congress, that this individual will come clean with the Congress and fulfill not just the
letter of the law, but the spirit of the law.
Page 15 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1313
311 of
of1299
2301
[Ted Koppel] Alright, let me just interrupt here for a moment, because were down to our last
minute and a half or so, Alan, it is inevitable in this kind of investigation that you run into a lot of
sleazy characters and I just want to get from you for our audience some sense of how much of the
information that we have compiled here comes from the sleazy characters and how much comes from
the few that we can really rely upon?
[Alan Friedman, New York Correspondent for the Financial Times of London] I think, ah Ted
the important thing to remember here is that we have had all kinds of allegations for the last three
months when our team has interviewed dozens of people, weve been acidulously cross checking and
weve waited to go ahead with this story until weve had very credible witnesses. Those who were
documented CIA operatives and those who were physically with Mr. Gates during those meetings, and
we asked some of them why would Mr. Gates take the risk and go out and meet with Mr. Cardoen and
get directly involved and get his hands dirty in these operations, especially as he was deputy director
of the CIA at the time himself.
We were told that he went out because he wanted to give his
improvtoire in order to make sure the job got done. Weve talked to a number of top people and cross
checked.
[Ted Koppel] Alright, Alan Friedman thank you very much, Congressman Gejdenson, thank you
very much, Ill be back in a moment.
END
Page 16 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1314
312 of
of1299
2301
Whistle-Blowing Activities Starting in June of 1987, local, state, and federal authorities were
called by Stanley J. Caterbone, including the Federal Bureau of Investigation, the Federal Securities
and Exchange Commission, Congressman Robert Walker, the Pennsylvania Attorney General, the
Lancaster District Attorney, Manheim Township Police, and a host of others.
The following is a memo of a meeting with ISC executive Mr. Lawrence Resch and Mr. Stanley J.
Caterbone at his office at Financial Management Group, Ltd., which took place on June 23, 1987. Mr.
Lawrence Resch, of San Clamente, California, was a long time associate of Mr. James Guerin who
worked as a marketing consultant, and was an ISC executive prior to the company going public in
1982. He served as Director of Marketing and head of Lancaster operations for then defunct United
Chem Con, an affiliate of ISC. He was sued by Ferranti International in 1990 for $189 million dollars
and indicted and found guilty by prosecutors for his role with ISC and served a jail term.
Upon the arrival of Mr. Larry Resch, Stan Caterbone met him in the lobby of Financial Management
Group, Ltd, at which time Larry Resch said "Carl Jacobson could not attend, we had to suddenly fly him
out of the country early this morning (flew to Chile) The meeting was started with the subject of the
financial difficulties of United Chem Con and possible alternatives. Larry Resch specifically addressed
the possibility of moving the operations of United Chem Con to another facility, with specific regards to
the Renovo Plant. Larry Resch specifically addressed the financing capabilities of Stan Caterbone,
along with possible management opportunities. Larry Resch also gave financial statements and
documents to Stan Caterbone for the latest fiscal year for United Chem Con. Stan Caterbone went on
to allege that United Chem Con had embezzled some $15,000,000 from the United States
Government for contracts that contained improprieties. Stan Caterbone also alleged improprieties of
International Signal & Control and James Guerin, with specific regards to its role in the United Chem
Con, and its business activities as related to government contracts. Stan Caterbone noted that he, as a
legal shareholder of International Signal & Control was concerned about improper business activities.
Larry Resch was taken by surprise by all of the above. Stan Caterbone became quite upset by the
evasiveness and the lack of specifics with regards to Larry Resch's conversation. In efforts to thwart
any further communication from James Guerin, United Chem Con, or International Signal & Control,
Stan Caterbone demanded a retainer fee of $10,000 before anyone contacted him again.
The following is a transcript of a meeting with Agent Howard Eisler, of the Pennsylvania Securities
Commission on September 29, 1987. The meeting was solicited at the bequest of Agent Howard Eisler
supposedly for an investigation into securities violations at Financial Management Group, Ltd.,
However, that also turned out to be untrue, or Agent Eisler also ignored all of the violations that
occurred at the company headquarters.
The meeting lasted approximately 4 hours at the residence of
Stanley J. Caterbone. Also present were attorney Mr. Robert Byers, and client of Stanley J. Caterbone,
Mr. Millard Johnson. Agent Howard Eisler, in November of 1987, requested that Stanley J. Caterbone
Page 17 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1315
313 of
of1299
2301
put any complaints or grievances in writing and never did anything with information or testimony from
the meeting.
[Stanley J.
Caterbone, ISC Shareholder; Founder Executive Vice President of Financial
Management Group, Ltd., and President of FMG Advisory, Ltd.,] - Chem Con is the big local
minority-held corporation that was doing a lot of Defense contracts-it was associated with ISC. They
went under last spring, beginning of the summer, and there was a lot of criminal allegations made,
none of them substantiated. And I was connected with that. They sent a board member in to see me a
week before this happened. Why. I don't know. Jim Christian owned it - now I hear rumors that I was
tied to ISC and I am close to several people in that organization. Why they sent someone in to
California to see me, I don't know. They wouldnt answer me. They wanted me to talk to a guy from
D.C., New York, a guy from the Caribbean. I don't know what the hell is going on.
[Mr. Robert Byer, Criminal Attorney for Stanley J. Caterbone] the supposition was - I don't
know how true it was a front for ISC.
[Stanley J.
Management Group, Ltd., and President of FMG Advisory, Ltd.,] - It was, I'll tell you why.
Because when Chem Con was started, back to their inception, you look at ISC's books. They didn't
have any money. Well, the fist thing Chem Con did was they went and got all that free money from
the government and you look where that money went. I bet I know where it went. This guy named
Guerin, James Guerin. And I know that they were selling contracts back. He runs ISC and he also has
his fingers pretty deeply into Chem Con. He's the one who started Chem Con, Guerin is the one who
started it.
[Mr. Millard (Bill) Johnson, Client of Mr. Stanley J. Caterbone] - Wasn't there some allegations
about a tie to Wedtech? (Defense Contractor of New York)
[Stanley J.
Management Group, Ltd., and President of FMG Advisory, Ltd.,] - You bet. They were tied, you'd
better believe they were tied with Wedtech. The same guys in Wedtech were invoked with ISC and
Chem Con.
ISC is sold over the London Exchange. (I bought my shares from Pennsylvania State
Senator Gibson Armstrong) I owned a thousand shares. I sold it when things started to hit the fanthey just did a multimillion dollar merger with a company in London. They probably think this is going
to cover their tracks. What they did was, they fronted all that money and started the contracts, went
bankrupt, and now the government is stuck for $18,000,000.
I know right now in this town's
viewpoint, I stole money, I am insane, and I am a lunatic I tell you I will not condemn Jim Christian
until he tells to my face what happened. "I was framed and set up. I dont know maybe Jim Christian
doesn't have the money. Maybe Guerin has it or somebody else has it.
Page 18 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1316
314 of
of1299
2301
__________________________________________________________________
ARGUMENT
__________________________________________________________________
Keith, 407 U.S. at 313-14. There, the Court explained that
[n]ational security cases . . . often reflect a convergence of First and Fourth Amendment values . . . .
Fourth Amendment protections become the more necessary when the targets of official surveillance
may be those suspected of unorthodoxy in their political beliefs. The danger to political dissent is acute
where the Government attempts to act under so vague a concept as the power to protect domestic
security.
Id. The Court thus concluded that Fourth Amendment freedoms cannot properly be guaranteed if
domestic security surveillances may be conducted solely within the discretion of the Executive Branch.
The Fourth Amendment does not contemplate the executive officers of Government as neutral and
disinterested magistrates. . . . The historical judgment, which the Fourth Amendment accepts, is that
unreviewed executive discretion may yield too readily to pressures to obtain incriminating evidence
and overlook potential invasions of privacy and protected speech. . . . [T]his Court has never sustained
a search upon the sole ground that officers reasonably expected to find evidence . . . and voluntarily
confined their activities to the least intrusive means . . . . The Fourth Amendment contemplates a prior
judicial judgment, not the risk that executive discretion may be reasonably exercised.
Page 19 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1317
315 of
of1299
2301
CERTIFICATE OF SERVICE
I hereby certify that on February 21, 2007, I have mailed by U.S. Postal Service, by electronic means, or by
facsimile the foregoing paper to the following (funds permitted) :
ANN BEESON
Attorney of Record
JAMEEL JAFFER
MELISSA GOODMAN (admission pending)
CATHERINE CRUMP (admission pending)
National Legal Department
American Civil Liberties Union Foundation
125 Broad Street, 18th Floor
New York, NY 10004-2400
(212) 549-2500
MICHAEL J. STEINBERG
KARY L. MOSS
American Civil Liberties Union Fund of Michigan
60 West Hancock Street
Detroit, MI 48201-1343
(313) 578-6814
Kate Martin
CENTER FOR NATIONAL SECURITY STUDIES
60 1 Thirteenth Street, N. W.
1120 19th Street, N.W.,
Washington, DC 20036
(202) 72 1-5650
Joseph Onek Erin N. Linder
Sharon Bradford Franklin
THE CONSTITUTION PROJECT
1025 Vermont Avenue,
(202) 580-6920
Donald B. Verrilli, Jr.
JENNER & BLOCK LLP
S. 800 Suite 1200 South
(202) 639-6095
JENNER & BLOCK LLP
330 N. Wabash Avenue
N. W. Chicago, IL 60611
(312) 222-9350
Randy Gainer
Davis Wright Tremaine LLP
1501 Fourth Avenue, Suite 2600
Seattle, WA 98101 - 1688
Lucy A. Dalglish, Esq.

Counsel of Record
Gregg P. Leslie, Esq.
Elizabeth J. Soja, Esq.
1101 Wilson Blvd., Suite 1100
Arlington, VA 22209-2211
(703) 807-2100
Attorneys for Amicus Curiae The Reporters
Committee for Freedom of the Press
Kathleen M. Sullivan
Derek L. Shaffer
Constitutional Law Center
Stanford Law School
559 Nathan Abbott Way
Stanford, California 94305-8610
ANN BEESON
Attorney of Record
JAMEEL JAFFER
MELISSA GOODMAN (admission pending)
SCOTT MICHELMAN (admission pending)
CATHERINE CRUMP (admission pending)
National Legal Department
American Civil Liberties Union Foundation
125 Broad Street, 18th Floor
New York, NY 10004-2400
(212) 549-2500
annb@aclu.org
David W. DeBruin
Theresa A. Chmara
Julie M. Carpenter
Michael B. DeSanctis
Wade B. Gentz
JENNER & BLOCK LLP
601 Thirteenth St., N.W., 12th Floor
Washington, D.C. 20005
tel. (202) 639-6000
fax (202) 639-6066
Margaret A. Costello
DYKEMA GOSSETT PLLC
400 Renaissance Center
Detroit, MI 48243
tel. (313) 568-5306
fax (313) 568-6893
Douglas N. Letter
Thomas N. Bondy
Anthony A. Yang
Attorneys, Appellate Staff
Civil Division, Room 7513
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Date: February 20, 2007
____________/s/________________
1250 Fremont Street
Lancaster, PA 17603
717-427-1821 facsimile
Page 20 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1318
316 of
of1299
2301
BAUSMAN MPO
Product
Descri p t i on
THANK YOU FOR SHOPPN

IG
WEIS MARKETS #41
CLUB CUSTOMER
Ite.
MC
r*rr
LANCASTER,p~
40041389011
Rice
1.49 F
1.49 F
1.OD-F
1.00-F
.OO BAL
.98
H8 VIENNA 60
HB VIENNA 80
COUPON 11009
MANUFACTURERCPN
TAX
Cash
CwGE
1.00
cowon savines. . .. . .. ... .. ..... .oZ
2.00
YOU- Total Savings are 6 7 . 1 1 ~ 2.00
2/20/07
.*r.
I,~>?~.?C;E
LaTIOh
TAX
Cash
E%S
06 B ~ L
Final
Price
LANCASTER PA 17604
First-Cless
1.50 oz.
PA
It$
Sales Receipt
Sale Unit
Qty Price
D
, .r i.ce
1.2, F
1.00 T
Issue PVI :
PHILADELPHIA PA 19101
First-Cl ass
1.30 oz.
2.27
2.27
.00
. Issue PVI:
2/18
DETROIT M I 48201
Fi rst-Cl ass
4.90 oz.
4:14 PM 0041201 0129 225
x
X
St
Issue PVI :
Total :
Paid by:
Cash
Change Due:
Bi l I # : 1000200788239
Clerk: 03
A l l sales f i n a l on stamps and postage.

Refunds for guaranteed services on1 y.
Thank you f o r your business.
January January
Sunday
22, 201722, 2017
Page
Page1319
317 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1320
318 of
of1299
2301
mailto:amgroup01@msn.com
717.427-1621 Fax
1250 Fremont Street
Lancaster, PA 17603
March 19, 2007

Eastern District Of Michigan Southern Division
The Clerk of The Court
Detroit, MI
Re:
Brief On Behalf Of Amici Curiae Stanley J. Caterbone And Advanced Media Group
In Support Of Plaintiffs Motion For Partial Summary Judgment
Dear Clerk of the Court:
Please see the attached for filing. On February 22, 2007, I did not have your address so I
forwarded the filing to the ACLU Office in Detroit with a note to please forward it to you for filing. I
have no way of confirming, so I am submitting another copy for you to file.
I thank you for your service in advance. If you require any additional information, please
contact me by email at the above address.
Respectfully,
Stan J. Caterbone
Pro Se Lititgant
Lancaster
NewJanuary
Era:2017
Dems'
inaction
January
Sunday
22,
22,
2017 on FISA harmful
http://eedition.lancasteronline.com/pages/news/edition/NEPM/2008...
Page
Page1321
319 of
of
1299
2301
Lancaster New Era

Dems' inaction on FISA harmful
It's things like this that make us wonder how serious some
Democrats are about confronting the terrorist threat on America.
The Democratic-led House let a crucial government-eavesdropping
law expire over the weekend before Congress began a 12-day
recess.
The eavesdropping won't end; it just makes the task that much
harder for our intelligence officials.
The House failed to adopt the bipartisan Senate version of the
Foreign Intelligence Surveillance Act, which would have renewed an
update of the law approved in August that makes it easier for the
government to spy on foreign phone calls and e-mails that pass
through the United States.
FISA, first adopted by Congress during the Cold War, would let the
government initiate wiretaps for up to one year. It also would
compel telecommunications to comply with wiretap orders while
shielding them from civil lawsuits that may be filed against them as
a result.
The provisions in the law have one purpose and one purpose only:
to protect the American people from further terrorist attacks.
"American citizens must understand, clearly understand that there's
still a threat on the homeland...," says President Bush. "We've got to
give our professionals the tools they need to be able to figure out
what the enemy is up to so we can stop it."
Some Democrats apparently don't see it that way. They downplay
FISA's expiration and accuse the president of fear-mongering and
misrepresenting the facts.
"This is not about protecting Americans. The president just wants to
protect American telephone companies," argues Rep. Rahm Emanuel
(D-Illinois), referring to the liability-protection provision that
insulates telecoms from lawsuits.
While the eavesdropping can continue, the compliance requirement
and liability protection for telecoms no longer apply. That means
telecoms' cooperation must be voluntary. And without the liability
protection, they're less likely to be so.
As a result, the government has to go back to the old way of getting
orders approved by the Foreign Intelligence Surveillance Court -- a
cumbersome process that ties intelligence agents up in red tape and
causes needless delay.
To get a court order, the government has to prove "probable cause"
before being allowed to tap a line inside the U.S. -- even if the
communication originates and ends in a foreign country. This is
difficult to do, and it takes time.
Indeed, by the time the government complies with the law, the
phone numbers or e-mails that it wanted to track could be obsolete.
"More than likely we would miss the very information we need to
prevent some horrendous act from taking place in the United States,"
says Mike McConnell, director of national intelligence.
1 of 2
2/19/2008 4:21 PM
Lancaster
NewJanuary
Era:2017
Dems'
inaction
January
Sunday
22,
22,
2017 on FISA harmful
http://eedition.lancasteronline.com/pages/news/edition/NEPM/2008...
Page
Page1322
320 of
of
1299
2301
The law does makes provisions for emergencies, but the paperwork
still must be completed within a few days.
Democrats who let the FISA law expire insist America is no less safe
from another terrorist attack. But can they be so sure?
The only thing certain is that Americans are not now getting the full
benefit of FISA protection. This is unacceptable.
We should be protecting the American people, not the terrorists.
The eavesdropping won't end; it just makes the task that much
harder for our intelligence officials.
2004-2007 Lancaster Newspapers

2 of 2
2/19/2008 4:21 PM
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
41299
Filed 06/23/15
Page 1 ofLAMBERT
52
Page
Page1323
321 of
of
2301
Stan J. Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
41299
Filed 06/23/15
Page 2 ofLAMBERT
52
Page
Page1324
322 of
of
2301
Stan J. Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
41299
Filed 06/23/15
Page 3 ofLAMBERT
52
Page
Page1325
323 of
of
2301
Stan J. Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
41299
Filed 06/23/15
Page 4 ofLAMBERT
52
Page
Page1326
324 of
of
2301
Stan J. Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
41299
Filed 06/23/15
Page 5 ofLAMBERT
52
Page
Page1327
325 of
of
2301
Stan J. Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
41299
Filed 06/23/15
Page 6 ofLAMBERT
52
Page
Page1328
326 of
of
2301
Stan J. Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
41299
Filed 06/23/15
Page 7 ofLAMBERT
52
Page
Page1329
327 of
of
2301
Stan J. Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
41299
Filed 06/23/15
Page 8 ofLAMBERT
52
Page
Page1330
328 of
of
2301
Stan J. Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
41299
Filed 06/23/15
Page 9 ofLAMBERT
52
Page
Page1331
329 of
of
2301
Stan J. Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
10 ofLAMBERT
52
Page
Page1332
330 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
11 ofLAMBERT
52
Page
Page1333
331 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
12 ofLAMBERT
52
Page
Page1334
332 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
13 ofLAMBERT
52
Page
Page1335
333 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
14 ofLAMBERT
52
Page
Page1336
334 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
15 ofLAMBERT
52
Page
Page1337
335 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
16 ofLAMBERT
52
Page
Page1338
336 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
17 ofLAMBERT
52
Page
Page1339
337 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
18 ofLAMBERT
52
Page
Page1340
338 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
19 ofLAMBERT
52
Page
Page1341
339 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
20 ofLAMBERT
52
Page
Page1342
340 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
21 ofLAMBERT
52
Page
Page1343
341 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
22 ofLAMBERT
52
Page
Page1344
342 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
23 ofLAMBERT
52
Page
Page1345
343 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
24 ofLAMBERT
52
Page
Page1346
344 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
25 ofLAMBERT
52
Page
Page1347
345 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
26 ofLAMBERT
52
Page
Page1348
346 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
27 ofLAMBERT
52
Page
Page1349
347 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
28 ofLAMBERT
52
Page
Page1350
348 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
29 ofLAMBERT
52
Page
Page1351
349 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
30 ofLAMBERT
52
Page
Page1352
350 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
31 ofLAMBERT
52
Page
Page1353
351 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
32 ofLAMBERT
52
Page
Page1354
352 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
33 ofLAMBERT
52
Page
Page1355
353 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
34 ofLAMBERT
52
Page
Page1356
354 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
35 ofLAMBERT
52
Page
Page1357
355 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
36 ofLAMBERT
52
Page
Page1358
356 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
37 ofLAMBERT
52
Page
Page1359
357 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
38 ofLAMBERT
52
Page
Page1360
358 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
39 ofLAMBERT
52
Page
Page1361
359 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
40 ofLAMBERT
52
Page
Page1362
360 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
41 ofLAMBERT
52
Page
Page1363
361 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
42 ofLAMBERT
52
Page
Page1364
362 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
43 ofLAMBERT
52
Page
Page1365
363 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
44 ofLAMBERT
52
Page
Page1366
364 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
45 ofLAMBERT
52
Page
Page1367
365 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
46 ofLAMBERT
52
Page
Page1368
366 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
47 ofLAMBERT
52
Page
Page1369
367 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
48 ofLAMBERT
52
Page
Page1370
368 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
49 ofLAMBERT
52
Page
Page1371
369 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
50 ofLAMBERT
52
Page
Page1372
370 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
51 ofLAMBERT
52
Page
Page1373
371 of
of
2301
Stan J. Page
Caterbone
CASE FILE
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
4 1299
Filed 06/23/15
52 ofLAMBERT
52
Page
Page1374
372 of
of
2301
Stan J. Page
Caterbone
CASE FILE
January January
Sunday
22, 201722, 2017
Page
Page1375
373 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1376
374 of
of1299
2301
Stan J Caterbone
Project Hope Foundation
1250 Fremont Street
Lancaster, PA 17603
IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY,

PENNSYLVANIA
CIVIL DIVISION
IN RE:
MEGHAN . LIAPPATT V
:
:
Docket No. CI-08-04781
CD 6 208A
AMICUS CURIAE IN SUPPORT OF A CLOSED HEARING

AND NOW comes before the said court Stanley J. Caterbone, appearing Pro Se,
Project Hope Foundation, and Advanced Media Group, as Movant, to file an Amicus in the above
captioned case.
The Movant has an interest in this case as Project Hope being an advocate and a 501
(3) ( c ) non-profit foundation focusing in mental health issues and mental health awareness;
Stanley J. Caterbone and Advanced Media Group having similar mental health issues before the
courts with a history and experience of how misaligned community attitudes towards persons labeled
with mental health problems can carry an unnecessary and costly burden and stigma.
This amicus provides a voice for the movants 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
opinion and ORDER of James P. Cullen of July 11, 2008 which ruled against a closed hearing.
Stanley J. Caterbone appeared pro se before a 7303 Section 303 Of The Pennsylvania
Mental Health Procedures Act P.S. 7303 hearing in the Lancaster General Hospital on April 7,
2006 and had a successful conclusion in arguing against commitment and treatment. Stanley
J. Caterbone was released after a 5-day evaluation, which is also being challenged in the
courts.
July 21, 2008 _________
Respectfully Submitted:
__________________
__________________
SSS
1250 Fremont Street
Lancaster, PA 17603
Page 1 of 35
January January
Sunday
22, 201722, 2017
Page
Page1377
375 of
of1299
2301
TABLE OF CONTENTS
1. BACKGROUND OF MOVANTS
Page 3
a. Stanley J. Caterbone
b. Project Hope
c. Advanced Media Group
2. PREFACE TO ISSUES BEFORE THE COURT
Page 7
3. ISSUES BEFORE THE COURT
Page 8
a. I) Should The Hearing On The Commonwealths Amended Petition Under

Section 304 Of The Pennsylvania Mental Health Procedures Act P.S. 7304 Is
Open To The Public?
b. II) Did The Court Give Due Consideration To The Claims By Meghan Lippiatt
Regarding Retaliation By The Public During And After A Public Hearing On
The Issues?
4. CONCLUSION _
Page 11
5. CERTIFICATE OF SERVICE
Page 12
6. EXHIBITS ___
Page 13
a. Jonathon Turley Post of December 13, 2007
Page 13
b. Biography of Jonathan Turley
Page 16
c. Conditional Release and Mandated Outpatient Treatment

By George F. Parker, M.D.
Page 29
d. Griffin PA, Steadman HJ, Heilbrun K

e.
A Look Behind the Scenes of HIPAA and the

Privacy Rule
f.
Page 22
Page 24
Federal Oversight of Psychiatric Records:

The Health Insurance Portability and Accountability Act
Page 28
g. More protections for patients and psychologists

under HIPAA
Page 33
Page 2 of 35
January January
Sunday
22, 201722, 2017
Page
Page1378
376 of
of1299
2301
BACKGROUND OF MOVANTS
Stanley J. Caterbone (CATERBONE)
CATERBONE has been following very closely the case of Meghan Lippiatt and was a witness
to the trial on one of the few last days before the Honorable Judge James P. Cullen in the
Lancaster County Court of Common Pleas to hear the testimony of Psychiatrist Dr. Gotlieb of the
Lancaster General Hospital.
CATERBONE had also written a response on the blog of nationally
known law expert and constitutional scholar Jonathan Turnley on December 19, 2007 days after
the conclusion of the trial. Jonathan Turley, like other national experts, had posted an opinion on
the Lippiatt case after the verdict and conclusion of the trial. The response is EXHIBIT A.
CATERBONE has been involved with Project Hope Foundation for more than 10 years and
has conducted extensive research in the field of mental illness and has been an advocate for
mental illness for almost 3 decades.
Mental illness has been an issue in his family since the
1960s and has been an extremely challenging dilemma resulting in the untimely and suspicious
deaths of two brothers in their 30s.
His oldest brother died in Santa Barbara, California on
Christmas day of 1984 with the death being ruled a suicide, but now known to have been a
murder. In 1996 his youngest brother, Tom had committed suicide and the circums tances are
currently being litigated in the federal courts as a wrongful death complaint.
CATERBONE has
researched and investigated the causes of both deaths as it relates to the issue of mental illness
and has conducted research and instigations into his own malicious diagnosis of his own mental
health record. His father, Samuel, has a history of mental health records however; he too has a
history of psychic phenomena and a history of suspicious activities with the United States
Government and the Lancaster community. His mental health record is also in dispute. He was a
very successful businessman and had served in the U.S. Navy as a radioman and graduated from
gunner school with honors. He also developed new technologies for the Dry Cleaning industry. He
has also conducted extensive research into areas concerning U.S. Government activities.
CATERBONE has developed relationships with mental health professionals for his work with
Project Hope and has been the main person responsible for coordinating and administrating the
mission of creating awareness and education to the community-at-large with the distribution of
Project Hopes video Numbers Dont Lie; including to the Mental Health and Retardation
Department of the County of Lancaster this past year. CATERBONE has worked extensively with
Contact Lancaster, the Mental Health Alliance of Lancaster County, and other mental health
organizations as well faith based organizations.
CATERBONE had dealings with national
professionals and organizations in the field; especially since C. EvreTt Koop, the former U.S.
Surgeon General and Tipor Gore made mental health awareness a top priority in 1998. Tipor Gore
also received the Project Hope video for distribution as a resource for other non-profit
organizations. CATERBONES research includes national and local trends of suicides; symptomatic
Page 3 of 35
January January
Sunday
22, 201722, 2017
Page
Page1379
377 of
of1299
2301
behavior in bi-polar and manic depression; and the issues and stigma confronting those affected
with mental illnesses.
CATERBONE brings a unique perspective to the courts that may help to shed light into how
people with mental illnesses are treated unfairly by family, friends, and the community-at-large.
It should be noted that CATERBONE is also telepathic with a history of psychic traits in his family
dating back 2 generations. CATERBONE is currently engaged in extensive litigation challenging his
own mental health record, treatment, and diagnosis in federal and state courts. His own mental
health record includes 2 fabricated suicide stories that are part of the record in hospitals and with
police departments; this is in addition to the 30 false arrests. Mental health and criminal records
can be very damaging in destroying a persons credibility and reputation and ultimately his
professional and personal life if not respected by all.
CATERBONE is presently the founder of Advanced Media Group and conducts his business
from Lancaster County, Pennsylvania. For the past several years, in addition to appearing before
the courts as a pro se litigator, Advanced Media Group has been developing several business
interests in the revitalization of downtown Lancaster,
Those projects include a downtown UPS
Copy and Shipping Store; the Theater at Hotel Brunswick; and the Excelsior Place Business Plan,
In 2006 CATERBONE began his role as an Activist Shareholder for Fulton Financial, which
is listed as "FULT" on the NASDAQ stock exchange. As a founder of Financial Management Group,
Ltd., a full service financial firm, CATERBONE has drawn upon the success in developing the
strategic vision for his company and the experience gained in directing the legal affairs and public
offering efforts in dealing with Fulton Financial.
In 2005 CATERBONE, as a Pro Se Litigant filed several civil actions as Plaintiffs that are in
current litigation in the United States District Court for the Eastern District of Pennsylvania, the
United States Third District Court of Appeals, the Pennsylvania Supreme Court, The Pennsylvania
Superior Court, the Commonwealth Court of Pennsylvania, The Court of Common Pleas of
Lancaster County, Pennsylvania. These litigations include violations of intellectual property rights,
anti-trust violations, and interference of contracts relating to several business interests. Central to
this litigation is the Digital Movie, Digital Technologies, Financial Management Group, Ltd,/FMG
Advisory, Ltd., and its affiliated businesses along with a Federal False Claims Act or Federal
Whistleblowers Act regarding the firm of International Signal and Control, Plc., (ISC) the $1Billion
Dollar Fraud and the Export violations of selling arms to South Africa and Iraq. This litigation dates
back to 1987. CATERBONE was a shareholder of ISC, and was solicited by ISC executives for
professional services. The Federal False Claims Act is currently part of RICO Civil Complaint in the
United States District Court for the Eastern District of Pennsylvania and the Third Circuit Court of
Appeals, as docket no. 05-2288.
Page 4 of 35
January January
Sunday
22, 201722, 2017
Page
Page1380
378 of
of1299
2301
A complete biography and history is located on the website of Advanced Media Group at:
PROJECT HOPE
Project Hope Foundation was founded in 1996 after the untimely suicide of Thomas P. Caterbone,
brother of Stanley J. Caterbone.
Project Hope was initially formed by another brother, Dr. Phillip
W. Caterbone of Austin Texas, and other friends and relatives that wanted to continue the legacy
of Tom Caterbone and make a contribution to the community-at-large in dealing with mental
health issues and mental health awareness.
In 1996 Project Hope Foundation produced the extremely successful instructional video Numbers
Dont Lie for helping teenagers deal with suicide and help them to identify kids which may be at
risk. The video was produced and directed by Dr. Phil Caterbone & Psychologist Craig Crabtree,
both of Austin, Texas. The video is a approximately 20 minutes and is accompanied by an
instructional workbook for the monitors and a workbook for the students. "Numbers Don't Lie"
has been sold to the Texas School Board of Education to pay for its development and production.
The video has been provided to other Faith Based non-profit organizations, school districts, church
groups, and municipalities by CATERBONE and Advanced Media Group over the past 10 years.
The video can be viewed online at: www.advancedmediagroup.youtube.com and clic king on the
Numbers Dont Lie video.
Project Hope provided funding for the Mental Health Alliance of Lancaster County, Contact/Lifeline
of Lancaster (The 24/7 Suicide Hotline), The Schreiber Pediatric Center, and other charitable
organizations and faith based charities. In 1999 Project Hope donated and constructed a soccer
field on the new Headquarters of the Schreiber Pediatric Center on Goods Road, in Lancaster.
Tom's Project Hope is funded by an annual golf tournament on the 1st Saturday in August, called
the Tommy Caterbone Memorial Golf Tournament.
The Lancaster County Mental Health/Mental Retardation department is currently using the video
as a resource Mental Health/Mental Retardation Department.
In 1989 CATERBONE founded Advanced Media Group, Ltd., which was one of only 4 or 65
U.S. domestic companies that had the capability to manufacture CD-ROM's.
Advanced Media
Group also developed tools, applic ations, and provided consulting to information technologies.
Page 5 of 35
January January
Sunday
22, 201722, 2017
Page
Page1381
379 of
of1299
2301
Advanced Media did business with commercial companies, government agencies, educational
institutions, and foreign companies including the Department of Defense; NASA, National
Institution of Standards & Technology (NIST); Department of Defense, The Defense Advanced
Research Projects Agency (DARPA); and the Defense Mapping Agency, Central Intelligence
Agency; (CIA), IBM; Microsoft, AMP; Commodore Computers, American Bankers Bond Buyers;
and a host of others. I also was working with R.R, Donnelly's Geo Systems; which was developing
various interactive mapping technologies, which is now a major asset of Map Quest. Map Quest is
the premier provider of mapping software and applications for the Internet and is often used in
delivering maps and directions for Fortune 500 companies.
Advanced Media Group now has interests in various business and fields including the film and
entertainment industries; information technologies; revitalizations of downtown Lancaster;
Research and Study in Mind Control and ESP; and the fulfillment and distribution of past
intellectual property assets.
PREFACE TO ISSUES BEFORE THE COURT1
Upon the verdict of the lower court trial of not guilty by reason of insanity, CATERBONE
posed the question of why a condition for release of a psychiatric evaluation was not issued by
presiding Judge James P. Cullen. This is evident in the Jonathan Turley Post of December 19,
2007 which states the following:
Here is a brief synopsis; In the VERDICT ORDER there did not seam
to be any condition for Ms. Liappatt to be held in custody until a
further psychiatric evaluation could be performed. This set in motion
a number of court filings by the District Attorney, the Defense
Counsel, and others trying to recommit her to a treatment facility.
There has been much research done on the subject of conditional releases in not guilty by
reason of insanity cases throughout this country and most all have concluded that conditional
releases are a very acceptable and successful legal alternative to quell the public fear and
animosity of persons getting away with murder.
In most cases the person is subject to a
variety of post verdict mental health treatment plans that may include community participation
The legal opinion of Stan J. Caterbone was formulated on or before December 19, 2007 prior
to conducting any research on the topic or using any internet search engine to define the words
conditional release or any similar terminology. Stan J. Caterbone again is suspicious of the
dates of the post on the Jonathan Turley blog of December 19, 2007. The post may have been
posted prior to that date.
Page 6 of 35
January January
Sunday
22, 201722, 2017
Page
Page1382
380 of
of1299
2301
until it can be proven by a certified psychiatrist that the person no longer poses any threat to
society before being released into the community.2 3
ISSUES BEFORE THE COURT
1. WETHER THE HEARING ON THE COMMONWEALTHS AMENDED PETITION UNDER
SECTION 304 OF THE PENNSYLVANIA MENTAL HEALTH PROCEDURES ACT P.S. 7304 IS
OPEN TO THE PUBLIC.
2. DID THE COURT GIVE DUE CONSIDERATION TO THE CLAIMS BY MEGHAN LIPPIATT
REGARDING RETALIATION BY THE PUBLIC DURING AND AFTER A PUBLIC HEARING ON
THE ISSUES.
I) SHOULD THE HEARING ON THE COMMONWEALTHS AMENDED PETITION UNDER

SECTION 304 OF THE PENNSYLVANIA MENTAL HEALTH PROCEDURES ACT P.S. 7304
IS OPEN TO THE PUBLIC?
Section 304 of the Pennsylvania Mental Health Procedures Act P.S. 7304
7304. Court-Ordered Involuntary Treatment Not To Exceed Ninety Days.

(a) Persons for Whom Application May be Made.-1. A person who is severely mentally disabled and in need of treatment, as
defined in section 301(a), may be made subject to court-ordered
involuntary treatment upon a determination of clear and present danger
under section 301(b)(1) (serious bodily harm to others), or section
301(b)(2)(i) (inability to care for himself, creating a danger of death or
serious harm to himself), or 301(b)(2)(ii) (attempted suicide), or
301(b)(2)(iii) (self- mutilation).
2. Where a petition is filed for a person already subject to involuntary
treatment, it shall be sufficient to represent, and upon hearing to
reestablish, that the conduct originally required by section 301 in fact
occurred, and that his condition continues to evidence a clear and present
danger to himself or others. In such event, it shall not be necessary to
show the reoccurrence of dangerous conduct, either harmful or
debilitating within the past 30 days.
2
Geoge M. Parker, MD Under conditional release, such acquittees are released into the
community with various conditions imposed; for example, they are often required to live in
specified housing and not to use illegal drugs. They remain under the jurisdiction of a criminal
judge or a central monitoring agency, such as a psychiatric security review board. Adherence to
mental health treatment in the community is almost always a condition of release. As leverage,
this type of mandated community treatment uses both avoidance of jail and avoidance of
hospitalizationboth a brief jail stay and rehospitalization are possible consequences of
violation of the conditions of release, depending on the state. See Exhibit B.
3
See Exhibits A thru D.
Page 7 of 35
January January
Sunday
22, 201722, 2017
Page
Page1383
381 of
of1299
2301
(c) Procedures for Initiating Court-ordered Involuntary Treatment for

Persons Not in Involuntary Treatment.-1. Any responsible party may file a petition in the court of common pleas
requesting court-ordered involuntary treatment for any person not
already in involuntary treatment for whom application could be made
under subsection (a).
2. The petition shall be in writing upon a form adopted by the department
and shall set forth facts constituting reasonable grounds to believe that
the person is within the criteria for court-ordered treatment set forth in
subsection (a). The petition shall state the name of any examining
physician and the substance of his opinion regarding the mental condition
of the person.
3. Upon a determination that the petition sets forth such reasonable cause,
the court shall appoint an attorney to represent the person and set a date
for the hearing as soon as practicable. The attorney shall represent the
person unless it shall appear that he can afford, and desires to have,
private representation.
4. The court, by summons, shall direct the person to appear for a hearing.
The court may issue a warrant directing a person authorized by the
county administrator or a peace officer to bring such person before the
court at the time of the hearing if there are reasonable grounds to believe
that the person will not appear voluntarily. A copy of the petition shall be
served on such person at least three days before the hearing together
with a notice advising him that an attorney has been appointed who shall
represent him unless he obtains an attorney himself, that he has a right
to be assisted in the proceedings by an expert in the field of mental
health, and that he may request or be made subject to psychiatric
examination under subsection (c)(5).
5. Upon motion of either the petitioner or the person, or upon its own
motion, the court may order the person to be examined by a psychiatrist
appointed by the court. Such examination shall be conducted on an
outpatient basis, and the person shall have the right to have counsel
present. A report of the examination shall be given to the court and
counsel at least 48 hours prior to the hearing.
6. Involuntary treatment shall not be authorized during the pendency of a
petition except in accordance with section 302 or section 303.
(e) Hearings of Petition for Court-order Involuntary Treatment.--A
hearing on a petition for court-ordered involuntary treatment shall be conducted
according to the following:
1. The person shall have the right to counsel and to the assistance of an
expert in mental health.
2. The person shall not be called as a witness without his consent.
3. The person shall have the right to confront and cross-examine all
witnesses and to present evidence in his own behalf.
4. The hearing shall be public unless it is requested to be

private by the person or his counsel.
5. A stenographic or other sufficient record shall be made, which shall be
impounded by the court and may be obtained or examined only upon the
Page 8 of 35
January January
Sunday
22, 201722, 2017
Page
Page1384
382 of
of1299
2301
request of the person or his counsel or by order of the court on good

cause shown.
6. The hearing shall be conducted by a judge or by a mental health review
officer and may be held at a location other than a courthouse when doing
so appears to be in the best interest of the person.
A decision shall be rendered within 48 hours after the close of evidence.
Under Section (e) 4. of the Section 304 of the Pennsylvania Mental Health Procedures
Act P.S. 7304 it clearly states the following:
The hearing shall be public unless it is requested to be
private by the person or his counsel.
In Judge James P. Cullen ORDER and OPINION of July 11, 2008 Judge Cullen appears to
be abusing his discretion by mandating a higher burden and threshold for showing good cause
why Ms. Lippiatt is entitled to her request of a closed hearing. It also appears that Judge Cullen
is trying to pacify the public interest and outcry when Meghan Liappitts was released at the
conclusion of her trial, which should have been addressed with a condition for release, which
Judge James P. Cullen failed to address in his VERDICT ORDER of December 13, 2008.
HIPAA CONSIDERATIONS
The privacy laws of health records addressed with the passage if the Health Information
Portability and Accountability Act (HIPAA) in 1996 may have some controlling interest in these
matters. A summary of HIPAA is as follows:
A major upshot of the Health Insurance Portability and Accountability Act
(HIPAA) of 1996 is a series of federal rules that have a considerable impact on
providers and patients their interactions, their rights, and their responsibilities.
In sorting through the details and compliance requirements of the privacy rule in
particular, it helps for practitioners to know something of the historical and
political context in which HIPAA and the rules that resulted from this law took
shape.
Under HIPAA, Congress tasked the Department of Health Human Services (HHS)
with developing federal rules that govern how patient records are handled,
shared, and protected in the health care system. The transactions rule, the
first rule promulgated by HHS, provides for standard formatting of electronic
patient records for health care claims and other purposes. This rule benefits
health professionals by making it easier for them to work with uniform rather
than multiple claims forms. While more rules will follow, the 800-pound gorilla
of the series, the privacy rule, was finalized last April. The privacy rule
provides some important protections for psychology records, with provisions that
will impact the confidentiality of the psychologist-patient relationship. 4
See Exhibit F: A Look Behind the Scenes of HIPAA and the Privacy Rule by Doug Walter, J.D.
Page 9 of 35
January January
Sunday
22, 201722, 2017
Page
Page1385
383 of
of1299
2301
An Open Hearing would be placing mental health records in the public domain
and may be a violation of the rights of Ms. Lippiatt as defined in the HIPAA code.
The general public really has no interest in the process or the Section 304 of the
Pennsylvania Mental Health Procedures Act P.S. 7304 hearing, but rather has an interest in the
conclusion of the hearing in protecting itself from someone whom may pose a danger or threat
to others. That danger and or threat to the community-at-large is not compromised nor is it
supported by an open hearing. That danger and or threat is only of importance and relevant if
Ms. Lippiatt is found to have a mental health illness and is not committed for treatment. The
question of an open or closed hearing is not relevant, only the conclusion of the matters that
will be presented to the courts.
II) DID THE COURT GIVE DUE CONSIDERATION TO THE CLAIMS BY MEGHAN LIPPIATT
REGARDING RETALIATION BY THE PUBLIC DURING AND AFTER A PUBLIC HEARING ON
THE ISSUES?
Stanley J. Caterbone has been subject to an unprecedented history of retaliation and
intimidation that has been the result of a stigma due to his mental health record. Although this
mental health records validity and authenticity is being challenged in several courts, the stigma
and treatment by the community-at-large is real and can be used to substantiate Ms. Lippiatts
claim of retaliation in her opposition to an open hearing. Subjecting Ms. Lippiatt to unnecessary
intimidation and retaliation for information that would be made public during an open hearing is of
concern to all who may face similar circumstances.
Stanley J. Caterbone has a criminal record of some 30 false arrests in Lancaster County
that would have never been possible without his mental health record. Law enforcement relied
upon the fact that Stanley J. Caterbone had a history and mental health record to discredit him
before the courts, in his arrests, although he was successful in having those arrests and
convictions dismissed and overturned.
Stanley J. Caterbone also must endure a systematic and problematic attack of harassment
in public that is also due to the same mental health record and his fabricated and diminished
reputation caused by the same.
The fact that Ms. Lippiatt was found not guilty by reason of insanity of murdering her small
children should compel the court to consider her claims of retaliation more seriously. If the courts
do no recognize the risks involved to Ms. Lippiatt and others that may come before the courts in
similar circumstances, the courts should be compelled to provide the burden of proof that would
Page 10 of 35
January January
Sunday
22, 201722, 2017
Page
Page1386
384 of
of1299
2301
be considered in closing the hearing for the same said reasons.
CONCLUSION
The Lippiatt case is apparently precedent in the County of Lancaster of a person being found
not guilty by reason of insanity. That being the case, the court should take extra precaution in
protecting all parties in all related matters and should be careful when reaching opinions and
conclusion that will be precedent to future and similar parties that will come before the courts.
Judge Cullens ORDER and OPINION of July 11, 2008 fails to protect the rights of Ms. Lippiatt
and others that may come before the courts, but does so unnecessarily. Closing the hearing to
the general public would not diminish the public interest, nor would it make the general public
safer. Only a conclusion of an involuntary commitment of Ms. Lippiatt IF she does now possess a
mental health illness that does pose a threat or danger to others.
July 21, 2008 _________
__________________
__________________

1250 Fremont Street
Lancaster, PA 17603
Page 11 of 35
January January
Sunday
22, 201722, 2017
Page
Page1387
385 of
of1299
2301
Service was made on this 21s t day of July 2008 upon the following by way of electronic
mails; first class U.S. mails; or personal delivery at the addresses set forth below:
Kelley M. Sekula, Esq, ADA

Lancaster County District Attorney Office
Lancaster County Courthouse
50 N. Duke Street
Lancaster, PA 17602
Julie M. Cooper, Esq.,
Street: 222 South Market Street
Elizabethtown, pa 17022-2439
Phone: (717) 367-1370
George C. Werner, Esq.,
Barley Snyder, LLC
126 East King Street
Lancaster, PA 17602
Alspach & Ryder (Ryder, Bruce P)
232 N Duke St
Lancaster, PA 17602-5205
Phone: (717) 393-3939
July 21, 2008 _________
__________________
__________________
Stanley J Caterbone, Pro Se

1250 Fremont Street
Lancaster, PA 17603
Page 12 of 35
January January
Sunday
22, 201722, 2017
Page
Page1388
386 of
of1299
2301
EXHIBIT A
Page 13 of 35
January January
Sunday
22, 201722, 2017
Page
Page1389
387 of
of1299
2301
The following can be viewed online at: http://jonathanturley.org

And search on LIPPIATT
Pa. Woman Who Killed Her Two Children Found Not Guilty by
Reason of Insanity
Published 1, December 11, 2007 Criminal law , Justice by Jonathan Turley
Meghan Lippiatt has been found not guilty by reason of insanity in a Lancaster court. Lippiatt
admitted suffocating her infant son and drowning her 2-year-old son in 2004.
The killing two-year-old Silas and his four- month-old brother Miles occurred weeks after a
break-up with her husband.
Lippiatt called 911 and told the operator: I did something really bad, I just killed my kids.
She later tried to kill herself and left a note which read: I am sorry, I didnt want to hurt
anyone. I am sorry, goodbye, please help me from the grave.
There is growing interest in allowing greater use of the insanity defense after it was heavily
curtailed after the shooting of President Ronald Reagan.
For a prior column on the insanity defense, click here
For the full story, click here
Response to Pa. Woman Who Killed Her Two Children Found

Not Guilty by Reason of Insanity
CATERBONE of Advanced Media Group wrote:
December 19, 2007
Dear Mr. Turley,
First of all I always look for your opinion when issues are looking for expert constitutional
scholars. I have been an avid learner of your opinion for many, many years.
Regarding this case, I dont know if you are aware, but there was a problem and fiasco after
the trial and wondered what your opinion was. She was freed immediately after her bench trial
upon a Habeas corpus filed by her defense counsel. See the following news account:
Here is a brief synopsis; In the VERDICT ORDER there did not seam to be any condition for Ms.
Liappatt to be held in custody until a further psychiatric evaluation could be performed. This set
in motion a number of court filings by the District Attorney, the Defense Counsel, and others
trying to recommit her to a treatment facility.
The following was my ema il to someone regarding my suspicion, I have later found that
temporary insanity, if in his verdict would free her immediately after trial:
December 18, 2007
To Ron Harper of http://www.5thestate.com
Are you following this case at all? This is truly a first class Lancaster County
smoke and mirrors game?
Page 14 of 35
January January
Sunday
22, 201722, 2017
Page
Page1390
388 of
of1299
2301
This is my analysis. And for the record, I did attend the trial and sat to hear
Gottlieb, the psychiatrist testify and be cross-examined. I have also studied
mental health issues for Project Hope, for my own case, and for my familys
different cases, especially my father and brothers Sam and Tom; for over 20
years. So I am not uneducated with the issues.
Being that this is the first such verdict of not guilty by reason of insanity in
Lancaster County, as reported, I think this whole case was purposely
mismanaged so that the next time such a verdict is before a Lancaster County
jury, they can say see, if you find the defendant not guilty by insanity, that
person may be released and freed without any treatment or conditions.
I think Judge Cullen should have to explain why he did not issue a
condition in his verdict to have Ms. Lippiatt held in Lancaster County
Prison or transferred to a mental health facility until the outcome of a
psychiatric evaluation. I dont understand why he did not do this, unless
the law prevented him from doing that. I will have to research this.
I would love to hear your opinion, if you find the time. Hope to meet you in the
future.
STAN J. CATERBONE
Page 15 of 35
January January
Sunday
22, 201722, 2017
Page
Page1391
389 of
of1299
2301
EXHIBIT B
Page 16 of 35
January January
Sunday
22, 201722, 2017
Page
Page1392
390 of
of1299
2301
Bio of JONATHAN TURLEY

Professor Jonathan Turley is a nationally recognized legal scholar who has written extensively
in areas ranging from constitutional law to legal theory to tort law. He has written over three
dozen academic articles that have appeared in a variety of leading law journals at Cornell,
Duke, Georgetown, Harvard, Northwestern, and other schools.
After a stint at Tulane Law School, Professor Turley joined the George Washington faculty in
1990 and, in 1998, was given the prestigious Shapiro Chair for Public Interest Law, the
youngest chaired professor in the schools history. In addition to his extensive publications,
Professor Turley has served as counsel in some of the most notable cases in the last two
decades ranging, representing whistleblowers, military personnel, and a wide range of other
clients. These include his representation of the Area 51 workers at a secret air base in Nevada;
the nuclear couriers at Oak Ridge, Tennessee; the Rocky Flats grand jury in Colorado; Dr. Eric
Foretich, the husband in the famous Elizabeth Morgan custody controversy; and four former
United States Attorneys General during the Clinton impeachment litigation. In the Foretich
case, Turley succeeded recently in reversing a trial court and striking down a federal statute
through a rare bill of attainder challenge. Professor Turley has also served as counsel in a
variety of national security cases, including espionage cases like that of Jim Nicholson, the
highest ranking CIA officer ever accused of espionage. Turley also served as lead defense
counsel in the successful defense of Petty Officer Daniel King, who faced the death penalty for
alleged spying for Russia. Turley also served as defense counsel in the case of Dr. Tom Butler,
who is facing criminal charges dealing with the importation and handling of thirty vials of
plague in Texas. He also served as counsel to Larry Hanauer, the House Intelligence Committee
staffer accused of leaking a classified Presidential National Intelligence Estimate to the New
York Times. (Hanauer was cleared of all allegations).
Among his current cases, Professor Turley represents Dr. Ali Al-Timimi, who was convicted in
Virginia in 2005 of violent speech against the United States. He also represents Dr. Sami AlArian, accused of being the American leader of a terrorist organization while he was a
university professor in Florida. He also currently represents pilots approaching or over the age
of 60 in their challenge to the mandatory retirement age of the FAA. Turley has
served as a consultant on homeland security and constitutional issues, including the Florida
House of Representatives.
Professor Turley is a frequent witness before the House and Senate on constitutional and
statutory issues as well as tort reform legislation. Professor Turley is also a nationally
recognized legal commentator. Professor Turley was ranked as 38th in the top 100 most cited
public intellectuals in the recent study by Judge Richard Posner. Turley was also found to be
the second most cited law professor in the country. In 2008, he was ranked in a study of the
nations top 500 lawyers - one of only a handful of academics. In prior years, he was ranked as
one of the nations top ten lawyers in military law cases as well as one of the top 40 lawyers
under 40.
Professor Turleys articles on legal and policy issues appear regularly in national publications
with over 500 articles in such newspapers as the New York Times, Washington Post, USA
Today, Los Angeles Times and Wall Street Journal. He is on the Board of Contributors of USA
Today. In 2005, Turley was given the Columnist of the Year award for Single-Issue Advocacy
for his columns on civil liberties by the Aspen Institute and the Week Magazine.
Professor Turley also appears regularly as a legal expert on all of the major television
networks. Since the 1990s, he has worked under contract as the on-air Legal Analyst for NBC
News and CBS News to cover stories that ranged from the Clinton impeachment to the
presidential elections. Professor Turley is often a guest on Sunday talk shows with over twodozen appearances on Meet the Press, ABC This Week, Face the Nation, and Fox
Sunday.Professor Turley teaches courses on constitutional law, constitutional criminal law,
environmental law, litigation, and torts. He is the founder and exectuve director of the Project
for Older Prisoners (POPS).
Page 17 of 35
January January
Sunday
22, 201722, 2017
Page
Page1393
391 of
of1299
2301
Professor Turley received his B.A. at the University of Chicago and his J.D. at Northwestern. (In
2008, he was given an honorary Doctorate of Law from John Marshall Law School for his
contributions to civil liberties and the public interest).
For further information: Ms. Kristen Hilderbrand 202-994-0537
Page 18 of 35
January January
Sunday
22, 201722, 2017
Page
Page1394
392 of
of1299
2301
EXHIBIT C
Page 19 of 35
January January
Sunday
22, 201722, 2017
Page
Page1395
393 of
of1299
2301
Letters
Conditional Release and Mandated Outpatient Treatment
George F. Parker, M.D.
To the Editor: In the thoughtful and stimulating article on mandated outpatient treatment by
Monahan and colleagues in the September 2001 issue (1), little mention was made of the fairly
substantial literature on mandated treatment of forensic populations in the community.
Conditional release has been used for decades as a technique for managing the risks inherent in
returning a person found not guilty by reason of insanity to the community.
Under conditional release, such acquittees are released into the community with various
conditions imposed; for example, they are often required to live in specified housing and not to
use illegal drugs. They remain under the jurisdiction of a criminal judge or a central monitoring
agency, such as a psychiatric security review board. Adherence to mental health treatment in
the community is almost always a condition of release. As leverage, this type of mandated
community treatment uses both avoidance of jail and avoidance of hospitalizationboth a brief
jail stay and rehospitalization are possible consequences of violation of the conditions of
release, depending on the state.
I recently conducted a thorough literature search, using PubMed and manual strategies, on the
topic of conditional release for persons found not guilty by reason of insanity. I found more than
60 articles, including more than 30 published in the past ten years. Many of the earlier studies
on conditional release focused on the demographic characteristics of persons found not guilty by
reason of insanity. However, most of the articles on this subject for the past 30 years have
reported arrest rates and hospitalization rates of persons on conditional release. A recent metaanalysis on this issue, based on statewide results from New York, California, and Oregon, found
estimated annual arrest rates to range from 3.4 to 7.9 percent, while the estimated annual
hospitalizatio n rates ranged from 14.5 to 25.8 percent (2,3). I recently presented a poster at
the annual meeting of the American Academy of Psychiatry and the Law showing that among
persons receiving assertive community treatment the annual arrest rate was 1.2 percent and
the annual hospitalization rate was 14.5 percent (4). In addition, some of the published reports
have included statistical models for factors that are predictive of the granting or revocation of
conditional release (5).
The literature on conditional release of persons found not guilty by reason of insanity thus may
hold some of the answers to the many questions about mandated community treatment posed
by Monahan and colleagues. In particular, the issues of the process of mandating treatment,
the outcomes of programs both for the individual and for the systemthat do mandate
treatment, and the legal, ethical, and political questions that result from mandating treatment
in the community have all been discussed, to greater or lesser degrees, in the conditional
release literature over the past 30 years.
Footnotes
Dr. Parker is associate professor of clinical psychiatry at Indiana University School of Medicine
in Indianapolis.
References
1. Monahan J, Bonnie RJ, Appelbaum PS, et al: Mandated community treatment: beyond
outpatient
commitment.
Psychiatric
Services
52:1198-1205,
2001[Abstract/Free Full Text]
2. Wiederanders MR, Bromley DL, Choate PA: Forensic conditional release programs and
outcomes in three states. International Journal of Law and Psychiatry 20:249-257,
1997[CrossRef][Medline]
Page 20 of 35
January January
Sunday
22, 201722, 2017
Page
Page1396
394 of
of1299
2301
3. Harris VL: Insanity acquittees and rearrest: the past 24 years. Journal of the American
Academy of Psychiatry and the Law 28:225-231, 2000[Medline]
4. Parker GF: Low reoffense rate in a conditional release program. Poster presented at the
annual meeting of the American Academy of Psychiatry and the Law, Boston, Oct 25-28,
2001
5. Callahan LA, Silver E: Factors associated with the conditional release of persons
acquitted by reason of insanity: a decision tree approach. Law and Human Behavior
22:147-163, 1998[CrossRef][Medline]
Page 21 of 35
January January
Sunday
22, 201722, 2017
Page
Page1397
395 of
of1299
2301
EXHIBIT D
Page 22 of 35
January January
Sunday
22, 201722, 2017
Page
Page1398
396 of
of1299
2301
Griffin PA, Steadman HJ, Heilbrun K.

Virginia Department of Mental Health, Mental Retardation, and Substance Abuse Services,
Richmond 23214.
Monitored treatment in the community, also known as conditional release, has been described
a s the most important advance in the treatment of insanity acquittees in the last decade.
Despite the importance of the development of conditional release, however, there has been
relatively little written about relevant issues and planning principles important in designing and
implementing conditional release systems. The present paper discusses important
considerations relevant to conditional release that are associated with key decision points
within systems for persons found not guilty by reason of insanity (NGRI). Four planning
principles, generalizable to all NGRI systems, are then presented in a way that integrates the
previous discussion. It is concluded that conditional release plays a crucial role in the treatment
of insanity acquittees and that mental health administrators may either proactively modify their
systems, in a way that balances public safety with individual rights and treatment needs, or
wait for the modification mandate to be forced upon them in the wake of a highly publicized,
heinous offense.
Page 23 of 35
January January
Sunday
22, 201722, 2017
Page
Page1399
397 of
of1299
2301
EXHIBIT E
Page 24 of 35
January January
Sunday
22, 201722, 2017
Page
Page1400
398 of
of1299
2301
A Look Behind the Scenes of HIPAA and the Privacy Rule

by Doug Walter, J.D.
A major upshot of the Health Insurance Portability and Accountability Act (HIPAA) of 1996 is a
series of federal rules that have a considerable impact on providers and patients their
interactions, their rights, and their responsibilities. In sorting through the details and
compliance requirements of the privacy rule in particular, it helps for practitioners to know
something of the historical and political context in which HIPAA and the rules that resulted
from this law took shape.
Under HIPAA, Congress tasked the Department of Health Human Services (HHS) with
developing federal rules that govern how patient records are handled, shared, and protected
in the health care system. The transactions rule, the first rule promulgated by HHS, provides
for standard formatting of electronic patient records for health care claims and other
purposes. This rule benefits health professionals by making it easier for them to work with
uniform rather than multiple claims forms. While more rules will follow, the 800-pound
gorilla of the series, the privacy rule, was finalized last April. The privacy rule provides
some important protections for psychology records, with provisions that will impact the
confidentiality of the psychologist-patient relationship.
The privacy rule may be divided into three parts. The provisions of the first part address when
and how patient records may be used and disclosed among treating providers and to third
parties. The second part provides patients with certain rights regarding their records, such as
the right to access and amend records. The third part outlines administrative requirements
that psychologists and other health care professionals and entities must follow in using and
disclosing patient records.
In essence, the privacy rule affords psychologists new protections regarding the records of
their patients, but it also requires psychologists to proactively ensure the protection of records
through certain administrative requirements. These include, for example, providing patients
with information about their privacy rights, implementing procedures to ensure records
privacy, and securing records in offices.
While the privacy rule includes some requirements already contained in various state laws,
some of the federal rules mandates are new. The rule may be understood, however, as
providing a national floor of patient records protections upon which states may build further
protections, since Congress has specifically provided that state laws providing for greater
records protection will not be preempted by the federal rule.
Some may question why a federal privacy rule was promulgated in the first place, since many
state laws already protect the privacy of patient records. The short answer is that state laws
vary in the extent to which they protect patient records privacy, particularly mental health
records. A federal floor of protection provides a baseline uniformity of records protection. The
long answer is rooted in the history leading to promulgation of the privacy rule.
The Stage for Conflict Is Set
HIPAA legislation and rulemaking, including development of the privacy rule, have much to do
with the emergence of managed care organizations (MCOs) in the early 1990s as the primary
payers for health care. Unlike insurers in the fee-for-service system, MCOs began demanding
broad access to patient records for payment and administrative purposes. Patients and
providers balked and fought to keep sensitive personal information outside of the claims management process.
Page 25 of 35
January January
Sunday
22, 201722, 2017
Page
Page1401
399 of
of1299
2301
management process.
By the mid 1990s, the insurance and business lobbies began pitching to Congress that a
uniform, electronic patient records system to standardize health insurance claims processing,
dubbed administrative simplification, would save the health care system billions of dollars
and relieve the inefficiency and fragmentation in health care claims management. Insurers
were also looking for a federal law that legitimized their demands for broad access to patient
records. While organized psychology supported administrative simplification, it could not come
at a cost to records privacy.
APA was at the forefront of groups concerned that the onerous MCO demands for patient
records disclosures often for administrative purposes not directly related to patient care
had eroded confidentiality. Provider and patient organizations advocated for privacy and
security safeguards that would be needed if Congress were to mandate uniform electronic
claims processing.
The stage for political conflict therefore was set by the time President Clinton included both
patient records privacy and administrative simplification provisions in his Health Security Act
of 1993, which failed to win passage. The inclusion of these provisions shed light on the
bitter fight brewing between patients/providers and MCOs over control of records and
foreshadowed the rancorous congressional debate to come. The underlying conflict, which
continues to this day, was the force that shaped HIPAA law in general and the privacy rule
specifically.
Battle Pits Provider Groups Against Insurers
The advocacy battle began in earnest when Senator Robert Bennett (R-Utah) introduced the
Medical Records Confidentiality Act in late October 1995. The Practice Directorate was
concerned by the Bennett bills bipartisan co-sponsorship by powerful members of Congress
and by the strong support of insurers and other influential organizations. The concern arose
from APAs taking a careful look at the bills details. The directorates analysis revealed
substantial weaknesses in protecting the rights of patients and providers with respect to the
privacy of records. APA and allied groups mobilized to prevent the Bennett bill from being
included in broader health care legislation that Congress also was seriously considering that
fall. That broader legislation eventually was enacted as HIPAA.
A "Final" Rule Is Subject to Change
The political battle between insurance and patient and provider organizations continues to
this day. President George W. Bushs Administration put the HIPAA privacy rule into effect
Page 26 of 35
January January
Sunday
22, 201722, 2017
Page
Page1402
400 of
of1299
2301
the rules privacy protections, and even expanding them. For example, the MHLG
continues to urge that the special privacy protection given to psychotherapy notes as
defined in the rule (see article on page 5) should be broadened to apply to other sensitive
information such as psychological testing data.
For several months, the directorates government relations staff worked to educate Congress
and the public about the need for a strong federal privacy bill, or at least a bill that would not
undermine existing state privacy laws that protected patients rights. APAs lobbying push
successfully countered the insurance industrys efforts to win inclusion of the Bennett bill in
HIPAA. In place of the Bennett bill, Congress incorporated a few sentences into HIPAA to
provide a timeline for action. Legislators gave themselves three years, until August 1999, to
enact a federal law governing records privacy and further directed that HHS would establish a
privacy rule within six months of Congress failure to meet its deadline.
Shortly after HIPAAs passage, it became increasingly clear that the patient and provider
lobbies and the insurance lobby were entrenched in polar positions. APA assessed that
Congress would not likely pass legislation. While the association continued to advocate for
appropriate privacy legislation in Congress, APA began focusing efforts on the Administration
in anticipation of a rule from HHS. Organized psychology sought a rule that would recognize
the particular privacy requirements of records associated with mental health treatment,
including the need for heightened protection for psychotherapy notes and other mental health
records.
Too Hot for Congress to Handle
Indeed, the privacy issue ultimately became too controversial for members of Congress to
handle, and HHS ended up proposing a federal privacy rule in November 1999. It looked like a
compromise for both sides of the debate. Insurers saw their broad access to records
recognized in the proposed rule. At the same time, consumers and providers had won strong
protections for records each time they were disclosed to insurers.
Throughout 2000, APA worked to ensure that the proposed rules strong patient protections
were preserved in a final rule. Meanwhile, the insurance lobby pushed to void the rule or at
least substantially weaken its protections. HHS released the final privacy rule in the last days
of the Clinton Administration in much the same form as the proposed rule. The Practice
Directorate considered the final rule a success, with qualification. For example, APA reiterated
in written comments to HHS that the privacy rule allowed insurers too much access to records
for administrative purposes not directly related to treatment. It appeared the conflict and
compromise characteristic of the legislative and rulemaking processes was reflected in the
final rule once it ultimately took effect last April.
The following chronology illustrates from 1993 through 2001 the major events and players
related to the HIPAA law and the final privacy rule from HHS.
Page 27 of 35
January January
Sunday
22, 201722, 2017
Page
Page1403
401 of
of1299
2301
EXHIBIT F
Page 28 of 35
January January
Sunday
22, 201722, 2017
Page
Page1404
402 of
of1299
2301
Federal Oversight of Psychiatric Records: The Health Insurance Portability and

Accountability Act
by Karen Welch
More than two years ago, I published an article on psychiatric records in Mental Health
World. This same article was included on one of the Internet editions of MHW found on our
website at www.mentalhealthworld.org. Since publishing that article, each month, I receive at
least one email asking questions about confidentiality and access to psychiatric records. The
previous MHW article on psychiatric records specifically addressed access to records and
confidentiality under New York State law. Since that article was written, the federal
government has created regulations under the Health Insurance Portability and Accountability
Act (HIPAA) which deal explicitly with access and confidentiality of all health care records. The
present article will summarize some of the main provisions of these regulations as they relate
to the confidentiality and access of psychiatric records.
It will also note how the HIPAA
regulations differ from New York Law.
The Health Insurance Portability and Accountability Act was passed by Congress in
1996. Final regulations regarding the privacy provisions of this law were issued by the Bush
administration in August 2002 and will become effective in April 14, 2003. These regulations
provide a comprehensive set of rules for the confidentiality and access to all health records.
Since this is a federal law, it affects everyone in the United States. The HIPAA privacy
regulations supersede any state law, to the extent that they provide greater protections than
state law. However if a states law provides greater privacy protections than HIPAA, then the
states rules apply.
General Provisions of HIPAA
HIPAA greatly expands the entities which must keep psychiatric records confidential.
Entities which are covered by the requirements of HIPAA include health care providers, health
plans and health care clearinghouses that transmit or maintain any health information via
electronic media. The definition of health plans includes group health plans, health insurance
issuers, HMOs, Medicaid programs, Medicare programs and long-term care policies.
Additionally, the law requires that business associates of covered entities which perform
services involving the use or disclosure of protected health information must enter into an
agreement to safeguard the privacy of the protected health information.
HIPAA also greatly expands the types of information that are protected. With a few
narrow exceptions, HIPAA applies to all individually identifiable health information in any form
held or transmitted by a covered entity. Individually identifiable means that it is information
from which a person can identify the person to whom it relates. The information is covered
whether it is oral or recorded. It also does not matter if it was created by a health care
provider, health plan, public health authority, employer, life insurer, school or university or
health care clearinghouse. The information may relate to past, present or future physical or
mental health or condition of an individual, the provision of health care to an individual or the
past, present or future payment of health care to an individual.
In contrast, under the New York Mental Hygiene Law, a clinical record means any
information covering or relating to the examination or treatment of a patient or client
maintained by the facility which has treated or is treating such patient or client.
Under the
New York Mental Hygiene Law, privacy protections apply to facilities that are operated or
licenced by the New York State Office of Mental Health. Additionally, the law requires that
disclosure of these records to third parties places the third party under an obligation to
maintain confidentiality.
For consumers of mental health services, the expansion of privacy protections found in
HIPAA is welcome. Often, individuals would successfully seal their clinical records under New
York law only to be thwarted by the fact that insurers or health information clearinghouses had
Page 29 of 35
January January
Sunday
22, 201722, 2017
Page
Page1405
403 of
of1299
2301
created their own records which were not subject to the confidentiality provisions of New York
law. Under HIPAA, the likelihood of this problem is substantially decreased since these entities
must now maintain strict confidentiality or face the penalties under the law.
Access By Individuals to Their Own Records
HIPAA creates a general right for an individual to access his or her own health records
subject to a number of exceptions. Additionally, the comments to the regulations state that
individuals have a right of access to information used to make health care decisions or
determine whether an insurance claim will be paid. The four exceptions to the general right of
access to records are:
1) psychotherapy notes;
2) information compiled in reasonable anticipation of, or use in, a civil, criminal or
administrative action and proceeding;
3) where access is prohibited by the Clincial Laboratory Improvements Amendments of
1988: or
4) records that are exempt under the regulations of the Clinical Laboratory
Improvements Amendment. The Clinical Laboratory Improvements Amendments of 1988 is an
act which forbids laboratories doing tests on human specimens to disclose the results to anyone
except the individual or entity who requested the test.
The definition of psychotherapy notes is notes recorded in any medium by a health
care provider who is a mental health professional documenting or analyzing the contents of a
conversation during a private counseling session or a group, joint, or family counseling
session.
Psychotherapy notes are intended to refer to a mental health professionals own
personal notes of a therapy session. Notes do not count as psychotherapy notes unless they
are kept separately from the patients medical chart.
Reviewable Denial of Access to Records
Under HIPAA, other than the unreviewable reasons discussed below, the right of a
patient to see his own chart can be restricted in only three circumstances. Each of these
circ umstances is reviewable by an appeal process.
First, a licensed health care professional may deny access if in the exercise of his
professional judgement it is determined that such access is reasonably likely to endanger the
life or physical safety of the individual or other person. Under this reason for denial, covered
entities may not deny the access on the basis of the sensitivity of the health information or the
potential for causing psychological or emotional harm. A health care professional must find
that the individual has exhibited suicidal or homicidal tendencies and that access to the records
would reasonably result in murder, suicide or other physical violence.
Second, there is a reviewable exception when the requested information relates to
another person (other than the health care provider) and in the professional judgement of the
licensed health care professional, the access would likely cause substantial harm to such
person.
Third, if the personal representative of an individual makes the request rather than the
individual himself, the request may be denied if the provision of access to records to the
personal representative is reasonably likely to cause substantial harm to the individual or other
person.
This scheme is somewhat different from that found in the New York Mental Hygiene
Law. Under New York law, the treating practitioner may review the information requested. If
after consideration of all factors, the practitioner determines that the requested review could
reasonably be expected to cause substantial and identifiable harm to the patient, client or
Page 30 of 35
January January
Sunday
22, 201722, 2017
Page
Page1406
404 of
of1299
2301
others, the facility may deny access to all or a part of the record and may grant access to a
prepared summary of the record.
Unreviewable Denial of Access to Records.
Under HIPAA, there are five areas where an entity may deny access to records without
an opportunity for review of this denial. The areas are:
1) the exceptions to the right of access described above
2) the request of a prison inmate to see his records if obtaining such copy would
jeopardize the health, safety, security, custody or rehabilitation of the prisoner or other
inmates or the safety of the correctional staff.
3) if the protected health information is
contained in records subject to the Privacy Act;
4) the information was obtained from someone other than a health care provider under
a promise of confidentiality and the access would be reasonably likely to reveal the source of
the information.
5) a research subjects request to see his records during research, if the consent form
for the research advised that access to records would be suspended during research and the
patient signed the consent form.
Process of Review of Denial of Access
The review of a denial of the access is to be conducted by a health care professional
designated by the covered entity. This professional may not have been directly involved in
the original denial of the request for access. The review must be conducted in a
reasonable time period but the regulations do not impose deadlines on any entity. There is
no provision for judicial review of this denial.
New Yorks review procedure for a denial of access appears to be more helpful to
consumers. Under the New York Mental Hygiene Law, if access to a psychiatric record is
denied, a patient has the right to appeal for review by the Clinical Records Access Review
Committee. A client must be notified by the facility of his right to a review of the denial by
the appropriate clinical record access review committee. If the client requests this review,
the facility must within ten days of the request, transmit the record to the chairman of the
appropriate committee with a statement setting forth the specific reasons access was
denied. If access is denied by the records access review committee, a patient has a right
to seek judicial review of this denial. Court review must be commenced within 30 days of
receiving notification of the committee decision.
Procedure for Correcting Records
Under HIPAA, an individual has the right to have a covered entity amend protected
health information or records about the individual in a designated record set. An
individuals request for amendment may be denied if the health information or record:
1) was not created by the covered entity;
2) is not part of the designated record set;
3) would not otherwise be available for inspection by the individual;
4) is accurate and complete.
An individual should make a request for the amendment in writing. The entity may
require [that omit DN] the individual to provide reasons to support a requested
amendment to a record. An entity must act on the request within 60 days of the request
for an amendment although this time may be extended once for 30 days if it notifies the
Page 31 of 35
January January
Sunday
22, 201722, 2017
Page
Page1407
405 of
of1299
2301
individual in writing of the reasons for the delay.

If the entity agrees to make the amendment to the consumers record it must do so
and make a reasonable effort to inform others about the amendment including persons
identified by the consumer as having the information and any persons that are known by
the entity to have the records. If the entity denies the consumers request to amend the
record, the entity must provide a timely written denial. The consumer can then submit a
written statement disagreeing with the denial. This information must be appended to the
record and included in any future disclosure.
Under the New York Mental Hygiene Law, an individual may challenge the accuracy
of the information maintained in his clinical record and may require that a brief written
statement prepared by him concerning the challenged information be inserted into the
clinical record. This statement shall become part of the permanent part of the record and
shall be released whenever the clinical record at issue is released. The information to be
challenged shall be only factual statements and shall not include a providers observations,
inferences or conclusions.
For information concerning access to records, confidentiality or sealing of records, or for
other questions concerning the mental health laws, please contact the PAIMI (Protection and
Advocacy for the Mentally Ill) program at Neighborhood Legal Services, 716/847-0650.
Sources
Stefan, Susan, Q&A, What effect do the recently promulgated HIPAA regulations on
privacy of records have for the rights of my clients to access their own records?, Center for
Public Representation, August 2002
Clemens, Jane F., New Federal Regulations Expand Protections For Privacy of Health
Records,
New York State Bar Journal, June 2002.
Flannery, John, Paley, Eric, and Roland, M.K. Gaedecke, With HIPPA deadlines on
horizon, whats required?, Buffalo Law Journal, September 26, 2002
Page 32 of 35
January January
Sunday
22, 201722, 2017
Page
Page1408
406 of
of1299
2301
EXHIBIT G
Page 33 of 35
January January
Sunday
22, 201722, 2017
Page
Page1409
407 of
of1299
2301
More protections for patients and psychologists under HIPAA

HIPAA's psychotherapy notes provision safeguards sensitive patient information.
BY JENNIFER DAW HOLLOWAY
Monitor staff
Print version: page 22
Though the mention of the Health Information Portability and Accountability Act (HIPAA)
privacy rule compliance date--April 14--can make some psychologists anxious, most applaud
the new law for increasing privacy protections.
Especially interesting to practitioners is the psychotherapy notes provision, says Russ Newman,
PhD, JD, APA's executive director for practice. The provision recognizes that certain kinds of
mental health information need to be protected more than other types of information. Under
HIPAA, psychotherapy notes are defined as "notes recorded in any medium by a mental health
professional documenting or analyzing the contents of conversation during a private counseling
session." These notes, which capture the psychologist's impressions about the patient and can
contain information that is inappropriate for a medical record, are similar to what psychologists
have historically referred to as "process notes."
HIPAA affords psychotherapy notes more protection--most notably from third-party payers-than they'd been given in the past. Under HIPAA, disclosure of psychotherapy notes requires
more than just generalized consent; it requires patient authorization--or specific permission--to
release this sensitive information. And, whereas in the past insurance companies have
requested entire patient records--including psychotherapy notes--in making coverage
decisions, now health plans cannot refuse to provide reimbursement if a patient does not agree
to release information covered under the psychotherapy notes provision.
"In the past, patients could refuse to have this type of information released, but then the
company might refuse to cover services," notes Newman. "The HIPAA privacy rule protection
stops that kind of practice from taking place."
Psychologists take note
The privacy rule gives rights to health professionals, as well as to their patients. Under the new
law, psychologists can decide whether to release their psychotherapy notes to patients, unless
patients would have access to their psychotherapy notes under state law (see the article about
HIPAA and state laws in last month's Monitor). Though the privacy rule does afford patients the
right to access and inspect their health records, psychotherapy notes are treated differently:
Patients do not have the right to obtain a copy of these under HIPAA. And when a psychologist
denies a patient access to these notes, the denial isn't subject to a review process, as it is with
other records.
There is a catch in the psychotherapy notes provision. HIPAA's definition of psychotherapy
notes explicitly states that these notes are kept separate from the rest of an individual's record.
So, if a psychologist keeps this type of information in a patient's general chart, or if it's not
distinguishable as separate from the rest of the record, access to the information doesn't
require specific patient authorization. According to the Department of Health and Human
Services (HHS), it makes good sense to keep the notes separate since this type of information
should not be available automatically.
This may, says Newman, be a practical difference from the way some psychologists have
previously stored patient information. But, "if psychologists want higher protections for
psychotherapy notes, then they should keep the information separate," he urges.
Daniel Abrahamson, PhD, professional affairs coordinator for the Connecticut Psychological
Association, adds that psychologists "shouldn't jump the gun." Keeping records separate is an
option and "each practitioner will need to determine whether the benefits of maintaining extra
protection outweigh keeping the records distinctly separate from medical records," he says. In
Page 34 of 35
January January
Sunday
22, 201722, 2017
Page
Page1410
408 of
of1299
2301
other words, some psychologists may decide that, for some patients, the information doesn't
particularly need the extra level of protection. If a particular treatment evolves and the
psychologist wants to keep the psychotherapy notes separate, he or she can choose to do that.
"It's part of good clinical judgment," says Abrahamson. "In the past, clinicians didn't include
some information in a record and therefore wouldn't be able to later document that
information. Now they have the option to include detailed content in separate notes."
In addition to keeping these notes separate from other patient information, psychologists
should be aware, says Newman, that there are certain parts of a record that are expressly not
considered psychotherapy notes--and that don't require patient authorization for disclosure-under the HIPAA privacy rule. This information includes medication prescription and monitoring,
counseling session start and stop times, modalities and fre quencies of treatment, results of
clinical tests, and any summary of diagnosis, functional status, treatment plans, symptoms,
prognosis or progress.
This portion of the rule is likely to leave some "potential for interpretation," says Newman.
"What if a managed-care company says it needs a summary of the themes from psychotherapy
sessions? They may say that's outside the psychotherapy notes provision. We'd argue that
divulging themes of the conversations in psychotherapy is tantamount to giving away the whole
conversation," he says.
In the same vein, testing information, like summary information, isn't included under
psychotherapy notes. APA submitted comments to HHS on both the proposed and final rules
asking that psychological test data be included in the provision. Disclosing this type of
information, says Newman, could divulge intimate details about a patient much like the
information from psychotherapy sessions. Unfortunately, he says, HHS declined to expand the
definition.
Despite the exclusion of certain information, however, the psychotherapy notes provision
should be heralded "as a significant victory for privacy advocates," says Nanci Klein, PhD,
professional affairs coordinator for the Utah Psychological Association. "Practitioners have long
found it onerous to have to release psychotherapy notes for additional treatment authorization
by managed-care companies." Now, she says, managed-care companies are only entitled to
certain types of information, not including psychotherapy notes.
"I think this defines the psychologist as the treating expert whose professional analysis and
opinion represent the core information necessary for making judgments about the necessity for
continued treatment," she adds.
This article is the second in a three-part series on HIPAA topics. The next piece, on HIPAA's
minimum necessary requirement, will appear in March.
Page 35 of 35
Case
2:16-mc-00049-EGS Page
Document
70
Page 1LAMBERT
of 4
January January
Sunday
22, 201722,
2017
Page
1411
409 of
of1299
2301Filed 11/21/16
Stan J. Caterbone
CASE FILE
Case
Document
70
Page 2LAMBERT
of 4
January January
Sunday
22, 201722,
2017
Page
1412
410 of
of1299
2301Filed 11/21/16
Stan J. Caterbone
CASE FILE
Case
Document
70
Page 3LAMBERT
of 4
January January
Sunday
22, 201722,
2017
Page
1413
411 of
of1299
2301Filed 11/21/16
Stan J. Caterbone
CASE FILE
Case
Document
70
Page 4LAMBERT
of 4
January January
Sunday
22, 201722,
2017
Page
1414
412 of
of1299
2301Filed 11/21/16
Stan J. Caterbone
CASE FILE
January January
Sunday
22, 201722, 2017
Page
Page1415
413 of
of1299
2301
mmmmmmmmmmmmm
mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm
xmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm
US Supreme Court 16-6822
Page 1 of 9
Tuesday November 22, 2016
January January
Sunday
22, 201722, 2017
Page
Page1416
414 of
of1299
2301
Page 2 of 9
January January
Sunday
22, 201722, 2017
Page
Page1417
415 of
of1299
2301
Page 3 of 9
January January
Sunday
22, 201722, 2017
Page
Page1418
416 of
of1299
2301
Page 4 of 9
January January
Sunday
22, 201722, 2017
Page
Page1419
417 of
of1299
2301
Page 5 of 9
January January
Sunday
22, 201722, 2017
Page
Page1420
418 of
of1299
2301
Page 6 of 9
January January
Sunday
22, 201722, 2017
Page
Page1421
419 of
of1299
2301
Page 7 of 9
January January
Sunday
22, 201722, 2017
Page
Page1422
420 of
of1299
2301
Page 8 of 9
January January
Sunday
22, 201722, 2017
Page
Page1423
421 of
of1299
2301
Page 9 of 9
1 of 1
January January
Sunday
22, 201722, 2017
Page
Page1424
422 of
of1299
2301
11/17/2016 4:39 AM
January January
Sunday
22, 201722, 2017
Page
Page1425
423 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1426
424 of
of1299
2301
Stan J. Caterbone LAMBERT

DRAFT
CASECOPY
FILE
Income source

the past 12 months
Amount expected
next month
You
Spouse
You
Spouse
Employment
Self-employment

Gifts
Alimony
Child Support

security, pensions,

$ 1,357.00
Public-assistance
(such as welfare)
Other (specify):
U.S.C.A. 16-1149 To US Supreme Court
1,357.00
Page 2 of 88
45
62
70
1,357.00
1,357.00
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1427
425 of
of1299
2301

DRAFT
CASECOPY
FILE
Employer
Address
Dates of
Employment
Gross monthly pay

$
$
$
Employer
Address
Dates of
Employment
Gross monthly pay

$
$
$

institution.
Type of account
Members1st
TD Ameritrade
Checking
Money Market
Amount you have

$ 1,000.00
$ 12,000.00
$

$
$
$
X Home
D
Value 25% of 80,000.00
D Other real estate

Value
D Motor Vehicle #1
Year, make & model
Value
D Motor Vehicle #2
Year, make & model
Value
D Other assets
Description
Value
Page 3 of 88
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1428
426 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1429
427 of
of1299
2301

DRAFT
CASECOPY
FILE
You
Your spouse
100.00
200.00

48.00
Life
Health
Motor Vehicle
Other:
300.00

$
Motor Vehicle
Credit card(s)
Department store(s)
Other:
Other (specify):
500.00
2,658.00
(specify):
Home Improvement
Page 5 of 88
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1430
428 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1431
429 of
of1299
2301

DRAFT
CASECOPY
FILE
No.
IN THE
PETITIONER
(Your Name)
vs.
RESPONDENT(S)
(Your Name)
1250 Fremont Street
(Address)
Lancaster, PA 17603

(717) 669-2163
(Phone Number)
Page 7 of 88
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1432
430 of
of1299
2301

DRAFT
CASECOPY
FILE
Appellant received
He filed two
He simply
MOTION TO DISMISS?
Page 8 of 88
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1433
431 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1434
432 of
of1299
2301

DRAFT
CASECOPY
FILE
TABLE OF CONTENTS
12
OPINIONS BELOW ........................................................................................................ 1
13
JURISDICTION...................................................................................................................

14
24
26
CONCLUSION....................................................................................................................
27
INDEX TO APPENDICES
APPENDIX A .............................................................................................................. 36
APPENDIX B ............................................................................................................... 41
APPENDIX C .............................................................................................................. 43
APPENDIX D .............................................................................................................. 47
APPENDIX E .............................................................................................................. 55
APPENDIX F .............................................................................................................. 60
APPENDIX G .............................................................................................................. 64
APPENDIX H .............................................................................................................. 71
APPENDIX I ............................................................................................................... 73
Page 10
12 of 88
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1435
433 of
of1299
2301

DRAFT
CASECOPY
FILE
CASES
PAGE NUMBER
Appendix B -
STATUTES AND RULES
OTHER
Page 11
13 of 88
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1436
434 of
of1299
2301

DRAFT
CASECOPY
FILE
IN THE

OPINIONS BELOW
the petition and is
to

; or,
[ ] is unpublished.
the petition and is
to
[ ] reported at
; or,
[ ] is unpublished.
Appendix
[ ] reported at
; or,
[ ] is unpublished.
The opinion of the
appears at Appendix
court
[ ] reported at
; or,
[ ] is unpublished.
1.
Page 12
14 of 88
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1437
435 of
of1299
2301

DRAFT
CASECOPY
FILE
JURISDICTION

was June 15, 2016
.
, and a copy of the
A
.
to and including
(date) on
(date)
in Application No.
A
.

.
appears at Appendix
.
to and including
(date) on
(date) in
Application No.
A
.
Page 13
15 of 88
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1438
436 of
of1299
2301

DRAFT
CASECOPY
FILE

Docket Number: 577
Judges: Black
380 U.S. 400 (1965)
POINTER
v.
TEXAS.
No. 577.
for petitioner.
defence."
Page 14 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1439
437 of
of1299
2301

DRAFT
CASECOPY
FILE
Page 15 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1440
438 of
of1299
2301

DRAFT
CASECOPY
FILE
I.
Page 16 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1441
439 of
of1299
2301

DRAFT
CASECOPY
FILE

Page 17 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1442
440 of
of1299
2301

DRAFT
CASECOPY
FILE
II.
Page 18 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1443
441 of
of1299
2301

DRAFT
CASECOPY
FILE
Page 19 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1444
442 of
of1299
2301

DRAFT
CASECOPY
FILE
course.
Louisiana, 379 U.S. 466, 472-473.[4]
subject.
Page 20 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1445
443 of
of1299
2301

DRAFT
CASECOPY
FILE
prosecution.[7]
Page 21 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1446
444 of
of1299
2301

DRAFT
CASECOPY
FILE
NOTES
Page 22 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1447
445 of
of1299
2301

DRAFT
CASECOPY
FILE

counsel." 349 U. S., at 134.
Page 23 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1448
446 of
of1299
2301

DRAFT
CASECOPY
FILE


1
MOTIONS, ETC.,.
2
3
Page 24 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1449
447 of
of1299
2301

DRAFT
CASECOPY
FILE
The
justice.
Page 25 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1450
448 of
of1299
2301


prison in 1997.
Appendix I.
Page 26 of 88
Wednesday October 12, 2016
January January
Sunday
22, 201722, 2017
Page
Page1451
449 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1452
450 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1453
451 of
of1299
2301
PROOF OF SERVICE
Mr. Craig Stedman,

50 N. Duke Street
Lancaster, PA 17602
Mr. XXXXXXXXX
Ibrahim, Jeremy
1700 Race St
Phone: (215) 568-1943
MCI - Framingham
P.O. Box 9007
xx 01704
Framingham,
PA

601 Market Street
xxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxx
Page 29 of 88
70
January January
Sunday
22, 201722, 2017
Page
Page1454
452 of
of1299
2301

DRAFT
CASECOPY
FILE
October 2015
OFFICE OF THE CLERK
CERTIORARI
I. Introduction

Page 30
21 of 88
29
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1455
453 of
of1299
2301

DRAFT
CASECOPY
FILE
IV. What To File
le:
See Rule 39.1.
V. Page Limitation

Page 31
22 of 88
30
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1456
454 of
of1299
2301

DRAFT
CASECOPY
FILE
I.

petition.

Pauperis
forma pauperis.
Page 32
23 of 88
31
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1457
455 of
of1299
2301

DRAFT
CASECOPY
FILE

V. List of Parties
A. Federal Courts
B. State Courts
Page 33
24 of 88
32
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1458
456 of
of1299
2301

DRAFT
CASECOPY
FILE

IX. Opinions Below
appears.
X. Jurisdiction
Page 34
25 of 88
33
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1459
457 of
of1299
2301

DRAFT
CASECOPY
FILE

appears.
of the case.
XIV. Conclusion
Page 35
26 of 88
34
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1460
458 of
of1299
2301
APPENDIX A
Page 36 of 88
70
January January
Sunday
22, 201722, 2017
Page
Page1461
459 of
of1299
2301
Page 37
27 of 88
35
45
62
70

DRAFT
CASECOPY
FILE
COPY
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1462
460 of
of1299
2301
Page 38
28 of 88
36
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1463
461 of
of1299
2301
Page 39
29 of 88
37
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1464
462 of
of1299
2301
Page 40
30 of 88
38
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1465
463 of
of1299
2301
APPENDIX B
Page 41 of 88
70
15-3400
January January
Sunday
22,Case:
201722,
2017
Document: 003112168218
Page: 1 StanDate
Filed: 12/31/2015
Page
Page1466
464 of
of1299
2301
J. Caterbone
LAMBERT
DRAFT
CASECOPY
FILE
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
December 31, 2015

To:

Clerk of Courts
Re:


course the U.S.C.A.

IMPORTANT
/S/
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
Page 42
31 of 88
39
45
62
70
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1467
465 of
of1299
2301
APPENDIX C
Page 43 of 88
70
January January
Sunday
22, 201722, 2017
Page
Page1468
466 of
of1299
2301
Page 44
32 of 88
40
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1469
467 of
of1299
2301
Page 45
33 of 88
41
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1470
468 of
of1299
2301
Page 46
34 of 88
42
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1471
469 of
of1299
2301
APPENDIX D
Page 47 of 88
70
January January
Sunday
22, 201722, 2017
Page
Page1472
470 of
of1299
2301
Page 48
35 of 88
43
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1473
471 of
of1299
2301
Page 49
36 of 88
44
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1474
472 of
of1299
2301
Page 50
37 of 88
45
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1475
473 of
of1299
2301
Page 51
38 of 88
46
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1476
474 of
of1299
2301
Page 52
39 of 88
47
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1477
475 of
of1299
2301
Page 53
40 of 88
48
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1478
476 of
of1299
2301
Page 54
41 of 88
49
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1479
477 of
of1299
2301
APPENDIX E
Page 55 of 88
70
January January
Sunday
22, 201722, 2017
Page
Page1480
478 of
of1299
2301
Page 56
42 of 88
50
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1481
479 of
of1299
2301
Page 57
43 of 88
51
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1482
480 of
of1299
2301
Page 58
44 of 88
52
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1483
481 of
of1299
2301
Page 59
45 of 88
53
45
62
70

DRAFT
CASECOPY
FILE
Wednesday
Tuesday
SundayOctober
October12,
10,
9, 2016
January January
Sunday
22, 201722, 2017
Page
Page1484
482 of
of1299
2301
APPENDIX F
Page 60 of 88
70
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
15
Filed 09/14/15
Page 1 of
3
Page
Page1485
483 of
of
1299
2301
Stan J. Caterbone
LAMBERT
DRAFT
CASECOPY
FILE

Petitioner,
v.
Respondents.
:
:
:
:
:
:
:
:
Civ. No. 14-2559
ORDER
counseled motion.
(Doc. No. 3.)
Civ. P. 29(a).
Page 61
54 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
15
Filed 09/14/15
Page 2 of
3
Page
Page1486
484 of
of
1299
2301
Stan J. Caterbone
LAMBERT
DRAFT
CASECOPY
FILE

On
Page 2 of 3
Page 62
55 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
Case
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Document
15
Filed 09/14/15
Page 3 of
3
Page
Page1487
485 of
of
1299
2301
Stan J. Caterbone
LAMBERT
DRAFT
CASECOPY
FILE
/s/ Paul S. Diamond

_________________________
Paul S. Diamond, J.
September 11, 2015
Page 3 of 3
Page 63
56 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1488
486 of
of1299
2301
APPENDIX G
Page 64 of 88
70
Document
Filed 09/03/15
Page 1 ofLAMBERT
6
Sunday
January January
22, 201722,Case
2017 5:14-cv-02559-PD Page
Page1489
487 of
of91299
2301
Stan J. Caterbone
DRAFT
CASECOPY
FILE

\
Petitioner
v.
MCI-FRAMINGHAM,
and
and
Respondents
Civ. No. 5:14-cv-02559-PD
S 17=n
F uu~t:
lY
SEP - 3 2D15
By
Dep. Clerk

which reads:
II
Page 65
57 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
Document
Filed
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD Page
Page1490
488 of
of91299
2301
09/03/15
Page 2 ofLAMBERT
6
Stan J. Caterbone
DRAFT
CASECOPY
FILE
United States.
2
Page 66
58 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
Document
Filed
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD Page
Page1491
489 of
of91299
2301
09/03/15
Page 3 ofLAMBERT
6
Stan J. Caterbone
DRAFT
CASECOPY
FILE
Pl~.,
3
Page 67
59 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
,jl
Document
Filed
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD Page
Page1492
490 of
of91299
2301
'
09/03/15
Page 4 ofLAMBERT
6
Stan J. Caterbone
DRAFT
CASECOPY
FILE
I
plaintiff.
4
Page 68
60 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
Document
Filed
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD Page
Page1493
491 of
of91299
2301
09/03/15
Page 5 ofLAMBERT
6
Stan J. Caterbone
DRAFT
CASECOPY
FILE
5
Page 69
61 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
.#
Document
Filed
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD Page
Page1494
492 of
of91299
2301
09/03/15
Page 6 ofLAMBERT
6
Stan J. Caterbone
DRAFT
CASECOPY
FILE
scaterbone@live.com
6
Page 70
62 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1495
493 of
of1299
2301
APPENDIX H
Page 71 of 88
1 of 2
January January
Sunday
22, 201722, 2017
Page
Page1496
494 of
of1299
2301
Visit AETV.com

SEARCH:
SHOP BY SUBJECT
Exclusively at
The A&E Store


06/11/07, why?

SHOP BY SHOW


Driving Force DVDs
Get $1 Shipping on
your entire order!
$24.95
Intervention DVDs
Qty: 1
Gift Finder
Toys & Games
Gift Certificates
DVDs en Espaol
Closed Caption
Catalog Request
Child's Play,
Deadly Play
DVD
American
Justice set DVD
$59.95
$24.95
Murder In A
College Town
DVD
$24.95
PRODUCT DETAIL:
-->

Page 72 of 88
Page 1 of 4

05.28.2007
5/28/2007 3:35 PM
January January
Sunday
22, 201722, 2017
Page
Page1497
495 of
of1299
2301
APPENDIX I
Page 73 of 88
January January
Sunday
22, 201722, 2017
Page
Page1498
496 of
of1299
2301

[Home Edition]
BARRY SIEGEL.
Los Angeles Times


Page 74 of 88
Page 1 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1499
497 of
of1299
2301

Page 75 of 88
Page 2 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1500
498 of
of1299
2301

to the camera?"
with Weaver.

Page 76 of 88
Page 3 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1501
499 of
of1299
2301
put into evidence.
audiotapes.

Page 77 of 88
Page 4 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1502
500 of
of1299
2301

"Correct."
"Correct."
perjury.

Page 78 of 88
Page 5 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1503
501 of
of1299
2301
agreement."
remedial steps."
none."
no?"

Page 79 of 88
Page 6 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1504
502 of
of1299
2301
"Yes sir."
Show's room.
now.
emotional problem."

Page 80 of 88
Page 7 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1505
503 of
of1299
2301
over with.

back then.
courageous act.

Page 81 of 88
Page 8 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1506
504 of
of1299
2301
. . ."
just that.
how much."

Page 82 of 88
Page 9 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1507
505 of
of1299
2301
go."

Page 83 of 88
Page 10 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1508
506 of
of1299
2301
civil rights laws."

Page 84 of 88
Page 11 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1509
507 of
of1299
2301

Page 85 of 88
Page 12 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1510
508 of
of1299
2301
County.
They haven't.

Page 86 of 88
Page 13 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1511
509 of
of1299
2301
Lambert."
hearing.;

Page 87 of 88
Page 14 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1512
510 of
of1299
2301

innocent.;
without permission.
special reports
ISSN/ISBN: 04583035

Page 88 of 88
Page 15 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1513
511 of
of1299
2301
CHAPTER
DIVIDER
January January
Sunday
22, 201722, 2017

Page
Page1514
512 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Stan J. Caterbone

1250 Fremont Street

Lancaster, PA 17603
717-598-2200
November 15, 2016

THE WHITE HOUSE
Re:

Dear Mr. President,

Page 1 of 91
January January
Sunday
22, 201722, 2017

Page
Page1515
513 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Respectfully,
___________/S/____________
1250 Fremont Street

Lancaster, PA 17603
717-669-2163
Page 2 of 91
January January
Sunday
22, 201722, 2017

Page
Page1516
514 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
ACTIVE COURT CASES
Lambert
Page 3 of 91
January January
Sunday
22, 201722, 2017

Page
Page1517
515 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 4 of 91
January January
Sunday
22, 201722, 2017

Page
Page1518
516 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Income source

the past 12 months
Amount expected
next month
You
Spouse
You
Spouse
Employment
Self-employment

Gifts
Alimony
Child Support

security, pensions,

$ 1,357.00
Public-assistance
(such as welfare)
Other (specify):
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
1,357.00
Page 5
2 of 91
45
62
70
88
1,357.00
1,357.00
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1519
517 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Employer
Address
Dates of
Employment
Gross monthly pay

$
$
$
Employer
Address
Dates of
Employment
Gross monthly pay

$
$
$

institution.
Type of account
Members1st
TD Ameritrade
Checking
Money Market
Amount you have

$ 1,000.00
$ 12,000.00
$

$
$
$
X Home
D
Value 25% of 80,000.00
D Other real estate

Value
D Motor Vehicle #1
Year, make & model
Value
D Motor Vehicle #2
Year, make & model
Value
D Other assets
Description
Value
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 6
3 of 91
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1520
518 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 7 of 91
January January
Sunday
22, 201722, 2017

Page
Page1521
519 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
You
Your spouse
100.00
200.00
$
$

48.00
Life
Health
Motor Vehicle
Other:
300.00

$
Motor Vehicle
Credit card(s)
Department store(s)
Other:
Other (specify):
500.00
2,658.00
(specify):
Home Improvement
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 8
5 of 91
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1522
520 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 9 of 91
January January
Sunday
22, 201722, 2017

Page
Page1523
521 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
No.
IN THE
PETITIONER
(Your Name)
vs.
RESPONDENT(S)
(Your Name)
1250 Fremont Street
(Address)
Lancaster, PA 17603

(717) 669-2163
(Phone Number)
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page
Page10
7 of
of88
45
62
70
91
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1524
522 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Appellant received
He filed two
He simply
MOTION TO DISMISS?
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page
Page11
8 of
of88
45
62
70
91
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1525
523 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 12 of 91
January January
Sunday
22, 201722, 2017

Page
Page1526
524 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
TABLE OF CONTENTS
12
OPINIONS BELOW ........................................................................................................ 1
13
JURISDICTION...................................................................................................................

14
24
26
CONCLUSION....................................................................................................................
27
INDEX TO APPENDICES
APPENDIX A .............................................................................................................. 36
APPENDIX B ............................................................................................................... 41
APPENDIX C .............................................................................................................. 43
APPENDIX D .............................................................................................................. 47
APPENDIX E .............................................................................................................. 55
APPENDIX F .............................................................................................................. 60
APPENDIX G .............................................................................................................. 64
APPENDIX H .............................................................................................................. 71
APPENDIX I ............................................................................................................... 73
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 13
12 of 91
10
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1527
525 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
CASES
PAGE NUMBER
Appendix B -
STATUTES AND RULES
OTHER
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 14
13 of 91
11
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1528
526 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
IN THE

OPINIONS BELOW
the petition and is
to

; or,
[ ] is unpublished.
the petition and is
to
[ ] reported at
; or,
[ ] is unpublished.
Appendix
[ ] reported at
; or,
[ ] is unpublished.
The opinion of the
appears at Appendix
court
[ ] reported at
; or,
[ ] is unpublished.
1.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 15
14 of 91
12
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1529
527 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
JURISDICTION

was June 15, 2016
.
, and a copy of the
A
.
to and including
(date) on
(date)
in Application No.
A
.

.
appears at Appendix
.
to and including
(date) on
(date) in
Application No.
A
.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 16
15 of 91
13
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1530
528 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

Docket Number: 577
Judges: Black
380 U.S. 400 (1965)
POINTER
v.
TEXAS.
No. 577.
for petitioner.
defence."
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 17
14 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1531
529 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 18
15 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1532
530 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
I.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 19
16 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1533
531 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 20
17 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1534
532 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
II.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 21
18 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1535
533 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 22
19 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1536
534 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
course.
Louisiana, 379 U.S. 466, 472-473.[4]
subject.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 23
20 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1537
535 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
prosecution.[7]
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 24
21 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1538
536 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
NOTES
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 25
22 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1539
537 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

counsel." 349 U. S., at 134.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 26
23 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1540
538 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE


1
MOTIONS, ETC.,.
2
3
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 27
24 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1541
539 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
The
justice.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 28
25 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1542
540 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE


prison in 1997.
Appendix I.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 29
26 of 91
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1543
541 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 30 of 91
January January
Sunday
22, 201722, 2017

Page
Page1544
542 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 31 of 91
January January
Sunday
22, 201722, 2017

Page
Page1545
543 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
PROOF OF SERVICE
Mr. Craig Stedman,

50 N. Duke Street
Lancaster, PA 17602
Mr. XXXXXXXXX
Ibrahim, Jeremy
1700 Race St
Phone: (215) 568-1943
MCI - Framingham
P.O. Box 9007
xx 01704
Framingham,
PA

601 Market Street
xxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxx
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 32
29 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1546
544 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
October 2015
OFFICE OF THE CLERK
CERTIORARI
I. Introduction

U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 33
21 of 91
29
30
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1547
545 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
IV. What To File
le:
See Rule 39.1.
V. Page Limitation

U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 34
22 of 91
30
31
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1548
546 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
I.

petition.

Pauperis
forma pauperis.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 35
23 of 91
31
32
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1549
547 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

V. List of Parties
A. Federal Courts
B. State Courts
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 36
24 of 91
32
33
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1550
548 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

IX. Opinions Below
appears.
X. Jurisdiction
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 37
25 of 91
33
34
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1551
549 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

appears.
of the case.
XIV. Conclusion
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 38
26 of 91
34
35
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1552
550 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX A
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 39
36 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1553
551 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
COPY
Page 40
27 of 91
35
37
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1554
552 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 41
28 of 91
36
38
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1555
553 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 42
29 of 91
37
39
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1556
554 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 43
30 of 91
38
40
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1557
555 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX B
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 44
41 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
15-3400
January January
Sunday
22,Case:
201722,
2017
Document:
003112168218
Page:
1 StanDate
Filed:
12/31/2015
REQUEST
FOR
COMMUTATION
Page
Page1558
556 of
of1299
2301
OF
THE SENTENCE
J. Caterbone
OF
LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
December 31, 2015

To:

Clerk of Courts
Re:


course the U.S.C.A.

IMPORTANT
/S/
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 45
31 of 91
39
42
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1559
557 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX C
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 46
43 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1560
558 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 47
32 of 91
40
44
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1561
559 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 48
33 of 91
41
45
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1562
560 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 49
34 of 91
42
46
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1563
561 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX D
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 50
47 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1564
562 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 51
35 of 91
43
48
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1565
563 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 52
36 of 91
44
49
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1566
564 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 53
37 of 91
45
50
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1567
565 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 54
38 of 91
46
51
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1568
566 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 55
39 of 91
47
52
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1569
567 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 56
40 of 91
48
53
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1570
568 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 57
41 of 91
49
54
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1571
569 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX E
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 58
55 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1572
570 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 59
42 of 91
50
56
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1573
571 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 60
43 of 91
51
57
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1574
572 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 61
44 of 91
52
58
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1575
573 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 62
45 of 91
53
59
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1576
574 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX F
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 63
60 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
Case
Document
15
Filed
Page
1 of
3
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Page
Page1577
575 of
of
1299
2301
OF
THE 09/14/15
SENTENCE
Stan J. Caterbone
OF LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

Petitioner,
v.
Respondents.
:
:
:
:
:
:
:
:
Civ. No. 14-2559
ORDER
counseled motion.
(Doc. No. 3.)
Civ. P. 29(a).
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 64
54 of 91
61
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Case
Document
15
Filed
Page
2 of
3
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Page
Page1578
576 of
of
1299
2301
OF
THE 09/14/15
SENTENCE
Stan J. Caterbone
OF LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

On
Page 2 of 3
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 65
55 of 91
62
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Case
Document
15
Filed
Page
3 of
3
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Page
Page1579
577 of
of
1299
2301
OF
THE 09/14/15
SENTENCE
Stan J. Caterbone
OF LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
/s/ Paul S. Diamond

_________________________
Paul S. Diamond, J.
September 11, 2015
Page 3 of 3
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 66
56 of 91
63
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1580
578 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX G
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 67
64 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
Document
Filed
Page
1 ofLAMBERT
6
Sunday
January January
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1581
579 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

\
Petitioner
v.
MCI-FRAMINGHAM,
and
and
Respondents
Civ. No. 5:14-cv-02559-PD
S 17=n
F uu~t:
lY
SEP - 3 2D15
By
Dep. Clerk

which reads:
II
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 68
57 of 91
65
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Document
Filed
Page
2 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1582
580 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
United States.
2
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 69
58 of 91
66
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Document
Filed
Page
3 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1583
581 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Pl~.,
3
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 70
59 of 91
67
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
,jl
Document
Filed
Page
4 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1584
582 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
'
I
plaintiff.
4
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 71
60 of 91
68
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Document
Filed
Page
5 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1585
583 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
5
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 72
61 of 91
69
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
.#
Document
Filed
Page
6 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1586
584 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
scaterbone@live.com
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
6
Page 73
62 of 91
70
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1587
585 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX H
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 74
71 of 91
88
Wednesday
Wednesday
November
October 12,
15, 2016
1 of 2
January January
Sunday
22, 201722, 2017
Page
Page1588
586 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Visit AETV.com
SEARCH:
SHOP BY SUBJECT
Exclusively at
The A&E Store


06/11/07, why?

SHOP BY SHOW


Driving Force DVDs
Get $1 Shipping on
your entire order!
$24.95
Intervention DVDs
Qty: 1
Gift Finder
Toys & Games
Gift Certificates
DVDs en Espaol
Closed Caption
Catalog Request
Child's Play,
Deadly Play
DVD
American
Justice set DVD
$59.95
$24.95
Murder In A
College Town
DVD
$24.95
PRODUCT DETAIL:
-->
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 75
72 of 91
88
Page 1 of 4
Wednesday
Wednesday
November
October 12,
15, 2016
05.28.2007
5/28/2007 3:35 PM
January January
Sunday
22, 201722, 2017

Page
Page1589
587 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX I
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 76
73 of 91
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1590
588 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE

[Home Edition]
BARRY SIEGEL.
Los Angeles Times

U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 77
74 of 91
88
Page 1 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1591
589 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 78
75 of 91
88
Page 2 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1592
590 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE

to the camera?"
with Weaver.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 79
76 of 91
88
Page 3 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1593
591 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
put into evidence.
audiotapes.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 80
77 of 91
88
Page 4 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1594
592 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE

"Correct."
"Correct."
perjury.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 81
78 of 91
88
Page 5 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1595
593 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
agreement."
remedial steps."
none."
no?"
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 82
79 of 91
88
Page 6 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1596
594 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
"Yes sir."
Show's room.
now.
emotional problem."
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 83
80 of 91
88
Page 7 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1597
595 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
over with.

back then.
courageous act.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 84
81 of 91
88
Page 8 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1598
596 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
. . ."
just that.
how much."
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 85
82 of 91
88
Page 9 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1599
597 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
go."
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 86
83 of 91
88
Page 10 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1600
598 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
civil rights laws."
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 87
84 of 91
88
Page 11 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1601
599 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 88
85 of 91
88
Page 12 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1602
600 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
County.
They haven't.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 89
86 of 91
88
Page 13 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1603
601 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Lambert."
hearing.;
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 90
87 of 91
88
Page 14 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1604
602 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE

innocent.;
without permission.
special reports
ISSN/ISBN: 04583035
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 91
88 of 91
88
Page 15 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1605
603 of
of1299
2301
P
usps.com
Flat Rate Env
062S0000000314
Click-N-Ship
Mailed from 17603
9405 5036 9930 0427 6970 66 0064 5000 0022 0500

$6.45
US POSTAGE
11/16/2016
0006
C000
PRIORITY MAIL 2-DAY
STAN CATERBONE
AMG
1250 FREMONT ST
SHIP
TO: BARACH OBAMA

THE WHITE HOUSE
USPS TRACKING #
9405 5036 9930 0427 6970 66
Cut on dotted line.
Instructions
USPS TRACKING # :


the package.
9405 5036 9930 0427 6970 66

Trans. #:
Print Date:
Ship Date:
Expected
Delivery Date:
From:
To:
389217451
11/16/2016
11/16/2016

Total
$6.45
$6.45
11/18/2016
STAN CATERBONE
AMG
1250 FREMONT ST
BARACH OBAMA
THE WHITE HOUSE
USPS.com - USPS Tracking
https://tools.usps.com/go/TrackConfirmAction?tLabels=940550369930...
January January
Sunday
22, 201722, 2017
English
Page
Page1606
604 of
of1299
2301
Customer Service
USPS Mobile
Register / Sign In
Still Have Questions?
USPS Tracking
Browse our FAQs
Get Easy Tracking Updates

Sign up for My USPS.
Tracking Number: 9405503699300427697066
Expected Delivery Day: Friday, November 18, 2016
Product & Tracking Information

Postal Product:
Features:
Priority Mail
USPS Tracking
Available Actions
Up to $50 insurance included
Text Updates
Restrictions Apply
Email Updates
DATE & TIME
STATUS OF ITEM
LOCATION
November 17, 2016 , 2:02

am
Arrived at USPS Origin

Facility
LANCASTER, PA 17604
Delivery Instructions
Your item arrived at our LANCASTER, PA 17604 origin facility on November 17, 2016 at 2:02 am. The
item is currently in transit to the destination.
November 17, 2016 , 12:47

am
Accepted at USPS Origin

Facility
LANCASTER, PA 17603
November 16, 2016 , 2:50

pm
Departed Post Office
LANCASTER, PA 17604
November 16, 2016 , 1:43

pm
Acceptance
LANCASTER, PA 17604
Track Another Package
Manage Incoming Packages
Tracking (or receipt) number
Track all your packages from a dashboard.

No tracking numbers necessary.
Sign up for My USPS
1 of 2
11/17/2016 4:52 AM
January January
Sunday
22, 201722, 2017
Page
Page1607
605 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1608
606 of
of1299
2301
1 of 2
January January
Sunday
22, 201722, 2017
Page
Page1609
607 of
of1299
2301
12/10/2016 1:43 PM
2 of 2
January January
Sunday
22, 201722, 2017
Page
Page1610
608 of
of1299
2301
12/10/2016 1:43 PM
1 of 1
January January
Sunday
22, 201722, 2017
Page
Page1611
609 of
of1299
2301
11/17/2016 4:39 AM
January January
Sunday
22, 201722, 2017
Page
Page1612
610 of
of1299
2301


January January
Sunday
22, 201722, 2017

Page
Page1613
611 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Stan J. Caterbone

1250 Fremont Street

Lancaster, PA 17603
717-598-2200
November 15, 2016

THE WHITE HOUSE
Re:

Dear Mr. President,

Page 1 of 91
January January
Sunday
22, 201722, 2017

Page
Page1614
612 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Respectfully,
___________/S/____________
1250 Fremont Street

Lancaster, PA 17603
717-669-2163
Page 2 of 91
January January
Sunday
22, 201722, 2017

Page
Page1615
613 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
ACTIVE COURT CASES
Lambert
Page 3 of 91
January January
Sunday
22, 201722, 2017

Page
Page1616
614 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 4 of 91
January January
Sunday
22, 201722, 2017

Page
Page1617
615 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Income source

the past 12 months
Amount expected
next month
You
Spouse
You
Spouse
Employment
Self-employment

Gifts
Alimony
Child Support

security, pensions,

$ 1,357.00
Public-assistance
(such as welfare)
Other (specify):
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
1,357.00
Page 5
2 of 91
45
62
70
88
1,357.00
1,357.00
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1618
616 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Employer
Address
Dates of
Employment
Gross monthly pay

$
$
$
Employer
Address
Dates of
Employment
Gross monthly pay

$
$
$

institution.
Type of account
Members1st
TD Ameritrade
Checking
Money Market
Amount you have

$ 1,000.00
$ 12,000.00
$

$
$
$
X Home
D
Value 25% of 80,000.00
D Other real estate

Value
D Motor Vehicle #1
Year, make & model
Value
D Motor Vehicle #2
Year, make & model
Value
D Other assets
Description
Value
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 6
3 of 91
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1619
617 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 7 of 91
January January
Sunday
22, 201722, 2017

Page
Page1620
618 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
You
Your spouse
100.00
200.00
$
$

48.00
Life
Health
Motor Vehicle
Other:
300.00

$
Motor Vehicle
Credit card(s)
Department store(s)
Other:
Other (specify):
500.00
2,658.00
(specify):
Home Improvement
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 8
5 of 91
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1621
619 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 9 of 91
January January
Sunday
22, 201722, 2017

Page
Page1622
620 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
No.
IN THE
PETITIONER
(Your Name)
vs.
RESPONDENT(S)
(Your Name)
1250 Fremont Street
(Address)
Lancaster, PA 17603

(717) 669-2163
(Phone Number)
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page
Page10
7 of
of88
45
62
70
91
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1623
621 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Appellant received
He filed two
He simply
MOTION TO DISMISS?
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page
Page11
8 of
of88
45
62
70
91
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1624
622 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 12 of 91
January January
Sunday
22, 201722, 2017

Page
Page1625
623 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
TABLE OF CONTENTS
12
OPINIONS BELOW ........................................................................................................ 1
13
JURISDICTION...................................................................................................................

14
24
26
CONCLUSION....................................................................................................................
27
INDEX TO APPENDICES
APPENDIX A .............................................................................................................. 36
APPENDIX B ............................................................................................................... 41
APPENDIX C .............................................................................................................. 43
APPENDIX D .............................................................................................................. 47
APPENDIX E .............................................................................................................. 55
APPENDIX F .............................................................................................................. 60
APPENDIX G .............................................................................................................. 64
APPENDIX H .............................................................................................................. 71
APPENDIX I ............................................................................................................... 73
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 13
12 of 91
10
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1626
624 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
CASES
PAGE NUMBER
Appendix B -
STATUTES AND RULES
OTHER
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 14
13 of 91
11
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1627
625 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
IN THE

OPINIONS BELOW
the petition and is
to

; or,
[ ] is unpublished.
the petition and is
to
[ ] reported at
; or,
[ ] is unpublished.
Appendix
[ ] reported at
; or,
[ ] is unpublished.
The opinion of the
appears at Appendix
court
[ ] reported at
; or,
[ ] is unpublished.
1.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 15
14 of 91
12
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1628
626 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
JURISDICTION

was June 15, 2016
.
, and a copy of the
A
.
to and including
(date) on
(date)
in Application No.
A
.

.
appears at Appendix
.
to and including
(date) on
(date) in
Application No.
A
.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 16
15 of 91
13
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1629
627 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

Docket Number: 577
Judges: Black
380 U.S. 400 (1965)
POINTER
v.
TEXAS.
No. 577.
for petitioner.
defence."
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 17
14 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1630
628 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 18
15 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1631
629 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
I.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 19
16 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1632
630 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 20
17 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1633
631 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
II.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 21
18 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1634
632 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 22
19 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1635
633 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
course.
Louisiana, 379 U.S. 466, 472-473.[4]
subject.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 23
20 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1636
634 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
prosecution.[7]
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 24
21 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1637
635 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
NOTES
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 25
22 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1638
636 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

counsel." 349 U. S., at 134.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 26
23 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1639
637 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE


1
MOTIONS, ETC.,.
2
3
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 27
24 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1640
638 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
The
justice.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 28
25 of 91
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1641
639 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE


prison in 1997.
Appendix I.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 29
26 of 91
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1642
640 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 30 of 91
January January
Sunday
22, 201722, 2017

Page
Page1643
641 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Page 31 of 91
January January
Sunday
22, 201722, 2017

Page
Page1644
642 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
PROOF OF SERVICE
Mr. Craig Stedman,

50 N. Duke Street
Lancaster, PA 17602
Mr. XXXXXXXXX
Ibrahim, Jeremy
1700 Race St
Phone: (215) 568-1943
MCI - Framingham
P.O. Box 9007
xx 01704
Framingham,
PA

601 Market Street
xxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxx
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 32
29 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1645
643 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
October 2015
OFFICE OF THE CLERK
CERTIORARI
I. Introduction

U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 33
21 of 91
29
30
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1646
644 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
IV. What To File
le:
See Rule 39.1.
V. Page Limitation

U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 34
22 of 91
30
31
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1647
645 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
I.

petition.

Pauperis
forma pauperis.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 35
23 of 91
31
32
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1648
646 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

V. List of Parties
A. Federal Courts
B. State Courts
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 36
24 of 91
32
33
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1649
647 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

IX. Opinions Below
appears.
X. Jurisdiction
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 37
25 of 91
33
34
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1650
648 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

appears.
of the case.
XIV. Conclusion
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 38
26 of 91
34
35
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1651
649 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX A
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 39
36 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1652
650 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
COPY
Page 40
27 of 91
35
37
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1653
651 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 41
28 of 91
36
38
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1654
652 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 42
29 of 91
37
39
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1655
653 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 43
30 of 91
38
40
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1656
654 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX B
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 44
41 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
15-3400
January January
Sunday
22,Case:
201722,
2017
Document:
003112168218
Page:
1 StanDate
Filed:
12/31/2015
REQUEST
FOR
COMMUTATION
Page
Page1657
655 of
of1299
2301
OF
THE SENTENCE
J. Caterbone
OF
LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
December 31, 2015

To:

Clerk of Courts
Re:


course the U.S.C.A.

IMPORTANT
/S/
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 45
31 of 91
39
42
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1658
656 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX C
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 46
43 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1659
657 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 47
32 of 91
40
44
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1660
658 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 48
33 of 91
41
45
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1661
659 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 49
34 of 91
42
46
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1662
660 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX D
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 50
47 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1663
661 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 51
35 of 91
43
48
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1664
662 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 52
36 of 91
44
49
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1665
663 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 53
37 of 91
45
50
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1666
664 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 54
38 of 91
46
51
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1667
665 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 55
39 of 91
47
52
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1668
666 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 56
40 of 91
48
53
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1669
667 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 57
41 of 91
49
54
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1670
668 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX E
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 58
55 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1671
669 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 59
42 of 91
50
56
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1672
670 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 60
43 of 91
51
57
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1673
671 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 61
44 of 91
52
58
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1674
672 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 62
45 of 91
53
59
45
62
70
88
Wednesday
Wednesday
Tuesday
Sunday
November
October
October12,
10,
15,
9, 2016
January January
Sunday
22, 201722, 2017

Page
Page1675
673 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX F
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 63
60 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
Case
Document
15
Filed
Page
1 of
3
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Page
Page1676
674 of
of
1299
2301
OF
THE 09/14/15
SENTENCE
Stan J. Caterbone
OF LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

Petitioner,
v.
Respondents.
:
:
:
:
:
:
:
:
Civ. No. 14-2559
ORDER
counseled motion.
(Doc. No. 3.)
Civ. P. 29(a).
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 64
54 of 91
61
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Case
Document
15
Filed
Page
2 of
3
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Page
Page1677
675 of
of
1299
2301
OF
THE 09/14/15
SENTENCE
Stan J. Caterbone
OF LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

On
Page 2 of 3
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 65
55 of 91
62
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Case
Document
15
Filed
Page
3 of
3
January January
Sunday
22, 201722,
20175:14-cv-02559-PD
Page
Page1678
676 of
of
1299
2301
OF
THE 09/14/15
SENTENCE
Stan J. Caterbone
OF LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
/s/ Paul S. Diamond

_________________________
Paul S. Diamond, J.
September 11, 2015
Page 3 of 3
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 66
56 of 91
63
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1679
677 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX G
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 67
64 of 91
70
88
Wednesday
Wednesday
November
October 12,
15, 2016
Document
Filed
Page
1 ofLAMBERT
6
Sunday
January January
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1680
678 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE

\
Petitioner
v.
MCI-FRAMINGHAM,
and
and
Respondents
Civ. No. 5:14-cv-02559-PD
S 17=n
F uu~t:
lY
SEP - 3 2D15
By
Dep. Clerk

which reads:
II
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 68
57 of 91
65
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Document
Filed
Page
2 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1681
679 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
United States.
2
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 69
58 of 91
66
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Document
Filed
Page
3 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1682
680 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Pl~.,
3
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 70
59 of 91
67
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
,jl
Document
Filed
Page
4 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1683
681 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
'
I
plaintiff.
4
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 71
60 of 91
68
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
Document
Filed
Page
5 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1684
682 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
5
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 72
61 of 91
69
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
.#
Document
Filed
Page
6 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
Page
Page1685
683 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
scaterbone@live.com
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
6
Page 73
62 of 91
70
62
70
88
Wednesday
Wednesday
Tuesday
November
October 12,
10,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1686
684 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX H
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 74
71 of 91
88
Wednesday
Wednesday
November
October 12,
15, 2016
1 of 2
January January
Sunday
22, 201722, 2017
Page
Page1687
685 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Visit AETV.com
SEARCH:
SHOP BY SUBJECT
Exclusively at
The A&E Store


06/11/07, why?

SHOP BY SHOW


Driving Force DVDs
Get $1 Shipping on
your entire order!
$24.95
Intervention DVDs
Qty: 1
Gift Finder
Toys & Games
Gift Certificates
DVDs en Espaol
Closed Caption
Catalog Request
Child's Play,
Deadly Play
DVD
American
Justice set DVD
$59.95
$24.95
Murder In A
College Town
DVD
$24.95
PRODUCT DETAIL:
-->
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 75
72 of 91
88
Page 1 of 4
Wednesday
Wednesday
November
October 12,
15, 2016
05.28.2007
5/28/2007 3:35 PM
January January
Sunday
22, 201722, 2017

Page
Page1688
686 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
APPENDIX I
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 76
73 of 91
88
Wednesday
Wednesday
November
October 12,
15, 2016
January January
Sunday
22, 201722, 2017

Page
Page1689
687 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE

[Home Edition]
BARRY SIEGEL.
Los Angeles Times

U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 77
74 of 91
88
Page 1 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1690
688 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 78
75 of 91
88
Page 2 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1691
689 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE

to the camera?"
with Weaver.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 79
76 of 91
88
Page 3 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1692
690 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
put into evidence.
audiotapes.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 80
77 of 91
88
Page 4 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1693
691 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE

"Correct."
"Correct."
perjury.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 81
78 of 91
88
Page 5 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1694
692 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
agreement."
remedial steps."
none."
no?"
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 82
79 of 91
88
Page 6 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1695
693 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
"Yes sir."
Show's room.
now.
emotional problem."
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 83
80 of 91
88
Page 7 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1696
694 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
over with.

back then.
courageous act.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 84
81 of 91
88
Page 8 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1697
695 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
. . ."
just that.
how much."
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 85
82 of 91
88
Page 9 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1698
696 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
go."
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 86
83 of 91
88
Page 10 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1699
697 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
civil rights laws."
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 87
84 of 91
88
Page 11 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1700
698 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 88
85 of 91
88
Page 12 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1701
699 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
County.
They haven't.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 89
86 of 91
88
Page 13 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1702
700 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
Lambert."
hearing.;
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 90
87 of 91
88
Page 14 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017

Page
Page1703
701 of
of1299
2301
OF THE SENTENCE
Stan J. Caterbone
OF LISA LAMBERT
MICHELLECASE
LAMBERT
FILE

innocent.;
without permission.
special reports
ISSN/ISBN: 04583035
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Page 91
88 of 91
88
Page 15 of 15
Wednesday
Wednesday
November
October 12,
15, 2016
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1704
702 of
of1299
2301
P
usps.com
Flat Rate Env
062S0000000314
Click-N-Ship
Mailed from 17603
9405 5036 9930 0427 6970 66 0064 5000 0022 0500

$6.45
US POSTAGE
11/16/2016
0006
C000
PRIORITY MAIL 2-DAY
STAN CATERBONE
AMG
1250 FREMONT ST
SHIP
TO: BARACH OBAMA

THE WHITE HOUSE
USPS TRACKING #
9405 5036 9930 0427 6970 66
Cut on dotted line.
Instructions
USPS TRACKING # :


the package.
9405 5036 9930 0427 6970 66

Trans. #:
Print Date:
Ship Date:
Expected
Delivery Date:
From:
To:
389217451
11/16/2016
11/16/2016

Total
$6.45
$6.45
11/18/2016
STAN CATERBONE
AMG
1250 FREMONT ST
BARACH OBAMA
THE WHITE HOUSE
USPS.com - USPS Tracking
https://tools.usps.com/go/TrackConfirmAction?tLabels=940550369930...
January January
Sunday
22, 201722, 2017
English
Page
Page1705
703 of
of1299
2301
Customer Service
USPS Mobile
Register / Sign In
Still Have Questions?
USPS Tracking
Browse our FAQs
Get Easy Tracking Updates

Sign up for My USPS.
Tracking Number: 9405503699300427697066
Expected Delivery Day: Friday, November 18, 2016
Product & Tracking Information

Postal Product:
Features:
Priority Mail
USPS Tracking
Available Actions
Up to $50 insurance included
Restrictions Apply
Text Updates
Email Updates
DATE & TIME
STATUS OF ITEM
LOCATION
November 17, 2016 , 1:06

pm
Arrived at USPS
Destination Facility
CAPITOL
HEIGHTS, MD 20799
Delivery Instructions
Your item arrived at our CAPITOL HEIGHTS, MD 20799 destination facility on November 17, 2016 at
1:06 pm. The item is currently in transit to the destination.
November 17, 2016 , 5:56

am
Departed USPS Facility
LANCASTER, PA 17604
November 17, 2016 , 2:02

am
Arrived at USPS Origin

Facility
LANCASTER, PA 17604
November 17, 2016 , 12:47

am
Accepted at USPS Origin

Facility
LANCASTER, PA 17603
November 16, 2016 , 2:50

pm
Departed Post Office
LANCASTER, PA 17604
November 16, 2016 , 1:43

pm
Acceptance
LANCASTER, PA 17604
Track Another Package
Manage Incoming Packages
Tracking (or receipt) number
Track all your packages from a dashboard.

No tracking numbers necessary.
Sign up for My USPS
1 of 2
11/17/2016 6:39 PM
January January
Sunday
22, 201722, 2017
Page
Page1706
704 of
of1299
2301

[Home Edition]
BARRY SIEGEL.
Los Angeles Times

Page 1 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1707
705 of
of1299
2301
Page 2 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1708
706 of
of1299
2301

to the camera?"
with Weaver.
Page 3 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1709
707 of
of1299
2301
put into evidence.
audiotapes.
Page 4 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1710
708 of
of1299
2301

"Correct."
"Correct."
perjury.
Page 5 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1711
709 of
of1299
2301
agreement."
remedial steps."
none."
no?"
Page 6 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1712
710 of
of1299
2301
"Yes sir."
Show's room.
now.
emotional problem."
Page 7 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1713
711 of
of1299
2301
over with.

back then.
courageous act.
Page 8 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1714
712 of
of1299
2301
. . ."
just that.
how much."
Page 9 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1715
713 of
of1299
2301
go."
Page 10 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1716
714 of
of1299
2301
civil rights laws."
Page 11 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1717
715 of
of1299
2301
Page 12 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1718
716 of
of1299
2301
County.
They haven't.
Page 13 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1719
717 of
of1299
2301
Lambert."
hearing.;
Page 14 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1720
718 of
of1299
2301

innocent.;
without permission.
special reports
ISSN/ISBN: 04583035
Page 15 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1721
719 of
of1299
2301
American Justice - A Teenage Murder Mystery

Aired at 09:00 AM on Friday, Oct 15, 2010 (10/15/2010)
View all transcripts from this day
Transcript
00:00:02 Got a knife, and went in, and slipped my fingers under the rope, and cut it.
00:00:12 And she moaned.
At that time, I saw that her throat was cut, so I basically cradled her in my arms, trying to
00:00:15
hold her together.
>> Kurtis: Hazel would later tell police that even though laurie's neck wounds were
00:00:32
severe, her daughter managed to name her killer.
>> She said that, "michelle did " and then she kept saying, "love you," until she was just "
00:00:40
>> Kurtis: Hazel knew the name.
"Michelle" was 19-year-old lisa michelle lambert, who had been stalking her daughter for
00:00:59
months and had threatened to kill her.
Police had a warrant out for lambert's arrest, but had claimed they had been unable to
00:01:09
locate her.
00:01:17 Lambert was upset with laurie for having briefly dated her boyfriend, lawrence yunkin.
Lambert, a bleached blonde who changed her brown eyes to blue with colored contacts,
00:01:22
went exclusively by her middle name, michelle.
00:01:34 At age 15, she had dropped out of high school and moved out of her parents' house.
00:01:39 They had accused her of stealing money from them.
She had moved in with her boyfriend, and the young couple were now living in a trailer
00:01:44
in the woods.
Six months before the murder, in june, 1991, when lambert found out that laurie show
00:01:51 was having a fling with her boyfriend, she began making harassing phone calls to laurie's
house and announced that she was pregnant with lawrence's baby.
00:02:05 She accused laurie of ruining her life.
00:02:10 >> A couple of times I called.
00:02:12 There were problems.
00:02:14 I was pregnant.
00:02:17 I was pregnant, and I just wanted to basically leave everything alone.
00:02:22 I wanted to stop having problems.
00:02:24 I had no idea what I was going to do.
>> And if you answered the phone, she would just scream obscenities at you, scream at
00:02:27 you how laurie ruined her life, that laurie had sex with lawrence, what a bad person laurie
was.
00:02:43 And if you didn't answer the phone, it would just keep ringing and ringing.
00:02:48 >> Kurtis: Hazel show finally had to have her phone number changed and unlisted.
January January
Sunday
22, 201722, 2017
00:02:53
00:03:00
00:03:09
00:03:20
00:03:24
00:03:26
00:03:28
00:03:36
00:03:44
00:03:58
00:04:04
00:04:15
00:04:21
00:04:28
00:04:40
00:04:49
00:04:57
00:05:21
00:05:31
00:05:38
00:05:44
00:05:58
00:06:04
00:06:10
00:06:18
Page
Page1722
720 of
of1299
2301
After only a week, laurie broke off the relationship with lawrence, and he returned to his
old girlfriend.
Laurie told her mother that lawrence had raped her, but she decided not to file a police
report against him, fearing it would make lambert even angrier.
When lambert could no longer harass laurie show by phone, she began stalking her at the
dress shop in a local strip mall where laurie worked as a sales clerk.
>> Laurie would get really nervous, upset, and want to go a different way.
She just didn't want michelle to see her.
She was terrified of her.
>> Kurtis: One day in late november, 1991, as laurie show was chatting with friends
outside the mall, lambert and her boyfriend drove by.
Lambert got out of the car, walked up to laurie, slapped her, and banged her head against
the cab of a truck.
>> I said something to the effect, "if something happens to my baby or if my baby dies, i
could just kill you," or, "i'm " that's what I said.
>> Kurtis: Laurie show and her mother responded by filing an assault complaint against
lambert.
The following month, hazel show held her dying daughter in her arms, convinced that
lambert's jealous rage had robbed her of her only child.
Paramedics arrived at the show apartment, but it was no use.
16-Year-old laurie was pronounced dead before her body was removed from her
bedroom.
Detectives immediately began interviewing friends of both the victim, laurie show, and
their chief suspect, lisa michelle lambert.
>> The one line that I always .. one afternoon we were talking, she said, one way or
another, she will get laurie show out of the picture.
>> Kurtis: Detective john bowman was told that on numerous occasions, lambert had
tried to recruit friends to help her injure laurie.
>> There was one young lady that I talked to in particular that i remember the interview
very well-- basically described the plot where lisa lambert was going to take laurie show,
kidnap her, take her into the city, and then use a knife and slit her throat.
>> Kurtis: On the night of the murder, police found lambert and her boyfriend at the
garden spot bowling alley in nearby strasburg, pennsylvania.
With them was a friend, 17-year- old tabitha buck, who had a gash across her right cheek.
When officers demanded to know hoshe'd been hurt, lambert did the talking.
>> Lambert voluntarily blurted out, "oh, yeah, well, we got into a fight earlier this
morning with some hispanic " tabby never said nothing.
>> Kurtis: Police brought all three in for questioning.
At the station, they separated the teenagers and interrogated each of them about the laurie
show murder.
Lawrence yunkin admitted that at dropped off lambert and buck near laurie show's
apartment complex.
He said he thought they were going to beat up le.
January January
Sunday
22, 201722, 2017
00:06:22
00:06:30
00:06:39
00:06:51
00:07:04
00:07:11
00:07:22
00:07:37
00:07:40
00:07:47
00:07:52
00:07:58
00:08:12
00:08:16
00:08:22
00:08:33
00:08:37
00:08:44
00:08:52
00:08:55
00:09:04
00:09:08
00:09:18
00:09:26
Page
Page1723
721 of
of1299
2301
He claimed he went to a nearby McDONALD'S FOR BREAKFAST AND Returned 15

minutes later.
He was unable to find the two young women near the woods where they had planned to
meet, but that after driving around for a few minutes, he spotted them.
He said he saw blood on lambert's hand and said the girls smelled funny, so he drove
them to his trailer to shower, and then took tabitha to school.
Lawrence confessed to police that he and lambert then washed the clothing that lambert
and tabitha had worn that morning, placed it in a pink trash bag, and threw it in a
dumpster behind a local kmart.
They also tossed the murder weapon and a pair of bloody tennis shoes into the nearby
susquehanna river.
While they were disposing of the evidence, lawrence said lambert told him that she and
tabitha had accidentally stabbed laurie show in the back, and then slit her throat to put her
out of pain.
Lawrence also reported to police that the evening before the murder, he had taken lambert
to a local kmart, where she had purchased items that were taken a rope, ski hats, and
gloves.
By now, officers had found the pink trash bag.
Filled with blood-stained evidence, it confi lawrence's statement.
In another interrogation room, lisa michelle lambert had a different story.
While she admitted to being in the show apartment, she claimed that tabitha buck was the
one who had attacked laurie.
lambert had already reported to police wearing that morning, and her answer didn't match
what police had just found in the dumpster.
>> That's when she started to add, "oh, yeah, I lied to you.
I didn't have this kind of clothing on; instead, I had sweat pants," blah, blah, blah.
That's when she changed, because she knew, obviously, somebody, more than likely
yunkin, had .. where these clothing could be found.
>> Kurtis: Lambert now also confessed that it was her idea to visit laurie show.
But she claimed she simply wanted to talk to laurie and tell her that she had finally
decided to leave her alone.
According to lambert, tabitha buck knocked on laurie's front door, and when laurie
answered, tabitha forced her way inside.
Lambert soon followed.
She said tabitha and laurie were fighting in the hallway, and claimed that the fight
eventually led to laurie's bedroom, where laurie tried to grab the telephone, but tabitha
threw it down.
She said tabitha then began to stab laurie.
>> Her face was red, and, like, she was having a hard time breathing, and I had seen
tabitha stab her in the back one time.
>> Kurtis: Lambert said laurie's body was jerking and she couldn't look at her anymore,
so she turned away and ran out of the door.
When one of the detectives wanted to know who had cut laurie show's throat, lambert
responded with surprise.
January January
Sunday
22, 201722, 2017
00:09:33
00:09:40
00:09:47
00:09:49
00:10:03
00:10:06
00:10:20
00:10:27
00:10:42
00:10:47
00:11:48
00:11:54
00:11:58
00:11:59
00:12:00
00:12:02
00:12:06
00:12:09
00:12:12
00:12:14
00:12:21
00:12:23
00:12:25
00:12:27
00:12:29
00:12:30
00:12:33
00:12:38
00:12:41
00:12:45
00:12:53
00:12:54
00:15:04
Page
Page1724
722 of
of1299
2301
" .. I was totally shocked.

That was when I believed him that she was dead, because he ..
..
I was stunned.
Charged with first-degree murder.
Prosecutors, unable to place lambert's boyfriend lawrence yunkin at the crime scene, cut a
deal with him in which he agreed to testify against both women.
>> Kurtis: As the laurie show murder case unfolded, it would become far more than a
small-town teenage love triangle turned violent.
A federal judge would proclaim that it was the worst example of prosecutorial
misconduct in the English-speaking world, and the FBI would end up investigating
charges that police lied under oath and prosecutors engaged in a cover-up.
At the center of this legal firestorm: Lisa Michelle Lambert.
Was she a killer or the victim of false testimony?[ coughing, tea kettle whistle ] [ water
pouring ] Beat your worst flu symptoms.
New Theraflu Max D [ punches ] contains the most powerfulmedicineable without a
prescription to fightyour worst flu symptoms.
Theraflu Max D. Serious power.
pastime?
Saving money.
And like baseball, people love their stats.
I started bringing my lunch to work -- 50 bucks a weekin my pocket.
Here's a good one: State farm insures40 million drivers.
More than geico and progressivecombined.
I saved becausei'm accident-free.
Of course,with so many ways to save including discountsof up to 40%, having that many
customersshouldn't be a surprise.
So ask a neighborabout state farm.
We saved when we insuredboth cars.

then call a state farm agent.
Popcorn!
Yeah! now that's whati'm talking about!
com to find out how much you couldsave on your auto insurance.
I saved because theyinsure my home too.
[ chuckles ] With 40 million fansout there, you're bound to knowone of them.
So talk to your neighbors, then call a state farm agent at 1-800-state-farm or visit
discountdoublecheck.com.

good hot dog.
>> Kurtis: On march 19, 1992, while awaiting trial for murder in a pennsylvania prison,
lisa michelle lambert was transferred to a nearby hospital, where she gave birth to a baby
January January
Sunday
22, 201722, 2017
00:15:18
00:15:21
00:15:27
00:15:32
00:15:40
00:15:44
00:15:53
00:16:10
00:16:17
00:16:20
00:16:30
00:16:40
00:16:46
00:17:00
00:17:06
00:17:12
00:17:20
00:17:28
00:17:37
00:17:39
00:17:44
00:17:46
00:17:56
00:17:58
00:18:04
00:18:10
00:18:22
Page
Page1725
723 of
of1299
2301
girl, whom she named kirsten.

The baby was placed in the custody of lambert's parents.
The biological father, lawrence yunkin, was also in prison and was no longer lambert's
boyfriend.
He was now the government's key witness against her.
Four months later, in july, fearing that perhaps any local jury would convict her, lambert
gave up her right to a trial by jury.
Instead, judge lawrence stengel would now decide her fate.
Prosecutors argued that lambert had planned and committed the murder of laurie show
and that she deserved to die for it.
>> Michelle lambert admitted that the statements of the witnesses regarding the
harassment, the threats to kill were accurate and disputed only whether she, lambert, ever
stated that she wanted to slit laurie show's throat.
>> Kurtis: Investigators had found a knife in the river where lambert's boyfriend
lawrence yunkin had said they dumped evidence.
It matched the knives in their trailer home.
Neighbors of laurie show also testified that on the morning of the murder they had seen
what appeared to be two women of equal height leaving the apartment complex.
This, the prosecutor argued, would exclude yunkin, who was much taller than lambert
and buck, who were roughly the same height.
A witness also confirmed seeing LAWRENCE AT a McDonald's that morning.
Prosecutors also leaned hard on the testimony of the murder victim's mother, hazel show,
who told the judge that she heard her dying daughter say, quote, "michelle did it,"
referring to lisa michelle lambert.
>> It seemed, quite honestly, like a pretty cut-and-dried murder case.
We've got the murder, we've got the suspects, and they seemed like the guilty parties.
>> Kurtis: In her defense, lambert took the stand and claimed that tabitha buck and her
former boyfriend lawrence were the real killers.
She insisted that she had been covering for lawrence when she told police that he was not
in the apartment on the morning of the murder.
Lambert told the judge that she had only planned to tie laurie up and cut her hair, but that
tabitha had gone wild, stabbing her with the knife.
>> Tabitha had gone crazy.
She had hurt laurie, and I tried to get her off of laurie.
I tried to get laurie out of there, and I couldn't do it.
I ran outside and I ran into lawrence, and lawrence took me down the stairs and pushed
me down and gave me an order to stay there, and that's where i stayed.
He ran back up the stairs.
The door slammed, I heard more .. that was all I know.
>> Kurtis: Prosecutor jack kenneff argued that lambert's story had conveniently evolved.
>> Initially, she said that none of them were there and that none of the three had anything
to do wi it then shifted to lawrence yunkin was totally innocent of the crime.
And by the time she got to trial, she was able to say that she actually saw lawrence
January January
Sunday
22, 201722, 2017
00:18:28
00:18:31
00:18:37
00:18:44
00:18:52
00:18:56
00:18:58
00:19:00
00:19:11
00:19:56
00:20:03
00:20:08
00:20:12
00:20:20
00:20:35
00:20:40
00:20:43
00:20:57
00:21:03
00:21:20
00:21:35
00:21:45
Page
Page1726
724 of
of1299
2301
yunkin go into the apartment.

So her story has changed over time.
>> Kurtis: Lambert said she initially er boyfriend because she thought laurie's death was
an accident.
She said she changed her mind about lying for him after they exchanged one of many
letters in prison.
In a strangely worded document that came to be known as "the 29 questions," yunkin
responded to a series of questions that lambert posed to him.
She claims lawrence's answers shocked her.
>> He basically didn't care.
He was like a monster.
In one of the questions, I asked him, "i know you're sorry and you didn't mean to kill her
and everything," because at that point I believed that he really hadn't meant to do it.
" >> Kurtis: Another question "will you always stick with me as long as I still don't tell
that you held laurie down " lawrence's answer, which doesn't quite match the question is:
" "are you sure that if I take the blame for you that I'll get less time," lambert writes, " "
lawrence yunkin tried to claim that his handwriting had been forged on the document, but
a prosecution expert testified that the document had not been >> the questions were
written by lambert, and yunkin wrote the answers.
>> Kurtis: The most controversial issue, however, was whether the dying teenager could
have named her killer.
Lambert's defense argued that it been impossible for laurie to speak.
Her neck had been slashed from ear to ear and her wound was more than an inch deep.
But even the defense experts were unable to rule out the possibility that she may have
spoken.
In the end, judge lawrence stengel said he believed laurie " >> we could not prove exactly
what her role was in the crime, but I think we clearly proved that she participated and that
she shared the intent to kill.
>> Kurtis: The judge returned a verdict of guilty of first- degree murder and criminal
conspiracy.
Lambert was sentenced to life in prison.
>> Kurtis: The judge said he spared lambert's life because of her youth, her lack of a
criminal record, and because he thought she could make a contribution, albeit in prison,
to her baby daughter and family.
Two months later, in september, 1992, tabitha buck went fore a jury in nearby
northampton county.
Her attorney argued that tabitha had no motive to kill laurie and that the murder was the
work of lambert and lawrence yunki the jury disagreed, however, and sentenced her to
life in prison without parole.
Yunkin's deal with the county had been called off after prosecutors accused him of lying
in his testimony about the " in october, he agreed to plead no contest to third-degree
murder and was sentenced to ten to 20 years in state prison.
By this time, lambert was already in state prison, and by her own account, living in fear.
>> Kurtis: Soon after she began serving her life sentence, Lisa Michelle Lambert accused
January January
Sunday
22, 201722, 2017
00:21:53
00:22:01
00:23:05
00:23:05
00:23:06
00:23:08
00:23:10
00:23:32
00:23:33
00:23:35
00:23:37
00:23:40
00:23:42
00:23:44
00:25:19
00:25:22
00:25:29
00:25:30
00:25:34
00:25:38
00:25:40
00:25:41
00:25:43
00:26:02
00:26:04
00:26:07
00:26:07
00:26:08
00:26:10
00:26:11
00:26:12
00:26:13
00:26:15
00:26:22
00:26:23
Page
Page1727
725 of
of1299
2301
a guard of raping her and was transferred to a prison in New Jersey.

Over the next four years, she appealed her case, until she finally won the attention of a
federal judge in Philadelphia.
The result for Lambert was a stunning reversal of fortune. Announcer ]WE Invited top
stylists to test OUR ProfessionalsHAIR CARE LINE.
[ Male Stylist 1 ] I LOVE NATURAL INGREDIENTS.
[ Female Stylist 2 ] I'M JEALOUS.
[ Female Announcer ] BUT IT'S NOT A SALON Brand.
IT'S Suave Professionals.
[ Female Announcer ] Suave Professionals With natural almond and shea butter is salonproven to moisturize as well as Aveda Dry Remedy.
Ready to try something new?
Campbell's has made changes.
Adding lower sodium sea salt to more soups.
Plus five dollars in coupons to get you started.
Campbell's condensed soup.
Pass it on.
it's amazing nnouncer ] PRILOSEC OTC alaska.
Home of one of the coldest, longest nights on the planet.
And asked frequent heartburn sufferers, like carl, to put prilosec otc' hour heartburn
protection to the test for two weeks.
The results?
I can concentrate on everything I'm doing, not even think about it anymore.
Since I've been taking it, I've been heartburn free, which is a big relief for me.
[ Male Announcer ] Take your 14-day challenge.
prilosec otc.
Heartburn gone. power on.
Ou ate this -- busted.
You know she always finds out.
Oooh!
You ruined mom's tablecloth.
Not this time.
What's that?
My get out of jail free card.
No way. you're busted.
[ chuckles ] [ Male Announcer ] Tide stain release.
An in-wash booster that works with any detergent, to target and remove tough stains the
first time.
[ Dad ] SEE?
Hey, look who's home.
January January
Sunday
22, 201722, 2017
00:26:23
00:26:23
00:26:26
00:26:28
00:26:29
00:26:39
00:26:48
00:27:05
00:27:10
00:27:21
00:27:25
00:27:27
00:27:34
00:27:49
00:28:00
00:28:02
00:28:10
00:28:20
00:28:34
00:28:44
00:28:53
00:29:08
00:29:21
00:29:33
00:29:38
Page
Page1728
726 of
of1299
2301
Huh.
What's that?
[ Male Announcer ] Tide stain release.
Stains out. no doubt.
Now also available as a pre-treat spray.
>> Kurtis: After her conviction in 1992 for first-degree murder, lisa michelle lambert
appealed her case, but was turned down every time.
Then, in 1996, she mailed a handwritten note to a federal judge in philadelphia and set in
motion a chain of events that would stun the legal world and horrify those who were
convinced of her guilt.
>> I wrote that police and prosecutors had framed me.
I wrote about the 29 questions that lawrence yunkin had admitted in his own handwriting
that he and tabitha buck had killed laurie show and that i was innocent.
>> Kurtis: In legal terms, lambert's letter was a petition under a clause in the u.s.
Constitution called habeas corpus.
It lets a federal judge decide if someone is being unjustly held in prison.
>> Normally what happens if a federal judge finds that there were substantial errors in a
state criminal proceeding of a federal constitutional nature, the federal judge will order
the state either to release the prisoner or to retry the prisoner.
>> Kurtis: The judge to whom lambert wrote, stewart dalzell, passed her letter along to a
big law firm in philadelphia, where it caught the eye of 34-year-old attorney christina
rainville.
She took the case.
Rainville was struck by the plea bargain that lambert's boyfriend, lawrence yunkin, had
worked out with lancaster county prosecutors.
She couldn't understand why investigators had discounted the possibility that yunkin had
played a greater role in the murder than he claimed.
>> In fact, the day before the murder, yunkin told his best friend at work that he was
never going to be back at work because he was going to be in jail for murder and that he
was planning to kill a girl over the weekend.
I think the evidence shows, in retrospect, that yunkin and buck this murder and that lisa
was set up to be there.
>> Kurtis: To her new lawyers, lambert seemed like an abused woman who had obeyed
an abusive boyfriend, even if that meant going to prison.
>> She both covers for yunkin because he tells her she has to-- he's saying, "you're a girl,
you'll get off easily"-- and she's doing what she's told, which is her conditioned reflex,
especially at times of crisis.
>> Kurtis: Her attorneys concluded that not only was lambert's 1992 trial a miscarriage of
justice, but she was, in fact, innocent of the crime for which she'd been convicted.
Over the fierce objections of lancaster county prosecutors, judge dalzell agreed to a
hearing and gave lambert's aggressive new lawyers access to nearly everything in the
government's files on the case.
The emerging evidence painted a troubling picture.
>> We've alleged over 200 errors that occurred in her trial, including 60 items of
January January
Sunday
22, 201722, 2017
00:29:57
00:30:10
00:30:19
00:30:25
00:30:32
00:30:44
00:30:53
00:31:03
00:31:10
00:31:33
00:31:44
00:31:55
00:32:02
00:32:13
00:32:23
00:32:35
00:32:42
00:32:50
00:32:59
00:33:03
Page
Page1729
727 of
of1299
2301
favorable evidence that the prosecution had that they didn't turn over to the defense, as
they're required to do so by law.
>> Kurtis: Among the items allegedly suppressed were pieces of evidence found at the
crime scene, a police videotape, and statements from witnesses that seemed to contradict
the county's version of events.
Lambert now made the stunning claim that three lancaster county police officers had
raped her six months before the murder.
She said prosecutors had focused on her to protect these men.
With their case gaining new attention, lambert's defenders also set to work reinventing
their client.
The blonde-haired beauty who went by her middle name, michelle, and wore blue contact
lenses now called herself lisa lambert and had brown hair and dark eyes.
>> Rainville probably thought that she'd get a lot further and get a sweeter image of lisa
to the public if she changed her image.
>> Kurtis: When the hearing began in march, 1997, lambert's attorneys claimed that the
lancaster county case was an elaborate frame-up and that tabitha buck and lawrence
yunkin were the true murderers.
They argued that the only thing their client was guilty of was trying to protect her
boyfriend.
>> If she doesn't cover up for him, he's going to get off anyway, because he always gets
away with things, and that's going to be an enormous risk to her child, that if she defies
him, when the child is born he will inflict some harm on the child, and she >> Kurtis:
Over the next 12 days, the defense brought in a parade of witnesses who took apart
lambert's 1992 trial.
Citing hospital records, an expert on physical and sexual abuse of women testified that
lambert's relationship with yunkin was abusive.
A speech expert attacked the notion that the dying laurie show could have spoken, saying
her neck wounds were far too severe for her to have formed any words.
But even more damning to the government's case were the revelations about misconduct
by investigators and prosecutors.
Lambert's defense team had discovered crime-scene evidence that lancaster county
prosecutors had ignored or failed to disclose to lambert's trial lawyer.
>> In 1992, the police testified at lisa's trial they never found a pink trash bag, they never
found any trash bags, and they never found any sneakers.
In 1997, we obtained video tape of the police finding the pink trash bag on the river bank,
and that information was suppressed.
>> Kurtis: Prosecud every one of the defense claims and insisted they had neither
destroyed nor tampered with any evidence.
>> When you look at the total picture, is this a case of a frame-up, of the police
deliberately engaging in misconduct?
Or is it a case, as the commonwealth now says, "well, there may have been some small
mistakes, but they didn't affect the ultimate outcome in any way"?
>> Kurtis: Judge dalzell grew increasingly impatient with the prosecutors.
On the stand, the local officials repeatedly contradicted themselves and the evidence.
January January
Sunday
22, 201722, 2017
00:33:07
00:33:13
00:33:16
00:33:21
00:33:25
00:33:47
00:33:52
00:34:03
00:34:19
00:34:25
00:34:35
00:34:41
00:34:52
00:34:54
00:34:55
00:34:58
00:35:11
00:35:18
00:35:26
00:35:34
00:35:39
00:35:45
00:36:01
00:36:09
00:36:21
00:36:26
Page
Page1730
728 of
of1299
2301
The judge began to berate them openly.

>> The judge was just against us from the beginning.
It was evident that he hated the police; he just hated lancaster county.
He didn't want, you know, anything to do with us.
I n't think you ould be able to go into a courtroom and the first day feel that he's going to
grant her an appeal, and from the second day feel that he wants to find a way to let her
go.
>> Kurtis: In lancaster county, the public followed the trial in disbelief.
>> I covered the hearing in philadelphia, so I'd have to call in here every day with my,
you know, view on what was happening today, and everyone would go, "well, do you
thing she's going to get off?
.." after hearing a couple of days of that federal hearing, I said, "i think she's going to get
out of here, something's going to " >> Kurtis: One of the people most troubled by the
federal hearing was the mother of the murder victim, hazel show.
And yet, she was the one who, in the end, revealed information that helped lambert's
cause.
In a private meeting with the lancaster district attorney, she now recalled that she had
seen lawrence yunkin near her apartment on the morning of the murder.
At the time, she said a police officer had told her not to worry about it.
It now emerged that, in fact, both hazel and a neighbor had while police had known about
this, they had failed to follow up on the lead.
>> They knew lawrence was involved.
They knew he was there.
And from day one, they just withheld that from the defense.
>> We force the state to prove guilt beyond a reasonable doubt before we imprison
somebody, and we say play fair by the rules: Don't manufacture evidence, don't hide
evidence, turn over exculpatory evidence, do it fairly.
>> Kurtis: The prosecutors' failure to disclose this information back in 1992 was
potentially illegal.
After all, a key part of their case was that lawrence yunkin could not be placed at the
crime scene, while lisa lambert could be.
This new informationid not prove that lawrence was in the apartment, but it would no
doubt have been useful in lambert's 1992 defense.
had no choice but to have hazel show tell the judge.
In a meeting in his chambers, she told her story, and immediately, chaos ensued.
>> So I get the words out that i actually saw lawrence's face that morning, and the judge
immediately says that she deserves relief.
And all this is going on, and I'm not talking anymore, I'm not telling him anything,
because he doesn't want to hear anymore.
And then they start talking about releasing her, and I'm " >> Kurtis: Judge dalzell had
heard enough.
By his count, six state witnesses had perjured themselves before him.
He declared that he was unaware of a case in the english- speaking world with as much
January January
Sunday
22, 201722, 2017
00:36:33
00:36:39
00:36:44
00:36:55
00:37:03
00:37:05
00:37:14
00:37:17
00:37:26
00:37:33
00:37:36
00:39:14
00:39:16
00:39:19
00:39:20
00:39:22
00:39:24
00:39:26
00:39:28
00:39:30
00:39:34
00:39:43
00:39:45
00:39:48
00:39:55
00:39:58
00:40:01
00:40:10
00:40:13
00:40:15
00:40:16
00:40:18
00:40:20
Page
Page1731
729 of
of1299
2301
misconduct by police and prosecutors.

He demanded that lambert be released immediately.
On the final day of the hearing, judge dalzell declared lambert innocent of all charges.
He accused lancaster county of making a "pact with the devil," and argued that the
prosecutors' misconduct violated lambert's constitutional right to due process.
In an unusual twist, he forbade the state of pennsylvania from ever retrying her.
He then ordered the u.s.
Attorney's office in to investigate county police and prosecutors.
>> Kurtis: The decision sent shock waves through the judicial system.
A number of states began lining up with Pennsylvania to contest the right of a federal
judge to forbid the state from re-trying Lambert.
Back in Lancaster County, Laurie Show's parents began a petition drive calling for the
impeachment of Judge Dalzell.
Lisa Michelle Lambert, meanwhile, was a free woman...
but not for long.(announcer)LIVING WITH ULCERATIVE Colitis?
I'm going sixtimes a day.
I had threeflares last year.
So many pills.
I missed myinterview.
My son'sgraduation.
The stomach pain.
I can't standthe steroids.
Isn't there anythingelse we can do?
(announcer)IF YOU'RE ON MEDICATIONS AND STILL Flaring, your uc may notbe
under control.
TAKE THE UC CONTROL QUIZAT livingwithuc.com And talk to your
gastroenterologist about the results andcurrent treatments.
bed Subway!
[ Male Announcer ] A BIG DAYDESERVES A BETTER Breakfast.
Choose froma dee-licious lineup OF OUR NEWEST $5 Footlong BREAKFAST MELTS,
LIKE THE Sunrise Subway Melt.
[ Strahan ] Subway.Build Your Better Breakfast.
your Subway With the $2.50 breakfast combo.
cup of piping-hot seattle's best coffee AND A SAVORY NEW SUNRISE Subway MELT
Built fresh to your order for just $2.50.
Subway. BUILD YOURBETTER BREAKFAST.
Ia can't be governed anymore.
I say baloney.
This state belongs to all of us.
We just have to decide we want to change.
I know government isn't a business and it shouldn't be, but the same values of
accountability and focus that make california businesses among the best in the world
January January
Sunday
22, 201722, 2017
00:40:32
00:40:38
00:40:40
00:42:09
00:42:18
00:42:28
00:42:41
00:42:47
00:42:58
00:43:04
00:43:08
00:43:11
00:43:16
00:43:30
00:43:34
00:43:46
00:44:00
00:44:08
00:44:14
00:44:31
00:44:35
00:44:47
00:44:54
00:45:10
00:45:13
Page
Page1732
730 of
of1299
2301
could do a lot to fix sacramento.

I'm on a mission to create more jobs, stop wasteful spending, and improve our schools.
Let's get to work.

>> Kurtis: On april 16, 1997, lisa michelle lambert walked out of judge stewart dalzell's
philadelphia courtroom a free woman.
The federal judge had declared her innocent and accused police, prosecutors, and exboyfriend lawrence yunkin of conspiring against her.
The decision provoked angry criticism in lancaster county, pennsylvania, where locals
gathered 37,000 signatures calling for the judge to be impeached.
Six states joined pennsylvania in filing a brief to the third circuit court of appeals.
They argued that lambert's federal hearing violated states' rights because lambert had not
yet presented her new allegations in state court first.
The court agreed, ruling that lambert should never have been in federal court in the first
place.
>> They didn't say one thing or another as to whether judge dalzell was right or wrong.
They just said let the state court decide those issues first.
>> Kurtis: So after ten months of freedom, lambert was returned to her new jersey prison
cell.
>> The first time that I was free and I walked out into the sunshine, I thought, "i'll never
be back in prison; I'll never " and here I am again, going through the same thing.
>> Kurtis: Now lambert would have to argue her case again in lancaster county court.
The pennsylvania attorney general's office, now of the case, prepared to argue that for
lambert's story to be believed, nearly 100 people would have had to be involved in the
conspiracy.
>> And that includes people that have no knowledge of one another, don't know one
another at all, have no reason-- or if they do know one another, have no reason to be
involved in this huge conspiracy together.
>> Kurtis: Not only did the frame-up seem unlikely, according to fawcett, the motive for
the frame-up, an alleged gang rape, was equally unbelievable.
Since her imprisonment, lambert had alleged rape on numerous other occasions.
>> The allegations included police officers, included family members, included prison
guards, included other men with whom she had had contact with, friends or friends of
friends.
And when we added all that up, we came to a figure of at least 11.
>> Kurtis: In april, 1998, lambert was again in front of judge lawrence stengel, the same
judge who had returned a guilty verdict against her back in 1992.
Now she had to prove that she had been unjustly convicted in that trial.
In her opening argument, lambert's defense attorney christina rainville again argued that
east lampeter police officers had raped lisa lambert six months prior to the murder of
laurie show and had then conspired with prosecutors to frame her.
Ime, however, the defense added another stunning allegation.
Lambert's attorneys said investigators took laurie show's body out of the morgue and
January January
Sunday
22, 201722, 2017
00:45:21
00:45:29
00:45:39
00:45:49
00:45:55
00:46:03
00:46:14
00:46:21
00:46:26
00:46:29
00:46:32
00:46:36
00:46:39
00:46:52
00:47:00
00:47:10
00:47:17
00:47:23
00:47:29
00:47:31
00:47:32
00:47:36
00:47:52
00:48:01
00:48:03
00:48:05
Page
Page1733
731 of
of1299
2301
moved it back to the apartment to stage crime-scene photographs.

They claimed these photos, which do not match the official crime- scene sketches, were
staged to implicate lambert.
>> Our belief that to redo the crime-scene photographs, laurie show's body had to be
returned to the crime scene.
>> The evidence shows that they did whatever was necessary to recreate the cri
photographs in a way that would discredit lisa.
>> Kurtis: Officers deny the charge and insist that the allegations by lambert's defense
were misleading.
The most implausible allegation for fawcett was lambert's claim to have been sexually
assaulted by county police officers.
In fact, one of the officers whom lambert accused of raping her, john bowman, was away
on his honeymoon, out of state, at the time she alleges that he broke into her house and
attacked her.
The officer submitted a marriage certificate and hotel receipts as proof.
>> You know, that allegation, in and of itself, really shot miss lambert's credibility.
This rape just didn't happen.
>> Kurtis: Lambert's charges also angered tabitha buck.
By this time, tabitha had already spent six years in prison.
She now agreed to tell her side of the story for the first time.
On the stand, buck admitted that by holding laurie show down during the struggle, she
had been an accomplice to her death, but claimed that it was lambert who actually
committed the murder.
>> Tabitha buck described what occurred at the conclusion of this incident, where laurie
show was already seriously injured.
She was on the floor, bleeding badly, and lambert kneeled next to her and sawed her neck
like a loaf of bread.
>> Kurtis: Tabitha also testified that lawrence yunkin was never in the apartment, and
accused lambert of lying to get out of prison.
Lambert insists that tabitha is the one lying.
>> She nailed her own coffin shut, and she is just trying to drag me down.
I think she's bitter.
I think she's miserable.
She knows she's never, ever going to get out of prison.
>> Kurtis: Throughout the eight weeks of court proceedings, prosecutors argued that it
was lambert who had the motive to kill, who had committed the previous assaults, and
who had purchased the rope, ski hats, and gloves that were taken to the apartment the
morning of the murder.
>> Lambert's conduct after the murder occurred indicated that it was her who planned
this thing, who carried it out, and so forth.
She was the one who got rid of evidence.
She admitted getting rid of evidence.
She told police about that.
January January
Sunday
22, 201722, 2017
00:48:07
00:48:16
00:48:19
00:48:22
00:48:25
00:48:28
00:48:32
00:48:46
Page
Page1734
732 of
of1299
2301
>> Kurtis: In the end, fawcett said that lambert's had tried just about everything to distract
attention from the fact that she was guilty of murder.
>> And the allegations were so outrageous.
I mean, there's no other way to say it than outrageous.
But the bottom line, of course, is none of them have been proven to be true.
>> Kurtis: Judge stengel agreed that lambert's allegations were implausible.
He denied her petition and ordered that she remain in prison.
>> Kurtis: In a 300-page opinion, Judge Lawrence Stengel said mistakes might have been
made by Lancaster police and prosecutors, but they did not amount to a conspiracy, and
they certainly didn't exonerate Lambert from the murder of Laurie Show.
Still, Lambert's case was far from over.
In a killers words: Lisa Michelle Lambert, nearly 25 years since Laurie ...
January January
Sunday
22, 201722, 2017
LNP Lisa Michelle Lambert Book

New Book
Rebuttal
1 of 11
http://lancasteronline.com/news/local/in-a-killer-s-words-lisa-michelle-l...
Page
Page1735
733 of
of1299
2301
Page 1 of 151
143
January 31, 2016

1/31/2016 9:25 PM
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
2 of 11
Page
Page1736
734 of
of1299
2301
Page 2 of 151
143
January 31, 2016

1/31/2016 9:25 PM
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
3 of 11
Page
Page1737
735 of
of1299
2301
Page 3 of 151
143
January 31, 2016

1/31/2016 9:25 PM
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
4 of 11
Page
Page1738
736 of
of1299
2301
Page 4 of 151
143
January 31, 2016

1/31/2016 9:25 PM
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
5 of 11
Page
Page1739
737 of
of1299
2301
Page 5 of 151
143
January 31, 2016

1/31/2016 9:25 PM
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
6 of 11
Page
Page1740
738 of
of1299
2301
Page 6 of 151
143
January 31, 2016

1/31/2016 9:25 PM
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
7 of 11
Page
Page1741
739 of
of1299
2301
Page 7 of 151
143
January 31, 2016

1/31/2016 9:25 PM
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
8 of 11
Page
Page1742
740 of
of1299
2301
Page 8 of 151
143
January 31, 2016

1/31/2016 9:25 PM
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
9 of 11
Page
Page1743
741 of
of1299
2301
Page 9 of 151
143
January 31, 2016

1/31/2016 9:25 PM
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
10 of 11
Page
Page1744
742 of
of1299
2301
Page 10 of 151
143
January 31, 2016

1/31/2016 9:25 PM
January January
Sunday
22, 201722, 2017
Page
Page1745
743 of
of1299
2301

__________________________________________________________________________
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:

Petitioner
v.
MCI-FRAMINGHAM,
and
CRAIG STEDMAN, THE DISTRICT ATTORNEY OF LANCASTER
and
KATHLEEN KANE, THE ATTORNEY GENERAL OF PENNSYLVANIA,
Respondents
Civ. No. 5:14-cv-02559-PD

which reads:
Rule 56. Summary Judgment

summary judgment, identifying each claim or defenseor the part of each claim or defenseon which
a party may file a motion for summary judgment at any time until 30 days after the close of all discovery.
1
New Book
Rebuttal
Page 11 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017
Page
Page1746
744 of
of1299
2301

the courts must conclude that In The United States District Court For The Eastern District of Pennsylvania, Federal Judge Stuart Dalzalls findings of April 14, 1997, in the Lisa Lambert case identifying acts
Lisa Michelle Lambert to the superior matter of restoring the integrity to the courts; by its own admis sion of wrongdoing, assuring the peoples of its commitment to administer equalities of justice, not inequalities of justice, balancing the scales of justice. Anything less, would take the full scope of jurisdiction out of the boundaries of our laws, negating our democracy and impugning the Constitution of the
United States.
2
New Book
Rebuttal
Page 12 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017
Page
Page1747
745 of
of1299
2301
I, Stanley J. Caterbone being duly sworn according to law, make the following affidavit concerning the years during which I was maliciously and purposefully mentally abused, subjected to a
10,000 documents, over 50 hours of recorded conversations, transcripts, and archived on several digi tal mediums. A Findings of Facts is attached herewith providing merits and the facts pertaining to
International Signal & Control, Plc. However, the merits of the violations contained in this affidavit will
are a direct consequence of my public disclosure of fraud within International Signal & Control, Plc., of
my shareholder rights granted in 1983, when I purchased my interests in International Signal & Con trol., Plc.. I will also prove intentional undo influence against family and friends towards compromising
the credibility of myself, with malicious and self serving accusations of insanity. I conclude that the
Courts would only challenge the judicial integrity of our Constitution.1. The activities contained herein
to the criminal record of International Signal & Control, including the illegal transfer of arms and technologies to an end user Iraq, the laws of disclosure must be forfeited by virtue that said activities
posed a direct compromise to the National Security of the United States.; the plaintiff will argue that
his public allegations of misconduct within the operations of International Signal & Control, Plc., as
States.. The activities of International Signal & Control, Pls., placed American troops in harms way. The
plaintiffs actions should have taken the American troops out of harms way causing the activities of the
International Signal & Control, Plc., to cease and desist. All activities contained herein have greatly
compromised the National Security of the United States, and the laws of jurist prudence must apply towards the Plaintiffs intent and motive of protecting the rights of his fellow citizens. Had the plaintiff
been protected under the law, and subsequently had the law enforcement community of the Common wealth of Pennsylvania, and the County of Lancaster administer justice, United States troops may have
3
New Book
Rebuttal
Page 13 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017
Page
Page1748
746 of
of1299
2301
Control, Plc., in as early as 1987.
activities within International Signal & Control, Plc,. On June 23, 1998, International Signal & Control,
Plc was negotiating for the $1.14 billion merger with Ferranti International, of England. Such disclo sures threatened the integrity of International Signal & Controls organization, and Mr. James Guerin
plaintiffs failed business dealings will demonstrate and substantiate financial incentive and motive. Defendants responsible for administering undo influence and interference in the plaintiffs business and
commercial enterprises had financial interests. The Commonwealth of Pennsylvania as a taxing authority, Lancaster County had a great investment whos demise would facilitate grave consequences to its
economic development. . Commonwealth National Bank (Mellon) would have less competition in the
mortgage banking business and other financial services, violating the lender liability laws. The Steinman Enterprises, Inc., would loose a pioneer in the information technologies industries, and would
protect the public domain from truthful disclosure. The plaintiff will also provide significant evidence of
4. Given the plaintiffs continued and obstructed right to due process of the law, beginning in June of
these activities, so described in the following Findings of Facts, regardless of any statute of limitations. Given the plaintiffs genuine efforts for due process has been inherently and maliciously ob structed, the courts must provide the opportunity for any and all remedial actions deserving to the
plaintiff.
5. Under current laws, the plaintiffs intellectual capacity has been exploited as means of dis crediting the plaintiffs disclosures and obstructing the plaintiffs right to due process of the law. The
and reason towards the plaintiffs activities and actions are a matter of record, demonstrated in the
Findings of Facts, contained herein.. The plaintiff will argue and successfully prove that the inherent
4
New Book
Rebuttal
Page 14 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017
Page
Page1749
747 of
of1299
2301
the plaintiffs alleged intellectual capacity. The plaintiff successfully argue that his mental capacity is
of very little legal consequence, if any; other than in its malicious representations used to diminish the
6. The plaintiff will demonstrate that the following incidents of illegal prosecutions were pur posefully directed at intimidating the plaintiff from further public disclosure into the activities of International Signal & Control, Plc., consequently obstructing the plaintiffs access to due process of the law.
Due to the fact that these activities to which the plaintiffs perpetrators were protecting were illegal activities, the RICO statutes would apply. To this day, the plaintiff has never been convicted of any crime
Dalzalls findings of April 14, 1997, in the Lisa Lambert case identifying acts of prosecutorial Misconduct, now, by virtue of this affidavit, now discloses evidence of a bona fide pattern of prosecutorial
the very same integrity of the court, which would tip the scales of justice even further from the peo ples deserving rights.. In the truthfulness of this affidavit, The Commonwealth must concede Lisa
must yield the criminal culpability of Lisa Michelle Lambert to the superior matter of restoring the in tegrity to the courts; by its own admission of wrongdoing, assuring the peoples of its commitment to
less, would take the full scope of jurisdiction out of the boundaries of our laws, negating our democ racy and impugning the Constitution of the United States. The plaintiff must be restored to whole.
5
New Book
Rebuttal
Page 15 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1750
748 of
of1299
2301
Page 16 of 151
143
January 31, 2016
1 of 2
January January
Sunday
22, 201722, 2017
Page
Page1751
749 of
of1299
2301

CLOSED,APPEAL,HABEAS,A/R,DOC-RESTRICT

Eastern District of Pennsylvania (Allentown)
CIVIL DOCKET FOR CASE #: 5:14-cv-02559-PD
LAMBERT v. BISSONETTE et al
Assigned to: HONORABLE PAUL S. DIAMOND
Case in other court: THIRD CIRCUIT COURT OF APPEALS, 15-03400
Cause: 28:2254 Petition for Writ of Habeas Corpus (State)

Date Terminated: 05/22/2014
Jury Demand: None
Nature of Suit: 530 Habeas Corpus: (General)
Jurisdiction: Federal Question
Petitioner
represented by JEREMY H.G. IBRAHIM

LAW OFFICES OF JEREMY H. GONZALEZ IBRAHIM
P.O. BOX 1025
CHADDS FORD, PA 19317
215-568-1943
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
V.
Respondent
LYNN BISSONETTE
SUPERINTENDENT, MCI-FRAMINGHAM
Respondent
THE DISTRICT ATTORNEY OF LANCASTER COUNTY,
PENNSYLVANIA
Respondent
THE ATTORNEY GENERAL OF PENNSYLVANIA
V.
Movant
AND ADVANCED MEDIA GROUP
represented by STANLEY J. CATERBONE

1250 FREMONT STREET
LANCASTER, PA 17603
717-669-2163
Email: scaterbone@live.com
PRO SE
Date Filed
Docket Text
05/02/2014
PETITION FOR WRIT OF HABEAS CORPUS (Filing fee $ 5 receipt number 100526.), filed by LISA MICHELLE LAMBERT. (Attachments: # 1 Civil
Cover Sheet)(ks, ) (Entered: 05/05/2014)
05/22/2014
CJA 20 APPIONTMENT OF ATTORNEY JEREMY H.G. IBRAHIM for LISA MICHELLE LAMBERT. SIGNED BY HONORABLE PAUL S.
DIAMOND ON 5/22/14. 5/22/14 ENTERED AND COPIES E-MAILED.(jpd) (Entered: 05/22/2014)
05/22/2014
ORDER THAT JEREMY IBRAHIM, ESQ., IS APPOINTED AS PETITIONER'S COUNSEL. ACCORDINGLY HER HABEAS PETITION IS
DISMISSED WITHOUT PREJUDICE TO PETITIONER'S RIGHT TO FILE A COUNSELED MOTION FOR RELIEF. COUNSEL SHOULD BE
PREPARED TO ADDRESS WHETHER PETITIONER MUST SEEK PERMISSION FROM THE COURT OF APPEALS BEFORE FILING A SECOND
OR SUCCESSIVE HABEAS PETITION. SIGNED BY HONORABLE PAUL S. DIAMOND ON 5/22/14. 5/23/14 ENTERED AND COPIES MAILED
TO PRO SE PETITIONER AND E-MAILED. (jpd) (Entered: 05/23/2014)
06/23/2015
BRIEF ON BEHALF OF AMICI CURIAE STANLEY J. CANTERBONE AND ADVANCED MEDIA GROUP IN SUPPORT OF LISA MICHELLE
LAMBERT'S HABEAU CORPUS, CERTIFICATE OF SERVICE.(jpd) (Entered: 06/25/2015)
07/06/2015
STATEMENT OF MOVANT STANLEY J. CATERBONE. (jpd, ) (Entered: 07/07/2015)
08/14/2015
LETTER FROM STAN J. CATERBONE DATED 8/7/15 ADDRESSED TO THE HONORABLE JUDGE J. CURTIS JOYNER AND THE
HONORABLE JUDGE PAUL S. DIAMOND RE: ELECTRONIC CASE FILING PRIVILEGES. (jpd) (Entered: 08/14/2015)
09/02/2015
MOTION TO FILE SUMMARY JUDGMENT filed by STANLEY J. CATERBONE. (ems) (Entered: 09/03/2015)
09/03/2015
ORDER THAT MOVANT STANLEY J. CATERBONE'S REQUEST FOR PERMISSION TO ELECTRONICALLY FILE DOCUMENTS (DOC. NO. 6)
IS DENIED. SIGNED BY HONORABLE PAUL S. DIAMOND ON 9/3/2015. 9/3/2015 ENTERED AND COPIES E-MAILED; AND MAILED TO PRO
SE. (ems) (Entered: 09/03/2015)
09/03/2015
MOTION TO FILE SUMMARY JUDGMENT filed by STANLEY J. CATERBONE.(jaa, ) Modified on 9/3/2015 (afm, ). Modified on 9/4/2015 (jaa, ).
(Entered: 09/03/2015)
09/03/2015
10
MOTION TO FILE STATEMENT OF MOVANT filed by STANLEY J. CATERBONE. (ems) (Entered: 09/04/2015)

New Book
Rebuttal
Page 17 of 151
143
January 31, 2016

12/7/2015 9:28 PM
2 of 2
January January
Sunday
22, 201722, 2017
Page
Page1752
750 of
of1299
2301
09/09/2015
11
MOVANT STANLEY J. CATERBONE'S MOTION TO FILE EXHIBT. (jpd, ) (Entered: 09/10/2015)
09/09/2015
12
MOVANT STANLEY J. CATERBONE'S MOTION TO FILE STATEMENT OF MOVANT.(jpd, ) (Entered: 09/10/2015)
09/09/2015
13
LETTER APPLICATION FROM TIMOTHY RICE #DU-2363 ADDRESSED TO THE HONORALE TIMOTHY R. RICE, UNITED STATES
MAGISTRATE JUDGE (jpd) (DOCKETED IN ERROR SEE 15-CV-291). (Entered: 09/10/2015)
09/09/2015
14
MOVANT STANLEY J. CATERBONE'S MOTION TO FILE EXHIBIT OF MOVANT. (jpd, ) (Entered: 09/10/2015)
09/14/2015
15
ORDER THAT MR. CATERBONE'S MOTIONS FOR SUMMARY JUDGMENT (DOC. NO. 8 AND 9) AND MOTIONS TO FILE EXHIBITS OR
STATEMENTS (DOC. NO. 10, 11, 12, 14) ARE DENIED AS FRIVOLOUS. IT IS FURTHER ORDERED THAT STANLEY J. CATERBONE MAY NO
LONGER SUBMIT FILINGS-WHETHER ELECTRONIC OR IN PAPER FORMAT IN THE ABOVE CAPTIONED MATTER. THE CLERK OF
COURT SHALL NOT DOCKET ANY SUCH FILINGS WITHOUT MY APPROVAL. SIGNED BY HONORABLE PAUL S. DIAMOND ON 9/11/15.
9/14/15 ENTERED AND COPIES MAILED TO PRO SE MOVANT AND E-MAILED TO COUNSEL. (jpd) (Entered: 09/14/2015)
09/30/2015
16
NOTICE OF APPEAL as to 15 Order on Motion for Summary Judgment,, Order on Motion for Order, Order on Motion for Miscellaneous Relief, Order on
Motion for Leave to File by STANLEY J. CATERBONE. IFP PENDING Copies to Judge, Clerk USCA, Appeals Clerk.(jpd) (Entered: 10/02/2015)
10/01/2015
17
Clerk's Notice to USCA re 16 Notice of Appeal, : (jpd, ) (Entered: 10/02/2015)
10/01/2015
18
MOVANT STANLEY J. CATERBONE'S MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS, CERTIFICATE OF SERVICE. (jpd) (Entered:
10/02/2015)
10/09/2015
NOTICE of Docketing Record on Appeal from USCA re 16 Notice of Appeal, filed by STANLEY J. CATERBONE. USCA Case Number 15-3400 (jpd, )
(Entered: 10/09/2015)
10/21/2015
19
ORDER THAT MR. CATERBONE'S MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS (DOC. NO. 18) IS DENIED. SIGNED BY
HONORABLE PAUL S. DIAMOND ON 10/21/15. 10/21/15 ENTERED AND COPIES TO USCA, MAILED TO PRO SE PETITIONER AND
E-MAILED. (jpd) Modified on 10/28/2015 (tjd). (Entered: 10/21/2015)
10/30/2015
20
EX PARTE ORDER FILED UNDER SEAL. SIGNED BY HONORABLE PAUL S. DIAMOND ON 10/30/15. 11/2/15 ENTERED AND COPIES
MAILED TO COUNSEL. (jpd) (Entered: 11/02/2015)
12/07/2015
21
MOVANT STANLEY J. CATERBONE'S MOTION TO RECUSE JUDGE PAUL DIAMOND. (jpd) (Entered: 12/07/2015)
PACER Service Center

Transaction Receipt
12/07/2015 21:27:19
PACER Login:
am6446:3514696:0
Description:
Docket Report
Search Criteria:
5:14-cv-02559-PD
Billable Pages:
Cost:
0.20

New Book
Rebuttal
Client Code:
Page 18 of 151
143
January 31, 2016

12/7/2015 9:28 PM
January January
Sunday
22, 201722, 2017
Page
Page1753
751 of
of1299
2301

__________________________________________________________________________
Petitioner
v.
MCI-FRAMINGHAM,
and
CRAIG STEDMAN, THE DISTRICT ATTORNEY OF
LANCASTER
and
KATHLEEN KANE, THE ATTORNEY GENERAL OF
PENNSYLVANIA,
Respondents
v.
Movant
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
Civ. No. 5:14-cv-02559-PD

U.S.C.A. 15-3400
MOTION TO RECUSE JUDGE PAUL DIAMOND

AND NOW comes before the said court Stanley J. Caterbone, appearing Pro Se, and Advanced Media Group, as Movant, to file the following MOTION for Recusal.
I, Stanley J. Caterbone, Appellant, do hereby request the Honorable PAUL J. DIAMOND, U.S.
District Court Judge disqualify himself from the above cases due to a conflict of interest, which his
impartiality might reasonably be questioned.
This same bias can be evidenced in the fact that
Jeremy H.G. Ibrahim, Sr., Esq, the Court Appointed Counsel for the PETITIONER Lisa Michelle Lambert sent an email to the Movant threatening prosecution for emails that were in fact advocating for
the successful resolution to this case, that is the release from further incarceration for the PETITIONER, Lisa Michelle Lambert. It looks as though the objective of dismissing the PETITIONER'S
Habeus Corpus in the very same ORDER appointing Jeremy H.G. Ibrahim, Sr., Esq as counsel was
to accomplish just that, dismiss the PETITIONER'S HABEUS CORPUS without any adjudication or judicial review. The MOVANT does not relish this MOTION and hopes that Your Honor has a reasonable explanation and can defend this MOTION and prove the MOVANT wrong.
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page19
1 of
of120
143
151
Sunday, November
January 29,
31, 2015
2016
January January
Sunday
22, 201722, 2017
Page
Page1754
752 of
of1299
2301
That very same bias is demonstrated in the ORDER of September 14,, 2015. The Appellant
Stanley J. Caterbones Federal False Claims Act litigation concerning International Signal & Control,
Plc., also includes agencies within the Commonwealth of Pennsylvania, including the Pennsylvania
Attorney Generals Office and the Pennsylvania Securities Commission, as material to the litigation.
On June 23, 2015, the AFFIANT, was listed on the Lisa Michelle Lambert Habeus
Corpus Case, No. 14-2559, filed in the U.S. District Court for the Eastern District of Pennsylvania, as the MOVANT, as depicted in the caption as stated v. Movant, STANLEY J.
CATERBONE AND ADVANCED MEDIA GROUP represented by STANLEY J. CATERBONE, PRO
SE, 1250 FREMONT STREET LANCASTER, PA 17603. See Attached.
On or about the week of June 29, 2015 the AFFIANT did in fact communicate with Mr.
Jeremy H.G. Ibrahim, Sr., Esq, appointed counsel on May 22, 2014, via a telephone conversation in
which Mr. Ibrahim stated I am very busy and will be in court in Delaware this week and will be in
touch with you later.
On July 9, 2015 the AFFIANT, did receive an email from Mr. Jeremy H.G. Ibrahim,
Sr., Esq, the appointed counsel as of the May 22, 2014, for Petitioner Lisa Michelle Lambert, U.S. District Court Case No. 14-2559, stated the following:
Kindly remove my email address. Your emails are harassing and causing distress. This a
cease and desist notice. I refer you to 18 USC 2261 and PA Code:
http://www.legis.state. pa.us/WU01/LI/LI/CT/HTM/18/00.027.009.000..HTM I will file a police r

eport shortly in my
township. Jeremy H. Gonzalez Ibrahim, Esq. USNA Blue & Gold Officer.
See Attached.
As filed and recorded in the ORDER of September 14, 2015 Judge Paul Diamond declared the following:
counseled motion. (Doc. No. 3.) She has not yet done so. On June 23, 2015, Stanley
Caterbonewho has nothing to do with Petitioner, her motion, or this case filed a pro se
amicus brief in support of the dismissed motion. (Doc. No. 4.) Caterbone neither sought
leave to file, nor indicated that he had received the Parties consent to file an amicus brief.
Fed. R. Civ. P. 29(a)
The amicus briefalthough providing some arguments in apparent
support of the dismissed motionessentially focuses on the damages Caterbone allegedly

suffered from his years of torture as a victim of U.S. Sponsored Mind Control or as a vic
tim of gang-stalking or organized stalking by more than 100 people. (Doc. No. 4 at 7, 9).
He also in includes a lengthy discussion of the perplexing question of Stan Caterbones in
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page20
2 of
of120
143
151
Sunday, November
January 29,
31, 2015
2016
January January
Sunday
22, 201722, 2017
Page
Page1755
753 of
of1299
2301
telligence, or lack thereof, and his work on a digital movie that is directly responsible for
the development of the internet. (Id. at 16-26). In addition, he details thirty governmental
attempts at mind control, including: 1) Blanketing my dwelling and surroundings with
electromagnetic energy; 2)Invading my thoughts via remote sensing technologies; and
3) Making me mentally hear others voices through the microwave hearing effect. (Id. at
27-30.) Caterbones involvement in the matter did not end with his amicus brief. On July 6,
2015, he filed with this Court an email that he had sent to the Lancaster Police, asserting
that he has synthetic telepathy. (Doc. No. 5.) On September 2 and 3, 2015, Caterbone
moved for summary judgment. (Doc. Nos. 8, 9.) On September 3, 2015, he moved to file
a copy of his motion for reconsideration of the denial of his petition to proceed in forma
pauperis in Pennsylvania state court, (which had been dismissed as frivolous). (Doc. No.
10.) On September 9, 2015, he also moved to file: 1) an email exchange with the subject
Muslims Us ing My Situation to Fight Against the USA; 2) a Wikipedia article on Entrap
ment; and 3) an exhibit of billing statements of his estimated fees for his 2007 work on
wholly unrelated federal and state court cases. (Doc. Nos. 11, 12, 14.) On September 9,
2015, Caterbone called my Chambers, demanding to speak with me, and then abruptly
hung up. I have already denied Caterbones request to file documents electronically. (Doc.
No. 9.) He has nonetheless continued to submit filings that have nothing to do with this
case. . See Attached.
The above ORDER and declarations by Judge Paul Diamond fail to mention the fact that the
declarations made by the AFFIANT, in his amicus, were for the sole purpose of providing to the
Court as much factual information and background information as possible with regards to the AFFIANT's legal odyssey in the federal court system since filing Case No. 05-2288 on May 16, 2005.
The AFFIANT has submitted volumes of evidence surrounding the massive efforts of Judges, Prosecutors, Friends, Relatives, Professional Colleagues, the Media, and Law Enforcement to discredit
the AFFIANT since the June 23, 1987 meeting with ISC Executive Larry Resch. In addition with regards to the subject of U.S. Sponsored Mind Control, the AFFIANT has been collecting Social Security Disability Benefits since April of 2008 for symptoms and illnesses related to the same. The Social Security Administration, in it's award letter of August of 2009, declared the AFFIANT mentally
disabled as of December of 2005, the time in which the AFFIANT declared under oath of law, as to
the time when the AFFIANT become a victim of full-time, 24/7 synthetic telepathy. The AFFIANT
can prove the preceding by virtue of the fact that there wasno medical reports from any doctors or
psychiatric professionals submitted during the applica
tion for benefits process, and the Social
Security Administration refused to grant the AFFIANT a psychiatric evaluation. Also, the AFFIANT
filed a Motion for a Hearing on October 26, 2015 to provide this Court with expert testimony proving the same.
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page21
3 of
of120
143
151
Sunday, November
January 29,
31, 2015
2016
January January
Sunday
22, 201722, 2017
Page
Page1756
754 of
of1299
2301
Clearly Judge Paul Diamond has continued that effort, demonstrated by his lack of attention to
the arguments made in the AFFIANT's amicus as to the merits and legal standing of the AFFIANT
with regards to the question of being the MOVANT in this case.
There is some indication that both Judge Paul Diamond and Mr. Jeremy H.G. Ibrahim, Sr., Esq,
are colluding to discredit the AFFIANT, Stanley J. Caterbone, and possibly derail the PETITIONER,
Lisa Michelle Lambert's efforts at relief and release from incarceration as stated in her pro se
Habeus Corpus of May 2, 2014. There seems to be no reasonable explanation at the lack of movement in the case from May, of 2014 until the day of June 23, 2015, some 14 months later, when
the AFFIANT, Stanley J. Caterbone, was listed as the MOVANT. This theory was first considered
back in June of 2015 by the AFFIANT, Stanley J. Caterbone.

Date: November 29, 2015
Stanley J. Caterbone, Pro Se, Movant

1250 Fremont Street
Lancaster, PA 17603
717-669-2163
scaterbone@live.com
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page22
4 of
of120
143
151
Sunday, November
January 29,
31, 2015
2016
January January
Sunday
22, 201722, 2017
Page
Page1757
755 of
of1299
2301

Case No. 14-02559, Lisa Michelle Lambert Habeus Corpus
Order Appealed: Motion for Judge Diamond to Recuse Himself
MOTION TO RECUSE JUDGE PAUL DIAMOND

November 29, 2015
TABLE OF CONTENTS
1. 15-3400 Lambert Appeal in U.S.C.A. Nov 28 MOTION for the Recusal of
Judge Paul Diamond
2. LAMBERT Docket Amicus Filed in Federal Court June 23, 2015
3. July 9, 2015 - Jeremy H Gonzalez Ibrahim Email Cease Desist
4. Sep 15, 2015 United States District Court Lisa Michelle Lambert Habeus
ORDER Summary Judgment DENIED Case No 5-14-cv-02559-PD
5. May 22, 2014 - Lambert ORDER Dismiss for Appellate Jurisdiction
6. EXHIBITS
7. Third Circuit 15-3400 Lambert Appeal Docket With Summaries of ALL
Recorded Filings as of November 29, 2015
8. Advanced Media Group Press Released re Proposed Organized Stalking Bill
9. Notarized Affidavits for Press Release and Executive Summary of
November 28, 2015
10.
Proposed Organized Stalking Bill
11.
May 2015 Richmond California City Ordinance to Ban Space Based
Weapons and Weapons of Mind Control

12.
Cover Page for Executive Summary
13.
Executive Summary
14.
Updates for Executive Summary October 10, 2015
15.
History of Federal Whistleblowing Case and Targeted Individual
16.
The Courts and the United States Legal System
17.
Family History
18.
The Public Record
19.
Is Lancaster County Ground Zero for U.S. Sponsored Mind Control
20.
Affidavit of Joinment of October 10, 2015
14-02559
Lambert Lambert
Habeus Corpus
LNP Lisa Michelle
New Book
Book
Rebuttal
Page23
5 of
Page
of120
143
151
Sunday, November
January 29,
31, 2015
2016
January January
Sunday
22, 201722, 2017
Page
Page1758
756 of
of1299
2301
21.
29 FALSE ARRESTS RECORD Since 1987
22.
21 ILLEGAL NO TRESPASS NOTICES
23.
Stan Caterbone's Notarized Affidavit for FFCHS September 16, 2010
Redacted Version
24.
Stan Caterbone's Detailed Victimization Affidavit of 2010
25.
Samuel P Caterbone US Sponsored Mind Control Affidavit 1996
26.
Sammy A. Caterbone Affidavit of US Sponsored Mind Control 1991
27.
Letter to Kathleen Kane re "Old Boys Network" of November 12,
2015 Hand Delivered to Agent Tyson of PA Attorney General Office

28.
Letter from Kathleen Kane of November 13, 2015
29.
No Trespass Notice from Tobias Frog of August 15, 2015
30.
Praecipe of CATERBONE v. Duke Street Business Center et.al., with
Named Defendants Tobias Frog and Owners of August 31, 2015
14-02559
LNP Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page24
6 of
of120
143
151
Sunday, November
January 29,
31, 2015
2016
January January
Sunday
22, 201722, 2017
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page1759
757 of
of1299
2301
Page
Page25
7 of
of120
143
151
Sunday, November
January 29,
31, 2015
2016
January January
Sunday
22, 201722, 2017
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page1760
758 of
of1299
2301
Page
Page26
8 of
of120
143
151
Sunday, November
January 29,
31, 2015
2016
January January
Sunday
22, 201722, 2017
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page1761
759 of
of1299
2301
Page
Page27
9 of
of120
143
151
Sunday, November
January 29,
31, 2015
2016
January January
Sunday
22, 201722, 2017
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page1762
760 of
of1299
2301
Page 28
10 of 151
143
120
Sunday, November
January 31,
29, 2016
2015
January January
Sunday
22, 201722, 2017
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page1763
761 of
of1299
2301
Page 29
11 of 151
143
120
Sunday, November
January 31,
29, 2016
2015
January January
Sunday
22, 201722, 2017
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page1764
762 of
of1299
2301
Page 30
12 of 151
143
120
Sunday, November
January 31,
29, 2016
2015
January January
Sunday
22, 201722, 2017
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page1765
763 of
of1299
2301
Page 31
13 of 151
143
120
Sunday, November
January 31,
29, 2016
2015
January January
Sunday
22, 201722, 2017
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page
Page1766
764 of
of1299
2301
Page 32
14 of 151
143
120
Sunday, November
January 31,
29, 2016
2015
January January
Sunday
22, 201722, 2017
Page
Page1767
765 of
of1299
2301
EXHIBITS
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page 33
15 of 151
143
120
Sunday, November
January 31,
29, 2016
2015
15-3400 Docket
1 of 5
https://ecf.ca3.uscourts.gov/cmecf/servlet/TransportRoom
January January
Sunday
22, 201722, 2017
Page
Page1768
766 of
of1299
2301
General Docket
Third Circuit Court of Appeals
Court of Appeals Docket #: 15-3400
Nature of Suit: 3530 Habeas Corpus
Lisa Lambert v. Superintendent Framingham MCI, et al
Appeal From: United States District Court for the Eastern District of Pennsylvania
Fee Status: Due
Docketed: 10/08/2015
Case Type Information:

1) civil
2) private
3) Habeas Corpus-prisoner
Originating Court Information:
District: 0313-2 : 5-14-cv-02559
Court Reporter: Joan Carr
Trial Judge: Paul S. Diamond, U.S. District Judge
Date Order/Judgment:
Date Order/Judgment EOD:
09/14/2015
09/14/2015
Date NOA Filed:

09/30/2015
Prior Cases:
None
Current Cases:
None

Plaintiff - Appellee
Jeremy H.G. Ibrahim, Sr., Esq.

Direct: 215-568-1943
Fax: 610-456-2727
[NTC Retained]
P.O. Box 1025
1631 Baltimore Pike
Chadds Ford, PA 19317
v.
SUPERINTENDENT FRAMINGHAM MCI
Defendant - Appellee
District Attorney Lancaster County

[NTC city/county gov]
Lancaster County Office of District Attorney
50 North Duke Street
Lancaster, PA 17608
DISTRICT ATTORNEY LANCASTER COUNTY


(see above)
ATTORNEY GENERAL PENNSYLVANIA


(see above)
-----------------------------STANLEY J. CATERBONE
Not Party - Appellant
14-02559
Lambert Lambert
Habeus Corpus
LNP Lisa Michelle
New Book
Book
Rebuttal
Direct: 717-669-2163
Email: scaterbone@live.com
[NTC Pro Se]
1250 Fremont Street
Lancaster, PA 17603
16 of 151
120
Page 34
143
Sunday, November
29, 2016
2015
January 31,
11/29/2015 10:38 AM
15-3400 Docket
January January
Sunday
22, 201722, 2017
Page
Page1769
767 of
of1299
2301

v.
SUPERINTENDENT FRAMINGHAM MCI;
DISTRICT ATTORNEY LANCASTER COUNTY;
*Stanley J. Caterbone,
Appellant
*(Pursuant to Rule 12(a), Fed.R.App.P.)
14-02559
Lambert Lambert
Habeus Corpus
LNP Lisa Michelle
New Book
Book
Rebuttal
2 of 5
17 of 151
120
Page 35
143
Sunday, November
29, 2016
2015
January 31,
11/29/2015 10:38 AM
15-3400 Docket
January January
Sunday
22, 201722, 2017
10/08/2015
30 pg, 3.25 MB
10/08/2015
Page
Page1770
768 of
of1299
2301
CIVIL CASE DOCKETED. Notice filed by Appellant Mr. Stanley J. Caterbone in District Court No. 5-14-cv02559. [-The notice of appeal that was attached to the entry was the incorrect document. The notice of
appeal has been corrected and notice is being resent.]--[Edited 10/09/2015 by CJG] (SB)
RECORD available on District Court CM/ECF. (SB)
2 pg, 27.26 KB
LEGAL DIVISION LETTER SENT advising that the case will be submitted to a panel of this Court for a
decision on the issuance of certificate of appealability and possible summary action. (JW)
42 pg, 4.58 MB
ECF FILER: EXHIBITS filed by Appellant Mr. Stanley J. Caterbone for the Court's consideration. Certificate
of Service dated 10/21/2015.--[Edited 10/22/2015 by CJG] (SJC)
0 pg, 0 KB
ECF FILER: Motion filed by Appellant Mr. Stanley J. Caterbone to proceed In Forma Pauperis. Certificate
of Service dated 10/21/2015. (SJC)
312 pg, 15.13 MB
ECF FILER: EXHIBITS filed by Appellant Mr. Stanley J. Caterbone for the Court's consideration. Certificate
of Service dated 10/22/2015.--[Edited 10/22/2015 by CJG] (SJC)
1 pg, 28.36 KB
COPY OF ORDER OF DISTRICT COURT dated 10/21/2015 denying Mr. Caterbone's motion to proceed in
forma pauperis signed by Paul S. Diamond, filed. (CJG)
44 pg, 4.6 MB
ECF FILER: DOCUMENT by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit. Certificate of
Service dated 10/23/2015.--[Edited 10/23/2015 by CJG] (SJC)
10/09/2015
10/21/2015
10/21/2015
10/22/2015
10/22/2015
10/23/2015
10/26/2015
ECF FILER: Request by Appellant Mr. Stanley J. Caterbone for Oral Argument. [SEND TO MERITS] (SJC)
194 pg, 22.28 MB
10/27/2015
2 pg, 21.62 KB
11/02/2015
227 pg, 29.4 MB
11/03/2015
8 pg, 1.94 MB
11/03/2015
FOLLOW UP LETTER to District Attorney Lancaster County for Attorney General Pennsylvania,
Superintendent Framingham MCI and District Attorney Lancaster County and Jeremy H.G. Ibrahim, Sr.,
Esq. for Lisa Michelle Lambert requesting the following document(s): Appearance Form on or before
11/10/2015. (CJG)
ECF FILER: DOCUMENT filed by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit.
Certificate of Service dated 11/02/2015.--[Edited 11/02/2015 by CJG] (SJC)
ORDER (Clerk) The motion proceed in forma pauperis is held in abeyance pending the submission of an
additional document. Appellant must submit this Court's affidavit of poverty within 14 days of the date of
this order or the appeal may be dismissed, filed. (CJG)
462 pg, 53.19 MB
ECF FILER: DOCUMENTS by Appellant Mr. Stanley J. Caterbone titled Submissions as Exhibits.
528 pg, 20.01 MB
0 pg, 0 KB
ECF FILER: Motion filed by Appellant Mr. Stanley J. Caterbone to proceed In Forma Pauperis. Certificate
of Service dated 11/04/2015. (SJC)
6 pg, 134.36 KB
ECF FILER: ARGUMENT In Response to Summary Action from Appellant Mr. Stanley J. Caterbone, filed.
Certificate of Service dated 11/06/2015 by ECF.--[Edited 11/06/2015 by MLR] (SJC)
174 pg, 33.18 MB
ECF FILER: DOCUMENT by Appellant Stanley J. Caterbone titled Submission as Exhibit. Certificate of
45 pg, 312.16 KB
ECF FILER: Motion filed by Appellant Mr. Stanley J. Caterbone Consideration for fees in the amount of
$284,702.50. Certificate of Service dated 11/07/2015.--[Edited 11/10/2015 by CJG] (SJC)
11/04/2015
11/04/2015
11/06/2015
11/06/2015
11/07/2015
11/09/2015
2 pg, 46.85 KB
11/10/2015
ECF FILER: DOCUMENT filed by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit "Audio
File of Authentic Recordings of 1987 and 1991". Certificate of Service dated 11/09/2015.--[Edited
11/10/2015 by CJG] (SJC)
102 pg, 4.75 MB
91 pg, 21.28 MB
11/10/2015
11/13/2015
ORDER (Clerk) The Motion Proceed In Forma Pauperis is referred to a motions panel, filed. (CJG)
1 pg, 6.04 KB
11/13/2015
185 pg, 19.73 MB
91 pg, 37.06 MB
1585 pg, 37.55 MB
ECF FILER: 3DOCUMENT filed by Appellant Mr. Stanley J. Caterbone titled submission as exhibit.
807 pg, 79 MB
11/16/2015
11/17/2015
11/18/2015
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
3 of 5
Page 36
18 of 151
143
120
Sunday, November
January 31,
29, 2016
2015
11/29/2015 10:38 AM
15-3400 Docket
January January
Sunday
22, 201722, 2017
Page
Page1771
769 of
of1299
2301
232 pg, 10.74 MB
232 pg, 9.11 MB
69 pg, 17 MB
275 pg, 20.95 MB
3 pg, 1.86 MB
ECF FILER: Motion filed by Appellant Mr. Stanley J. Caterbone for 30 Day Continuance. Certificate of
11/19/2015
11/20/2015
11/21/2015
11/22/2015
11/22/2015
11/24/2015
1 pg, 71.71 KB
11/25/2015
783 pg, 35.13 MB
11/27/2015
ORDER (Clerk) The motion for continuance is granted to the extent it can be construed as a motion for
extension of time to file a response regarding possible summary action. Appellant's response must be filed
and served within thirty (30) days of the date of this order, filed. (CJG)
128 pg, 16.12 MB
ECF FILER: 3rd Circuit EXHIBIT re Chapter 11 Reorganization Plan for Case No. 05-23059 Filed January
12, 2010, November 27, 2015 filed by Appellant Mr. Stanley J. Caterbone. Certificate of Service dated
11/27/2015. (SJC)
94 pg, 10.13 MB
ECF FILER: 3rd Circuit Lambert Appeal EXHIBIT re Affidavit of APPELLANT Stanley J. Caterbone re
Judge Diamond Misconduct, November 28, 2015 filed by Appellant Mr. Stanley J. Caterbone. Certificate of
Service dated 11/28/2015. (SJC)
11/28/2015
14-02559
LNP
Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
4 of 5
Page 37
19 of 151
143
120
Sunday, November
January 31,
29, 2016
2015
11/29/2015 10:38 AM
15-3400
January January
Sunday
22,Case:
201722,
2017
Document: 003112098354
Page: 1 StanDate
Filed: 10/09/2015
Page
Page1772
770 of
of1299
2301
J. Caterbone
LAMBERT CASE FILE
OFFICE OF THE CLERK
MARCIA M. WALDRON
UNITED STATES COURT OF APPEALS
CLERK
FOR THE THIRD CIRCUIT
TELEPHONE
215-597-2995
21400 UNITED STATES COURTHOUSE

601 MARKET STREET
PHILADELPHIA, PA 19106-1790
Website: www.ca3.uscourts.gov
October 9, 2015
Mr. Stanley J. Caterbone

1250 Fremont Street
Lancaster, PA 17603
RE: Lisa Lambert v. Superintendent Framingham MCI, et al.
Case Number: 15-3400
District Case Number: 5-14-cv-02559
_________________________________________________
Dear Mr. Caterbone:

This appeal has been listed for possible summary action by a panel of this Court, pursuant to
Chapter 10.6 of the Internal operating Procedures of the United States Court of Appeals for the
Third Circuit. See also Third Circuit Local Appellate Rule(3rd Cir. LAR) 27.4 Chapter 10.6
provides that the Court sua sponte (by its own action) may take summary action on an appeal if it
appears that no substantial question is presented or that subsequent precedent or a change in
circumstances warrants such action. Specifically, the Court may affirm, reverse, vacate, modify,
or remand the judgment or order appealed. The parties may submit written argument supporting
or opposing summary action.
The panel of this court that considers possible summary action also will consider whether a
certificate of appealability is required for the purpose of this appeal. See 28 U.S.C. Section 2253.
If the Court determines that a certificate of appealability is required, appellant's notice of appeal
will be deemed to be such an application, unless appellant has submitted a formal application for
a certificate of appealability. See 3rd Cir. LAR 22.1.
Any response regarding summary action or issuance of a certificate of appealability must be
received in the Clerk's Office within thirty (30) days of the date of this letter. Please submit to
the Clerk and original copy of any response, and a certificate of service indicating that all parties
have been served with a copy of the response. The Court will carefully review the District Court
record, along with any written submissions received from the parties.
14-02559
LNP Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page 38
20 of 151
143
120
Sunday, November
January 31,
29, 2016
2015
15-3400
January January
Sunday
22,Case:
201722,
2017
Document: 003112098354
Page: 2 StanDate
Filed: 10/09/2015
Page
Page1773
771 of
of1299
2301
J. Caterbone
LAMBERT CASE FILE
October 9, 2015
Page 2
_________________
Issuance of the briefing schedule will be stayed pending action by the Court. If the Court
declines to take summary action or grants the application for a certificate of appealability, the
Clerk will issue a briefing schedule. The parties will be advised of any order issued in this
matter.
Very truly yours,
Marcia M. Waldron, Clerk
By:
Jo-Ann Williams, Administrative Assistant
cc:

14-02559
LNP Lisa Michelle
Lambert Lambert
Habeus Corpus
New Book
Book
Rebuttal
Page 39
21 of 151
143
120
Sunday, November
January 31,
29, 2016
2015
15-3400
January January
Sunday
22,Case:
201722,
2017
Document: 003112168218
Page: 1 StanDate
Filed: 12/31/2015
Page
Page1774
772 of
of1299
2301
J. Caterbone
LAMBERT CASE FILE
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
December 31, 2015

To:

Clerk of Courts
Re:


course the U.S.C.A.


/S/
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
LNP Lisa Michelle Lambert Book Rebuttal
Page 40 of 151
January 31, 2016
15-3400
January January
Sunday
22,Case:
201722,
2017
Document: 003112176757
Page: 1 StanDate
Filed: 01/12/2016
Page
Page1775
773 of
of1299
2301
J. Caterbone
LAMBERT CASE FILE
UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

December 21, 2015
CCO-032
No. 15-3400
LISA LAMBERT
v.
SUPERINTENDENT FRAMINGHAM MCI;
DISTRICT ATTORNEY LANCASTER COUNTY;
STANLEY J. CATERBONE,
Appellant
(E.D. Pa. No. 5-14-cv-02559)
Present: FISHER, JORDAN and VANASKIE, Circuit Judges
1.
Motion by Appellant to Dismiss the Appeal Pursuant to Fed. R. App. P.

42(b); and
2.
Letter by Appellant clarifying that the Motion to Dismiss is requested

without prejudice to renewal
Respectfully,
Clerk/cjg
_________________________________ORDER________________________________
The foregoing Motion to Dismiss the Appeal without prejudice is granted.
By the Court,
s/ Thomas I. Vanaskie
Circuit Judge
Dated: January 12, 2016
CJG/cc:
A True Copy :
Marcia M . Waldron, Clerk
LNP Lisa Michelle Lambert Book Rebuttal
Page 41 of 151
January 31, 2016
15-3400
January January
Sunday
22,Case:
201722,
2017
Document: 003112180452
Page: 1 StanDate
Filed: 01/15/2016
Page
Page1776
774 of
of1299
2301
J. Caterbone
LAMBERT CASE FILE
scaterbone@live.com
717-669-2163

1250 Fremont Street
Lancaster, PA 17603
_______________________________________________________________________________
:
PETITIONER
:
:
v.
:
CASE NO. 3400-2015
:
:
RESPONDANT
:
:
:
APPELLANT
:
MOTION FOR THIRD CIRCUIT COURT OF APPEALS JUDGE MICHAEL FISHER TO RECUSE
_______________________________________________________________________
I hereby on this 15th day of January, 2016, I, Stanley J. Caterbone, APPELLANT appearing
pro se, submit this MOTION FOR THIRD CIRCUIT COURT OF APPEALS JUDGE MICHAEL
FISHER TO RECUSE whereas Judge Michael Fisher did preside in the ORDER of January 12, 2016.
On January 14th via an email from Attorney and Co-Author Dave Brown, I was alerted to the fact
that the FISHER in the curium of judges was that of the same Micheal Fisher that was the
Pennsylvania Attorney General during the second prosecution of Lisa Michelle Lambert in the
Lancaster County Court of Common Pleas. In his email Attorney Dave Brown wrote the following:
Sorry to hear it. Its amazing that Mike Fisher was the lead Third Circuit Judge who granted
the motion to dismiss. He should have recused himself from any case involving Lisa because when
he was A.G., he filed a flurry of baseless recusal motions which culminated in Dalzell recusing
himself in January 2012. As we describe in the book, it was dirty politics. At the end of your e-mail,
you state: I am not going to let you [suggesting me] get away with this. You mean that you wont
let them Judge Diamond, Third Circuit get away with this Good idea filing the motion to reinstate
your appeal. Hey, were eager to see how Judge Diamond rules on the Application Pro Hac Vice for
California lawyer Brian Claypool to get involved in Lisas case. You keep an eye on the docket more
regularly than I do. Can you let me know if you see an Order from Diamond granting or denying
Brians Application? Thanks.
15-3400
LNP
LisaLambert
MichelleAppeal
Lambert
re Book
J. Michael
Fisher
Rebuttal
Recusal
Fisher RecusalPage
Page
421ofof151
75
78
Friday, January 31,

15, 2016
15-3400
January January
Sunday
22,Case:
201722,
2017
Document: 003112180452
Page: 2 StanDate
Filed: 01/15/2016
Page
Page1777
775 of
of1299
2301
J. Caterbone
LAMBERT CASE FILE
Please see the following EXHIBIT for reference of the preceding.
/S/
Date: January 13, 2016

1250 Fremont Street
Lancaster, PA 17603
(717)-669-2163
scaterbone@live.com
15-3400
LNP
LisaLambert
MichelleAppeal
Lambert
re Book
J. Michael
Fisher
Rebuttal
Recusal
Fisher RecusalPage
Page
432ofof151
75
78
Friday, January 31,

15, 2016
15-3400
January January
Sunday
22,Case:
201722,
2017
Document: 003112180452
Page: 3 StanDate
Filed: 01/15/2016
Page
Page1778
776 of
of1299
2301
J. Caterbone
LAMBERT CASE FILE
EXHIBT
15-3400
LNP
LisaLambert
MichelleAppeal
Lambert
re Book
J. Michael
Fisher
Rebuttal
Recusal
Fisher RecusalPage
Page
443ofof151
75
78
Friday, January 31,

15, 2016
D. Michael Fisher - Wikipedia, the free encyclopedia
1 of 3
15-3400
January January
Sunday
22,Case:
201722,
2017
https://en.wikipedia.org/wiki/D._Michael_Fisher
Document: 003112180452
Page: 4 StanDate
Filed: 01/15/2016
Page
Page1779
777 of
of1299
2301
J. Caterbone
LAMBERT CASE FILE
D. Michael Fisher
From Wikipedia, the free encyclopedia
Dennis Michael Fisher (born November 7, 1944), known commonly as Mike

Fisher, is a United States federal judge of the Court of Appeals for the Third
Circuit.
Michael Fisher
Contents
1 Early career and education
2 Political career
2.1 Attorney General
2.2 2002 gubernatorial election
3 Federal judicial service
4 Personal life
5 References
6 External links
Judge of the United States Court of Appeals for

the Third Circuit
Incumbent
Assumed office
Early career and education

He began his legal career in his hometown of Pittsburgh following his graduation
from Georgetown University in 1966 and Georgetown University Law Center in
1969. As an Assistant District Attorney for Allegheny County, he handled nearly
1,000 cases, including 25 homicides. He continued to practice law during his
career in the General Assembly and was a shareholder or partner in various
firms, including Houston Harbaugh, where he practiced from 1984 to 1997.
Fishers law practice included civil litigation, commercial law, estate planning
and real estate.
December 15, 2003

Appointed by
George W. Bush
Preceded by
Carol Los Mansmann
43rd Attorney General of Pennsylvania

In office
January 21, 1997 December 15, 2003
Governor
Tom Ridge
Preceded by
Tom Corbett
Succeeded by
Jerry Pappert
Political career
Member of the Pennsylvania Senate

from the 37th district
Before his election as Attorney General, Fisher served for 22 years in the
Pennsylvania General Assembly, serving 6 years in the State House and 16 years
as a member of the State Senate. He was a member of the House and Senate
Judiciary Committees, the Chair of the Senate Environmental Resources and
Energy Committee and the Majority Whip[1] of the Senate. During his legislative
career, he was a leader in criminal and civil justice reform and an architect of
many major environmental laws. He ran unsuccessfully for lieutenant governor
in 1986, serving as the running mate of Bill Scranton.
In office
January 6, 1981 November 30, 1996
Attorney General
Prior to becoming a judge, he was elected Attorney General of Pennsylvania in
1996 and re-elected in 2000. Fisher personally argued major cases in state and
federal appellate courts. In March 1998, he successfully argued before the United
States Supreme Court a precedent-setting case ensuring that paroled criminals
meet the conditions of their release.
In a 2009 documentary film about the politics behind attempts to move the
Barnes Foundation art collection to the Philadelphia Museum of Art called The
Art of the Steal, Fisher admitted using pressure on Lincoln University officials
to get them to approve the move.[2]
15-3400
LNP
LisaLambert
MichelleAppeal
Lambert
re Book
J. Michael
Rebuttal
Fisher RecusalPage
Page
454ofof151
78
Preceded by
Michael Schaefer
Succeeded by
Tim Murphy
Republican Whip of the Pennsylvania Senate

In office
Preceded by
David Brightbill
Succeeded by
David Brightbill
Member of the Pennsylvania House of

Representatives
from the 40th district
In office
Preceded by
Jay Wells
Succeeded by
Frank Marmion
Personal details
Friday, January 31,

15, 2016
1/15/2016 6:27 AM
2 of 3
15-3400
January January
Sunday
22,Case:
201722,
2017
Document: 003112180452
Page: 5 StanDate
Filed: 01/15/2016
Page
Page1780
778 of
of1299
2301
J. Caterbone
LAMBERT CASE FILE
2002 gubernatorial election
Born
November 7, 1944
Pittsburgh, Pennsylvania, U.S.
Fisher ran for governor of Pennsylvania in the 2002 election. Early in the
Political party Republican
campaign, the Republican State Committee gravitated to him as the nominee,
much to the chagrin of State Treasurer Barbara Hafer, who had explored a run.
Alma mater
Georgetown University
After Fisher won the nomination unopposed, Hafer endorsed the Democrat, Ed
Rendell and later switched her party affiliation to the Democratic Party. Fisher's campaign website was praised as being among the
best during the 2002 election cycle.[3]
Fisher's candidacy was unable to gain traction, and he was down in the polls by double digits throughout the fall. In the end, Fisher
could not catch Rendell and lost 53.4%44.4%.
Federal judicial service

Fisher was appointed to the United States Court of Appeals for the Third Circuit to serve with Marjorie Rendell, Governor Rendell's
wife. Fisher was nominated by President George W. Bush on May 1, 2003, to a seat vacated by Carol Los Mansmann. He was
confirmed by the United States Senate on December 9, 2003, and received commission on December 11, 2003. Fisher officially
resigned as Attorney General and assumed his judicial office four days later.[4]
Personal life
Fisher and his wife, Carol, an education consultant, have two children. Michelle is an attorney, and Brett works in the Merchant
Services Business.
References
1. "Pecora's Retreat Leave Jubelirer In Top Position". The Pittsburgh Post-Gazette. January 2, 1991. Retrieved November 26, 2011.
2. Kennedy, Randy (March 29, 2011). "Arts Beat". The Culture at Large. Retrieved March 29, 2011.
3. Drulis, Michael (2002). "Best & Worst Websites". PoliticsPA. The Publius Group. Archived from the original on 2002-10-17.
4. "Pappert Takes Over For Fisher As Attorney General". WGAL Politics. WGAL. Retrieved November 26, 2011.
External links
Media related to Mike Fisher at Wikimedia Commons
D. Michael Fisher (http://www.fjc.gov/servlet/nGetInfo?jid=3047&cid=999&ctype=na&instate=na) at the Biographical
Directory of Federal Judges, a public domain publication of the Federal Judicial Center.
15-3400
LNP
LisaLambert
MichelleAppeal
Lambert
re Book
J. Michael
Rebuttal
Fisher RecusalPage
Page
465ofof151
78
Friday, January 31,

15, 2016
1/15/2016 6:27 AM
3 of 3
15-3400
January January
Sunday
22,Case:
201722,
2017
Document: 003112180452
Page: 6 StanDate
Filed: 01/15/2016
Page
Page1781
779 of
of1299
2301
J. Caterbone
LAMBERT CASE FILE
Pennsylvania House of Representatives
Preceded by
Jay Wells
Member of the Pennsylvania House of

Representatives
for the 40th district
19751980
Succeeded by
Frank Marmion
Pennsylvania State Senate

Preceded by
Michael Schaefer
Member of the Pennsylvania Senate

for the 37th district
19811996
Succeeded by
Tim Murphy
Party political offices

Preceded by
David Brightbill
Deputy Leader of the Republican Party in the

Pennsylvania Senate
19911996
Succeeded by
David Brightbill
Preceded by
William Scranton
Republican nominee for Lieutenant Governor of

Pennsylvania
1986
Succeeded by
Harold Mowery
Preceded by
Ernie Preate
Republican nominee for Attorney General of

Pennsylvania
1996, 2000
Succeeded by
Tom Corbett
Preceded by
Tom Ridge
Republican nominee for Governor of Pennsylvania

2002
Succeeded by
Lynn Swann
Legal offices
Preceded by
Tom Corbett
Attorney General of Pennsylvania

19972003
Succeeded by
Jerry Pappert
Preceded by
Carol Los Mansmann
Judge of the United States Court of Appeals for

the Third Circuit
2003present
Incumbent
Retrieved from "https://en.wikipedia.org/w/index.php?title=D._Michael_Fisher&oldid=678787928"

Categories: 1944 births Georgetown University Law Center alumni
Judges of the United States Court of Appeals for the Third Circuit Living people
Members of the Pennsylvania House of Representatives Pennsylvania Attorneys General Pennsylvania lawyers
Pennsylvania Republicans Pennsylvania State Senators Politicians from Pittsburgh, Pennsylvania
United States court of appeals judges appointed by George W. Bush
This page was last modified on 31 August 2015, at 16:47.
Text is available under the Creative Commons Attribution-ShareAlike License; additional terms may apply. By using this
site, you agree to the Terms of Use and Privacy Policy. Wikipedia is a registered trademark of the Wikimedia Foundation,
Inc., a non-profit organization.
15-3400
LNP
LisaLambert
MichelleAppeal
Lambert
re Book
J. Michael
Rebuttal
Fisher RecusalPage
Page
476ofof151
78
Friday, January 31,

15, 2016
1/15/2016 6:27 AM
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1782
780 of
of1299
2301
Page 48
40 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1783
781 of
of1299
2301
Page 49
41 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1784
782 of
of1299
2301
Page 50
42 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1785
783 of
of1299
2301
Page 51
43 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1786
784 of
of1299
2301
Page 52
44 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1787
785 of
of1299
2301
Page 53
45 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1788
786 of
of1299
2301
Page 54
46 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1789
787 of
of1299
2301
Page 55
47 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1790
788 of
of1299
2301
Page 56
48 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1791
789 of
of1299
2301
Page 57
49 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1792
790 of
of1299
2301
Page 58
50 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1793
791 of
of1299
2301
Page 59
51 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1794
792 of
of1299
2301
Page 60
52 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1795
793 of
of1299
2301
Page 61
53 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1796
794 of
of1299
2301
Page 62
54 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1797
795 of
of1299
2301
Page 63
55 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1798
796 of
of1299
2301
Page 64
56 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1799
797 of
of1299
2301
Page 65
57 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1800
798 of
of1299
2301
Page 66
58 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1801
799 of
of1299
2301
Page 67
59 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1802
800 of
of1299
2301
Page 68
60 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1803
801 of
of1299
2301
Page 69
61 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1804
802 of
of1299
2301
Page 70
62 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1805
803 of
of1299
2301
Page 71
63 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1806
804 of
of1299
2301
Page 72
64 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1807
805 of
of1299
2301
Page 73
65 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1808
806 of
of1299
2301
Page 74
66 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1809
807 of
of1299
2301
Page 75
67 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1810
808 of
of1299
2301
Page 76
68 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1811
809 of
of1299
2301
Page 77
69 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1812
810 of
of1299
2301
Page 78
70 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1813
811 of
of1299
2301
Page 79
71 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1814
812 of
of1299
2301
Page 80
72 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1815
813 of
of1299
2301
Page 81
73 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1816
814 of
of1299
2301
Page 82
74 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1817
815 of
of1299
2301
Page 83
75 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1818
816 of
of1299
2301
Page 84
76 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1819
817 of
of1299
2301
Page 85
77 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1820
818 of
of1299
2301
Page 86
78 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1821
819 of
of1299
2301
Page 87
79 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1822
820 of
of1299
2301
Page 88
80 of 151
143
January 31, 2016
January January
Sunday
22, 201722, 2017
Page
Page1823
821 of
of1299
2301
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
January 22, 2016
Op Ed
LNP
Lisa
Letter
Michelle
re Kathleen
Lambert
Kane
New Book
Book
Rebuttal
Page
Page
Page
8111of
89
ofof151
143
29
Monday,
Sunday, January 25,
24, 2016
31,
January January
Sunday
22, 201722, 2017
Page
Page1824
822 of
of1299
2301
_____________/S/___________
ACTIVE COURT CASES
Op Ed
LNP
Lisa
Letter
Michelle
re Kathleen
Lambert
Kane
New Book
Book
Rebuttal
Page
Page
Page
8222of
90
ofof151
143
29
Monday,
Sunday, January 25,
24, 2016
31,
January January
Sunday
22, 201722, 2017
Page
Page1825
823 of
of1299
2301
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
November 12, 2015

Ms. Kathleen Kane
2015.
amicable fashion.
717-669-2163
Stan J. Caterbone
Newslanc
Op
LNP
Ed
Lisa
Letter
Michelle
Letter
re Kathleen
toLambert
the Editor
Kane
New Book
Book
Rebuttal
Page
Page
Page
Page
83333of
91
of
of
of151
143
699
Wednesday,
Tuesday,
Monday,
December
January 25,
15, 2016
20,
31,
2015
January January
Sunday
22, 201722, 2017
Newslanc
Op
LNP
Ed
Lisa
Letter
Michelle
Letter
re Kathleen
toLambert
the Editor
Kane
New Book
Book
Rebuttal
Page
Page1826
824 of
of1299
2301
Page
Page
Page
Page
84444of
92
of
of
of151
143
699
Wednesday,
Tuesday,
Monday,
December
January 25,
15, 2016
20,
31,
2015
January January
Sunday
22, 201722, 2017
Newslanc
Op
LNP
Ed
Lisa
Letter
Michelle
Letter
re Kathleen
toLambert
the Editor
Kane
New Book
Book
Rebuttal
Page
Page1827
825 of
of1299
2301
Page
Page
Page
Page
85555of
93
of
of
of151
143
699
Wednesday,
Tuesday,
Monday,
December
January 25,
15, 2016
20,
31,
2015
15-3400
January January
Sunday
22,Case:
201722,
2017
Document: 003112153497
Page: 1 StanDate
Filed: 12/14/2015
Page
Page1828
826 of
of1299
2301
J. Caterbone
LAMBERT CASE FILE
scaterbone@live.com
717-669-2163

1250 Fremont Street
Lancaster, PA 17603
_______________________________________________________________________________
:
PETITIONER
:
:
v.
:
CASE NO. 3400-2015
:
:
RESPONDANT
:
:
:
APPELLANT
:
MOTION TO DISMISS
_______________________________________________________________________
I hereby on this 14th day of December, 2015, I Stanley J. Caterbone, appearing pro se, as
the APPELLANT do hereby file a Motion to Dismiss the above captioned appeal for reasons previously
affirmed in previous filings.

Date: December 14, 2015

1250 Fremont Street
Lancaster, PA 17603
(717)-669-2163
Newslanc
Op Ed
LNP
Lisa
Letter
Michelle
Letter
re Kathleen
toLambert
the Editor
Kane
New Book
Book
Rebuttal
Page
Page
Page
Page
86666of
94
of
of
of151
143
699
Wednesday,
Tuesday,
Monday,
December
January 25,
15, 2016
20,
31,
2015
1 of 3
January January
Sunday
22, 201722, 2017
December 9, 2015
Page
Page1829
827 of
of1299
2301
Breaking: Kanes staff has approved one of two contracts needed to hire a special prosecutor to investigate the porno email
scandal
by Bill Keisling
Have Republicans in the top levels of Pennsylvania government and courts engineered a takeover of the Democraticcontrolled state attorney generals office?
Has this high-level palace coup taken place under everyones noses?
Are the criminal charges brought by Republican officials against AG Kane, her subsequent
law license suspension, and efforts by the state senate to remove her from office all simply
a ruse meant to distract voters from what is really going on: an attempt by Republicans to
control policy in the attorney generals office, and throughout state government, without
having won an election?
Recent developments in all three branches of Pennsylvania government make these
reasonable questions.
Several weeks ago, on November 18, four high-level staffers from the AGs office testified
before the state senate committee exploring AG Kanes removal from office that theyve
been running nearly all the offices legal functions since Kane could no longer practice law.
First Deputy Attorney General Bruce Beemer, and three executive deputy attorneys general
Robert Mulle, James Donahue, and Lawrence Cherba testified they have effectively
Kathleen Kane
taken control of the elective attorney generals office following Kanes unprecedented law
license suspension.
First Deputy AG Beemer is a holdover from the days when Republican Attorney General Tom Corbett ran the office, before
Kanes election in 2012.
When she came into office Kane probably thought Beemer was a nice guy, and a competent and experienced career
prosecutors, who should be kept around.
But did Attorney General Kane make a mistake not having her own loyalists in these top positions?
Several weeks back, Beemer and the other three made a splash at
the senate impeachment committee when they spoke about the
importance of the many criminal cases the office was responsible
for handling.
But criminal cases prosecuted by the AGs office are, from a public
policy perspective, small potatoes.
The state AGs office is a johnny-come-lately in criminal
prosecutions. Before the office became an elective one in 1980, the
AGs office seldom if ever prosecuted criminals. (Criminal
prosecutions, before 1980, were referred to local DAs.)
Newslanc
Op
LNP
Ed
Lisa
Letter
Michelle
Letter
re Kathleen
toLambert
the Editor
Kane
New Book
Book
Rebuttal
Four guys running the AG's office: who voted for them?
Page
Page
Page
8777ofof
95
of151
143
99
Wednesday,
Monday, January 25,
20, 2016
31,
1/20/2016 5:25 AM
2 of 3
January January
Sunday
22, 201722, 2017
Page
Page1830
828 of
of1299
2301
For centuries, the most important job of the Pennsylvania attorney general has been to issue opinions on the legality or
constitutionality of state actions or programs.
Opinions issued by the Attorney General can and do concern the nuts and bolts of how state agencies are run from the
legality of programs, to who is hired, to how paper clips are bought, to the treatment and execution of prisoners.
Legal opinions of the attorney general carry the full force of law, until and unless a court overturns them.
Beemer and his three associates, testifying before the state senate, played down these important constitutional
responsibilities. These days, Beemer said, the AGs office rarely if ever issues important opinions on government or interagency matters.
Two recent and important issues demanding high-level decisions in the AGs office clearly demonstrate this is not true.
The first issue is a constitutional matter: the state senate is set to vote on whether to hold a hearing to remove Kane from
office, bypassing the constitutional impeachment process. Its the historic role of the attorney generals office to intervene on
questions of the legality of removing an official from office.
The second issue is a personnel, or contract, matter: The contract for Kanes choice of the special prosecutor to investigate
the court pornography email scandal must be reviewed and approved by her office.
AG Kane selected Douglas Gansler, a former Maryland attorney general, and his Washington DC-based law firm, to review
the hundreds of thousands of emails Kane found on her office servers.
But contracts hiring Gansler and his firm must be approved and signed by the attorney generals office staff.
The responsibility to review and approve Ganslers contract fell to one of the four AG office employees who testified several
weeks ago before the state senate panel to remove Kane: Robert Mulle, the executive deputy attorney general of the civil
law division.
Two employment contracts, one involving Gansler and the other his firm, landed on Deputy AG Mulles desk last week. Mulle
evidentially at first objected to the form and content of the special prosecutor agreements.
Kanes spokesman, Chuck Ardo, tells me, (Deputy AG) Mulle was able to work with Kane to massage the first of the two
contracts, about the firm.
That first contract has been signed, Ardo says. But Ganslers personal contract has yet to be approved, or signed.
They are still working on Ganslers contract, Ardo says. But she certainly got the first part approved.
Needless to say, the last thing state Republicans want is an unfettered special prosecutor looking into hundreds of
thousands of correspondence found on the AGs email servers.
Likewise, the attorney generals office must soon respond to the senates demand for a hearing to remove Kane from office.
Those running Kanes office apparently dont seem to be in any hurry, or think its their job, to weigh in on the constitutionality
of the senates proposed action.
But, it should go without saying, if a Democrat-controlled senate were to try removing a Republican attorney general in this
matter, the court papers already would be flying.
Likewise, if the porno email scandal involved mostly Democrats, instead of mostly Republican prosecutors and judges, a
special prosecutor would likely already be on the job.
So Kane finds herself having difficulties directing her own staff to work on these two important matters.
Three million Pennsylvania voters elected Kane. Voters didnt elect her staff members.
Newslanc
Op
LNP
Ed
Lisa
Letter
Michelle
Letter
re Kathleen
toLambert
the Editor
Kane
New Book
Book
Rebuttal
Page
Page
Page
8888ofof
96
of151
143
99
Wednesday,
Monday, January 25,
20, 2016
31,
1/20/2016 5:25 AM
3 of 3
January January
Sunday
22, 201722, 2017
Newslanc
Op
LNP
Ed
Lisa
Letter
Michelle
Letter
re Kathleen
toLambert
the Editor
Kane
New Book
Book
Rebuttal
Page
Page1831
829 of
of1299
2301
Page
Page
Page
8999ofof
97
of151
143
99
Wednesday,
Monday, January 25,
20, 2016
31,
1/20/2016 5:25 AM
1 of 3
January January
Sunday
22, 201722, 2017
Page
Page1832
830 of
of1299
2301
(https://twitter.com/BBumsted_Trib)

New Book
Rebuttal
Page 98
90 of 151
143
January 31, 2016

1/25/2016 5:22 AM
2 of 3
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1833
831 of
of1299
2301
Page 99
91 of 151
143
January 31, 2016

1/25/2016 5:22 AM
3 of 3
January January
Sunday
22, 201722, 2017

New Book
Rebuttal
Page
Page1834
832 of
of1299
2301
Page
Page100
92 of
of143
151
January 31, 2016

1/25/2016 5:22 AM
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1835
833 of
of1299
2301
Page
Page
Page
Page
101
93
11of
of
of143
51
151
51
Thursday, December
January 31,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Page
Page1836
834 of
of1299
2301

scaterbone@live.com
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
(717)669-2163
PRESS RELEASE
_________________________________________________
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
Page
Page
102
94
12of
2
of
of
1 143
50
51
151
51
Thursday,
Friday, December
January 31,
11,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1837
835 of
of1299
2301
Page
Page
Page
Page
103
95
23of
3
of
of143
50
51
151
51
Thursday,
Friday, December
January 31,
11,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Page
Page1838
836 of
of1299
2301
Capitol Office
State Capitol
Jefferson City Mo.
573-751-0246
District Office
Second Street
King City Mo.
660-535-6664
May 21, 2009

Sincerely,
Rep. Jim Guest
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
Page
104
96
34of
4
of
of143
50
51
151
51
Thursday,
Friday, December
January 31,
11,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Page
Page1839
837 of
of1299
2301
Bill
A) Findings
Convention.
B) Purpose
or four years.
**
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
Page
Page
105
97
45of
5
of
of
2 143
50
51
151
51
Thursday,
Friday, December
January 31,
11,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Page
Page1840
838 of
of1299
2301
telepathy devices.
one year..
in good faith.
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
Page
Page
106
98
56of
6
of
of
3 143
50
51
151
51
Thursday,
Friday, December
January 31,
11,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Page
Page1841
839 of
of1299
2301
(c)
recipient.

Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
Page
Page
107
99
67of
7
of
of
4 143
50
51
151
51
Thursday,
Friday, December
January 31,
11,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Page
Page1842
840 of
of1299
2301
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
Page
100
108
78of
8
of
of
5 51
50
143
151
51
Thursday,
Friday, December
January 31,
11,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Page
Page1843
841 of
of1299
2301

weapons
May 20, 2015

FacebookTwitterMore
9 comments
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
Page
101
109
89of
9
of
of
8 51
50
143
151
51
Thursday,
Friday, December
January 31,
11,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Page
Page1844
842 of
of1299
2301

Related posts:

weapons
Comments

Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
Page
Page
102
110
10
910of
of
9of50
51
143
151
51
Thursday,
Friday, December
January 31,
11,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Page
Page1845
843 of
of1299
2301
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
October 10, 2015
and
Executive Summary
I remain,
Stan J. Caterbone
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
103
111
10
11
ofof41
50
51
143
151
51
Page
111of
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1846
844 of
of1299
2301

&
STAN J. CATERBONE
EXECUTIVE SUMMARY
copyright 2009
do you believe in?
Date Updated:
October 10, 2015
Date Completed:
Date Initiated:
July 28, 2009

July 8, 2009
Stan J. Caterbone
scaterbone@live.com
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
104
112
11
12
ofof41
50
51
143
151
51
Page
212of
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1847
845 of
of1299
2301

The
By
the
end
of
the
summer
of
2010
every
social
media
site,
including
the

And Again, the
Since August 1,

Lambert.

Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
105
113
12
13
ofof41
50
51
143
151
51
Page
313of
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1848
846 of
of1299
2301
no
$600.00.
Common Pleas.
Pennsylvania.
The
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
106
114
13
14
ofof41
50
51
143
151
51
Page
414of
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1849
847 of
of1299
2301

Stan J. Caterbone.
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
107
115
14
15
ofof41
50
51
143
151
51
Page
515of
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1850
848 of
of1299
2301
HISTORY
local laws.
This
ISC was a
INTERNATIONAL
States as of 1992.
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
108
116
15
16
ofof41
50
51
143
151
51
Page
616of
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1851
849 of
of1299
2301
Agency (CIA).
Directors?

scandal.
Patent Office.
subsidiaries.
Carlos Cardoen.
believe him.


Lancaster, County.
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
109
117
16
17
ofof41
50
51
143
151
51
Page
717of
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1852
850 of
of1299
2301



possible.

Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
110
118
17
18
ofof41
50
51
143
151
51
Page
818of
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1853
851 of
of1299
2301

Mind Control.
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
111
119
18
19
ofof41
50
51
143
151
51
Page
919of
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1854
852 of
of1299
2301

WEAPONS.
topic.
without success.
This
more information.
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
112
120
19
20
20of
of151
50
51
143
51
Page
10
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1855
853 of
of1299
2301
FAMILY HISTORY
the following:
business.

Samuel Caterbone,
subprograms.
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
113
121
20
21
21of
of151
50
51
143
51
Page
11
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1856
854 of
of1299
2301
solvents.
His
In 1973 Samuel P.
account.
his record online.
He was in perfect
Julianne McKinney,
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
114
122
21
22
22of
of151
50
51
143
51
Page
12
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1857
855 of
of1299
2301
By his own
suicide.
It left him in the
The
The Schizophrenia
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
115
123
22
23
23of
of151
50
51
143
51
Page
13
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1858
856 of
of1299
2301
School.
Over the
were sold.
very short fashion.
Record:
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
116
124
23
24
24of
of151
50
51
143
51
Page
14
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1859
857 of
of1299
2301
Pennsylvania.
THE PUBLIC RECORD

courts.

court filings.

Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
117
125
24
25
25of
of151
50
51
143
51
Page
15
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1860
858 of
of1299
2301


Stan J. Caterbone
scaterbone@live.com
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
118
126
25
26
26of
of151
50
51
143
51
Page
16
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1861
859 of
of1299
2301
September 7, 2009
Stan J. Caterbone
Advance Media Group
1250 Fremont Street
Derrick Robinson
P.O. Box 9022
Phone 1-800-571-5618
Fax 1-866-433-4170
Derrick,
see
attached.
ISC.
Dollar Fraud.
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
119
127
26
27
27of
of151
50
51
143
51
Page
17
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1862
860 of
of1299
2301

Wikipedia.
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
120
128
27
28
28of
of151
50
51
143
51
Page
18
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1863
861 of
of1299
2301
James Cross
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
121
129
28
29
29of
of151
50
51
143
51
Page
19
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1864
862 of
of1299
2301
Stan J. Caterbone
scaterbone@live.com
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
122
130
29
30
30of
of151
50
51
143
51
Page
20
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1865
863 of
of1299
2301
AFFIDAVIT
The
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
123
131
21
30
31
31ofof151
41
50
51
143
51
Thursday,
Saturday,
Friday, December
October
January 10,
11,
31,
17, 2015
2016
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1866
864 of
of1299
2301
Page
Page
Page
124
132
31
32
32ofof151
50
51
143
51
Thursday,
Friday, December
January 31,
11,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1867
865 of
of1299
2301
Page
Page
Page
125
133
32
33
33ofof151
50
51
143
51
Thursday,
Friday, December
January 31,
11,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1868
866 of
of1299
2301
Page
Page
Page
126
134
33
34
34ofof151
50
51
143
51
Thursday,
Friday, December
January 31,
11,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Page
Page1869
867 of
of1299
2301
scaterbone@live.com
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603

December 6, 2015
Work-In-Progress

Advanced
LNP
Lisa Michelle
Medi Group
Media
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
127
135
35
35ofof151
51
143
51
Thursday, December
January 31,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Page
Page1870
868 of
of1299
2301
14. 1GIF Friday's, Lancaster, by Manager, in January of 2010, No Formal Notice

Formal Notice
Officer.
Wordpress Blog.
Debra Hoeckler
26.Pennsylvania Liquor Control Board, Nortwest Office Building, November 23, 2015,
Dated: December 6, 2015
Advanced
LNP
Lisa Michelle
Medi Group
Media
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
128
136
36
36ofof151
51
143
51
Thursday, December
January 31,
17, 2016
2015
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1871
869 of
of1299
2301
Page
Page
Page
129
137
36
37
37of
of151
50
51
143
51
Page
27
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1872
870 of
of1299
2301
Page
Page
Page
130
138
37
38
38of
of151
50
51
143
51
Page
28
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1873
871 of
of1299
2301
Page
Page
Page
131
139
38
39
39of
of151
50
51
143
51
Page
29
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
! "
Page
Page1874
872 of
of1299
2301
"
$% &
!
" #
%
"&#
(
'
!
(
,
"
"
")
"
""
-
)
!
! "
!
'
%
" !
"
!
)
+
!
" *
"
"
,
,
,
*
%
*
(
%
!
/"0
1
1 ,
"
"
4
!
"
"
!
!
#
.
.
&,,0
%
1 ,
2"3
!
)
** ! "
&,,..$/
&,,
%
&,,
%
&
, "
"
00
"
!,
"
6
7
7 , !
&,,-
8,
:
(
$;$
"2
! " ,
, ,
** !
;
5
$
!
&,,@
,
.
&<;=
>
1
9
,
&,,=
$
,
>
A
1 B3
.+
&,,=
1 B3
2
>
%
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
132
140
39
40
40of
of151
50
51
143
51
Page
30
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
<
Page
Page1875
873 of
of1299
2301
1
1
* "
!
"
C#
"$
"
<
*
&, ,
24
#9
; "
&,,@(&,,= A
3
24
5
!
%
&,,0 4
! %3
"
"
!
&,,
%
!
4
'
5
4
D
%
%
"
""
,! "
0 =
0 =9
9
00&9 00
:
9
&,,-
&, , $
!
%
!
D
%
%
=
F
!
))
+
/4
),
"
0 =
/
$
G
3
%
00
3
3
"
%#
$
$
&, ,
&,,4
!- "
.
&,,@
,
*
&,,<
E
&,,
-) !
/ 4
24
/
$
D
&, ,
D
$
&,,-
&,,0
%
D
!
D
D %
7F !
>
!
D
$
A
8F
$
%
;
D
.
%
&,,3
E
$
*
00=; 00
$
5
! 7
0 =
00
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
133
141
40
41
41of
of151
50
51
143
51
Page
31
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
)
A
Page
Page1876
874 of
of1299
2301
24
$;$
00
(F
&
%
B
5
00 9
" * <
00=( 00 9
:#
> ) "" ""

$
;3
#, " !
&,,-
"
"
"
0 =
&, ,
/
.
$
B
3
3
=
0 =
) "
.
&,,1
0 =
24
" "
3
"
&,,@
" E
""
B
$
<
&,,1
.
&,,-
,-(&&
2
=
@,
"
&,
3
&,,!
&,,@
&,,@
0 =
@, 1
&,,@
9
!
@,
#" !,
0 =
" "1 ,
"
"*
":
" E
F
&,,-
!
B
/
!
"
00=( 00 9
B
:
9
$
'
.
&,,1
9
0 =
&, ,
/
.
00 9
/
&,,9
&,
( "
!
.
00
$
!
&, ,
F
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
3
7
8
!
&,,
&, ,
Page
Page
Page
134
142
41
42
42of
of151
50
51
143
51
Page
32
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
&
, * "
&&
*#
Page
Page1877
875 of
of1299
2301
"
&:
;!
&<
:
%
$
&, ,
$
&,,-
!-
,
5
%
"
>
$
$
< !-
24
? "
;
>
&,,0
B
&,,%
(
$
&, ,
&-
A
.+ $
&@
! :
&,,$
: , *
&, ,
* @
&,,@
"
E
3
&,,
"
&,,0
7 "!
7 "
0 =
*
&=
) "
":
)"
&,,@
"
&
&0
!
< ")
+
9 &,,@
:
9
&, ,
&,,
00
:,
!6
"
"
" .
9 &,,0
0 = "&#
, *
&,,@
/
" F
0 =
;A
0 =
F
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
0 =
Page
Page
Page
135
143
42
43
43of
of151
50
51
143
51
Page
33
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1878
876 of
of1299
2301
!
3
"
$
+
0 =
I $
$
0 =
"2
'
+$;F
D
"$
&,;&,
3
A
00
'
$ 24
"1E1# $
K
E
A
00&
>
L
F
F
B
F
+
0=,K
A
$
$
1
+
>
1
$
>
B
!
3
F
1
00
) % 3
&,,-
!
>
! A !
00,K
1 B3
>
F
F
& 1
F
8
! 4
'
A
! 4
A
0=,K
F
00,K
0 ,K
0<,K
3
/
>
%
&,,
) %$
D 1
"
$
0 <9 F
0@,K
0@,K
$
2!
A? D!B
#
*
$
7
+
00
D 18
.
E
$
M 1
00= E
0 =
%
0 ,K
$
0 =
M
00
!
&,,9
(
9
!
1
,-(
$ !2B+EF2
(&&
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
136
144
43
44
44of
of151
50
51
143
51
Page
34
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1879
877 of
of1299
2301
") !
"
7!
N
.
!
5
F
(
(
5
G
*
A'
, ?
*
? 1
!,
A
(
> "
!, '!
,
B
A
" " * #" !, " "
$C
* #" !, D
73
8
* 7
,
"
"
&
"
#
.
"
#(
5
7
9
'
5
%
7A
8 !
8 !
'
!
7D .2
O
% 8
'
7
'
(
(
%
%
4
K
K
M %
%
K
'
7E
(
8
"
%
'
%(
(
(
4
;
(
7
7
87
(
(
8
8
- 7 > !,
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
137
145
44
45
45of
of151
50
51
143
51
Page
35
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1880
878 of
of1299
2301
* , "
!
B
B
B
B
B
B
B
B
.
.
&
B
B
B
B
B
@
E
@
E
&. @
DD
@
. DD
"
@
& DD
@
. DD
@
& DD
@
$ DD
@
DD
@
E
DD
@
EB& DD
@
EB DD
@
& B DD
@
DD
@
& DD
@
DD
@
& DD
@
DD
B@
)
B@
DD
!
!
))
1"
)
*
!
")
1
3
1
"
)
)
, "
*"
"
, "
!
*
"
")
"
7
"!
"
*
!
*
")
!
6, "
1
5
)
>
' "
*
, "
1 ,!
, "
)
!
"
"
!
!
1
"": !
1 , 1
"": !
"
1
"": !
!
"
! * !
)
*
"E
DD
")
E DD
%
,
!
!"
, "
"
"
"
1 ,"
DD
*)
PPPPPPP "
>7
%#
'?
Stan J. Caterbone
"
Stan J. Caterbone
"
June 19, 2015

Pennsylvania
$
Lancaster
19
PPPPPPP
15
June
&,PP

F
SJC
I
.
I
&, ,
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page
Page
138
146
45
46
46of
of151
50
51
143
51
Page
36
of
41
Don't Know When
24
$
$
Q &, , "!
I
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1881
879 of
of1299
2301
Page
Page
Page
139
147
46
47
47of
of151
50
51
143
51
Page
37
of
41
Page 35 of 41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
06/10/2007
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1882
880 of
of1299
2301
Page
Page
Page
140
148
47
48
48of
of151
50
51
143
51
Page
38
of
41
Page 36 of 41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
06/10/2007
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1883
881 of
of1299
2301
Page
Page
Page
141
149
48
49
49of
of151
50
51
143
51
Page
39
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1884
882 of
of1299
2301
Page
Page
Page
142
150
49
50
50of
of151
50
51
143
51
Page
40
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Advanced
LNP
Lisa Michelle
Medi Group
Media
Grop
Group
Lambert
Press
Press
New
Book
Release
Release
Book
Rebuttal
Page
Page1885
883 of
of1299
2301
Page
Page
Page
143
151
50
51
51of
of151
50
51
143
51
Page
41
of
41
Thursday,
Friday, December
January10,
11,
31,
17, 2015
2015
2016
Saturday,
October
January January
Sunday
22, 201722, 2017
Page
Page1886
884 of
of1299
2301

__________________________________________________________________________
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:

Petitioner
v.
MCI-FRAMINGHAM,
and
CRAIG STEDMAN, THE DISTRICT ATTORNEY OF LANCASTER
and
KATHLEEN KANE, THE ATTORNEY GENERAL OF PENNSYLVANIA,
Respondents
LANC. C.P. NO. 0423-1992
____________________________________________________
BRIEF ON BEHALF OF AMICI CURIAE STANLEY J. CATERBONE
and ADVANCED MEDIA GROUP
IN SUPPORT OF LISA MICHELLE LAMBERT'S HABEAU CORPUS
____________________________________________________
Date: June 20, 2015
_________/s/_______________
1250 Fremont Street
Lancaster, PA 17603
717-826-5354
scaterbone@live.com
January January
Sunday
22, 201722, 2017
Page
Page1887
885 of
of1299
2301
TABLE OF CONTENTS
TABLE OF AUTHORITIES ................................................................................ ii

I.STATEMENT OF INTEREST OF AMICUS CURIAE...................................................3
II. BRIEF IN SUPPORT OF AMICUS CURIE..........................................................5
III. ARGUMENT.................................................................................................7
IV. AFFIDAVIT of TARGETED INDIVIDUAL ..............................................................24
VI. ILLEGAL NO TRESPASS NOTICES AGAINST STAN J. CATERBONE AND
ADVANCED MEDIA GROUP .................................................................................33
VII. FALSE ARRESTS OF STAN J. CATERBONE 1987 TO 2015 ....................................35
VIII. Social Security Disability Proof of Benefits and Application .................EXHIBIT
January January
Sunday
22, 201722, 2017
Page
Page1888
886 of
of1299
2301
__________________________________________________________________
STATEMENT OF INTEREST OF AMICUS CURIAE
__________________________________________________________________
Stan J. Caterbone, herein called CATERBONE is a private citizen and the founder
and only shareholder of the United States incorporated business Advanced Media Group, Ltd.,
and registrar of the fictitious name Advanced Media Group, all Pennsylvania corporations.
CATERBONE was a whistle-blower and shareholder in 1987 involving the United States De fense Contractor International Signal & Control, Plc., known as ISC. In 1992, International
Signal & Control was indicted and found guilty of among other things a Billion Dollar Fraud
and export violations concerning illegally shipping cluster bomb technologies, missile defense
systems, and other defense systems to foreign interests including South Africa, Iraq and Saddam Hussein. Cluster bombs and related technologies are known to have been exported to
Iraq by the Chilean Arms Dealer Carlos Cardoen, a joint venture partner of International Signal & Control. The Central Intelligence Agency is confirmed to have been involved in a covert
program to arm Iraq during the 1980s with close ties to International Signal & Control, which
allegedly included the help of the National Security Agency, a former end user of International Signal & Control technologies under the early 1980s program Project X.
A Presidential
Finding in 1984 by the Bush Administration was executed to implement the program of arm ing Saddam Hussein and Iraq with the cluster bomb technologies.
Serious allegations of
these programs were the focus of investigations that included the knowledge and supervision
of then appointed nominee for the Director of Central Intelligence Agency, Robert M. Gates.
Since 1987, CATERBONE has been the victim of vast civil conspiracy that started in
1987 to cover-up allegations of fraud within International Signal & Control during the negotiations and merger of International Signal & Control and Ferranti International of England.
CATERBONE alleges that warrant-less surveillance was used to obstruct justice and moot his
constitutional rights in an effort to divert attention away from his allegations of fraud within
International Signal & Control back in 1987, and afterwards to the present as a means to
deny his access to the courts for remedy and relief, and Federal False Claims Act violations.
After finally accessing the State and Federal Courts as a pro se litigant, the vast conspiracy
obstructed every due process right that was afforded by the United States Constitution. The
business of Advanced Media Group has been greatly compromised and intellectual property
stolen during the late 1980s and early 1990s that included information technology contracts
with the United States Government.
3
January January
Sunday
22, 201722, 2017
Page
Page1889
887 of
of1299
2301
The interest of amicus in this case is ensuring that constitutional rights of private citizens are not compromised and justice subverted through information obtained from warrantless surveillance upon which there is no just cause for any allegations or association with terrorism. Whistle-Blowers are inherently supportive of a system of checks and balances within
our government that go beyond our constitutional doctrines regarding the same.
Whistle-
Blowers ensure that the rule of law is universally applied to all government officials in all
branches of government. The Federal False Claims Act and its provisions protect individuals
from abuse of power, while providing relief and remedies for those that were wronged and
those that had the courage to cite a wrong.
It is too easy for present and future administrations to abuse their power and utilize
warrantless surveillance as a means of subverting and obstructing justice for those that are
engaged in Whistle-Blowing cases that concern National Security. Without the proper oversight and judicial review, a Whistle Blower can be place on terrorist lists for malicious reasons
without the knowledge or just cause. This is in direct conflict with keeping our democracy
free of corruption while adhering to the spirit of the constitution in the manner our founding
fathers envisioned.
CATERBONE have been a Targeted Individual, TI, and Victim since 1987. In 1987 CATERBONE blew the whistle (public Allegations and Complaints to State and Federal Authorities
of Fraud during merger negotiations with British Defense Contractor Ferranti International)
on an international defense contractor named International Signal & Control, or ISC, who was
selling arms (Everything from Telemetry Systems to Cluster Bombs) to Iraq via South Africa
and was convicted of a $1 Billion dollar Fraud in 1992 by the United States Attorney and several other federal agencies. See ABC/News 20/20 and Nightline in 1991. They were founded
and headquartered in my hometown of Lancaster, Pennsylvania. CATERBONE was a shareholder and was solicited by a top ISC Executives (Convicted as a Mastermind of the Billion
Dollar Fraud) to help finance some of their operations through an affiliate called United Chem
Con.
ISC was a Department of Defense (DOD) Contractor and a partner with United States
Intelligence Agencies since it's beginnings in the early 1970's. One of it's first contracts was
Project X with the National Security Agency or NSA of Ft. Meade, Maryland. Former Secretary of the Navy, Bobby Ray Inman was on the Board of Directors of ISC and was also on the
Board of Directors of Science Applications International Corporation, or SAIC.
SAIC was a
huge defense contractor that was the recipient of the Defense Intelligence Agency, or DIA,
program on Remote Viewing, which SAIC named Project Stargate.
4
It was reported that
January January
Sunday
22, 201722, 2017
Page
Page1890
888 of
of1299
2301
Bobby Ray Inman declined the nomination for Secretary of Defense under the first Clinton
Administration because of the ISC and Trecor scandals.
In the early 1990's I was a subcon -
tractor on a project for the Defense Advanced Research Project Agency, or DARPA, with the
National Institute of Standards and Technology, or NIST called TIMIT.
The project developed
speech corpora for the development of computer based speech recognition systems. I was
also involved in the bidding of other Department of Defense contracts dealing with information technologies. In 1998 I was stalked and approached by an employee of the National Security Agency, or NSA in York, Pennsylvania who said my problems were not with the NSA,
but the good ole boys.
In 2005 I was detained by 2 Defense Intelligence Agency, or DIA
officers in a museum on a military base in Austin, Texas and was questioned and interviewed
regarding my civil actions filed in federal court for several hours. CATERBONE was released
and told to stay off of all military bases. My brother, a Family Physician in Austin Texas had
to verify my travel plans and the fact that CATERBONE was staying with him prior to my release.
CATERBONE's father, Samuel P. Caterbone, Jr. alleged he was part of U.S. Navy experiments in the 1940's and experienced synthetic telepathy in the 1970's, 1980's and 1990's as
outlined in memos and documents he had authored; and from my personal conversations
with him prior to his death. Ms. Amy Fuchs of the Disclosure Project confirmed that he was
most likely given an ET experience via synthetic telepathy. He died in 2001 in New York City
of cancer. My brother was in the U.S. Air Force in the late 1960's and I allege was a victim of
the LSD experiments relating to MKULTRA in the late 1960's and a victim of murder (Suspi cious Suicide with tainted medical reports) in Santa Barbara California in 1984; Notarized
Complaints were filed to the California Attorney General in 1991. He made a declaration type
statement prior to his death that he got bad LSD while in the U.S. Air Force.
Organized stalking and harassment began in 1987 following the public allegations of fraud within ISC. As far back as the late 1980's I thought that my mind was being
read, or "remotely viewed". During the times that legal Counsel and attorneys were solicited
in 1987, 1991, and 1997 Organized Stalking and Harassment and other forms of attacks experienced by Targeted Individuals were severely increased. In 2005 the U.S. sponsored mind
control turned into an all-out assault of mental telepathy; synthetic telepathy; and pain and
torture through the use of directed energy devices and/or electromagnetic weapons. This assault was no coincidence in that it began simultaneously with the filing of the federal action in
U.S. District Court, of CATERBONE v. Lancaster County Prison, et. al., or 05-cv-2288.
5
January January
Sunday
22, 201722, 2017
Page
Page1891
889 of
of1299
2301
__________________________________________________________________________
BRIEF IN SUPPORT OF AMICUS CURIAE
__________________________________________________________________
Was Judge Larry Stengel Involved in 1987 with the Extorted $25,000 from the Airplane and
was Attorney Tim Lanza Representing M. Johnson?
In 1997 CATERBONE had solicited Attorney Christina Rainville of Philadelphia and pro
bono attorney for Lisa Michelle Lambert in the Laurie Show murder case. The murder trials
and appeals of the Lambert case demonized Ms. Christina Rainville and U.S. District Court
Judge Stewart Dalzell.
After CATERBONE submitted documents and audio recordings, Ms. Christina Rainville
had communicated with CATERBONE that she was not able to take his case due to the fact
that her Philadelphia law firm had banned her from taking on any more Lancaster County residents, despite the fact that many more sought her legal counsel.
On December 31, 1997, CATERBONE had also personally delivered a CD-ROM to the
chambers of U.S. District Court Judge Stewart Dalzall in an effort to bring attention to his
case. In May of 1998 CATERBONE submitted an AFFADAVIT to the law firm of Schneider and
Harrison outlining the prosecutorial misconduct or Finding of Facts of the 1987 cover-up for
Ms. Christina Rainville. CATERBONE alleges that these facts were part of the attitude and the
motives for the law enforcement-at-large of Lancaster County and the Commonwealth of
Pennsylvania to ignore the rule of law and procedure in order to bring these false arrests and
malicious prosecutions. The Lancaster County community-at-large had the same attitude toward CATERBONE.
The Lambert case received national notoriety when U.S. District Judge Stuart Dalzell
freed Lambert on a Habeus Corpus appeal hearing citing she was actually innocent beyond
a reasonable doubt. Judge Dalzell was quoted in chambers as saying, I can tell you, Mr.
Madenspacher, that Ive thought about nothing else but this case for over three weeks, and in
my experience, sir, and I invite you to disabuse me of this at oral argument, I want you and I
want the Schnader firm to look for any case in any jurisdiction in the English-speaking world
where there has been as much prosecutorial misconduct, because I havent found it.
6
January January
Sunday
22, 201722, 2017
Page
Page1892
890 of
of1299
2301
The case was covered by a 3 part series in the Los Angeles Times by writer Barry Seigel on November 10, 1997 and a television episode on the A&E Network American Justice
Series. The Lancaster community gathered over 37,000 signatures on a petition to impeach
U.S. District Judge Stewart Dalzell for his rulings. In the end, the Commonwealth of
Pennsylvania took control of the case and appealed the ruling that freed Lambert sending her
back to prison.
The case went all the way to the U.S. Supreme Court in 2005, after being denied any
review. The case accentuated the rights of Federal Law vs. State Law and the Commonwealth
of Pennsylvania solicited a team of attorney generals from across the nation to help their
cause.
CATERBONE attended a hearing before Judge Larry Stengel in the Lancaster County
Court of Common Pleas and to this day, due to his knowledge and experience with the Lancaster County Judicial System and Law Enforcement believes the case should have never
been conducted without a jury trial, and that the over zealous prosecution proves that pro secutorial misconduct was never thoroughly investigated or prosecuted in the Lambert case.
CATERBONE will not let that happen in his cases.
In addition the U.S. District Judge that took over the Lambert Case after Judge Stewart
Dalzall was forced to recuse himself was U.S. District Judge Anita Brody. Judge Anita Brody
has ruled on several of my cases in the U.S. District Court for the Eastern District of
Pennsylvania.
All of my challenges to my Chapter 11 Bankruptcy Petition Case No. 05-23059
are heard by Judge Anita Brody. This may not be coincidence.

In April of 2009 CATERBONE applied to the Social Security Adminstration for Disability
Benefits alleging disability for his years of torture as a victim of U.S. Sponsored Mind Control.
After supplying all the necessary supporting documentation and without any Psychiatric Evaluations CATERBONE received his Award Letter declaring him disabled as of December of
2005, the date used as the start of his full-time synthetic telepathy. SSA paid him retractively to April of 2008 and in August of 2009 CATERBONE received a payment of $21, 456.00
and monthly benefits of some $1,500.00 per month. All of this was accomplished with any
outside counsel. U.S. Congressman Joe Pitts office was requested to assist in the matter of
getting a psychiatric evaluation, however their endeavors proved moot.
January January
Sunday
22, 201722, 2017
Page
Page1893
891 of
of1299
2301
On Episode 435 for ABC News the THE KILLING OF LUARIE SHOW Pennsylvania Attorney General Prosecutor Christie Fawcett states that it would have taken 100 people to collaborate together to make her story believable. I can show evidence that organized stalking
or gang stalking of targeted individuals often involvs volumes of people. The following is
taken from the Wikipedia page on STALKING and defines stalking by groups:
STALKING BY GROUPS
See also: Mobbing
According to a U.S. Department of Justice special report[13] a significant number of
people reporting stalking incidents claim that they had been stalked by more than one per son, with 18.2% reporting that they were stalked by two people, 13.1% reporting that they
had been stalked by three or more. The report did not break down these cases into numbers
of victims who claimed to have been stalked by several people individually, and by people
acting in concert. A question asked of respondents reporting three or more stalkers by polling
personnel about whether the stalking was related to co-workers, members of a gang, fratern ities, sororities, etc., did not have its responses indicated in the survey results as released by
the DOJ. The data for this report was obtained via the 2006 Supplemental Victimization Survey (SVS), conducted by the U.S. Census Bureau for the Department of Justice.[14]
According to a United Kingdom study by Sheridan and Boon, [21] in 5% of the cases they
studied there was more than one stalker, and 40% of the victims said that friends or family of
their stalker had also been involved. In 15% of cases, the victim was unaware of any reason
for the harassment.
Over a quarter of all stalking and harassment victims do not know their stalkers in any capa city. About a tenth responding to the SVS did not know the identities of their stalkers. 11% of
victims said they had been stalked for five years or more. [13]
A study from Australia and the United Kingdom by Lorraine Sheridan and David James, [22]
compared 128 self-defined victims of 'gang-stalking' with a randomly selected group of 128
self-declared victims of stalking by an individual. All 128 'victims' of gang-stalking were
judged to be delusional, compared with only 3.9% of victims of individual-stalking. There
were highly significant differences between the two samples on depressive symptoms, posttraumatic symptomatology and adverse impact on social and occupational function, with the
8
January January
Sunday
22, 201722, 2017
Page
Page1894
892 of
of1299
2301
self-declared victims of gang-stalking more severely affected. The authors concluded that
'group-stalking appears to be delusional in basis, but complainants suffer marked psychological and practical sequelae. This is important in the assessment of risk in stalking cases,
early referral to psychiatric services and allocation of police resources.'
In the URBAN DICTIONARY the definition of gang-stalking states:
ORGANIZED STALKING:
A system of organized psychological terror tactics used against a person who has become an enemy of an individual or a government. Subtle but effective techniques of stalking
by multiple individuals and psychological intimidation and manipulation are used to slowly but
surely drive the target to make complaints to authorities who will see the complaints as
bogus because of the methods used against the target. As a result, the target gets labelled
as mentally ill.
There are as many stalking tactics as there are targets as the multistalkers will tailor
the stalking to the individuals habits and individual personality. Some common examples or
organized stalking are: following the target on foot, by car and public transportation,
crowding the target's space in a public place, murmuring insults under the breath so only the
target can hear, sitting in the car outside the target's residence, starting "fights" in public
with the target, doing "skits" on the street which involves information only the target should
know but has been found out via surveillance of the target, stealing and vandalism of the target's possesions.
In my final analysis I can attest the I have the victim of gang-stalking or organized stalking by more than 100 people.
January January
Sunday
22, 201722, 2017
Page
Page1895
893 of
of1299
2301
________________________________________________________________
ARGUMENT
__________________________________________________________________
HAD LANCASTER COUNTY (Pennsylvania) LOST ITS SOVEREIGNTY BEFORE IT LOST
ITS SOUL?1
Each time a man stands up for an ideal, or acts to improve the lot of others, or strikes out
against injustice, he sends forth a tiny ripple of hope. And crossing each other from a million
different centers of energy and daring, those ripples build a current which can sweep down
the mightiest walls of oppression.. by Robert F. Kennedy
In 1987 Stan J. Caterbone Had Unjustly Lost His Freedoms, His Rights, And His Pursuit Of Life, Liberty And Justice.
The following is an amazingly true and factual account of an extraordinarily bizarre
tragedy that has turned one mans life into an eleven (11) 2 year free fall into Dantes Hell.
On the surface, this is a story of a victim struggling to seek the truth, but in reality, the evidence will conclude that this is a victim, literally, held hostage by virtue of his truth. Later, the
preponderance of evidence that Stan Caterbone has amassed and his obsession for meticulously documenting his ordeal might seem eccentric, yet his demonstrated ability to react to
events before they unfold appears mystical. And this was his manner in which he tactfully defended and protected his life. It is these actions that have painted the landscape with a dire
vengeance for his ruin. His actions will ultimately serve to protect, preserve, and foster the
truth of his story, incriminating the culpability of his many perpetrators, while at the same
time being twisted and tainted in a relentless manner to attack his credibility.
This is a story of a human being endearing for his rights, living in fear of his life, and
the remedial actions required for the truth to set him free. A victim forever believing in his
accomplishments and his visions, yet forced to adhere to a life of their diversions. Fatefully,
ten years after being taken as a political hostage, with the aid of numerous arrests and
In April of 1997, Federal Court Judge Stuart Dalzall said Lancaster County had lost its soul in
the worst case of prosecutorial misconduct ever found in the English speaking language regarding the Lisa Michelle Lambert hebeas corpus hearing in the notorious Laurie Show murder case.
1
10
January January
Sunday
22, 201722, 2017
Page
Page1896
894 of
of1299
2301
false imprisonments conveniently falling short convictions, a Federal Judge, Judge Stuart
Dalzall, of the Eastern District Court of Pennsylvania, opened a Pandoras Box into the true
colors of the inner workings and politics of ultra conservative Lancaster County, Pennsylvania,
a supposedly Gods country. His findings reeled a dramatic and emotional response from the
Lancaster County community that was akin to the assassination of JFK. A community where
obstructions of justice strikes a startling and stark contrast to the image it so desperately
embraces. A community proud of its tough on crime judges, a community of plain folks
and Amish, and a community settled in a beautiful landscape abundant in an agricultural
bounty. This is not a community of compromising integrity. Or so it has been perceived.
Judge Dalzalls extremely controversial findings were responsible for Pennsylvanias
own crafting of the Laurie Bill, the retaliation by the Commonwealth of Pennsylvania intended to curb the Federal Courts interference within the respective states own jurisdictions and
proceedings. Or was it a political maneuver to close the lid on Pandoras Box? The
Pennsylvania Attorney General and the Lancaster County District Attorney have both thrown
all their might and all their muscle at turning the tides of Judge Dalzalls findings. This story
and Stan Caterbones rights have been violated and abused by some of the very same principals that were responsible for Judge Dalzalls unsettling revelations. Lancaster County prosecutors were found to have engaged in one of the grossest acts of prosecutorial misconduct
found in the English speaking language, which allegedly occurred in this now famous Lisa
Michelle Lambert case, a murder trial which began in the summer of 1992. Subsequently, it is
now in the midst of a treacherous appeal process convened by Judge Dalzall. And if so, by
fate, in Philadelphia, Pennsylvania; the home of the Freedom Fighters.
It is this public disclosure, that casts a new light and sudden hope for freedom into
Stan Caterbones unbelievable and horrid story, that begun just four years prior to the
murder of Laurie Show. It is the decisive similarities of how both victims were subjected to a
very calculated and politically motivated attempts to frame and fabricate circumstances to
obtain the results that justified the means for illicit self-serving interests. This very same conduct, committed by public servants, elected and enlisted to enforce the law, to which Judge
Dalzell found so appalling. Conduct, which violated the very same rights their respective offices are commissioned to protect. Conduct, which strikes the meaning of We The People
from our nations very own Constitution.
11
January January
Sunday
22, 201722, 2017
Page
Page1897
895 of
of1299
2301
Fortunately, Stan Caterbones story is laced with a thread of faith, a faith in God. And
because of his faith, Stan Caterbone will forever regard Lisa Michelle Lambert3 and Laurie
Show as his little Angels of Justice, a Godsend. An answer to his many prayers, that for the
first time in ten years provided a small glimmer of hope, and a few moments of solitude that
have materially justified his own tragic experience. The realization that the truth is that much
more believable because of the trials and tribulations of Lisa Michelle Lambert. Unfortunately,
this revelation came at the unfortunate and untimely death of Laurie. However, it just may be
Gods intentions of a Higher Purpose.
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 Caterbones rights for justice. Its 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 Boys club of Lancaster County. A process obsessed with keeping its
disclosure from escaping beyond the confines of Pandoras Box. Its a tenure of power that
evolved from the days of this countrys 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!
The author admitted in an affidavit in 1998 that he did not know the criminal culpability of Lisa
Michelle Lambert, and further argues that it was because of the prosecutorial misconduct and the
erroneous handling of the crime scene that the truth evaded both the prosecution and the defense
as to who actually killed Laurie Show.
3
12
January January
Sunday
22, 201722, 2017
Page
Page1898
896 of
of1299
2301
AT ISSUE
The central issue in this story is a cover up, a cover up of mass proportions, and of
perplexing design, with national consequences. The fact of the matter is that this cover up
has had ramifications throughout this world; specifically the Middle East The cover up would
be emphatically unbelievable without the wealth of evidence, especially the recorded conversations with Pennsylvania officials. A cover up that permeates from what will later emerge as
the 4th largest financial fraud (Billion Dollars) in the history of the United States coupled with
the covert sales of arms to Iraq. And five years after this cover up began, these same munitions were used against our own troops in the Persian Gulf War. And of course, there are admitted ties to the Central Intelligence Agency (CIA) and the National Security Agency (NSA)..
And this cover up and story, which began in June of 1987, in Lancaster County, preceded
criminal indictments by the United States Attorney General, the Federal Bureau of Investigation (FBI), the Internal Revenue Service (IRS), the Department of Justice and Commerce,
and more. A vast array of criminal activities conspired from the ultra conservative Lancaster
County, where God is supposedly supreme, and its hard line approach to crime is said to be
preeminent. In June of 1987, Lancaster County was immersed in a dynamic twist of fate, with
a host of players which may never be fully identified.
The irony of this story is how Lancaster County manages the disclosure of the very
same criminal activities that this story proves that it condoned, prior to the intervention of
federal authorities. It most dramatically will prove the nature of its integrity, or lack thereof.
International Signal & Control, (ISC) is the controversial player in this web of conspiracy.
In 1987, ISC was the third largest employer in Lancaster County, a non-discrete defense con tractor. In all due respect to our beloved country, this report is in no way challenging the
policies or the activities of the Department of Defense, or the vast agencies of the Intelli gence Community, especially the CIA or the NSA (National Security Advisory). with regards
to ISCs foreign dealings. Trying to protect the world of malicious and evil empires is a process which never ends, and whose players are constantly changing. And our respective intelligence agencies are continually challenged with the task of trying to make a difference, in accordance with protecting our national security. Unfortunately, given the nature of their discrete activities, and given the CIAs history of avoiding congressional approval in certain situ ations, our current laws are void of effectively dealing with the peripheral catastrophes of
such activities that inherently transpire. The CIA remains immune, while everyone outside
suffers the consequences.
13
January January
Sunday
22, 201722, 2017
Page
Page1899
897 of
of1299
2301
The fact that the CIA, or anyone of the other intelligence community, may have been
involved, does not grant a blanket of immunity over activities which were not material to protecting our national security. If a company provides a service to anyone in the intelligence
community, our constitution, our laws, and its respective commercial regulatory authorities,
must still have the full sense of their jurisdiction. The intelligence community may not have
the right of intervention into the commercial enterprise, or organization, circumventing the
rights of its employees, shareholders, creditors, and customers. No United States law or statute suggests that there is any involuntary mandate that requires any of the preceding to
compromise his or her interests in the respective enterprise for the sake of national security,
or the respective intelligence agency. There must be considerations paid to all involved for
those rights and interests that compromise such a relationship. Otherwise, the CIA could effectively gain control of any domestic corporation it so desires, without ever owning one
share of its outstanding stock, simply by enlisting its product or services for the sake of national security. The CIA requires a formal vehicle to enlist the aid of our domestic commercial
enterprises. ISC is a proven and unfortunate example of that.
Stan Caterbone was a shareholder of record of International Signal & Control (ISC) for
the previous four years prior to when this tragic ordeal began. Stan Caterbone was to purchase the stock from now Republican Pennsylvania Senator Gib Armstrong, who was in the
brokerage business at the time and selling ISC stock. The stock was sold over the London
Securities Exchange, supposedly for reasons to suppress information. Stan Caterbone was interested in the stock because of his appetite for technology, and was more curious about the
business of ISC, than anything. In fact, Stan Caterbone had never made any inference to any
of the illicit dealings with Iraq. However, the perpetrators of this story, attempt to hide behind
a vale of national security," in an effort to find legal immunity from all wrongdoing. In ac cordance, the record will prove that this is merely a smoke screen used to intimidate and obstruct Stan Caterbones access for due process of the law.
The trials and tribulations of Stan Caterbone are unprecedented in terms of emotional and psychological duress, fortunately his indestructible faith in God, and his enduring
belief in himself and the truth, endures his life. There was one attempt on the his life, days
within the public disclosure of the CIAs involvement with the local Lancaster County defense
contractor (ISC), which Ted Kopel reported on ABC News Nightline, on May 23, 1991, 4 years
after the initial cover up began. This story will depict a series of systematic and strategic of14
January January
Sunday
22, 201722, 2017
Page
Page1900
898 of
of1299
2301
fensive attacks upon Stan Caterbone and his businesses that will result failed business enterprises, and a Hollywood motion picture, deserted. An impeccable professional reputation and
a flawless credit rating purposely sabotaged. Financial opportunities, that in 1987, were al most impossible to extrapolate, Vast financial opportunities and aspirations forever a part of
history. This horrendous Crime was perpetrated for the interest of a cover up, further protecting the corrupt enterprises of Lancaster County's International Signal & Control (ISC). A
quest for justice that polarized every relationship Stan Caterbone maintained, in Lancaster
County and beyond, including friends and family. This story demonstrates a methodology of
his perpetrators for keeping Stan Caterbone quarantined from justice and public disclosure,
through a malicious means of credibility proponents, and horrendously deceptive tactics.
Financial motives prominently displayed in the hands of all of the perpetrators, which absolves the burden for a traditional conspiracy.
The emotional response to the truth of this story is compelling, to say the least.
Subsequently, the startling keen sense of perception that Stan Caterbone had demonstrated is even more intriguing. It is this extraordinary quality that is responsible for saving
his life, while yet at the same time providing his perpetrators with an alibi and a vehicle for
discrediting his startling allegations and his story. This story embellishes a dichotomy of perception that had Hollywood producers from his film project call his work genius, while his per petrators from the Lancaster County Community conveniently and maliciously labeling him as
insane and emotionally disturbed."
15
January January
Sunday
22, 201722, 2017
Page
Page1901
899 of
of1299
2301
THE LANDSCAPE
The perplexing question of Stan Caterbones intelligence, or lack thereof, is best analyzed as a question of perception. However it terms of the legal consequences of the activities
contained herein, they are of little if any relevancy. The fact of the matter is that the mental
deficiencies have very little relevancy to this story, other than serving as a means to discredit Stan Caterbone, a vehicle to facilitate the cover up, and a blanket of immunity for all of the
perpetrators.
The heart of Stan Caterbones legal dogma is best described as follows: If a person, is
perceived to have a mental deficiency; yet whose actions and decisions are always proven
to be instinctually and amazingly prudent, always abiding within the law, and in the best interest of his affairs, what rights and protection do the laws afford him from persons abusing
that perception, in order to yield political and financial rewards, as a direct consequence of
his demise? Furthermore, how does the law protect his rights, if any and all malicious acts
against Stan Caterbone, are constantly and immediately disregarded because he is perceived
to not to be credible? As this story unfolds, these questions will become even more troubling and appalling. Although Stan Caterbone could never describe the pain of his trauma, he
would often say that the closest situation that may compare is that of a woman being continuously raped, night after night, helplessly praying for relief, struggling to free herself from
her captor, all with no avail. He would call it as being brain f------.
Stan Caterbone, coming from the lower middle class of Lancaster City, was only 29
years old when this tragedy began. Coming from a broken home, he was the third of six
boys. While at a very young age, he would help his mother run a dry cleaning business, in an
amazing similarity like Lisa Michelle Lambert, he had also nursed his mother during bouts of
depression. While in high school, he was nursing his mothers depression, while at same time
tending to his older brothers bouts of schizophrenia. Stan Caterbone had learned to listen to
the obscenities of mental illness since he was a child. He learned to fill the shoes of his ab sent father in helping his mother raise his three younger brothers.. Stan Caterbone was often
called the little old man because of his extraordinary maturity as a child. Stan Caterbone
was determined to break the barrier of the Good Ole Boys club or the power elite, and
had always felt a sense of compassion for those less fortunate, and those neglected by those
of material means, the oppressed and impoverished. He had an undivided aspiration to
someday make a difference to those that could not help themselves, especially his older
16
January January
Sunday
22, 201722, 2017
Page
Page1902
900 of
of1299
2301
brother. Through his ingenious, resourceful, and honest business approach, he was relentlessly growing his business and their respective missions, in constant reminder of his oppression. His in depth understanding of computer technology and his vision were his most powerful allies. Always pushing the envelope for advanced technologies and seeking solutions for
the most efficient means of his operations.. He knew that every break was going to be few
and far between, he dedication himself to his work, and married his business affairs, always
In 1986, after serving on the Board of Directors for the Central Pennsylvania Chapter
of International Association of Financial Planners (IAFP), Stan Caterbone had made a large
contribution to increasing its membership and its awareness among local professionals, as
its vice president. In an effort to promote the organization, Stan Caterbone solicited a nationally recognized and prominent financial planner from Washington, D.C., to be a headline
speaker at a dinner meeting. Ms. Alexandra Armstrong, one of the most nationally recognized
financial planners, often headlined in Money Magazine, attracted 100 industry professionals to
the Treadway Resort Inn. The attendance was unprecedented for the local IAFP chapter. The
IAFP is the authoring organization for certification as a financial planner. It was through the
direct conversations with Ms. Armstrong regarding his ideas and her experience, that inspired
Stan Caterbone to pursue his ambitions of growing his own financial firm, which he began in
the following months.
Disgruntled with the conflicts of interest and the lack of incentive for various professionals to work together in managing ones wealth, a process which lacked efficiency, this entrepreneur founded the firm Financial Management Group, Ltd., or FMG as it was often
called. The firm was to incorporate a one-stop-shopping strategy and incorporate financial
services, legal, accounting, tax preparation, real estate, insurance, mortgage banking, and
estate services all in one firm, all residing in one location, all taking advantage of the synergistic approach toward managing wealth. And to provide the professionals long term security
and equity participation, all participants were encouraged to purchase stock in the company.
This was a new and innovative approach that attracted a lot of attention from investors and
clients, but also came a lot of nervous twitches from competitors, especially in conservative
Lancaster County.
Stan Caterbone began recruiting professionals from all of the other firms, with great
success. He had enlisted two partners whom he had worked with at IDS/American Express,
17
January January
Sunday
22, 201722, 2017
Page
Page1903
901 of
of1299
2301
to carry out his mission, which he began after extensive market studies and his early version
of the company, Pro Financial Group, Ltd., His two partners had followed Stan Caterbone to
an independent broker dealer in Atlanta, named Financial Services Corporation, where Ms. Alexandra Armstrong was associated, and encouraged Stan Caterbone to visit, during their
discussion after dinner. Within one year, by June of 1987, the firm had invested over $40
million for respective clients.
The company had developed satellite offices throughout Pennsylvania and in several
other states, through his unique design. This firm was causing the other financial services
companies and the local banks in Lancaster County a run for their money. The firm had built
a new 20,000 square foot office building just a few miles north of the city. The firm was at tracting clients, associates, and nervous attention from, well just about everybody. Considering the capabilities, legal, real estate, insurance, financial services, accounting, FMG was
making as many enemies as it was making friends. And Stan Caterbone always believed in
the premise that its always better to have people talking about you, regardless of the matter,
than to have no one notice you. And they were talking. Stan Caterbone was only in his late
twenties when he started this organization,. He held several positions; he was Executive Vice
President and Secretary of Financial Management Group Ltd, and President of FMG, Advisory,
Inc., which was one of the many subsidiaries parent company owned. Stan Caterbone acted
as the architect and legal administrator of the organization, in addition to building his own
financial planning clients. He filed all of the articles of incorporation in the Commonwealth of
Pennsylvania and submitted all of the tedious and rigorous filings necessary for the
Pennsylvania Securities Commission, which were very demanding considering Stan Caterbone, was selling stock of his company to his associates and investors. Stan Caterbone and
his associates had also attracted some very prominent Lancastrianss to invest in his venture,
coming from various professional circles, all infatuated with this extraordinary and intriguing
concept of this young victim. All had seen its potential for success and financial reward.
Many of his friends were involved, and in Lancaster, everyone knows everybody, so it
seams.. And everyone talks, gossip is as common as jogging. This exaggerated trait of Lancaster County, will later to come back to haunt Stan Caterbone, in a way that is most sickening. In a way that will parallel the attitudes and sentiments in the Lisa Michelle Lambert story.
18
January January
Sunday
22, 201722, 2017
Page
Page1904
902 of
of1299
2301
In 1987, his business affairs were reaching a point of incredible success. In fact, most
of his family and friends, have always questioned the merits of their legitimacy. He always
conducted his affairs with the presumption that time could not afford the opportunity to com plete his agenda, while at the same time disclosing his business affairs to persons that were
not directly involved.. Accomplishing his mission was first and foremost. But in Lancaster
County, that was difficult. Lancastrianss have a notion to fear what they dont know, and will
always believe what they think they know, regardless of its merits. In Lancaster County new
ideas are shunned unless coming from their own, and their own ideas are often kept close at
bay, inhibiting progress and stymieing learning. By June of 1987, a majority of his business
affairs were conducted out of the grasp of Lancaster County, his unknown activities made
others curious, especially in Lancaster County, where the blessing of the power elite was essential for success. But, deep down inside, he knew he could never be accepted, because he
did not descend from a family of social grace. This fueled his aspirations for success even
further, committed to prove that intelligence was innate and learned, not a direct correlation
to material wealth or social grace.
An elder attorney, Mr. Kenellm Shirk, a very respected and prominent older Lancaster
attorney, who was part of the status quo, provided one of his most cherished testimonials to
his concept, his reputation, and his mission. Mr. Shirk had petitioned the Pennsylvania Bar
Association, after meeting with Stan Caterbone, to obtain their blessing and their knowledge
of any laws which would forbid his firm to provide a satellite office in the headquarters of Financial Management Group, Ltd., (FMG) Mr. Shirks firm was to provide a partner, and estate
services to the clients of FMG. The Pennsylvania Bar provided a lengthy recommendation that
did not prohibit a relationship, although cautioned it to proceed with careful review. The fact
that the very young and unknown Stan Caterbone could attract an elder, conservative Lancaster County attorney to associate with his firm was an encouraging sign of respect. Ironically, Mr. Shirk is the father of Roy Shirk Jr., Lisa Michelle Lamberts first attorney who represented her during trial of 1992, the proceeding which was the center of Judge Dalzalls controversial and appalling findings. Stan Caterbone prided himself on his entrepreneurship, and
after building the foundation for FMG, he set out to take advantage of its resources and its
synergism.
19
January January
Sunday
22, 201722, 2017
Page
Page1905
903 of
of1299
2301
By June of 1987, Stan Caterbone had developed a fairly substantial mortgage banking
relationship with a Houston, Texas banker. That operation was capable of providing lending to
potential developers and businesses in the range of $ 3 million to $100 million. And the lend ing packages were as competitive if not more competitive than the local lending institutions
of Lancaster County, capable with even higher lending limits. In a matter of months of securing this relationship, Stan Caterbone
and his partner were evaluating deals from
Pennsylvania, New Jersey, New York, Florida, and as far away as California.
There was a uniqueness to his capabilities that was very appealing to potential borrowers. Because of the vast array of services of FMG, potential developers had the opportunity to
obtain both debt and equity financing through his companies. In plain terms, most shopping
centers raised capital by raising funds through investors coupled with a mortgage. This gave
potential developers one place to take down the deal rather than dealing with many other
professionals at the same time. It was a much more efficient process for all. Stan Caterbone
was capable of providing a mortgage, while at the same time selling shares in a shopping
center through its vast client base of investors at FMG. This also gave Stan Caterbone a formidable presence into the venture capital markets, by way of his strong ability to raise capital
through his vast portfolio of clients of FMG. And this was a rarity that developers and investors loved. Investors were attracted because they could invest in equity type real estate
projects with real sense of knowing the developer, or kicking the bricks of the project. This
was far different than investing in a nationally syndicated project, with properties scattered
all over the country, and with developers that they did not know. The synergistic approach to
his organization began paying dividends by developing other peripheral markets and businesses.
Given the complex nature of Stan Caterbones design of FMG, internal struggles within
the organization readily became the challenge. Orchestrating the relationships among all of
the different professionals, and trying to adhere to the interests of the clients, the professionals and of the firm, FMG, managing the daily activities required immense thought and
prudence on the part of the principals. Of, course, Stan Caterbone assumed honesty and integrity to be a given. And for most it was. However there were times when the senior partner
engaged in tactical rights of power.
20
January January
Sunday
22, 201722, 2017
Page
Page1906
904 of
of1299
2301
In the later part of 1986, after Stan Caterbone had developed FMG to the point where
its future was on stable grounds, his two partners conveniently attempted to circumvent his
position and regain control of his stock and the firm. In fact, after Stan Caterbone refused to
collaborate on a scheme to set up his other partner, the remaining two partners began to
attempt to regain Stan Caterbones control. Through intimidating techniques, the partners
began to attack his presence. Stan Caterbone became agitated, especially because he played
the lead role and was responsible for the formation of the company, methodically designing
and developing its foundation, with great success. And now after the company was beyond
its point of greatest risk, due to in large part Stan Caterbones efforts, the other two partners wanted to take advantage of his work, and take the cream of the pie for their own fin ancial gain. It was a difficult task to carry out because Stan Caterbone was the most respected of all three partners, consistently keeping their respective policies in the best interest of
the firm and of the other associates and stockholders. In fact, most feared that the loss of
control of Stan Caterbone would ultimately lead to adverse consequences. However the two
partners trued unsuccessfully to weaken his position, and when that didnt work, they focused on weakening Stan Caterbone, via intimidation and humiliation The coup and hostile
environment caused a state of depression for Stan Caterbone, although he kept to his daily
duties and responsibilities, accordingly, he called a client and friend who was a psychiatrist,
whom he trusted and respected. It was easy access to a professional, yet on a very informal
basis. Because Stan Caterbone had a family history of mental deficiencies, he wanted to
seek the proper help.
The psychiatrist had diagnosed Stan Caterbone as having Bi Polar Mood disorder. The
psychiatrist had quickly discounted any correlation between the current state of affairs, and
his partners abuse. The psychiatrist rationale was that because the startup of the company
was so successful in such a short period of time , and his demonstrated intelligence and creativity, Stan Caterbone must have been in a state of mania, and of course now, was subsiding
in a state of depression, the typical cycle for manic depressants. Stan Caterbone complied
with the psychiatrist. And after refusing to sell out to his partners, vowed to regain his business and rescind any efforts to give up his claim to his accomplishments. The depression
soon faded. Stan Caterbone never disclosed the fact that he had sought help to anyone other
than family members. This coup lead to Stan Caterbones aggressive approach to grow the
business, and to posture himself in projects that would ultimately remain in his control, out of
21
January January
Sunday
22, 201722, 2017
Page
Page1907
905 of
of1299
2301
he influence of his partners. Particularly of most interest was saving the mortgage banking
activities and the digital movie, which he did successfully, but apparently too successfully.
22
January January
Sunday
22, 201722, 2017
Page
Page1908
906 of
of1299
2301
THE DIGITAL MOVIE

Through an act of fate, in February of 1987, Stan Caterbone found himself in a
meeting with Tony Bongiovi at Power Station studios. Through one of his partners, he reluctantly traveled to New York to consider financing a motion picture. Stan Caterbones own lack
tolerance for the risk associated with film investments was overshadowed by the opportunity
to visit a recording studio. Although his associate was a friend of Tonys, he was not familiar
with his accomplishments, or his work, so he thought. If nothing else, it was a weekend away
from Lancaster, and a chance to visit the Big Apple. Intriguingly, he found more than he had
ever imagined on that weekend excursion. Tony Bongiovi, a musical genius, whos credits include one of the most recognized recording studios in the country, Power Station Studios.
Tony Bongiov produced the sound track for Star Wars, and is responsible for the format of
one of the most successful recording artist of the 80s, Jon Bon Jovi, his cousin. Power
Station
has recorded the albums for some of the most influential artists of all time, including Diana
Ross, Madonna, The Rolling Stones, Steve Winwood, Bruce Springsteen, etc., Tony, an eccentric genius, of Italian decent, had many talents, from music to aerospace engineering.
Stan Caterbones associates sister met Tony while he flew his plane into Lancasters airport
for repairs. They dated for some time and Stan Caterbones associate and Tony became
friends, which led Stan Caterbone to Tonys Power Station Studios.
Tony was looking to finance his new project, which was to be the first digital movie.
And, given Stan Caterbones extreme appetite for technologies, coupled with his amazing
sense of perception, he dramatically recognized the future evolution for the technical merits
of delivering digital video and digital audio entertainment to the mass markets. By June of
1987, Stan Caterbone was positioned as the Executive Producer, collaborating with Flatbush
Films of Hollywood California, the movie producers, entrusted with the mission of finding investors to provide funding for the first digital movie, and to manage the ensuing business
The movie was to be shot on-location at the Jersey shore points, mostly in Wildwood.
Tony strategically envisioned making a movie in the horror genre. There were several specific
reasons that supported this strategy. First, he determined that it was the least expensive
format to produce, we all estimated a budget of $4 million for the production and post production. Secondly, the horror genre would compliment a very intense sound track. The sound
track was important to enhance the new digital format, and also provide the means to intro23
January January
Sunday
22, 201722, 2017
Page
Page1909
907 of
of1299
2301
duce a new band that he had been grooming in his studio for the past several years, French
Lick, his predecessor to Bon Jovi. There had been bad blood between Tony and his cousin
Bon Jovi, which resulted in legal disputes pertaining to Tonys financial interests in Jons
success. It was an unfortunate situation considering Tonys father and Jons father were
brothers living in the same area. It was a subject that Tony never wanted to discuss, except
for his contributions toward Jons career.
If by another act of fate, Stan Caterbone had the privilege of meeting one of the many
superstars while working at Power Station studios. While growing up, at an early age, Stan
Caterbone would sneak up into the bedroom of his oldest brother, and start up his old General Electric stereo phonograph and listen to his favorite album - Diana Ross and the Supremes.
It was a passion and a ritual that provided an early infatuation to music, and to Diana Ross.
Stan Caterbone was only 10 or 11 years old. And at this early age, he noticed and listened to
the annoying hiss, that conventional hiss that always seemed to overshadow the music,
And in a mystical twist of fate, while engrossed in a project dedicated to delivering music without that hiss (digital) - Stan Caterbone opened the door to the recording suite to pack
his bags for the journey back to Lancaster; - and there she sat, with a glowing array of
beauty, more beautiful than any picture could ever tell, Ms. Diana Ross. She was pregnant
and in the middle of a recording session, for a new album. Her assistant quickly demanded,
in a stern and protective voice, that we leave, and Stan Caterbone and his associate replied
this is our makeshift bedroom, we are just gathering our belongings. Stan Caterbone
walked toward Diana Ross, who was seated near his bag, and she asked and who are you?,
Stan Caterbone calmly replied his name and absorbed as much of her beauty as his eyes
could behold before walking out the door. The room that was his bedroom the nigh before,
and suddenly transfixed into the recording suite of Diana Ross, thinking back some twenty
years earlier, one of the many gifts that God would bestow upon him. A living memorial and
reminder to his older brother, who died on Christmas day of 1985, his best friend who taught
him two of his greater pleasures in life, Diana Ross, and listening to music. He prayed that his
And so, the digital movie project that Stan Caterbone had embraced in 1987 had personal significance, and he never ever doubted his instincts regarding the technical merits of
24
January January
Sunday
22, 201722, 2017
Page
Page1910
908 of
of1299
2301
the project. Stan Caterbones perception that the entertainment industry would deliver full
length motion pictures in a truly digital medium will later become a truly remarkable vision.
The technical merits of this project and at this particular time with respect to Stan Ca terbones extreme sense of perception require analysis. To truly understand this time perception, some of the attributes of digital technologies need to be fully understood. In 1987,
Compact DISC (CD) technology was only now being introduced to the commercial markets.
Stan Caterbones own crafting of his joint venture proposals, dominated by the term digital
movie, is in itself some 4 or 5 years away. In 1987, there was very little use of the term di gital, with the exception of research and development engineers. Stan Caterbone will,
throughout the documentation of this story, will have preceded a terminology that has literally become the root of most technological advancements in the computer and telecommunications industries of our present day, 10 years after Stan Caterbones vision. Today, digital is
found to be part of or referred to in just about every product available in the commercial
markets.
Entertainment, Inc., for the digital movie. After weeks of researching the current state-ofaffairs within SONY, and after his proposal was completed, SONY publicly announced their desire to open the markets for new and emerging technologies on the cover of TIME
magazine, another demonstrated sense of perception. It was this proposal, when delivered
to one of the Hollywood producers in Santa Monica, California, after reading a draft of the
proposal she said you are a genius. The proposal was introduced to Tony Bongiovi at the
Wildwood Boardwalk, where many of scenes were to be shot, and he approved of the proposal and thought that it had great merits. Tony, who wanted very to do with the business ele ments of his project, gave Stan Caterbone complete authority to secure the financing of the
project, with a salary as Executive Producer, and a percentage of the profits on the back end.
After review of Stan Caterbones research and proposals, his vision and his passion,
which is Sonys satellite entertainment system (TV), delivering digital audio and digital video
entertainment. That technology is fast eroding at the cable industry. Stan Caterbone had his
patent research center around the PSDMS system, the Power Station Digital Movie System.
And that was in 1987, some seven years before SONY delivered his dreams. Later Stan Caterbone would also accurately predict that the 90s would become the Information Age be25
January January
Sunday
22, 201722, 2017
Page
Page1911
909 of
of1299
2301
cause of the direct contributions and advancements of digital technologies, which is directly
responsible for the development of the INTERNET.
26
January January
Sunday
22, 201722, 2017
Page
Page1912
910 of
of1299
2301
AFFIDAVIT of TARGETED INDIVIDUAL

I, Stanley J. Caterbone, Targeted Individual or TI, residing at: 1250 Fremont
Street, Lancaster, Pennsylvania, 17603, do hereby state that I am at least 18 years of
age, that I am a citizen or a legal resident of the United States of America, that I am of
sound mind, and that I am the person whose signature follows on this Affidavit. The purpose
of this document is (1) to advise Congress as well as state and local officials of organized
stalking and electronic and mind manipulation torture being committed against me and (2) to
request a state, local, or Congressional investigation and hearing on the use of remotely-op erated directed energy attacks and mind control technologies on Americans in this country.
Our Government is responsible for protecting its citizens from elements that
covertly harass, torment, murder, and cause victims to commit suicide through organized stalking and remote electronic torture. Yet, unbiased research indicates that
certain elements of Government either engage in these activities or protect those who perform them. I seek the complete dismantling of any officially-sanctioned covert Government
torture programs, the passage of legislation specifically outlawing that high-tech torture, and
the full prosecution of any person, regardless of his rank or position, who has violated my
civil rights and my most basic human rights. The assaults on my mind and body have been
occurring for 24 year(s) and include, but are not limited to the following victimization's:
1.Blanketing my dwelling and surroundings with electromagnetic energy. Bombarding my body with debilitating electronic and mind manipulation effects. Directed
Energy Weapons Causing Severe Pain to Body and Brain. Began in at least 2005 and
still continuing, with complaints to Freedom From Covert Harassment and Surveillance,
FFCHS in 2009, and in cited in various state and federal court cases over the past several
years.
Attacks causing severe artificial pain most likely from Directed Energy Devices syn chronized with telepathic harassment and organized stalking and harassment have been
logged and reported to law enforcement and medical professionals since 2008. Prior to 2008
the attacks were experienced and reported to medical professionals but the sources were not
known. Also reported attacks of pain to a family physician, emergency room personnel and
psychiatrists.
2.Invading my thoughts via remote sensing technologies. Was sent an autonomous
email in 1998 introducing the term remote viewing. Various technologies and tactics are being used to create emotional signatures that induce various emotional states; a systematic
complete hacking of my mind.
3.Making me mentally hear others' voices through the microwave hearing effect.
Synthetic and/or Mental Telepathy. First started to experience telepathy/synthetic telepathy in 2005 with full-time 24/7 connection during the same time to present. When fulltime telepathy started a male conducted interrogations lasting several hours at a time concerning a wealth of subjects including ISC/CIA Knowledge. Cannot disconnect from continuous conversations at all times with one female person. The handlers know everything I know
and experience in real time. During 2006 and 2007 have been telepathic with some 10 or
more persons, both male and female for short durations. Can recall most conversations and
subject matter with identities of who they said they were. Interrogation type harassment is
still being used telepathically to harass and for some sleep deprivation. Made first complaints
to DARPA, the FBI, and U.S. Senator Arlen Specter in 2007. Some conversations by the persons that are telepathic with me elude to some program similar to the DARPA datalog pro27
January January
Sunday
22, 201722, 2017
Page
Page1913
911 of
of1299
2301
gram where they record your entire life. Everything that you try to do on a daily basis is subject matter for conversation and harassment. Interference with thought, harassment, and interrogation is used often times with electromagnetic weapon attacks to the brain or body.
4.Depriving me of sleep due to neurological intervention. Mostly Experienced Sleep
Deprivation Techniques during periods of time in 2008 to 2010. Mostly with attacks of pain
from Directed Energy Weapons to back, neck, head (brain); and heart on a few occasions;
and with harassment from telepathy.
5.Introducing poisonous gas and radiation toxins into my home.
First experienced
toxic gases (Chloroform?) in heavy doses in 2006-2007. Made complaints to the Lancaster
City Police Department and the Southern Regional Police. Experienced attacks that would
cause dizziness at home, in automobile and in public. Was informed it was being released
through a distribution system the size of fishing line. To counter attacks used cotton in nostrils and gas mask. In 2009 experienced attacks of what is said to be sleeping gas, when at tacked could not open eyes. Took Pictures during some attacks.
6.Having me stalked en masse on foot and in vehicles. vandalizing my home and/or
car. Gang Stalking or Organized Stalking began in 1987 and continues today. It includes
strangers using gestures such as finger under eye; various forms of harassment; and public
mobbing. Complaints have been filed in 1987; 1992;1998 and 2005 to 2010. Complaints
were made to various public officials and local, state, and federal agencies as mental duress.
The terms organized stalking, gang stalking, targeted individual, etc., was not learned until a
few years ago. The organized stalking and harassment followed in several states, some while
traveling from Lancaster, Pennsylvania to California. Tracking technologies may have been
used and most likely are still being used. Police were involved in most places.
7.Tapping (Bugging) my phones. Complaints of phone tapping/tampering were made to
New Jersey Bell in 1987 with a service call to Stone Harbor, New Jersey to check lines and
phones. The same was done by a Bell Atlantic repairman in Conestoga, Pennsylvania in
1998. In 2004 a complaint with a report number was filed with the Pennsylvania Attorney
General Office in Pittsburgh, Pennsylvania (Agent Amy Zelnick) regarding interference with
phone calls and impersonations by perps intercepting and rerouting calls. Computer Hacking
complaints were filed to local authorities in the County of Lancaster and the Cyber Crime unit
of the Federal Bureau of Investigation in 2005 to 2010.
8.Blacklisting me in the labor market. Filed complains of employment discrimination with
the Pennsylvania Attorney General in 2006 and the Lancaster County Human Relations Commission in 2008.
9.Workplace mobbing. Experienced in 1987 at Financial Management Group, Ltd., American
Helix of High Industries in 1991 and Pflumm Contractors, Inc., in 1997/1998. Filed com plaints and logs as mental duress and harassment. Was forced out of all 3 organizations as a
result of the mobbing and harassment.
10.Public Mobbing. Public type mobbing and organized stalking and harassment was perpetrated heavily in the years 2005 to 2010 in the following places: The Lancaster County
Courthouse, The Lancaster County Public Library, the Pennsylvania Career Link, and the
Millersville University Library and University Offices. I was given suspicious and illegal No
Trespass Notices in some 18 public places in Lancaster County in the years 2005 to 2009
without just cause. I was complaining of stalking and harassing in most all of those public
places. The Lancaster County Public Library and the Millersville University took away my access to a computer after my personal computers were vandalized and/or hacked inoperable.
28
January January
Sunday
22, 201722, 2017
Page
Page1914
912 of
of1299
2301
Fulton Bank took away my safe deposit box. Others included my church of worship, various
bars and restaurants and one attorneys office. Complaints have been filed regarding the
same in courts and with various authorities.
11.Attempted Murder. Experienced with an attempt of vehicular homicide in 1991 after National News Media reported ISC/CIA-NSA connection of Arms to Irag. The incident involved
a vehicle changing lanes and direction and heading directly toward me in the wrong direction
running me off the road, narrowly missing a tree. I Filed the incident in federal courts and
used as a motion to seal federal case no. 05-2288 in 2005 in the United States District Court
for the Eastern District of Pennsylvania.
12.Pet Killing. Cat was killed in 2005 with complaints to the Lancaster County Humane Shelter and the Southern Regional Police Department.
13.Illegal Entries of Home/Properties. First in 1987 in Stone Harbor, New Jersey, then
again in 1991; 1997-1998; and most serious in 2005 to 2010. Filed Police Reports and insurance claims, most with the Southern Regional Police Department of Conestoga,
Pennsylvania , State Farm and Harleysville Insurance Companies.
14.Illegal Repossessions. Airplane in 1987 containing legal and business files. Home/Property and Contents in 2006 also containing legal and business files and documents.
15.Physical Assaults. One attack and filed complaint with police report in Los Osos California
in 2005 and one in the City of Lancaster. Police reports were filed and obtained for both.
16.False Arrests. Experienced 7 in 1987 and more than 20 in 2005 and 2006 in the Com monwealth of Pennsylvania Lancaster County Court of Common Pleas. The false arrests were
charges that were all dismissed prior to court hearings.
17.False Imprisonments. Spent 7 to 10 days in Lancaster County Prison in 1987 with all
charges dismissed and again for some 60 days in 2006 with all charges dismissed. The 60
Days of imprisonment of 2006 was triggered with a false report of missing a bail supervision
meeting, which was confirmed to be false in court; however bail was maliciously and purposefully reinstated as secured instead of unsecured. The appropriate appeal was filed which
secured my release after some 60 days of false imprisonment. There were no charges that
resulted in any convictions.
18.Psychiatric Abuses with False Suicide Allegations from Perpetrators/Stalkers. One
in 1987 resulting in a forced hospitalization for several hours by police in Stone Harbor, New
Jersey. And one again in February of 2005 resulting in police restraining me in my home and
abusing me.
This one was a fraudulent and phony email sent to police by a perp. The
Southern Regional Police had to vacate after the email was proven to be a fraud.
19.Vandalism to Property. First in 1987 in Stone Harbor, New Jersey, then again in 1991;
1997-1998; and most serious in 2005 to 2010. Filed Police Reports and insurance claims,
most with the Southern Regional Police Department of Conestoga, Pennsylvania and Harleysville Insurance Company. 3 computers have been rendered inoperable since 2005 along with
various electronics equipment; dvd recorders; printers; household items; appliances; etc.,
Most insurance claims have been paid. In the past years a wave of purchased items, online
and in stores, were received broken or the wrong item and all had to be returned. Some included items to secure my property, and others included computer related items, others were
household and clothing items.
29
January January
Sunday
22, 201722, 2017
Page
Page1915
913 of
of1299
2301
20.Gas Lighting. The illegal entering of home and causing psychological duress by moving
items and or hiding items. First reported in 1998 to the Conestoga Police and continued to
present. Clothing was also manipulated and altered. The term gas lighting was only
learned in 2010, although it was reported to police as harassment by neighbors of friends.
The daily draining of my hot tub was also used as a psychological warfare tactic and used to
run up utility bills. Numerous complaints were made to police in 2008 to 2010.
21.Thefts of Property. Not Yet Completed.
22.Vandalism to Car/Truck. Since 2005 have experienced years of gas siphoning, battery
outages, letting air out of tires, and wetting of inside of floor mats as psychological warfare
tactics by perps and stalkers. Made numerous complaints the Lancaster City Police Department.
23.Toxic Chemical Causing Running Nose. Experienced on regular basis in 2009 when in
public places. Was not in conjunction with cold/flu symptoms. Research states it is a tactic
used in organized stalking.
24.Computer Hacking. Computer Hacking complaints were filed to local authorities in the
County of Lancaster and the Cyber Crime unit of the Federal Bureau of Investigation in 2005
to 2010. Numerous complaint numbers have been secured. Complaints of cell phone hack ing was also reported in 2010. Websites and blogs were regularly hacked and sometimes
taken off-line. Electronic calenders, court documents, and financial records were often hacked
causing many problems of the years, including having to withdraw civil complaints.
25.Cyber Stalking. Most in 2005 to 2010. Complaints to Microsoft legal counsel, Yahoo
Message Board, and the FBI Cyber Crime Unit.
26.Interference/Delay/Theft of U.S. Mails. First reported to U.S. Postmaster of mail tampering and illegal changing of address in 1987. In 2008 to 2009 have made several more
complaints to the U.S. Postmaster Inspector General who claim to have begun investigations.
Some caused missed court hearings and other missed appointments and or meetings.
27.Electromagnetic Weapons Causing Severe Muscle Spasms/Cramps. First experienced in 2006 to present. One experience in 2006 was while I was in my hot tub and the
pain and cramp was so severe in my left calf muscle (you automatically bend over to rub it
out, which placed my head underwater) I had to crawl out of the hot tub before almost
drowning.
28.Electromagnetic Weapons Causing Sexual Stimulation. First experienced in 2005.
29.Forced Hospitalizations. Forced Hospitalizations in 1987 (2) one for 6 hours and one for
5 days; 2006 one for 3 days; 2009 one for several hours while in intensive care for emer gency surgery; and 2010 one for 8 days. Filed complaints to Citizens Commission for Human
Rights in 1991 and 2008.
30.Manipulation and Theft of Documents. Numerous thefts and manipulation of all legal
and business documents both in paper and in electronic format have occurred since 1987.
Microfiche/Microfilming began in 1987 and other measures to secure documents have been
ongoing to present. Numerous complaints have been filed with law enforcement since 1987.
30
January January
Sunday
22, 201722, 2017
Page
Page1916
914 of
of1299
2301
Statement
I have been a Targeted Individual, TI, and Victim since 1987. In 1987 I blew the whistle
(public Allegations and Complaints to State and Federal Authorities of Fraud during merger
negotiations with British Defense Contractor Ferranti International) on an international defense contractor named International Signal & Control, or ISC, who was selling arms
(Everything from Telemetry Systems to Cluster Bombs) to Iraq via South Africa and was convicted of a $1 Billion dollar Fraud in 1992 by the United States Attorney and several other
federal agencies.
See ABC/News 20/20 and Nightline in 1991. They were founded and
headquartered in my hometown of Lancaster, Pennsylvania. I was a shareholder and was solicited by a top ISC Executives (Convicted as a Mastermind of the Billion Dollar Fraud) to help
finance some of their operations through an affiliate called United Chem Con.
ISC was a De-
partment of Defense (DOD) Contractor and a partner with United States Intelligence Agencies
since it's beginnings in the early 1970's. One of it's first contracts was Project X with the National Security Agency or NSA of Ft. Meade, Maryland. Former Secretary of the Navy, Bobby
Ray Inman was on the Board of Directors of ISC and was also on the Board of Directors of
Science Applications International Corporation, or SAIC. SAIC was a huge defense contractor
that was the recipient of the Defense Intelligence Agency, or DIA, program on Remote Viewing, which SAIC named Project Stargate. It was reported that Bobby Ray Inman declined the
nomination for Secretary of Defense under the first Clinton Administration because of the ISC
and Trecor scandals.
In the early 1990's I was a subcontractor on a project for the Defense
Advanced Research Project Agency, or DARPA, with the National Institute of Standards and
Technology, or NIST called TIMIT.
The project developed speech corpora for the develop -
ment of computer based speech recognition systems. I was also involved in the bidding of
other Department of Defense contracts dealing with information technologies. In 1998 I was
stalked and approached by an employee of the National Security Agency, or NSA in York,
Pennsylvania who said my problems were not with the NSA, but the good ole boys.
In
2005 I was detained by 2 Defense Intelligence Agency, or DIA officers in a museum on a mil itary base in Austin, Texas and was questioned and interviewed regarding my civil actions
filed in federal court for several hours.
I was released and told to stay off of all military
bases. My brother, a Family Physician in Austin Texas had to verify my travel plans and the
fact that I was staying with him prior to my release.
My father alleged he was part of U.S. Navy experiments in the 1940's and experienced
synthetic telepathy in the 1970's, 1980's and 1990's as outlined in memos and documents he
had authored; and from my personal conversations with him prior to his death. Ms. Amy
31
January January
Sunday
22, 201722, 2017
Page
Page1917
915 of
of1299
2301
Fuchs of the Disclosure Project confirmed that he was most likely given an ET experience via
synthetic telepathy. He died in 2001 in New York City of cancer. My brother was in the U.S.
Air Force in the late 1960's and I allege was a victim of the LSD experiments relating to
MKULTRA in the late 1960's and a victim of murder (Suspicious Suicide with tainted medical
reports) in Santa Barbara California in 1984; Notarized Complaints were filed to the California Attorney General in 1991. He made a declaration type statement prior to his death that
he got bad LSD while in the U.S. Air Force.
Organized stalking and harassment began in 1987 following the public allegations of
fraud within ISC. As far back as the late 1980's I thought that my mind was being read, or
"remotely viewed". During the times that legal Counsel and attorneys were solicited in 1987,
1991, and 1997 Organized Stalking and Harassment and other forms of attacks experienced
by Targeted Individuals were severely increased. In 2005 the U.S. sponsored mind control
turned into an all-out assault of mental telepathy; synthetic telepathy; and pain and torture
through the use of directed energy devices and/or electromagnetic weapons.
This assault
was no coincidence in that it began simultaneously with the filing of the federal action in U.S.
District Court, of CATERBONE v. Lancaster County Prison, et. al., or 05-cv-2288.
This targeting has ruined every aspect of my life.
32
January January
Sunday
22, 201722, 2017
Page
Page1918
916 of
of1299
2301
Some Perspectives
The calculated and technological entry into another persons mind is an act of monumental
barbarism which obliterates perhaps with the twiddling of a dial the history and civilization
of mans mental development. It is more than an abuse of human rights, it is the destruction
of meaning. For anyone who is forced into the hell of living with an unseen mental rapist, the
effort to stay sane is beyond the scope of tolerable endurance. The imaginative capacity of
the ordinary mind cannot encompass the horror of it. We have attempted to come to terms
with the experiments of the Nazis in concentration camps. We now have the prospect of sys tematic control authorized by men who issue instructions through satellite communications
for the destruction of societies while they are driving new Jaguars and Mercedes, and going
to the opera.
"On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mind Invasive Technology"by Carole Smith Global Research, October 18, 2007; Journal of Psycho-Social Studies, 2003.
People have no comprehension of how lethal only one aspect (aside from the obvious of
driving the victim completely insane) of telepathy technology can be in disrupting and ruining
an individual's life through the sabotaging of his/her daily activities. Everything an individual
does begins with a momentary thought. From the split second that thought is learned by the
person on the other end (telepathically) -
the individual's right to privacy is not the real
threat or loss. The real lethal weapon is the advantage in disrupting or preventing the individual from accomplishing whatever he/she is going to do before they actually do it. With a
simple cell phone call or instant message, the Advanced Team is in place to subvert; sabotage; manipulate; propagandize; smear; disrupt; or even prevent the task or activity from being accomplished in any successful manner. The perps are skilled at creating scenarios that
are covertly arranged to simulate everyday occurrences to make the victim at fault for the
loss or failure. Imagine the consequences when these activities have legal and financial implications.
With telepathy technology the need for tracking and surveillance technology is
greatly diminished and may even become obsolete. This is not merely Mind Invasive Technology, as Carole Smith so eloquently wrote this is LIFE Invasive Technology. Say Goodbye to any true sense of capitalism and free enterprise in the not to distant future unless of
course someone stops these illegal and disastrous technology transfers and leaks. Stan J.
Caterbone
33
January January
Sunday
22, 201722, 2017
Page
Page1919
917 of
of1299
2301
Organized or Gang Stalking

A system of organized psychological terror tactics used against a person who has become an
enemy of an individual or a government. Subtle but effective techniques of stalking by multiple individuals and psychological intimidation and manipulation are used to slowly but surely
drive the target to make complaints to authorities who will see the complaints as bogus because of the methods used against the target. As a result, the target gets labeled as mentally
ill.
There are as many stalking tactics as there are targets as the multistalkers will tailor the
stalking to the individuals habits and individual personality. Some common examples or organized stalking are: following the target on foot, by car and public transportation, crowding
the target's space in a public place, murmuring insults under the breath so only the target
can hear, sitting in the car outside the target's residence, starting "fights" in public with the
target, doing "skits" on the street which involves information only the target should know but
has been found out via surveillance of the target, stealing and vandalism of the target's possessions.
Organized Stalking Website
Organized Stalking is a form of terrorism used against an individual in a malicious attempt
to reduce the quality of a persons life so they will: have a nervous break-down, become in carcerated, institutionalized, experience constant mental, emotional, or physical pain, become homeless, and/or commit suicide. This is done using well-orchestrated accusations,
lies, rumors, bogus investigations, setups, framings, intimidation, overt or covert threats,
vandalism, thefts, sabotage, torture, humiliation, emotional terror and general harassment. It
is a ganging up by members of the community who follow an organizer and participate in a
systematic terrorizing of an individual. Mark M. Rich
34
January January
Sunday
22, 201722, 2017
Page
Page1920
918 of
of1299
2301
The acts described above violate many laws aimed at protecting Americans.
Some of these laws include but are not limited to the following:
10 USC 921, Article 121 -- Larceny and wrongful appropriation
10 USC 920A, Article 120a -- Stalking
18 2340 USC -- Torture
18 USC 241 -- Conspiracy against rights of sovereign, free, God created, spirit and soul beings
18 USC 213 -- Illegal Surreptitious entry
18 USC 242 -- Deprivation of rights under color of law
18 USC 35 -- Imparting or conveying false information
18 USC 1117 -- Conspiracy to Murder
18 USC 1111 -- Murder
18 USC 1905 -- Disclosure of information generally
42 USC 1983 -- Civil action for deprivation of rights
42 USC 1985 -- Conspiracy to interfere with civil rights
31 USC 5328 -- Whistleblower protections
18 USC 1512 -- Engaging in misleading conduct
18 USC 1503 -- Intimidating a witness/victim
18 USC 1512 -- Tampering with a witness/victim
18 USC 1513 -- Retaliation against a witness/victim
18 USC 1510 -- Obstructing a criminal investigation, conflict of interest roles in government
18 USC 1509 -- Impeding due exercise of rights by attempting to prevent, obstruct, impede
and Interfere with same
18 USC 1622 -- Subordination of perjury by procuring another to commit perjury
35
January January
Sunday
22, 201722, 2017
Page
Page1921
919 of
of1299
2301

March 14, 2010
Work-In-Progress
Community Stalking and Organized Libel/Slander Campaign Strategy Issue a few
every year to support false arrests; false imprisonment; fabricated mental illness history. In
addition to isolate by prohibiting entrance to major entertainment venues with good live music. Prohibit from defending against the lies and slander in public to a minimum. Also, destroy history of strong Christian values and church attendance on a weekly basis by keeping
away from church. The Millersville University Graduate Studies No Trespass Notice was accommodated by the denial of entitled benefits of LETA Job Training Education Course of the
Paralegal program at HACC during the same time period.

4. Lancaster Newspapers, Inc., by Steve Weaver, Manager in 2006, No Notice, Corraborated by Jack Buckwalter, Chairman and CEO and George Warner, Atty with Barley
Snyder, LLC, No Formal Notice
5. Ruby Tuesday, Manor Shopping Center, Lancaster, by Manager and Lancaster
City Police in 2006, No Formal Notice
6. Alley Kat Restaurant and Bar, Lancaster by Bartender Ms. Santinello, Brett
Stabley, and Lancaster City Police, No formal Notice in 2006
8. Marion Court Restaurant, Lancaster, by Security Personnel, corroborated by Michael Geesey, in 2008, No Formal Notice
11. Lancaster County Library and Duke Street Business Center, by Executive Director in March of 2009, by 1st Class Mail
13. Millersville University Graduate Studies and Millersville University, Millersville, by Lori Austin, Judicial Affairs, via Certified Mail in June of 2009.
15. Lucky Dog Restaurant and Bar, Lancaster, by Robert Donnelly, in January of 2010,
No Formal Notice
36
January January
Sunday
22, 201722, 2017
Page
Page1922
920 of
of1299
2301
16. Saint Mary's Catholic Church, Lancaster, by Don Spica, Usher and Lancaster City
Police Department in Feb of 2010, No Formal Notice
37
January January
Sunday
22, 201722, 2017
Page
Page1923
921 of
of1299
2301
STANLEY J. CATERBONE, PRO SE LITIGATOR

27 CRIMINAL CHARGES DISMISS/WITHDRAWN/NOT-GUILTY
1987 TO 2007
1. 09/01/1987 Cc2706 Terroristic Threats - M1 Quashed / Dismis / Demur Sus
2. 09/03/1987 Cc2902-1 Unlawful Restraint - M1 Quashed / Dismis / Demur Sus
3. 09/03/1987 Cc3304a2 Criminal Mischief - F3 Nolle Prossed / Withdrawn
4. 09/03/1987 Cc3502 Burglary - F1 Quashed / Dismis / Demur Sus
5. 09/03/1987 Cc3701al Robbery - F1 Quashed /Dismis /Demur Sus
6. 09/03/1987 Cc3921a Theft By Unlwf Taking Or Dispo F3 Nolle Pros / Withdrawn
6. 09/03/1987 Cc3933a1 Unlawful Use Of Computer - F3 Nolle Pros /Withdrawn
7. 09/03/1987 Cc3933a2 Unlawful Use Of Computer - F3 Quashed / Disnis / Demur Sus
8. 12/05/2006 1 18 5503 A2 Disorderly Conduct-Unreasonable Noise - Withdrawn
(Lower Court)
9. 12/05/2006 1 18 3926 A4 Theft Of Services-Acquisition Of Services Withdrawn
(Lower Court)
10. 12/05/2006 1 18 2709 A7 Harassment - Comm. Repeat In Another Manner With drawn (LC)
14. 01/23/2007 1 18 6501 A1 Scatter Rubbish Upon Land/Stream Etc Dismissed (Lower
Court)
18. 01/18/2007 1 75 1786 F Oper Veh W/O Req'd Financ Resp Not Guilty
19. 04/30/2007 1 18 5503 A4/ Disorder Conduct Hazardous/Physi Off Not Guilty
20. 04/30/2007 2 18 5507 A / Obstruction Highways Not Guilty
21. 04/30/2007 3/ 18 2709 A3 Harassment - Course Of Conduct W/No Legiti Purpose
Nolle Pros
22. 04/30/2007 1 75 3111 A / Disregard Traffic Control Device Not Guilty Nolle Pros
23. 05/10/2007 M2 18 5104 Resist Arrest/Other Law Enforce 08/04/2006 K4775120
24. 05/10/2007 3 M1 18 908 A Make Rep/Sell/Etc Off Weap 08/04/2006 K4775120 Nolle
Pros
26. 11/01/2007 S 75 3714 A Careless Driving 08/04/2006 Nolle Pros
27. 11/01/2007 75 3802 A1* DUI: Gen Imp/Inc of Driving Safely Nolle Pros
7 1987 CHARGES DISMISSED OUT OF 7 CHARGED
12 SOUTHERN REGIONAL POLICE CHARGES DISMISSED OR OVERTURNED ON APPEAL
38
January January
Sunday
22, 201722, 2017
Page
Page1924
922 of
of1299
2301
I hereby certify that on June 20, 2015 I have mailed by U.S. Postal Service the foregoing paper to the following :
Mr. Craig Stedman,

50 N. Duke Street
Lancaster, PA 17602
Ms. Kathleen Kane,

Ibrahim Jeremy
1700 Race St
Phone: (215) 568-1943
Lisa Michelle L
MCI - Framingham
P.O. Box 9007
Framingham, PA 01704
Date: June 20, 2015
_________/s/_______________
1250 Fremont Street
Lancaster, PA 17603
717-426-5354
scaterbone@live.com
39
January January
Sunday
22, 201722, 2017
Page
Page1925
923 of
of1299
2301
EXHIBIT
SOCIAL SECURITY DISABILITY BENEFITS AND APPLICATION VERIFICATION
40
CourtSunday
Rejects January
Lisa
Michelle
Lambert's Appeal
January
22, 2017
22, 2017
http://65.54.175.250/cgi-bin/getmsg/CourtRejectsLisaMichelleLam...
Page
Page1926
924 of
of1299
2301
Welcome to About.com
What is About.com?
I'm Charles Montaldo, your Guide to Crime / Punishment. If this MSN search
is not what you were looking for, you may want to see our other popular
topics, such as Current Cases, Historical Crimes, or Death Penalty.
Related Topics
Issues / Controver...
Juvenile Crime
Law Enforcement
Missing Kids/Adult...
FREE Crime / Punishment Newsletter Enter email address

Crime / Punishment

Crime/Punishment Blog
Join the Crime & Punishment Discussion | Main | Michael Jackson Taken to Hospital
June 03, 2005

The U.S. Supreme Court has rejected the appeal of Lisa Michelle Lambert, who was convicted in 1991 of the stabbing of
a teenage rival in a case that became a USA Network TV movie, "The Stalking of Laurie Show."
The high court refused to hear the case, thereby upholding an earlier appeals court ruling that said that "Lambert's trial
was fair, amply supported and not infected by material error or injustice."
The court ruling apparently ends a long legal battle by Lambert to reverse her conviction. She had previously been freed
from prison in 1997 when a federal district judge ruled that Lambert was "actually innocent" and called the prosecutor's
behavior during her trial "the worst case of prosecutorial misconduct in English-speaking experience."
An appeals court later overturned the judge's ruling and she was returned to prison. She is serving a life sentence in
Clinton, N.J. Also convicted in the case were Lambert's boyfriend, Lawrence Yunkin, and friend Tabitha F. Buck. Yunkin
pleaded guilty to third-degree murder and was released to a halfway house in January pending his release. Buck is
serving a life sentence.
See Also:
Court Rejects Appeal in Stabbing Case
Earlier Article:
Court Upholds Lisa Michelle Lambert's Conviction
Topic Index | Email to a Friend | Print this Page

Our Story | Be a Guide | Advertising Info | Work at About | Site Map | Icons | Help
User Agreement | Ethics Policy | Patent Info. | Privacy Policy | Kids' Privacy Policy
2006 About, Inc., A part of The New York Times Company. All rights reserved.
1 of 1
4/26/2006 7:50 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1927
925 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Printable Version of Topic

Click here to view this topic in its original format
TalkBack _ News _ WHY ARE LANCASTER MURDERS NOT PUBLICIZED?

Posted by: outoftowner Aug 4 2004, 02:30 PM
I am always a little amazed as to why some crimes get intense national coverage and other strikingly similar crimes go largely
unreported. It seems to me that the tragic murder of Cristina Colon, apparently at the hands of the father of her child, and the
disappearance of Cortney Fry under suspicious circumstances are being inexplicably underreported, both locally and nationally.
There would appear to be no difference in severity or significance of these two cases from the Scott and Laci Peterson case or the
Lori Hacking murder. Why is this so? Is it an intentional cover up, the social status of the victims, failure of the media to do its job,
or some other reason. I am also, while we are at it, curious as to the total absence of news coverage on Jonathan Luna's death in
Ephrata now nearly a year ago.
Posted by: Daisy Lee Myers Aug 4 2004, 03:33 PM
WRITE TO THE ASSOCIATED PRESS FOR THE PA area and ask them.
their office is in PHILLY.
info@ap.org
they pick up the regional news for most major newspapers.
Posted by: Hope Aug 4 2004, 04:00 PM
Maybe we should be thankful that these two incidents are not being publicized nationally. This way the police can do their jobs in
peace and not get harassed by the media and have every little thing analyzed to death.
Posted by: Mixxster Aug 4 2004, 04:39 PM
As tragic as the Laci Peterson and Lori Hacking cases are, they really should not be generating the obscene amount of coverage
they are. There are all kinds of worthy subjects that get short end of the media stick because they're not big rating generators.
Women go missing every day, pregnant women go missing, kids get abducted. The media frenzy in these cases, usually when the
victims are attractive and white, is way overblown.
Posted by: Hope Aug 5 2004, 08:04 AM
1 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1928
of
of1299
2301
I know this is a little off topic but I heard a statistic the other night that the number one cause of death among pregnant women is
homicide. Isn't that sad?
Posted by: WGM1171 Aug 8 2004, 09:11 PM
OOT'er,
If those two cases were published nationally, then no one would want to come to the convention center!
In reality, there are many, many murders each year in this country with similar MO's. It's a sad state of affairs when these cases
don't generate much interest, but the fact of the matter is that a homicide just doesn't carry the same 'sting' that it once did. Maybe
more people should watch "Bowling for Columbine"...
The saddest story of homicides I read was in today's Sunday paper. Eleven children died at the hands of savage beasts in the last
year. That's just plain out pathetic!
Posted by: Kate Aug 8 2004, 10:37 PM
The savage murder of the 7 month old girl was the most difficult for me to read. How could anyone do such a vile thing to a baby.
Posted by: CommTech Aug 9 2004, 09:52 AM

Well read yesterday's paper "outoftower". You got your wish... Happy?
Posted by: RU4real? Aug 10 2004, 08:56 AM
With a 24/7 news cycle thanks to the cable networks anything and everything gets reported. Do you really think we would know
anything about Laci Peterson if the news were limited to the traditional half hour or hour nightly news broadcasts?
Posted by: outoftowner Aug 10 2004, 02:47 PM
Replying to : "Well read yesterday's paper "outoftower". You got your wish... Happy?"
That was certainly not my "wish," and hardly is on target, nor appropriate,
and is a particularly distasteful comment.
My point, which I had thought was clearly stated, was the curious fact that some murders (and other crimes) generate national
attention and others do not. It is obviously sad and tragic that Lancaster's murder and suicide rates are skyrocketing, but my
2 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1929
of
of1299
2301
question was more general, and more directed to the nature of journalism and its reflection of our society and its values. Hundreds
of children go missing each year; Elizabeth Smart is on the national nightly news. Hundreds of young husbands/boyfriends kill their
wives/girlfriends; Laci Peterson and Lori Hacking are plastered across the covers of half the nation's magazines. Yet the murders
and disappearances of Cristina and Cortney receive scant attention outside of Lancaster County. I was trying to elicit reasoned and
intelligent responses as to why people believe that this was so.
I appreciate the thoughts of Mixxster, Kate, WGM1171, and RU4real on this topic, and sympathize with Hope's thoughts.
Posted by: SusQRiverRat Aug 11 2004, 07:18 PM
I think it's a case of "The squeaky wheel gets the grease"
In both the Hacking and Peterson cases the families were on local news pleading for the safe return of their loved ones. Not just
once, but several times during the ordeal. The story was picked up by the cable news channels and away they went.
All it takes is getting spotted by the producers at one of the cable news networks, and the non-stop, round-the-clock coverage
begins. The AP puts it out there, and it is the individual publications that make the decision wether or not to run a particular story.
But get the attention of the cable stations and BAM, it's worldwide. "This is CNN. All Laci, all of the time!"
I have lived in this area all my life. This area has always had a reputation for being low key and largely conservative (not meant in
a political context, so no flames please). We just need to get more vocal about the issue and we will attract outside attention. Once
you garner outside attention, local media outlets have no choice but to follow suit.
That said, Cortney Frye's family and friends have done a superb job of getting the word out. I pray that their hard work gets results
and they get the answers they so desprately seek.
Posted by: outoftowner Aug 26 2004, 02:57 AM
and perhaps some greater publicity on Cortney Fry's disappearance would help find her, and the truth...rather than have her fate
remain among the unknown and soon forgotten, at least by police...
Posted by: outoftowner Sep 30 2004, 01:47 PM
any word on Cortney Fry?
Posted by: lancasterlover Oct 3 2004, 09:55 PM
QUOTE(RU4real? @ Aug 10 2004, 07:56 AM)
With a 24/7 news cycle thanks to the cable networks anything and everything gets reported. Do you really think we would know
anything about Laci Peterson if the news were limited to the traditional half hour or hour nightly news broadcasts?
RU4Real....."Everything gets reported?"..... You didn't really say that did you?
3 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1930
of
of1299
2301
Unfortunately, I think you did. There are so many unreported, missing women, even dead women, it's freakin epidemic.
I'm a freelance writer, specializing in female homicides. As for Lancaster, it's the morbid underbelly of a county in total control of what
gets publicized,if there is no police report, there isn't even a dead body, at that point. Do you really think the reporters at LNP get all
the info from the cops? Those people are told what to write about.....even with the selective info the cops decide to give them!
Basically, the cops in Lancaster, run the newspapers....all three of them! Unless it's an article about rake repair, or the recipe section.
There is no "investigative" reporting!
Do you think it's a coincedence that the new multi-million dollar police station is right next to the 3-paper news monopoly? Do you
think all cities work that way?
Sorry, pal, but I know more about Lancaster for reasons I can't even go into here, your post just cried out for a response.
Your world is indeed small if you think "everything" gets reported. Good Grief!
You even said, "anything and everything'.....what in the hell are you talking about?
The cable networks, my friend, are all owned by about 4 major corporations now.
Get a clue. There's so much we don't know about, it's mind-boggling. The reporters at the LNP know that too. They need the job. They
have families to support. And they are selected very very carefully.
Lancaster wants those tourism dollars. They don't like bad publicity. The most famous they got , they hadn't planned on. Lisa Lambert
and the Amish drug bust, back in 1998....It was brief. Lambert's case only became famous when a Federal Judge ripped the lid off the
way they handle investigations there. Cortney Fry?
Find out who here husband/boyfriend was, if he hasn't just left town already. It's just too easy to get away with murder these days.
Nobody wants to get involved. Being a witness can get you killed. And it's just going to get worse.
If, as you say, anything and everything gets reported, why does one need to come to this media website to learn about Mary Ann
Bagenstose, Courtney Fry, Brenda Heist, Christy Mirack, .....you have no idea how many others there are. Lancaster is so full of these
secrets, it's truly frightening. Laci Peterson's case had elements like "Christmas Eve disappearance", "beautiful 8 months pregnant
wife', "husband gone "fishing" on the day of her disappearance"..... What needs to be done is this: All of Lancaster's missing women
need to brought together, like the location in Canada, where 30 or more women were found on one guy's pigfarm; they were all
hookers, so the cops didn't sweat it. Disposable women. Women, oftimes are considered "disposable" in Lancaster as well. Dateline did
an hour-long show on the Canadian women.........2 years ago. None of those women had ever been heard about before then. There's
a whole world of murder going on out there that never gets reported.
You need to understand that. Big time.
Posted by: Kate Oct 3 2004, 11:34 PM
QUOTE
4 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1931
of
of1299
2301
RU has been banned. You're almost two months late for this post.
I'm a freelance writer, specializing in female homicides.
Great - go audition for Law and Order SVU.
QUOTE
As for Lancaster, it's the morbid underbelly of a county in total control of what gets publicized,if there is no police report, there isn't
even a dead body, at that point. Do you really think the reporters at LNP get all the info from the cops? Those people are told what
to write about.....even with the selective info the cops decide to give them! Basically, the cops in Lancaster, run the
newspapers....all three of them! Unless it's an article about rake repair, or the recipe section. There is no "investigative"
reporting!
If you're a free lance writer then why haven't you written or worked for LNP? Perhaps they would appreciate your style of
"investigative" reporting.
QUOTE
Good grief - the multimillion dollar police station is two blocks north of LNP. So much for accuracy on your part.
QUOTE
Lambert's case only became famous when a Federal Judge ripped the lid off the way they handle investigations there
.
After Lambert batted her long eyelashes and cried on the judge's shoulder. Dalzell did not follow proper judicial procedure by sending
the appeal back to local court where she would have been denied.
Looks like you need to get your facts straight.
5 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1932
of
of1299
2301
Posted by: lancasterlover Oct 4 2004, 01:52 AM
QUOTE(Kate @ Oct 3 2004, 10:34 PM)

QUOTE
QUOTE
As for Lancaster, it's the morbid underbelly of a county in total control of what gets publicized,if there is no police report, there
isn't even a dead body, at that point. Do you really think the reporters at LNP get all the info from the cops? Those people are told
what to write about.....even with the selective info the cops decide to give them! Basically, the cops in Lancaster, run the
reporting!
QUOTE
QUOTE
6 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1933
of
of1299
2301
.
After Lambert batted her long eyelashes and cried on the judge's shoulder. Dalzell did not follow proper judicial procedure by
sending the appeal back to local court where she would have been denied.
Hey Kate. well, I'm relieved that RuU4real was banned, I get very disturbed when someone thinks that all murders and missing women
get reported.....wow, talk about misinformed.
I'm well aware how most Lancastrians feel about Lisa Lambert. As a journalist, I was there for the Federal Hearing. Judge Stewart
Dalzell had no bias when it came to this hearing. For you to say that Lisa "batted her eyelashes at him" ....were you there to hear the
testimony? Were you there when virtually all the evidence was proven to be altered, destroyed, or simply not admitted in her original
trial in 1992? Evidence that clearly proved that Lawrence Yunkin killed Laurie Show? With the help of Tabitha Buck.
Yunkin's bloody sweatpants, covered in Laurie Show's blood. Size x-tra x-tra large. Lisa never wore them. Neither did she wear his
size 12 sneakers. She knew where he had thrown them though. When Det. Barley went to find them, he brought Smokey Roberts to
film the search. They found Yunkin's bloody sneakers, but edited out that portion of the tape. In Dalzell's courtroom, both versions
were played.
Yunkins earring was found at the scene, the back found in Laurie's hair, during the autopsy, then destroyed. Are you familiar with any
of this information? If you weren't at the Federal Hearing, then perhaps not. Did you actually see Lisa Lambert batting her eyelashes at
judge Dalzell? No, you did not, dear.
I was there. In the end, his decision was overturned on a technicality, Kate. Lisa had already exhausted her state appeals, so there
was no turning the case back to Lancaster, as you suggest. They invented a second P.C.R.A. hearing, because a new trial was out of
the question, so tainted, altered, and destroyed was the original evidence. I was there for that too. Robert Reed took the 5th
ammendment 59 times when he got on the stand. He had already cooperated with the F.B.I.
I could go on and on, but you need to know Kate, if you were not in that courtroom to hear and see the evidence that was never
introduced in the original trial in 1992, which proved, without a doubt, that Yunkin was the killer, along with Tabitha Buck.........it's you
who don't have your facts straight, my dear. I know how you feel about Lisa Lambert. It's very typical, you have alot of company, and
somehow you feel like it's O.K. to say Lisa batted her eyelashes at the judge, when in fact, that never happend, and you obviously
were not there.
If you bothered to read the transcripts, you might find yourself surprised. You can't read any of the transcripts from the Lancaster
trials, and subsequent P.C.R.A hearings. They aren't available. Why? They've been altered, they don't want anybody to read what
really went on, and by the way, kate, were you at the original 1992 trial? Or, are you just one of the many who decided without doing
your homework, that Lisa Lambert is the cold-blooded killer that a Federal Judge who didn't know her, just let go because she batted
her eyelashes at him?
Give me a break.
7 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1934
of
of1299
2301
QUOTE(lancasterlover @ Oct 4 2004, 12:52 AM)

QUOTE
QUOTE
As for Lancaster, it's the morbid underbelly of a county in total control of what gets publicized,if there is no police report, there
isn't even a dead body, at that point. Do you really think the reporters at LNP get all the info from the cops? Those people are
told what to write about.....even with the selective info the cops decide to give them! Basically, the cops in Lancaster, run the
reporting!
QUOTE
Do you think it's a coincedence that the new multi-million dollar police station is right next to the 3-paper news monopoly? Do
you think all cities work that way?
8 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1935
of
of1299
2301
QUOTE
.
After Lambert batted her long eyelashes and cried on the judge's shoulder. Dalzell did not follow proper judicial procedure by
sending the appeal back to local court where she would have been denied.
Hey Kate. well, I'm relieved that RuU4real was banned, I get very disturbed when someone thinks that all murders and missing
women get reported.....wow, talk about misinformed.
I'm well aware how most Lancastrians feel about Lisa Lambert. As a journalist, I was there for the Federal Hearing. Judge Stewart
Dalzell had no bias when it came to this hearing. For you to say that Lisa "batted her eyelashes at him" ....were you there to hear
the testimony? Were you there when virtually all the evidence was proven to be altered, destroyed, or simply not admitted in her
original trial in 1992? Evidence that clearly proved that Lawrence Yunkin killed Laurie Show? With the help of Tabitha Buck.
Yunkin's bloody sweatpants, covered in Laurie Show's blood. Size x-tra x-tra large. Lisa never wore them. Neither did she wear his
size 12 sneakers. She knew where he had thrown them though. When Det. Barley went to find them, he brought Smokey Roberts to
film the search. They found Yunkin's bloody sneakers, but edited out that portion of the tape. In Dalzell's courtroom, both versions
were played.
Yunkins earring was found at the scene, the back found in Laurie's hair, during the autopsy, then destroyed. Are you familiar with
any of this information? If you weren't at the Federal Hearing, then perhaps not. Did you actually see Lisa Lambert batting her
eyelashes at judge Dalzell? No, you did not, dear.
I was there. In the end, his decision was overturned on a technicality, Kate. Lisa had already exhausted her state appeals, so there
was no turning the case back to Lancaster, as you suggest. They invented a second P.C.R.A. hearing, because a new trial was out of
the question, so tainted, altered, and destroyed was the original evidence. I was there for that too. Robert Reed took the 5th
ammendment 59 times when he got on the stand. He had already cooperated with the F.B.I.
I could go on and on, but you need to know Kate, if you were not in that courtroom to hear and see the evidence that was never
introduced in the original trial in 1992, which proved, without a doubt, that Yunkin was the killer, along with Tabitha Buck.........it's
you who don't have your facts straight, my dear. I know how you feel about Lisa Lambert. It's very typical, you have alot of
company, and somehow you feel like it's O.K. to say Lisa batted her eyelashes at the judge, when in fact, that never happend, and
you obviously were not there.
If you bothered to read the transcripts, you might find yourself surprised. You can't read any of the transcripts from the Lancaster
trials, and subsequent P.C.R.A hearings. They aren't available. Why? They've been altered, they don't want anybody to read what
really went on, and by the way, kate, were you at the original 1992 trial? Or, are you just one of the many who decided without
doing your homework, that Lisa Lambert is the cold-blooded killer that a Federal Judge who didn't know her, just let go because she
9 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1936
of
of1299
2301
batted her eyelashes at him?

Give me a break.
One more thing, Kate. Do you know what a free-lance writer is? Obviously not.
A free-lance writer does not work for a 3-paper monopoly like LNP. There is no "investigative reporting" there. They do what they are
told. I don't care if the new Police Station is right next to them, or a block away, the fact of the matter is, the police are in charge of
what gets reported. LNP writes stories based on what the police provide.
Free-lance reporters, like myself, sell stories to outlets that are interested in all aspects of a crime. Reporters at LNP don't have that
option.
No free-lance reporter would ever succumb to the rules laid down by LNP Inc.
Unless they were going undercover, and that would be a great idea. You'd have to put on a real good show, however, to get a job
there, under those circumstances.
Once they found out you had EVER been a free-lance reporter, the interview would be quickly over.
Believe what you want about Lisa Lambert and Judge Dalzell. If you weren't there, or you haven't read the testimony, you have no
idea what you're talking about.
Why bother to do the research, after all, when it's so much easier to assume she was guilty, ignoring what was revealed in Federal
Court? You are not alone. Every reporter in the courtroom during those three weeks, knows what I'm talking about. It's what put that
hearing on the front page of the Los Angeles Times. A good friend of mine wrote that story. Once Lisa was released, Lancaster County
was terrified. They knew a civil suit was not far behind. Alvin B. Lewis came to the rescue. Had he not, a virtual flood of similar suits
were waiting to be revealed.
He is a powerful guy, Alvin B. He's also the head of the Lancaster County Crime Commission. That one poster, astonished, got it right
about the bankrobbers. It's one of the stories I'm working on right now. Lancaster is the playground for bank robbers......only one,
recently, was actually tracked. The crime in that county is atrocious, for it's size. I'm not the only journalist keeping track of what goes
on in Lancaster County. You commented, I noticed, how horrible it was for that baby to get abused to death? Do you think the ones
you read about are the only ones?
Keep batting your eyelashes, Kate. The truth is just too grisly, and you wouldn't believe it anyway.
Posted by: Daisy Lee Myers Oct 4 2004, 03:35 AM

HMM...
" LA TIMES"...
10 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1937
of
of1299
2301
BERNARD STEIN OR STERN
heather johnston: "is it "ALOT" OR "A LOT?"

i remember you using "ALOT" in your postings.
thanks
daisy
ps- i ain't the writer..
QUOTE(Daisy Lee Myers @ Oct 4 2004, 02:35 AM)
HMM...
" LA TIMES"...
BERNARD STEIN OR STERN
heather johnston: "is it "ALOT" OR "A LOT?"

i remember you using "ALOT" in your postings.
thanks
daisy
ps- i ain't the writer..
Daisy? is it? Alot, or a lot? I have no idea what you are getting at.... but the journalist who printed the fabulous front page article about
Lisa Lambert's well-deserved release....I suspect you were not there either.....his name is Barry Siegel. He wrote the article, it was
absolutely accurate, and it was on the front page. He last year won the Pulitzer Prize, for a story he reported on in Utah. And your
point about Alot or a lot? I have no clue.........I do know that Ms. Johnston is not a moron, by any means, she was in the courtroom
with me, and heard the testimony which resulted in Lisa's release, and you people trashing her, have zero credibility....in the outside
world. Barry Siegel gave Lisa Lambert's hearing exposure like Lancaster had never seen. I was there Daisy, were you?...I don't think
so....
His article gave Laurie Show's murder investigation new light that Lancaster certainly did not want. Have you read the article, Daisy?
Were you in the courtroom in 1997, as Heather Johnston and I were?
11 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1938
of
of1299
2301
Call her anything you want. I was there. She was there. Everybody there knew why Lisa Lambert was released.......read the
transcripts, Daisy. They are available online.....
Then talk to me about alot, or a lot? What the hell are you talking about?
I have no idea. I do know Ms. Johnston, however. Do you?
Posted by: Kasey1 Oct 4 2004, 06:59 AM

I hope that you, as a free-lance [sic] reporter, get a very good editor, because you really need one. Are you actually trained as a
journalist? And if you aren't even from Lancaster County, how do you know of all these stories of missing and murdered women
about which we never hear?
And if you did live in Lancaster County and know how things are handled by people who have no reason or interest in being
dishonest, you'd know that most of the claims of false or destroyed evidence designed to convict LML falsely are completely
impossible.
QUOTE(lancasterlover @ Oct 4 2004, 03:18 AM)
Daisy? is it? Alot, or a lot? I have no idea what you are getting at.... but the journalist who printed the fabulous front page article
about Lisa Lambert's well-deserved release....I suspect you were not there either.....his name is Barry Siegel. He wrote the article, it
was absolutely accurate, and it was on the front page. He last year won the Pulitzer Prize, for a story he reported on in Utah. And
your point about Alot or a lot? I have no clue.........I do know that Ms. Johnston is not a moron, by any means, she was in the
courtroom with me, and heard the testimony which resulted in Lisa's release, and you people trashing her, have zero credibility....in
the outside world. Barry Siegel gave Lisa Lambert's hearing exposure like Lancaster had never seen. I was there Daisy, were
you?...I don't think so....
His article gave Laurie Show's murder investigation new light that Lancaster certainly did not want. Have you read the article,
Daisy? Were you in the courtroom in 1997, as Heather Johnston and I were?
Call her anything you want. I was there. She was there. Everybody there knew why Lisa Lambert was released.......read the
transcripts, Daisy. They are available online.....
Then talk to me about alot, or a lot? What the hell are you talking about?
I have no idea. I do know Ms. Johnston, however. Do you?
Welcome back to LOL TalkBack, Heather Johnston aka lancasterlover, aka imbackagain. Are you going to behave this time
12 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1939
of
of1299
2301
around? Of course not. Life on LOL has been somewhat quiet lately but I'm sure you'll spice it up again.
It wasn't too difficult to see your "smokescreen" once I had time to read your latest posts - all centered around murdered or missing
women or poking fun at Lancaster. Some things never change.
Heard you were in Lancaster this past July filming some sore of documentary at the courthouse. Is the documentary finished yet?
Posted by: Kasey1 Oct 4 2004, 08:06 PM

Looks like Princess Ellipses who has the LML worship site and "lancasterlover" have very similar grammatical quirks sometimes. In
other posts, it looks like someone else is writing.
QUOTE(Kasey1 @ Oct 4 2004, 07:06 PM)
Looks like Princess Ellipses who has the LML worship site and "lancasterlover" have very similar grammatical quirks sometimes. In
other posts, it looks like someone else is writing.
Kasey - take notice of the time of lancasterlover's posts - all at early am hours for the east coast. Ms. Johnston lives in California. Ms.
Johnston also claimed to be a freelance writer and loved to mock Lancaster law enforcement as well as LNP.

I just love people who assume Lancaster County is like something out of that movie "The Village" and that we need some
semi-literate conspiracy theorist from somewhere enlighted, like California, to lead us into the 21st century.
Wow, did you know there are some intelligent, educated people who live in Lancaster by choice? Shocking, isn't it! Some were even
born here, saw the rest of the world, and decided to stay here anyway!

13 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1940
of
of1299
2301
Looks like Princess Ellipses who has the LML worship site and "lancasterlover" have very similar grammatical quirks sometimes.
In other posts, it looks like someone else is writing.
Kasey - take notice of the time of lancasterlover's posts - all at early am hours for the east coast. Ms. Johnston lives in California.
Ms. Johnston also claimed to be a freelance writer and loved to mock Lancaster law enforcement as well as LNP.
Oh , Kate, you poor thing, every time I look at your little batgirl mask, I get a little sad for you. Do you really think that the only
person on the west coast who believes Lisa Lambert is innocent is Heather Johnston?
Get a clue, for your own sake. The Lisa Lambert case got national attention, batgirl. I realize you have alot of clout here on the LNP
talkback scene.
But you've never read the transcripts from the Federal Hearing, that's painfully obvious. I am not Heather Johnston, so put your
Brenda Starr outfit back in the closet, dear.
I read your posts and frankly, you and Big Bird, are as shallow as a wading pool.
Although I don't know "astonished", I was truly astonished by your remarks to her. She's been raped by her father, and yet you tell
her, "It's just a bunch of dirty laundry", etc. etc. Kate, your life obviously has been everything wonderful and not tainted by
experiences that others have found a little disturbing.
No brainer there. You are so ignorant about what happened to Lisa Lambert, as is your buddy, Big Bird,(who cares what his real name
is..)...I suggest you and he read the unedited transcripts from the Federal Hearing, which ended in Dalzell setting Lisa free..... the fact
that you both liken yourselves to be Nancy Drew becasue both Heather and I are not only friends, but were next to each other when
the

Looks like Princess Ellipses who has the LML worship site and "lancasterlover" have very similar grammatical quirks sometimes.
In other posts, it looks like someone else is writing.
Kasey - take notice of the time of lancasterlover's posts - all at early am hours for the east coast. Ms. Johnston lives in California.
Ms. Johnston also claimed to be a freelance writer and loved to mock Lancaster law enforcement as well as LNP.
14 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1941
of
of1299
2301
Oh my God, Batgirl! You mean because my posts are at the same time as Heather's, that must mean we are the same person? LMAO.
No, really, Batgirl, there's only one person on the west coast who has read about Lisa Lambert. It has to be the dreaded Heather
Johnston, right?...Get a life, girl. Do you have any idea how many fans Lisa Lambert has? It's not an accident, Batgirl. This case gave
Lancaster exposure it never wanted. Why? Corruption, my dear, corruption for all the world to see.... I was there when they were
literally "caught in the headlights".....Barley, Solt, Savage, Kenneff, it was a freakin nightmare, and it's all on Heather's website... and
mine too...since we've become friends.....the testimony is on there.....by those you think are so innocent. Why would they lie?
Oh gosh, I don't know. I do know. It's my website, and my friend's too. She will reveal the testimony at the proper time. She's not an
idiot. She's not I'mbackagain, whatever that means. She's someone you'll never Know...because she's on the west coast.......
Heather and I are best friends. I only posted here because she told me whatwould most likely happen. She was right. You people who
haven't read the Federal Transcripts, don't care how investigations work in your town. It's safer to believe what you're told....at least
when it comes to your town, correct? Is that right?
That's right sir.
hjj
QUOTE(Kasey1 @ Oct 4 2004, 05:59 AM)
I hope that you, as a free-lance [sic] reporter, get a very good editor, because you really need one. Are you actually trained as a
journalist? And if you aren't even from Lancaster County, how do you know of all these stories of missing and murdered women
about which we never hear?
And if you did live in Lancaster County and know how things are handled by people who have no reason or interest in being
dishonest, you'd know that most of the claims of false or destroyed evidence designed to convict LML falsely are completely
impossible.
Completely impossible? Is that what you said? Good Lord.

False claims against Lisa Lambert? Is that what you said? I think it was.
Read the Federal Hearing transcripts, Einstein.
Lancaster County has secrets from here to the ends of the earth...
If you happen to be from the West Coast, it must be "Me", Heather Johnston, because, hey, we are both from the West Coast!
Kate, keep that little batgirl thing going....you are so clueless, and I am not Heather Johnston. Whatever floats your boat, honey...
She told me this would happen. She was so right..
15 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1942
of
of1299
2301
Good night.
Posted by: daddyg Oct 5 2004, 07:04 AM

It's like a bad dream that keeps coming back....
Oh my goodness, Lancasterlover. If you are not Heather, there is someone posting EXACTLY LIKE YOU--same "facts," insults, and
grammatical errors--on other criminal justice boards in the last few days and signing Heather's name. Perhaps you'd best use all
your dubious brainpower to get to the bottom of this tangled web of identity theft/impersonation intrigue. Or might this be some
kind of unfortunate MPD situation?
If you have one of your characteristic meltdowns, then I guess we will know for sure...
Posted by: eurytopic Oct 5 2004, 07:40 AM
If ignored long enough, trolls eventually go away...
I am so ignorant, and I'm sure it's because I was born and raised right here in Lancaster County. I sure had them Phi Beta Kappa
people at that thar collitch place fooled though, heh heh. Them gived me a key and a paper with my name on and everything.
Anyway, I am sure this is just because I am a stupid rube, but why, if lancasterlover isn't Heather, did she sign this post "hjj"?
blah blah
"Heather and I are best friends. I only posted here because she told me whatwould most likely happen. She was right. You people
who haven't read the Federal Transcripts, don't care how investigations work in your town. It's safer to believe what you're
told....at least when it comes to your town, correct? Is that right?
That's right sir.
hjj"
Garsh, you mean if I read the Federal Transcripts I will be smart, too? I feel just like the Scarecrow on the way to Oz. Let me at
'em.
16 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1943
of
of1299
2301
But wait. If everything Dalzell did was so jurisprudentially impeccable, remind me again why LML is back in prison.
I am too stupid to get it, I guess.
Posted by: Kate Oct 5 2004, 08:06 AM
QUOTE(eurytopic @ Oct 5 2004, 06:40 AM)
yep - annother "bannation day" on the way. Keep it up Heather, you haven't fooled anyone.
Posted by: ominousne Oct 5 2004, 10:40 AM

duplicate due to 504 internet error
Posted by: ominousne Oct 5 2004, 10:41 AM
This thread is getting ugly
I don't doubt there was corruption. I don't know a thing about Lisa Lambert except what I heard from friends since moving here.
Yes, some intelligent people are here by choice, but some of us moved for a single person, not just to live in Lancaster PA.
Lancaster is a large city with urban areas that still wants to be Mayberry USA. It's not going to happen. Mayberry is gone, not only
because of size, but because of all the corruption here. The 'good ole boy network' is alive and well and they're scratching each
other's backs just like they're supposed to. If someone is offering to take you into the 21st century, please, allow them to do so.
On the other hand, Lancaster County has some beautiful scenery, some good people, some good food and lots of activities to keep
the lovers of the outdoors complacent. Don't let the charm of Lancaster County be destroyed by the corruption of Lancaster City.
Not to slam Kasey, just a little joke on the side..
My MENSA trumps your Phi Beta Kappa
17 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1944
of
of1299
2301
Posted by: daddyg Oct 5 2004, 11:05 AM
QUOTE
If someone is offering to take you into the 21st century, please, allow them to do so.
Why?
Posted by: Quincy Oct 5 2004, 11:20 AM

Well, what do you know....
Heather Johnson has returned. Would that be to start another diatribe about the poor unfortunate Lambert, now that her pathetic
lover Yunkin have been paroled? Would it be to antagonize us Lancastrians since she has just found out about Federal Judge
Stengel?
Lancasterlover, onewhoknows, righttoknow and what ever else you chose to call yourself, you have not been forgotten. You have
actually been on my mind since Judge Stengel started his federal Judgeship this summer.
Be prepared. The moderators will not tolerate you previous behavior, Heather. None of us old timers are fooled. Using a fictitious
friend that just happened to be with you in Lancaster during the Lambert PCR hearing in 1996 and that same supposed friend just
happens to be with you in California??? Talk about a figment of an imagination.
Free Lance writer....I was under the impression that you had to be published and paid to be a free lance writer.
QUOTE(ominousne @ Oct 5 2004, 09:41 AM)
Not to slam Kasey, just a little joke on the side..

My MENSA trumps your Phi Beta Kappa
Got that, too.

And, onimousne, I'd like to add that people who are from the county originally have a problem with people like Heather Johnston who
18 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1945
of
of1299
2301
come here on a mission to save us from our benighted ways. We are not all uncultured inbreds or backwards rubes who don't know or
care about the "outside world" . The "Lancaster County cold shoulder" about which so many move-ins complain has more to do with
their attitude than the fact that people "from here" are inherently unwelcoming. Do you rush to embrace people who treat you in a
condescending fashion?
Many of my closest friends are people who are "not from here" yet have chosen to make the best of being here and bringing good
ideas from their own experience to this community. I like learning new ways of doing things, as most people do, when they are
presented in a positive way.
Posted by: Quincy Oct 5 2004, 12:14 PM

I guess I have a lot of that southern hospitality that my mother grew up with heavily ingrained in me.
I was born and raised here in Lancaster, but I hate to think that the former slogan for Pennsylvania could be so far off when
describing the area. I think Lancaster has become so oversaturated with what the locals consider tourists, that the locals forgot the
meaning of courtesy and generosity. I remember days not that long ago when the attitude in the county was dramatically different.
Kasey, you pointed out a critical point. No one likes to be looked down upon. During the late 1960's and early 1970's there was a
huge influx of people into the county. That rapid growth has not stopped since. The rapid growth and the people moving in from
other areas that are not familiar with the culture of the local community cause many to view the locals as country bumpkins. Some
might have been, but the newcomers held that perception for the masses. Hence the rapid development of Hempfield and Manheim
Townships in the 60's and 70's. Move to the 90's and you have all the peoplecomingg to the area fromPhiladelphiaa and New York
to get away from the crime and stuff. Locals that were here from the movement in the 60's and 70's were lumped into the group of
bumpkins despite the fact that they moved here from elsewhere. Ibelievee that at this point, Lancaster lost it's sense of hospitality
and good graces.
There true locals are still the same as they used to be. They are not influenced by the opinions of the newcomers to the area. It is
the pseudo-old Lancaster families that have manifested the poor relations of the area.
QUOTE(Kate @ Oct 5 2004, 07:06 AM)

QUOTE(eurytopic @ Oct 5 2004, 06:40 AM)
yep - annother "bannation day" on the way. Keep it up Heather, you haven't fooled anyone.
19 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1946
of
of1299
2301
Can you smell what the Rock has cooking?

I bet we are in for a tidal wave. It has been too long since the last vestiges of comments from the west coast. If we thought Hurricane
Ivan brought floods to this area, I can only anticipate what board flooding there will be in the days to come.
I smell a troll lurking in the darkness of the web anonymity.
Posted by: dimples Oct 5 2004, 03:16 PM

Welcome back HJJ, just when I thought things were quieting down here on ye old boards.
Well we all know how I feel about Lisa "the liar" Lambert. So I'm not going to go into another tirade about that subject.
As for Murders, etc not being run in the media, thank your lucky stars. See how Laurie Show's murder got turned around? Just
watch the USA Movie the Stalking of Laurie Show if you don't believe me. As I have said numerous times, the only ones that know
the absolute truth in Laurie's murder, are Tabitha, Lisa, Lawrence and Laurie. One out of four is dead and another two out of four
haven't told the truth in at least 13 years while the fourth has yet to tell her side of the story.
I'm waiting for the real truth, when Lisa finally gives up the chirade she is living and admits to the truth, unfortunately I don't
believe that will ever happen in my life time, and we all know it won't happen in Laurie's.
Nope, Laurie was given a raw deal by a low life scum named Lisa Michelle Lambert. Lambert's boy toy, Yunkin was a piece of work
too. I bet she is seething to know that he is out on parole while she is locked up in NJ still. Oh well, she had her nine months of
freedom and enjoyed it while it lasted. More than the chance that Laurie had at the hands of LML and her mercy. Too bad that the
"Free lance Writer" has focused so much of her attention on the "Pathetic" pathological liar Lambert. If one were a quality
investigative reporter, they would have had the contacts to speak with the inmates on the cell block that LML was housed with.
They would have had direct quotes from those women that were housed with her, not just those quotes that were solicited on the
stand as testimony in the original trial.
I fail to understand why HJJ and her cronies keep insisting on citing the Federal Habeas Corpus Hearing as proof of LML innocence.
The US Supreme Court refused to hear an appeal based on the US District Court of Appeals ruling. When the Appeals Court sent
the case back to Judge Stengel and the State system for failure to exhaust State resources, they erased the significance of the
transcripts of Dazell's trail. Essentially they no longer exist in the eyes of the LAW. The law is what matters. Not HJJ's personal
opinion. Besides, Dazell excluded witnesses and evidence for no reason other than his prejudices. His ruling was legitimately
overtured based on his misconduct. Judge Brody upheld Judge Stengel's ruling as well. And now Judge Stengel sits on the Federal
Bench. Rainville and her husband knew they had been slick talked by their client and that is why the case has failed to go
anywhere from there. Hence the reason Rainville is no longer handling this type of law and decided to go where money is in the
first place.
20 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1947
of
of1299
2301

In the meantime, untruths are being spewed on Justice Junction by Ms. Johnston.
The murder of Laurie Show occurred in 1991. Ms. Johnston is still obsessed with freeing Laurie's killer six years after the last legal
hearing.
More vomit from the peanut gallery. LML is where she needs to be. The only ones that can help her now are the US Supremes. We
all know how well they like hearing criminal cases. Factor in they already shot her case down before, she has nothing to go on at
this point. Appeals only.
HJJ can vomit type all she wants. It is not going to happen. LML is in jail, the Supreme will not be hearing her case, no time soon, if
ever. After that, her only chance would be a pardon. Yeah right.
I just picked up the New Era, and there's a front-page article about a vigil being held 10/17 for Cortney Frey.
About time.
Columbia really should have turned this case over to the State Troopers or something. They have done nothing with it. Pathetic on
the part of management of the boro PD.
Hey, just in time for the holidays, for those of you with more money than sense...
http://www.freelisalambert.com/Pages/Merchandise.html
SOME "MERCHANDISE" FROM THE FREELISALAMBERT WEBSITE.

Gee, just when I thought Ron Savage was going to be the only one to attempt to profit from the Lambert case, we have this. But,
then again, it will doubtless be the one-stop shopping place for all your gift-giving needs.
Wonder what this merchandise can be, eh? "FREE LISA" tee-shirts? Incredible shrinking sweat pants and a magical phone cord? Or
21 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1948
of
of1299
2301
perhaps a date with the dashing Dalzell to the County morgue, to sign out some bodies and return them to their crime scenes for
some zany photo ops? How about an amazing Robin Weaver action figure--"He 'roids, he rapes, he dates Cristy Mirack"? And what
little Lancaster County boy wouldn't love to pretend he is Butch Yunkin, with his very own Lisa puppet? Or perhaps some beautiful
dolls every little girl would love to have of poor, maligned Lisa Lambert ("bucket-o-eyeliner sold separately") and Tina Rainville
("doll's actual degree of dowdiness may vary from ad photo")?
But WAIT! Here's some irony you can have for free, no shipping and handling required:
In the words of HJJ/imbackagain/lancasterlover/freelisalambert website owner from this very board
(http://talkback.lancasteronline.com/index.php?showtopic=174&st=300):
"....Hazel Show lied....Yes...
And that's the most emotional and sad fact about this case.
Yes. She lied.
That's the truth.
But what's even sadder...is Hazel Show was also selling her daughter's death along with Ronald Savage.
The truth is brutal sometimes, Harv. But there it is.
What a relief to hear from you. Harv, I think you are a very smart person.
I know it's hard to accept these things. Hazel Show lied.
It's just too irrefutable and in the context of what I am about to post concerning Savage...
Both of them were cashing in on the murder of this young woman.
It makes me sick to think about it too, but it's true."
Love ya, peace out.
Posted by: pio Oct 9 2004, 12:26 PM

I want to first say this. I dont know if Ms. Lambert is guilty or not. I do know what the court ruled. I am very very familular with
this case. I have no family or friendly ties to the convicted or anyone asc. with this case. Except, I dont want to cloud the situation.
. The Lancaster City Police Dept. The East and West Lampeter Twp Police , The East Hempfield Twp Police ,The Manor Twp Police
Dept ,The Manheim Township Police Dept. Manheim Boro All have had police officers/Det working for them who where corrupt.
They lied concerning the facts of situations to suit their personal gains. Buy getting the "pinch." I am not saying the Depts are
22 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1949
of
of1299
2301
corrupt, I am saying that certain officers behavior has led to wronful arrest. As high echoleon seemed to be sincere about following
procedure. I hope that all the involved, especially on the law enforcement side are being truthful. I recall a specific incident from
one of the mentioned Twps. An Officer was hitting on a employee when she declined he was clearly upset. A week later low and
behold she got a DUI. As if that was not enough. He was told by another officer she was coming thru the twp. he waited for her on
the road that lead to her house. You got she was arrested again . For driving with out a license while DUI suspended. Ok you get
my point. Police corruption as tainted the lives of many people. I do know that when the officers involved are involved scadalous
behavior it compromises the cases of all of those they have been incontact with. Its truly a shame because Law enforcement
should require their officers to undergo the polygraph. Not the defendents. They are so sure that they are creditable , they should
force their own to use them, before any significant case. In my opinion, they give those test to prospective employees. Good. Now
give it to the employees. We need to have these things known. They have no rights to deny the polygraph as long as they are
employed by the Dept. good luck to all Involved.
Posted by: SusQRiverRat Oct 9 2004, 01:55 PM
QUOTE
I recall a specific incident from one of the mentioned Twps. An Officer was hitting on a employee when she declined he was clearly
upset. A week later low and behold she got a DUI. As if that was not enough. He was told by another officer she was coming thru the
twp. he waited for her on the road that lead to her house. You got she was arrested again . For driving with out a license while DUI
suspended. Ok you get my point.
Sorry, but whatever point you may be trying to make escapes me.
Regardless of any charge of possible corruption, if a person blows over .10 (now .08) or has the equivalent in a blood test it is unlawful
and cause for arrest.
The arrest would not be valid, nor would the DA's office file charges without either a breathalizer or blood test.
As for the driving under suspension, DUH. Break the law, pay the consequences. Common sense should dictate if someone knows
cops, and said cops know that they are under suspension, then don't freakin' drive!
Sounds more like stupidity than corruption to me.
Posted by: pio Oct 9 2004, 04:52 PM

Susq. I dont think you got the point. Indeed driving without a license and Dui are offenses. However the intial contact between
police and this person were not because of chance or even because the person was driving erratically. It was because of the young
lad having his pride hurt. And then having other police tell him when they seen her driving......on her way home from work. I just
was trying to illistrate the mentality of some officers. The boldness, cockyness, power surge they have .....And rest assured that
this is the most minor of situations. I hope you figure out what I am saying. Again we must look at situations from all angles .
sometime when something seems to be a little more investigating will show you a different picture....what did you think of the
polygraph test for the officers involved........And remember the defendents rights are still protected, they dont have to take it.....
23 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1950
of
of1299
2301
Posted by: Dallas Oct 9 2004, 06:44 PM
QUOTE(lancasterlover @ Oct 3 2004, 09:55 PM)
The most famous they got , they hadn't planned on. Lisa Lambert and the Amish drug bust, back in 1998....It was brief.
As a freelance writer, specializing in female homicides...

I suppose since you mentioned Lisa Lambert that you wrote about Laurie Show (THE VICTIM).
QUOTE
Lambert's case only became famous when a Federal Judge ripped the lid off the way they handle investigations there.
I certainly hope that you are not implying that the murderer was done wrong by the way the investigation was handle. Let's not loose
track of the real focus here the VICTIMS!
QUOTE
Sorry, pal, but I know more about Lancaster for reasons I can't even go into here, your post just cried out for a response.
You leave us in doubt of what "you" know. Why mention it if you were going to follow it up with something?
QUOTE
Lancaster wants those tourism dollars. They don't like bad publicity.
I agree. That is why they protect the Amish i.e. going after UPN, etc.

For those of you who are following discussions regarding the poster who claims to be a freelance reporter investigating the Laurie
Show case (and on and on), here is a sample of some of what is behind her opinions on the case, in a usement post regarding her
24 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1951
of
of1299
2301
interest in the Bruderhof communities:

from
http://groups.google.com/groups?q=rumspringanow+laurie&hl=en&lr=&selm=ff024fff.0207301421.464b8106%40posting.google.com&rnum=1
*********************************
Heather Johnston says: "Greetings to you all: I recently have immersed myself in order to educate myself in all things Bruderhof
that I can find. I operate a
website called freelisalambert.com available on google only that deals
with the murder of a young girl named Laurie Show. Her grandfather was
the Amish "doctor" a term I use loosely as he was an osteopath...quite
different than an M.D. for over 40 years he administered his brand of
"healthcare" exclusively to the Amish in Lancaster County,PA ... but
he held another powerful position simultaneously in this same county.
He was the exclusive County Coronor.
The body count, could there be one done..would rival the halocaust. As
you know most likely, there are no divorces within the Amish...no
outsiders even police and especially investigators even bother with
such things as murder, child abuse..(only a few rare cases that I have
been able to find)..
I live in California but I received so much e-mail when my site first
appeared back in 1998..(I didn't even own a computer..just did all the
writing and had someone else operate it (my then husband
actually)..that I decided to go to Lancaster County. The experience
changed my life.
Would anyone care to discuss the parallel between a culture like the
Amish knowingly producing deformed children because of the generations
long incest,
and a company like Rifton Enterprises that manufactures equipment to
allegedly assist these handicapped people.
My current interest also involves the hundreds of DNA geneticists and
their drug company sponsors using these horribly suffering children to
advance their personal academic careers and utilize a huge segment of
guinea pigs for their latest drug's acceptance by the FDA.
It's a pleasure for me to say that although I am not a Church going
person and no organized religion do I belong to...oddly though it may
seem, I believe in Jesus Christ. I survived a car that was
intentionally trying to kill me as I attempted to cross the street. It
was going 45 miles an hour. I was a pedestrian trying like hell to get
out of the way. I didn't. But I lived. The woman who picked me up from
25 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1952
of
of1299
2301
the street was named Tonetta Harp. I was told she was my guardian
angel. At first I laughed. Then I read about Laurie Show. She helps to
guide me in my quest for justice. Mostly abused children is my focus.
She has led me down this path....there is no other reason to explain
my devotion to this research.
I am thoroughly amazed at the Rifton Aviation link. How these guys are
able to get away with their tax-exempt status clearly is bought and
paid for by the blood of these Bruderhof kids. To say it's an outrage
is an understatement.
I feel there is juvenile prostitution underlying all this as well.
Call me a conspiracy theorist if you want, I've heard it before. So be
it.
I have done my homework. Some of you might not know it, but The
Bruderhofs have hired a big time PR. firm to spin everything about
them on the web.
Could be they have their hands in this very site as well."
********************************************
More from a different post in the same group:
"Your comments didn't offend me, just for the record, I ask questions
that hopefully will give me a more rounded and shall we say thorough
picture of who the Anabaptists are, were and becoming in this
precarious age we find ourselves in.
Almost everyone involved in the Lisa Lambert trial and especially
Laurie Show's family is involved in a deeply fundamental Christian
faith...if not the Amish then the Mennonites. Perhaps your friend can
confirm what took me awhile to realize...In Lancaster Pennsylvania the
Mennonites are the protectorant of the Amish culture which they have
carefully cultivated into a marketing goldmine."
This should give you a clue as to the type of person we're dealing with here.
Posted by: dimples Oct 9 2004, 07:57 PM
26 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1953
of
of1299
2301
Ya know it's too bad the show family can't sue the pants off HJJ and her website for defamation of character or something.
QUOTE(dimples @ Oct 9 2004, 06:57 PM)
Other than the "merchandise" to be sold on the website, whatever that is, they probably couldn't get very much.
In order to keep this area of the forum reasonably sane, I am going to start a thread of this miscreant's writings on the Forum Forum.

QUOTE(dimples @ Oct 9 2004, 06:57 PM)
Other than the "merchandise" to be sold on the website, whatever that is, they probably couldn't get very much.
In order to keep this area of the forum reasonably sane, I am going to start a thread of this miscreant's writings on the Forum
Forum.
Kasey - your thread under "forum" has been closed and I must agree with Dave. There really is no point in rehashing the Heather
Johnston saga. The more we comment the more she enjoys it. It's best to ignore and maybe she will either behave or simply go away.
In the meantime - people in various parts of the US are reading her "free lance writing" efforts on Justice Junction and believing her.
Before long, they too will see her obsessiveness and tune her out.
Lisa Lambert is in jail for the remainder of her life. Justice has been served.
Posted by: eurytopic Oct 10 2004, 10:11 AM
27 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1954
of
of1299
2301
Kate:
QUOTE
There really is no point in rehashing the Heather Johnston saga. The more we comment the more she enjoys it. It's best to ignore
and maybe she will either behave or simply go away.
Right on. Being trolled is one thing; actually doing the trolling on the troll's behalf is another.
If these boards obsessed about every person out there who has a screw loose, there'd be no time to discuss anything else.
Posted by: SusQRiverRat Oct 10 2004, 10:28 AM

In going back to the original question posed by the author of this thread, hjj and the whole Lambert thing are perfect examples of
why Lancaster murders SHOULDN'T be widely publicized.
Posted by: pio Oct 10 2004, 11:06 AM
Right!!!
Kate and I can attest that giving more attention to necessary to some people, when it comes to criminal cases, makes them feel as
if they have some sort of power or knowledge. In the case of HJJ, she has inaccurate information. She holds on to misguided
interpretation to justify her understanding of things. She claims to understand and have knowledge of the law. In the past she
made claims of being a private investigator. She fails to understand application of the law and understand court rulings. She fails to
understand the difference between different kinds of court proceedings or the courts that hold the hearing them self.
In relation to other cases, such as the Courtney Fry case, it is a horror that this case is not getting more local attention. There has
been little to no attention to her plight. I have seen one or two photographs of her and that was back in the summer. There has
been no further release of information. No data concerning potential last know whereabouts. No request to the public for "Have you
seen her? If so, who was she with, what was happening, what was she wearing, when was it, were was it?" etc. I have seen more
information on Cold Case Files from cases that are 20 years old than what there is with this case. So does Jimmy Hoffa, the Boy in
the Box and the Black Daliah. If the Columbia cops are not competent to handle this investigation, they need to hand it over to an
authority that is equipped to handel it, and do it soon before it gets colder than it already is.
Yes, you all are right, and I apologize for reacting as I did to the erroneous and egregious garbage. This was my first exposure to
28 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1955
of
of1299
2301
the depths of the madness, so now I will join the ranks of "those who know better."
On to Cortney Fry. This appears to be another case, like Laci Peterson's, in which the home and any vehicle possibly involved in
the commission of a crime of domestic violence will yield little in the way of conclusive evidence. That the boyfriend was getting rid
of some items that Cortney was planning to toss "anyway" is more than a little curious--I am hoping those items were carefully
examined for any forensic value they may have. IIRC, the boyfriend went to his family in Delaware shortly after Cortney's dad
reported her missing--let's hope the family members he saw then were interviewed thoroughly about this visit.
Does anyone know if the Columbia police have asked the State Police for any help yet in this case?
Don't hold your breath, Big Bird, waiting for a conviction in Courtney Fry's murder.
How about Brenda Heist? Christy Mirack? Christine Colon? I heard her boyfriend might be a suspect! Hey, it's a start!
Let's not forget Mary Ann Bagenstose.......it's only been what, 20 years now?
But we have new leads! 20 years later! No, really.
Your comment about Lancaster murders not being publicized, somehow being rightfully connected to the cover-up of all things Lisa
Lambert and Laurie Show....
Ie; the Public just gets everything all mucked up unless they're from Lancaster.
That's what a 3-paper monopoly will do to the uneducated mind.
Go back to Sesame Street, Kasey. It's truly right up your alley.
Posted by: Straydog Oct 24 2004, 12:31 PM
Points? HJJ gets special points for letting us know that:
1. Lancaster murders are not publicized.
Truth is unless you are from that town,city,metro area,suburbs etc.you won't see it in anything except the local papers, UNLESS it
is picked up by one of the news agencies such as AP. When the pagans and the Amish were caught selling drugs,that's national
news. When a person wields a machete at a school and threatens a school population, that is news.
2. Philadelphia,New York Post,NY Times, etc.have enough of their own murders to bother to publicize a murder in a sleepy little city
like Lancaster or its environs.
Kacy1- Yes the State Police were brought in.Columbia does not have the resources within their Police Department to do all the
investigation theirselves.State Police have the forensic tools to carry it further.
No bust on Columbia,none of our Police Depts.rely solely on their own investigators.
Given the time and opportunity almost all murders are eventually solved. A disappearance is another matter. Any adult can leave
29 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1956
of
of1299
2301
to go on a walkabout whenever they want to.

Another Topic: Since all of HJJs web sites are owned by her,it is best to ignore them. Time and Time again she has proven to us
that she does not know the meaning of the word CULPABILITY and what that means to the Commonwealths(Not State)Criminal
Code.
She will not (HJJ)have closure until 1.Lisa Lambert is freed.Or 2.Lisa Lambert dies. Long live Lisa so that she may enjoy being a
guest at our Commonwealth Prisons for a Looooong time.
Edited to add the word all

Posted by: Starling Oct 25 2004, 09:56 PM
QUOTE(Straydog @ Oct 24 2004, 12:31 PM)
Points? HJJ gets special points for letting us know that:

1. Lancaster murders are not publicized.
Truth is unless you are from that town,city,metro area,suburbs etc.you won't see it in anything except the local papers, UNLESS it
is picked up by one of the news agencies such as AP. When the pagans and the Amish were caught selling drugs,that's national
news. When a person wields a machete at a school and threatens a school population, that is news.
2. Philadelphia,New York Post,NY Times, etc.have enough of their own murders to bother to publicize a murder in a sleepy little
city like Lancaster or its environs.
Kacy1- Yes the State Police were brought in.Columbia does not have the resources within their Police Department to do all the
investigation theirselves.State Police have the forensic tools to carry it further.
No bust on Columbia,none of our Police Depts.rely solely on their own investigators.
Given the time and opportunity almost all murders are eventually solved. A disappearance is another matter. Any adult can leave
to go on a walkabout whenever they want to.
Another Topic: Since all of HJJs web sites are owned by her,it is best to ignore them. Time and Time again she has proven to us
that she does not know the meaning of the word CULPABILITY and what that means to the Commonwealths(Not State)Criminal
Code.
She will not (HJJ)have closure until 1.Lisa Lambert is freed.Or 2.Lisa Lambert dies. Long live Lisa so that she may enjoy being a
guest at our Commonwealth Prisons for a Looooong time.
Edited to add the word all
I agree on all points.
30 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1957
of
of1299
2301
I am somewhat confused about one thing.

How can you call yourself "lancasterlover" when you obviously have such disdain for not only the place, but most of the people that
reside here? It seems that, in your mind, we are just a bunch of ignorant, backwards-a$$, country bumpkins that live to frame
innocent trailer park skanks for crimes they, in your mind didn't commit.
Regardless of what delusions you may have regarding the guilt or innocence of Lisa Lambert, she was tried and convicted. The
conviction has been upheld NUMEROUS times.
I have had the opportunity to travel all across this great country of ours. I have visited 35 of the 50 states, and before I draw my
last breath, I hope to visit more. I have seen some truly beautiful places and could have settled in any one of them. I choose to
stay here because of all the places I've been, this is the best.
That is the true definition of a Lancaster lover.
Posted by: Kate Oct 26 2004, 11:37 AM
A troll is a troll..........
It would be in everyone's best interest to ignore "lancasterlover".
Posted by: Straydog Oct 26 2004, 01:43 PM

YO TROLL ! AKA Lancasterlover: Let ME clarify some things since YOU are the one blasting ME1. I was a Constable,just so you can verify it why don't you call the Lancaster County Courthouse, ask for the person responsible
for Constables and ask them if I was a Constable from 1986-1994.
Or you can send in a FOIA form and they can send it to you. I was also a Correctional Officer during much of that time.(1983-1989)
I left the County Prison because of Burn Out and the desire to become a "full time Constable".
2. A "Lowly Clerk"! Well I suppose if I was not in charge there 5 out of seven evenings, I suppose if I was not responsible for
schedules and time sheets, and logging in all new releases,well got the picture?
Gary,the owner, and I left on less than good terms mainly because I did not like the idea of selling used videos(cleaned and shrink
wrapped)as new. I was also putting in tooo many hours.
What HJJ may not(or choose not to)remember is that I also worked a Full Time job at the Welfare Office as a Courier/Mail
Man/Gopher. This too can be proven by a simple phone call. Call the Welfare Office, ask for personnel, and ask them if I worked
there. Simply done.
3. HJJ,if she chooses to forget a simple fact,lives in her very own world. We did have discussions any time she came to the Video
Store and wanted to chat. Most of the time it was just listening to her w/o much input from me.
Ask her about dating Gary,she probably has a selective memory about that too.
Ask her about Dale(female)who was also listening when HJJ would start to spout off about ALL the conspiracies in Lancaster
County.
31 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1958
of
of1299
2301
4. Anything I make a claim about here will be ignored by you.

YOU will not verify the facts. YOU will take HJJ at face value and not verify what I have posted now.
I did point out to HJJ that there were many errors in the investigation,and that the Officers of East Lampeter AT THAT TIME could
not perform a good investigation because,quite frankly,they did not know how to.
And I also informed her of the law concerning Culpability and Lisa Lamberts role in the murder. I also did state to her that this
would not happen now,because the Officers are better trained and would call in the State Police,city police,etc.to help w/the
investigation.
5. And maybe this should be number 1, I am out of work.True fact. It is also A TRUE FACT that I am a disabled,retired,Diabetic
that has already at the ripe age of 48 had a heart attack,lower back fusion,neck fusion and quite frankly I CANNOT WORK.PERIOD.
E.Mail me or send a Private Message,I will be glad to give you the dates for all these nasty things that took control of my life so
that you can know the facts. I wish I could work,you cannot know how badly I would like to go back to work.
6. A troll is a troll is a troll is a troll. YOU will not change,even after I encourage you to verify my past. A past which you have
posted so EVERY ONE can see it,read it,and talk about it. You choose to believe a mentally unstable(and I am being kind
here)female who just can't get it. I really feel bad for you. I hope YOU get the help that YOU need. Period.
Posted by: ominousne Oct 26 2004, 04:42 PM

I don't often agree with straydog, but there is NO reason for posting his personal information here for everyone to see. This is a
violation of the law of internet privacy and if he wishes, lancasterlover, he could sue you for that and not have to worry about being
out of work.
I suggest everyone report the post made giving personally identifying information and ask that it be removed from the forum.
Posted by: eurytopic Oct 26 2004, 05:00 PM
I'm not sure what kind of laws there are to govern it, but I agree that posting personal info (accurate or not) about another LOL-TB
mamber, as "lancasterlover" did, is quite unethical. Would hope that Dave is paying attention, and (red)acts accordingly.
I continue to be amazed and amused at the durability of this LML/HJJ crap.
Posted by: Starling Oct 26 2004, 05:55 PM
Wow, even I am at a loss for words. That was totally over the top.
I reported it early this morning. IMO, this thread should be closed.
32 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1959
of
of1299
2301
Trust me, Kate, I know a troll when I smell one. I really try hard to not feed them, but there comes a time.....
Straydog, My hat is off to you. You handled that with class.
I hope the Mods do the right thing here.
Posted by: eurytopic Nov 9 2004, 08:41 AM
I think it's time for lancasterlover to take a forced vacation from this site.
Posted by: SusQRiverRat Nov 9 2004, 09:51 AM
While I was reading that I couldn't shake the image in my head of Humphrey Bogart rolling those steel balls in his hand and saying
"It was the strawberrys".
Pure delusion. With writing skills such as that, I'm not surprised that she's a freelancer.
Powered by Invision Power Board (http://www.invisionboard.com)

Invision Power Services (http://www.invisionpower.com)
33 of 33
7/20/2008 8:02 PM
Windows Live Hotmail
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
January January
Sunday
22, 201722, 2017
Windows Live Home

Inbox
New
Page
Page1960
958 of
of1299
2301
Hotmail
Reply
Spaces
Mail
OneCare
Reply all
Forward
Delete
Junk
Web
Move to
Junk
Drafts
Sent
Options
LA Times Artcle on Lambert Trial by Barry Siegel November 10, 1997
Americom
From: Stan Caterbone (amgroup01@msn.com)

Sent: Sat 10/20/07 12:35 PM
To: barry@barry-siegel.com
Andale
U.S. District Court Case No. 05-2288
Deleted
BargainLand
Barnstormers
Craigs List
DE Communications
amgroup01@
HAD LANCASTER COUNTY (Pennsylvania) LOST ITS SOVEREIGNTY

BEFORE IT LOST ITS SOUL?[1]
ebay
Ebay Sent Mssgs
Faxes
Fulton Bank
jen
LancChamber
Listings
omnis
ONE.org
Project Hope
Robert f Kennedy
Saved Sent Messages
Shipping
Site Webmasters
Unpaid Payments

In 1987 This Plaintiff (Stan J. Caterbone) Had Unjustly Lost His Freedoms, His
Rights, And His Pursuit Of Life, Liberty And Justice.
Manage folders
Today
The following report (most identities purposely omitted from this version) is
Mail
an amazingly true and factual account of an extraordinarily bizarre tragedy that has turned
Contacts
one mans life into an eleven (11)[2] year free fall into Dantes Hell.
Calendar
On the surface, this is a story of a victim struggling to seek the truth, but in reality, the
evidence will conclude that this is a victim, literally, held hostage by virtue of his truth.
Later, the preponderance of evidence that Stan Caterbone has amassed and his obsession
for meticulously documenting his ordeal might seem eccentric, yet his demonstrated ability
1 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1961
959 of
of1299
2301
to react to events before they unfold appears mystical. And this was his manner in which
he tactfully defended and protected his life. It is these actions that have painted the
landscape with a dire vengeance for his ruin. His actions will ultimately serve to protect,
preserve, and foster the truth of his story, incriminating the culpability of his many
perpetrators, while at the same time being twisted and tainted in a relentless manner to
attack his credibility.
This is a story of a human being endearing for his rights, living in fear of his life,
and the remedial actions required for the truth to set him free. A victim forever believing in
his accomplishments and his visions, yet forced to adhere to a life of their diversions.
Fatefully, ten years after being taken as a political hostage, with the aid of numerous
arrests and false imprisonments conveniently falling short convictions, a Federal Judge,
Judge Stuart Dalzall, of the Eastern District Court of Pennsylvania, opened a Pandoras
Box into the true colors of the inner workings and politics of ultra conservative Lancaster
County, Pennsylvania, a supposedly Gods country. His findings reeled a dramatic and
assassination of JFK. A community where obstructions of justice strikes a startling and
stark contrast to the image it so desperately embraces. A community proud of its tough
on crime judges, a community of plain folks and Amish, and a community settled in a
beautiful landscape abundant in an agricultural bounty. This is not a community of
compromising integrity. Or so it has been perceived.
Judge Dalzalls extremely controversial findings were responsible for Pennsylvanias

own crafting of the Laurie Bill, the retaliation by the Commonwealth of Pennsylvania
intended to curb the Federal Courts interference within the respective states own
jurisdictions and proceedings. Or was it a political maneuver to close the lid on Pandoras
Box? The Pennsylvania Attorney General and the Lancaster County District Attorney have
both thrown all their might and all their muscle at turning the tides of Judge Dalzalls
findings. This story and Stan Caterbones rights have been violated and abused by some of
the very same principals that were responsible for Judge Dalzalls unsettling revelations.
Lancaster County prosecutors were found to have engaged in one of the grossest acts of
prosecutorial misconduct found in the English speaking language, which allegedly
occurred in this now famous Lisa Michelle Lambert case, a murder trial which began in the
summer of 1992. Subsequently, it is now in the midst of a treacherous appeal process
convened by Judge Dalzall. And if so, by fate, in Philadelphia, Pennsylvania; the home of
the Freedom Fighters.
It is this public disclosure, that casts a new light and sudden hope for freedom into
Stan Caterbones unbelievable and horrid story, that begun just four years prior to the
murder of Laurie Show. It is the decisive similarities of how both victims were subjected to
a
very
calculated
and
politically
motivated
attempts
to
frame
and
fabricate
circumstances to obtain the results that justified the means for illicit self-serving interests.
This very same conduct, committed by public servants, elected and enlisted to enforce the
2 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1962
960 of
of1299
2301
law, to which Judge Dalzell found so appalling. Conduct, which violated the very same
rights their respective offices are commissioned to protect.
Conduct, which strikes the
meaning of We The People from our nations very own Constitution.
Fortunately, Stan Caterbones story is laced with a thread of faith, a faith in God.
And because of his faith, Stan Caterbone will forever regard Lisa Michelle Lambert[3] and
Laurie Show as his little Angels of Justice, a Godsend. An answer to his many prayers,
that for the first time in ten years provided a small glimmer of hope, and a few moments of
solitude that have materially justified his own tragic experience. The realization that the
truth is that much more believable because of the trials and tribulations of Lisa Michelle
Lambert. Unfortunately, this revelation came at the unfortunate and untimely death of
Laurie. However, it just may be Gods intentions of a Higher Purpose.
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 Caterbones rights for justice. Its 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 Boys club of Lancaster County. A process obsessed with
keeping its disclosure from escaping beyond the confines of Pandoras Box. Its a tenure
of power that evolved from the days of this countrys 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!
AT ISSUE
The central issue in this story is a cover up, a cover up of mass proportions, and of
perplexing design, with national consequences. The fact of the matter is that this cover up
has had ramifications throughout this world; specifically the Middle East The cover up
would be emphatically unbelievable without the wealth of evidence, especially the recorded
conversations with Pennsylvania officials. A cover up that permeates from what will later
emerge as the 4th largest financial fraud (Billion Dollars) in the history of the United States
coupled with the covert sales of arms to Iraq. And five years after this cover up began,
these same munitions were used against our own troops in the Persian Gulf War. And of
course, there are admitted ties to the Central Intelligence Agency (CIA) and the National
Security Agency (NSA).. And this cover up and story, which began in June of 1987, in
Lancaster County, preceded criminal indictments by the United States Attorney General,
the Federal Bureau of Investigation (FBI), the Internal Revenue Service (IRS), the
3 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1963
961 of
of1299
2301
Department of Justice and Commerce, and more. A vast array of criminal activities
conspired from the ultra conservative Lancaster County, where God is supposedly supreme,
and its hard line approach to crime is said to be preeminent. In June of 1987, Lancaster
County was immersed in a dynamic twist of fate, with a host of
The irony of this story is how Lancaster County manages the disclosure of the very
same criminal activities that this story proves that it condoned, prior to the intervention of
federal authorities. It most dramatically will prove the nature of its integrity, or lack
thereof. International Signal & Control, (ISC) is the controversial player in this web of
conspiracy. In 1987, ISC was the third largest employer in Lancaster County, a
non-discrete defense contractor. In all due respect to our beloved country, this report is in
no way challenging the policies or the activities of the Department of Defense, or the vast
agencies of the Intelligence Community, especially the CIA or the NSA (National Security
Advisory). with regards to ISCs foreign dealings. Trying to protect the world of malicious
and evil empires is a process which never ends, and whose players are constantly
changing. And our respective intelligence agencies are continually challenged with the task
of trying to make a difference, in accordance with protecting our national security.
Unfortunately, given the nature of their discrete activities, and given the CIAs history of
avoiding congressional approval in certain situations, our current laws are void of
effectively dealing with the peripheral catastrophes of such activities that inherently
transpire. The CIA remains immune, while everyone outside suffers the consequences.
The fact that the CIA, or anyone of the other intelligence community, may have
been involved, does not grant a blanket of immunity over activities which were not
material to protecting our national security. If a company provides a service to
anyone in the intelligence community, our constitution, our laws, and its
respective commercial regulatory authorities, must still have the full sense of their
jurisdiction. The intelligence community may not have the right of intervention into
the commercial enterprise, or organization, circumventing the rights of its
employees, shareholders, creditors, and customers. No United States law or
statute suggests that there is any involuntary mandate that requires any of the
preceding to compromise his or her interests in the respective enterprise for the
that.
Stan Caterbone was a shareholder of record of International Signal & Control (ISC)
for the previous four years prior to when this tragic ordeal began. Stan Caterbone was to
4 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1964
962 of
of1299
2301
purchase the stock from now Republican Pennsylvania Senator Gib Armstrong, who was in
the brokerage business at the time and selling ISC stock. The stock was sold over the
London Securities Exchange, supposedly for reasons to suppress information. Stan
Caterbone was interested in the stock because of his appetite for technology, and was more
curious about the business of ISC, than anything. In fact, Stan Caterbone had never made
any inference to any of the illicit dealings with Iraq. However, the perpetrators of this story,
attempt to hide behind a vale of national security," in an effort to find legal immunity from
all wrongdoing. In accordance, the record will prove that this is merely a smoke screen
used to intimidate and obstruct Stan Caterbones access for due process of the law.
The trials and tribulations of Stan Caterbone are unprecedented in terms of

emotional and psychological duress, fortunately his indestructible faith in God, and his
enduring belief in himself and the truth, endures his life. There was one attempt on the his
life, days within the public disclosure of the CIAs involvement with the local Lancaster
County defense contractor (ISC), which Ted Kopel reported on ABC News Nightline, on May
23, 1991, 4 years after the initial cover up began. This story will depict a series of
systematic and strategic offensive attacks upon Stan Caterbone and his businesses that will
result failed business enterprises, and a Hollywood motion picture, deserted. An impeccable
professional reputation and a flawless credit rating purposely sabotaged. Financial
opportunities, that in 1987, were almost impossible to extrapolate, Vast financial
opportunities and aspirations forever a part of history. This horrendous Crime was
perpetrated for the interest of a cover up, further protecting the corrupt enterprises of
Lancaster County's International Signal & Control (ISC). A quest for justice that polarized
every relationship Stan Caterbone maintained, in Lancaster County and beyond, including
friends and family. This story demonstrates a methodology of his perpetrators for keeping
Stan Caterbone quarantined from justice and public disclosure, through a malicious
means of credibility proponents, and horrendously deceptive tactics. Financial motives
prominently displayed in the hands of all of the perpetrators, which absolves the burden for
a traditional conspiracy.
The emotional response to the truth of this story is compelling, to say the least.
Subsequently, the startling keen sense of perception that Stan Caterbone had
demonstrated is even more intriguing. It is this extraordinary quality that is responsible for
saving his life, while yet at the same time providing his perpetrators with an alibi and a
vehicle for discrediting his startling allegations and his story. This story embellishes a
dichotomy of perception that had Hollywood producers from his film project call his work
genius, while his perpetrators from the Lancaster County Community conveniently and
maliciously labeling him as insane and emotionally disturbed."
THE LANDSCAPE
The perplexing question of Stan Caterbones intelligence, or lack thereof, is best
analyzed as a question of perception. However it terms of the legal consequences of the
activities contained herein, they are of little if any relevancy. The fact of the matter is that
5 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1965
963 of
of1299
2301
the mental deficiencies have very little relevancy to this story, other than serving as a
means to discredit Stan Caterbone, a vehicle to facilitate the cover up, and a blanket of
immunity for all of the perpetrators.
The heart of Stan Caterbones legal dogma is best described as follows: If a person,
is perceived to have a mental deficiency; yet whose actions and decisions are always
proven to be instinctually and amazingly prudent, always abiding within the law, and in the
best interest of his affairs, what rights and protection do the laws afford him from persons
abusing that perception, in order to yield political and financial rewards, as a direct
consequence of his demise? Furthermore, how does the law protect his rights, if any and all
malicious acts against Stan Caterbone, are constantly and immediately disregarded
because he is perceived to not to be credible? As this story unfolds, these questions will
become even more troubling and appalling. Although Stan Caterbone could never describe
the pain of his trauma, he would often say that the closest situation that may compare is
that of a woman being continuously raped, night after night, helplessly praying for relief,
struggling to free herself from her captor, all with no avail. He would call it as being brain
f------.
Stan Caterbone, coming from the lower middle class of Lancaster City, was only 29
years old when this tragedy began. Coming from a broken home, he was the third of six
boys. While at a very young age, he would help his mother run a dry cleaning business, in
an amazing similarity like Lisa Michelle Lambert, he had also nursed his mother during
bouts of depression. While in high school, he was nursing his mothers depression, while at
same time tending to his older brothers bouts of schizophrenia. Stan Caterbone had
learned to listen to the obscenities of mental illness since he was a child. He learned to fill
the shoes of his absent father in helping his mother raise his three younger brothers.. Stan
Caterbone was often called the little old man because of his extraordinary maturity as a
child. Stan Caterbone was determined to break the barrier of the Good Ole Boys club or
the power elite, and had always felt a sense of compassion for those less fortunate, and
those neglected by those of material means, the oppressed and impoverished. He had an
undivided aspiration to someday make a difference to those that could not help
themselves, especially his older brother. Through his ingenious, resourceful, and honest
business approach, he was relentlessly growing his business and their respective missions,
in constant reminder of his oppression. His in depth understanding of computer technology
and his vision were his most powerful allies. Always pushing the envelope for advanced
technologies and seeking solutions for the most efficient means of his operations.. He knew
that every break was going to be few and far between, he dedication himself to his work,
and married his business affairs, always embracing his projects with a passion.
In 1986, after serving on the Board of Directors for the Central Pennsylvania
Chapter of International Association of Financial Planners (IAFP), Stan Caterbone had made
a large contribution to increasing its membership and its awareness among local
professionals, as its vice president. In an effort to promote the organization, Stan
6 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1966
964 of
of1299
2301
Caterbone solicited a nationally recognized and prominent financial
planner from
Washington, D.C., to be a headline speaker at a dinner meeting. Ms. Alexandra Armstrong,

one of the most nationally recognized financial planners, often headlined in Money
Magazine, attracted 100 industry professionals to the Treadway Resort Inn. The attendance
was unprecedented for the local IAFP chapter. The IAFP is the authoring organization for
certification as a financial planner. It was through the direct conversations with Ms.
Armstrong regarding his ideas and her experience, that inspired Stan Caterbone to pursue
his ambitions of growing his own financial firm, which he began in the following months.
Disgruntled with the conflicts of interest and the lack of incentive for various
professionals to work together in managing ones wealth, a process which lacked efficiency,
this entrepreneur founded the firm Financial Management Group, Ltd., or FMG as it was
often called. The firm was to incorporate a one-stop-shopping strategy and incorporate
financial services, legal, accounting, tax preparation, real estate, insurance, mortgage
banking, and estate services all in one firm, all residing in one location, all taking
advantage of the synergistic approach toward managing wealth. And to provide the
professionals long term security and equity participation, all participants were encouraged
to purchase stock in the company. This was a new and innovative approach that attracted a
lot of attention from investors and clients, but also came a lot of nervous twitches from
competitors, especially in conservative Lancaster County.
Stan Caterbone began recruiting professionals from all of the other firms, with great
success. He had enlisted two partners whom he had worked with at IDS/American Express,
to carry out his mission, which he began after extensive market studies and his early
version of the company, Pro Financial Group, Ltd., His two partners had followed Stan
Caterbone to an independent broker dealer in Atlanta, named Financial Services
Corporation, where Ms. Alexandra Armstrong was associated, and encouraged Stan
Caterbone to visit, during their discussion after dinner. Within one year, by June of 1987,
the firm had invested over $40 million for respective clients.
The company had developed satellite offices throughout Pennsylvania and in several
other states, through his unique design. This firm was causing the other financial services
companies and the local banks in Lancaster County a run for their money. The firm had
built a new 20,000 square foot office building just a few miles north of the city. The firm
was attracting clients, associates, and nervous attention from, well just about everybody.
Considering the capabilities, legal, real estate, insurance, financial services, accounting,
FMG was making as many enemies as it was making friends. And Stan Caterbone always
believed in the premise that its always better to have people talking about you, regardless
of the matter, than to have no one notice you. And they were talking. Stan Caterbone was
only in his late twenties when he started this organization,. He held several positions; he
was Executive Vice President and Secretary of Financial Management Group Ltd, and
President of FMG, Advisory, Inc., which was one of the many subsidiaries parent company
owned. Stan Caterbone acted as the architect and legal administrator of the organization,
7 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1967
965 of
of1299
2301
in addition to building his own financial planning clients. He filed all of the articles of
incorporation in the Commonwealth of Pennsylvania and submitted all of the tedious and
rigorous filings necessary for the Pennsylvania Securities Commission, which were very
demanding considering Stan Caterbone, was selling stock of his company to his associates
and investors. Stan Caterbone and his associates had also attracted some very prominent
Lancastrianss to invest in his venture, coming from various professional circles, all
infatuated with this extraordinary and intriguing concept of this young victim. All had seen
its potential for success and financial reward.
Many of his friends were involved, and in Lancaster, everyone knows everybody, so
it seams.. And everyone talks, gossip is as common as jogging. This exaggerated trait of
Lancaster County, will later to come back to haunt Stan Caterbone, in a way that is most
sickening. In a way that will parallel the attitudes and sentiments in the Lisa Michelle
Lambert story.
In 1987, his business affairs were reaching a point of incredible success. In fact,
most of his family and friends, have always questioned the merits of their legitimacy. He
always conducted his affairs with the presumption that time could not afford the
opportunity to complete his agenda, while at the same time disclosing his business affairs
to persons that were not directly involved.. Accomplishing his mission was first and
foremost. But in Lancaster County, that was difficult. Lancastrianss have a notion to fear
what they dont know, and will always believe what they think they know, regardless of its
merits. In Lancaster County new ideas are shunned unless coming from their own, and
their own ideas are often kept close at bay, inhibiting progress and stymieing learning. By
June of 1987, a majority of his business affairs were conducted out of the grasp of
Lancaster County, his unknown activities made others curious, especially in Lancaster
County, where the blessing of the power elite was essential for success. But, deep down
inside, he knew he could never be accepted, because he did not descend from a family of
social grace. This fueled his aspirations for success even further, committed to prove that
intelligence was innate and learned, not a direct correlation to material wealth or social
grace.
An elder attorney, Mr. Kenellm Shirk, a very respected and prominent older
Lancaster attorney, who was part of the status quo, provided one of his most cherished
testimonials to his concept, his reputation, and his mission. Mr. Shirk had petitioned the
Pennsylvania Bar Association, after meeting with Stan Caterbone, to obtain their blessing
and their knowledge of any laws which would forbid his firm to provide a satellite office in
the headquarters of Financial Management Group, Ltd., (FMG) Mr. Shirks firm was to
provide a partner, and estate services to the clients of FMG. The Pennsylvania Bar provided
a lengthy recommendation that did not prohibit a relationship, although cautioned it to
proceed with careful review. The fact that the very young and unknown Stan Caterbone
could attract an elder, conservative Lancaster County attorney to associate with his firm
was an encouraging sign of respect. Ironically, Mr. Shirk is the father of Roy Shirk Jr., Lisa
8 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1968
966 of
of1299
2301
Michelle Lamberts first attorney who represented her during trial of 1992, the proceeding
which was the center of Judge Dalzalls controversial and appalling findings.
Stan
Caterbone prided himself on his entrepreneurship, and after building the foundation for
FMG, he set out to take advantage of its resources and its synergism.
By June of 1987, Stan Caterbone had developed a fairly substantial mortgage

banking relationship with a Houston, Texas banker. That operation was capable of
providing lending to potential developers and businesses in the range of $ 3 million to $100
million. And the lending packages were as competitive if not more competitive than the
local lending institutions of Lancaster County, capable with even higher lending limits. In a
matter of months of securing this relationship, Stan Caterbone and his partner were
evaluating deals from Pennsylvania, New Jersey, New York, Florida, and as far away as
California.
There was a uniqueness to his capabilities that was very appealing to potential
borrowers. Because of the vast array of services of FMG, potential developers had the
opportunity to obtain both debt and equity financing through his companies. In plain
terms, most shopping centers raised capital by raising funds through investors coupled
with a mortgage. This gave potential developers one place to take down the deal rather
than dealing with many other professionals at the same time. It was a much more efficient
process for all. Stan Caterbone was capable of providing a mortgage, while at the same
time selling shares in a shopping center through its vast client base of investors at FMG.
This also gave Stan Caterbone a formidable presence into the venture capital markets, by
way of his strong ability to raise capital through his vast portfolio of clients of FMG. And
this was a rarity that developers and investors loved. Investors were attracted because
they could invest in equity type real estate projects with real sense of knowing the
developer, or kicking the bricks of the project. This was far different than investing in a
nationally syndicated project, with properties scattered all over the country, and with
developers that they did not know. The synergistic approach to his organization began
paying dividends by developing other peripheral markets and businesses.
Given the complex nature of Stan Caterbones design of FMG, internal struggles
within the organization readily became the challenge. Orchestrating the relationships
among all of the different professionals, and trying to adhere to the interests of the clients,
the professionals and of the firm, FMG, managing the daily activities required immense
thought and prudence on the part of the principals. Of, course, Stan Caterbone assumed
honesty and integrity to be a given. And for most it was. However there were times when
the senior partner engaged in tactical rights of power.
In the later part of 1986, after Stan Caterbone had developed FMG to the point
where its future was on stable grounds, his two partners conveniently attempted to
9 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1969
967 of
of1299
2301
circumvent his position and regain control of his stock and the firm. In fact, after Stan
Caterbone refused to collaborate on a scheme to set up his other partner, the remaining
two partners began to attempt to regain Stan Caterbones control. Through intimidating
techniques, the partners began to attack his presence. Stan Caterbone became agitated,
especially because he played the lead role and was responsible for the formation of the
company, methodically designing and developing its foundation, with great success. And
now after the company was beyond its point of greatest risk, due to in large part Stan
Caterbones efforts, the other two partners wanted to take advantage of his work, and
take the cream of the pie for their own financial gain. It was a difficult task to carry out
because Stan Caterbone was the most respected of all three partners, consistently keeping
their respective policies in the best interest of the firm and of the other associates and
stockholders. In fact, most feared that the loss of control of Stan Caterbone would
ultimately lead to adverse consequences. However the two partners trued unsuccessfully to
weaken his position, and when that didnt work, they focused on weakening Stan
Caterbone, via intimidation and humiliation The coup and hostile environment caused a
state of depression for Stan Caterbone, although he kept to his daily duties and
responsibilities, accordingly, he called a client and friend who was a psychiatrist, whom he
trusted and respected. It was easy access to a professional, yet on a very informal basis.
Because Stan Caterbone had a family history of mental deficiencies, he wanted to seek
the proper help.
The psychiatrist had diagnosed Stan Caterbone as having Bi Polar Mood disorder.
The psychiatrist had quickly discounted any correlation between the current state of affairs,
and his partners abuse. The psychiatrist rationale was that because the startup of the
company was so successful in such a short period of time , and his demonstrated
intelligence and creativity, Stan Caterbone must have been in a state of mania, and of
course now, was subsiding in a state of depression, the typical cycle for manic depressants.
Stan Caterbone complied with the psychiatrist. And after refusing to sell out to his
partners, vowed to regain his business and rescind any efforts to give up his claim to his
accomplishments. The depression soon faded. Stan Caterbone never disclosed the fact that
he had sought help to anyone other than family members. This coup lead to Stan
Caterbones aggressive approach to grow the business, and to posture himself in projects
that would ultimately remain in his control, out of the influence of his partners. Particularly
of most interest was saving the mortgage banking activities and the digital movie, which
he did successfully, but apparently too successfully.
THE DIGITAL MOVIE

Through an act of fate, in February of 1987, Stan Caterbone found himself in a
meeting with Tony Bongiovi at Power Station studios. Through one of his partners, he
reluctantly traveled to New York to consider financing a motion picture. Stan Caterbones
own lack tolerance for the risk associated with film investments was overshadowed by the
opportunity to visit a recording studio. Although his associate was a friend of Tonys, he
was not familiar with his accomplishments, or his work, so he thought. If nothing else, it
10 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1970
968 of
of1299
2301
was a weekend away from Lancaster, and a chance to visit the Big Apple. Intriguingly, he
found more than he had ever imagined on that weekend excursion. Tony Bongiovi, a
musical genius, whos credits include one of the most recognized recording studios in the
country, Power Station Studios. Tony Bongiov produced the sound track for Star Wars,
and is responsible for the format of one of the most successful recording artist of the 80s,
Jon Bon Jovi, his cousin. Power Station
has recorded the albums for some of the most influential artists of all time, including Diana
Ross, Madonna, The Rolling Stones, Steve Winwood, Bruce Springsteen, etc., Tony, an
eccentric genius, of Italian decent, had many talents, from music to aerospace engineering.
Stan Caterbones associates sister met Tony while he flew his plane into Lancasters
airport for repairs. They dated for some time and Stan Caterbones associate and Tony
became friends, which led Stan Caterbone to Tonys Power Station Studios.
Tony was looking to finance his new project, which was to be the first digital
movie. And, given Stan Caterbones extreme appetite for technologies, coupled with his
amazing sense of perception, he dramatically recognized the future evolution for the
technical merits of delivering digital video and digital audio entertainment to the mass
markets.
By June of 1987, Stan Caterbone was positioned as the Executive Producer,
collaborating with Flatbush Films of Hollywood California, the movie producers, entrusted
with the mission of finding investors to provide funding for the first digital movie, and to
manage the ensuing business elements it required.
The movie was to be shot on-location at the Jersey shore points, mostly in
Wildwood. Tony strategically envisioned making a movie in the horror genre. There were
several specific reasons that supported this strategy. First, he determined that it was the
least expensive format to produce, we all estimated a budget of $4 million for the
production and post production. Secondly, the horror genre would compliment a very
intense sound track. The sound track was important to enhance the new digital format, and
also provide the means to introduce a new band that he had been grooming in his studio
for the past several years, French Lick, his predecessor to Bon Jovi. There had been bad
blood between Tony and his cousin Bon Jovi, which resulted in legal disputes pertaining
to Tonys financial interests in Jons success. It was an unfortunate situation considering
Tonys father and Jons father were brothers living in the same area. It was a subject that
Tony never wanted to discuss, except for his contributions toward Jons career.
If by another act of fate, Stan Caterbone had the privilege of meeting one of the
many superstars while working at Power Station studios. While growing up, at an early
age, Stan Caterbone would sneak up into the bedroom of his oldest brother, and start up
his old General Electric stereo phonograph and listen to his favorite album - Diana Ross and
the Supremes. It was a passion and a ritual that provided an early infatuation to music,
and to Diana Ross. Stan Caterbone was only 10 or 11 years old. And at this early age, he
noticed and listened to the annoying hiss, that conventional hiss that always seemed to
11 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1971
969 of
of1299
2301
overshadow the music, whether played on an album, on the radio, 8-track tape, or
cassette.
And in a mystical twist of fate, while engrossed in a project dedicated to delivering

music without that hiss (digital) - Stan Caterbone opened the door to the recording suite to
pack his bags for the journey back to Lancaster; - and there she sat, with a glowing array
of beauty, more beautiful than any picture could ever tell, Ms. Diana Ross. She was
pregnant and in the middle of a recording session, for a new album. Her assistant quickly
demanded, in a stern and protective voice, that we leave, and Stan Caterbone and his
associate replied this is our makeshift bedroom, we are just gathering our belongings.
Stan Caterbone walked toward Diana Ross, who was seated near his bag, and she asked
and who are you?, Stan Caterbone calmly replied his name and absorbed as much of her
beauty as his eyes could behold before walking out the door. The room that was his
bedroom the nigh before, and suddenly transfixed into the recording suite of Diana Ross,
thinking back some twenty years earlier, one of the many gifts that God would bestow
upon him. A living memorial and reminder to his older brother, who died on Christmas day
of 1985, his best friend who taught him two of his greater pleasures in life, Diana Ross,
and listening to music. He prayed that his brother was watching from above.
And so, the digital movie project that Stan Caterbone had embraced in 1987 had
personal significance, and he never ever doubted his instincts regarding the technical
merits of the project. Stan Caterbones perception that the entertainment industry would
deliver full length motion pictures in a truly digital medium will later become a truly
remarkable vision.
The technical merits of this project and at this particular time with respect to Stan
Caterbones extreme sense of perception require analysis. To truly understand this time
perception, some of the attributes of digital technologies need to be fully understood. In
1987, Compact DISC (CD) technology was only now being introduced to the commercial
markets. Stan Caterbones own crafting of his joint venture proposals, dominated by the
term digital movie, is in itself some 4 or 5 years away. In 1987, there was very little use
of the term digital, with the exception of research and development engineers. Stan
Caterbone will, throughout the documentation of this story, will have preceded a
terminology that has literally become the root of most technological advancements in the
computer and telecommunications industries of our present day, 10 years after Stan
Caterbones vision. Today, digital is found to be part of or referred to in just about every
Entertainment, Inc., for the digital movie. After weeks of researching the current
state-of-affairs within SONY, and after his proposal was completed, SONY publicly
12 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1972
970 of
of1299
2301
announced their desire to open the markets for new and emerging technologies on the
cover of TIME magazine, another demonstrated sense of perception. It was this proposal,
when delivered to one of the Hollywood producers in Santa Monica, California, after reading
a draft of the proposal she said you are a genius. The proposal was introduced to Tony
Bongiovi at the Wildwood Boardwalk, where many of scenes were to be shot, and he
approved of the proposal and thought that it had great merits. Tony, who wanted very to
do with the business elements of his project, gave Stan Caterbone complete authority to
secure the financing of the project, with a salary as Executive Producer, and a percentage
of the profits on the back end.
After review of Stan Caterbones research and proposals, his vision and his passion,
which is Sonys satellite entertainment system (TV), delivering digital audio and digital
video entertainment. That technology is fast eroding at the cable industry. Stan Caterbone
had his patent research center around the PSDMS system, the Power Station Digital Movie
System. And that was in 1987, some seven years before SONY delivered his dreams. Later
Stan Caterbone would also accurately predict that the 90s would become the Information
Age because of the direct contributions and advancements of digital technologies, which
is directly responsible for the development of the INTERNET.
Stan Caterbones obsession with his digital movie has proven to be one of his
[1] In April of 1997, Federal Court Judge Stuart Dalzall said Lancaster County had
lost its soul in the worst case of prosecutorial misconduct ever found in the English
speaking language regarding the Lisa Michelle Lambert hebeas corpus hearing in the
notorious Laurie Show murder case.
[3] The author admitted in an affidavit in 1998 that he did not know the criminal
prosecutorial misconduct and the erroneous handling of the crime scene that the truth
evaded both the prosecution and the defense as to who actually killed Laurie Show.

Stan J. Caterbone
Visit Our Blog
Visit Our Video Biography
13 of 14
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1973
971 of
of1299
2301
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.
Windows Live Hotmail and Microsoft Office Outlook together at last. Get it now!
Reply
Reply all
Forward
Delete
Move to
Want to race through your inbox even faster? Try the full version of Windows Live Hotmail. (It's free, too.)
2007 Microsoft
14 of 14
Privacy
Legal
Help Central
Account
Feedback
10/20/2007 1:12 PM
January January
Sunday
22, 201722, 2017
Page
Page1974
972 of
of1299
2301
Welcome to the Lancaster County Courts Web Site

Lambert

CRIMINAL
COMMONWEALTH OF
PENNSYLVANIA
v.
No. 0423 - 1992

:
Relief Act
:
:
Post Conviction
OPINION
BY: STENGEL, J., AUGUST 24, 1998
Click here to download self-extracting zipped file - Word Perfect format
Click here to download self-extracting zipped file - MS Word format
TABLE OF CONTENTS
I. INTRODUCTION
II. BACKGROUND
A. The Trial
January January
Sunday
22, 201722, 2017
Page
Page1975
973 of
of1299
2301

evidence
IV. THE 1992 VERDICT: FINDINGS OF FACT AND CONCLUSIONS OF LAW
C. The Abuse Issue
January January
Sunday
22, 201722, 2017
Page
Page1976
974 of
of1299
2301

1. Credibility
2 . Footprints in the hallway and bedroom
3 . The white sweatshirt
O. Robert Reed's Testimony
VIII. CONCLUSION: THE QUE STION OF INNOCENCE
January January
Sunday
22, 201722, 2017
Page
Page1977
975 of
of1299
2301
ORDER
ADDENDUM TO OPINION
I. INTRODUCTION
Lisa Michelle Lambert's petition under the Post Conviction Relief Act ("PCRA"), 42
Pa. C.S.A. Section 9541 et seq. (1998 Supp.),(1) is now before this court. Ms.
Lambert was convicted of first degree murder for the death of Laurie Show and
sentenced to life in prison. The guilty verdict was entered on July 20, 1992, after a
non-jury trial.
Ms. Lambert's petition contends that her conviction and sentence are wrongful,
illegal and unconstitutional on the basis of after-discovered evidence. She believes
that this after-discovered evidence proves her innocence and credibility, and
establishes a fundamental miscarriage of justice. She also argues that intentional
acts of prosecutorial misconduct, deliberate falsification of evidence, witness
tampering, violations of discovery obligations, presentation of perjured testimony
and ineffective assistance of both trial and appellate counsel formed the basis for
her conviction. Ms. Lambert contends that she cannot be retried because the
prosecution intended to deny her a fair trial.
The 257 claims stated in the amended petition present various facets of certain
major issues. In this opinion, we address these issues. This court has had an
opportunity to consider Ms. Lambert's claims in light of the testimony at her 1992
trial, the testimony at her eight week 1998 PCRA hearing and the legal issues and
arguments presented by her counsel and by the Commonwealth. On the basis of
this fully developed record, we are in a position to make factual findings, credibility
rulings and legal decisions in the interest of a full resolution of all claims raised by
Ms. Lambert.
We find that Hazel Show's testimony regarding her daughter's dying declaration
was credible in 1992 and remains credible today. We find that the expert analysis
so ably presented by both sides of this case does not constitute such "afterdiscovered evidence" as would cause this court to make any change in the
credibility determination which formed an important basis for the 1992 verdict.
We find that the so-called "29 questions" did not and could not raise a reasonable
doubt as to petitioner's guilt and does not form the basis for any contention that
the Commonwealth presented perjured testimony.
While sympathetic to the evidence of past abuse presented by Ms. Lambert, we do
not find, under the law, that her diagnosis as a "battered person" has any legal
impact on the issues before us.
We find petitioner's evidence regarding the involvement of Tabitha Buck and
Lawrence Yunkin to be fraught with concerns over Ms. Lambert's credibility. Should
we resolve many of those credibility questions in petitioner's favor, we still do not
believe the testimony about the involvement of others is exculpatory of Ms.
Lambert and it certainly does not establish her innocence.
January January
Sunday
22, 201722, 2017
Page
Page1978
976 of
of1299
2301
We are concerned regarding the discovery issues arising out of the information
made available to the police in 1992 by Kathleen Bayan and by Hazel Show. After
careful analysis of the legal obligations of the Commonwealth and the credibility of
all the witnesses involved in these two issues, we do not believe the issues provide
a basis for relief under the PCRA.
In 1992 we resolved the issue regarding the contact by First Assistant District
Attorney John A. Kenneff with defense expert witness Isidore Mihalakis, M.D., in
advance of trial. Nothing about the hearing in 1998 changes our view of that issue.
We find the issues regarding Laura Thomas's credibility, Lawrence Yunkin's black
sweatpants, the video of the river search, the statement taken of Ms. Lambert, the
photographs of the crime scene and the pearl earring to have more sensational
appeal than legal merit. The issues have generated more heat than light in this
case.
We have analyzed the many allegations of constitutional or discovery violations and
find that the Commonwealth's compliance with the Pennsylvania Rules of Criminal
Procedure regarding discovery and the requirements of Brady v. Maryland(2) has
been well established by the facts and the law.
Finally, we find no basis in law or in fact to hold either trial counsel or appellate
counsel ineffective.
On the basis of our consideration of these issues, our study of the law and our
careful consideration of the now fully developed record, we find that Ms. Lambert
has not established a basis for relief under the Post Conviction Relief Act. Our
findings on the individual issues raised by the petition will be set forth in the
sections to follow.
II. BACKGROUND
Lisa Michelle Lambert, in addition to another woman, Tabitha Faith Buck, was
charged with criminal homicide for the death of Laurie Show. The homicide took
place on December 20, 1991, in the condominium occupied by Ms. Show and her
mother, Hazel Show. Ms. Lambert was 19 years old at the time; Ms. Show was 15
years old. A third person, Lawrence Stewart Yunkin, was charged with hindering
apprehension. Ms. Lambert was Mr. Yunkin's girlfriend; she was, at the time,
pregnant to him.
A. The Trial
After waiving her right to a trial by jury, Ms. Lambert proceeded to trial and was
found guilty of first degree murder and criminal conspiracy to commit murder on
July 20, 1992. The Commonwealth elected to seek the death penalty in the
Lambert case. Following a hearing on the penalty phase, the court declined to
impose the death penalty and sentenced Ms. Lambert to a term of life in prison
without the possibility of parole.
January January
Sunday
22, 201722, 2017
Page
Page1979
977 of
of1299
2301
Ms. Lambert's post verdict motions were filed on July 28, 1992. In essence, Ms.
Lambert argued that her conviction was against the weight of the evidence. She
raised a dozen claims of error essentially challenging evidentiary or procedural
rulings,(3) but her primary thrust was that there was insufficient evidence to
support a conclusion that she was the killer of Laurie Show. The court denied Ms.
Lambert's post verdict motions in an opinion dated July 19,
1994. (4) No appeal was taken from that order.
Ms. Lambert's family then hired a new attorney who filed a request with this court
for a new trial on the basis of after-discovered evidence and the alleged
ineffectiveness of her court-appointed attorney. At the joint request of the assistant
district attorney and her privately-retained attorney, an evidentiary hearing was
conducted over a two-day period in November 1994. (5) Counsel indicated a desire
to take all issues up on appeal at that time.(6)
The post verdict evidentiary hearing addressed the issues of ineffective assistance
of counsel and after-discovered evidence. Ms. Lambert attacked only the assistance
of counsel rendered to her by Roy D. Shirk, Esquire.(7) Specifically, she claimed he
was ineffective for the following reasons: (1) failing to call character witnesses in
her defense; (2) failing to introduce evidence of abuse by Mr. Yunkin; (3) calling a
witness to contradict her testimony; (4) failing to seek suppression of statements
she made to the police; (5) failing to present evidence of bad reputation for the
veracity of witness Laura Thomas; (6) failing to seek a new trial based upon new
evidence of Mr. Yunkin's nolo contendere plea to third degree murder; and (7)
failing to impeach Mr. Yunkin with his statements to the police that he knew prior
to the death of Laurie Show of plans to physically harm her.
The after-discovered evidence was that Mr. Yunkin "lied" about his involvement in
the crime, thereby violating the terms of his plea agreement with
the District Attorney's Office.(8) Ms. Lambert argued that if she had known at trial
that Mr. Yunkin was going to violate his plea agreement and that he would admit to
third degree murder, her defense at trial would have been enhanced. New counsel
argued that "this Court was deprived of critical information--evidence that Yunkin
was not merely an accessory after the fact, but that he had deliberately lied, that
he was in breach of a plea agreement, and that he pled nolo contendere to
involvement in the killing of Laurie Show." (Defendant's Memorandum of Law in
Support of Post Verdict Motion for a New Trial at 14) The question was whether this
court, or any finder of fact, c ould reasonably have been swayed by an admission
that Mr. Yunkin had lied in his testimony at trial. A review of the record and a
consideration of the totality of the record showed that Mr. Yunkin's credibility was
dubious at best.
The court found that the "after-discovered" evidence was not really new evidence
at all. It was simply the same story introduced at the Lambert trial with a slightly
different "spin." The court denied Ms. Lambert's post verdict motion for a new trial
in an order and opinion dated March 14, 1995.
January January
Sunday
22, 201722, 2017
Page
Page1980
978 of
of1299
2301
Ms. Lambert appealed this court's findings to the Superior Court of Pennsylvania,
raising essentially the same claims regarding ineffective assistance of trial counsel
and after-discovered evidence. Specifically, Ms. Lambert claimed that her trial
counsel was ineffective for failing to introduce evidence of her good character and
of the abuse inflicted upon her by Mr. Yunkin. Ms. Lambert also argued the afterdiscovered evidence of Mr. Yunkin's plea agreement and perjury. The Superior
Court affirmed the judgment of sentence without opinion on January 4, 1996.
Commonwealth v. Lambert, 450 Pa. Super. 714, 676 A.2d 283 (1996) (table).
In her appeal to the Pennsylvania Supreme Court filed on February 2, 1996, Ms.
Lambert raised the same claims. The petition for allowance of appeal to the
Supreme Court of Pennsylvania was subsequently denied without comment on July
2, 1996. Commonwealth v. Lambert, 545 Pa. 650, 680 A.2d 1160 (1996).

Ms. Lambert never filed a petition under the Pennsylvania Post Conviction Relief
Act. Instead, she sent a handwritten pro se petition for writ of habeas corpus to the
United States District Court for the Eastern District of Pennsylvania on September
12, 1996. Counsel was appointed by the district court to represent her on a pro
bono basis and an amended petition for writ of habeas corpus was filed on January
3, 1997. The petition included the claims previously presented in state court, but
also introduced new claims asserting that (1) Ms. Lambert was "actually innocent,"
(2) that there was massive misconduct by the prosecution and the police, (3) that
after-discovered evidence created manifest injustice, and (4) that trial counsel had
been ineffective in a multitude of ways.
In its answer to the amended petition, the Commonwealth maintained that Ms.
Lambert was not entitled to federal review because she had not exhausted her
state court remedies as to all of the claims in her pleading and had committed
procedural default. In the alternative, the Commonwealth claimed that the habeas
petition should be denied on its merits. The Commonwealth explicitly stated in its
pleading that it was not waiving the exhaustion requirement in any way.
Simultaneously with the first amended petition, counsel filed a motion for
permission to take discovery, which the Commonwealth opposed. The district court
granted the motion on January 16, 1997, citing unspecified unusual circumstances,
and ordered broad, expedited discovery in the federal habeas corpus proceeding.(9)
Despite the Commonwealth's objections to the petition on the grounds of
exhaustion, the matter proceeded to an evidentiary hearing(10) on Ms. Lambert's
claims of actual innocence and prosecutorial misconduct.(11) The hearing
commenced on March 31, 1997. (12) After 14 days of testimony, the district court
granted the writ, declared Ms. Lambert to be "actually innocent," barred the
Commonwealth from conducting a retrial for the murder of Laurie Show, and
permanently released Ms. Lambert from prison.
In its 90-page memorandum opinion of April 21, 1997, the district court found
numerous instances of prosecutorial misconduct and offered its opinion that some
January January
Sunday
22, 201722, 2017
Page
Page1981
979 of
of1299
2301
of this conduct might involve criminal activity on the part of members of the
Lancaster County District Attorney's staff. The court also ruled that Ms. Lambert
had exhausted all her state claims with the exception of those based on afterdiscovered evidence. To the extent that there were claims which a Pennsylvania
court might view as not having been waived, the district court found that the state
proceedings would be ineffective to protect Ms. Lambert's rights. Lambert v.
Blackwell, 962 F. Supp. 1521, 1553-55 (E.D. Pa. 1997).
The district court referred First Assistant District Attorney Kenneff to the United
States Attorney for the Eastern District of Pennsylvania for investigation of
allegations of criminal activity in the prosecution of the Lambert homicide case. The
district court also (1) demanded that District Justice Ronald W. Savage, a former
county detective involved in the investigation of the Lambert case, be investigated
by the Judicial Conduct Board of the Pennsylvania Supreme Court, and (2) offered
its opinion that another assistant district attorney and two county detectives, one
now retired, were guilty of prosecutorial misconduct.
The district court's ruling was appealed to the Court of Appeals for the Third Circuit
on April 22, 1997. (13) On December 29, 1997, a three-judge panel of the Third
Circuit vacated the decision of the district court and remanded this case to the
district court with the direction to dismiss the federal habeas petition without
prejudice. Lambert v. Blackwell, 134 F.3d 506 (3d Cir. 1997). The Third Circuit
found that the district court was without jurisdiction to hear the case because Ms.
Lambert had not yet exhausted her state remedies. Ms. Lambert's application for
rehearing en banc was denied, with four judges dissenting.
While her application for rehearing was pending, Ms. Lambert moved for a stay of
the Third Circuit's order and also filed an emergency application seeking the same
relief from the United States Supreme Court. On February 2, 1998, the Third Circuit
refused to stay its order, as did Justice David H. Souter, as Circuit Judge, the same
day. Thereafter, petitioner surrendered to prison officials on February 4, 1998. (14)
A petition for writ of certiorari, seeking review of the Third Circuit's opinion, was
filed by petitioner on April 23, 1998, and is pending in the United States Supreme
Court, where it is docketed at No. 97-8812. On April 24, 1998, petitioner filed with
the Third Circuit an application, pursuant to Rule 23 of the Federal Rules of
Appellate Procedure, for release from custody pending the Supreme Court's
consideration of her petition for writ of certiorari. (15) This petition for release from
custody was denied by the Third Circuit in an order and opinion filed on August 3,
1998.
An unverified Post Conviction Relief Act petition was filed on behalf of Ms. Lambert
in the Court of Common Pleas of Lancaster County on February 2, 1998. (16)
Contemporaneously with the filing of the PCRA petition, Ms. Lambert's counsel filed
a petition with the Supreme Court of Pennsylvania requesting that the Supreme
Court assume King's Bench jurisdiction over this case, remove the PCRA petition
from the Court of Common Pleas of Lancaster County, render a decision based
upon the record established in the habeas corpus proceeding in district court, and
January January
Sunday
22, 201722, 2017
Page
Page1982
980 of
of1299
2301
stay the reincarceration of Ms. Lambert pending her appeal.

On February 2, 1998, the district attorney requested the Commonwealth of
Pennsylvania Office of Attorney General to assume prosecution of this case. The
Attorney General granted that request under the Commonwealth Attorneys Act,
pursuant to 71 P.S. Section 732-205(a)(3) and (c) (1990). On February 9, 1998,
the Attorney General entered an appearance and filed pleadings in the Supreme
Court. On February 10, 1998, Ms. Lambert's attorneys asked the Supreme Court of
Pennsylvania to remove the Attorney General as counsel for the Commonwealth.
The Supreme Court denied petitioner's request for King's Bench jurisdiction and
issued an order dated February 25, 1998, remanding the PCRA petition to the Court
of Common Pleas of Lancaster County with a directive that the petition be disposed
of within 120 days.(17) The Court also dismissed the motion to compel removal of
the Attorney General without prejudice to petitioner's right to refile that motion in
the Court of Common Pleas. Lastly, the emergency motion for writ of prohibition to
prevent the reincarceration of petitioner was dismissed as moot, petitioner having
returned to prison on February 4, 1998.
This court obtained a copy of the order of the Supreme Court on March 2, 1998. (18)
The PCRA petition also was received in chambers on March 2, 1998. A copy of
petitioner's motion to disqualify the Attorney General was forwarded to the court on
March 4, 1998. A response was sent by the Attorney General on March 5, 1998,
and a hearing was held on this matter on March 6, 1998. (19)
Ms. Lambert's motion to compel removal of the Attorney General as counsel was
denied in an opinion and order dated March 11, 1998, the court having held that
the Attorney General had the power to prosecute the PCRA petition pursuant to 71
P.S. Section 732-205. Upon motion of counsel for petitioner, an additional order
was entered on March 11, 1998, directing the Commonwealth to file an answer to
the PCRA petition. The Attorney General subsequently filed a response to Ms.
Lambert's PCRA petition on behalf of the Commonwealth on March 31, 1998.
The original PCRA petition contained some 57 claims of after-discovered evidence,
117 claims of prosecutorial misconduct, including 45 claims of Brady/Giglio
violations, and 21 claims of ineffective assistance of counsel. For this reason, the
court did not impose an expedited deadline on the filing of an answer, but chose to
require an answer within the 20 days which would normally be required under the
Pennsylvania Rules of Civil Procedure for an answer to a complaint or a petition.
The Commonwealth's filing of an answer in 20 days in no way delayed the
proceeding, due to the plethora of motions filed by petitioner, which are chronicled
below.
On March 6, 1998, the court issued an "Order Limiting Publicity" which contained
the text of Rule 3.6 of the Rules of Professional Conduct.(20) This was the subject of
collateral litigation in this court which took place in March 1998 and which resulted
in a modification of the original order. (21) For a discussion, see Commonwealth v.
Lambert, 76 Lanc. L. Rev. 184 (1998), now pending in the Superior Court.
In addition to the motion to remove the attorney general, petitioner filed an
additional 17 prehearing motions or petitions for the court's consideration over an
eight-week period. Most of these matters were briefed by the parties; all were
January January
Sunday
22, 201722, 2017
Page
Page1983
981 of
of1299
2301
argued orally before the court at petitioner's request. Petitioner's additional filings
will be set forth seriatim in chronological order.
On March 11, 1998, petitioner filed a motion to file the record of the habeas corpus
hearing before the federal district court with this PCRA court and to deny a hearing
on the issues covered therein. Received with this approximately 50-page motion
were 30 volumes of the Federal Court of Appeals' Appendix. After the issues were
briefed by the parties and argued by counsel, the court denied petitioner's motion
to enter the federal record as the record in this PCRA proceeding in an opinion and
order entered on April 6, 1998. (22) See Commonwealth v. Lambert, 76 Lanc. L.
Rev. 169 (1998).
Because Ms. Lambert's petition and the Commonwealth's response thereto raised
material issues of fact, the court, on April 6, 1998, entered an order scheduling a
hearing on the petition pursuant to Pa. R. Crim. P. 1508. A prehearing conference
was scheduled for April 9, 1998.
Ms. Lambert's counsel made oral motions at the prehearing conference on April 9,
1998, to have themselves and their law firm appointed as counsel for petitioner. In
the alternative, counsel requested that petitioner be permitted to proceed in forma
pauperis so that they could be reimbursed all costs incurred on petitioner's behalf.
Written motions regarding the appointment of counsel, the in forma pauperis status
of petitioner, and the reimbursement of costs were subsequently filed with the
Clerk of Courts on April 15, 1998.
Included in petitioner's prehearing memorandum of April 21, 1998, was a written
request to incorporate admissions of the Commo nwealth "actors" from prior
proceedings, as well as all of the police reports, police notes, and other documents
turned over by the Commonwealth during the federal proceeding. The
Commonwealth responded on April 20, 1998, with a motion in limine directed to
Ms. Lambert's proposed introduction of prior federal testimony as "admissions." On
April 23, 1998, after hearing argument from counsel, the court denied petitioner's
request to incorporate certain portions of the testimony from the federal habeas
proceeding as admissions against the Commonwealth in the PCRA proceeding.(23)
Petitioner next presented to the court on March 13, 1998, a 119-page motion for
bail and release on her own recognizance pending disposition of her PCRA petition
by this court. The parties filed legal memoranda and presented oral argument. An
opinion and order were entered on April 3, 1998, denying petitioner's motion for
bail. (24) See Commonwealth v. Lambert, No. 0423-1992, slip op. (Lanc. Co. C.P.
April 3, 1998).
Petitioner's first motion for discovery was received by the court on April 3, 1998,
and argued before the court at the first prehearing conference on April 9, 1998. At
the conclusion of the argument, the court issued a ruling from the bench regarding
the various discovery matters raised in petitioner's first discovery motion.(25)
Specifically, the court denied petitioner's request to (1) depose inmates at SCIDallas relative to statements allegedly made by Mr. Yunkin, (2) depose "Smokey"
Roberts regarding the existence of a report or log of his diving shoots, (3) obtain
discovery of the Commonwealth's "discriminate use of PCRA rules," (4) obtain
discovery of the Commonwealth's "purpose" in pursuing Ms. Lambert's PCRA, and
January January
Sunday
22, 201722, 2017
Page
Page1984
982 of
of1299
2301
(5) obtain discovery of the Commonwealth's efforts to "intimidate" the judiciary

over the Lambert case. The court did grant petitioner's request for any logs
maintained by the police of all photographs taken by police in the murder
investigation, directing the Commonwealth to determine if they existed and, if so,
to produce them to petitioner.
On April 6, 1998, petitioner served a change of venue motion on the court. This
was followed on April 8, 1998, with a motion for definite pleading by the
Commonwealth on the issues of waiver and other procedural requirements under
the PCRA and for a determination by the court whether it would raise such issues
sua sponte. On April 15, 1998, petitioner filed a motion for sanctions against John
Show, the victim's father, and Justice Ronald Savage, a former officer with the East
Lampeter Police Department, for violation of the original "Order Limiting Publicity."
These three outstanding motions were argued via a speaker phone in the
courtroom at the second prehearing conference on April 21, 1998. (26)
Petitioner's counsel began the April 21, 1998, conference by requesting the
disqualification of this court pursuant to Rule 3(C)(1)(a) of the Rules of Professional
Responsibility. Counsel argued that because the court viewed a piece of evidence at
the 1992 trial in this matter, the court could be a fact witness at the PCRA
proceeding as to the physical nature of that evidence. Specific ally, Ms. Lambert
argued that the sweatpants introduced into evidence at the 1992 trial were not the
same sweatpants introduced at the federal habeas hearing in 1997. Counsel for
petitioner asserted that this court had personal knowledge of a disputed evidentiary
matter which required recusal. This court's findings regarding the size of the
clothing and its significance at trial were clearly stated in our July 19, 1994,
opinion. See Section IV, infra. Ms. Lambert's request was denied on the record
after the court considered the arguments of counsel.
The parties thereafter addressed the change of venue issue, the motion for definite
pleading by the Commonwealth, the motion for sanctions for violation of the "gag"
order, the motion for appointment of counsel, and the motion for reimbursement of
costs. At the conclusion of this first prehearing, the court issued oral rulings from
the bench denying the motion for a more definite pleading and denying the motion
for sanctions.(27) The court reserved its ruling on the other matters.
On April 23, 1998, the court held a third prehearing conference via a speaker
phone in the courtroom. Counsel discussed Ms. Lambert's petition to proceed in
forma pauperis, the request for reimbursement of costs, the motion for
appointment of counsel, and the change of venue motion. Immediately following
this conference on April 23, 1998, the court entered a written order confirming
rulings made from the bench and disposing of several other of petitioner's motions.
Specifically, (1) the court denied the motion for more definite pleading, (2) the
court denied as moot the motion for sanctions for violations of the gag order, (3)
the court denied the motion to sit outside Lancaster County, (4) the court denied
petitioner's request to incorporate certain admissions from the federal habeas
hearing, (5) the court granted the motion to proceed in forma pauperis and to have
all costs necessary for the PCRA proceeding reimbursed by the County, and (6) the
court denied the motion for court appointment of defense counsel. (28)
A second motion for discovery was filed by Ms. Lambert on April 28, 1998. In this
motion, petitioner requested (1) all evidence favorable to her which had not
January January
Sunday
22, 201722, 2017
Page
Page1985
983 of
of1299
2301
previously been disclosed, (2) a summary of the anticipated testimony of each

witness the Commonwealth intended to call, (3) the addresses and telephone
numbers of all Commonwealth witnesses, (4) all evidence of any prior statements
that were inconsistent with testimony that the Commonwealth intended to offer in
the PCRA proceeding, (5) all documents that related to or embodied agreements or
proposed or prospective agreements between Commonwealth witnesses and/or
their counsel in exchange for testimony in the PCRA proceeding, (6) a copy of all
exhibits that the Commonwealth intended to use, and (7) the Commonwealth's
impressio ns as to why Tabitha Buck may have been untruthful in her federal
deposition.(29) The court granted petitioner's request for all Brady/Giglio (30)
materials, the addresses and telephone numbers of Commonwealth witnesses, and
copies of all Commonwealth exhibits. The remaining discovery requests were
denied.
On April 30, 1998, the first day the court heard testimony in this PCRA proceeding,
petitioner moved for leave to amend the PCRA petition. This motion was granted
the same day. In addition, petitioner filed three motions on April 30, 1998, all of
which were argued in open court.
The first was a motion to admit the federal court testimony of Haresh G.
Mirchandani, M.D., the chief medical examiner for Philadelphia. Dr. Mirchandani had
recently declined to appear as an expert witness for petitioner in her PCRA
proceeding in Lancaster. An order was entered on April 30, 1998, denying the
motion to admit the prior federal court testimony of Dr. Mirchandani as he was not
an "unavailable witness" as that term is defined in 42 Pa. C.S.A. Section 5917.
The second motion requested transcripts and corresponding ASCII disks of all
prehearing matters, as well as the PCRA proceeding. The court ordered that
transcripts be given to petitioner but declined to order the court reporters to
produce ASCII disks.
Lastly, on April 30, 1998, Ms. Lambert petitioned the court to retain an investigator
to assist in her case. An order was entered on May 13, 1998, granting this motion
and authorizing an investigator to be compensated by the court at the rate of
$40.00 per hour with a maximum allowable expense of $1,000.00 for the
investigation.(31) Petitioner subsequently filed a second motion for appointment of
an investigator to assist in her rebuttal case, which this court approved on June 16,
1998.
During the course of the PCRA hearing, petitioner presented seven additional
motions to the court. On May 28, 1998, petitioner filed a motion to subpoena the
bank statements, canceled checks, and church wedding records of Officer John
Bowman and his wife. This motion was granted on June 16, 1998, after an inchambers conference with counsel for the Bowmans.
Petitioner also filed motions in limine to preclude the expert testimony of three
Commonwealth witnesses: (1) Roger J. Levin, M.D., an otolaryngologist; (2) Wayne
K. Ross, M.D., a forensic pathologist; and (3) Joseph L. Burton, M.D., a forensic
pathologist.(32) Additionally, counsel for petitioner filed a motion in limine to
preclude all evidence not introduced at the 1992 trial and to limit the
Commonwealth's witnesses. Following oral argument by counsel, these motions in
January January
Sunday
22, 201722, 2017
Page
Page1986
984 of
of1299
2301
limine were denied by the court on June 16, 1998.

The last two motions were filed by petitioner on June 10, 1998, at the close of her
case. Petitioner submitted a list of admissions to be offered into evidence. Those
proposed admissions will be addressed in this opinion in Section VII.P, infra. She
also filed a second motion for leave to amend the petition, which was granted on
June 16, 1998.
The Commonwealth filed two prehearing motions. As discussed previously, the
Commonwealth filed a motion in limine objecting to the proposed use of federal
testimony as admissions in the PCRA proceeding. The court denied petitioner's
request to incorporate the testimony of Commonwealth "actors" as admissions and,
in effect, granted the Commonwealth's first motion in limine.
On April 27, 1998, the Commonwealth filed a second motion in limine to preclude
the testimony of Ann W. Burgess, Ph.D., on the issue of "battered person
syndrome." After briefing and argument by the parties, the court denied the
Commonwealth's motion in limine on May 18, 1998, and permitted the testimony of
Dr. Burgess in this proceeding.(33)
The Commonwealth's last motion in limine was filed on May 12, 1998, during the
course of the proceeding. This motion sought to preclude the testimony of
Professor Charles W. Wolfram on legal ethics and the propriety of lawyers' conduct.
After reviewing the parties' briefs and hearing oral argument on the issue, the court
granted this motion in limine on May 18, 1998. (34) The hearing commenced on April
30, 1998. (35) Petitioner presented 73 witnesses and offered the admission of 478
exhibits. She rested her case on June 11, 1998.
The Commonwealth presented 39 witnesses and offered the admission of 123
exhibits. The Commonwealth rested its case June 22, 1998. Closing arguments
were held on June 24, 1998, lasting a full day.
The record includes 36 volumes of notes of testimony (more than 8,000 pages) and
601 exhibits. The court addressed 28 motions, wrote four opinions, and issued 28
orders. It heard oral argument on outstanding legal matters on at least three
occasions prior to the hearing and additionally held three prehearing conferences.
The PCRA hearing itself covered 38 days in court over an eight- week period.
At the conclusion of the hearing, the court was asked to decide petitioner's claims
of 157 allegations of prosecutorial misconduct, including 66 allegations of
Brady/Giglio violations, 72 allegations of after-discovered evidence, and 28
allegations of ineffective assistance of c ounsel.
The petitioner must establish that an error or defect in her case resulted in a
"fundamentally unfair conviction." Commonwealth v. Carbone, --- Pa. ---, 707
A.2d 1145, 1148 (1998) (quoting Commonwealth v. Weinder, 395 Pa. Super.
608, 626-27, 577 A.2d 1364, 1374 (1990)). The purpose of the PCRA is to provide
January January
Sunday
22, 201722, 2017
Page
Page1987
985 of
of1299
2301
a means of obtaining collateral relief for those persons who did not commit the
crimes for which they have been convicted, or who are serving sentences longer
than the legal maximum. 42 Pa. C.S.A. Section 9542. It is not a means of relitigating issues that have already been addressed on direct appeal, or which could
have been raised earlier. Commonwealth v. Buehl, 540 Pa. 493, 500, 658 A.2d
771, 775 (1995).
To obtain relief under the PCRA, the petitioner must prove, by a fair preponderance
of the evidence, that her conviction was the result of:
(1) a violation of the Constitution of Pennsylvania or the Constitution or laws of the
United States, which, under the circumstances, so undermined the truthdetermining process that no reliable adjudication of guilt or innocence could have
taken place, 42 Pa. C.S.A. Section 9543(a)(2)(I); or
(2) the ineffective assistance of counsel, at trial or on appeal, which, under the
circumstances, so undermined the truth-determining process that no reliable
adjudication of guilt or innocence could have taken place, 42 Pa. C.S.A. Section
9543(a)(2)(ii); or
(3) the unavailability at the time of trial of exculpatory evidence that has
subsequently become available and which would have changed the outcome of the
trial if it had been introduced, 42 Pa. C.S.A. Section 9543(a)(2)(vi).
These elements under a PCRA claim provide general categories for consideration of
the many claims asserted by Ms. Lambert. To further explain the process by which
this court must evaluate Ms. Lambert's claims for relief, we discuss the elements of
a PCRA case in the subsections to follow.
The question of prosecutorial misconduct is by far the most troubling in this case.
This is the area where concerns about the integrity of the system, the corruption of
the criminal trial process, and alleged unethical conduct by the prosecuting
attorney and the investigating detectives come under sharp scrutiny. This is an
area rife with emotion and a distracting level of hyperbole. The history of this case
teaches that reasoned analysis of the prosecutorial misconduct issues can easily
give way to rhetorical flourish and personal outrage. Yet, no issue is well resolved
through the barometer of personal feelings of advocates or a ground swell of
community opinion or media coverage. It is necessary to look at the law to
determine what might constitute prosecutorial misconduct and then to look directly
to the facts of this case to analyze what happened, what did not, and what it might
mean.
The issue of prosecutorial misconduct is subject to an analysis under the PCRA
statute and under the Pennsylvania Supreme Court decision in Commonwealth v.
Smith, 532 Pa. 177, 615 A.2d 321 (1992).
There is no specific provision for prosecutorial misconduct under the PCRA.
However, the Act provides that a petitioner, to be eligible for relief, must plead and
January January
Sunday
22, 201722, 2017
Page
Page1988
986 of
of1299
2301
prove by a preponderance of the evidence that her conviction resulted from:

A violation of the Constitution of this Commonwealth or the Constitution or laws of
the United States which, in the circumstances of the particular case, so undermined
the truth-determining process that no reliable adjudication of guilt or innocence
could have taken place.
42 Pa. C.S.A. Section 9543(a)(2)(i). Ms. Lambert claims that police and
prosecutors' misconduct deprived her of due process. She further contends that the
Commonwealth's failure to disclose certain information to her trial counsel was a
constitutional violation.
A second focus in the prosecutorial misconduct area is Smith. The Pennsylvania
Supreme Court in Smith held that the double jeopardy clause of the Pennsylvania
constitution prohibits the retrial of a defendant (1) when prosecutorial misconduct
is intended to provoke the defendant into moving for a mistrial, or (2) when the
conduct of the prosecutor is intentionally undertaken to prejudice the defendant to
the point of the denial of a fair trial. 532 Pa. at 186, 615 A.2d at 325.
In Smith, there were two incidents of intentional prosecutorial misconduct. The
first concerned adhesive lifters. Certain adhesive lifters were used at the autopsy to
remove granular particles which looked like sand from between the victim's toes.
These adhesive lifters were discovered by the Commonwealth during the Smith trial
but were not disclosed to Smith's defense counsel. The prosecutor wrote a memo
saying, "It is obvious from [defense counsel's] tactics thus far that he will attempt
to establish that Mrs. Reinert was killed at the shore in Cape May, New Jersey by
William Bradfield, Chris Pappas, and Susan Myers. The sand, therefore, is
extremely materia l to the defense case." 532 Pa. at 182, 615 A.2d at 323. The
Commonwealth's theory in Smith was that the victim was murdered in
Pennsylvania. The defense theory was that she was murdered in Cape May, New
Jersey, and the sand in her toes would have supported the defense position. Yet
the Commonwealth did not disclose the existence of the sand between the toes of
the victim.
The second incident involved denial of an agreement with a witness. The Court
found that the Commonwealth deliberately denied the existence of an agreement
under which its witness, Mr. Martray, received lenient treatment at sentencing in
return for testimony against Smith. 532 Pa. at 181, 615 A.2d at 322-23.
For purposes of this opinion, the alleged prosecutorial misconduct will be
considered to determine whether it was intended to provoke Ms. Lambert into
moving for a mistrial or whether it was intentionally undertaken to prejudice
defendant to the point of the denial of a fair trial. 532 Pa. at 186, 615 A.2d at 325.
Ms. Lambert also argues that failure to turn over exculpatory evidence violated her
constitutional rights as set forth in Brady. In Brady, the United States Supreme
Court held that "the suppression by the prosecutor of evidence favorable to an
accused upon request violates due process where the evidence is material either to
guilt or to punishment, irrespective of the good faith or bad faith of the
prosecutor." 373 U.S. at 104. Pennsylvania promulgated Criminal Rule of Procedure
305(B)(1) in response to Brady, requiring Commonwealth disclosure to defense
counsel, upon request, of "any evidence favorable to the accused which is material
January January
Sunday
22, 201722, 2017
Page
Page1989
987 of
of1299
2301
either to guilt or to punishment, and which is within the possession of the attorney
for the Commonwealth." Pa. R. Crim. P. 305(B)(1)(a).
When the reliability of a witness may be determinative of the guilt or innocence of
an accused, nondisclosure of evidence affecting the credibility of witnesses falls
within the general rule as pronounced by Brady. Giglio, 405 U.S. at 154.
Undisclosed evidence is "material" under Brady, however, only "if there is a
reasonable probability that, had the evidence been disclosed to the defense, the
result of the proceeding would have been different." United States v. Bagley, 473
U.S. 667, 682 (1985). The prosecution in Bagley failed to disclose impeachment
material about its two key witnesses: the witnesses had contracts with the
government to pay them money commensurate with information furnished. This
violated respondent's due process rights under Brady. Bagley, 473 U.S. at 671.
The Supreme Court shed yet more light on the materiality issue by pronouncing
that "a showing of materiality does not require demonstration by a preponderance
that disclosure of the suppressed evidence would have resulted ultimately in the
defendant's acquittal," and that Brady is violated "by showing that the favorable
evidence could reasonably be taken to put the whole case in such a different light
as to undermine confidence in the verdict." Kyles v. Whitley, 514 U.S. 419, 435
(1995). Kyles also adds to the materiality test that suppressed evidence must be
considered collectively, rather than just item by item. Id. at 507.
However, a defendant is not entitled to the benefit of the Brady doctrine "[w]here
the exculpatory information is not only available to the defendant but also lies in a
source where a reasonable defendant would have looked." Barnes v. Thompson,
58 F.3d 971, 975 (4th Cir. 1995) (citations omitted). See Commonwealth v.
McElroy, 445 Pa. Super. 336, 352, 665 A.2d 813, 820 (1995) (citing Gelormo,
327 Pa. Super. at 231, 475 A.2d at 771, indicating that Rule 305(B)(1) is not
intended to apply where defense counsel has equal access to evidence it seeks to
compel).
Most recently, the Supreme Court of Pennsylvania held that "the Brady rule is not
an all-encompassing directive to the prosecution to disclose all evidence in its
possession to a criminal defendant." Commonwealth v. Appel, 547 Pa. 171, 203,
689 A.2d 891, 907 (1997). The evidence that was the subject of Appel's alleged
Brady violation was statements made by people who knew the appellant which
were descriptive of his strange behavior and unusual ideas. Appellant maintained
that the Commonwealth had a duty to disclose this information to the defense or
the trial court to be considered in determining his competency. The court held that
the statements were not relevant to Appel's guilt or innocence, but merely to his
competency, and as such did not violate the rule as pronounced in Brady. Appel,
547 Pa. at 203, 689 A.2d at 907.
The PCRA requires a petitioner to plead and prove ineffective assistance of counsel
which so undermined the truth-determining process that no reliable adjudication of
guilt or innocence could have taken place. 42 Pa. C.S.A. Section 9543(a)(2)(ii);
Appel, 547 Pa. at 199-201, 689 A.2d at 905. Petitioner must prove: (1) there is
merit to the underlying claim; (2) counsel had no reasonable basis for his course of
conduct; and (3) there is a reasonable probability that but for the act or omission in
January January
Sunday
22, 201722, 2017
Page
Page1990
988 of
of1299
2301
question the outcome of the proceeding would have been different.

Commonwealth v. Douglas, 537 Pa. 588, 597, 645 A.2d 226, 230 (1994) (citing
Commonwealth v. Pierce, 515 Pa. 153, 527 A.2d 973 (1987)) (referred to
hereafter as the "Douglas/Pierce" test). "Prejudice in the context of a claim of
ineffective assistance of counsel is determined by an evaluation of whether 'but for
the arguably ineffective act or omission there is a reasonable probability that the
result would have been different.'" Commonwealth v. Sneeringer, 447 Pa.
Super. 241, 248, 668 A.2d 1167, 1170 (1995) (quoting Commonwealth v.
Donahue, 428 Pa. Super. 259, 282, 630 A.2d 1238, 1249-50 (1993)).
A petitioner cannot obtain post-conviction review of claims previously litigated on
appeal by alleging ineffective assistance of prior counsel and presenting new
theories of relief to support previously litigated claims. Commonwealth v.
Peterkin, 538 Pa. 455, 460-61, 649 A.2d 121, 123 (1994), cert. denied, 515 U.S.
137 (1995). Further, counsel cannot be considered ineffective for failing to assert a
meritless claim and is presumed to have been effective. Id.; Commonwealth v.
Marshall, 534 Pa. 488, 633 A.2d 1100 (1993). See Commonwealth v. Henry, --Pa. ---, 706 A.2d 313, 323 (1997); Commonwealth v. Baker, 531 Pa. 541, 562,
614 A.2d 663, 673 (1992).
When the three prongs of the Douglas/Pierce standard are met, the petitioner is
then required to demonstrate that the ineffectiveness rendered the truthdetermining process inherently unreliable. 42 Pa. C.S.A. Section 9543(a)(2)(ii). In
Buehl, a plurality decision, the Supreme Court was divided on the issue of whether
this statutory requirement is merely a restatement of the prejudice standard set
forth in Douglas/Pierce, which requires a "reasonable probability" that but for the
ineffectiveness the outcome of the proceeding would have been different, or
whether it constitutes a higher burden for the petitioner in a PCRA proceeding. The
lead opinion in Buehl held that the PCRA requires a more stringent showing of
prejudice than that required on direct appeal. Buehl, 540 Pa. at 505, 658 A.2d at
777. In Buehl, the plurality found that counsel was ineffective for failing to request
a cautionary instruction regarding the use of other crimes evidence but concluded
that "while we are able to say that due to the prejudicial nature of the evidence in
question the outcome of Appellant's trial may have been different . . . we are
unable to say that due to the omission the adjudication of guilt is unreliable." Id. at
508, 658 A.2d at 779. This conclusion was based on the court's finding that all the
evidence in the case "created overwhelming evidence of Appellant's guilt." Id.
In Buehl, Chief Justice Nix, concurring, and Justices Cappy and Flaherty, in
dissent, concluded that there is no distinction between the prejudice prong of the
test in Pierce and the language of the PCRA requiring proof that counsel's
ineffectiveness "so undermined the truth-determining process that no reliable
adjudication of guilt or innocence could have taken place." Justices Cappy and
Flaherty expressed the view that a determination that counsel's ineffectiveness
may have resulted in a different outcome necessarily renders the truth-determining
process unreliable. Buehl, 540 Pa. at 515, 658 A.2d at 786 (Cappy, J., dissenting).
The Superior Court subsequently held that there is no substantive distinction
between the prejudice standard applicable on direct appeal and the prejudice
standard applicable under the PCRA. Commonwealth v. Kimball, 453 Pa. Super.
193, 199-200, 683 A.2d 666, 669 (1996) (en banc), allocatur granted, 548 Pa.
615, 693 A.2d 587 (1997). See Carbone, --- Pa. at ---, 707 A.2d at 1153. This
January January
Sunday
22, 201722, 2017
Page
Page1991
989 of
of1299
2301
position would seem to be supported by recent cases of the Supreme Court in

which the Court has stated that to prevail on an ineffectiveness claim raised under
the PCRA, the defendant must demonstrate the three elements of the
Douglas/Pierce test only. See, e.g., Commonwealth v. Henry, --- Pa. at ---,
706 A.2d at 323; Appel, 547 Pa. at 199-200, 689 A.2d at 905.
evidence
After-discovered evidence can provide the basis for a remedy on a collateral appeal
, under the PCRA. The petitioner must prove: (1) the evidence must have been
unavailable at the time of trial; (2) the evidence must be exculpatory; and (3) the
evidence must be of such a quality that it would change the outcome of the trial.
Commonwealth v. Bonaccurso, 425 Pa. Super. 479, 484, 625 A.2d 1197, 1199
(1993); 42 Pa. C.S.A. Section 9543(a)(2)(vi). To grant such relief the court must
be satisfied that the evidence "could not have been obtained at trial by reasonable
diligence, that it is not cumulative or of such a nature that it merely impeaches
credibility, and that it would be likely to compel a different result."
Commonwealth v. Reese, 444 Pa. Super. 38, 44-45, 663 A.2d 206, 209 (1995).
See Commonwealth v. Schuck, 401 Pa. 222, 229, 164 A.2d 13, 17 (1960), cert.
denied, 368 U.S. 884 (1961).
Unlike the test for ineffective assistance of counsel which focuses on the reliability
of the truth-determining process, after-discovered evidence claims focus on
whether that evidence "would have changed the outcome of the trial if it had been
introduced." 42 Pa. C.S.A. Section 9543(a)(2)(vi) (amended November 1995,
effective January 16, 1996).(36) In granting a new trial in Bonaccurso, the PCRA
court made two crucial credibility determinations: that the after-discovered
witness's testimony was reliable and that the defendant did not have the
opportunity to tell his story to the court at the original trial because of counsel's
ineffectiveness for presenting the wrong defense.
In a concurring opinion in Bonaccurso, Judge Beck of the Superior Court noted
that the after-discovered evidence must independently and reliably corroborate the
defense theory presented at trial. She noted her concern that the majority opinion
in Bonaccurso could lead to "hindsight justice." 425 Pa. Super. at 489, 625 A.2d
at 1202. Judge Beck noted that generally defendants will not likely succeed in
obtaining collateral relief based upon new theories inconsistent with their trial
defense.
The standard for after-discovered evidence is more strict than for a Brady/Giglio
disclosure violation and the reason for this difference has been explained by the
United States Supreme Court:
[T]he fact that such evidence was available to the prosecutor and not submitted to
the defense places it in a different category than if it had simply been discovered
from a neutral source after trial. For that reason the defendant should not have to
satisfy the severe burden of demonstrating that newly discovered evidence
probably would have resulted in acquittal. If the standard applied to the usual
motion for a new trial based on newly discovered evidence were the same when the
evidence was in the State's possession as when it was found in a neutral source,
there would be no special significance to the prosecutor's obligation to serve the
January January
Sunday
22, 201722, 2017
Page
Page1992
990 of
of1299
2301
cause of justice.
United States v. Agurs, 427 U.S. 97, 111 (1976). This explains why a petitioner
may prevail upon her Brady claims where her after-discovered evidence claims
provide no relief. Commonwealth v. Galloway, 433 Pa. Super. 222, 227 n.5, 640
A.2d 454, 457 n.5 (1994).
An issue is deemed finally litigated if (1) the highest appellate court in , which a
petitioner could have had review as a matter of right has ruled on the merits of the
issue, Commonwealth v. Szuchon, 548 Pa. 37, 41, 693 A.2d 959, 961 (1997), or
(2) the issue has been raised and decided in a proceeding collaterally attacking the
conviction or sentence. 42 Pa. C.S.A. Section 9544(a); Appel,, 547 Pa. at 186, 689
A.2d , a, t 898. Allegations of ineffectiveness of counsel may not be used to obtain
subsequent review of an issue that has previously been found to be without merit.
Commonwealth v. DeHart, 539 Pa. 5, 17, 650 A.2d 38, 44 (1994). The PCRA
petitioner must plead and prove that the failure to litigate the issue prior to trial,
during trial, or on direct appeal could not have been the result of any "rational,
strategic or tactical decision by counsel." 42 Pa. C.S.A. Section 9543(a)(4).
If the allegations of error have not been fully litigated, the PCRA also requires that
a petitioner demonstrate that these allegations of error have not been waived. An
issue is deemed waived if the petitioner could have raised it but failed to do so
before trial, at trial, during unitary review, on appeal, or in a prior state post
conviction proceeding. 42 Pa. C.S.A. Section 9544(b). To obtain review of such an
issue, the petitioner must show that his failure to appeal a ruling or raise an issue
was not knowing and intentional. Commonwealth v. Craddock, 370 Pa. Super.
139, 142-43, 535 A.2d 1189, 1191 (1988), aff'd, 522 Pa. 491, 564 A.2d 151
(1989).
Finally, the PCRA requires that all petitions be filed within one year of the date the
judgment becomes final, which is either at the conclusion of direct review, or at the
expiration of the deadline for seeking review. 42 Pa. C.S.A. Section 9545(b)(3).
The PCRA statute and the case law provide certain elements which the petitioner
must establish by a preponderance of the evidence in each of the several areas she
asserts. Each section requires the judge to determine what impact the evidence in
question would have had at trial. The after-discovered evidence must have been
unavailable, exculpatory and would have changed the outcome of the trial if it had
been introduced. The prosecutorial misconduct charges require the court to
determine whether the constitutional violations so undermined the truthdetermining process that no reliable adjudication of guilt or innocence could have
taken place. Similarly, the PCRA requires a petitioner to establish ineffective
assistance of counsel which rendered the truth-determining process unreliable.
For there to be a Brady violation, the petitioner must prove that the
Commonwealth failed to disclose exculpatory evidence or favorable evidence which
January January
Sunday
22, 201722, 2017
Page
Page1993
991 of
of1299
2301
was "material." Brady, 373 U.S. at 87-88. "Material" has been defined as follows:
The evidence is material only if there is a reasonable probability that, had the
evidence been disclosed to the defense, the result of the proceeding would have
been
different. A 'reasonable probability' is a probability sufficient to undermine
confidence in the outcome.
Galloway, 433 Pa. Super. at 229, 640 A.2d at 457 (quoting Bagley, 473 U.S. at
682). The Brady claims then require the court to find that the result of the
proceeding would have been different had the material evidence been disclosed.
In each of these four major areas, there is an element for the trial court to
determine whether the alleged misconduct, Brady violations, after-discovered
evidence or ineffective assistance of counsel would have made a difference to the
outcome of the trial. Would the after-discovered evidence have "changed the
outcome of the trial?" Did the prosecutorial misconduct "so undermine the truthdetermining process that no reliable adjudication of guilt or innocence could have
taken place?" Did the Brady violations involve "material" evidence, i.e., would the
evidence have changed the outcome of the trial? Did the ineffective assistance of
counsel render the truth-determining process unreliable?
In this case, the judge sitting in review of the PCRA claims also sat without a jury in
the 1992 trial. In a typical case, a PCRA court would consider claims of afterdiscovered evidence, prosecutorial misconduct, ineffective assistance or Brady
violations and make its best judgment as to what would have influenced the jury.
In the case of a constitutional violation, the truth-determining process would have
been the jury's analysis and deliberations on the verdict. The court could speculate
about what would have mattered to the jury and what would not have mattered.
And so it goes for the after-discovered evidence, the Brady violations and the
ineffective assistance claims.
In this case, however, there was no jury and there is no need for this court to
project what might have mattered and what might have affected the jury's analysis
of the case. Here, the court listened to the evidence in 1992, considered the
arguments of counsel and determined a verdict. This court is in a unique position to
say what would have made a difference in the truth-determining process in 1992.
This court knows what affected the outcome of the case, knows what was
important in the truth-determining process and knows what was material.
Our research has disclosed no appellate case law on the standard to be applied to a
PCRA petition to a court who heard the initial case non-jury. It seems to make
sense that the court in the unique position of hearing a case non-jury would have
insight into the basis for the verdict that would not be available to a judge in a jury
trial. To speculate about the impact of certain evidence on a jury when in reality
the court itself heard the evidence and made the decision would seem both
unproductive and unnecessary. For example, how could this court in good
conscience find that after-discovered evidence would have changed the outcome of
the trial were a jury to hear the new evidence when, in reality, this court knows
January January
Sunday
22, 201722, 2017
Page
Page1994
992 of
of1299
2301
that it would not have changed the outcome?

This is one practical consequence of petitioner's decision to waive her right to a jury
trial in 1992. In all the appeals, motions and petitions which followed since the
verdict in 1992, never once has petitioner contended that her decision to proceed
non-jury was improper. Never once has she contended that Attorney Shirk was
ineffective for advising her to proceed non-jury, never once has she argued that
her waiver was something other than knowing and voluntary, and never once has
she challenged the colloquy which led to the court approval of her waiver of a jury
trial. In fact, it is likely that petitioner views that decision as a successful decision.
In any event, by her choice to proceed non-jury, petitioner has afforded this court
an insight into the PCRA issues which would not otherwise have been available had
the case been tried with a jury.
Early in petitioner's case, she called Lieutenant Renee L. Schuler(37) as a witness.
Petitioner's counsel requested permission to cross-examine this witness because
she was "hostile" or "adverse." This request was denied. On May 4, 1998, petitioner
called retired Pennsylvania State Police Officer Carl S. Harnish. The request to treat
the witness as hostile or adverse was renewed. We asked for case authority and
each side presented legal argument.
Petitioner cited Commonwealth v. Butler, 529 Pa. 7, 601 A.2d 268 (1991), in
support of her request that she be allowed to cross-examine police witnesses on
direct. Mr. Greenberg argued on behalf of petitioner that these proceedings went
directly to the workings of the criminal justice system, that the police witnesses in
this proceeding were hostile and adverse, as those terms are used in the law, and
that justice required that petitioner be allowed to cross-examine each witness and
to proceed with leading questions rather than standard direct examination. This
court considered Butler and found it to provide no support for petitioner's
contention.(38) We indicated at that time that the question of a police witness being
hostile or adverse could not be addressed in a blanket ruling. The court promised to
consider the situation as to each witness and make a determination before, or
during, that witness's testimony about whether the witness would be treated as a
hostile or adverse witness.
We advised counsel that "hostility" required a showing of surprise during the
witness's testimony or an obvious lack of cooperation, reluctance or evasiveness in
answering questions. As to whether a witness is "adverse," the court informed
counsel that such a declaration required a showing that the witness had a direct
personal interest in the outcome of the litigation.
This same analysis was applied when former Detective Ronald C. Barley testified.
On May 5, 1998, at the beginning of the afternoon session and during the time Mr.
Barley was on the stand, Mr. Greenberg asked if he might "put a position on the
record." He was given permission and made the following statement:
Your Honor, I feel obligated to put this position on the record to establish what our
position is going forward in this proceeding so there's no subsequent question. And
January January
Sunday
22, 201722, 2017
Page
Page1995
993 of
of1299
2301
I want to assure the court that I'm not taking this position lightly.
The situation that I predicted yesterday is exactly as I then suggested. By
immunizing the police and the prosecutor witnesses from cross examination and in
addition by allowing the Commonwealth to lead them, the court has made it
impossible for the petitioner to properly put on her case.
Crucial points of witness testimony made explicitly in federal court that could be
established by a single cross examination question that never will be asked in this
proceeding now are removed from the record before this court by witnesses'
convenient losses of memory and recollection.
The result is that the record being made in our view, and our position is, is
completely corrupted. We will go forward as we must to exhaust the alleged state
remedies that are allegedly available to this petitioner, but it's our position that this
proceeding is without integrity in terms of finding fact and seeking truth and it's our
position that any findings made herein against petitioner are entitled to absolutely
no deference as a result in any subsequent court.
(N.T., PCRA at 783-784.)(39)

A reading of the text of Mr. Greenberg's diatribe does little to capture the disdainful
tone of these remarks. When given an opportunity to present case law in support of
his request to cross-examination police witnesses, he produced nothing. Faced with
a ruling adverse to his position, he chose to stand in open court and assault the
integrity of this court.
The issue of leading questions came up with every police or prosecution witness. In
addition to Lieutenant Renee Schuler and former Detective Barley, petitioner
sought to ask leading questions of First Assistant District Attorney Kenneff,
Detective Raymond E. Solt,(40) and District Justice Ronald W. Savage,(41) among
others. Because this issue featured so prominently throughout the hearing, we
have included a discussion of the law on this point.
The general rule is that the party calling a witness is not permitted to examine him
or her by means of leading questions. Wargo v. Pittsburgh Railways Co., 376
Pa. 168, 101 A.2d 638 (1954); Buckman v. Philadelphia & Reading Railway
Co., 227 Pa. 277, 75 A. 1069 (1910). "A leading question is one which puts the
desired answer in the mouth of the witness." Commonwealth v. Chambers, 528
Pa. 558, 579, 599 A.2d 630, 640 (1992) (citing Commonwealth v. Dreibelbis,
493 Pa. 466, 476, 426 A.2d 1111, 1116 (1981)).
One may, however, cross-examine his own witness where the witness proves to be
hostile and unwilling, or where the party calling the witness is surprised by
testimony of the witness inconsistent with prior statements. Gantt v. Cox & Sons
Co., 199 Pa. 208, 48 A. 992 (1901). A thorough examination of the Pennsylvania
case law associated with this exception reveals an abundance of cases which define
"hostility" by way of the definition of "surprise," but an absence of any cases which
offer a definition of the discrete term "hostile witness."(42)
January January
Sunday
22, 201722, 2017
Page
Page1996
994 of
of1299
2301
The term "hostile" has been considered by a number of courts. Where a party is
surprised in the testimony of a witness by his unexpectedly turning hostile, counsel
may exercise the right of cross-examination of the witness, or impeach his
testimony by other witnesses. Commonwealth v. Turza, 340 Pa. 128, 16 A.2d
401(1940). The party requesting leave to declare its witness hostile bears the
burden of proving that statements by the witness were unexpected, contradictory
to earlier statements, harmful to the party calling the witness, and would result in
injustice should the movant's request be denied. Tiburzio-Kelly v. Montgomery,
452 Pa. Super. 158, 186, 681 A.2d 757, 771 (1996). When one's witness turns
hostile by telling a different version on the witness stand than he told the calling
party prior thereto, the latter may plead surprise and request leave to crossexamine the witness and impeach him by his prior inconsistent statement.
Commonwealth v. Duffy, 238 Pa. Super. 161, 167, 353 A.2d 50, 54 (1975).
Clearly, the term "hostile" has been treated by Pennsylvania courts as involving an
element of "surprise."
It is within the sound discretion of the trial court to decide whether counsel may
exercise the right to cross-examine his own witness on a plea of surprise.
Commonwealth v. Barber, 275 Pa. Super. 144, 151, 418 A.2d 653, 657 (1980);
Duffy, 238 Pa. Super. at 167, 353 A.2d at 54. In exercising its discretion, the trial
court must apply a four-part test. First, the testimony given by the witness must be
unexpected; second, the testimony must be contradictory to the witness's earlier
statements; third, the testimony must be hurtful or injurious to the party calling
the witness and beneficial to the opposing side; and fourth, the scope of the crossexamination may not be excessive. Id. at 151-52, 418 A.2d at 657; Duffy, 238 Pa.
Super. at 167-68, 353 A.2d at 54.
Since the purpose of the cross-examination and impeachment is to induce the fact
finder to disbelieve the testimony of the witness, there must be something in the
witness's testimony, which, if believed by the fact finder, will be hurtful or injurious
to the party calling him. Commonwealth v. Thomas, 459 Pa. 371, 379, 329 A.2d
277, 281 (1974). Therefore, if there is no testimony which needs to be neutralized,
or which if accepted unchallenged will not aid the opposite party, or which was not
hurtful to the side calling him, there is no excuse for cross-examination to impeach
or discredit. Seldon v. Metropolitan Life Ins. Co., 157 Pa. Super. 500, 509, 43
A.2d 571, 577 (1945).
Even without a plea of surprise, where the witness is identified with an adverse
party and reluctant to testify against that party, leading questions may be used in
direct examination within the discretion of the trial court. Duffy, 238 Pa. Super. at
167-68, 353 A.2d at 54. Since the issue depends heavily upon evaluating the
witness's in-court demeanor, aspects of which may not even be reflected in the
record, it is recognized that trial courts must be given discretion to determine
whether a witness is hostile or unwilling to testify.
It is well settled that a witness who has an interest adverse to the party calling him
may be called as on cross-examination. Whether a witness's interest is adverse to
the party calling him to testify, for purposes of determining whether he could be
called as if under cross-examination, is a factual determination within the court's
discretion. American States Ins. Co. v. Maryland Casualty Co., 427 Pa. Super.
170, 192, 628 A.2d 880, 891 (1993) (citing Gaul v. Consolidated Rail Corp., 383
Pa. Super. 250, 556 A.2d 892 (1989)). This interest must be a direct interest in the
January January
Sunday
22, 201722, 2017
Page
Page1997
995 of
of1299
2301
outcome of the suit in which he is called. An agent-principal relationship alone is

not sufficient. Indirect, contingent and supplementary interests will not suffice.
Brown v. Popky, 413 Pa. 236, 196 A.2d 638, 645-46 (1964). Nor are employees
of an adverse party ordinarily themselves "adverse" for purposes of permitting a
party to call them as on cross. Commonwealth, Department of Health v.
Brownsville Golden Age Nursing Home, Inc., 103 Pa. Cmwlth. 449, 470 n.7,
520 A.2d 926, 936 n.7 (1987).
In this case, we considered whether any of these police or prosecution witnesses
had any legal rights or liabilities which would be affected by this court's decision on
the PCRA issues. We approached this issue at the outset of the hearing by
contemplating three possible remedies or outcomes in this case which could
arguably affect these witnesses: (1) a new trial for Ms. Lambert; (2) a declaration
that there has been prosecutorial misconduct and that she cannot be retried under
Smith; and (3) a finding of prosecutorial misconduct which may be used to further
a federal investigation that might be taking place.(43)
If this court would award a new trial to Ms. Lambert, there would be no direct effect
on any personal rights or liabilities of any of the police witnesses. New trials are
granted by appellate courts in regular course. A declaration that because of
intentional prosecutorial misconduct Ms. Lambert cannot be retried under Smith
does not affect the personal rights or liabilities of any of these police or prosecution
witnesses. To say that one or all of them might be disappointed with such a result
is not to say that it would have a direct effect on the personal rights or liabilities of
these individuals. The possible impact of this court's decisions in this case on the
federal investigation demanded by the district court is contingent and remote.
There is simply no basis to find that this court's decision in favor of Ms. Lambert
would somehow prejudice the investigation against the police or that the converse
is true. Even if the federal investigative authorities will look to this court's findings
for additional information about the conduct of the police, that does not rise to the
level of a direct personal interest in the outcome of this litigation. The fact that
there may be some instructive or persuasive value in a collateral proceeding does
not establish this kind of interest.
There simply was no basis to consider the police and prosecution witnesses adverse
under Pennsylvania law. Nor was there any basis to find any of them hostile, with
the exception of Officer Robert S. Reed, who was declared hostile and whose
testimony will be dealt with below. All, except Officer Reed, demonstrated a
willingness to answer questions.
The federal rules depart from Pennsylvania practice on this issue. Ru le 611(c) of
the Federal Rules of Evidence permits the use of leading questions on direct
examination of a hostile witness, an adverse party, or a witness identified with an
adverse party, without any requirement of a showing of hostility or adversity. Rule
611(c) suggests that witnesses who are adverse parties or identified with one may
be presumed predisposed against the direct examiner without requiring a
demonstration of that fact.
Prior to the adoption of F.R.E. Rule 611(c), before a party could lead a witness on
direct examination, it had to be shown that the witness was actually hostile or was
an adverse party, officer, director, or managing agent of such adverse party. Ellis
v. City of Chicago, 667 F.2d 606, 612 (7th Cir. 1981); United States v. Bryant,
January January
Sunday
22, 201722, 2017
Page
Page1998
996 of
of1299
2301
461 F.2d 912, 918-19 (6th Cir. 1972). Rule 611(c), however, significantly enlarged
the class of witnesses presumed hostile, "and therefore subject to interrogation by
leading questions without further showing of actual hostility." Ellis, 667 F.2d at 613
(citing F.R.E. 611 advisory committee note); see also Perkins v. Volkswagen of
America, Inc., 596 F.2d 681, 682 (5th Cir. 1979) (error for trial court to rule that
employee of defendant would be plaintiff's witness if plaintiff called him).
The federal courts, in applying Rule 611(c), have allowed the use of leading
questions in direct examination of law enforcement officials (regardless of whether
he or she is a local, state or federal officer) because they are "identified" with an
adverse party, i.e., the prosecution, in actions by the Government against criminal
defendants. United States v. Duncun, 712 F. Supp. 124 (S.D. Ohio 1988)
(granting the defendant's motion to invoke Rule 611(c) in direct examination of
police officers and government agents). In such cases, the burden is on the
Government to make a positive showing that the witness is not hostile, biased or so
identified with the adverse party that "the presumption of hostility which is the
cornerstone of Fed. R. Evid. 611(c) should not be indulged." Id. at 126.
Some commentators and courts have cautioned against such unwarranted
generalizations about the type of relationship sufficiently close to a party to permit
a presumption of bias and suggest that Rule 611(c) be applied with caution. See
Charles A. Wright & Victor J. Gold, Federal Practice and Procedure: Evidence
Section 6168 at 426 (1993 & 1998 Supp.). See also Suarez Matos v. Ashford
Presbyterian Community Hosp., 4 F.3d 47, 50 (1st Cir. 1993) (trial court erred
in permitting plaintiff to ask leading questions of witness as he could not be
deemed a hostile witness simply by virtue of the fact he was expected to give
testimony favorable to defendant). One federal court has recognized that Rule
611(c) is subject to the overriding command of Ru le 611(a) that the court "shall
exercise reasonable control over the mode . . . of interrogating witnesses" to elicit
truth, avoid delay and protect against harassment. F.R.E. 611(a). The court noted
that a district judge would certainly not allow leading questions of an adverse party
where this mode of interrogation was distorting the testimony of the witness.
Rodriquez v. Banco Central Corp., 990 F.2d at 13.
None of the police and prosecution witnesses listed above were parties in this case;
their interests were adverse to petitioner's only in a collateral sense. The simple
fact is that petitioner had previously been involved in a federal habeas corpus
proceeding where allegations of misconduct were made against these witnesses.
That does not create a personal interest or stake in the outcome of this PCRA
litigation.
Petitioner's counsel demonstrated hostility toward each of these witnesses by the
tone and manner of their questioning, if nothing else. Their demonstrated hostility
to these witnesses does not make the witnesses themselves adverse or hostile.
This court had every opportunity to observe these witnesses on the stand. Each
appeared willingly, some in response to a subpoena. There was no need for
petitioner or the court to coerce their attendance at the hearing nor did their
answers to any questions appear to be evasive. In fact, each appeared willing to
answer questions. Each was cooperative and responsive. There was nothing about
the testimony of any of these witnesses which would even suggest that any was
hostile.
January January
Sunday
22, 201722, 2017
Page
Page1999
997 of
of1299
2301
Leading questions are useful to exact truthful statements from a witness who has a
clear and demonstrated tendency to give evasive, unresponsive or argumentative
answers. Leading questions should not be used to exact admissions, in the manner
of an inquisition, from a witness who is attempting to provide responsive answers
to direct questions. Nor should leading questions be used to cut off a witness's
opportunity to provide an explanation. In short, leading questions are not meant to
be loaded questions. And when an affirmative answer is exacted from a witness to
a line of questioning loaded with assumptions favoring only the inquisitor, the
leading question becomes not a tool of truth but of advocacy and intimidation. Our
decision to require direct questioning of witnesses called by petitioner is supported
by the law and was a sound exercise in discretion. The fact that the federal district
court permitted leading questions of police witnesses in the habeas corpus
proceeding does not dic tate how this court should apply Pennsylvania law.
The record indicates that these witnesses were extensively examined and
repeatedly impeached by petitioner. Under these circumstances, there was no
abuse of the PCRA court's discretion.
IV. THE 1992 VERDIC T: FINDINGS OF FACT AND CONCLUSIONS OF LAW
Ms. Lambert was found guilty of first degree murder on July 20, 1992. She filed
post verdict motions in which she claimed that her conviction was against the
weight of the evidence. In a July 19, 1994, opinion filed in response to the issues
raised in the post verdict motions, this court discussed its factual findings leading to
the conviction and whether the verdict was against the weight of the evidence. We
found that the verdict was well supported by the evidence.
Because so much of the analysis of the PCRA claims has a direct bearing on the
integrity of the truth-determining process or whether any new information would
have changed the outcome of the case, we include our findings of fact from the
1994 opinion:
The arguments raised by defendant are best considered in a factual context. The
facts, as found by the trial court, may be summarized as follows. Lisa Michelle
Lambert was romantically involved with Lawrence Yunkin. During an interlude in
their relationship, Mr. Yunkin dated Laurie Show. They apparently dated on one or
two occasions during the summer of 1991. The evidence at trial made clear that
Ms. Lambert reacted strongly to this development and that she expressed her
anger at Laurie Show to a number of her friends. In fact, a plan was developed in
the summer of 1991 that included kidnaping, harassing and terrorizing Laurie
Show. Apparently, Ms. Lambert was the author of this plan and she enlisted several
of her friends to execute the plan. The 'kidnaping' did not happen when several of
the group warned Laurie Show.
This 'bad blood' continued. Ms. Lambert confronted Laurie Show at the East Towne
Mall and struck her. According to the victim's mother, Hazel Show, the victim was
afraid of Ms. Lambert. It appears that Ms. Lambert was stalking Laurie Show during
the summer and into the fall of 1991.
On December 20, 1991, Hazel Show received a call from a person who claimed to
be her daughter's guidance counselor. The caller requested a conference with Hazel
Show before school the next morning. The following morning Hazel Show left the
January January
Sunday
22, 201722, 2017
Page
Page2000
998 of
of1299
2301
condominium to keep this 'appointment.' While she was gone, two persons knocked
on the door of the Show condominium and entered when Laurie Show answered. A
commotion followed and these two figures then left the second floor condominium,
walked across a field, cut through a parking lot by some adjoining condominiums in
the same complex and got into an automobile. Hazel Show waited at the Conestoga
Valley High School for the guidance counselor and when the guidance counselor did
not appear at the time for the appointment, Hazel Show returned by automobile to
her condominium. She found her daughter laying on the floor of her bedroom,
bleeding profusely from a large slash wound across her neck. Laurie whispered to
her mother the words, 'Michelle... Michelle did it.' Laurie Show then died in her
mother's arms.
All this happened on the morning of December 20, 1991. During the evening of that
same day, East Lampeter Township Police, assisted by the Pennsylvania State
Police, arrested Lisa Michelle Lambert, Lawrence Yunkin and Tabitha Faith Buck in a
bowling alley. During questioning by police, Ms. Lambert admitted to being in the
condominium that morning but said Ms. Buck did the stabbing. Mr. Yunkin admitted
to driving the two women to the location and waiting in the car until they returned.
Ms. Buck made no statement to the police.
The evidence at trial clearly established a pattern and history of ill will directed by
Ms. Lambert to Laurie Show. Various witnesses documented an assault by Ms.
Lambert on Laurie Show at the East Towne Mall in November, 1991. There was no
evidence to controvert this. Ms. Lambert threatened Laurie Show with harm if she
went to the police regarding the assault in November, 1991. Ms. Lambert
encountered a friend of hers in December, 1991 at the Park City Mall and indicated
that she was aware that the police were looking for her on a simple assault charge.
In addition, Hazel Show had confronted Ms. Lambert on at least one prior occasion
and had called the East Lampeter Township Police in the summer of 1991. In
December, 1991, Hazel Show went to the East Lampeter Township Police to discuss
the simple assault charge. There was credible testimony at the trial to show that
Laurie Show was afraid of Ms. Lambert.
All of this evidence was relevant as to whether Laurie Show would have willingly
admitted Ms. Lambert and Ms. Buck to her condominium on the morning of
December 20, 1991. Given this history of ill will, it is comp letely credible that Laurie
Show would have admitted Ms. Lambert or anyone in the company of Ms. Lambert
to her home at any time.
Numerous facts developed at trial provided both direct and circumstantial evidence
linking Ms. Lambert to the homicide. On December 19, 1991, defendant bought a
50 foot length of rope and two ski hats at the K-Mart in the East Towne Mall. This
was established by credible testimony from Mr. Yunkin and through a K-Mart
receipt. Defendant took the rope with her on December 20, 1991. Defendant, by
her own admission, took a knife from her kitchen at home to the Show
condominium on December 20, 1991. Mr. Yunkin and Ms. Lambert picked Ms. Buck
up at her home at approximately 6:30 a.m. and Mr. Yunkin dropped the two
women off near the Show condominium at approximately 6:45 a.m. Mr. Yunkin was
seen by the manager of a McDonald's at approximately 7:00 a.m. on December 20,
1991. This McDonald's is very close to the Show home.
January January
Sunday
22, 201722, 2017
Page
Page2001
999 of
of1299
2301
It is very safe to conclude from the evidence that Mr. Yunkin was aware of Ms.
Lambert's feelings about Laurie Show. Mr. Yunkin had dated Laurie Show for a brief
period and then was part of two kidnapping plots in July of 1991 and August of
1991. Mr. Yunkin was aware that Ms. Lambert and Ms. Buck were going to the
Show condominium on December 20, 1991. He was also aware that Ms. Lambert
had a rope and a knife with her.
The Show condominium is on the second floor of a two story structure containing a
number of condominiums. Access to the Show home is gained by ascending a flight
of steps which are on the exterior of the building. The steps are made of metal and
they are partially enclosed. A sidewalk runs in front of the building. A person going
up or down the steps can easily be heard by someone standing out on the sidewalk.
A person walking normally on the deck outside the Show condominium can be
plainly heard by someone inside the condominium or someone outside the
condominium. The construction of the condominium is such that sound travels
through the walls. These facts were clearly established by testimony from Hazel
Show, from the neighbors who lived in the condominium under the Show
condominium and by the court's own view conducted at the premises during the
trial.
Mr. and Mrs. Richard Kleinhans, the neighbors who lived in the condominium
beneath Laurie and Hazel Show, testified that they could hear Laurie Show getting
ready for school in the morning.
A physical inspection of the Show condominium reveals that at least half of Laurie
Show's bedroom can be seen from the main hallway of the condominium. From the
small hallway outside her bedroom, most of her bedroom can be seen. It should be
noted that the layout and construction of the condominium is such that any
commotion in Laurie Show's bedroom could easily have been heard from any
location in the front part of the Show condominium.
The structure of the condominium and the testimony of Mr. Kleinhans with respect
to his ability to hear what was going on in the Show condominium are very
important in this case. Ms. Lambert indicated, in one version of the events, that she
was outside Laurie Show's bedroom and that Ms. Buck was inside the bedroom
struggling with the victim. This version of the story would suggest that Ms. Lambert
was not in the bedroom at the time of the killing. The defendant offered this
version of the facts to support her story that Ms. Buck did the killing and that she
was a horror-struck bystander. A visit to the Show condominium taken by the court
in the company of counsel and an examination of the layout of the condominium
severely undermines Ms. Lambert's position under this version of the facts. Simply
stated, any person standing in the dining room area, kitchen area or bathroom area
of the Show condominium would be well aware of any struggle, commotion or
disturbance going on in Laurie Show's bedroom. The condominium is simply not
that big. A person standing in the hallway or in the dining area would have an easy
view into the bedroom and would certainly be able to hear almost anything taking
place in the bedroom.
From the physical layout of the condominium alone, Ms. Lambert's position that she
was helpless and unaware of what Ms. Buck might have been doing in Laurie
Show's bedroom is patently unbelievable.
January January
Sunday
22, 201722, 2017
Page 2002
1000 of 2301
1299
The secondary significance of a description of the layout of the Show condominium

is to buttress and support the testimony of Mr. Kleinhans, who lives with his wife
below the Show condominium. He testified as to his ability to hear any commotion
or unusual noise from the condominium above his. An inspection of the premises
wholly and absolutely supports Mr. Kleinhans. The construction is such that any
commotion, noise or disturbance can be heard in the condominium below. In fact,
the court observed during a visit to the condominium that a person walking
normally up the steps and across the small balcony to the front door of the Show
condominium can easily be heard from the area below the condominium.
The physical findings at the crime scene, the testimony at trial of the defendant,
the trial testimony of Hazel Show, the history of ill will between defendant and the
victim and the circumstantial evidence developed at trial all lead to the conclusion
that defendant was guilty of the murder of Laurie Show.
Commonwealth v. Lambert, No. 0423-1992, slip op. at 3-10 (Lanc. Co. C.P. July
19, 1994).(44)
In 1994, we specifically considered Ms. Lambert's version of the events of
December 20, 1991, as she presented them at trial. We summarized her story as
follows:
Defendant's story, as presented at trial, was that she and Ms. Buck initially went to
the condominium. She and Ms. Buck then went inside and began to struggle with
Laurie Show. Somehow, somewhere, a knife 'appeared.' According to Ms. Lambert,
she was initially holding down Laurie Show's legs so that Ms. Buck could cut her
hair. When Ms. Buck began to stab Laurie Show, Ms. Lambert began to pull Laurie
from the apartment but Laurie 'slipped' from her hands. According to Ms. Lambert,
she ran out of the condominium, in horror, and sat on the staircase down at the
ground area. At this point, Mr. Yunkin appeared, uttered an expletive and jumped
over Ms. Lambert and went into the apartment. In Ms. Lambert's view of the case,
whatever happened when Mr. Yunkin and Ms. Buck were in the apartment resulted
in Laurie Show's death.
Commonwealth v. Lambert, July 19, 1994, slip op. at 12.
Putting aside the issue of credibility and considering only the legal significance of
Ms. Lambert's version of the facts, we concluded:
. . . Even if Ms. Lambert's story at trial was completely credible, she would still be
an accomplice to the crime of murder. She freely admits to going to the
condominium in possession of a rope and a knife. She admits to going into the
condominium and participating in the attack. The only variation is that she
contends that Ms. Buck was the aggressor and that Mr. Yunkin ultimately assisted.
Her presence and her participation, by her own admission, would support a finding
of criminal responsibility for the death of Laurie Show on an accomplice basis.
At trial, Ms. Lambert's testimony, her statement to Corporal Solt, Mr. Yunkin's
testimony and the questionnaire (45) created a number of factual inconsistencies.
January January
Sunday
22, 201722, 2017
Page 2003
1001 of 2301
1299
The court found the questionnaire to be inconclusive and not sufficient to raise a
reasonable doubt about defendant's guilt. We were aware that either Ms. Lambert's
testimony at trial or Ms. Lambert's statement to Corporal Solt was at least partially
untruthful and we viewed Mr. Yunkin's testimony with a large measure of
skepticism. Much of this controversy was created by the self-serving statements of
the participants in the crime. To resolve these factual inconsistencies, we carefully
considered the observations of witnesses who had no interest in the proceeding and
who observed pieces of this drama as it unfolded on the morning of December 20,
1991. This discussion is found in the 1994 opinion:
The observations of disinterested third parties established several very important
facts. Mr. Kleinhans, who lived in the condominium below the Shows, heard
footsteps up the outdoor steps, heard Laurie Show's door open, heard a scream
followed by a thud. After several minutes passed, he heard the door slam and
heard people descending the steps. He looked out the window and saw two figures
of roughly the same height and build with hoods pulled over their heads. Ms. Buck
and Ms. Lambert are of roughly the same height and, given winter clothing and
hoods over their heads, could have appeared to be of roughly the same build. Ms.
Lambert wanted the court to believe that one of those figures was Mr. Yunkin and
the other Ms. Buck. Mr. Yunkin is significantly taller than either of the two women.
Mr. Kleinhans gave very credible testimony that the two figures he observed were
of roughly the same stature.
Another disinterested witness observed two figures with hoods over their heads
coming across a lawn adjacent to the parking lot at the Show condominium. They
were coming from the vicinity of the Show condominium down across another
parking area toward a road. The timing of this sighting of the two figures coincides
with the time at which Hazel Show was returning from Conestoga Valley High
School and was shortly after Mr. Kleinhans made his observation of the two figures.
A third fact established by a disinterested witness was that Mr. Yunkin was at the
nearby McDonald's restaurant at 7:00 a.m. The manager testified that she
observed Mr. Yunkin and that she later recognized his picture on the newscast
following the arrest of the three. This coincides with Mr. Yunkin's story that he went
to the McDonald's, ordered an orange juice and home fries, waited for a period of
time and then went to pick up the women along the road.
Mr. Kleinhans's testimony completely undermines the story told by Ms. Lambert. To
hear Ms. Lambert's version, there must have been a great deal of shouting,
bumping, sweating, crying, screaming and general commotion in the condominium.
This was followed by, according to Ms. Lambert, her 'escape' from the mayhem
inflicted by Ms. Buck. As part of this 'escape,' Ms. Lambert related that she went
half way down the staircase and sat. Then, supposedly, Mr. Yunkin ascended the
steps, swore out loud when Ms. Lambert told him that Ms. Buck was in the
condominium and went in after Ms. Buck.
Mr. Kleinhans testified that he heard no such commotion. Nor did Mr. Kleinhans
observe three individuals. Nor did Mr. Kleinhans observe anyone the size of Mr.
Yunkin. Nor did Mr. Kleinhans hear any screaming, fighting or doors slamming,
other than the initial entrance and exit.
Given the court's view of the condominium and Mr. Kleinhans's description of the
January January
Sunday
22, 201722, 2017
Page 2004
1002 of 2301
1299
layout of his condominium in relation to the Show condominium, his testimony is

very important. By his clear factual statements, the likelihood that such a
commotion, as described by Ms. Lambert, took place is extremely slight at best. Mr.
Kleinhans testified as to what he heard and as to what he did not hear. He offered
no opinion and offered no interpretation of the events he related. He was found to
be extremely credible by the court sitting as fact finder in this case. His testimony
was in direct conflict with Ms. Lambert's version of the story at trial. Her version
would have involved a kind of 'noiseless mayhem' and this simply is not a credible
story. Mr. Kleinhans was directly below, was paying attention to what was going on
and remembered very clearly what he heard and what he did not hear. The lack of
any commotion, crashing, shouting, stomping, yelling or other related noises
renders Ms. Lambert's already incredible story completely incredible.
The testimony of Mr. Kleinhans, of Mr. and Mrs. Fry who saw the two hooded
figures coming from the direction of the Show condominium toward their own
condominium, and of the manager of the McDonald's restaurant established facts
which were entirely consistent with the Commonwealth's theory of the case and
which were largely uncontradicted. The testimony of these witnesses established
circumstantial evidence which was very important in this court's reasoning process
in 1992. (46)
Ms. Lambert claimed that her conviction was against the weight of the evidence.
This court denied post verdict motions on that basis and Ms. Lambert did not
appeal. Although petitioner filed a direct appeal in the Superior Court, she failed to
include a challenge to the weight of the evidence. This issue, therefore, was waived
and cannot be renewed in a collateral proceeding under the PCRA. 42 Pa. C.S.A.
Section 9544. See also, Appel, 547 Pa. at 186, 689 A.2d at 898; Commonwealth
v. Williams, 389 Pa. Super. 489, 492, 567 A.2d 709 (1989). An issue has been
waived "if the petitioner could have raised it but failed to do so. . .on appeal." 42
Pa. C.S.A. Section 9544(b).
In the July 19, 1994, opinion, we did consider whether the verdict was supported
by or was against the weight of the evidence. In so many words, petitioner has
challenged the sufficiency of the 1992 evidence in this PCRA proceeding. Much of
Ms. Lambert's PCRA case calls into question the evidence introduced in the 1992
trial. Rather than rule that she has waived any possible challenge to the 1992
evidence by not raising the issue of "sufficiency" in the Superior Court, we allowed
her to present her evidence and her arguments which called the 1992 evidence into
question. We did this in the interest of full litigation of all of petitioner's claims.
After Ms. Lambert's challenge to the weight of the evidence in her initial post
verdict motions filed by Mr. Shirk, she then was given an opportunity to challenge
the effectiveness of her trial attorney and to raise certain claims of after-discovered
evidence and prosecutorial misconduct in a post verdict hearing on November 18,
1994. This court made certain findings in response to those claims. See
Commonwealth v. Lambert, No. 0423-1992, slip op. (Lanc. Co. C.P. March 14,
1995).
In consideration of those post verdict issues raised by the new attorney retained by
Ms. Lambert's family, we again considered the record of the 1992 trial. We noted
January January
Sunday
22, 201722, 2017
Page 2005
1003 of 2301
1299
that Ms. Lambert's counsel, Jules Epstein, Esquire, raised a number of issues and
appeared to ask this court to consider those issues out of the context of the entire
record. For example, Mr. Epstein challenged trial counsel's failure to call character
witnesses in a first degree murder case. A superficial consideration of that issue
might suggest that the failure to call character witnesses for the defendant in an
important case would be problematic. However, considering this issue against the
backdrop of the entire record, the decision not to call character witnesses seemed
more than prudent. As to the request that we ignore the record in favor of certain
discreet issues, we noted:
Ms. Lambert's new attorney invites this court, and any reviewing court, to view the
transcript of this trial as if it were a cold specimen in a laboratory, to be studied,
dissected and analyzed in a sterile environment. The court is invited to excise
certain portions of the transcript with the cold scalpel of cynicism and to carefully
study those portions of the record which, under a certain light or a different lens,
could be viewed as error. While interesting as pure, detached legal analysis, this
method of analysis of a trial record yields only part of the whole picture.
This case is not a law school research project or an examination question. This case
involves a consideration of the record of a murder trial. And as with all trials, it is
necessary to look at the record in totality. This trial was conducted in a context, as
is every trial. This trial was more than a recording of words, more than the
emotionless, cold series of questions and answers reflected in a transcript. A trial
involves human beings, thinking, speaking, pausing, listening, telling the truth,
shading the truth, avoiding the truth. It involves people speaking loudly, speaking
softly, crying, reacting to others who are speaking or crying. Counsel, the parties
and the fact finder observe facial expressions, tone of voice, body position,
inflection, statements and reactions to statements.
This court will not reevaluate the evidence from the trial nor is it required to do so.
This court can, however, recall and consider the entire record of the trial in
evaluating the performance of trial counsel. The court must consider the whole
record to determine whether any alleged errors by trial counsel were so serious as
to deprive the defendant of a fair trial, i.e., a trial whose result is reliable.
Commonwealth v. Carter, supra. Considering the various alleged errors of trial
counsel in the light of the entire record, this court can find no error which, in any
way, deprived defendant of a fair trial.
Commonwealth v. Lambert, March 14, 1995, slip op. at 38-40.
If nothing else, this case will give pause to anyone who considers the relationship
between the federal and the state courts. A brief consideration of the principle of
comity is necessary in this opinion for several reasons. First, it will help to explain
why this court conducted an eight-week hearing on a PCRA petition. Second, a view
of the comity question from our vantage point may possibly help in understanding
this court's decision as the case progresses through an appellate court. Third, the
context of this case has been instrumental in framing the issues. A complete
discussion of the context of this case would be greatly lacking without a
January January
Sunday
22, 201722, 2017
Page 2006
1004 of 2301
1299
consideration of the treatment afforded the issues and the participants by the
federal district court in 1997.
What do we mean by "comity?" The Third Circuit, in considering this case in 1997,
gave a succinct and clear answer:
The doctrine of comity '"teaches that one court should defer action on causes
properly within its jurisdiction until the courts of another sovereignty with
concurrent powers, and already cognizant of the litigation, have had an opportunity
to pass upon the matter."' Rose v. Lundy, 455 U.S. 509, 518, 102 S.Ct. 1198,
1203, 71 L.Ed.2d 379 (1982) (quoting Darr v. Burford, 339 U.S.200, 204, 70 S.Ct.
587, 590, 94 L.Ed. 761 (1950)). Indeed, we opined in Toulson v. Beyer, 987 F.2d
984, 986 (3d Cir. 1993), that requiring exhaustion of state remedies 'addresses
federalism and comity concerns by "afford[ing] the state courts a meaningful
opportunity to consider allegations of legal error without interference from the
federal judiciary."'
Lambert v. Blackwell, 134 F.3d at 513 n.18 (citations omitted).
Comity appears to require deference. Comity appears to require understanding
and, perhaps, even respect for the treatment given the issues in state court. The
federal district court took significant liberties with state court criminal practice. The
federal district court did this in a number of ways. First, it allowed for an
unprecedented and unbounded level of discovery. In a three- month period of time,
some 55 depositions were taken.(47) The document production ordered by the
federal district court was at odds with any concept of attorney work product under
even the most liberal standards. In effect, the most permissive approach to civil
discovery was applied to a criminal case.
Second, the federal district court substituted its own fact finding on critical issues
from the 1992 trial. Something other than "comity" is at work when fundamental
findings of fact in a state court homicide case are "dismissed" by the federal district
court.
Third, the federal district court substituted its legal judgment for the state court's
analysis. For example, this court made a ruling on the discussion between First
Assistant District Attorney Kenneff and Dr. Mihalakis in response to Ms. Lambert's
counsel's motion for a mistrial at the 1992 murder trial. In making that finding, this
court held a conference in chambers, on the record, in the presence of all counsel
and the expert witness. This issue will be treated in more detail in Section VII.H,
infra. Suffice it to say, for purposes of our discussion of comity, that substitution of
the federal judge's legal analysis for the state court judge's legal analysis was an
"overruling" by a court which, at the moment, possessed a stronger and more
immediate power. It was not "comity" befitting a constitutional democracy.
Finally, by employing a creative and aggressive approach to exhaustion, the federal
district court deprived this court of the opportunity to revisit the legitimate issues
raised by petitioner in a proper context. Aggressive may be a good adjective for
investment strategy or athletic performance, but not for legal analysis.
Is this what the Anti-Terrorism and Effective Death Penalty Act of 1996 ("AEDPA"),
January January
Sunday
22, 201722, 2017
Page 2007
1005 of 2301
1299
28 U.S.C. Section 2254, contemplated? If so, then federal legislation defining the
role of federal habeas corpus in the criminal justice universe has made this a very
strange place. This approach to "comity" will cause the state court murder trial
simply to become a rest stop on the way to federal justice. Will we have state court
homicide convictions ultimately decided in a forum under a lighter burden of proof
and where state court criminal convictions will come under the often misleading
microscope of civil discovery? Will we now as a matter of federal due process and
equal protection put every state court murder conviction under the scrutiny of
boundless discovery, creative advocacy and a court willing to reach conclusions
based upon a partly developed record?(48)
In federal habeas corpus litigation, factual determinations made by the state courts
are correct unless the petitioner can rebut the presumption of correctness by clear
and convincing evidence. See 28 U.S.C. 2254(e)(1). With respect to legal
conclusions, the federal courts are required to give deference to legal conclusions
made on the claims for relief by the state courts. See 28 U.S.C. Section 2254(b).
In Commonwealth v. Traviglia, 541 Pa. 108, 661 A.2d 352 (1995), the Supreme
Court reiterated that it is the responsibility of the state--not federal--courts to
make factual determinations in the first instance and that the latter must give
deference to the former. Specifically, both the Post Conviction Hearing Act court
and the federal district court resolved a factual dispute: whether a non-use
agreement had been struck in Indiana County. The PCHA court concluded that a
non-use agreement was not in existence; the district court came to the opposite
conclusion. In this regard, the Supreme Court stated:
Similar, nearly identical, records can legitimately support two different holdings;
that two different holdings may result from similar records does not mean that one
determination is somehow invalid. . . . A factual determination by a federal district
court in no way 'overturns' the factual determination made by, and subsequently
affirmed by, the courts of our commonwealth.
541 Pa. at 108, 661 A.2d at 362-63 (footnote omitted).
In this case, the federal district judge failed to give the state court record due
consideration and the deference to which it is entitled under law. For our purposes,
the "findings" of the district court in the habeas case in no way "overturned" the
factual findings made by this court.
As the Court of Appeals appropriately noted, "a finding of actual innocence, as that
term has come to be used in federal habeas corpus jurisprudence, is not the
equivalent of a finding of not guilty by a jury or by a court at a bench trial."
Lambert v. Blackwell, 134 F.3d at 509. See Bousley v. United States, --- U.S.
---, 118 S.Ct. 1604, 1607, 140 L.Ed.2d 828, 840-41 (1998) ("'actual innocence'
means factual innocence, not mere legal insufficiency") (citing Sawyer v. Whitley,
505 U.S. at 339).
Ms. Lambert maintains in this PCRA that she is actually innocent of Laurie Show's
murder. In the heading to the first section of her list of claims, she states: "After-
January January
Sunday
22, 201722, 2017
Page 2008
1006 of 2301
1299
Discovered Evidence Proves Lambert's Innocence . . . ." (See Exhibit A, Section

A.(49)) Pennsylvania law, unlike its federal counterpart, does not specifically
recognize "actual innocence" as a basis for relief.(50) Consequently, there is no body
of state law specifically defining the parameters of proof of such a claim. But, in
federal decisional law, it is well established that when a petitioner makes a claim of
this sort, the government is not limited to the existing record to rebut any showing
that petitioner might make. It may present "any admissible evidence of [a]
petitioner's guilt. . . ." Bousley, --- U.S.at ---, 118 S.Ct. at 1607, 140 L.Ed.2d at
841. While a finding of "actual innocence" is not within the purview of the PCRA,
Ms. Lambert's case is centered on her belief that she is an innocent person,
wrongly convicted.
A two-judge motions panel of the Third Circuit in reviewing this case stated:
"Although the district court could not of course make a determination that Lambert
was not guilty of an offense tried in a state court proceeding, a finding of
'innocence' by the district court would appear to be a conclusion that prosecutorial
misconduct was a determinative factor in unjustly bringing about a guilty verdict."
See, 962 F. Supp. at 1528." Lambert v. Blackwell, Nos. 97-1281, 97-1283 and
97-1287, slip op. at 7 (3d Cir. May 6, 1998).
The finding of "actual innocence" could not have been a declaration that Ms.
Lambert did not commit this crime. "Actual innocence" does not actually mean
"innocent." It is, rather, a commentary on the weight of the evidence of
prosecutoria l misconduct and the application of a remedy under federal law. Ms.
Lambert has not been proven innocent and she does not stand before this court as
an innocent woman forced to prove her conviction was unfair. She has been
convicted of first degree murder and the federal finding of "actual innocence" is no
more than a footnote to that verdict.
This case presents a complex narrative of police corruption, heartless, dishonest
prosecutors, ineffective defense lawyers, an unwitting trial judge, rubber stamp
appellate courts and a fast breaking series of "shocking" revelations and "explosive"
disclosures. The petition raises well over two hundred allegations of prosecutorial
misconduct, new evidence, ineffective assistance of counsel, and discovery
violations. To accept petitioner's theory of this case, it is necessary to understand
her entire story. Each allegation has a place along a story line which must be true if
Ms. Lambert's case is to have any merit. Before delving into a discussion of the
merits of this case, we offer, as context, the following synopsis of the story,
according to Ms. Lambert.
We caution that this section does not present this court's findings of fact.
Rather, these "facts" represent petitioner's vers ion of this story.
On Friday morning, December 20, 1991, a 15 year old girl was murdered in her
condo in East Lampeter Township. Her mother returned home from a brief errand,
found her and held her in her arms until she died. Hearing the mother's cries for
help, a neighbor called 911. A dispatch was broadcast to East Lampeter Township
Police. Officer Robin Weaver, a Township police officer, was on patrol in that area
and heard the broadcast over his radio. He recognized the location and the name
January January
Sunday
22, 201722, 2017
Page 2009
1007 of 2301
1299
and he responded without being dispatched.

Weaver was the first officer on the scene. He realized the victim was Laurie Show
and recalled Laurie Show had been harassed in a loc, al mall by Michelle Lambert, a
19 year old local resident. Weaver knew that Ms. Lambert and her boyfriend,
Lawrence Yunkin, had a disagreement of some sort with Laurie Show. Weaver also
knew that three officers from his department gang raped Ms. Lambert in her
apartment on June 17, 1991.
As he stood in the Show condo that morning, while Laurie Show died in the arms of
her grieving mother, Weaver's response was not to summon help, not to comfort
Mrs. Show, not to render aid to the victim, and not to search the condo premises
for suspects. Rather, Weaver's response was to plan, then and there, a conspiracy
which would implicate Michelle Lambert in the murder of Laurie Show, thereby
relieving his cohorts of any further worries about the gang rape of Ms. Lambert that
prior June.
This is the essential truth of this case as presented by petitioner: that the murder
of Laurie Show was a fortuitous moment for the East Lampeter Township police.
Further "truths" follow as the story unravels. Detective Savage, the crime
investigator for East Lampeter Township, responded to the scene. Savage knew
about the gang rape. Savage and Weaver heard Mrs. Show tell neighbors and
family that she believed the murder was "a set up" and that she believed Michelle
did it. They took her aside that morning and as they questioned her about the case,
they suggested to her that her daughter told her that Michelle did it. Because she
was vulnerable, because she was in shock, and because she hated Michelle
Lambert, Mrs. Show was willing to believe, then and there, what the police told
her: that her daughter made a dying declaration identifying Michelle as her killer.
Later, based solely on the subliminal suggestion of a cunning detective made just
outside her daughter's blood-soaked bedroom, Mrs. Show would testify about this
dying declaration under oath in two preliminary hearings and two first degree
murder trials.
The police suggested this dying declaration even though they had proof that
morning that Laurie Show couldn't speak. This proof was in the form of an
observation by Ken Zeyak, an EMT with no training in anatomy, no medic al
education and no experience in observing wounds such as those suffered by Laurie
Show. Yet, Mr. Zeyak, the first ambulance person on the scene, immediately noted
that the victim had a severed left carotid artery. Zeyak, Weaver and Savage knew
that a severed left carotid artery means you can't speak. Yet, knowing she couldn't
speak, the police suggested to the mother that the dying declaration pointed the
finger squarely at the woman they had gang raped six months before.
A team from the police department descended on the condo and began to gather
evidence. They took pictures all over the condo. Some of these pictures showed
blood in the front hallway, including bloody footprints all over the tile floor. The
victim's body was taken from the scene and transported to the county morgue
located in the basement of the county nursing home. An autopsy was scheduled for
9 o'clock the following morning.
The police conspiracy to frame Ms. Lambert, hatched that morning in the midst of
an emotional and confusing murder scene before an investigation even began,
January January
Sunday
22, 201722, 2017
Page 2010
1008 of 2301
1299
forever changed the "true" facts of this case. Ms. Lambert has now presented her
view of what really happened.
Lisa Michelle Lambert and Lawrence Yunkin began dating in 1989. He was abusive
to her, sodomized her, and struck her whenever he disagreed with her. She came
from a strong Christian, middle class, suburban family and she had lost her
virginity to him. This meant that she was going to marry him, despite the abuse.
She left home at the age of 16 and began to live with Lawrence at his parents'
home. Later they moved into their own apartment and in the late summer, early
fall of 1991, they moved to a trailer in Pequea, a rural township "across town" from
East Lampeter.
Lawrence turned her from a brown haired, brown eyed, shy, Christian, suburban
teenager into a lynx. He told her to dye her hair blond, which she did. He told her
to make her brown eyes blue, which she did with, tinted contact lenses. He told her
to ditch the frumpy suburban teenage wardrobe and get something tight and short,
which she did. She became Rural Barbie, with an attitude. This 19 year old
lumberyard laborer, with the Adonis looks and the Svengali mind, dominated and
controlled her every move. They had a sexual relationship, but she didn't like it
much because he was cruel and rough. In fact, she didn't like it much for over two
years.
In the early summer of 1991, Lisa Michelle, known now only as "Michelle," began to
look for a way out of the relationship. She was tired of being a blond haired, blue
eyed wearer of tight clothes just to please this galoot. She broke up with Lawrence,
b, ut they continued, to , live together and to sleep in the same bed. She even saw
another man, but this was when Lawrence was sleeping, exhausted from a day of
boorish behavior. While Lawrence slept, Michelle crept out of the bedroom to the
outside where she encountered Allen Rudolph, her new friend. She and Allen played
midnight basketball. Then Allen would pull her in the window of his house where
they would sit on the floor in his bedroom, listen to rock and roll, laugh and, of
course, have sex. Then she would, by the light of the early dawn, creep back into
Lawrence's bed.
Lawrence found out about this and came to the swimming pool where she was
sunning herself in a bikini, although she really didn't like wearing small tight
clothes. Lawrence threw all of her clothes out of the van, all over the swimming
pool and screamed at her for four or five hours. This caught the attention, and the
affection, of Michael Pawlikowski, a life guard at the pool. He became romantically,
but not sexually, involved with Michelle through the rest of the summer.
On June 17, 1991, around the time when Michelle had broken up with Lawrence but
was still sleeping with him, was sleeping with Allen but not dating him, and was
inadvertently catching the eye of Mike the life guard, she was gang raped by three
police officers. As she lounged at twilight in her living room in her bikini after a day
of sunbathing, three police officers came to her door. They were able to open the
door because Lawrence had broken the window pane one day. The three officers
raped her. She heard each of them speak but she couldn't see them. She could
only see their police badges reflecting light off the street lights coming in through
the window.
Michelle's first response to this rape was to call Mrs. Show, the mother of Laurie
January January
Sunday
22, 201722, 2017
Page 2011
1009 of 2301
1299
Show. She called Mrs. Show because Lawrence was, at that time and for a period of
one week, dating Laurie Show. She called Mrs. Show to find out where Lawrence
was. Mrs. Show didn't quite understand the question because it was hidden among
a screaming barrage of obscenities, profanities and threats against her daughter.
Michelle then called a number of other people looking for Lawrence. She didn't call
her parents, she didn't go to the hospital, she didn't go to a rape crisis center and
she didn't go to any police officer in any other department anywhere.
She called Mrs. Show a lot that summer. She would call her to find out where
Lawrence was and to tell Mrs. Show to keep her daughter away from Lawrence.
Sometimes, when Mrs. Show would hang up after being called every day for several
weeks, Michelle would continue to call and the phone would ring in the Show
residence all evening. Mrs. Show changed her number to an unlisted one and the
telephone calls stopped.
Michelle didn't think the phone calls were getting through to Laurie so she got some
friends to help her with a plan to "embarrass" Laurie, to keep her away from
Lawrence. They were going to go to Laurie's home, kidnap her and take her down
to "the ward."(51) They were going to cut off her hair, take off her clothes, blindfold
her, and tie her to a post. They were going to hang a sign around her indicating
that she was available for sex for any of the locals. One evening, they got so far as
to get in two cars and to head over to the Show residence. It was at this point that
two of the teenagers decided that this sounded like a little more than a "prank" and
decided to warn Laurie not to answer the door if anyone should come. They turned
around and didn't go to the Show residence that evening.(52)
Time passed and Michelle discovered that she was pregnant to Lawrence, she
believed with twins. Even though she lived with Lawrence miles from East
Lampeter, even though Lawrence no longer saw Laurie, even though they were
living worlds apart, Michelle wanted to make sure Laurie never took her man from
her again. So, she asked her new friend, Tabby, to go to the Show residence with
her to really scare Laurie. She told Tabby that she had arranged for Mrs. Show to
be out of the home that morning.(53)
Michelle bought a 50 foot length of rope and two ski masks from K-Mart. She took
a large butcher knife from her kitchen. She told Tabby to wear sunglasses, put her
hair up and leave the makeup in the bathroom.
Michelle and Tabby went to the condo a few days before Christmas. Michelle
wanted to talk to Laurie. They knocked on the door and when Laurie answere d,
they pushed their way in and began to struggle. Michelle just wanted to talk, but
Tabby wanted to cut Laurie's hair off. Tabby pulled out a knife that came from
Michelle's kitchen, even though Tabby hadn't been in Michelle's kitchen that
morning, and Tabby stabbed Laurie. Michelle realized that this was a bad scene.
She told Tabby to stop it and she tried to pull Laurie by her wrists out of her
bedroom and down the hall. This left blood all over the floor and the walls. But
Tabby pulled Laurie back in the bedroom and Michelle went outside. Michelle sat on
the steps and cried because she was afraid of Tabby and worried about Laurie.
Lawrence arrived and asked what had happened. Michelle told Lawrence about
Tabby and Laurie. Lawrence swore at Michelle and went inside. Then Lawrence and
Tabby came out and all three ran to Lawrence's car and drove home.
January January
Sunday
22, 201722, 2017
Page 2012
1010 of 2301
1299
Michelle knew something bad happened to Laurie but she couldn't get help. She
couldn't call any friends, she couldn't call the police, she couldn't tell her parents.
This was because Lawrence watched her "like a hawk" and she knew he would hit
her if she made a false move. So they drove home, took showers and drove Tabby
to school. They ate lunch at home and Michelle watched Matlock, which would come
in handy later when she was questioned by the police because she would already
know about her rights. Then they went Christmas shopping. Then they went to cut
down a Christmas tree at Lawrence's grandmother's house. This explains why they
had ski masks, a knife and a rope. On the package of the rope, there is a picture of
a man dragging a Christmas tree, which is why Michelle bought that particular
rope--to pull the Christmas tree.
Last year when they were cutting down a Christmas tree with a knife at
grandmom's, Michelle got wood chips in her eyes and in her hair. She got "pink
eye" from the wood chips. So this year she took sunglasses and a ski mask and
gloves so that she would be protected.
Then they went to Tabby's house. Tabby was watching the news and heard that the
girl was dead. So they decided not to arouse any suspicion and to go about their
normal Friday night business, which means they went to the bowling alley. The
police came to the bowling alley and asked Tabby why she had a big scratch on her
cheek. Michelle, who was afraid of Tabby and who didn't make one false move
because Lawrence was watching her "like a hawk," stepped up and told the police
that Tabby got the scratch in a fight with some Puerto Ricans girls who had made a
pass at Lawrence that morning.
The police then took them to the station. Michelle told the police about the Puerto
Rican girls and the scratch and about cutting the Christmas tree. When the police
told her Laurie Show was dead, she started to cry, but not because she had
anything to do with it. Then Corporal Raymond Solt, a Pennsylvania State Police
polygraph examiner, gave Michelle a lie detector test. He strapped Velcro straps all
over her arms. Then he took out a needle and told her he was going to inject her
with something. Probably it was truth serum. She thought this was part of the test
so she let him do it. Then he asked her some questions. She began to tell him
about going to the Show condo that morning. She told him that she and Tabby
went inside and that all three struggled. She said that Tabby pulled a knife and that
she, Michelle, held Laurie's feet so Laurie wouldn't kick her. She then told Solt that
she and Tabby left, pulled their hoods up and ran across a parking lot, across a
field, down a hill, across a stream, through some woods and out onto a road, where
Lawrence was waiting. She told Solt that she didn't plan to kill Laurie, that Tabby
went crazy and that she held Laurie down while Tabby went crazy.
Solt typed up her statement and she read it. She signed her name across each
page of the statement. Then Solt gave her some blank papers to sign her name.
She didn't understand this but she signed her name across these papers, too.
Meanwhile, the police reviewed four rolls of photographs of the crime scene.
Michelle told them she tried to help Laurie escape. Michelle also told them that
Tabby threw the phone across the room. When they looked at the crime scene
photographs, sometime after five or six in the morning when Michelle told them
this information, they realized that the photographs were wrong. If the telephone
was across the room, this would mean that Michelle was telling the truth and Tabby
January January
Sunday
22, 201722, 2017
Page 2013
1011 of 2301
1299
was the killer. But the police needed to prove that Michelle was the killer, because
they had gang raped her and wanted her to go to prison forever or maybe get the
death penalty. There was only one thing to do: take Laurie's body back to the
condo and take the pictures again.
Sometime after 6 o'clock in the morning, when Michelle's statement was finished,
the police went to the county morgue, in the basement of a public building, took
the body out of the morgue and put it in a police car. Then they drove to the condo
where they were met by a state police officer, who agreed to take the pictures
again because he got it wrong earlier that day. First, they cleaned up all the blood
in the hallway. They missed one or two footprints but most of the blood was
cleaned up so the new pictures would show that Michelle was lying about helping
Laurie get out of the condo.(54)
They took new pictures of the body with the telephone cord wrapped around the
leg. This would show that Michelle was lying about Tabby throwing the telephone
across the room. The telephone cord around the leg would show that Michelle was
the killer.
Then they got the body back in the police car, back down the highway and into the
morgue. They had to do this by 9 o'clock because the autopsy was scheduled at 9
o'clock and they had to have the body back for the autopsy.
The autopsy was very important because Weaver and Savage knew they had to tell
the doctors that Laurie spoke and that her carotid artery couldn't have been
severed, even though they knew from Ken Zeyak, the ambulance person who had
never seen a carotid artery, that the carotid was "definitely cut." So they called
First Assistant District Attorney Kenneff, who prosecutes these cases. They told him
what the problem was. Mr. Kenneff went to the autopsy that morning and told Dr.
Penades, the pathologist, all about the carotid. Even though Dr. Penades was board
certified in anatomical pathology, the prosecutors had to tell him how the carotid
artery worked and that it was cut. They got Dr. Annese, a throat surgeon, to attend
the autopsy. He was a good choice because he was a friend of the Show family.
Together with Dr. Penades, he would say that the carotid artery was intact. They
would all agree that Laurie Show could have spoken to her mother.
This seems like a lot to happen inside one day. But the next day, police officers go
to the river. Lawrence and Michelle told the police that they had put Lawrence's
sneakers and a shirt in a pink trash bag and cast it into the river. They also threw
the knife in the river but it was not in a bag. The police go to the river two days
before Christmas when the water temperature is in the thirties, and they try to
figure out how they can use the river to really frame Michelle Lambert. They are
looking for a pink trash bag with sneakers in it. They find the pink trash bag and
they notice that one of the divers has a video camera and is filming them. So they
wave at him to turn the camera off. They take Lawrence's sneakers and other items
out of the bag and throw them away. Then they take the pink bag and they put it
in ice. They think of a way to make it look like it was stuck in frozen ice, even
though when they took the sneakers out it was not stuck in ice. Then they take a
picture of the pink bag stuck in frozen ice to make it look like they never found a
bag in the first place.
The next day a diver finds a sneaker which is full of mud and has black rot all
January January
Sunday
22, 201722, 2017
Page 2014
1012 of 2301
1299
around the canvas where it touches the sole. Even though the murder was three
days before and it looks like the sneaker has been in the river for two years, they
figure it is probably the sneaker of the murderer and they throw it away, too.
A month later, the police record the statement of Lawrence Yunkin. They have been
rehearsing his statement with him for a month to make sure that he says exactly
what they want him to say so they can frame Michelle. He is represented by a
lawyer, who is an officer of the court and enjoys a good reputation in his
community. They take a recorded statement of Lawrence but he can't seem to get
the wrong story right so they have to keep stopping the tape to tell him what to
say.
In the meantime, Michelle decided to cover up for Lawrence even though she knew
Lawrence and Tabby killed Laurie and even though she was sorry about this and
even though she didn't know what really happened. So she wrote some questions
on paper and left them in a book in the prison library. Lawrence got the questions
and wrote in answers. A lot of the questions looked strange because words are
squeezed in, words are inserted and some of the words are written over very
heavily. The answers, which Lawrence wrote on the paper, did not make sense but
they could be interpreted to say that Lawrence at least knew something about the
murder. Even though Michelle was covering up for Lawrence, she thought it was
necessary to send him a questionnaire to find out what he did. So that she could
cover up. She got the questionnaire some time in February. Her baby was born in
March. She wouldn't tell her attorney about the questions until closer to trial. Her
attorney told her she might get the death penalty and that evidence linking anyone
else to the crime, especially Lawrence, might help her. Still, she stuck to her guns.
It was only when her attorney offered to give her a bottle of hair bleach that she
came up with the questions. It was important for Michelle to bleach her hair
because Lawrence wanted her to be a blond. Her need to dye her hair blond for
Lawrence, even though she had been in prison for four months, was facing a
murder charge and knew that Lawrence was going to testify against her, was
important. It was important because she was a battered woman and Lawrence had
control over her.
At her trial in July 1992, Michelle decided not to cover for Lawrence anymore. She
told the judge that she went to the condo that morning to talk to Laurie. When they
got inside, Tabby went crazy and Michelle tried to help her. All she did was sit on
Laurie's legs while Tabby attacked her. Then she ran outside to the steps and that
is when Lawrence came in.
She was interviewed before trial by Dr. Carey, a psychiatrist. She told Dr. Carey
about the gang rape but asked him not to mention it. Dr. Cary testified about his
evaluation of Michelle. He felt she was abused and controlled by Lawrence and that
she had been extremely upset about Lawrence's attentions to Laurie. He found it
significant that Michelle had only ever been with one man and that she was true
and faithful to Lawrence. Six years later in a post conviction hearing, Michelle was
asked about Allen Rudolph and why she didn't tell Dr. Carey about sneaking out at
night with Allen. Michelle testified that she did tell this to Dr. Carey but he had a
hearing aid and didn't hear her.
Michelle was convicted of first degree murder and given a sentence of life in prison.
While in a women's prison in Cambridge Springs, Pennsylvania, she was brutally
January January
Sunday
22, 201722, 2017
Page 2015
1013 of 2301
1299
raped, beaten and kept in isolation for 18 months. Because of the mistreatment she
received at this prison, she was unable to help the lawyer whom her parents hired
to file her appeal. She couldn't tell him the true story. That is why her conviction
was affirmed by the Superior Court of Pennsylvania and that is why the
Pennsylvania Supreme Court denied the request for review.
She was eventually transferred to a prison in Delaware; then transferred again to a
prison in New Jersey. At the prison in New Jersey, she wrote in her own hand a
federal habeas corpus petition. Attorneys were appointed for her from a large
Philadelphia law firm and she went to court in April 1997 before a federal judge in
Philadelphia. He understood the truth of this case. He knew that the police were
corrupt and that they changed the evidence. He knew that the statements she gave
to Solt were really made up by the police. He knew that all they were doing that
morning at the condo, with a knife and a rope, was a "teenage prank." He knew
that the dying declaration was phony because an EMT saw the severed carotid
artery and a speech professor, who did not, said there is no way Laurie could have
spoken. He saw through to the truth that police officers, in response to a horrifying
murder scene, saw the fortuitous opportunity to frame a teenage girl because they
had gang raped her. He knew that she was telling the truth because she was a
battered woman and any inconsistencies in her story were because she had been
battered. He knew that the "29 questions" really was nothing more than a
confession by Lawrence and that it was a reliable document. He knew that a state
court trial judge had found the dying declaration to be credible and had ruled that
the "29 questions" was unreliable and inconclusive. He didn't know that the police
carried the body back into the condo and he didn't know that the police injected
Michelle with truth serum before they took her statement. He didn't know this
because Michelle's lawyers didn't learn about this until later, after the habeas
proceeding.
So, even though Michelle was in the condo that morning and even though Michelle
had a demonstrated history of hatred and animus toward Laurie, and even though
two versions of Michelle's story not only put her in the condo that morning but had
her involved in the struggle leading to Laurie's death, he found her to be "innocent"
and declared her a victim.
This is the story line which flows logically from the individual allegations of
misconduct and "new evidence." Item by item, the allegations of prosecutorial
misconduct taken out of the context of Ms. Lambert's entire story make this look
like a corrupt and unreliable prosecution. But in order to accept them and find them
true, it is also necessary to accept their place along this story line.
The above scenario is an understatement. It is a bare boned description of what
must have happened in 1991 and through the progress of this case, according to
petitioner. This is the context as seen by Ms. Lambert for the claims she has
presented to this court.
The "dying declaration" is in this case simply because a federal judge disagreed
with this court's assessment of the facts at trial. At the core of this issue is the
January January
Sunday
22, 201722, 2017
Page 2016
1014 of 2301
1299
credibility of Hazel Show. The expert testimony is relevant to support or question

her veracity on this point.
With an attitude that does not even suggest deference to the state court's fact
finding, the federal district court dismissed the "keystone" of the 1992 verdict at
the start of his analysis:
It became clear during the hearing that this keystone of the Commonwealth's case
must be removed, and by that fact alone the arch of guilt collapses.
Lambert v. Blackwell, 962 F. Supp. at 1528.
That choice, to reach back five years into a state court record which had been
reviewed and affirmed on appeal and to change this court's finding of a crucial fact,
has become another keystone. That choice, which was a keystone of the district
court's decision, now supports petitioner's case.
Mrs. Show testified in the 1992 trial that her daughter Laurie made a dying
declaration to her in which she identified Michelle Lambert as the killer. Mrs. Show
testified in 1992 that she came upon her daughter in her bedroom, that she took
her head and shoulders into her arms and she cradled her, after cutting the rope
that had been tightened around Laurie's throat. (N.T., Trial at 792-93.) As she
cradled Laurie's head in her arms, Laurie uttered the words, "Michelle did it. .
.Michelle. . .Michelle. . .I love you. . .I love you. . .I love you. . .I love you." (N.T.,
Trial at 793, 795, 818.)
Whether this dying declaration ever occurred was a central issue in the 1992 trial.
It was a central issue in the federal habeas proceeding in 1997 and was perhaps
the central issue in the PCRA hearing. No less than six expert witnesses testified at
the PCRA hearing regarding the medical and physiological issues presented by the
dying declaration.
This court found Mrs. Show to be a credible witness on this and other topics in the
1992 trial. See Commonwealth v. Lambert, July 19, 1994, slip op. at 17-18. We
found her to be credible by observing her testimony in the courtroom on the
witness stand as she related her recollection from the morning of December 20,
1991. We further considered her conversations with medical personnel and others
at the scene of the murder on the morning of December 20, 1991. We knew in
1992 that she related almost immediately that "Michelle" committed the murder
and that it was a "set up." Her recollection from that morning and the information
in the police reports show that she, at some point, told investigating police officers
that her daughter spoke those words to her.
At the 1992 trial, we also had the benefit of the testimony of Dr. Penades, the
pathologist who performed the autopsy on Laurie Show, and Dr. Annese, an
otolaryngologist who attended the autopsy specifically to observe the structures of
the neck and to offer an opinion of the possibility of speech. The defense called Dr.
Mihalakis, who ruled out the possibility of clear and normal speech but who
acknowledged that Laurie Show was capable of "somewhat slurred and less
intelligible" communication consistent with the dying statement. (N.T., Trial at 344-
January January
Sunday
22, 201722, 2017
Page 2017
1015 of 2301
1299
45, 357.)
With the benefit of this evidence, the court made a decision in 1992 that the dying
declaration took place, that Mrs. Show was credible on this point, and that the
dying declaration linked Ms. Lambert to the murder.
The PCRA petition raises a number of counts of after-discovered evidence which
petitioner contends cast doubt on the dying declaration. Specifically, petitioner
contends that Laurie Show's left carotid artery was severed, (Exhibit A, Section A at
para. 1), that Laurie Show could not have been conscious at the time she made the
dying declaration, (Exhibit A, Section A at para. 2), and that speech was medically
impossible, according to Charles R. Larson, Ph.D., (Exhibit A, Section A at para.
59). Further, petitioner cites as after-discovered evidence certain credibility
questions which impact on the 1992 testimony supporting the dying declaration:
that Dr. Mihalakis was paid more by Lancaster County after the 1992 trial, (Exhibit
A, Section A at para. 17); that Dr. Mihalakis changed his testimony, (Exhibit A,
Section A at para. 18); that Dr. Annese compromised his testimony because of his
familiarity with the Show family, (Exhibit A, Section A at para. 60); and that Mrs.
Show did not tell anyone that Laurie said "Michelle did it" until nearly two hours
after the murder, (Exhibit A, Section A at para. 61).
The federal district court found that Ms. Lambert proved to him "at least by clear
and convincing evidence that Laurie Show could not have said 'Michelle did it'."
Lambert v. Blackwell, 962 F. Supp. at 1529. In so doing, the federal district court
ruled that Mrs. Show was not credible on this point, despite the fact that he did not
have an opportunity to hear and observe her testimony in 1992. Further, the
federal district court based its finding on "evidence" that Laurie Show's carotid
artery was cut, thereby rendering speech impossible. He based this finding on the
testimony of an EMT, who admittedly had minimal, if any, training in anatomy, and
on the testimony of a speech professor from Northwestern University, Dr. Larson,
who never observed Laurie Show's body, who did not attend her autopsy, who is
not a medical doctor, whose sole surgical experience is limited to monkeys, and
who was willing to offer opinions far outside his area of expertise.(55) The federal
district court was able, somehow, to overlook the testimony of Dr. Penades from
the 1992 trial, as well as the testimony of Dr. Annese from the 1992 trial. Each of
these witnesses had, literally, hands-on contact with the structures of the neck of
Laurie Show during the course of the autopsy.(56)
At the PCRA hearing, petitioner produced Dr. Larson to testify about the
mechanisms of speech. He made a thorough and interesting presentation on how
the various structures of the neck and mouth and respiratory system work together
to produce speech. He offered this as a prelude to his expert opinion that it was not
possible for Laurie Show to articulate intelligible speech. Dr. Larson contends it was
not possible for Laurie Show to say "Michelle did it." (N.T., PCRA at 2414-15.) He
offered this opinion without ever having had the opportunity to observe the
structures in Laurie Show's neck and relied exclusively on crime scene and autopsy
photographs, the autopsy report and testimony at the various prior hearings. (N.T.,
PCRA at 2442.)
Dr. Larson also offered an opinion that the left carotid artery on Laurie Show was
severed. (N.T., PCRA at 2381.) Dr. Larson, whose knowledge of human anatomy,
albeit well articulated and detailed, is limited to charts, diagrams, photographs,
January January
Sunday
22, 201722, 2017
Page 2018
1016 of 2301
1299
transparencies, past experience performing experimental surgeries on live monkeys

and, apparently, the occasional experiment with a cadaver, was called to offer an
opinion as to the integrity of the anatomy of a crime victim whom he never
observed. Would that this were not enough, he never offered an opinion as to the
significance of the cut carotid. Petitioner's counsel apparently chose to leave these
conclusions to the medical witnesses who, indeed, did address the significance of
"the cut carotid."(57)
Dr. Larson testified that the cut on Laurie Show's neck was between the thyroid
cartilage and the hyoid bone. He gave his opinion that this injury would cause the
tongue to, essentially, lose its anchor, resulting in movement of the tongue up into
the pharynx. Dr. Larson testified that the trauma to the neck would have caused
the tongue to change its position and occlude the air passage necessary to create
speech. (N.T., PCRA at 2418.) Dr. Larson appeared to this court to be
knowledgeable about the speech process. He could say what would happen if a
certain portion of the vocal tract is impaired or destroyed. He could not, however,
testify with any expertise about what actually might happen to the structures
effecting the vocal tract given certain physical injuries. His knowledge in this area is
only theoretical. He must make certain assumptions about the impact of certain
trauma on the vocal tract. With these assumptions, he can then conclude what the
possible effect on the victim's ability to form words, syllables or sounds might be.
Perhaps if Dr. Larson's analysis of the mechanisms of speech had been supported
by credible and persuasive medical testimony, his opinion and explanation might
have been more helpful to the court. The medical witnesses offered by petitioner
did not provide the necessary medical support for Dr. Larson's theoretical
explanations of the process of human speech.
Michael M. Baden, M.D., was the first medical expert called by petitioner. He is a
forensic pathologist from New York City and has extremely impressive credentials.
He was originally contacted by the Commonwealth, who decided not to call him as
a witness after receiving his report. (See Report of Dr. Baden, Petitioner's Exhibit
3011.) They disclosed the report to petitioner and petitioner's counsel called Dr.
Baden.
His opinion, in essence, was that Laurie Show would have died within a few minutes
of receiving her wounds. He felt she would have had to lose consciousness within
three minutes and suffer brain death within two minutes after that. (N.T., PCRA at
3165-66.) If her left carotid was severed, she would have lost consciousness within
a minute or so. (N.T., PCRA at 3169.)
There were several troubling aspects to Dr. Baden's evaluation. His report referred
to the victim of this case as Lisa Michelle Lambert.(58) Dr. Baden also opined from
his review of the autopsy report and testimony relating to the autopsy that there
was no dissection of the neck. (N.T., PCRA at 3175.) He believes there was an
obligation to dissect the neck. (Id.) In fact, the testimony of the physicians who
performed the autopsy, and the physicians who took the time to review the autopsy
report, was that the larynx and trachea were dissected from the neck and the
carotid examined. (N.T., PCRA at 6845.) While it does not appear that the carotid
artery was taken apart, piece by piece, while it lay inside the neck of the victim, it
was dissected and tied off. It was Dr. Penades who noted upon examination of the
carotid artery after the neck had been dissected that the carotid was not cut and
that it was intact. (N.T., Trial at 96.) How Dr. Baden could offer an opinion as to
January January
Sunday
22, 201722, 2017
Page 2019
1017 of 2301
1299
the autopsy procedure and the integrity of the carotid artery in light of this clear
testimony and statement in the report defies belief. He created the impression for
this court that his analysis may well have been hurried in the midst of other
pressing matters.
Dr. Baden focused more on the cause of death and the time of death in relation to
the time of the infliction of the injuries. He gave a range of time within which Laurie
Show would have lived given certain assumptions as to the nature and extent of
the injuries to her neck. He specifically noted that he could not tell from the
autopsy photographs whether the carotid artery was severed. He made the
statement that an EMT would be in a better position to give an opinion as to the
carotid artery given the EMT's opportunity to observe the injury at the scene.(59)
(N.T., PCRA at 3197.) He offered no support for this belief. Dr. Baden appeared to
this court to beg the issue of whether the carotid artery was, in fact, cut by
deferring to the observations of the EMT, Ken Zeyak, who testified earlier in the
hearing. With the opportunity to observe Dr. Baden on the witness stand and to
attempt to reconcile his testimony with other evidence in the case, we found this
statement to be patently unbelievable. Later in the hearing, Dr. Levin, a throat
surgeon, testified that medical students and medical residents who observe neck
surgery are often unable to pick out structures in the neck and throat area without
guidance from a more experienced physician. (N.T., PCRA at 6244.)
We believe it is likely that Dr. Baden was attempting to be respectful of other
witnesses in this proceeding and that his choice to "defer" to the EMT testimony
was, in reality, a way of saying that he, himself, could not tell whether the carotid
artery was cut. Dr. Baden did not offer an in-depth discussion of the impact of the
neck wounds of Laurie Show on her mechanisms of speech. This would have been
the medical testimony necessary to give support and credence to Dr. Larson's
explanation of the speech processes. Dr. Baden provided no significant medical
support for Dr. Larson's opinion regarding the mechanisms of speech involved in
this case.
Petitioner's next dying declaration expert was John E. Smialek, M.D., chief medical
examiner for the State of Maryland. Dr. Smialek offered an opinion that was
interesting but implausible given other evidence in the case. According to Dr.
Smialek, Laurie Show did not die from the horrific lacerations to her neck. Rather,
she bled to death from the stab wound to her back. (N.T., PCRA at 3276-77.) In
fact, she bled to death so quickly from the stab wound that she was dead when her
throat was cut, according to Dr. Smialek. We know that the throat was cut before
Ms. Buck and Ms. Lambert left the condominium and we know that Laurie Show
demonstrated signs of life to a number of personnel, medical and otherwise, that
morning. Thomas Chapman felt a pulse and observed Laurie move her leg, (N.T.,
PCRA at 914), Charles Robert May noted faint ventricular fibrillation, goose bumps
and lip movement, (N.T., PCRA at 1430-32, 1434), Lisa Hinkle Billiter observed
ventricular fibrillation some time after Mr. May, (N.T., PCRA at 1018), and Mrs.
Show observed Laurie communicating the identity of her killer, (N.T., PCRA at
5658). For Dr. Smialek to be believed, all these other witnesses would have to be
completely disbelieved.
Dr. Smialek offered an interesting medical view of an alternative scenario. He did,
however, note that it was impossible to tell from the autopsy photographs whether
the carotid artery was severed. (N.T., PCRA at 3282-84.) Dr. Baden also found it
January January
Sunday
22, 201722, 2017
Page 2020
1018 of 2301
1299
difficult to tell from the photographs if the carotid was severed. (N.T., PCRA at
3197.) These two experts, called by petitioner, cast serious doubt on the witness
who appeared to provide the most convincing testimony to the federal district
court: Ken Zeyak.
Mr. Zeyak was at the time a volunteer EMT and was the first of the medical
personnel to arrive in the condominium that morning. Mr. Zeyak had EMT training
for five months, eight hours per week. He believes he learned the location of the
carotid artery in basic anatomy. He admitted that the training he received as a
registered nurse, subsequent to this incident, provided him with much more
anatomy training. He recalled a clear observation of the left carotid and noted that
it was severed, it was spasming and no blood was coming from the artery. (N.T.,
PCRA at 706.) He has never in his life seen an autopsy nor seen an exposed carotid
artery. (N.T., PCRA at 718.) He has no good idea of the basic anatomy of the neck
as was evidenced by his answers on cross-examination. (N.T., PCRA at 719-723.)
In his EMT training he never observed an autopsy, never observed surgery, never
looked at a cadaver, never viewed a model of the neck structures, though he
believes there may have been diagrams of the carotid in one of his anatomy texts.
(N.T., PCRA at 718, 746-47.) It was interesting and instructive as to Mr. Zeyak's
credibility that he was able to identify the carotid artery on photographs,
(Petitioner's Exhibit 1514A; N.T., PCRA at 743), which were of no help to two world
famous forensic pathologists, Drs. Baden and Smialek. (60)
Dr. Levin, a professor of otolaryngology at the Penn State College of Medicine in
Hershey, Pennsylvania, testified in the Commonwealth's case. Dr. Levin also
testified at the federal habeas proceeding in 1997. Dr. Levin performs surgery on
the neck at least three times per week. Much of his experience is in the oncology
field and he has some experience in traumatic injuries to the neck and throat.
Dr. Levin testified that it was "very unlikely" that Laurie Show's carotid artery was
cut. (N.T., PCRA at 6172.) He based this on the autopsy report and autopsy and
crime scene photographs. In direct contradiction of Mr. Zeyak, Dr. Levin testified
that he could not see the carotid artery, much less a cut carotid artery, on any of
the autopsy photographs. He opined that the carotid artery lies deep to the
sternocleidomastoid muscle and offered his opinion from the photographs that the
sternocleidomastoid muscle was intact on Laurie Show. (N.T., PCRA at 6175.)
According to Dr. Levin, several of the "strap muscles" anterior to the
sternocleidomastoid muscle were severed and a portion of the sternocleidomastoid
muscle was cut but the muscle itself was intact. This suggested to Dr. Levin that
the carotid was intact as well. Further, Dr. Levin noted that in Dr. Penades's
autopsy report the carotid was observed and found to be uncut and intact.
Dr. Levin opined that Laurie Show could have been alive and that medically
speaking, she had the capacity to utter weak, breathy sounds such as her mother
described. (N.T., PCRA at 6185-86, 6188.) Dr. Levin also testified that with the
head cradled in the fashion described by Mrs. Show, the internal airways could
have been sufficiently closed to allow air passage through the larynx such as to
create some speech. He believes it would not have been a complete closure and
that air would have been escaping through the holes in the neck, but that some
closure sufficient for speech could have been achieved.(61) (N.T., PCRA at 6186-87.)
Dr. Burton, a forensic pathologist from the Atlanta area, testified on behalf of the
January January
Sunday
22, 201722, 2017
Page 2021
1019 of 2301
1299
Commonwealth as well. Dr. Burton was the only medical witness who
acknowledged that medicine has its limits. He testified as to the physiology and the
anatomy involved in speech, particularly in the victim of this crime. (N.T., PCRA at
6873-74.) He also testified that frequently events occur which appear to be
impossible from a medical standpoint. (N.T., PCRA at 6886-88.) Dr. Burton, in
addition to providing thorough and interesting medical testimony, articulated the
central issue for the analysis of all these expert opinions: the experts are talking
about that which is possible or impossible strictly from a medical or scientific
perspective. Dr. Burton was the only medical expert who assessed the situation
taking into account the medical facts and the clinical picture. (N.T., PCRA at 6875,
6955-56.) Dr. Burton testified that the presence of Mrs. Show may have stimulated
and aro used Laurie. (N.T., PCRA at 6875.) Dr. Baden and Dr. Smialek were
impressive with their knowledge and their background, but neither acknowledged
the need to consider the clinical picture in the context of the medical possibilities.
The clinical picture in this case is what Mrs. Show saw and heard and did.
Dr. Burton offered the following expert opinions: (1) there was no anatomic
evidence that Laurie Show could not speak, (N.T., PCRA at 6873, 6884-88); (2)
there was no forensic or medical evidence that the carotid artery was severed,
(N.T., PCRA at 6840, 6844, 6865, 6981); (3) he could not identify the carotid
artery in the autopsy photographs, (N.T., PCRA at 6841, 6988-89); (4) Laurie could
have been conscious when her mother returned to the condominium, (N.T., PCRA
at 6884, 6884-88); and (5) the carotid had been dissected by Dr. Penades, (N.T.,
PCRA at 6927, 6981-82).
Dr. Ross, the forensic pathologist for Lancaster County, was the last medical expert
to testify on behalf of the Commonwealth. Dr. Ross took exception to most, if not
all, of the expert opinions offered by Drs. Baden and Smialek. Unlike his colleagues,
Dr. Ross believes that (1) Laurie was conscious when her mother came home,
(N.T., PCRA at 7329-30, 7332-33, 7354, 7400-01, 7404-07), (2) cradling Laurie's
neck could reestablish her airway and make speech possible, (N.T., PCRA at 736162, 7388-89), (3) Laurie was capable of speech, (N.T., PCRA at 7363, 7401-02,
7403), (4) Laurie was alive when the neck wound was inflicted, (N.T., PCRA at
7310), (5) the carotid artery was not severed, (N.T., PCRA at 7302, 7378), and (6)
Dr. Penades did dissect out the neck, (N.T., PCRA at 7366). Dr. Ross, however, did
agree with the defense experts on one thing: one cannot identify the carotid artery
on the autopsy or crime scene photographs. (N.T., PCRA at 7369.)
This collection of expert opinions all goes to whether the testimony of Mrs. Show in
July 1992 was credible. Experience teaches that expert opinion is sometimes
helpful, sometimes not. Experts once thought the world was flat. Dr. Burton's
admonition that we must look at the clinical picture in conjunction with the medical
evidence is most helpful. Drs. Levin, Ross, Penades, Annese and Burton all testified
that what Mrs. Show perceived was possible. They did not say it happened, they
did not say it did not happen. They only said that what Mrs. Show observed was
medically and physiologically possible.
For purposes of our PCRA hearing, all this testimony comes under the heading of
"after-discovered evidence." The court must inquire as to whether this evidence
was unavailable at trial, is exculpatory and whether it would have changed the
outcome of the trial. Reese, 444 Pa. Super. at 44, 663 A.2d at 209. On the first
issue, all of this evidence was available at trial. The essential facts, the autopsy
January January
Sunday
22, 201722, 2017
Page 2022
1020 of 2301
1299
photographs, the autopsy report and the essence of the dying declaration, were all
well known in 1991 and 1992. Had petitioner chosen to do so, she could have
called expert witnesses to testify as to what Drs. Baden, Smialek and Larson said at
the PCRA hearing. Nothing about the essential facts as to the dying declaration has
changed. The only after-discovered evidence is the expert analysis of those facts.
This court does not believe that an expert's opinion is after-discovered evidence.
Expert opinion may well be a subsequent interpretation of the available evidence
and might be "after-discovered" in the sense that no one inquired as to these
opinions at the time of the trial. But the essential facts, the evidence on which the
opinions are based, are the same today as they were in 1991 and 1992.
Is the after-discovered evidence exculpatory? The opinions are mixed and there is a
disagreement among the experts as to whether Laurie Show could have spoken.
Certainly the opinions of experts who testified favorably as to petitioner would be
exculpatory as to her position. Yet these are only exculpatory opinions, not
exculpatory facts or evidence.
Finally, would the new "opinions" have changed the outcome of the trial? This court
has considered the expert opinions in 1992 and the expert opinions in 1998 and
finds nothing that would have changed the verdict in this case. The testimony of
Dr. Larson, a speech professor, was informative but largely in a theoretical sense.
He "pic ked out" the carotid artery on the autopsy photographs and offered an
opinion that it was severed. But Drs. Baden, Smialek, Levin, Burton and Ross, all
medical doctors, said that they could not determine whether the carotid artery was
severed from a review of the same photographs. Dr. Larson's opinion as to the
impact of the neck wounds on the movement of Laurie Show's tongue was disputed
by Drs. Levin, Burton, and Ross. No medical witness called by petitioner was able
to give credible supporting medical testimony for Dr. Larson's explanation. Dr.
Larson's understanding is based largely on charts, diagrams and photographs. In
the face of the overwhelming medical evidence presented by the Commonwealth,
both at trial and at the PCRA hearing, his expert opinion fell short.
In an analysis of whether the new "opinions" would have changed the outcome of
the trial, we begin with the testimony of Mrs. Show. We found her to be credible in
the 1992 trial. At that time, the court had the benefit of the testimony of Dr.
Penades and Dr. Annese, both of whom carefully observed the structures in Laurie
Show's neck during the autopsy. We found them to be credible. Based on their
examination of the neck wound, the vocal tract, and the structures of Laurie Show's
neck during the autopsy, they offered opinions which have yet to be contradicted in
any credible way.
Petitioner's case, led principally by Dr. Larson, assumes that Laurie Show's carotid
artery was cut. The court is asked to conclude on this basis that there was no
possibility of speech and that death followed the infliction of the wounds in a very
short period of time. We find that there is conclusive evidence that the carotid
artery was not cut. Petitioner would have this court ignore the autopsy report and
the testimony of Drs. Penades and Annese. In the alternative, petitioner would
have us believe that the autopsy report was falsified and that these two physicians
lied under oath about findings in the autopsy. We simply find no support anywhere
in the record of this case for that argument. We observed Drs. Penades and Annese
testify, we considered their testimony and find no basis to conclude that they were
January January
Sunday
22, 201722, 2017
Page 2023
1021 of 2301
1299
lying.
The testimony of the EMTs carries no weight on this issue. Only Mr. Zeyak is sure
that the carotid artery was cut but he did not, and does not, have the medical
expertise to make this finding. Dr. Baden's and Dr. Smialek's testimony that Laurie
Show would have died, or would have been without brain function, before Mrs.
Show arrived is contradicted by witnesses at the scene who observed signs of life.
The medical personnel and neighbors arrived well after Mrs. Show came back into
her home and found her daughter. The more credible and persuasive expert
testimony was that of Drs. Levin, Burton, and Ross.
This "battle of the experts" has not shaken the credibility of Mrs. Show on this
issue. Petitioner contends that Mrs. Show did not tell anyone that Laurie said
"Michelle did it" until nearly two hours after the murder. (Exhibit A, Section A at
para. 61.) Lisa Hinkle Billiter, the registered nurse on Community Hospital's life
support unit which responded to the scene, testified that after attending to Laurie,
she and the other medics left the bedroom and approached Mrs. Show in the living
room to inform her that they were unable to do anything further for her daughter.
At that time, Mrs. Show "explained that she felt that Laurie had -- that she'd been
setup, that she had been made to go to the school for a guidance counselor
appointment that was never to occur, and that Lisa had -- or excuse me -- that
Laurie had said to her Michelle did it." (N.T., PCRA at 1025-26.) This statement (62)
by Mrs. Show occurred well before her police interviews and reveals that
petitioner's contention that the dying declaration was "suggested" to her by the
police is baseless.(63)
No expert has established that it would have been impossible for Laurie Show to
speak. In fact, competent and credible expert testimony proves in a clear and
convincing way that the dying declaration was possible. No evidence was presented
in 1992 or has been presented in the PCRA hearing which would cause this court to
change its finding that Mrs. Show was credible in 1992 when she testified as to her
daughter's dying declaration. The expert opinions in 1998, had they been presented
in 1992, would not have changed the outcome of the case.
The "29 questions" is a document which was passed between Ms. Lambert and Mr.
Yunkin at the Lancaster County Prison between the time of their arrest and Ms.
Lambert's trial. (64) How can a document which was of no consequence to the fact
finder in 1992 take on significance six years after the trial? Petitioner contends that
certain after-discovered evidence regarding this document gives it added weight
and points toward the culpability of Mr. Yunkin and away from the culpability of Ms.
Lambert. The after-discovered evidence is the fact that Lawrence Yunkin was
probably not truthful and forthcoming in his testimony about the "29 questions" in
the 1992 trial.
That would have, perhaps, some significance to this court as the fact finder in the
PCRA context had the court given any weight to Mr. Yunkin's testimony in the first
instance. This court made clear in its opinion on the post verdict motions that it did
not find Mr. Yunkin credible and had many reservations about the veracity and
reliability of the "29 questions." See Commonwealth v. Lambert, July 19, 1994,
January January
Sunday
22, 201722, 2017
Page 2024
1022 of 2301
1299
slip op. at 11-12.

All Mr. Yunkin really said about those questions and answers is that he
remembered a similar document, that he recalled the questions being written in
pencil and that he wrote answers in pen. (N.T., Trial at 274-79.) He believed that
the document marked Petitioner's Exhibit 1119 at the PCRA hearing and
Defendant's Exhibit 5 at the 1992 trial was not the document on which he actually
wrote. (N.T., Trial at 276.)
At the 1992 trial, the defense produced John C. Gencavage, a handwriting expert
who examined the document. He offered his opinion that the document contained
no erasures and no graphite, indicating that there had been no pencil writing on the
document. (N.T., Trial at 869.) Mr. Kenneff stipulated to this testimony on the basis
that he had the document examined by a Pennsylvania State Police document
examiner as well. (N.T., Trial at 888-89.) There was never any effort by the
Commonwealth to hide what Mr. Yunkin said or to somehow bolster what Mr.
Yunkin said with expert testimony. Mr. Kenneff freely and openly acknowledged
that his expert's analysis of the document was consistent with the defense expert
and these expert opinions were both inconsistent with Mr. Yunkin's testimony.
Mr. Kenneff made the appropriate argument that these facts went to the veracity of
Mr. Yunkin and the reliability of the document. Mr. Kenneff further argued that the
court was free to accept all, part, or none of the document and the testimony
regarding the document.(65) (N.T., Trial at 1231-32.)
In 1992 and today, this court assessed the "29 questions" as inherently suspicious
and of very little help to the fact finder. (A copy of this document is attached to this
opinion in the "Addendum to Opinion.") To say this document is a "confession" by
Mr. Yunkin(66) is simply wrong. This is a document which contains answers which
are barely responsive to the questions. The questions contain words which are
crammed in the spaces and the questions are, if nothing else, entirely self-serving.
A number of possibilities exist. One is that Mr. Yunkin did, in fact, answer a
questionnaire which was written in pencil and that Ms. Lambert then traced his
answers onto another document all in pen. This would alleviate the erasures and
the traces of graphite. Another possibility is that there were several such
documents circulated between Ms. Lambert and Mr. Yunkin. At the PCRA hearing,
Petitioner's Exhibit 1474 was offered into evidence. This was a copy of another
questionnaire which appears to be in the same or similar handwriting as appears on
Petitioner's Exhibit 1119.
The "29 questions" does not take on the stature of after-discovered evidence
simply because a federal judge disagreed with a state judge's analysis of the
document's importance. Perhaps the "29 questions" would have raised a reasonable
doubt to the federal judge and perhaps, standing alone, this inherently unreliable
document would have served as the basis for his conviction of Mr. Yunkin.
The reality of this case is that the "29 questions" was fully and well considered in
the 1992 trial. Mr. Shirk made every possible use of this document, pointing out to
the court that Mr. Yunkin appeared to have made admissions as to his involvement
in the murder, that Ms. Lambert's story that she was covering for Mr. Yunkin is
buttressed by the "29 questions" and that, if nothing else, the "29 questions"
created a reasonable doubt as to who was actually in the condominium and who
January January
Sunday
22, 201722, 2017
Page 2025
1023 of 2301
1299
actually killed Laurie Show. Subsequent discussions of that document have not
changed this court's mind as to its importance in 1992 or today.
Mr. Kenneff never hid his belief that Mr. Yunkin was not being forthright about that
document. In truth, no one involved in the 1992 trial could quite figure out who
wrote what on that document and what it meant. Had the Commonwealth been
able to use that document in a way to implicate Mr. Yunkin, this court believes the
Commonwealth would have done so. At no time in 1992 did the Commonwealth
evidence any interest in removing Mr. Yunkin from the case. In fact, in Mr.
Kenneff's closing, he noted that "his heart, his mind, and his stomach" told him
that Mr. Yunkin participated in the murder of Laurie Show. (N.T., Trial at 1272.)
To say that Mr. Yunkin's testimony that he wrote answers in pencil was perjury is
interesting. Under this world view, any testimony that differs from any other
testimony might well be "perjury" in the eye of the person who disagrees. In this
case, that would mean that at least one or more of the experts who testified are
perjurers. Certainly they did not agree and they gave diametrically opposed
testimony on certain basic facts, i.e., whether the carotid artery was severed.
With respect to the "29 questions," all petitioner can say is that Mr. Yunkin testified
in a way that was disputed by expert testimony. That argument goes to the weight
of Mr. Yunkin's testimony and the court gave little weight to Mr. Yunkin's
testimony.
Subsequent developments, i.e., the appearance of Petitioner's Exhibit 1474, (67)
would suggest that Mr. Yunkin may well have not perjured himself with respect to
the "29 questions." It is now clear that there was more than one document passed
between Ms. Lambert and Mr. Yunkin. Could Petitioner's Exhibit 1474, which is a
copy, have been originally written partly in pen and partly in pencil and used in
some fashion by Ms. Lambert to create a document written entirely in pen? Did she
include words and omit words so as to compose questions suited to the answers?
These are all questions that are unanswered and unanswerable.
For the purposes of analysis of the evidence in this case, the "29 questions" was
and remains an unreliable, inconclusive document. At best, it would have
established a reasonable doubt. This court found that it did not and that finding has
not been assailed by anything other than sound and fury, signifying nothing.
C. The Abuse Issue
Dr. Ann W. Burgess testified for a full day on "battered person syndrome" and its
application to this case. Dr. Burgess holds a doctorate in psychiatric nursing and is
a professor at the University of Pennsylvania. She was described by petitioner's
counsel as the world's leading expert on the psychology of battered women.
"Battered person syndrome" testimony is generally admissible under Pennsylvania
law for the very limited purpose of showing a defendant's state of mind as it relates
to self-defense in murder prosecutions.
In Commonwealth v. Gallagher, 519 Pa. 291, 547 A.2d 355 (1988), the
Supreme Court ruled that an expert witness's testimony regarding a victim's
affliction with "rape trauma syndrome" took the issue of the victim's credibility from
January January
Sunday
22, 201722, 2017
Page 2026
1024 of 2301
1299
the jury and was, therefore, improper. In Gallagher, the expert witness was Dr.
Ann Burgess, who testified that aspects of the syndrome could affect a rape
victim's ability to identify the rapist. In commenting on Dr. Burgess's testimony,
the Pennsylvania Supreme Court stated: "It is clear that the only purpose of the
expert testimony was to enhance the credibility of the victim." 519 Pa. at 297, 546
A.2d at 358 (emphasis in original). The Court went on to note:
The question of whether a particular witness is testifying in a truthful manner is one
that must be answered in reliance upon inferences drawn from the ordinary
experiences of life and common knowledge as to the natural tendencies of human
nature, as well as upon observations of the demeanor and character of the witness.
. . . [T]he question of a witness' credibility has routinely been reserved exclusively
for the jury.
Gallagher, 519 Pa. at 297, 546 A.2d at 358 (quoting Commonwealth v. Seese,
512 Pa. 439, 443, 517 A.2d 920, 922 (1986) (citations omitted; emphasis added)).
The Court added that "[s]uch testimony would invest the opinions of experts with
an unwarranted appearance of authority on the subject of credibility, which is
within the facility of the ordinary juror to assess." 519 Pa. at 297, 547 A.2d at 358
(footnote omitted).
In 1997, the federal district court accepted Dr. Burgess's testimony to bolster Ms.
Lambert's credibility. The testimony was used almost exclusively for that purpose.
The federal district court noted that Dr. Burgess's testimony "explain[s] why for so
long [Ms. Lambert] covered for. . .Yunkin." Lambert v. Blackwell, 962 F. Supp. at
1535. (68)
The most recent development in the use of battered person syndrome is seen in
Commonwealth v. Miller, 430 Pa. Super. 297, 634 A.2d 614 (1993), appeal
denied 538 Pa. 622, 646 A.2d 1177 (1994). In Miller, battered person syndrome
expert testimony was admissible on the question of the reasonable belief
requirement of self defense in a case which involved a history of abuse between the
victim and the defendant. The Superior Court confirmed earlier jurisprudence in this
area by stating that such evidence is not admissible "to improperly bolster the
credibility of the defendant. . . ." Id. at 313, 634 A.2d at 622. The use of expert
testimony to exp, lain the statements made by the defendant after the killing
improperly invades the providence of the jury. Id. at 311 n. 3, 634 A.2d at 622
n.3. Under Miller, battered person syndrome might be relevant if the victim of the
killing had been the abuser.
But that is not the way it was offered in this case. The battered person syndrome
was offered for the following purposes:
(1) to explain why Ms. Lambert "covered up" for Lawrence Yunkin;
(2) to explain why Ms. Lambert refused to give Mr. Shirk the "29 questions" until
several months after the murder;
(3) to explain why Ms. Lambert told one story to Detective Solt, another story to
the court in 1992, and another story in her deposition, the federal habeas hearing,
January January
Sunday
22, 201722, 2017
Page 2027
1025 of 2301
1299
and the PCRA hearing;

(4) to explain why Ms. Lambert was of little help to Mr. Shirk and Mr. Epstein
during the litigation of the post verdict motions; and
(5) to explain why Ms. Lambert finally told the "real story" in her hand written
federal habeas petition, composed on the floor of her cell in New Jersey by the light
streaming in under her cell door.
The Commonwealth moved to exclude the testimony of Dr. Burgess on the basis
that it was "bolstering" testimony which went only to enhance the credibility of Ms.
Lambert. The Commonwealth cited to the Gallagher and Miller decisions, and
other Pennsylvania appellate decisions in support of this argument.(69) This court
agreed with the Commonwealth's position that the testimony of Dr. Burgess insofar
as it explains why Ms. Lambert told one story, changed her story, covered up for
another person, took the blame for the murder or protected her paramour, is not
relevant under any reading of Pennsylvania law.
We allowed Dr. Burgess's testimony on the narrow issue of waiver. That is,
petitioner asserted a concern that the Commonwealth might ask this court to
dismiss the petition because it was not filed within the applicable statute of
limitations, i.e., one year from the date the judgment became final. See 42 Pa.
C.S.A. Section 9595(b)(1).
At the PCRA hearing, counsel for the Commonwealth did not take a position on
whether the petition was barred by the statute of limitations. It was determined
that this argument would be made at the conclusion of the hearing after all the
evidence was in and the parties were given an opportunity to assert legal
argument. It seemed appropriate to consider Ms. Lambert's state of mind during
the 1992 through 1997 time frame to the extent it explained why she did not file a
PCRA in a timely fashion.
At this point, the Commonwealth has made no motion to dismiss the petition for
failure to file within the required time. In fact, it appears there was no issue
regarding the limitation period. The narrow issue, therefore, on which Dr. Burgess's
testimony was permitted is not, in fact, an issue in this case.
Yet, consistent with the history of this case, we are required to discuss an issue
which has great emotional and public appeal while having little or no legal
importance. The issue of abuse in this case has taken on a life of its own. The issue
of abuse is central to Ms. Lambert's emotional case. Because Ms. Lambert's status
as a victim is central to almost every claim she raises, a full analysis of the truth of
her case requires an analysis of the expert testimony offered to secure her place in
that sad galaxy. Further, because it is clear to this court that petitioner will litigate
the issue of battered person syndrome in the appellate courts, this discussion is
included to explain our analysis and decision.
Petitioner makes much of the impact on her life of the abusive relationship she
shared with Lawrence Yunkin. Mr. Yunkin's abusive conduct toward Ms. Lambert
January January
Sunday
22, 201722, 2017
Page 2028
1026 of 2301
1299
was a central issue in the 1992 trial, the post verdict motions and the appeals to
the Superior and Supreme Courts of Pennsylvania. Mr. Yunkin's conduct was
described in vivid and detailed testimony by Ms. Lambert. Mr. Yunkin, himself,
acknowledged certain bizarre and arguably abusive behaviors when he testified. It
appeared likely to this court in 1992 that Mr. Yunkin and Ms. Lambert shared an
abusive relationship which, sadly, was not unlike many we see in the criminal
system, domestic violence system and family court. Asked to describe his
relationship with Ms. Lambert in 1992, Mr. Yunkin gave the ironic response,
"Constantly at each other's throats." (N.T., Trial at 250.) Certain witnesses ch,
aracterized the relationship as more one-sided and others pointed out that each did
a share of the arguing and the confronting.
Petitioner asserts that Mr. Yunkin's abusive, domineering and controlling persona
directed every aspect of her existence. According to Ms. Lambert, her blond hair
and blue eyes were a function of Mr. Yunkin's obsession that she look like a
"Barbie." In fact, we now know that she was bleaching her own hair blond as early
as age 13 or 14 and that she discussed with her hairdresser the damage that was
being done to her hair by the dye. (N.T., PCRA at 6373-74.) Further, during the
eight-day 1992 trial, Ms. Lambert appeared in the courtroom every day with blond
hair and blue eyes. We have learned through testimony at this hearing that the
blue eyes were created by the wearing of tinted contact lenses. We note, however,
that the trial took place eight months after her last contact with Mr. Yunkin, eight
months after her incarceration, and with no rea, son for her t, o conti, nue a
behavior pattern that was "dictated" entirely by Mr. Yunkin. In short, the assertions
about her appearance simply are not credible.
According to Ms. Lambert, Mr. Yunkin dominated her every move. Yet, the tone of
correspondence exchanged between Mr. Yunkin and Ms. Lambert after each had
been arrested would suggest otherwise. A fair reading of the letters offered into
evidence in this proceeding(70) would show that Ms. Lambert was anything but
demure and unassertive. Ms. Lambert apparently learned that Mr. Yunkin sent a
handwritten postcard to Mrs. Show from prison on December 23, 1991. The
postcard states:
I don't know what to say for what happened but I'm sorry. I know this doesn't
bring Laurie back. If I could die & take her place & let her come back, I swear to
you I would. Laurie was a nice person, and she cared about you & her father a lot
[sic]. When Michelle saw her somewhere I would try to keep her from Laurie and
that's the truth. I had nothing against Laurie. For that week we went out she was
so nice to me. I feel it was my fault for going out with her & none of this would of
happened. All I can say is I'm sorry & I didn't know. Sincerliy [sic] Lawrence
In a letter postmarked January 25, 1992, from Ms. Lambert to Mr. Yunkin, while
both were in prison, Ms. Lambert wrote the following:
Dear Sweet Pea,
Lawrence, where is your head? Why on earth did you write to Laurie's mother?
WHAT in the world did you say? You should know better than that! All her mother
has ever done, is harrass [sic] us! Just leave her alone! That post-card could end
January January
Sunday
22, 201722, 2017
Page 2029
1027 of 2301
1299
up in the paper! Are you crazy? What are you trying to pull? Her mother is telling
lies about us, trying to get us in real bad trouble, and you go and try to be buddies
with her!. . .
It is difficult to pinpoint a moment in the PCRA hearing as the most bizarre. One
likely contender, however, was the testimony by Dr. Burgess as to the sexually
explicit poem dated January 16, 1992, written by Ms. Lambert for Mr. Yunkin. Dr.
Burgess focused on one line at the end of the poem to suggest that the sexual
relationship between Ms. Lambert and Mr. Yunkin was violent, abusive and "not
pleasurable for the female." We print the poem in its entirety only to illustrate that
the author, Lisa Michelle Lambert, may well have been contemplating another kind
of relationship:
Hick-o-ry, Dick-o-ry - Dock,
I'll lick you stiff as a rock,
When the clock strikes four,
I'll shove you onto the floor,
And ride your fat hard cock.
You'll feel me fast and tight,
And make me scream all thru the night,
I'll beg for more and more,
As you pull my hair, and call me a whore,
And you ram me harder and harder,
Until the morning light.
And when you fall asleep,
I'll still make you do me deep,
And when you tiredly moan,
I'll match you with a groan,
As you hurt me 'till I weep.
(Petitioner's Exhibit 422 (emphasis in original).)
The image that Ms. Lambert now tries to market, that she was a demure,
January January
Sunday
22, 201722, 2017
Page 2030
1028 of 2301
1299
dominated, controlled victim, is contrary to so much evidence. From her verbal and
physical assaults on Laurie Show, to her planning the abduction in the summer of
1991, from planning the attack on Laurie Show on the morning of December 20,
1991, to her strongly worded letter to Mr. Yunkin in the prison, Ms. Lambert
demonstrated a character that is anything but demure and controlled.
The first reference to the alleged gang rape of Ms. Lambert came in the testimony
of Gene L. Carey, M.D., a psychiatrist from Hershey Medical Center, at the death
penalty phase of the trial of 1992. Dr. Carey volunteered that Ms. Lambert had
shared with him a description of this incident and had asked him not to mention it
in his testimony. (N.T., Penalty Phase at 58.) If, in fact, this rape occurred, it is
inexcusable and wrong. On the assumption that it did happen on June 17, 1991,
the impact of that incident on petitioner's claims for relief must be addressed. The
gang rape may be relevant for three reasons: (1) it may explain why the East
Lampeter Township police officers "framed" Ms. Lambert for the murder; (2) it may
explain why Ms. Lambert did not go to the police immediately on the morning of
December 20, 1991; and (3) it serves to buttress Dr. Burgess's characterization of
Ms. Lambert as a victim.
There is no proof that the gang rape occurred other than Ms. Lambert's own
statement. She chose not to seek medical help, she chose not to contact any
authorities, she chose not to tell her parents and she chose not to share the
experience with her boyfriend or any friend. She drew a picture of one of the
"rapists" and that picture was later "identified" in testimony by Mr. Shirk as Officer
John Bowman of East Lampeter Township Police. (N.T., PCRA at 3428-29.) On the
basis of this irresponsible "identification," serious allegations were made against
Officer Bowman at the outset of this proceeding and in the prelude to this
proceeding.(71)
Officer Robin Weaver of the East Lampeter Township Police Department was named
by Ms. Lambert as one of the rapists. Yet, no proof of this very serious allegation
was established. Rather, Ms. Lambert testified to being terrified upon seeing an
East Lampeter Township police officer at the Lancaster Catholic High Carnival within
a week of the alleged rape (or three, depending on the witness) to the extent that
she rushed to avoid any eye contact with this police officer. Her description of
terror in seeing him, buttressed by the testimony of Michael Pawlikowski, who
accompanied her to the carnival, suggested that she lived in fear of the officers
who did this to her. Yet, on August 1, 1991, in response to a harassment and
assault complaint, the very same Officer Robin Weaver spoke with Mr. Yunkin and
Ms. Lambert at the East Towne Mall for a period of 20 minutes or more. He spoke
to them about their contacts with Laurie Show and about the charge of assault and
harassment. He attempted to talk to them about their behavior. (Commonwealth's
Exhibit 51.) According to Officer Weaver's uncontradicted and credible testimony,
Ms. Lambert and Mr. Yunkin participated in this discussion with him. (N.T., PCRA at
6359-63.) This would appear to belie Ms. Lambert's position that she lived in fear of
the police offic ers, especially Officer Weaver.
Ms. Rainville, co-counselor for petitioner, went so far as to suggest throughout the
hearing that Ms. Lambert's child, born in March 1992, was the product of this gang
rape. (N.T., PCRA at 32.) Yet, we know better. In one of Ms. Lambert's letters to
January January
Sunday
22, 201722, 2017
Page 2031
1029 of 2301
1299
Mr. Yunkin while in prison, she refers specifically to the baby and to Lawrence as
the father. She wrote:
Listen to me. Yes, I told my parents they can have the baby! They are going to
take care of him until I get out. I can not give the baby to your parents, Lawrence!
Look at what your parents did to you! Your mom "babied" you so much, you can't
even think for yourself!
(Commonwealth Exhibit 10 (emphasis in original).) Ms. Lambert then wrote in the
same letter:
Another thing, you weren't even happy when I told you I was pregnant! You hit me,
and went out and slept with that tramp! And then, for 4 months after that, you
didn't even believe I was pregnant! As far as I'm concerned, this baby doesn't have
a father!
Lawrence, I love you, but because of how horrible you've treated me , I love the
baby more. I love the baby more, because he is the good part of you.
We know as a matter of public record here in Lancaster County that the custody of
her daughter has been the subject of several court proceedings. We know that Mr.
Yunkin has acknowledged paternity and we know that DNA testing was conducted.
Judge Wayne G. Hummer of this court wrote: "DNA testing has been completed and
found that Lawrence Yunkin was not excluded as the biological father of the said
child and calculated that the probability of paternity was 99.98 %. Defendants
[Leonard M. Lambert, Judy L. Lambert and Lisa Michelle Lambert] have not
objected to these results." Yunkin v. Lambert, No. 102 -1993, slip op. at 2 (Lanc.
Co. C.P. June 29, 1994) (court held that the Yunkins, as paternal grandparents,
had standing to request custody of Ms. Lambert's and Mr. Yunkin's daughter). Does
it appear curious to anyone beside this court that Ms. Lambert will allow her
attorney to assert that one of the rapists was the father of her daughter while
choosing not to contest DNA evidence that Lawrence Yunkin was the father of the
child by a probability of 99.98 percent?
The fact of the gang rape has little, if any, legal significance in the analysis of the
issues raised by the PCRA petition. It has enormous significance in creating a level
of emotional intensity and sympathy, which drives much of petitioner's case.
It would be a tragic and inexcusable event if, indeed, it took place. The level of
sorrow one might feel for petitioner having undergone such terrible treatment has
no bearing, however, on the legal significance of that event to her case. Whatever
occurred on June 17, 1991, has no place in the analysis of petitioner's claims.
The gang rape is in this case only to give the police a motive to frame Ms. Lambert
for the murder of Laurie Show. To believe this, the court must believe that Officer
Weaver, upon entering the Show condominium on December 20, 1991, observed a
dying teenage girl and thought first to use the event to frame Ms. Lambert. To
believe this, the court must accept that Detective Savage took a grieving mother
January January
Sunday
22, 201722, 2017
Page 2032
1030 of 2301
1299
aside within an hour of her daughter's death and planted in her mind the
suggestion that her daughter made a dying declaration. To believe this, the court
would have to accept that these police officers were acting first and foremost in an
effort to use the murder of Laurie Show to frame a woman who was gang raped six
months earlier by them or by members of their department. This is just not
believable.
Nor does the gang rape explain why Ms. Lambert failed to go to the police on the
morning of December 20, 1991. In fact, given every opportunity to explain to the
police and at trial why she did not report the murder after she fled from the
condominium complex, she never mentioned fear of the police because of a "gang
rape." She talked about Mr. Yunkin watching her "like a hawk," she talked about
being afraid of Ms. Buck, and she talked about not having access to a telephone.
Yet, she went to collect her paycheck, she went to the local mall, she went to Mr.
Yunkin's grandmother's home, she went back to Ms. Buck's residence and then
ultimately to the bowling alley. It strikes this court as unbelievable that Ms.
Lambert failed to report this incident to anyone because of fear of the police arising
out of the "gang rape."
Except as support for Dr. Burgess's characterization of Ms. Lambert as a victim, the
gang rape has no legal significance in this case. As we discussed earlier in this
section, Dr. Burgess's evaluation of Ms. Lambert would not be admissible under
Pennsylvania law to explain her conduct, her statements, or her choice to "cover
up" for Mr. Yunkin. The expert opinion that Ms. Lambert is a victim of abuse and
that she, therefore, acts in certain ways because of this status, has no bearing on
any legal issue in this case.
The gang rape would neither explain nor would it justify the well documented
course of physic al and verbal assaults by Ms. Lambert on Laurie Show, a history of
stalking Laurie Show and the plot to kidnap and do serious physical harm to Laurie
Show. Nor would it excuse the plan to go to her condominium on December 20,
1991, to cut off her hair, an incident which has been irresponsibly referred to as a
"prank." For these reasons, we find that the gang rape has no legal significance in
this case. There is no factual support in the record. It certainly would not explain
any of petitioner's actions nor would it explain or call into question the conduct of
the police during the course of the investigation of this case.
Petitioner contends that she was subjected to brutal, degrading and long lasting
mistreatment while at the State Correctional Institution at Cambridge Springs. It is
true that a corrections officer was convicted of sexual offenses having to do with his
conduct with Ms. Lambert. She contends this was a repeated and prolonged course
of prison rape. The facts suggest otherwise.
The perpetrator of these incidents with Ms. Lambert was convicted of aggravated
indecent assault, indecent assault and official oppression. He was not charged with
nor was he convicted of rape or any of the other sex offenses involving force or lack
of consent.(72) It appears from the evidence at the PCRA hearing that Ms. Lambert
and this corrections officer had a voluntary sexual relationship and that he was
convicted because he was a corrections officer and she was an inmate. In fact, in
January January
Sunday
22, 201722, 2017
Page 2033
1031 of 2301
1299
her conversations with her counselor in prison, Ms. Lambert referred to the
perpetrator as "her buddy." (N.T., PCRA at 7564.) She also justified her
relationship with this man by telling her counselor: "[M]y hormones are up to here
[the counselor gestured by raising her hand above her head]. . . . All the other
women have everybody else out there, outside the fence, and I have what's in
here." (Id.)
To suggest that the incidents involving Ms. Lambert were not "rape" is not to
diminish them or to excuse them. They should never have happened and the state
corrections system and the authorities in Crawford County took action in response
to this conduct. Interestingly, it was not Ms. Lambert who reported the conduct.
Rather, she was contacted by investigating authorities. In fact, she denied having
any relationship with the perpetrator in the initial interviews. (N.T., PCRA at 7578.)
The significance of the conduct at Cambridge Springs is high in emotion and low in
legal relevance. No prison inmate should be subjected to official oppression nor
should any inmate be subjected to indecent assault. Yet, these incidents do not
excuse murder, they do not excuse a period of intense harassment or stalking of
the victim which occurred in 1991, and they do not call for a new trial. The
Cambridge Springs incidents enhance petitioner's victim status which, once
established and enhanced, goes nowhere. It appears that the narrow legal
significance would be to explain how little Ms. Lambert was able to offer in assisting
Mr. Epstein in litigating her post verdict motions.(73) That may well be true. Yet,
there was no prejudice because Mr. Epstein did a credible and thorough job
representing Ms. Lambert. She has been given every opportunity to litigate every
meritorious claim, and many other claims, in the federal proceeding and in this
PCRA.
Tabitha Buck received a severe scratch on her face on December 20, 1991. There is
no question that she received that scratch either in the Show condominium or
during her flight across the field and through the trees to Mr. Yunkin's car. Ms.
Buck has no explanation for when she got the scratch, but does not deny she
sustained the injury during or immediately after the murder.
Petitioner's counsel devote substantial energy to this issue and to the suggestion
that the police somehow "overlooked" this scratch. Petitioner's counsel suggest that
because Ms. Buck had a scratch and Ms. Lambert had no scratches or bruises, that
Ms. Buck must have been the murderer.
In fact, Ms. Buck is a convicted murderer. She was found guilty by a jury of second
degree murder arising out of the events of December 20, 1991. The prosecuting
attorney and police officers in this case never wavered from their position that Ms.
Buck was fully involved in the murder. The fact that the victim may well have
injured Ms. Buck and did not injure Ms. Lambert does not prove that Ms. Lambert is
innocent. At best, it proves that Ms. Buck was, in fact, involved and this issue has
already been proven beyond a reasonable doubt to a jury.
January January
Sunday
22, 201722, 2017
Page 2034
1032 of 2301
1299

The same holds true with evidence of Ms. Buck's animus toward Laurie Show. There
was testimony at the PCRA hearing from Rick Lentz that he was in Laurie Show's
company when she was verbally assaulted and "smacked around" by Ms. Buck in
the fall of 1991. (N.T., PCRA at 2945-46.) This testimony would only go to support
Ms. Buck's involvement in the murder. Ms. Buck has been convicted of murder.
Proof of her actions toward Laurie Show or her animus does not disprove
petitioner's actions or animus. The evidence of Ms. Buck's animus is of no relevance
to this PCRA proceeding.
The police used a bloodhound to search for evidence along the Susquehanna River.
See Section VII.K, infra. Mr. Shirk testified that he did not know that Ms. Buck's
sweater was used to scent the bloodhound. (N.T., PCRA at 3364.) However, he also
stated that he had received and reviewed Officer Reed's river search report which
clearly states: "A white sweater worn by def. Tabatha Buck was brought to the
scene by myself for use of the blood hound [sic]." (Petitioner's Exhibit 1295.)
Ms. Lambert admitted buying the rope, (N.T., Trial 991-92), admitted agreeing with
Ms. Buck and Mr. Yunkin to use the rope to tie up Laurie Show, (N.T., Trial at 100001), and admitted watching as Ms. Buck cut off a portion of the rope, (N.T., Trial at
1000). Of course, Ms. Buck's scent was on the rope. However, just because Ms.
Buck's scent was on the rope does not mean that Ms. Lambert's was not. There was
no testimony that the dog attempted to trace Ms. Lambert's scent and failed. This
"evidence" that Ms. Buck's scent was on the rope does not exculpate Ms. Lambert.
Tabitha Buck's testimony in this hearing marked the first time she has testified
under oath in a courtroom about the events of December 20, 1991. Previously she
testified in a deposition as part of the federal proceeding but was not called as a
witness. We discuss Ms. Buck's testimony in this section because it is relevant to
Ms. Lambert's involvement in the killing of Laurie Show, it is relevant to the extent
it corroborates or disputes essential facts which have been called into question by
petitioner, and it is relevant to the core issue of Ms. Lambert's petition: that she is
an innocent woman wrongly convicted.
Ms. Buck first met Ms. Lambert and Mr. Yunkin in September 1991 while riding "the
loop" in Lancaster. (74) (N.T., PCRA at 6617-18.) Ms. Buck was 17 years old at the
time and was attending Penn Manor High School. She, Michelle and Lawrence "hung
out" through the fall of 1991. (N.T., PCRA at 6618.) In the fall of 1991, she became
aware of difficulties between Michelle and Laurie Show. She recalled Michelle saying
that she did not like Laurie and referring to her several times as a "bitch." (N.T.,
PCRA at 6619.)
On the evening of December 19, 1991, around 10:30 p.m., Michelle came to visit
her at the apartment she shared with her mother. Lawrence was outside in the car.
Michelle was "very upset" and "went on and on about wanting to get Laurie back. .
. ." (N.T., PCRA at 6620.) Ms. Buck described her as "crying and ranting, raving,
January January
Sunday
22, 201722, 2017
Page 2035
1033 of 2301
1299
she was upset." (Id.) Ms. Buck testified, "I asked her what she was going to do.
She said, I'll kill her." (N.T., PCRA at 6620-21.) Michelle told Ms. Buck that she
wanted her (Buck) to go with her to see Laurie the next morning. Ms. Buck was
also told to "wear [her] hair up, to not wear any make-up and not to wear any
fingernail polish." (N.T., PCRA at 6622.) Ms. Buck testified that she knew Laurie
Show "by sight" because they rode the same school bus when Ms. Buck attended
Conestoga Valley High School. (N.T., PCRA at 6623.)
Ms. Buck testified that Michelle and Lawrence picked her up on the morning of
December 20, 1991. (N.T., PCRA at 6623.) Michelle appeared to give Lawrence
directions from the intersection by the McDonald's on Lincoln Highway. (N.T., PCRA
at 6625-26.) Lawrence dropped them off on Oak View Road by a field. (N.T., PCRA
at 6626-27.) Ms. Buck understood that Lawrence was going to go to McDonald's.
(N.T., PCRA at 6628.) Michelle told him to pick them up in 15 minutes. (Id.) They
then walked across the field toward the condominium complex. (N.T., PCRA at
6628-29.) Michelle was looking for the condominium and was not sure of the
correct number. She then located the condominium. (N.T., PCRA at 6629-30.) They
went to the bottom of the steps and Michelle told Ms. Buck to go upstairs, knock on
the door and ask for Hazel Show. She did so and Laurie answered the door. Ms.
Buck asked if Hazel was home and Laurie said, "No." (N.T., PCRA at 6630-31.)
Michelle told Ms. Buck the night before that Hazel should not be there because she
had called and arranged for Mrs. Show to be at a counselor's appointment. (N.T.,
PCRA at 6631-32.)
At that point, Michelle made her way inside. Ms. Buck then described:
Michelle apparently pushed Laurie back some distance. They were, like, in front of
the kitchen area or the living room area. And they were holding each other's arms
wrestling, like, arguing, yelling. At one point, Laurie, I guess, broke away from
Michelle and came toward me and I remember Michelle saying something about
don't go, stop or something and -- oh, I did have sunglasses on. I failed to mention
that. And Laurie grabbed my face, pushed me somehow and knocked the
sunglasses off and Michelle was behind her and she had a knife and they were in
the corner there where the door meets the wall, the hinges of the door, I guess.
(N.T., PCRA at 6633-34.)
Ms. Buck then went on to describe Laurie's attempts to escape:
A. . . . Laurie coming at me, moving me. I was right there inside the doorway.
Q. Okay. Do you know what Laurie was trying to do when she came toward you?
A. My guess is she was probably trying to leave.
Q. Okay. And could she leave?
A. She didn't have a chance.
Q. And why not?
January January
Sunday
22, 201722, 2017
Page 2036
1034 of 2301
1299
A. Michelle was on her.

(N.T., PCRA at 6636.)
Ms. Buck described the knife as a "large kitchen knife" and described how Michelle
ended up huddled with Laurie in the corner near the front door. (N.T., PCRA at
6637-38.) Laurie had grabbed the blade of the knife and Michelle pulled it out of
her hand. As a result, Laurie's hands were cut. (N.T., PCRA at 6638.) According to
Ms. Buck, Laurie then got away and went into her bedroom. Michelle then "grabbed
her by the back of her hair when she walked through the door and she cut her
hair." (N.T., PCRA at 6637-39.) Ms. Buck recalls seeing Laurie with a phone in her
hand and was uncertain about what happened to the phone. (N.T., PCRA at 6640.)
Ms. Buck then went on to describe more of a struggle in the bedroom. When Laurie
was on her knees facing the bed, Michelle hit her in the back of the head with the
butt of the knife. She hit her more than twice in this way. (N.T., PCRA at 6641-42.)
Michelle then handed Ms. Buck the knife and attempted to put a rope over Laurie's
head. (N.T., PCRA at 6642.) Apparently, Michelle told Laurie to stop struggling and
to cooperate because "it would be a lot easier this way" and then she put the rope
over her head. (Id.) Laurie then began to struggle and reached for a pair of
scissors. Ms. Buck moved the scissors out of Laurie's reach. (N.T., PCRA at 664344.)
Ms. Buck testified:
Q. What happened after you moved the scissors out of Laurie's reach?
A. Michelle told me to cut her throat.
Q. Michelle told you to cut Laurie's throat?
A. Uh-huh.
Q. What did you say to Michelle?
A. I said, no.
Q. Okay. Did you still have the knife in your hand at that point?
A. Yes.
Q. What did you do with the knife?
A. Michelle took it back.
Q. What happened after that?
A. She cut her leg and told her to stop struggling.
January January
Sunday
22, 201722, 2017
Page 2037
1035 of 2301
1299
(N.T., PCRA at 6644.)

Ms. Buck then went on to describe Laurie kicking and fighting with Michelle. She
testified:
A. Michelle told me to grab her feet, make her stop kicking and I did.
Q. You did that?
A. Yes.
(N.T., PCRA at 6645.)
Ms. Buck described sitting on Laurie's feet and facing away from her. As she sat on
Laurie's feet, Laurie was struggling and at some point her feet stopped moving.
Then Ms. Buck got off her feet and looked at Laurie. When asked what she saw, she
said, "I saw her throat cut." (N.T., PCRA at 6647-48.) She noted that Michelle was
sitting next to Laurie, on Laurie's right side. She said that the throat was cut deeply
enough that she (Ms. Buck) could see into Laurie's throat and could hear a "hissing,
whooshing sound." (N.T., PCRA at 6648.) She then testified:
Q. After you turned around and saw that Laurie's throat was cut and you saw that
Michelle was still next to Laurie, did you see that the knife was still in Michelle's
hand?
A. Yes.
Q. What did you see Michelle do then?
A. When I looked at Laurie I said, is she dead? Did you kill her? And Michelle said, I
don't know and proceeded to further cut Laurie's throat.
Q. Can you describe what she did when she further cut Laurie's throat?
A. She held her chin back with her left hand and cut her throat as though she were
cutting bread.
Q. Okay. Did you see how many times that cut went across Laurie's throat?
A. Several times.
(N.T., PCRA at 6649.)
Ms. Buck related that Michelle had the tip of the knife and handed it to her. Ms.
Buck put it in her coat pocket, picked up her sunglasses and they left the
condominium. Michelle told her to put her hood up and they went back across the
complex area. (N.T., PCRA at 6650-51.) She testified that they went down the
staircase and headed in the direction toward the wooded area. They walked behind
or in a line of trees behind the Frys' condominium, went across a field and toward
the road. They ended up along the road in some bushes. Ms. Buck indicated on an
January January
Sunday
22, 201722, 2017
Page 2038
1036 of 2301
1299
aerial photograph of the condominium complex, (Commonwealth's Exhibit 5), that

she and Michelle ended up on Oak View Road north of the condominium entrance.
She testified that Lawrence was there and picked them up. (N.T., PCRA at 665155.) All she recalls about the conversation in the car was Lawrence looking over at
Michelle and saying, "Blood?" (N.T., PCRA at 6655-56.)
They then went back to Michelle's and Lawrence's trailer. Michelle and Ms. Buck
took showers. She recalls that she took the tip of the knife out of her pocket and
tossed it somewhere in a room in the trailer. She borrowed a pair of black stretch
legging pants, put on her white sweatshirt and Michelle and Lawrence took her to
school. (N.T., PCRA at 6657-58.)
Ms. Buck testified about the cut on her cheek and she believes that she got the cut
sometime during the events that occurred in the morning of December 20. (75) (N.T.,
PCRA at 6658-59.) She recalls that she took her jeans off and borrowed pants
because there was blood on her jeans. She left her Miami Dolphins jacket with
Michelle and Lawrence because they said they would wash it. (N.T., PCRA at 665960.)
On cross-examination, Ms. Buck acknowledged that she lied in her April 1997
federal deposition in that she was not complete in her answers. She also indicated
that she was not truthful when speaking to Detective Joseph Geesey when he came
to visit her at Muncy in 1997. (N.T., PCRA at 6726.) Ms. Buck testified that there
were certain significant issues which she "left out" in her deposition testimony.
These were:
(1) she did not talk about Michelle placing the rope around Laurie Show's neck;
(2) she did not talk about Michelle's feelings about Laurie Show;
(3) she did not talk about her sunglasses;
(4) she did not talk about Michelle making the last cut on Laurie Show's throat;
(5) she did not talk about Michelle telling her about the phone call to Mrs. Show the
night before. Rather, she suggested that she learned that Mrs. Show would not be
in the condominium that morning as they approached the front door;
(6) she left out the testimony about Michelle telling her not to wear make-up and
nail polish and to put her "hair up";
(7) she left out the testimony about Michelle handing the knife to her during the
attack;
(8) she left out the testimony about Michelle telling her to "cut Laurie's throat"; and
(9) she lied about wearing black stretch pants because she knew that her jeans had
blood on them and did not want to admit that. (N.T., PCRA at 6732; 6773; 6732;
6733; 6729-30; 6731-32;6732; 6733; 6732-33.)
When questioned as to why she did not tell the whole truth in her deposition, Ms.
January January
Sunday
22, 201722, 2017
Page 2039
1037 of 2301
1299
Buck testified:
A. Several reasons. One, I was very scared. I had been told for a very long time -A. I was told not to say anything to anybody for a very long time and I was left
under the impression that the more I knew of anything the worse off it would be for
me. And aside from that, I was extremely intimidated that day. And I don't expect
many people will understand this other reason. But being a lifer and having been
incarcerated a lifer for as long as I have now, I would like to see women doing a life
sentence go home, get out of jail, and I just couldn't see saying certain things,
even against Michelle, if this were going to be a chance for her to go home.
(N.T., PCRA at 6673-74.)
At Ms. Buck's deposition during the federal proceeding, she was represented by R.
Russell Pugh, Esquire, of Lancaster. Immediately following the deposition, she
wrote a letter to Mr. Pugh explaining that she had been less than completely
truthful in her deposition testimony. We reprint the entire letter in the text of this
opinion because it sheds light on the extent of Ms. Buck's untruthfulness in her
deposition and her state of mind at that time, and it contains an explanation as to
her actions. It is also significant to this court that she c hose to acknowledge her
lack of complete candor in a letter to her attorney without any prompting and
before she was ever confronted with any inconsistencies. The deposition was April
4, 1997. The letter bears the date of April 8, 1997:
Mr. Pugh,
I have not been completely honest about what happened. Most of what I've told
you is the truth but I've purposely left some things out. Some very important
things. I knew how Michelle felt about Laurie. She talked about it all the time. She
always said how she wanted to kill her. She would think of different ways to do it
and would ask me my opinion. would tell her that her plans would work and she'd
laugh. She never followed through with any of them so I truly didn't take her
seriously. At first I didn't know who she was talking about when she said 'Laurie'
but when she told me her name was Laurie Show and she went to C.V., I made a
point to find out who it was. Laurie rode my bus and I avoided her. I never spoke
to her. I doubt if she even knew my name.
When Michelle came to the apartment on the 19th, she was upset and wanted to
talk. She said she was going to get Laurie because the police were after her for an
assault against Laurie. She told me she had called Ms. Show and pretended to be a
counselor from school. She said that Ms. Show wouldn't be at home in the morning
and she wanted me to go with her. I asked her what she was going to do and she
said she was going to kill her. I didn't believe her and I told her so. Then she said
she was just going to get her back for dating Lawrence and for calling the police on
her. I had never seen Michelle fight anyone--she was all talk so I guess I just
figured she was just talking and wasn't really going to hurt Laurie. I told her I
would go with her. She said for me not to wear any nail polish or make-up and to
put my hair up. She said that way, if anything did happen --there would be no
January January
Sunday
22, 201722, 2017
Page 2040
1038 of 2301
1299
evidence of who was there. Again, I didn't take her seriously.

The next day, I wore an old pair of blue jeans that were a favorite of mine and my
white sweatshirt. When Michelle came she asked if I had any sunglasses and I said
yes. She told me to bring them. I did wear make-up and my hair was down. She
didn't say anything about it so I knew she wasn't serious about what she had said.
When we got to the apartment Michelle told me to put the sunglasses on so that
Laurie wouldn't recognize me. I told her she didn't know me anyway but she
insisted I wear them. Once we were inside the apartment, all hell broke loose.
When Laurie tried to run to the door, she grabbed my glasses and threw them in
the corner. She may have scratched me then.
In the bedroom when Laurie was kneeling over the bed, Michelle handed me the
knife after hitting Laurie with it. Then she pulled out the rope from under her shirt
(jergo) and tried to put it around Laurie's neck. She told Laurie it would look like a
suicide and if Laurie didn't give in, then she (Michelle) would get a group of pagans
to sacrifice her. Laurie stopped struggling and allowed Michelle to put the rope
completely over her head. Then she went for the scissors. When I pushed them
away Michelle told me to cut Laurie's throat. I looked at her like she was crazy and
I said 'no!' She told me to give her the knife and I did. Laurie was struggling again
and Michelle cut her leg. She told her it would be a lot worse if she didn't
cooperate. That's when Laurie started kicking again and Michelle told me to grab
her feet. In the process of getting her feet down, she kicked me in my mouth.
When I got off of Laurie's feet, I saw the neck wound and heard the air escaping. In
my mind I knew that she must be dead but I asked anyway. I asked Michelle, 'Is
she dead? Did you kill her?' She said, 'I don't know.' Then she cut Laurie's neck
even deeper. I saw her do it. That's when she said, 'Come on. Let's go.' On my way
out I picked up my sunglasses and we left.
At the trailer we took showers and Michelle gave me a pair of black stretch pants to
wear. My jeans had ripped open on one of the legs and there was blood on them.
Everything else I told you was true. I didn't think she would actually do it and once
she did--I was scared half to death. I don't know why I didn't tell you about her
calling Ms. Show. I don't know why I didn't tell you about the rope. All I know is
that I'm telling you the whole truth now. This is very hard for me to do but I figure-what do I have to lose? I'm already doing Life. I know that I lied under oath at the
deposition and I don't know what that will mean now. When I testify in court, I
want to tell the truth. I hope that it isn't too late.
I know I've disappointed you. You believed me and I lied to you. I apologize to you
for deceiving you. If you want to wash you hands of my case--I won't blame you.
Maybe I'll end up dying in prison but at least my conscience will be clear. I know
that I had no intentions of harming Laurie and I didn't believe Michelle would,
either. But maybe I do deserve this life sentence. If I'm meant to go home --God
will let me go and it won't happen without Him.
Again, I am so sorry for lying to you. I'm sorry for lying to everybody including
Detective Geesey. I hope that you won't hate me because of it. I feel like the world
January January
Sunday
22, 201722, 2017
Page 2041
1039 of 2301
1299
has been lifted from my shoulders but I know it will be hard for me to face you
now. I am so sorry.
Sincerely, Tabitha F. Buck
(Commonwealth's Exhibit 65 (emphasis in original); N.T., PCRA 6678-82.)
The court is faced with an unusual and interesting credibility assessment with this
witness. She has acknowledged that she was less than completely truthful under
oath. It appears that on several points she told the truth but not the whole truth.
On other points, she made statements contrary to the truth. Yet, almost
immediately, she confessed these lies to her lawyer. (76) Ms. Buck was never called
as a witness in the federal proceeding, so it is likely that she may never have been
"caught" in her lies. Her lack of truthfulness did not help or hurt her own situation,
given that she is serving a life sentence for murder. To this end, it is unlikely that
fear of perjury charges would have motivated her to confess her lack of honesty to
her attorney. She is serving a life sentence without the possibility of parole, which
in Pennsylvania means exactly that. Possible perjury penalties would have little, if
any, real impact on her life.
Further, her decision not to tell the whole truth did not hurt Ms. Lambert. In fact,
Ms. Buck soft-pedaled certain facts regarding Ms. Lambert's involvement. Had
these "lies" been for a malicious purpose, i.e., to prejudice Ms. Lambert's petition in
federal court, they might carry greater weight. It appears that the "lies" were an
effort, however ignoble, to help her former co-defendant. She explained this as a
feeling of sympathy not so much for a former co-defendant but for a fellow "lifer."
Petitioner's counsel did a good and thorough job of exposing these various lies in
cross-examination of Ms. Buck. Petitioner would have us completely disregard Ms.
Buck's testimony on that basis. This is not the law, however. We frequently include
in our instructions to a jury in a criminal case the maxim "falsus in uno, falsus in
omnibus" which means "false in one, false in all." Essentially, this means that if a
witness deliberately testified falsely about a material point, the fact finder may
choose to disbelieve the rest of his or her testimony. But the fact finder is not
required to do so. The fact finder should consider all other factors bearing on the
witness's credibility in deciding whether to believe other parts of his or her
testimony. Commonwealth v. Parente, 184 Pa. Super. 125, 130-32, 133 A.2d
561, 563-64 (1957), aff'd, 392 Pa. 38, 139 A.2d 924 (1958). See Commonwealth
v. Tyler, 305 Pa. Super. 15, 23, 451 A.2d 218, 222 (1982); Commonwealth v.
Joyce, 202 Pa. Super. 350, 353 n.1, 197 A.2d 226, 228 n.1 (1963).
In evaluating credibility, the court looks to how the witness testifies, what the
witness says, what interest the witness has in the outcome of the proceeding and
the relationship of the witness to the petitioner/defendant or others involved in the
case. The court considers whether, in general, the witness's testimony makes
sense. We look not only at the witness herself, and her background and history in
the case, but also to extrinsic factors which impact on credibility. For example, it is
proper for the court to consider whether other evidence in the case supports the
testimony of the witness. If other evidence, including the testimony of other
witnesses and items of physical evidence, shows that the witness's testimony is
less than accurate, then these other items of evidence would have a negative
January January
Sunday
22, 201722, 2017
Page 2042
1040 of 2301
1299
impact on credibility.
One very important factor is whether the witness is willing to falsify testimony so as
to further her own interests. This does not seem to be the case with Tabitha Buck.
At the PCRA hearing, we had the benefit of an exchange of letters between
petitioner's counsel and Ms. Buck regarding petitioner's intentions in the federal
habeas proceeding. Ms. Buck received a "solicitation" of sorts from petitioner's
counsel, Ms. Rainville. Ms. Rainville was writing to Ms. Buck with a request for
cooperation and a suggestion that she may wish to follow Ms. Lambert's path
through federal court with a federal habeas petition of her own. Ms. Buck replied,
also in writing, with certain statements that provide insight to her credibility and
which confirm certain statements she made in her testimony at the PCRA hearing.
For completeness sake, we include the text of each letter as it was read into the
record at the hearing. The letter from Ms. Rainville to Ms. Buck is dated November
15, 1996, and was admitted as Commonwealth's Exhibit 64. The letter reads:
Dear Ms. Buck,
My law firm has been appointed by the federal court in Philadelphia to represent
Lisa Lambert in the preparation of her federal habeas petition. I am writing to you
because I believe that we have discovered new evidence that may help you as well
as Lisa. We believe that the new evidence may prove that Butch Yunkin was
present, and participated in the murder. Since Mr. Yunkin was a key prosecution
witness against both you and Lisa, this new evidence may meet the standard set
forth in a relatively new Supreme Court case, Kyles v. Whitley, 115 S. Ct. 1555
(1995), which held that a retrial was warranted due to the prosecution's failure to
disclose evidence favorable to the defense regarding a key informant and
prosecution witness. Simply stated, while you will need your own lawyer to give
you guidance, our new evidence might be enough to get you a new trial.
You and Lisa are no longer friends, and I understand that there is a great deal of
bitterness between the two of you. Indeed, the two of you have many legal
interests that are in conflic t. However, we have information which may help you get
a new trial, and you have information which might help prove that Yunkin was
there. 1991 was a long time ago, and you and Lisa are now in a unique situation of
being able to help each other by telling the truth about Yunkin's real role in the
killing.
If you are currently represented by a lawyer, you should forward my letter to your
lawyer, and have your lawyer call me. If you are not represented by a lawyer, you
may call me collect at 215-751-2374. I hope that I will be hearing from you or your
lawyer soon.
Sincerely, Christina Rainville
(Commonwealth's Exhibit 64; N.T., PCRA at 6668-69.)
Ms. Buck's response is undated, but was written in response to Ms. Rainville's
letter. It was admitted into the record at the PCRA hearing as Commonwealth's
Exhibit 63. It reads as follows:
January January
Sunday
22, 201722, 2017
Page 2043
1041 of 2301
1299
Dear Ms. Rainville:

In response to your letter dated November 15, 1996, I must say that whatever
'new evidence' you claim to have discovered is, in fact, untrue. I realize that your
law firm was appointed to Miss Lambert's case and you will do whatever you can in
defense of her. You would even place Mr. Yunkin at the scene of the crime and try
to pin the blame, so to speak, on him in an effort to help Michelle (Lisa). The truth
is, however, Mr. Yunkin was not there and he did not participate in the crime.
Michelle knows that fact as well as I do. I will not fabricate lies and corroborate
with Michelle just to get myself off easy. You see, contrary to popular belief, I do
not take other people's lives into my own hands. I don't know if Mr. Yunkin knew
what Michelle was planning to do but I do know he was not there and he did not kill
Laurie. I will not lie and cause him to have a life sentence for something he didn't
even do. I know exactly what being in that situation feels like. I have no
information that would help Michelle nor do I have any that would hurt Lawrence.
Ms. Rainville, if I'm to be granted a re-trial, it will not be based on circumstantial
evidence which I know to be untrue. I resent the assumption that I would
jeopardize someone else's life just to make my own a little easier. That is a
character flaw of your client, Ms. Lambert, and I am nothing like her. There is only
one truth. I know it. Michelle knows it. God knows it.
I will be of no assistance to you and Lisa Michelle Lambert.
Cordially, Tabitha F. Buck
(Commonwealth's Exhibit 63 (emphasis in original); N.T., PCRA at 6670-72.)
While we believe that Ms. Buck's decision to withhold portions of the truth in her
deposition testimony and in her discussions with Detective Geesey was
unfortunate, we do not think that this choice establishes that she is a wholly
untruthful person who is not worthy of belief in any way in this proceeding. In fact,
she relates aspects of the story which are consistent with other testimony in
evidence and which are consistent in general terms with her letter to Ms. Rainville
written prior to the deposition. There cannot be a justification for lying under oath
but there certainly can be explanations which bear on the overall credibility of the
person shown to be untruthful on certain points.
From Ms. Buck's testimony, we can conclude with certainty that Ms. Lambert is
anything but innocent of the charge of murder. Ms. Buck's testimony is consistent
with the observations made by Mr. Kleinhans, Mr. and Mrs. Fry, and with the
history of hatred and animus demonstrated by Ms. Lambert during the summer and
fall of 1991. The evidence as to Ms. Lambert's planning of the assault, Ms.
Lambert's and Ms. Buck's approach to the condominium, their escape, and their
activities the remainder of the day of December 20, 1991, is consistent with much
of the evidence both at trial and the PCRA.
In assessing Ms. Buck's credibility in the PCRA hearing, we carefully considered her
testimony in light of its inconsistency with her deposition. We have carefully
considered the fact that she was untruthful at points in her deposition and in her
discussions with Detective Geesey. We observed her as she testified and we noted
January January
Sunday
22, 201722, 2017
Page 2044
1042 of 2301
1299
the substance of her responses and the manner in which she considered and
responded to questions. Unlike Ms. Lambert, Ms. Buck does not have an answer for
everything. She has acknowledged that there are certain facts which she cannot
reconcile, and she is candid about that which she does not remember. She was
forthcoming about her untruthful answers in her deposition and in her discussion
with Detective Geesey.
We firmly believe that Ms. Buck found herself in the middle of a vengeful
conspiracy. We do not doubt for a minute that she was aware that Ms. Lambert
intended to do harm to Laurie Show and that she went along for reasons that only
she knows. She is not an innocent. But to her credit, she acknowledges that fact.
Ms. Buck has nothing to gain by lying about Ms. Lambert's involvement in the
death of Laurie Show. In her testimony at the PCRA, she had the candor and the
decency to accept responsibility for her own role in the killing. She knows that she
blocked Laurie Show's path as Laurie tried to escape. She knows that she held
Laurie's legs down while Ms. Lambert cut her throat. In our close observation of Ms.
Buck as she testified and in our subsequent consideration of her testimony, we find
her to be credible in her description of the murder. She has acknowledged that she
deserves her sentence because of her actions on December 20, 1991. She has
acknowledged her guilt under oath in a courtroom in the same courthouse in which
her own PCRA petition is pending. What possible impact will this admission have on
her own PCRA claim that her trial resulted in a "fundamentally unfair" conviction?
Ms. Buck knows full well that, when she took the stand to acknowledge, under oath
in a courtroom, that she actively participated in the killing of Laurie Show, she
severely compromised any chance she has that a state or federal court will be
inclined to find that she has been wrongly convicted. Her testimony will not take a
day off her life sentence and will not change the events of December 20, 1991. We
find her credible in her description of what happened that morning.
In his statement to the police and in his testimony at trial, Lawrence Yunkin denied
involvement in the murder of Laurie Show. Ms. Lambert denied Mr. Yunkin's
involvement in her statement to Corporal Solt. In four months' of letters from
prison, she denied his involvement. At trial, Ms. Lambert implicated Mr. Yunkin in
the murder of Laurie Show. Much of petitioner's case in the PCRA hearing involves
evidence pointing to Mr. Yunkin's involvement, evidence as to his credibility,
evidence as to why Ms. Lambert might have "covered" for Mr. Yunkin, and an
attempt to discredit those facts which show that Mr. Yunkin was not involved.
In separate sections of this opinion we consider some of those issues. The "29
questions" go directly to Mr. Yunkin's involvement and this is discussed in Section
VII.B., supra. Kathleen Bayan's testimony would implicate Mr. Yunkin and is
discussed in Section VII.F, infra. Similarly, Hazel Show's testimony concerns Mr.
Yunkin's involvement and is considered in Section VII.G, infra. The issue of the
pearl earring contains allegations of after-discovered evidence and prosecutorial
misconduct and is considered in a separate section of this opinion, Section VII. N,
infra.
In this section, we address the remaining allegations pointing to Mr. Yunkin's
January January
Sunday
22, 201722, 2017
Page 2045
1043 of 2301
1299
involvement. The first of these is the license plate found in the search of Mr.
Yunkin's car after his arrest. The license plate bears the number YHM-028. Two
characters of this license plate were identified by Kathleen Bayan to Detective
Savage in his interview of her in July 1992. Petitioner points to this evidence as
conclusive proof that Mr. Yunkin drove in the condominium complex that morning
with the YHM-028 license plate and later changed the license plate to evade the
authorities.
There is a problem with this line of reasoning. The police investigation at the time
the license plate was found in the Yunkin car revealed that YHM-028 was a plate
registered to Lawrence Yunkin. It was apparently a license plate which was on a
van previously owned by Mr. Yunkin. In any event, the police concluded at that
time that the license plate was of no evidentiary value. This court finds it unlikely
that Lawrence Yunkin would have "disguised" his vehicle by using another license
plate which was registered to him. We do not believe that the license plate found in
the Yunkin vehicle implicates Mr. Yunkin in the murder.
A second issue concerns 158 seconds of the audiotape of Mr. Yunkin's statement.
At the beginning of one side of the tape of a cassette used to record Mr. Yunkin's
statement is 158 seconds of narrative in a female voice. The narrative has nothing
to do with this case and appears to be an academic lecture of some kind. Did the
police mask an incriminating portion of Mr. Yunkin's statement by taking the
cassette to an academic lecture? That seems unlikely. More likely is that the
cassette used to record Mr. Yunkin's statement had been used by someone on a
prior occasion to record a speech. It seems likely that the police simply did not
rewind the tape completely. This lack of attention to detail on the part of Detective
Savage in preparing the tape recorder to record Mr. Yunkin's statement does not
prove anything.
The third issue is related to the tape recording of Mr. Yunkin's statement. Listening
to the tape, one can hear several "clicks," indicating that the tape was stopped, or
paused, and started again. District Justice Savage recalls that the taping was
interrupted so that Mr. Yunkin could confer with his attorney, Douglas Cody,
Esquire. This is confirmed by Mr. Cody. (N.T., PCRA at 6465.) There is a break near
the end, after Mr. Yunkin had been given an opportunity to review his typed
statement. At that point, he included several corrections. Petitioner contends that
the "breaks" or "clicks" indicate occasions when Mr. Yunkin was coached by the
police to state certain facts which would incriminate Ms. Lambert or to remove
certain statements exculpatory to Ms. Lambert.
This court found Mr. Cody's testimony on this subject to be credible and convincing.
Mr. Cody testified that the police did nothing improper in taking the statement and
that the recorder was not turned off for any improper reason. (N.T., PCRA at 6466.)
When asked whether the police officers did anything to coach his client, Mr. Cody
responded: "Absolutely not." (Id.) When asked if the police did anything to suggest
how Mr. Yunkin should answer or should not answer, Mr. Cody replied: "Not on one
question." (Id.) Mr. Cody also confirmed that he did not observe the police erase
anything on the tape. (N.T., PCRA at 6467.) Finally, Mr. Cody confirmed that the
transcript of the statement accurately reflected the statement given by Mr. Yunkin.
(Id.)
Based on the record from the PCRA hearing, we find beyond any doubt that there
January January
Sunday
22, 201722, 2017
Page 2046
1044 of 2301
1299
was no misconduct in the taking or recording of Mr. Yunkin's statement.

A fourth issue regarding Mr. Yunkin's involvement concerns the alleged date rape of
Laurie Show. We should note that the only "proof" of the date rape came from
police reports of discussions with Hazel Show regarding her daughter's brief
relationship with Mr. Yunkin. Mr. Yunkin never acknowledged a "date rape," no
police report was filed and no investigation conducted. In fact, it appears that Ms.
Lambert is convinced that there was never any "date rape." A review of her many
letters to Mr. Yunkin from prison in which she characterized Laurie Show as a
"tramp," "slut," and "whore" would suggest that Ms. Lambert believed the brief
relationship between Mr. Yunkin and Laurie Show, if any, was consensual and not
the product of any force by Mr. Yunkin. The only possible relevance of this "date
rape" charge was Mr. Yunkin's purported fear that the incident would be
investigated by the police and that he would go to jail for rape. There appears to be
nothing more than speculation and surmise in support of this argument.
At best, it would support some animus by Mr. Yunkin or some motivation by Mr.
Yunkin to murder Laurie Show. We already know that Mr. Yunkin drove Ms.
Lambert and Ms. Buck to the condominium that morning, that he was aware they
had certain items with them which could be used in an assault on Laurie Show and
that he picked them up after this was over. We believe Mr. Yunkin was aware of
their plans. There is no doubt that Mr. Yunkin was involved in this conspiracy.
Could his fear of a date rape charge have motivated his participation in this
murderous conspiracy? Certainly. Does it establish that he was in the condominium
that morning committing the murder? It certainly does not.
The prosecution's failure to disclose the information supplied by Ms. Bayan in no
way violated the due process rights afforded by Brady and Pa. R. Crim. P. 305.
Kathleen Bayan contends that she spoke to Detective Savage in early July 1992. As
a result of that conversation, Ms. Bayan prepared a handwritten statement for
Detective Savage detailing the events of the morning of the murder. (Petitioner's
Exhibit 2008 at DA3037- DA3042.) According to her statement, she was pulling out
of her driveway in the Oak Condominium complex when she saw a late model
brown car speeding by. The driver was male and appeared to have light hair. The
front and back passengers were of an indeterminate sex and had dark clothing on.
Ms. Bayan stated that she could not see their faces clearly because of the distance
between the cars, because of the dirty car windows and because of a perceptual
disability that limits her span of focus. She did, however, note that the occupants of
the car were between the ages of 16 and 22.
Ms. Bayan told this to Detective Savage when he came to her condominium in July
1992 to inquire about the whereabouts of her son, Elliott, on the morning of the
murder. (N.T., PCRA at 4759-60, 4761.) Apparently, witnesses had observed a
number of young people at or around the school bus stop near the condominium
entrance and Elliott was one of those students who occasionally waited for the bus.
Kathleen Bayan related this story to Detective Savage after approximately one-half
hour of a discussion regarding herself, her son and her son's educational and
medical problems.
January January
Sunday
22, 201722, 2017
Page 2047
1045 of 2301
1299
At the PCRA hearing, Ms. Bayan related t, hat on the morning of the murder, she
left her home between 7:10 and 7:15 a.m. for an appointment in Harrisburg. (N.T.,
PCRA at 4752.) As she started to pull out of her driveway, she saw a brown car
driving in an erratic manner on Black Oak Drive. She recalls seeing a man with long
curly blond hair wearing a baseball cap driving with a front female passenger and a
back female passenger. (N.T., PCRA at 4757.) He was driving very fast and was
swerving. (N.T., PCRA at 4758.) It appeared to her there was an argument going
on inside the car and that the driver was attempting to push down the heads of the
passengers. (N.T., PCRA at 4757-58.) Ms. Bayan clearly recalled seeing the face of
the girl in the backseat and identified her as Tabitha Buck. (N.T., PCRA at 4757,
4796-97.) She saw all this in a matter of seconds as they drove past her going 30
to 35 m.p.h. (N.T., PCRA at 4803.) She then followed them out of the condominium
complex, following several car lengths behind. (N.T., PCRA at 4802.)
1. Credibility
Kathleen Bayan observed a great deal of detail from her vantage point in her own
car while the car in question flashed past her. She indicated that there was an
argument going on and recalls the color of the car, the color of the driver's hair and
a description of the passengers. She offered no explanation for not coming forward
with that information between December 1991 and July 1992. This fact in and of
itself would not be fatal to her credibility but it does raise a question. She had
ample opportunity to read newspapers, become acquainted with the facts of the
case and come to know the details of the description of the participants long before
July 1992.
In addition, she did not immediately tell Detective Savage of her observations. Only
after she had a lengthy discussion of other personal issues, did she offer her
observation of what she had seen.
It is appropriate for the PCRA court to consider the credibility of a witness to
determine if the after-discovered witness's testimony is reliable. Bonaccurso, 425
Pa. Super. at 490, 625 A.2d at 1202 (Beck, J., concurring). Ms. Bayan's credibility
was somewhat diminished in her testimony in the PCRA proceeding by her
responses to questions on cross-examination. She acknowledged that she has a
visual handicap. This handicap affects her ability to perceive objects other than that
specific object on which she focuses. That is, as Ms. Bayan explained, if she looks
at one object, she cannot see the details of anything else surrounding that finite
discreet item. This suggests that perhaps if Ms. Bayan was looking at the long curly
hair of the driver of the brown car, perhaps she was unable to see the occupants.
Or, if she was observing the make and color of the car, perhaps she was unable,
due to her handicap, to see the occupants.
Ms. Bayan testified in this proceeding by way of teleconference from Pensacola,
Florida. She had represented to the court and counsel in a telephone conference at
the beginning of the proceeding that she was unable to travel to Pennsylvania
because she is the sole support and transportation for a handicapped fianc.
Because of this sympathetic concern, the court made arrangements for Ms. Bayan
to testify by way of video conference. She testified from a public broadcasting
studio in Pensacola and her testimony was observed and questions posed to her
from the WGAL television studio in Lancaster, Pennsylvania. These arrangements
were made because the credibility of Ms. Bayan is a crucial part of this hearing and
January January
Sunday
22, 201722, 2017
Page 2048
1046 of 2301
1299
because credibility can best be assessed by a face-to-face observation of a witness

as the witness is telling her story and responding to questions.
There are two important credibility points regarding Ms. Bayan's testimony. First,
by the court's observation of her as she testified, she appeared less than
completely credible as she answered the questions. The court is not surprised that
Detective Savage, upon his interview with her in July 1992, found there to be
problems with her credibility.
The second and more important issue as to Ms. Bayan's credibility has to do with
the contention that she was unable to travel to Pennsylvania. As we learned later in
the hearing, Ms. Bayan has an active warrant for her arrest in the offices of District
Justice Savage, formerly Detective Savage.(77) This warrant arises out of her failure
to pay certain county tax obligations while she was a resident of Lancaster County.
(N.T., PCRA at 6327-28.) We also note that she was the defendant in a lawsuit by
her condominium association and the judgment was satisfied by a sheriff's
execution sale of her furniture, presumably left behind at the condominium. (N.T.,
PCRA at 6329-30.) Ms. Bayan was sued twice before, by the taxing authority,
permitted the obligations to go to judgment, and satisfied the prior two obligations
upon the issuance of warrants. (N.T., PCRA at 6325-26, 6329-30.)
It is reasonable to infer that she was aware that a warrant had issued or would
issue for her given her past history with the local taxing authority. One is left to
wonder whether Ms. Bayan's reluctance to come to the jurisdiction was truly the
result of her life situation or rather whether the existence of an active warrant in
Lancaster County played some role. Even giving Ms. Bayan the benefit of the
doubt, this fact does impugn her credibility.
In Pennsylvania, it is mandatory for the Commonwealth to disclose evidence which
is favorable to the accused and which is material to either guilt or punishment. Pa.
R. Crim. P., Rule 305 (B)(1), 42 Pa. C.S.A. The comment to Rule 305 indicates that
the rule is intended to apply the constitutional guarantees which Brady commands.
Absent a specific request by the defendant for exculpatory evidence, a prosecutor
has a duty to make evidence available to the defense that is truly exculpatory
rather than merely favorable.(78)
The Supreme Court of Pennsylvania has defined Brady violations as: (1) the failure
to disclose , an agreement between the C, ommonwealt, h and a witness,
Commonwealth v. Moose, 529 Pa. 218, 602 A.2d 1265 (1992); (2) the failure to
disclose out-of-court statements by an accomplice claiming responsibility for the
murder, Commonwealth v. Green, 536 Pa. 599, 640 A.2d 1242 (1994); and (3)
the pretrial failure of the Commonwealth to disclose evidence proving bias of a
defense witness, Commonwealth v. Ulen, 539 Pa. 51, 650 A.2d 416 (1994).
In contrast, the Pennsylvania Supreme Court has held that where the prosecution
did not reveal statements by its witness that he saw someone other than the
defendant in possession of the murder weapon several weeks after the murders,
such evidence was not exculpatory and, thus, lacked materiality. Buehl, 540 Pa. at
January January
Sunday
22, 201722, 2017
Page 2049
1047 of 2301
1299
504, 658 A.2d at 776. Likewise, a prosecution's failure to disclose an alleged

agreement with one guilt-phase witness was not a Brady violation entitling the
defendant to a new trial. Commonwealth v. Morales, 549 Pa. 400, 701 A.2d 516
(1997).
A central issue in this case is whether Kathleen Bayan's disclosure to Detective
Savage in July 1992 should have been disclosed to Attorney Shirk. Mr. Kenneff was
aware of the Bayan disclosure and was aware that Detective Savage had obtained
this information from her just prior to the start of the trial. At that time, Ms.
Lambert had related her story to Corporal Solt. Her story, as set forth in the "Solt
Statement," was that she and Ms. Buck left the Show condominium, proceeded
across the condominium complex, across a lawn, down a gully, through some
bushes and across a field to Oak View Road. (See Section VII.L, infra.) There, on
Oak View Road, they were picked up by Lawrence Yunkin. As of early July 1992,
the only "story" the Commonwealth knew from Ms. Lambert was that she fled on
foot from the Show condominium to Oak View Road. She was not contending that
Mr. Yunkin was in the complex, that the two young women entered the car in the
condominium complex, or that they entered the condominium complex and drove
around for any purpose.
The district attorney's discovery obligation under Rule 305 and under Brady was to
disclose information to the defense which would be material and exculpatory. As of
the start of trial, the disclosure by Kathleen Bayan was neither material nor
exculpatory to defendant. In fact, all Ms. Bayan's disclosure accomplished was to
place Mr. Yunkin in the condominium complex. This may have been inculpatory for
Mr. Yunkin, but not exculpatory for Ms. Lambert.
Mr. Kenneff evaluated his discovery obligation and chose to communicate with Mr.
Shirk regarding Ms. Lambert's position. He did so in a letter asking simply whether
Ms. Lambert still asserted that Mr. Yunkin picked her up on Oak View Road.
(Petitioner's Exhibit 1764.) Mr. Shirk responded to Mr. Kenneff that this was her
contention.
Under these facts and under Rule 305 and Brady, Mr. Kenneff had no obligation to
disclose the Bayan statement to Mr. Shirk. Examine for a moment what possible
basis there would be for the disclosure. Given Ms. Lambert's statement to Corporal
Solt, providing the Bayan disclosure to Ms. Lambert would give her a reason to
change or modify her story. Giving a criminal defendant an opportunity to revise
her story is not a basis for requiring disclosure in discovery.
Should the Commonwealth have anticipated that Ms. Lambert would dramatically
change her story during the course of the trial? Discovery under either Rule 305 or
Brady does not require that the prosecution employ a crystal ball. Now, in
hindsight, we know that Ms. Lambert changed her story at trial and placed Mr.
Yunkin in the condominium complex. This story was told after the Commonwealth
rested its case and during the defense case-in-chief.
The question then became whether Mr. Kenneff had an affirmative obligation to
provide information about the Bayan statement to the defense once Ms. Lambert
told a new version of her story during trial. The Commonwealth's contention was
that Ms. Lambert was lying at trial. Her statement of December 21, 1991, was the
most credible version of the facts because she gave that statement before she
January January
Sunday
22, 201722, 2017
Page 2050
1048 of 2301
1299
understood the legal ramifications to her of placing herself in the condominium. She
had every reason to change her story at trial and the Commonwealth's argument
that the story at trial was a fabrication had considerable merit.
Mr. Kenneff did the responsible thing by confirming with Mr. Shirk what Ms.
Lambert's story was going to be. Mr. Shirk replied that Ms. Lambert contended that
she was picked up on Oak View Road. There is nothing unusual about one party
weighing its obligations under the rules and making choices under those rules as to
what must be disclosed. This is the essence of the adversarial process and Mr.
Kenneff did nothing more than evaluate his own obligations under the rules of
discovery. His choice, upon confirmation of the story by Mr. Shirk, to not disclose
the Bayan statement was proper.
When Ms. Lambert changed her story at trial, Mr. Kenneff's obligation was the
same: to disclose evidence that was exculpatory. Ms. Bayan's statement was not
exculpatory merely because Ms. Lambert calls it exculpatory. It is true that Ms.
Bayan's statement, if credible, would support some part of Ms. Lambert's trial
testimony. Ms. Bayan's statement would support only Ms. Lambert's description of
how she fled that morning. Yet, Ms. Lambert's own testimony put her in flight from
the condominium after participating in an assault which led to a murder. Her trial
testimony established that she was deeply involved in the conspiracy and the
murder. Ms. Bayan's statement might have been inculpatory to Mr. Yunkin but not
exculpatory to Ms. Lambert.
Exculpatory evidence is evidence which extrinsically tends to establish a
defendant's innocence. Hudgens, 400 Pa. Super. at 97-98, 582 A.2d at 1361. Ms.
Bayan's story does nothing to establish Ms. Lambert's innocence. Evidence that Ms.
Lambert was seen fleeing the scene of a murder in the company of two people
whom she identified at trial as the murderers would not "extrinsically tend to
establish" her innocence. The Kathleen Bayan story is, simply stated, not
exculpatory as to Ms. Lambert. At best, Ms. Bayan's story would tend to support
the version Ms. Lambert told at trial and would thereby "shade" her level of
culpability for the murder. Yet, by her own admission of going with Ms. Buck to the
condominium that morning, of planning an assault on Laurie Show and of
participating at some level in the assault which led to Laurie Show's death, she
would still be guilty of first degree murder. The information would, therefore, not
be "material" for Brady/Giglio purposes or for compliance with Pa. R. Crim. P. 305
in that the information would not have changed the outcome of the trial.
The ultimate question is whether the failure to disclose the Bayan statement so
undermined the truth-determining process that no reliable verdict was possible.
This court finds that even if Ms. Bayan had testified at trial, even if Ms. Lambert
had the support of Ms. Bayan for her revised story that Mr. Yunkin was in the
complex, the verdict would have been the same.
We did not find Kathleen Bayan credible at the PCRA hearing. We find that Ms.
Lambert's statement to Corporal Solt of how she fled, Ms. Buck's testimony about
how they fled together, Mr. Kleinhans's testimony about seeing two hooded figures
of about the same size heading away from the condominium, and the observations
January January
Sunday
22, 201722, 2017
Page 2051
1049 of 2301
1299
of Mr. and Mrs. Fry, to be convincing and credible on this point. Because it is
contrary to overwhelming credible evidence, her story would have had no impact.
Even if we were to find that the failure to disclose Ms. Bayan's statement was a
constitutional violation, it did not so undermine the truth-determining process that
no reliable adjudication of guilt or innocence could have taken place.
In fact, petitioner's contention that Ms. Bayan saw Ms. Lambert, Ms. Buck and Mr.
Yunkin in the complex that morning cannot be reconciled with petitioner's
contention that Mrs. Show saw them as well. Ms. Lambert would have this court
believe that Mrs. Show left the school at 7:25 a.m., per Ms. Berry. Testimony has
shown that the trip from the school to the complex takes approximately ten
minutes. If Mrs. Show saw the three that morning, it would have been around 7:35
a.m. Yet, Ms. Bayan testified that she saw them as she left for Harrisburg between
7:10 a.m. and 7:15 a.m. This internal inconsistency in petitioner's case lends
further support to our finding that Ms. Bayan's testimony would not have changed
the outcome of the trial. Nor does it have any impact on the reliability of the
verdict.

Mrs. Show testified at the PCRA hearing that she saw a car on the morning of
December 20, 1991, that she now believes may have been Mr. Yunkin's car. She
testified in response to questions by petitioner's counsel:
Q. Mrs. Show, on the morning of December 20th, 1991, when you drove back into
the condominium complex, what, if anything, did you see driving out of the
condominium complex?
A. Remembering in 1991, I did not remember anything. Until 1997 I had a memory
of seeing Yunkin in a car.
Q. Can you tell us what you remember today of seeing Yunkin in the car?
A. I remember coming in the entrance. I don't know approximately where. But it
had to be in a break between the trees and the shrubbery, looking over to my left,
and seeing Lawrence's face. At that time not even realizing who it was, that it was
just a man with blond hair. But he's looking at me with a startled, surprised look on
his face, seeing him push someone down in the front seat with blond hair and
seeing someone with dark hair in the back seat. But I don't recall seeing the car.
Q. Do you recall what color the car is?
A. It's just a brownish color.
(N.T., PCRA at 5635-36.)
Mrs. Show was then asked if she had ever discussed the possibility that she saw
this car with Detective Savage:
January January
Sunday
22, 201722, 2017
Page 2052
1050 of 2301
1299
Q. Okay. Back in 1991, 1992, did you have any discussions with anyone about it?
A. No.
Q. Did you discuss with Detective Savage at all the fact that you'd seen a brown
car?
A. What I told Detective Savage, he had told me a neighbor lady mentioned that
she had seen a brown car leaving our complex.
When he said that, I saw a flash of a brownish color and I said to him, a brownish
color? And then we went over this, had I seen a car? I wasn't sure. Where was it? I
wasn't sure. What type of car? Was anyone in it? And I had nothing in my memory
except when he said this brown color, I just saw a flash of a brown car. Not even
knowing that it was a car or anything and I tried to jog my memory to get more
information but there wasn't anything there.
And I started to become upset about this because it was important because this
neighbor lady was saying there were three people in the car. But nothing was
there. I couldn't remember anything and he told me that I was getting upset and
he told me not to worry about it, if something came back, we'd go from that point.
But nothing ever came back and I was to testify in a couple of days and I just
forget [sic] all about it.
Q. When did you have this discussion with Detective Savage?
A. It was probably a couple days before the trial.
Q. Before Ms. Lambert's trial?
A. Yes.
(N.T., PCRA at 5642-43.)(79)
Her chief recollection is that the car was coming toward her and there was nothing
impeding her view of the car. She recalls that she had to drive a distance after she
saw the car. It is possible that she saw the car out on Oak View Road. (N.T., PCRA
at 5648.) She thinks it was around 7:20 a.m. when she was coming back from the
school. (N.T., PCRA at 5649.)
Mrs. Show testified at the PCRA hearing that Detective Savage told her "not to
worry about it." Petitioner's counsel referred Mrs. Show to her federal testimony
and asked the following questions:
Q. Do you remember testifying in federal court that Detective Savage told you not
to dwell on it?
Q. Do you remember testifying to that?
A. I think I've said that here. That he said, you know, not to worry about it, not to
January January
Sunday
22, 201722, 2017
Page 2053
1051 of 2301
1299
get upset about it or dwell on it because as far as what I had to testify to, I was
saying what I remembered and something that I had no memory about there
wasn't much I could do about it. So don't get upset about it.
(N.T., PCRA at 5644-45.)
This revelation by Mrs. Show, long after the 1992 trial, presents several issues.
First, does this testimony establish that she saw the Yunkin car? Second, was
Detective Savage's instruction to her "not to worry about it" a form of misconduct?
Third, is the information about the car after-discovered evidence entitling Ms.
Lambert to relief?
First, Mrs. Show did not say at the PCRA hearing that she remembered a car in
1992. She recalled a brownish flash and was not sure it was a car. She did not
recall a car until she was sitting in a federal courtroom in 1997 listening to District
Justice Savage. At most, this testimony, had it been presented in 1992, would
buttress the testimony of Ms. Bayan that a brown car was seen leaving the
condominium complex. The problem is that Mrs. Show cannot conclusively put the
car inside the condominium complex. She cannot rule out the possibility that she
saw the car out on Oak View Road.
Second, as to the misconduct question, it appears from Mrs. Show's testimony that
she was not reasonably certain of any detail in 1992. From her own description, she
was becoming very upset because she thought she was failing to recall important
information which would help the police. It was in this context that Detective
Savage told her not to worry. At that time, the police had the testimony of the
Kleinhanses and the Frys who put Ms. Lambert and Ms. Buck fleeing together
across the fields toward Oak View Road. Ms. Lambert and Mr. Yunkin had both told
the police in their statements that the pick up was on Oak View Road. The only
information to disclose is that Mrs. Show had an "image" of a brownish flash as she
approached or entered the complex that morning. It does not seem that there was
really anything to disclose. Detective Savage's comment "not to worry about it" in
the circumstances does not appear to be a directive to "bury" exculpatory evidence.
Third, is this after-discovered evidence? It certainly was unavailable at the trial, so
the first prong is met. We turn then to the question of whether the information is
"exculpatory." At best, it corroborates the story told by Ms. Lambert at trial and
undermines the story told by Ms. Lambert to Corporal Solt. It would tend to show
that Ms. Lambert was being untruthful with the police when she gave her
statement. Given the paucity of detail in the story, it is entirely likely that the
recollection would have been given little weight. It was certainly not exculpatory in
the sense that it established that Ms. Lambert was fleeing the scene of a murder.
Given the fact that she planned the activities of that morning, given the fact that
she participated in the assault on Laurie Show that morning and given the fact that,
at trial, she was placing responsibility for the murder on Mr. Yunkin and Ms. Buck,
the fact that she was seen in a car in their company fleeing the complex does not
sound too exculpatory. The only significance of this "recollection" of Mr. Yunkin's
car would be to place Mr. Yunkin at the scene. But evidence inculpatory to Mr.
Yunkin is not exculpatory to Ms. Lambert. If Mr. Yunkin and Ms. Lambert are fleeing
the scene of a murder arising out of an assault which Ms. Lambert "started" and
January January
Sunday
22, 201722, 2017
Page 2054
1052 of 2301
1299
Mr. Yunkin "finished," the fact that she is seen in his car is hardly exculpatory.
It is unlikely that this information would have changed the outcome of the trial.
Even if entirely believed and even if it was found to support Ms. Lambert's story
that Mr. Yunkin was inside the condominium complex and that she was in the car
with him, this does not exculpate Ms. Lambert. It might lend more support to an
argument that Mr. Yunkin was somehow involved, which does not exclude Ms.
Lambert's involvement. Under the best story put forth by Ms. Lambert, she was in
the condominium and participated in the acts which led to the death of Laurie
Show. She claims she left and Mr. Yunkin went in. We never believed that story.
The fact that Mrs. Show remembered something that may buttress one fact of a
story we found to be incredible does not suggest that the story became any more
credible. It would not have made a difference in the outcome of the trial.

Shortly before trial, Mr. Shirk informed Mr. Kenneff that Dr. Mihalakis, a forensic
pathologist, would be testifying for the defense. In April 1992, Dr. Mihalakis had
entered into a contract with the County of Lancaster to perform forensic pathology
services in criminal cases. Over the weekend before trial, Mr. Kenneff placed a
telephone call to Dr. Mihalakis to express his concern about the doctor's choice to
testify for the defense.
The issues regarding the involvement of Dr. Mihalakis were raised at trial and in
post verdict motions, and considered by this court in its opinion of July 19, 1994.
Nevertheless, petitioner has included this issue in her case. The Commonwealth
argues that this issue has been previously litigated and, therefore, waived. Because
petitioner raised a claim of after-discovered evidence and "witness tampering" with
respect to Dr. Mihalakis, we will address the issue in this opinion. We note further
that the federal district court featured this issue in its discussion of the federal
habeas petition.(80)
The issues raised in the PCRA petition are:
(1) Dr. Mihalakis's income from Lancaster County increased 400 percent the year
after the Lambert trial (1993) and then dropped to nothing, (Exhibit A, Section A at
para. 17);
(2) Mr. Kenneff discussed with Dr. Mihalakis his proposed testimony and crossexamination questions and that Dr. Mihalakis did not want Mr. Kenneff to be upset
with him and offered to withdraw, thus Dr. Mihalakis changed his testimony to help
the prosecution, (Exhibit A, Section A at para. 18); and
(3) Mr. Kenneff's unauthorized, pretrial ex parte contact with a defense expert, Dr.
Mihalakis, (Exhibit A, Section B(4) at para. 30).
In 1994, in response to Ms. Lambert's long delayed post verdict motions and briefs,
we considered this issue in an opinion. At that time, we stated:
During the trial, a lengthy conference was held in chambers regarding the possible
January January
Sunday
22, 201722, 2017
Page 2055
1053 of 2301
1299
testimony of Dr. Isidore Mihalakis. Dr. Mihalakis is a forensic pathologist who was
called by the defense to testify as to the wounds inflic ted on the neck of the victim.
This expert was going to explain the difficulty, or impossibility, of a person
speaking with these wounds. The point of this testimony was to rebut the
Commonwealth's evidence that the victim identified her killer just before she died.
Prior to the testimony of Dr. Mihalakis, counsel for the defense submitted a motion
for sanctions to the court on the basis that the assistant district attorney had
contacted Dr. Mihalakis in advance of his testimony. Defendant argued that the
assistant district attorney attempted to intimidate or coerce Dr. Mihalakis.
The court held a hearing on this motion in chambers with the assistant district
attorney, the district attorney, defense counsel, defendant's private investigator
and Dr. Mihalakis all present. . . .
Essentially, Dr. Mihalakis was under a consulting contract with the Lancaster
County District Attorney's Office. The assistant district attorney, Mr. Kenneff,
indicated his surprise and concern when it was learned that Dr. Mihalakis would
appear as a defense witness. Mr. Kenneff was concerned as to his ability to crossexamine a witness whom he has retained for testimony in other cases. He placed a
call to Dr. Mihalakis and raised this concern and also discussed with him, in general
terms, his anticipated trial testimony.
The court specifically addressed Dr. Mihalakis at the hearing in chambers. The court
questioned Dr. Mihalakis on whether he felt intimidated, coerced or in any way
threatened by Mr. Kenneff's call. Dr. Mihalakis emphatically stated he did not. In
fact, Dr. Mihalakis had issued a report and indicated, in chambers, that it was his
intention to testify consistent with that report.
Nothing about the testimony of Dr. Mihalakis in the hearing in chambers nor
anything about Dr. Mihalakis's testimony during the trial indicates that there were
any threats, intimidation or coercion. The court found defendant's motion for
sanctions to be without any basis in law or in fact and properly denied the motion.
At trial in 1992, Dr. Mihalakis testified as to the cause of death. He agreed with Dr.
Penades that, essentially, Laurie Show bled to death. He stated that asphyxiation
due to breathing in blood was a contributing factor. His first opinion was as to
cause of death and the length of time it would have taken the victim to die. He
testified:
A. To bleed to death, it would take multiple minutes. There are a lot of variables;
however, I think it would definitely be considerably less than a half hour.
Q. Somewhere between multiple minutes and considerably less than a half hour?
A. Right.
(N.T., Trial at 341.) He was asked how long it would take for Laurie Show to lose
consciousness. He stated: "Unconsciousness would have to be minutes. It would
January January
Sunday
22, 201722, 2017
Page 2056
1054 of 2301
1299
not have to be a huge number of minutes but it wouldn't be that terribly quickly
also." (N.T., Trial at 342.)
Dr. Mihalakis was then asked by defense counsel about Laurie Show's ability to
speak. He noted damage to the tongue muscle and to the structures in the neck.
He gave the following testimony:
Q. What would be the effect of that loss of dexterity to the central portions of the
tongue?
A. The loss of the dexterity would be those words that have a tongue related
sound; may be somewhat slurred and less intelligible.
Q. And a tongue related sound as you described it would be, for the record and for
the Court, what kind of a sound might that be?
A. A sa, da, ja, ka, yul.
(N.T., Trial at 344.) Dr. Mihalakis further testified:
Q. There may be testimony presented at a later date in this trial that the decedent
might've possibly said, Michelle did it. Are the sounds in that phrase, would they be
affected by the damage to the muscles in the center of the tongue, affecting the
tongue and speech, would that have affected the ability to speak that phrase?
A. It would have to be affected in part. Ma is predominately a lip sound, and the

tongue and lips are controlled by a different set of nerves so the ma sound should
not've been affected. If it was affected it was to a minor degree.
The chael may have been somewhat less clear and the da may have been
somewhat less clear.
(N.T., Trial at 344-45.)
On cross-examination at trial, Dr. Mihalakis affirmed this testimony:
Q. Moving on to the issue to the injuries to the neck and the effect on the ability to
speak. As I understand your testimony, you feel that the ability of Laurie Show to
speak as a result of the injuries that she suffered would be compromised but not
eliminated.
A. That is correct.
There was absolutely nothing about this testimony which was in any way
inconsistent with Dr. Mihalakis's report to defense counsel of June 29, 1992. This
report was prepared before Mr. Shirk informed Mr. Kenneff that Dr. Mihalakis would
be testifying and before Mr. Kenneff had any contact with Dr. Mihalakis. In the
January January
Sunday
22, 201722, 2017
Page 2057
1055 of 2301
1299
report of June 29, 1992, Dr. Mihalakis addresses a question put to him by defense
counsel's investigator:
Question 3: Could Laurie Show say anything afterward; could she have said,
'Michelle did it'?
Answer: The wound track of the neck wounds described by Dr. Penades involves
cutting of a major portion of the base of the tongue except for possibly the pillars
on each side. Such a cut would certainly limit but not totally eliminate phonation
especially words and letters that involve the tongue. M is a letter that is primarily
phonated by the lips. If the head is down and air can pass from the windpipe to the
mouth M could certainly be enunciated. 'Chelle' are somewhat more difficult to
enunciate and 'did' it very much tongue dependent so that would be very difficult to
enunciate but not totally impossible depending on how much tongue muscle was
left. We are told by Dr. Penades that literally one could look at her throat and see
the vertebral column. However, we are not told about the sides of the tongue.
The other factors that must be taken into consideration are the recurrent laryngeal
nerves. If one such nerve is cut, it causes a hoarse voice, and if both are cut, the
cords assume a midline neutral position, and at best, the only sound that can be
made is a 'breathy' type sound but hardly any intelligible speech. Neither Dr.
Penades nor his consulting otolaryngologist, Dr. Joseph S. Annese, address the
status of the recurrent laryngeal nerves. In spite of this shortcoming I believe that
these nerves were not cut because they are tucked in such a location that to
selectively injure them without cutting the carotids and deep jugular vessels is
essentially impossible. Thus, for all intents and purposes, you have to consider
phonation based on the injury to the tongue.
At the colloquy in chambers on July 10, 1992, Dr. Mihalakis acknowledged that he
had been contacted by Mr. Kenneff. He testified that he did not feel intimidated or
coerced by Mr. Kenneff. He stated clearly, unequivocally, and emphatically that he
would testify at trial consistent with his June 29, 1992, report. Dr. Mihalakis is a
medical professional of considerable stature in his field and in his community. When
he said that he would testify to the opinions expressed in his letter, he was
completely credible. And, in fact, his testimony at trial bore out this representation.
During the colloquy in chambers on Friday, July 10, 1992, Mr. Kenneff asked Mr.
Shirk to "address what chilling effect the phone call has had on his ability to
present his defense." Mr. Shirk's response demonstrates that, upon talking further
with Dr. Mihalakis, he did not believe the phone call would make any difference in
Dr. Mihalakis's testimony:
I asked Doctor Mihalakis, I indicated to him I never met him. I never met him, I
don't know him, and I asked him quite frankly if this would affect his testimony in
any way, shape or form. I think the exact word I used was whether he would pull
his punches. He indicated to me he would not.
I indicated, you know, it was very important because, you know, I don't want to
find out on the stand Friday and he indicated that in no way, in any way would it
January January
Sunday
22, 201722, 2017
Page 2058
1056 of 2301
1299
affect his testimony Friday. I can honestly say to you at this point there is no way it
has a chilling effect. He hadn't been on the stand. I think he's an honorable enough
man that it will not have a chilling effect.
TH E COURT: What's the problem?
MR. SHIRK: I think there is a problem in the call being made in the first place. Your
Honor, I'm going to say right here on the record, I think Mr. Kenneff's phone call
was probably the result of blowing off some steam. I'm not going to accuse him of
having any ulterior motive.
(N.T., Trial at 323-24.)
Mr. Shirk and Mr. Kenneff had a discussion about coming in to see the judge on
Monday, the first day of trial to address the Mihalakis issue. It was going to be Mr.
Kenneff's intention to ask the court to direct Mr. Shirk away from questions about
Dr. Mihalakis's contract with the County. Mr. Kenneff alluded to this fact, among
others, in responding to Mr. Shirk.
With regard to what would happen on Monday, I did frankly discuss with Doctor
Mihalakis the problem that I saw of the defense being able to put him up on the
stand and say to him, isn't it true you are testifying for Mr. Kenneff a couple
months down the road? I could not possibly, once that type of question was asked
in front of a jury, do anything with his testimony no matter how damaging it was.
And about a contract. I said I was going to address the matter with the Court. What
my thinking on it was, those questions, even though they are time and again asked
of expert witnesses, are irrelevant. I was going to come in here and tell the Court
that we would not object as long as the Court rules that questions of that nature
were irrelevant.
We came in here Monday and found there was no need for that because there
wasn't a jury. A particular judge with a background such as yours knows exactly
what the story is with these guys and for that reason I didn't pursue the matter any
further, and for that reason I'm not concerned whatsoever about Doctor Mihalakis
testifying in this case.
Finally, it would be stupid for me to threaten the doctor when I have to use him a
few months down the line in a case just as important as this case.
(N.T., Trial at 326-27.)
The court then had an opportunity to question Dr. Mihalakis:
THE COURT: All right. No one made a request of you that you withdraw, did they?
DR. MIHALAKI S: No, no, they did not. In fact we kind of -- actually it was more
joking than anything with Mr. Kenneff. What do we do with you now that you are a
consultant? And then in fact I offered, I said look, I won't mention it when it comes
to mentioning my credentials.
January January
Sunday
22, 201722, 2017
Page 2059
1057 of 2301
1299
THE COURT: You are a forensic pathologist by training and background?

DR. MIHALAKIS: That's correct.
THE COURT: And probably today is not the first time you've testified in a criminal
case.
DR. MIHALAKIS: No, it is not.
THE COURT: And you've done your examination and you have your opinions that
you are going to state as part of this case, I take it.
DR. MIHALAKIS: Yes. I have a consultative letter.
THE COURT: What is the date of that letter? About when was it written to him?
DR. MIHALAKIS: (Looking at a document ..) June 29.
THE COURT: All right. And I take it that your testimony would be consistent with
that consultative letter.
DR. MIHALAKIS: I would hope so, yes.
THE COURT: Okay. Is there anything about the discussion you had with Mr. Kenneff
that causes you to not say what was in that letter?
DR. MIHALAKIS: No, I don't believe so.
THE COURT: Did you feel threatened or intimidated or coerced by that discussion
you had with Mr. Kenneff?
DR. MIHALAKIS: No, sir, I did not.
THE COURT: Okay.
Mr. Shirk, are you aware of any rule of professional conduct that prevents an
attorney in a criminal case from contacting an expert of a witness who would testify
for the other side?
MR. SHIRK: No, I'm not.
(N.T., Trial at 328-30.)
The problem was that Dr. Mihalakis did not give the testimony that Mr. Shirk had in
mind. Mr. Shirk testified in this PCRA hearing that he was aware of the report and
did not think the report was very helpful. In fact, Mr. Shirk testified that he told Dr.
Mihalakis that the report wasn't going to "help us a lot." (N.T., PCRA at 3440.) After
a discussion with Dr. Mihalakis about the report, Mr. Shirk seemed to think that Dr.
Mihalakis could be possibly more helpful in court than he was in his letter.
However, Mr. Shirk testified that Dr. Mihalakis "indicated to me at all times that he
January January
Sunday
22, 201722, 2017
Page 2060
1058 of 2301
1299
would not be able to say, to a degree of medical certainty, that Laurie Show could
not talk." (Id.) Mr. Shirk was aware that Dr. Mihalakis believed she did not speak
and Dr. Mihalakis gave Mr. Shirk his reasons. (N.T., PCRA at 3440-41.) Mr. Shirk
believes that Dr. Mihalakis "modified" his opinion in a telephone conversation.
(N.T., PCRA at 3441.)
In fact, Messrs. Shirk, Goldberg and Mihalakis had a meeting at a local restaurant
just prior to Dr. Mihalakis's testimony. There is no doubt that they knew what Dr.
Mihalakis was going to say on the witness stand. In fact, in this PCRA hearing, Dr.
Mihalakis testified that there was "no doubt in my mind that Mr. Shirk knew very
much what I was going to say." (N.T, PCRA at 2542.)
The only "new" evidence presented at the PCRA hearing had to do with Dr.
Mihalakis's income from the county. Dr. Mihalakis testified that his income from
Lancaster County increased because there was an increase in murder cases in
Lancaster County. He performed a number of autopsies in 1992 and these cases
came to trial in 1993. He did 16 autopsies for Lancaster County in 1993. It is clear
that his compensation increased because there was an increase in homicide cases
in Lancaster County in 1992 and 1993.
To take the fact of increased compensation out of context and attach some sinister
significance to this is misleading.(81) As testimony established, Lancaster County
was in a period of transition in 1992 in terms of handling murder cases. Dr.
Penades, who had been the county pathologist for years, was in the process of
retiring. The district attorney entered into a contract with Dr. Mihalakis dated April
8, 1992, for consulting services involving forensic pathological examinations,
assistance in criminal investigation, training, and expert testimony at preliminary
hearings and trials. (Petitioner's Exhibit 2087.) Pursuant to this agreement, Dr.
Mihala kis performed autopsies in 1992 and 1993. He also testified in several major
cases in 1993. His income began to trail off after 1993 because of the involvement
of Dr. Ross, a forensic pathologist who took over these responsibilities in Lancaster
County on a full-time basis in 1994.
According to the testimony of Mr. Kenneff and Mr. Madenspacher, both of whom
were uncontradicted on this point, there was a significant increase in homicide
cases in their office in 1992 and 1993. Unlike the major metropolitan centers, the
number of homicide cases in Lancaster County each year is relatively low. In a year
where there is a significant increase, there is a significant strain on the system and
a significant increase in the need for, among other things, expert testimony from a
forensic pathologist. When given more than superficial consideration, the increase
in compensation does not even come close to the kind of "payola" pronounced by
petitioner's counsel. (82)
The second allegation of after-discovered evidence by Ms. Lambert basically
involves Mr. Kenneff's conversation with Dr. Mihalakis and this has been fully
considered in the 1994 opinion and in the discussion above.
The third allegation of wrongdoing involving Dr. Mihalakis is a claim of "witness
tampering or retaliation." In essence, the federal district court disagreed with this
court's finding that there was no prejudice to defendant by the conversation
between Mr. Kenneff and Dr. Mihalakis. The federal district court attached greater
significance to this issue than did the state court without the benefit of any
January January
Sunday
22, 201722, 2017
Page 2061
1059 of 2301
1299
additional relevant evidence.

In 1992 during a colloquy in chambers, and again in considering post verdict
motions in 1994, we carefully considered whether the behavior of Mr. Kenneff was
unethical under the Rules of Professional Responsibility. Clearly, Mr. Kenneff should
not have contacted Dr. Mihalakis and, in hindsight, all would agree with this. Did it
violate any stated canon of professional responsibility? The answer to that is no. In
fact, counsel for the defense was asked that specific question during the colloquy
and was unable to point to any violation of the Rules of Professional
Responsibility.(83)
This was more than simply an advocate contacting his opponent's expert witness.
In fact, Mr. Kenneff and Dr. Mihalakis were involved in a contractual relationship
that was in existence for only three months at the time of the trial. This expert was
"sprung" on the Commonwealth just before trial in that Mr. Shirk informed Mr.
Kenneff that Dr. Mihalakis would be testifying in a conversation on Thursday, July
2, 1992. Trial was set to begin the following Monday. These extenuating
circumstances explain Mr. Kenneff's displeasure at Mr. Shirk's retaining of Dr.
Mihalakis and at Dr. Mihalakis's willingness to assist the defense. His call to Dr.
Mihalakis was the result of this displeasure.
Mr. Kenneff testified at the PCRA hearing that he was going to ask the court for
cautionary instructions about the relationship between Dr. Mihalakis and the
County. When the case turned into a non-jury trial, this concern was alleviated.
The court does not make evidentiary rulings based upon allegations of unethical
conduct. The court can sanction counsel, can warn counsel and can suggest
appropriate disciplinary action.(84) The remedy for a violation of the Rules of
Professional Conduct is disciplinary action. While the contact between Mr. Kenneff
and Dr. Mihalakis created an issue in the 1992 trial, this court saw no reason for a
mistrial based on a demonstrated lack of prejudice to petitioner. This court saw no
basis on which to refer Mr. Kenneff to the Disciplinary Board. This court also notes
that in the ensuing years, neither Mr. Shirk, nor Mr. Goldberg, nor Mr. Epstein, nor
Ms. Lambert, nor Ms. Lambert's family saw fit to refer this issue to the disciplinary
authorities. It was arguably improper conduct with some justification under the
circumstances. The bottom line is that it did not affect the witness's testimony at
trial. He testified consistent with his report and his testimony was no surprise to
petitioner's counsel.
The question remains why did Mr. Shirk and Mr. Goldberg call Dr. Mihalakis under
these circumstances? Possibly, it was to cast doubt about Laurie Show's ability to
speak. Dr. Mihalakis certainly established that any speech would have been faint.
Keep in mind that the Commonwealth witnesses said that speech was possible and
Dr. Mihalakis qualified this and said it would have been very difficult for her to
enunciate.
A second reason to call Dr. Mihalakis would have been to cast doubt on the fact
that Laurie Show was alive for a full half hour. He helped the defense in this area
by providing a strong basis on which a fact finder could doubt that Laurie Show
lived long enough to speak to her mother. The fact that this court did not find a
reasonable doubt about guilt based upon this testimony does not mean it was a
January January
Sunday
22, 201722, 2017
Page 2062
1060 of 2301
1299
mistake to put Dr. Mihalakis on the stand.

A third possibility, that defense counsel put Dr. Mihalakis on the stand knowing he
would not help them but with the belief that the Kenneff conversation would create
a strong appeal issue, is not considered by this court. This court is aware of the
professional integrity, skill and judgment of the defense attorneys involved in this
case and rules out any untoward use of Dr. Mihalakis's testimony under these
circumstances. It is likely that Dr. Mihalakis was put on the stand because of his
strong testimony on the time of death, the time for loss of consciousness, and the
difficulty in phonation or enunciation. The fact that he could not rule out speech
does not mean he was useless to the defense.

Petitioner contends that she now has after-discovered evidence relevant to the
credibility of Laura Thomas. Ms. Thomas was a witness at trial as to Ms. Lambert's
animus against Laurie Show. Specifically, Ms. Lambert contends that after the
murder, Ms. Thomas was caught lying to the East Lampeter Township police about
being "kidnaped." Petitioner contends that after Ms. Thomas agreed to say Ms.
Lambert planned to "slit Laurie's throat" in her trial testimony, her charges were
reduced to disorderly conduct and she was only made to pay a small fine. (Exhibit
A, Section A, para. 41.) Further, petitioner claims that neither Laura Thomas nor
her father, Floyd Thomas, said anything about Ms. Lambert's plans to "slit
[Laurie's] throat" in their initial interviews with the police. (Exhibit A, Section A,
para. 42.) Ms. Lambert lists those same allegations under the heading of
Brady/Giglio violations. (Exhibit A, Section B(5), paras. 66 and 68.) Finally, Ms.
Lambert refers to Ms. Thomas's testimony as "false and/or perjured" to the extent
that Ms. Thomas related that Ms. Lambert wanted to "slit Laurie Show's throat."
(Exhibit A, Section B(6), paras. 109 and 110.)
To understand this issue, it is important to look first at Laura Thomas's testimony in
1992. Ms. Thomas was a friend of Ms. Lambert's in 1991. She was one of a group
of teenagers enlisted by Ms. Lambert to abduct Laurie Show. She testified at trial
about discussions of a plan to do harm to Laurie Show:
Q. Who participated in the discussions leading to this plan to do something bad?
A. It was myself, Kimona Warner, Vince Orsi, Rachel Winesickle, Lawrence and
Michelle.
Q. Who told you what the plan was to be?
A. Michelle.
Q. What did Michelle tell you the plan was to be?
A. Okay. We were supposed to go over to Laurie's house and, myself and Kimona,
and we were supposed to go and knock on her door and say that we were going to
a fraternity party and there was like three college guys we were supposed to meet
there, supposedly. We were supposed to get her out of the house and then we
January January
Sunday
22, 201722, 2017
Page 2063
1061 of 2301
1299
were supposed to go take her downtown on Green Street, tie her to a telephone
pole, or some kind of a pole, and Michelle was going to cut her hair and slit her
throat, beat her up, spray paint a sign, black pussy, on her.
Q. All of this was told to you by Michelle?
A. Yes.
(N.T., Trial at 668-69.)
This plan never came to fruition because Laura Thomas and Kimona Warner went
to Laurie Show's house and warned her. Ms. Thomas went on to describe another
discussion regarding harm to Laurie Show:
Q. Now did Michelle ever try to obtain your assistance again in a similar plan or
another plan to hurt Laurie?
A. Yeah. She always wanted me to go and pick her up, get her out of the house
because she knew that I was friends with Laurie.
Q. Where did the conversation regarding this occur?
A. Right outside my house on my picnic table that we all sat at.
Q. At any time did Michelle say to you what she intended to do once you got Laurie
out of the house?
A. Well, this time it wasn't getting her out of the house; I don't know what it was.
But she just said I swear to God I'm going to kill her. She said I'm going to slit her
throat.
Now, six years later, Ms. Lambert claims to have after-discovered evidence that
proves Ms. Thomas was lying. Ms. Lambert centers this issue on the absence of any
reference to slitting Laurie Show's throat in Ms. Thomas's interviews with the police
at the time of the murder. Ms. Thomas spoke to Officer Flory on December 20,
1991, to Officer Bowman on January 2, 1992, and to Officer Renee Schuler on
January 5, 1992. Only the January 14, 1992, report of Officer Bowman's interview
with Laura Thomas on January 2, 1992, contains any reference to Ms. Thomas's
recollection of a statement by Ms. Lambert that she was going to slit Laurie Show's
throat. (Commonwealth's Exhibit 4; Commonwealth's Exhibit 41.)
Ms. Lambert suggests that Ms. Thomas included the language "slit her throat" at
trial in exchange for favorable treatment by the East Lampeter Township Police
Department on a "false reports" charge against her. This is absurd given the fact
that Ms. Thomas's January 2, 1992, statement very clearly includes the "slit her
throat" language. This statement was taken six weeks before the "false reports"
charge was made against Ms. Thomas.
Moreover, this is a misleading argument based upon a contrived and superficial
January January
Sunday
22, 201722, 2017
Page 2064
1062 of 2301
1299
understanding of the "false reports" incident. The incident involved a call by Linda
Thomas, Laura's mother, to the East Lampeter Township police regarding her
daughter's story about a "kidnaping." Officer Robert Reed of East Lampeter
Township interviewed Laura Thomas and prepared a report dated February 18,
1992. In short, Laura Thomas had "staged" her own kidnaping to attract the
attention of her apparently disinterested boyfriend. Her report was intended to get
back to the boyfriend and to draw his sympathies. It was not intended to get back
to Mrs. Thomas or to the police. Because the police did become involved and
because her deception led to a police investigation, albeit prompted by her mother,
Officer Reed charged Laura Thomas with disorderly conduct.
Petitioner makes much of the fact that this was a "false reports" charge which was
"reduced" to disorderly conduct by the East Lampeter Township police. First of all,
this was not a "false reports" charge in any way, shape or form. A "False Reports to
Law Enforcement Authorities" charge under 18 Pa. C.S.A. 4906(b), would have
involved conduct by Laura Thomas in making a false report to the police about an
incident knowing it did not occur. Laura Thomas did not do this. The elements of
"false reports" could not have been established under these facts.
In any event, a "false reports" charge would be a misdemeanor of the third degree.
The difference between a misdemeanor of the third degree and a summary offense
to a juvenile offender, to the police or to the Juvenile Court, is legally and factually
insignificant. Only a lack of understanding of the elements of a crime under
Pennsylvania law, a lack of understanding of the different treatment afforded
juvenile offenders and adult offenders under Pennsylvania law, and a tendency to
proclaim dramatic findings based upon a partially informed analysis could lead
anyone to attach significance to Officer Reed's decision to charge Ms. Thomas with
summary disorderly conduct. In fact, it is likely that neither a misdemeanor false
reports nor a summary disorderly conduct would have placed Ms. Thomas in the
formal juvenile justice system. It is more likely that either charge would have been
handled in the same or in a similar way: with a fine at the district justice level or
through informal probation with the Juvenile Probation Office involving no more
than a fine.
The second issue with respect to Laura Thomas is whether the report about her
"kidnaping" should have been disclosed to Mr. Shirk. (85) At the PCRA hearing, Mr.
Shirk testified that he would have liked to have been able to cross-examine Ms.
Thomas about this kidnaping report. (N.T., PCRA at 3392.) When questioned about
what use he could have made of the report at trial, he was less emphatic. In fact,
he acknowledged that it could be put to no legal use at trial but that he certainly
would have "attempted to use it and let the other side stop me." (N.T., PCRA at
3526.) Is it a Brady/Giglio violation to withhold information that could never be
put to a legal use or purpose at trial? Does the Commonwealth have an obligation
to provide the defendant with information which would create error if used? We
suggest that Mr. Shirk knows the answers to these questions and Mr. Shirk candidly
acknowledged that he would have tried to use the kidnaping incident, hoping the
Commonwealth would fail to object.
To argue that this report would have generated admissible impeachment material
as to Laura Thomas is just plain wrong. There is no other way to describe it. Under
the Juvenile Act, Ms. Thomas's juvenile record would have been inadmissible for
January January
Sunday
22, 201722, 2017
Page 2065
1063 of 2301
1299
impeachment purposes in 1992. See, 42 Pa. C.S.A. Section 6354. (86)

The "slit her throat" issue has no merit. Mr. Shirk had available to him the report of
Officer Bowman which described Laura Thomas's description of Ms. Lambert's plan
to "slit" Laurie's throat. (Commonwealth's Exhibit 4; Commonwealth's Exhibit 41.)
He also had reports of Officers Flory and Schuler which did not mention the "slit her
throat" language. (See, Commonwealth's Exhibit 4.) He had every opportunity to
c ross-examine Ms. Thomas on this inconsistency and to argue that she fabricated
this aspect of her story. The real question is whether this would have made any
difference at all. Given the violent, premeditated, degrading plot to kidnap Laurie
Show, remove her clothing, physically assault her, and leave her tied up and
vulnerable to predators, the expression "slit her throat" is mere icing on the cake.
Without that language, Ms. Thomas was still describing a series of felonies which
spoke loudly and clearly to Ms. Lambert's hatred toward Laurie Show. When and
where and why she included language about slitting Ms. Show's throat is but one
fact in an otherwise unshakeable body of evidence demonstrating this prolonged
and hostile attitude exhibited by Ms. Lambert against Ms. Show.
Whether there was any discovery or Brady violation is addressed by Mr. Shirk's
cross-examination of Ms. Thomas at trial. In his cross-examination, he refers to a
police report of an interview of January 10, 1992. (N.T., Trial at 677.) Not only did
Mr. Shirk have the police reports available to him regarding the initial interviews of
Ms. Thomas, he also met with Ms. Thomas on June 18, 1992, in his office in
preparation for trial. The thrust of Mr. Shirk's cross-examination was to establish
that there was no mention of slitting a throat in the meeting of June 18, 1992. In
fact, this was a major thrust of Mr. Shirk's cross-examination of Ms. Thomas in
general. Ms. Thomas would not agree with Mr. Shirk's characterization of their
meeting. Mr. Shirk, in reference to the meeting in his office on June 18, 1992, with
Ms. Thomas and friends, asked the following of Laura Thomas:
Q. And didn't everyone pretty much agree that there was nothing said that night
about slitting Laurie's throat; it was simply to - not simply - but to take her to
town, tie her to a pole, cut her hair and put a sign, write on her, free black pussy?
A. No, we did say we were going to slit her throat.
Q. Who said that?
A. Me and Kim and Rachel. She wouldn't Q. That night in my office?
A. Yes.
The clear testimony was that in the June 18, 1992, meeting with Mr. Shirk, Ms.
Thomas related that Michelle said she was going to slit Laurie's throat. Whether Mr.
Shirk wanted to use the December 1991 and January 1992 interviews of Ms.
Thomas to impeach her on this point, he certainly could not claim surprise at trial
January January
Sunday
22, 201722, 2017
Page 2066
1064 of 2301
1299
about this aspect of Ms. Thomas's testimony. She clearly told Mr. Shirk from the
witness stand that she had informed him prior to trial that the "slit the throat"
concept had been discussed by Ms. Lambert in the summer of 1991.

The black sweatpants were of relatively little value to this court as the fact finder in
1992. Today, they play a leading role in Ms. Lambert's post conviction drama. In
1992, the issue of the black sweatpants was simple. Mr. Yunkin testified that Ms.
Lambert wore them on the morning of the murder, but that they were his
sweatpants. Ms. Lambert told Corporal Solt that she was wearing black sweatpants
at the time of the murder. The only real question was whether she could have worn
sweatpants owned by the larger Lawrence. This was resolved by the court's
observations of the sweatpants, of Mr. Yunkin, of Ms. Lambert, and the conclusion
that Ms. Lambert could certainly have worn the garment.
Today petitioner contends that Mr. Yunkin's testimony about Ms. Lambert wearing
his clothing was false and perjured testimony. Further, petitioner contends that
some time between the 1992 trial and the 1997 federal habeas hearing, the
Commonwealth "switched" a pair of lady's (or boy's extra large) sweatpants for the
men's extra large sweatpants admitted into evidence in 1992 as Commonwealth's
Exhibit 9. Specifically, petitioner contends that the bloody sweatpants, sized men's
extra large, were destroyed by the Commonwealth and a smaller pair substituted.
The analysis can begin, and should end, with the observation that there was no
charge of misconduct regarding the black sweatpants in the 1992 trial. Petitioner
can point to no fabrication, alteration, modification or destruction of any evidence
regarding any item of clothing at or before the 1992 trial. Petitioner's only
contention with respect to the 1992 trial is that Mr. Yunkin's testimony about Ms.
Lambert wearing his clothing must have been false and, therefore, the
Commonwealth offered perjured testimony in support of the conviction.(87)
References to clothing are easily ascertained from the 1992 record. Ms. Lambert's
first description to the police about her attire was given in her statement dated
December 21, 1991. She told the police that she "had on a jergo. It's a strawy
thing, with a hood on it. I have it in my closet. I also had on a Bart Simpson TShirt, stretch pants, and these white shoes and socks." (Petitioner's Exhibit 1016-A,
Pennsylvania State Police Investigative Report of December 22, 1991, at 10.)
Toward the end of her interview with Corporal Solt, she changed her story:
The reason I was so scared, when I walked out I had different shoes, (sneakers),
socks, a red flannel shirt & white socks on, & black sweat pants. When Tabby came
out, she had blood on her hands & she grabbed my arm & got blood all over the
arm of my flannel shirt. I don't know if Lawrence saw that or not. I put it in a
dumpster, behind K-Mart or something.
In fact, the clothing described by Ms. Lambert was recovered by the police from a
truck that had picked up the trash from behind the K-Mart dumpster. (N.T., Trial at
January January
Sunday
22, 201722, 2017
Page 2067
1065 of 2301
1299
132-34.)(88)
At trial, Ms. Lambert admitted that while she changed her statement regarding the
clothes she wore, that changed statement was a lie designed to cover up Mr.
Yunkin's participation. (N.T., Trial at 1035-36, 1172-73.) At trial she gave yet
another version of her apparel at the crime scene. She stated: "I had on black
pants. They were like black slush pants and a black Harley Davidson shirt, my black
MTV sweatshirt and gray and white jergo." (N.T., Trial at 1076.) This testimony
contradicted both versions given to Corporal Solt.
Mr. Yunkin testified at trial about Ms. Lambert's apparel on the morning of the
murder. On direct questioning by Mr. Shirk, Mr. Yunkin testified:
Q. Now when you dropped Michelle and Tabby off, do you recall what they were
wearing?
A. Yes. Michelle had on a flannel shirt, sweatpants and a jergo.
(N.T., Trial at 203.) Mr. Kenneff then held up the black sweatpants marked as
Commonwealth's Exhibit 9 and questioned Mr. Yunkin about these:
A. Sweatpants that I owned.
Q. Do you recall seeing those on December 20, 1991?
A. Yes, I do; on Michelle.
Q. Were those sweatpants on Michelle when she left your car on the morning of
December 20, 1991 at approximately 6:45 a.m.?
A. Yes.
Q. Was it unusual for Michelle to wear your clothing?
A. No it was not.
Q. Was t, here anything in particular at that time to cause Michelle to wear your
clothing?
A. She was pregnant at the time.
Q. How many months pregnant was she?
A. About seven months.
Mr. Shirk cross-examined Mr. Yunkin and Mr. Yunkin confirmed that Ms. Lambert
January January
Sunday
22, 201722, 2017
Page 2068
1066 of 2301
1299
was wearing "black sweatpants." He also confirmed that those sweatpants were his.
(N.T., Trial at 225-26.)
Donald Bloser testified at trial that Commonwealth's Exhibit 9, the black
sweatpants, tested positive for the presence of blood. (N.T., Trial at 613-14.)
Vincent M. Orsi was called as a defense witness at trial and was shown the black
sweatpants by Mr. Shirk. Mr. Shirk first questioned him as to whether he had ever
seen Mr. Yunkin in black sweatpants:
Q. When had you seen Mr. Yunkin wearing black sweatpants?
A. I had slept over a few times and he wore them to bed, or if he was bumming
around the apartment he would wear them.
Q. I'm going to show you what's been marked Commonwealth's exhibit 9. Do you
recognize those sweatpants?
A. (Looking at the exhibit) Yeah. He would wear them to bed, bumming around the
house.
Q. They look familiar and similar to the ones he would wear?
A. (Nodding head affirmatively) Yeah.
(N.T., Trial at 904-05.)
None of this testimony appeared particularly pivotal at the 1992 trial. The black
sweatpants were never mentioned in Mr. Kenneff's opening statement or in Mr.
Shirk's opening statement. The sweatpants were not mentioned in Mr. Kenneff's
closing argument where certain items of evidence material to the Commonwealth's
theory of the case were discussed. Mr. Shirk argued that the sweatpants were worn
by Mr. Yunkin in his closing. (N.T., Trial at 1243-44.) Mr. Shirk argued that the
more likely wearer of the sweatpants was Mr. Yunkin and that this suggested that
Mr. Yunkin was in the condominium that morning and participated in the murder.
This court carefully considered that argument at trial and rejected it as proof that
Mr. Yunkin was present in the condominium. This issue was addressed in this
court's opinion on post verdict motions. See Commonwealth v. Lambert, July 19,
1994, slip op.
There is absolutely no merit to the contention that Mr. Yunkin's testimony about
Ms. Lambert wearing his clothes was false or perjured. We found this to be
believable in 1992 and nothing we have learned or heard since that time changes
that opinion.
Further, there is no proof that the sweatpants admitted into evidence as
Commonwealth's Exhibit 9 in 1992 have ever been altered, changed, or
substituted. Petitioner suggests that the sweatpants in 1992 were so large that Ms.
Lambert would be "swimming in them." There is simply no testimony or even any
January January
Sunday
22, 201722, 2017
Page 2069
1067 of 2301
1299
argument to this effect.(89)

The controversy over the black sweatpants arose at the federal habeas hearing. In
petitioner's amended habeas petition she refers to "Yunkin's grossly oversized
clothing, that would have severely impeded her movements. . . ." See Lambert v.
Blackwell, 962 F. Supp. at 1531. Petitioner's characterization of the black
sweatpants as "grossly oversized clothing" appeared to be at odds with the size of
the sweatpants which were produced to petitioner by the Commonwealth. These
sweatpants, according to the Commonwealth, were the same sweatpants as were
admitted into the 1992 trial as Commonwealth's Exhibit 9. Armed with the
assumption that Commonwealth's Exhibit 9 was, in fact, a grossly oversized pair of
baggy black sweatpants and faced with a pair of black sweatpants which do not
appear to be "grossly oversized," petitioner's counsel leaped to the conclusion that
the sweatpants were "switched." For petitioner to argue that the sweatpants were
"switched" is somewhat tame.(90) But the evidence does not support this dramatic
and "shocking" possibility.
In the PCRA hearing, Mr. Shirk was shown Petitioner's Exhibit 1004, the black
sweatpants in question. He testified that to the best of his recollection, they are
smaller than the sweatpants used at trial. (N.T., PCRA at 3301.) He offered his
opinion that these sweatpants would not fit Mr. Yunkin. (N.T., PCRA at 3302.) Julius
Hyman, a textile expert, offered his opinion that the black sweatpants, Petitioner's
Exhibit 1004, were actually sized boy's extra large, not men's extra large. (N.T.,
PCRA at 358.) He was shown a photograph of the sweatpants which was taken in
1992 by Mr. Shirk, (Petitioner's Exhibit 3833), and compared that with the
sweatpants introduced into evidence at the PCRA as Petitioner's Exhibit 1004. He
offered his opinion that the sweatpants are different. (N.T., PCRA at 371-72.)
Yet, the Commonwealth's investigator, James Gallagher, testified that he conducted
an experiment where he obtained the same cardboard box lids, (Commonwealth's
Exhibits 56 and 57), on which the sweatpants rested in Mr. Shirk's 1992
photograph. (N.T., PCRA at 6568-69.) He took the sweatpants in question, laid
them out over the same box lids, and took a photograph that was substantially the
same as Mr. Shirk's photograph. (N.T., PCRA at 6569-75.)
Lieutenant Renee Schuler testified to Petitioner's Exhibit 1158, which is an evidence
log, listing the content, s of a trash bag found at the incinerator on Saturday
morning, December 21, 1991. (N.T., PCRA at 3835.) Officer Renee Schuler found a
pair of "ladies dress 'black' sweatpants (appears small size)" and listed these on the
evidence log. (Id.) Mr. Kenneff testified that these sweatpants eventually became
Commonwealth's Exhibit 9 at the 1992 trial. (N.T., PCRA at 1900.) Donald Bloser,
who performed blood testing on the sweatpants in 1992, identified his markings on
the exhibit in question at the PCRA hearing. (N.T., PCRA at 218.) He noted that the
markings are faded. (N.T., PCRA at 217.)
This court had the opportunity to view the sweatpants during the hearing. Certainly
they would have been baggy on Ms. Lambert. Certainly they appear to be more
consistent with a "ladies' large" or a "boy's extra large" size than with a "men's
ext ra large." We are left only to speculate as to whether the pants fit Mr. Yunkin.(91)
We found no evidence to suggest that the sweatpants were "switched." There
appears to be some disagreement as to whether Mr. Yunkin could have worn these
January January
Sunday
22, 201722, 2017
Page 2070
1068 of 2301
1299
pants, whether they were "baggy" sweatpants as recalled by Mr. Shirk, and
whether by the size alone of the sweatpants they could have been worn by either
Ms. Lambert or Mr. Yunkin. We are left with the reliable and uncontradicted
evidence log which catalogs these as ladies' dress black sweatpants. We are left
with a comparison of the photographs from Mr. Shirk's office in 1992 and from the
evidence room in the PCRA hearing in 1998. These photographs are substantially
similar. We note Mr. Hyman's conclusion that the sweatpants in evidence contain
an elastic waistband and the sweatpants in Mr. Shirk's photograph do not appear to
have an elastic waistband. However, upon careful examination, the photograph
taken by Mr. Shirk is out of focus and it appears that, there could possibly h, ave
been an e, lastic waistband, although blurred by the photograph.
All this discussion about "switched" sweatpants is misleading. It would have been
silly to switch these sweatpants. They were considered at trial, they were identified
as having been owned by Mr. Yunkin and worn by Ms. Lambert. The court issued an
opinion in 1994 confirming that "title" to the sweatpants had nothing to do with the
verdict. The most we could conclude in 1992 was that Ms. Lambert could possibly
have worn the sweatpants and the fact they were owned by Mr. Yunkin did not
prove Mr. Yunkin's involvement in the murder.
Even if we assume the sweatpants were "switched" during the habeas corpus
hearing, that does nothing to establish after-discovered evidence, prosecutorial
misconduct or ineffective assistance of counsel under the PCRA. Even if the
sweatpants had been "switched" in 1997, this is is not a fact that would have
changed the outcome of the 1992 trial nor did it so undermine the truthdetermining process in 1992 that no reliable verdict was possible. Petitioner's
counsel would simply disagree with this court's conclusion that Ms. Lambert could
have worn the sweatpants offered into the record in 1992. They were not present
at the trial. This court was present and concluded on the record that it was possible
for her to have worn these sweatpants.
In the July 19, 1994, opinion, we noted: "The court listened to the testimo ny
regarding the clothing, observed the size of the garments and the size of the
people involved, i.e., Ms. Lambert, Ms. Buck and Mr. Yunkin, and found there to be
no question raised by the fact that the clothing appeared to be Mr. Yunkin's."
Commonwealth v. Lambert, July 19, 1994, slip op. at 14. That factual finding
was within the province of this court and was not attacked in any way by counsel in
the appellate process. If the federal district court found that the sweatpants were
"switched" during the proceeding, then it had every right to be concerned. But the
concern would have been for the Commonwealth's conduct during the habeas
hearing, not for the effect switching the sweatpants in 1997 would have had on the
1992 verdict. We simply do not have any conclusive evidence in this record which
would establish that the sweatpants were switched. We further find that argument
is of no legal significance to this PCRA case even if it would have factual support.
We looked at what was available to this court in 1992 and whether after-discovered
evidence regarding the integrity of the evidence in 1992 is now available to this
court. We considered whether presentation of the sweatpants as evidence in 1992
was the result of prosecutorial misconduct. We find neither to be the case.
Therefore, we find that the issue of the black sweatpants has no bearing on
petitioner's post conviction claim.
January January
Sunday
22, 201722, 2017
Page 2071
1069 of 2301
1299

On December 22, 1991, two days after the murder of Laurie Show, the police
conducted a search of the Susquehanna River near the Pequea Creek inlet.
(Petitioner's Exhibit 1295.) Two critical pieces of evidence were found: a large
butcher knife and a rope. (N.T., PCRA at 800, 805.) This search was conducted by
the East Lampeter Township Police Department with the assistance of local scuba
divers. The search was filmed by William "Smokey" Roberts, a professional scuba
diver and videographer. (Petitioner's Exhibit 1040.) Mr. Roberts reviewed, edited
and copied the tape made of the search for the police and the district attorney's
office.(92) (Petitioner's Exhibit 1695; N.T., PCRA at 1107-1110.) Only this edited
version was turned over to Ms. Lambert's defense attorney. Mr. Shirk testified to
seeing the river search tape at the East Lampeter Township Police Department.
(N.T., PCRA at 3360, 3363.) He also stated that he received a copy of Officer
Reed's report that stated the videotape was edited by Smokey Roberts "to cut
down on time span and to eliminate unnecessary background noise." (N.T., PCRA at
3358; Petitioner's Exhibit 1295.) At no time, however, did Mr. Shirk request a copy
of the unedited tape.
Ms. Lambert contends that the police and/or prosecution edited the videotape to
delete allegedly exculpatory evidence of the police finding a pink bag at the river.
(Exhibit A, Section B(4) at para. 48.) The edited tape, however, showed an empty
pink bag embedded in ice. (N.T., PCRA at 1110, 3498-99; Petitioner's Exhibit
1695.) This pink bag was determined by the police to be immaterial to the case and
so was not recovered. (N.T., PCRA at 801-03.)
The edited tape also showed another empty bag of indeterminate color which was
found by the police along the river bank. (N.T., PCRA at 3498; Petitioner's Exhibit
1695.) However, this too was found to be irrelevant to the investigation and was
not seized as evidence.
At trial, Detective Barley was questioned by defense counsel as to whether during
the river search he found a trash bag containing sneakers. He stated he did not.
(N.T, Trial at 144.) Mr. Shirk explained in his PCRA testimony that he did not
impeach Detective Barley with the video, which clearly shows the discovery of a
pink bag, because he assumed it was one of many things found at the river that
simply was not relevant to the investigation. (N.T., PCRA at 3363.) As Mr. Shirk's
testimony reveals, it is reasonable to interpret Detective Barley's answer as a
denial that a trash bag with evidence in it, i.e., Mr. Yunkin's sneakers, the rope, the
knife, two pairs of sunglasses and the hats, was found during the search. The
evidence before this court, testimonial and video, showed that the plastic bags
were empty.(93)
Detective Barley's denial that he found a pink trash bag was immaterial to the case,
especially in light of the fact that the disposal of a trash bag by Ms. Lambert was
not an issue at trial. Ms. Lambert testified at trial that she disposed of a red bag(94)
containing the rope, the knife, two pairs of sunglasses, the hats, Yunkin's sneakers
and some rocks by throwing it into the Susquehanna River. (N.T., Trial at 1025-27,
1056.) Although Mr. Kenneff questioned Ms. Lambert about the color and size of
the bag and whether Mr. Yunkin threw anything in the river separate from the bag,
he did not question that Ms. Lambert threw the bag in the river. (N.T., Trial at
1154-55.) At trial, the Commonwealth never contended that Ms. Lambert did not
January January
Sunday
22, 201722, 2017
Page 2072
1070 of 2301
1299
throw a bag into the river. To the contrary, the Commonwealth introduced Mr.
Yunkin's testimony that Ms. Lambert did throw a bag into the river. (N.T., Trial at
219.) This testimony had no effect on the outcome of the trial.
A second river search was organized for December 23, 1991. (Petitioner's Exhibit
1295.) At that time a diver discovered a sneaker in the Pequea Creek. (N.T., PCRA
at 823-24.) Detective Barley determined that it had no evidentiary value because it
was old, stained brown, decaying, packed with mud, had black rot, had rotted
threads, and had clearly been in the water more than three days. (N.T., PCRA at
823-24, 828-30.) It was found not in the river, like the rope and knife, but in the
Pequea Creek inlet which empties into the river and, therefore, could not have been
the sneaker the police were looking for. (N.T., PCRA at 824, 825.) For these
reasons, the sneaker was not seized as evidence.
Ms. Lambert contends that the undisclosed sneaker was exculpatory and, thus,
kept from the defense. At the time of the search, the police knew only that: (1) Mr.
Yunkin said that Ms. Lambert threw a trash bag containing shoes and rocks into the
river, (Commonwealth's Exhibit 4, West Lampeter Township Police Supplemental
Report by Officer Jere Schuler), and (2) Ms. Lambert said she had tossed sneakers
into the river, (Petitioner's Exhibit 2079). Thus, at the time of the search, the police
would have believed that anything found in the river relating to the murder would
incriminate Ms. Lambert because Ms. Lambert was the person who disposed of the
evidence. Clearly, so early in the investigation, the police would not ignore
evidence that might assist them in solving the murder, whether it incriminated only
Ms. Lambert (if the sneaker was Ms. Lambert's), or both Ms. Lambert and Mr.
Yunkin (if the sneaker was Mr. Yunkin's, but discarded by Ms. Lambert). Thus, it is
certainly plausible that an empty pink bag, embedded in ice, would be insignificant
to the searching officers, as would a black, rotted sneaker that had been in the
Pequea Creek for an extended period of time. The prosecutors and police officers in
this case could not then have known that Ms. Lambert would later disavow her presearch statements and later implicate Mr. Yunkin. The investigation must be viewed
in the light of what they knew when they acted.

Early in the morning of December 21, 1991, Ms. Lambert gave a statement to
Corporal Raymond Solt of the Pennsylvania State Police. This has been referred to
as the "Solt Statement' and has the designation of Petitioner's Exhibit 1023.
Corporal Solt was originally called in to administer a polygraph examination, to
which Ms. Lambert had consented.
Ms. Lambert actually gave to the police two statements on December 21, 1991. (95)
The first, given to Corporal Solt prior to the polygraph, was a handwritten
statement containing what has become known as "the alibi story."(96) She gave this
handwritten statement in response to Corporal Solt's request to tell him what
happened. He was going to use her story to compose questions for the polygraph
examination.
During the polygraph, Corporal Solt advised Ms. Lambert of his opinion that she
was not being truthful about what happened in the Show condominium. Ms.
January January
Sunday
22, 201722, 2017
Page 2073
1071 of 2301
1299
Lambert then departed from the "alibi story."(97)

She told Corporal Solt that she and Ms. Buck were dropped off by Mr. Yunkin and,
in fact, they went into the Show condominium. She told Corporal Solt that it was
her idea to go because "I wanted to talk to Laurie." (Petitioner's Exhibit 1016-A,
PSP Report at 7.) She described how Ms. Buck went to the door, how Laurie
answered the door and how both went into the condominium: "I went upstairs and
went in and shut the door." (Id.)
Ms. Lambert described an attack, largely conducted by Ms. Buck and largely
witnessed by Ms. Lambert. On the second page of the "Solt Statement," Ms.
Lambert related:
Laurie tried to grab a scissors, and Tabby took them away and I don't know what
she did with them. I saw she had a knife and I saw her bring it down. It looked like
it bounced off. It didn't look real. Whenver [sic] she pulled it, Laurie jerked and fell
on the floor and rolled away and I heard that sound (indicating a 'woosh') and
Laurie coughing and kept saying that she was sorry. She was sorry, and saying:
'You're not going to leave me here?' and I saw Tabby take the knife and hitting and
I saw the knife come down, in her hair. Seh [sic] couldn't breathe right and was
making that sound ('woosh') and coughing and laying there and saying: 'Don't
leave me.'. She said she was sorry. She coughed, her body was jerking and stuff. I
couldn't look anymore and I turned away.
From her statement, it is clear that she was aware that Laurie had been stabbed.
She described a sound consistent with the back injury which punctured a lung and
she described how Ms. Buck's action made her sick. She went on to describe the
path she took when she left the apartment. In Corporal Solt's report, he relates
what Ms. Lambert told him:
. . . .I started to run, I'm not sure which way. Tabby told me to slow down. I ran
like up through the buildings and came out in somebody's back yard. I came out at
the cream house with shutters, I think they were blue. Tabby ran a different way. I
met up with her then right by the bushes at the woods.
(Petitioner's Exhibit 1016-A, PSP Report at 8.)
Later, at page 5 of the "Solt Statement," when asked where she went when she left
the apartment, she stated:
I got confused and I had no idea where I was and I ended up in someone's back
yard. I was in two fields while I was running and a patch of woods. I steped [sic] in
a creek and tripped over a barbed wire fence and fell. The creek was like a little run
off, not like a creek. I fell and landed in the briars. I ended up in those people's
back yard. I stood still and I saw Tabby walking down, through the woods, and she
was calm about it, and I ran.
January January
Sunday
22, 201722, 2017
Page 2074
1072 of 2301
1299

Ms. Lambert also described what she was wearing:
When we walked up, I had on a jergo. It's a strawy thing, with a hood on it. I have
it in my closet. I also had on a Bart Simpson T- shirt, stretch pants, and these
white shoes and socks. I didn't have my hood up. We just walked around. Tabby
had her hood up. That is my jacket that I had on, over there. (pointing to a black
leather jacket in the interview room.)
The typewritten statement taken by Corporal Solt, i.e., the "Solt Statement,"
covers five and one-half typed pages. Each of these pages was signed by petitioner
in red felt-tipped pen upon completion of the statement. At the bottom of page six
and extending to page seven, there is hand printed lettering and then cursive
writing which contains an addition to the statement. This information was obtained
by Corporal Solt from Ms. Lambert in response to his question to her about whether
she had anything further to add to the statement. The pages containing the hand
printed and hand written portions are also signed by Ms. Lambert.
Ms. Lambert contends that the hand printed, handwritten portion on the last one
and one-half pages of her original statement are phony. She contends that she
signed blank papers at the time of her interview but that she did not understand
why she was doing that. She contends that Corporal Solt "filled in" these signed
papers with a "statement" which he created.
Petitioner presented expert witness testimony from William J. Ries, a forensic
document examiner. He testified that the recording of a statement from Ms.
Lambert on "plain paper" as opposed to "statement paper" is "unusual and odd."
(N.T., PCRA at 3621.) He opined that a statement should be taken on "formal
statement paper." (Id.) He also opined that the signature of Lisa Michelle Lambert
across the statement is "highly unusual." (N.T., PCRA at 3622-23.) When asked
whether he could tell if Ms. Lambert's signature was placed on the document after
the statement itself, he stated that "the red ink appears to be on top of the black
ballpoint pen writing on page 7 of Miss Lambert's statement." (N.T., PCRA at 3635.)
Mr. Ries is a retired Philadelphia polic e officer with experience in examining
documents. He testified as to the standard practice in Philadelphia, that is, the
taking of a statement on "official statement paper." He could not give any reason
for that practice other than compliance with departme nt procedure and certainly
could offer no opinion as to how the lack of "official statement paper" might affect
the integrity of the contents of the statement. (N.T., PCRA at 3644-45.) Mr. Ries
gave his commentary on Corporal Solt's methods and disapproved of the use of
plain paper in favor of "official statement paper." He disapproved of the practice of
having Ms. Lambert sign the statement across the page and noted that he has
never seen this done.(98) (N.T., PCRA at 3622-23.) Taken to its logical conclusion,
Mr. Ries's opinion would suggest that Corporal Solt should not have taken the
statement because he did not have "official statement paper" available to him. The
fact is that Mr. Ries really had very little to offer this court by way of criticism of the
"Solt Statement." His opinion failed to take into account that Corporal Solt was
taking a statement in the middle of night in a local police station using materials
January January
Sunday
22, 201722, 2017
Page 2075
1073 of 2301
1299
available to him. Mr. Ries's tone of disapproval and his inconsequential criticism of
Corporal Solt's methods were of no help to this court and appeared to be little more
than advocacy dressed in expert's clothing.
Detective Solt testified that he used the paper available to him in the East
Lampeter Township Police Department. The first section of the statement, that is
the five and one-half typed pages, is on bond paper, which he obtained from a
secretary's desk by the typewriter he was using to type her statement. (N.T., PCRA
at 3099, 3122.) Ms. Lambert was then transported to another room of the station
and, at that point, she began to give him additional information. He took the only
available paper, from another desk, which was a different grading of paper, and
began to record what she was saying, first in hand printed lettering and then in
cursive writing. (N.T., PCRA at 3105-06, 3111-12, 3122.) He testified that he
switched from hand printing to cursive because he was writing quickly. (N.T., PCRA
at 3111-12, 3130.) Detective Solt testified at the PCRA hearing that he saw her
sign each page with a red pen after each paper was reviewed. (N.T., PCRA at 3114,
3129-30.)
The Commonwealth presented expert testimony from Lieutenant Joseph
Bonenberger, a document examiner with the Pennsylvania State Police. He offered
his opinion that the signature of Lisa Michelle Lambert is on top of the written and
printed material on the last two pages of her statement. Under microscopic
examination, he determined that wherever the red fibers crossed the other
printing, there was a slight smearing. His conclusion was that the statement was
signed by Ms. Lambert after the writing was placed on the paper. (N.T., PCRA at
7170-71.)
The time at which Ms. Lambert signed the statement also presents an issue in this
case. In Corporal Solt's report, he notes that the statement was completed at 7:51
a.m. and that Ms. Lambert signed the original of the "typed notes of the interview"
at 8:07 a.m. (Petitioner's Exhibit 1016, Corporal Solt's report of December 22,
1991.) These times are confirmed in Corporal Solt's testimony. (N.T., PCRA at
3101, 3118.)
Ms. Lambert points the court to the testimony of Detective Clarence L. Flory, who
transported Ms. Lambert to Community Hospital to have blood drawn. He testified:
Q. What time did you transport Ms. Lambert to Community Hospital?
A. 8:00 a.m. Roughly, 8:00 a.m.
Q. And what time was her blood drawn?
A. Approximately right away, around 8:00 a.m. I just have an approximate time.
(N.T., PCRA at 3715.)
In Detective Flory's report, he notes on the last page: "At approx. 0800 hrs., 21
December 91, this officer transported Lambert to Community Hospital of Lancaster
to obtain a sample of blood. Blood being drawn by Kimberly Felger, R.N. at approx.
January January
Sunday
22, 201722, 2017
Page 2076
1074 of 2301
1299
0800 hrs., 21 December 91." (Petitioner's Exhibit 2065.)

Ms. Lambert's argument is that Corporal Solt presented false testimony about the
time she signed the statement, noting that she was at Community Hospital at the
time Corporal Solt contends the statement was signed.
It appears that the sequence of events here might be more reliable than the
precise times. Corporal Solt testified that the statement was completed at 7:51
a.m. and signed at 8:07 a.m. From his overall testimony and from his practice of
recording specific times, we believe his recollection of the times to be reliable. It
appears that Detective Flory was giving an approximate time, not an exact time. In
fact, every time Detective Flory referred to the time of transport to Community
Hospital, he used the word "approximate." This appears in his testimony and in his
report. He testified that he transported Ms. Lambert at "roughly 8:00 a.m." and
that her blood was drawn "around 8:00 a.m." (N.T., PCRA at 3715.) We know that
one or the other of those events did not take place at exactly 8:00 a.m. The East
Lampeter Township Police Department office is located east of the City of
Lancaster; Community Hospital is located just east of the city line. The time of
transport would be approximately 10 to 15 minutes. Allowing for time to place Ms.
Lambert in a police car, to drive to Community Hospital, to remove her from the
police car and to escort her to the blood lab, it is reasonable to expect that the
process took anywhere from 15 to 20 minutes.
When asked about the sequence of events that morning, without respect to exact
times, Detective Flory testified that he transported Ms. Lambert to Community
Hospital when Ms. Lambert's questioning was finished. (N.T., PCRA at 3715.)
From this testimony, we can conclude that Detective Flory took custody of Ms.
Lambert after her questioning was finished. Could Detective Flory's testimony that
he took her to the hospital at "approximately 8:00 a.m.," "roughly 8:00 a.m.," or
"around 8:00" have meant that he took her after she signed her statement at 8:07
a.m.? That certainly seems reasonable and we believe it is fair to conclude that that
is how this took place. To point to Detective Flory's testimony as precise on the
question of time and to, therefore, leap to the conclusion that Corporal Solt was
falsifying his report is a leap unsupported by the facts or by common sense. It is
clear that the sequence of events that morning had Ms. Lambert finish her
statement, review the statement, sign the statement and then to go to Community
Hospital in the company of Detective Flory.
Petitioner's final claim regarding her "fake statement" is that Corporal Solt
"injected" her in the arm before administering the polygraph examination. This
bizarre and wholly unsupported allegation surfaced at the PCRA hearing. The
"factual basis" for this charge is that Ms. Lambert had a slight bruise on the inside
of her arm upon inspection at the time of her arrest. (N.T., PCRA at 3784-85;
Petitioner's Exhibit 1609.) This slight, unexplained bruise became the marking of a
truth serum injection. Ms. Lambert was quick to adjust her story to accommodate
the "injection." She described how she was hooked up to the polygraph machine
with a number of Velcro straps and that Corporal Solt then injected her with a
needle. (N.T., PCRA at 5297, 5372.)
There is absolutely no support in the record for the allegation that Ms. Lambert was
injected with truth serum. In fact, if she was really injected with "truth serum," why
January January
Sunday
22, 201722, 2017
Page 2077
1075 of 2301
1299
should she complain about what she said under its influence? We dismiss that
charge as incredible.
With respect to the substance of the statement, we note that Ms. Lambert
expressed familiarity with its contents at the 1992 trial. At the PCRA hearing, Ms.
Lambert was reluctant to say that she had even read the statement in 1992.
However, Mr. Shirk noted that he went over the statement with her in detail. (N.T.,
PCRA at 3447-49, 3527-28.) This would be consistent with basic, good practice for
a criminal defense lawyer and Mr. Shirk has demonstrated a high level of skill,
dedication and expertise at a very high level. It would be unbelievable to this court
that Mr. Shirk would not have gone over Ms. Lambert's statement with her in great
detail in preparation for trial. Mr. Shirk is uncertain whether he actually showed her
the statement or whether he had it in front of him and read portions of the
statement to her in preparing her for trial. (Id.) There really would be no significant
difference between these two approaches. The fact is that she was familiar with the
contents of her entire statement before trial. Her own trial counsel established this
fact.
In fact, in 1992, Ms. Lambert was asked about what she told Corporal Solt. This
question was in specific reference to her statement. She was asked, "Everything
Trooper Solt said you said was the truth[?]." And she responded, "Yes." (N.T., Trial
at 1035.)
Further, in a letter written from Ms. Lambert to Mr. Yunkin in the prison on
December 23, 1991, she adopted the information she gave to Corporal Solt in the
statement. (Commonwealth's Exhibit 16.) That is, her letter to Mr. Yunkin sets forth
the same information with respect to her apparel on the day of the murder.
In the handwritten portion of the "Solt Statement," Ms. Lambert states she was
wearing ". . . a red flannel shirt & white socks [ ] & black sweat pants." (Petitioner's
Exhibit 1023 at 7.) She makes further reference to Ms. Buck getting "blood all over
the arm of my flannel shirt." (Id.)
In the December 23, 1991, letter, she uses the same reference to how Ms. Buck
grabbed her arm and "got blood all over my red flannel." (Commonwealth's Exhibit
16 at 2.) Also in the letter, she refers to fleeing with Ms. Buck and meeting up with
her "down at the woods." (Commonwealth's Exhibit 16 at 3.)
Any contention that the handwritten (or printed) portion of the statement was
made up by Corporal Solt after Ms. Lambert signed the statement is clearly
contradicted by her own testimony at trial and her own handwritten letter to Mr.
Yunkin of December 23, 1991.
For PCRA analysis purposes, this issue of the "altered statement" involves neither
prosecutorial misconduct nor after-discovered evidence. There simply is no proof of
either under the elements required by the Act.
To establish prosecutorial misconduct, Ms. Lambert must prove by a preponderance
of the evidence that Detective Solt had her sign blank pages and then completed,
in his own handwriting, a false statement which he then attributed to Ms. Lambert.
On this issue we have Detective Solt's sworn testimony against Ms. Lambert's
January January
Sunday
22, 201722, 2017
Page 2078
1076 of 2301
1299
sworn testimony. Having listened carefully to the testimony of each witness, this
court finds that Detective Solt is far more credible than Ms. Lambert on this issue.
We consider their statements at the PCRA hearing together with all other evidence
in this case both from the 1992 trial and from the balance of the testimony at the
PCRA hearing. For one thing, Ms. Lambert was well aware in 1992 of the contents
of her statement and never in her own testimony or through her lawyers'
arguments made an issue of or raised a question about her statement. Her bald
assertion that the statement was phony against Detective Solt's testimony as to the
steps he took to obtain the statement carries no weight whatsoever. Petitioner's
expert, Mr. Ries, does nothing to establish that the statement was the result of any
prosecutorial misconduct. The Commonwealth's expert, Lieutenant Bonenberger,
offers a reasonable opinion that the signature of Ms. Lambert was placed on the
document after the typed, printed or written portions. This court really does not
require the assistance of the experts on this issue. Given Ms. Lambert's testimony,
Detective Solt's testimony, Ms. Lambert's letter of December 23, 1991, to Mr.
Yunkin, and Ms. Lambert's testimony at trial, we find there to be no basis for a
finding of prosecutorial misconduct on this issue.
With respect to after-discovered evidence, the simple truth is that if the statement
had been altered, the alteration was plainly available to Ms. Lambert at the 1992
trial. She is unable to meet the first prong of the after-discovered test, i.e., that the
evidence was unavailable at trial. The contention that this was an "altered
statement" is without merit under any analysis.
Petitioner contends that Detective Solt is guilty of perjury in his testimony about
the statement. There is certainly no basis for a finding that Detective Solt perjured
himself in testifying about the statement. At best, his testimony is at
odds with Ms. Lambert's testimony.(99) We have already acknowledged that
Detective Solt's testimony is at odds with Ms. Lambert's testimony regarding the
statement. We resolved in 1992, and we resolve again, this credibility issue in favor
of Detective Solt and against Ms. Lambert. This inconsistency between these
witnesses is not perjury as to either Detective Solt or Ms. Lambert.

Ms. Lambert contends that the police altered or fabricated photographs of the crime
scene to (1) show a telephone cord wrapped around the victim's leg, thereby
proving that Ms. Lambert's version of the story of what happened in the
condominium that morning is false, (2) hide bloody footprints in the front hallway
and in Laurie Show's bedroom, and (3) include Tabitha Buck's white sweatshirt in
the crime scene.
A second level of alleged police misconduct regarding the crime scene photographs
concerns the nature of the photographs and the number of photographs taken. Ms.
Lambert contends that photographs of important parts of the crime scene, such as,
fingerprints, blood spatters and the like, were not taken. In the alternative, she
argues that such photographs were taken but were destroyed.
January January
Sunday
22, 201722, 2017
Page 2079
1077 of 2301
1299

A series of crime scene photographs show a telephone cord wrapped around the leg
of Laurie Show. Laurie's body was positioned in her bedroom and a number of
photographs show the cord connecting a handset to the base of the telephone
wrapped once around her leg down near the ankle. Why is this of significance?
First, because the diagrams prepared by Officer Weaver do not show the telephone
cord wrapped around the leg of the victim. In fact, they show the telephone close
to her leg but not touching it. Second, Ms. Lambert testified at trial that Ms. Buck
grabbed the telephone from Laurie Show's hand and threw it across the room. If
Ms. Lambert was telling the truth, then the telephone would be somewhere away
from Laurie Show's body. If Ms. Lambert was not telling the truth, then the
telephone might, presumably, be near Laurie Show's body. In essence, petitioner
believes that the police wrapped the telephone cord around the leg of the victim in
an intentional act to discredit her story. Ms. Lambert attempts to discredit the
crime scene photographs by pointing to the crime scene diagram prepared by
Officer Weaver.
Officer Weaver testified that he did not prepare the diagram to scale, that there
were literally hundreds of items in the bedroom and that he did not record the
location or the description of each and every item. (N.T., PCRA at 1710.) The
telephone was placed in the diagram after the body was removed from the
bedroom. (N.T., PCRA at 1783.) In fact, he was preparing these diagrams
essentially to show the position of the body and the major articles of furniture in
the bedroom. (N.T., PCRA at 1710.) This was the first homicide investigation in
which he had been involved and the first crime scene he had drawn. (N.T., PCRA at
1777.) In his testimony he did not seem to attach much, if any, significance to the
precise location of these various objects. (N.T., Trial at 34; N.T., PCRA at 1784-86.)
Petitioner questioned almost every witness who was present in the crime scene that
morning as to the location of the telephone cord. No one was able to specifically
recall whether the telephone cord was, in fact, wrapped around the leg of Laurie
Show. Petitioner takes this wholesale lack of recollection about a detail of
questionable relevance and parlays it into an affirmative statement that the
telephone cord was not wrapped around the leg of the victim.
This analysis requires two substantial leaps: (1) a leap from the failure of any
witness to recall the telephone cord around the leg to the c onclusion that the cord
was not around the leg; and (2) a leap from that conclusion to the conclusion that
the police found it necessary to go back into the condominium, lay the body out on
the floor, wrap the telephone cord around the leg and then take a series of
photographs. These photographs would show that Ms. Lambert was lying when she
gave her statement about Ms. Buck throwing the telephone across the room.
Followed to its logical end, what possible reason would the police have to discredit
Ms. Lambert's statement that Ms. Buck threw the telephone across the room?
Certainly, they were not interested in ruling out evidence of Ms. Buck's
involvement. Certainly, Ms. Buck's throwing the telephone across the room and the
location of the cord around Laurie Show's leg are not mutually exclusive. It appears
that the telephone was close to the entrance of the bedroom, by the bed, when
Laurie picked it up. If Ms. Buck threw it across the relatively small bedroom, it
could easily have landed near the closet where Laurie's body came to rest. With the
January January
Sunday
22, 201722, 2017
Page 2080
1078 of 2301
1299
base separated from the handset, the apparatus could have extended across the
floor on the opposite, i.e., window, side of the room. With respect to wrapping the
cord around the leg, Laurie's body could have come to rest on top of the cord and
the telephone could have been moved as the several medical and police personnel
tended to Laurie or processed the crime scene.
This allegation of misconduct assumes that the police took every detail of Ms.
Lambert's statement in the early hours of December 21, 1991, and sought to
orchestrate the items of physical evidence available to them, in this case, the
photographs, to discredit that statement. This just does not make any sense. In so
"discrediting" Ms. Lambert's statement, the police would have been compromising
evidence of Ms. Buck's involvement. The police have never, under any
circumstances or under any interpretation of the evidence, sought to diminish Ms.
Buck's involvement. In fact, the Commonwealth pursued a first degree murder
prosecution against Ms. Buck resulting in a jury verdict of second degree murder in
September 1992.
As to the issue of after-discovered evidence, the crime scene photographs were
certainly available to Mr. Shirk in 1992. The crime scene drawings prepared by
Officer Weaver were available as well. In fact, Officer Weaver took the stand in
1992 and was cross-examined by Mr. Shirk. If any discrepancy between the
photographs and the drawing were of any importance to the Lambert defense effort
in 1992, they would have been raised at that time. This is certainly not evidence
which was unavailable at the time of trial. The only thing "unavailable" at the time
of trial was the unfounded suspicion that there is something untoward about these
photographs due to the fact that they are not entirely consistent with the crime
scene drawings.
With respect to "prosecutorial misconduct," petitioner has established nothing by
way of facts or evidence to show that these photographs were somehow fabricated
or changed. Under the analysis required in a PCRA proceeding, nothing about these
photographs undermined the truth-determining process or would have changed the
outcome of the trial.
2. Footprints in the hallway and bedroom
Petitioner presented the testimony of a representative of Compleat Restorations.
Compleat Restorations was called to the scene on December 23, 1991, to clean the
condominium at the request of Mrs. Show's insurance company. Compleat
Restorations took some photographs, one of which shows a reddish smudge or
mark on the floor in the tile entranceway. This mark could be interpreted to be a
footprint. This is now presented by petitioner as proof that the testimony in 1992
that there was no blood in the hallway or any footprints in the hallway was false,
fabricated and perjured.
The fact that a Compleat Restorations photograph shows a smudge in the
entranceway which could be viewed as a footprint establishes nothing. Compleat
Restorations came into the condominium three days after the murder. In that time,
literally dozens of persons were in and out of the home. Testimony was that the
blood on the carpet on Laurie's bedroom had soaked through to the point where it
had stained the concrete underneath. There were copious amounts of blood all over
the bedroom. Anyone going in and out of that room could well have tracked blood
January January
Sunday
22, 201722, 2017
Page 2081
1079 of 2301
1299
out through the hallway. To say that a smudge on the floor which looks like a
footprint had to be the footprint of the murderer (and no one else) and was,
therefore, hidden by the police is just not true. The Compleat Restorations'
photographs do show markings on the floor which could be interpreted to be bloody
shoe prints. This does not establish that the shoe prints were placed there by the
killer.
Officer Weaver testified at trial that there was a bloody footprint in the hallway and
that he believed that it was made by medical personnel. (N.T., Trial at 38, 49-50,
54-55.) He also testified that he saw no distinct footprints in the bedroom. (N.T.,
Trial at 53-54.) Pennsylvania State Polic e Trooper Anthony Suber testified credibly
about this at the PCRA hearing, as well. (N.T., P.C.R.A. at 6539-40, 6545.)
Perhaps petitioner and her counsel disagree with the police assessment on the
morning of December 20, 1991, about the relevance or the importance of the
footprints in the bedroom. That issue was available to petitioner and her defense
counsel at trial and, in fact, there was a significant amount of discussion and
argument over footprints at the scene. Nothing about the case has changed since
that time.
Finally, Trooper Suber, who took the photographs at the crime scene, took a
videotape of the interior and the exterior of the condominium at the conclusion of
his work. By that time most of the investigative personnel had cleared out of the
condominium, Laurie Show's body had been taken to the morgue, and the
investigation was largely completed. He photographed, by way of a video camera,
the entire interior of the Show condominium before he left that morning. The video
shows some markings on the tile floor which could well have been consistent with a
significant amount of traffic in and out of the condominium that morning. This video
was taken prior to the photographs taken by Compleat Restorations. There are
blood spatters and markings on the wall just inside the doorway with corresponding
spots, presumably blood, on the floor just underneath. Trooper Suber carefully
recorded these on the videotape. That tape was available to trial counsel and was
shown at the trial.
The photographs of the front hallway are very important to petitioner's theory of
this case. In the story she told at trial, she attempted to rescue Laurie Show by
grabbing her by the wrists and dragging her from the bedroom to the hallway. At
that point, Laurie Show had been stabbed in the back and, presumably, would have
been bleeding profusely.(100) Yet, the crime scene photographs show very little
blood in the front hallway. This led Mr. Kenneff to pose the question in his closing
argument: "Where is the blood?" (N.T., Trial at 1283.) Mr. Kenneff was referring to
the crime scene photographs and pointing out that the physical evidence did not
support Ms. Lambert's story that she became Laurie Show's "rescuer" that morning.
Ms. Lambert's response to this is that the police altered or fabricated photographs
to dispute her story.(101) She contends: (1) that the hallway was cleaned up before
the photographs were taken; or (2) a rug was moved so as to hide bloody
footprints while the photographs were taken; or (3) the photographs were
"cropped" so as to cut out bloody footprints.
In reality, several of the photographs of the hallway show an Oriental type throw
rug which is positioned in somewhat of an angle. A careful inspection of several of
January January
Sunday
22, 201722, 2017
Page 2082
1080 of 2301
1299
these photographs shows a reddish smudge near the doorway, which could
certainly be a mark made by a shoe which had tracked across blood. One of these
photographs shows a figure standing outside the condominium door, who was later
identified as Reverend Samuel Knupp. Reverend Knupp testified that he was
present at the condominium that morning and had been summoned there to assist
Mrs. Show. (N.T., PCRA at 5939, 5941-43.) This would establish that the
photograph of the hallway was taken that morning and not later that night or the
next day as petitioner suggests. In any event, on certain of the photographs, a
reddish smudge is visible. The fact that the carpet may have been moved to cover
a portion of the smudge does not suggest a sinister cover up. Rather, it suggests
that the throw rug was easily moved and shifted to different positions as people
moved in and out of the condominium that day.
With respect to the "cropping" of photographs, Trooper Suber testified that certain
machines which print photographs from negatives will sometimes cut the print at
an inappropriate point. (N.T., PCRA at 6525-26.) This could easily have been done
in the many copies made of the many photographs which are now in the record of
this case. It is important to note that there are "non- cropped" photographs of the
same door, hallway and portion of the wall showing a full view.
Petitioner argues that the photographs show a blood spatter on the wall and at
least one bloody footprint in the hallway. She contends that this establishes that
Mr. Kenneff's "where's the blood?" argument was false and misleading. The
photograph of the wall showing the blood spatter just inside the front door of the
condominium was carefully reviewed at trial. The photographs of the entranceway
to the condominium were available for all to see at trial. Mr. Kenneff's argument
that there is no physical evidence to support Ms. Lambert' s story was absolutely
correct. The fact that there is a bloody footprint and a blood spatter on the wall
does not support her contention that she dragged the mortally wounded and
bleeding Laurie Show by the wrists into the hallway. Judging from the amount of
blood on the carpet in the bedroom, it is logical to conclude that were Ms.
Lambert's story to be true, there would be copious amounts of blood in the hallway.
The court understood Mr. Kenneff's argument to be a reference to a lack of
significant blood in the hallway. The fact that there was a blood spatter and a
footprint or two does not render the "where's the blood?" argument false or
misleading.
3. The white sweatshirt
Petitioner presented evidence that Ms. Buck wore a white sweatshirt on the
morning of the murder. She also presented testimony that Ms. Buck appeared at
Penn Manor High School after the murder wearing a white or off-white sweatshirt
turned inside out. Petitioner points to the white sweatshirt in the crime scene
photographs and argues that this is Ms. Buck's sweatshirt, placed there by the
police.
The problem is that there is no testimony which would establish that the police had
Ms. Buck's sweatshirt or that the police had access to Ms. Buck's sweatshirt while
the crime scene photographs were taken or when they were allegedly fabricated in
the early morning hours of December 21, 1991. The bald assertion that the white
sweatshirt lying near or next to Laurie Show's body in certain crime scene
January January
Sunday
22, 201722, 2017
Page 2083
1081 of 2301
1299
photographs is Ms. Buck's sweatshirt is without any foundation in the evidence.

Ms. Lambert contends that photographs of the crime scene are missing or they
were destroyed. She bases this argument on essentially two grounds: (1) the
testimony of Stephen Hale; and (2) by inference from the fact that the photographs
produced to her counsel during the federal proceeding were not produced all at one
time, in logical sequence, accompanied by a printed log.
Mr. Hale is a retired polic e officer from rural Ohio who has experience in
investigating crime scenes. He has taken photographs of crime scenes. He offered
his opinion that had he photographed the crime scene at the Show condominium on
December 20, 1991, he would have taken more pic tures. Ms. Rainville, as counsel
for Ms. Lambert, argues from this "opinion" that some pictures must, therefore, be
missing. That is, because the Commonwealth did not produce in federal discovery
the number and type of photographs Mr. Hale would have taken, the
Commonwealth must, therefore, be hiding something. All Mr. Hale was able to
establish at the PCRA hearing was that the police officers taking the crime scene
photographs were "incompetent" in his view. But this is not a case about
incompetent photographers or negligence on the part of an investigating police
department. This is a case where the court is evaluating claims of after-discovered
evidence, prosecutorial misconduct and ineffective assistance of counsel. The fact
that Mr. Hale, or his "ordinary competent crime scene photographer," might have
done more than Trooper Suber and Pennsylvania State Police Trooper Joseph C.
Reeves did is of little or no consequence to this case. Perhaps rather than four rolls
of film, they should have taken ten rolls of film. That argument invites nothing
more than speculation and leads nowhere. The fact is there were ample
photographs taken for the Commonwealth, the defense and the court to understand
the nature of the crime scene at the 1992 trial. No issue was raised as to the
photographs at that time.
With respect to the "destruction" of photographs, Detective Geesey testified that he
took steps to verify that the District Attorney's Office had all the Pennsylvania State
Police photographs prior to turning them over to petitioner's counsel in 1997. (N.T.,
PCRA at 3900.) Lieutenant Renee Schuler was asked to obtain photographs from
East Lampeter. Photographs from the District Attorney's files were also obtained. It
appears that the photographs were produced in stages to petitioner's counsel in
Philadelphia pursuant to the district court's order. The photographs were not
produced all at one time, in an orderly fashion. This appears entirely reasonable
given the fact that the various crime scene photographs had been used in two
preliminary hearings and two homicide trials more than five years before the
federal discovery order. It was established at the PCRA hearing that there was no
set procedure or protocol for the storage of photographs. It appears likely that
some were in the District Attorney's files, certain photographs were with the
Pennsylvania State Police and others may have been at East Lampeter Township.
The record makes clear that reasonable and good faith efforts were made to locate
all available photographs.
The "destruction of photographs" claim basically arose in the discovery phase to the
federal habeas proceeding. A number of witnesses testified in the PCRA hearing as
to the manner in which the Lancaster County District Attorney's Office produced
January January
Sunday
22, 201722, 2017
Page 2084
1082 of 2301
1299
photographs to petitioner's counsel in Philadelphia. Several witnesses testified to

the so-called "Christmas Eve production" where a series of photographs arrived in
the offices of Schnader Harrison Segal & Lewis, counsel for petitioner, on December
24, 1996. It appears from all accounts that photographs were received from the
Lancaster County District Attorney's Office in several stages. This manner of
complying with the discovery directives of the district court, combined with the fact
that the State Police did not take the hundreds of photographs Mr. Hale would have
taken, has led to petitioner's conclusion that photographs were hidden or destroyed
rather than disclosed to her counsel in Philadelphia prior to the habeas hearing. As
we discussed above, it appears more likely that the production of photographs was
accomplished in stages because the photographs were located in several different
places.
As an ironic commentary on this issue, petitioner's counsel found themselves poorly
organized and frustrated when it came time to organize their photographs to move
their admission into evidence during the PCRA hearing. On June 9, 1998, during the
questioning of District Attorney Madenspacher, counsel for petitioner attempted to
have certain photographs shown to the witness. There was confusion as to the
numbering and location of the exhibits despite the fact that the court had dedicated
a secure area adjacent to the courtroom for the storage of evidence. In addition,
counsel for petitioner had at least two paralegals at all times assisting the two
attorneys trying this case. Nevertheless, when attempting to organize and present
certain photographs, counsel for petitioner were unable to locate the exhibits.
There were several breaks taken during the afternoon session for the purpose of
locating these photographs. Christy Fawcett, Esquire, counsel for the
Commonwealth, made the following statement for the record:
I would like to place on the record that we have now spent approximately 15 to 20
minutes attempting to straighten out exhibits that were previously marked by the
petitioner.
And in addition we also spent some time during Mr. Madenspacher's testimony
attempting to clarify some of those issues. In addition to what has been today,
there was a period at the beginning of the case, and this frankly may or may not be
on the record, I don't recall, but where there was several hours spent trying to
clear up mismarking of exhibits.
And my purpose for requesting that this be placed on the record is not to indicate
in anyway that I think anybody was deliberately trying to rearrange or cause
problems with the exhibits, but I think it is instructive and illustrative of the
problems that occur when there are large numbers of photographs and other
exhibits that - and other items of evidence that are being given into discovery, for
instance, being attempted to locate, subsequent to a trial, to give to counsel and so
forth.
And I think it's an illustration of how mistakes sometimes happen that are nobody's
fault. They're simply honest mistakes and I think that's occurred here and, as I
argue to the court later on, that could've been easily what occurred at later points
in this case.
(N.T., PCRA at 5806-07.)
January January
Sunday
22, 201722, 2017
Page 2085
1083 of 2301
1299
In essence, petitioner's counsel could not locate photographs that had previously
been marked, were somewhere in the courtroom or in the evidence room, and
which they wished to show to a witness. The court quite agrees with counsel's
statement that the organization, management and retrieval of large numbers of
exhibits, photographs or otherwise, can be very difficult.(102) The PCRA hearing was
a clinic on this subject. It is not at all hard for this court to believe that the District
Attorney's Office, East Lampeter Township and the Pennsylvania State Police might
have had difficulty locating and producing all photographs of the crime scene in one
complete and well-orchestrated production. Human nature and the litigation
process being what they are, it is completely understandable how these
photographs could have been produced in 1996 and 1997 in several stages without
any sinister significance. There simply is no proof of any prosecutorial misconduct,
destruction of evidence or fabrication of evidence arising out of these facts with the
crime scene photographs.
In early to mid-January 1992, Dean Haas, Hazel Show's nephew, was helping clean
the Show condominium. He found a pearl earring on the tile floor just inside the
front door up against a baseboard. Mrs. Show turned this earring over to Corporal
Renee Schuler and told her she did not recognize the earring as her daughter's.
Corporal Renee Schuler turned the earring over to Detective Savage who prepared
a report dated February 7, 1992. The report notes that the earring was shown to
Mr. Yunkin:
On 02-07-92, this officer showed the pearl stud earring to Lawrence Yunkin. At that
time, Yunkin stated that he is sure that Michelle Lambert did, in fact, own a set of
earrings exactly like the earring that this officer presented to him. Yunkin stated he
does not recall when Michelle may have worn said earrings, did not recall if she had
this type of earring on the morning of 12-20-91 and did not recall Tabatha Buck
having earrings on on 12-20-91. Yunkin stated that other than remembering that
Lambert had earrings exactly like these, he could provide no other information as
to where they were at this time when she wore them or any other information.
Petitioner's contends that there is misconduct associated with this pearl earring.
Specifically, she claims that the report of Detective Savage, (Petitioner's Exhibit
1190), was a "deliberate falsification of evidence" because Mr. Yunkin had told the
police on February 5, 1992, that he sometimes wore the earring. Petitioner is
actually referring to the testimony of Detective Barley from the PCRA hearing.
Detective Barley testified that Mr. Yunkin told him he wore "an earring." (N.T.,
PCRA at 677.) Mr. Yunkin never acknowledged to Detective Barley that he wore
that specific pearl earring. The most Mr. Yunkin said was that on occasion he wore
an earring similar to that one but did not state or admit that he wore that earring
at any time.
Whether or not Mr. Yunkin acknowledged that he wore the pearl earring found in
the Show condominium, there is no proof whatsoever of destruction of evidence,
after-discovered evidence, prosecutorial misconduct or any other untoward
behavior regarding the pearl earring. In fact, Ms. Lambert' s defense counsel at
trial emphasized the earring and suggested very strongly that Mr. Yunkin wore that
January January
Sunday
22, 201722, 2017
Page 2086
1084 of 2301
1299
earring that morning. Roy Shirk had available to him Mr. Yunkin's printed
statement, a 19-page document, which was marked in the PCRA hearing as
Petitioner's Exhibit 1661. Mr. Shirk was aware that the earring had been found in
the condominium, was aware that Mr. Yunkin wore earrings, and worked very hard
to find someone who could say that Mr. Yunkin wore that pearl earring. In the PCRA
hearing, Mr. Shirk testified that Richard Jeffries "went to great lengths . . . to find
people who had seen Mr. Yunkin wearing that earring." (N.T., PCRA at 3388.) Ms.
Lambert had told Mr. Shirk that Mr. Yunkin wore that specific earring.
Assuming the complete truth of all of petitioner's allegations regarding misconduct
as to the earring, they come to nothing. Mr. Shirk believed that Mr. Yunkin wore
the earring, searched for witnesses to support this, and cross- examined Mr. Yunkin
on whether he wore the earring. He could have done nothing more with the earring
at trial.
Mr. Shirk cross-examined Mr. Yunkin about the pearl earring in a thorough and
forceful way. It was obvious to the court that Mr. Shirk was prepared on this issue
and he, in fact, established that the earring was one that Mr. Yunkin had worn on
occasion or similar to one that Mr. Yunkin had worn on occasion. Mr. Shirk showed
Mr. Yunkin a photograph of the pearl earring at trial and asked him if he been
shown that by the police. Mr. Yunkin testified that he did talk about the earring
with the police and said, "I said it looks like an earring that Michelle owns." (N.T.,
Trial at 258.) Mr. Shirk then asked him:
Q. But who wore them?
A. I wore -- About three times I wore one.
Q. You wore the pearl earrings?
A. One,, yes.
(N.T., Trial at 258-59.)
Mr. Yunkin went on to tell Mr. Shirk at trial that he had told the police he wore the
earring. Mr. Shirk then argued to the court that the police intentionally left out a
reference to Mr. Yunkin's wearing the earring in the report they filed. He also
accused the police of leaving that information out of Mr. Yunkin's statement. In
fact, Mr. Yunkin was not certain that he told the police about the earring in giving
his statement. He was sure that he told Corporal Solt about the earring in his
meeting with Corporal Solt just prior to trial. (N.T., Trial at 259.)
Mr. Shirk moved for a mistrial on the basis of the Commonwealth's failing to
disclose to him that Mr. Yunkin wore the pearl earring. Mr. Shirk argued that the
defense was not notified that Mr. Yunkin wore a pearl earring like that and
contended "it was kept out of his statement." (N.T., Trial at 1181.) Mr. Kenneff
noted to the court that he found out that Mr. Yunkin wore the pearl earring from
Mr. Shirk. (N.T., Trial at 1197.) The court found there to be no prejudice and no
evidence that the information was "kept out of the statement" or withheld from the
defense. Mr. Shirk made every good use of the information about the pearl earring
in cross-examining Mr. Yunkin. Under cross-examination by Mr. Shirk, Mr. Yunkin
January January
Sunday
22, 201722, 2017
Page 2087
1085 of 2301
1299
admitted that he wore a pearl earring. That appears to the court to be the most use
Mr. Shirk could have made of the earring at trial.
The earring itself was apparently a generic pearl-like earring, as described by a
number of witnesses. There was nothing distinctive about the earring. In fact, the
earring could have come from Mr. Yunkin, from Ms. Lambert or from Ms. Buck. We
ruled out the fact that it may have come from Laurie Show because her mother
stated early on in the investigation that her daughter did not own an earring like
that. The fact that Mr. Yunkin wore earrings and the fact that the earring was of a
generic type does not establish what petitioner wants to establish: that Mr. Yunkin
wore that earring in the condominium that morning and that it fell out while he was
murdering Laurie Show. There simply is no factual basis for this finding nor is there
enough of a basis to draw any inference in petitioner's favor on this point.
O. Ro bert Reed's Testimony
Robert S. Reed was called as a witness by petitioner. Mr. Reed is a former East
Lampeter Township police officer who participated to some extent in the
investigation of this case. Mr. Reed was called as a witness in the PCRA hearing on
May 11, 1998. Two days before that, he had been convicted of several felonies
involving sexual assaults on a minor. At least two of these charges carried with
them mandatory minimum sentences of five years each.
When Mr. Reed came into the courtroom, he stated his name and then indicated
that he did not wish to answer questions. He was given an opportunity during a
recess to consult with his attorney and then returned to the witness stand. At that
time, the following colloquy occurred:
THE COURT: Mr. Reed, you indicated a few moments ago that you did not wish to
answer any questions until you had a chance to speak with your attorney. Is that
correct?
THE WITNESS: That's correct, your Honor.
THE COURT: All right. Have you had a chance now to speak with your attorney?
THE WITNESS: Yes, I did, your Honor.
THE COURT: All right. And is that Attorney Robert Reese?
THE WITNESS: That's correct.
THE COURT: Having spoken with Mr. Reese, do you wish to answer questions at
this time?
THE WITNESS: No, I do not.
THE COURT: And why is that, Mr. Reed?
THE WITNESS: At this time I'd just like to reserve that for a later time, your Honor.
January January
Sunday
22, 201722, 2017
Page 2088
1086 of 2301
1299
I have no explanation at this time. I just don't want to answer any questions.
THE COURT: Okay. Mr. Reed, is your refusal to answer any questions today
motivated in any way by a concern against self incrimination?
THE WITNESS: No, your Honor.
(N.T., PCRA at 1539-40.)
At that point, a conference was held at sidebar with counsel. Counsel discussed
with the court whether there was a legitimate Fifth Amendment privilege which
could be invoked by Mr. Reed. The court then explained to Mr. Reed that if he
refused to answer a question, the court could direct him to answer and his failure
to comply could result in a contempt citation. The court further advised him that if
it was a matter of self incrimination, he could invoke his rights under the Fifth
Amendment of the United State Constitution and, if satisfied that there was a basis
on which to invoke the privilege, we would not direct him to answer the question.
Our research on this issue during the trial disclosed that a witness's right to invoke
the Fifth Amendment extends to potential criminal liability that is collateral or
remote. This court was aware that Officer Reed was one of the police officers whose
conduct was condemned by the federal district court in 1997 and who was referred
to the United States Attorney's Office for investigation. This court has no idea as to
the status or progress of any such investigation. However, the fact remained on
May 11, 1998, that there was a potential open investigation in the United States
Attorney's Office in the Eastern District of Pennsylvania and that answers to any
questions put to Mr. Reed during the PCRA hearing could have bearing on his
culpability on any charges or allegations being investigated by the United States
Attorney. This court honestly believed that the privilege would apply even if the
possibility of investigation, charges or conviction in federal court was remote.(103)
<, P>The court then gave permission to petitioner's counsel to question Mr. Reed.
In response to a series of questions, he asserted his privilege under the Fifth
Amendment and refused to answer. It became clear that he was asserting this
privilege as to every question. For example, he responded to a question as to his
employment status by invoking the Fifth Amendment privilege:
Q. Mr. Reed, where were you employed in 1991?
A. I'm refusing to answer that under the Fifth Amendment.
(N.T., PCRA at 1544-45.)
We ruled that it was proper for Mr. Reed to invoke the Fifth Amendment privilege in
light of the allegations made in the federal proceeding. The question remains for
our purposes, what is the remedy? Petitioner's counsel argue that we should draw
an adverse inference to his assertion of the Fifth Amendment privilege on each
question. The Commonwealth contends that Mr. Reed should be considered
"unavailable" and that his testimony in the federal proceeding should be used as his
January January
Sunday
22, 201722, 2017
Page 2089
1087 of 2301
1299
testimony in this proceeding.

Generally, the fact finder may not draw an inference from a witness's exercise of
his constitutional right not to incriminate himself regardless of whether the
inference is favorable to the prosecution or the defense. Commonwealth v.
Greene, 445 Pa. 228, 231, 285 A.2d 865, 867 (1971). In this case, the initial
colloquy with Mr. Reed disclosed that he was not so much concerned about self
incrimination as he was simply unwilling to participate in the hearing. Given his
apparent state of mind following the conviction on the sex offenses, this was
understandable. With the explanation given to him as to his options in answering
questions, it appears that Mr. Reed used the Fifth Ame ndment privilege against self
incrimination as a "ticket" to not answer any questions. He appeared hostile to the
proceedings and, at one point, refused to look at the river search videotape which
was played directly in front of him and about which he was asked some questions.
The court noted for the record that Mr. Reed did not look at the television screen
for the entire eight minutes it took to play the video. (N.T., PCRA at 1554.) It
appears that Mr. Reed may well have been angry with himself or at the world. In
any, case, this led to a, wholesale lack , of cooperation with counsel's questions.
Given the circumstances and in light of Greene, it seems appropriate to consider
Mr. Reed "unavailable." We have, therefore, considered his testimony from the
federal proceeding, which was presented on Monday, April 14, 1997, the tenth day
of the habeas corpus hearing. (N.T., Habeas Hearing at 2184-2228.)
On June 10, 1998, counsel for petitioner submitted a document entitled "Petitioner
Lisa Lambert's List of Admissions to be Offered into Evidence." The document
contains a long listing of page references from the transcript of the federal habeas
proceeding involving the testimony of Detective Solt, former Detective Barley,
Officer Bowman, Mr. Kenneff, former Chief Jacob A. Glick, District Justice Savage,
Lieutenant Renee Schuler and Officer Weaver. Each of these witnesses was called
by petitioner at the PCRA hearing. The proposed admissions refer to substantial
portions of the deposition and federal court testimony of these witnesses. They are
offered in this proceeding as "admissions" by these witnesses. We addressed the
proposed use of petitioner's federal habeas corpus record in this proceeding in an
opinion filed April 6, 1998. See Commonwealth v. Lambert, 76 Lanc. L. Rev. 169
(1998). In that opinion, we considered the various arguments in favor of the
request that we accept the federal habeas record as the evidentiary record for the
PCRA. We ruled at that time that there is no basis in law or in common sense for so
doing. With respect to the federal habeas record, we noted:
This is not to say that the record produced in April 1997 in federal court cannot be
put to any use in this proceeding. As all parties have agreed, the record contains
testimony under oath and may be used in the same way prior testimony under oath
can be used in any proceeding. The court would prefer not to decide this case on a
series of admissions extracted from depositions and from the federal record. The
court is aware that Rule 1507, 'Disposition Without Hearing,' provides for the
disposition of a petition without a hearing when the petition and answer show that
there is no genuine issue concerning any material fact. Pa. R. Crim. P. 1506(b). The
court does not view this Rule as an invitation to the parties to submit this case in a
posture similar to a motion for summary judgment under Rules 1035.1 through
January January
Sunday
22, 201722, 2017
Page 2090
1088 of 2301
1299
1035.5 of the Rules of Civil Procedure.

76 Lanc. L. Rev. at 182.
Our position has not changed since that time. In fact, counsel for petitioner put the
federal habeas record to good use during the PCRA proceeding. The record was
used to impeach witnesses, to refresh the recollection of witnesses and, in the case
of Officer Reed, to provide testimony where a witness has become "unavailable" for
the PCRA hearing. The wholesale use of testimony from the federal proceeding and
the ensuing necessary argument as to whether certain statements constitute
admissions under the law was precisely what we hoped to avoid in holding a PCRA
hearing. Now, after a lengthy hearing, we believe the request that we consider
statements from the federal proceeding as "admissions" is superfluous. We,
therefore, deny the request that the proposed admissions contained in petitioner's
pleading be used as evidence in this case.
The elements of a PCRA ineffective assistance of counsel claim are discussed in
Section III.B.1.b, supra, of this opinion. As to each allegatio n of ineffective
assistance, Ms. Lambert must show: (1) there is merit to the underlying claim; (2)
counsel had no reasonable basis for his course of conduct; and (3) that there is a
reasonable probability that but for the act or omission in question, the outcome of
the proceeding would have been different. There are 22 allegations of ineffective
assistance of counsel regarding Mr. Shirk in petitioner's second amended petition.
(Exhibit A, Section C.) We will address those allegations in this section.
1. Failing to push for discovery

Mr. Shirk, Ms. Lambert's trial counsel, did, in fact, request discovery. He requested
and "pushed for" all information to which he was entitled under Pa. R. Crim. P. 305.
In fact, Mr. Shirk requested a conference with the court on discovery and presented
his concerns before trial.
Petitioner criticizes Mr. Shirk for failing to obtain the level of discovery she achieved
in the federal habeas proceeding. The simple answer to that is the Rules of Criminal
Procedure in Pennsylvania do not provide for that kind of discovery. In the federal
proceeding, petitioner's counsel took in excess of 50 depositions and caused the
production of attorney work product from the prosecuting attorney. The level of
discovery permitted by the district court far exceeded the scope of discovery under
the Pennsylvania Rules of Criminal Procedure. This court is satisfied that Mr. Shirk
made a request for all materials discoverable under Pa. R. Crim. P. 305 and Brady.
2. Failing to call character witnesses
This issue has been previously litigated. This court considered the claim raised by
Mr. Epstein on behalf of Ms. Lambert. See Commonwealth v. Lambert, March 14,
1995, slip op. at 6-24. No additional evidence was offered on this issue at the PCRA
hearing.
January January
Sunday
22, 201722, 2017
Page 2091
1089 of 2301
1299
3. Failing to use an expert in speech

Mr. Shirk retained a well known forensic pathologist, Dr. Mihalakis, to testify on the
issue of speech in this case. Dr. Mihalakis prepared a report for Mr. Shirk in which
he discussed the possibilities of speech for Laurie Show.
The "underlying claim" here is that a speech expert would have established that
Laurie Show could not have spoken to her mother. This is a claim of questionable
merit. As we have seen from the lengthy testimony at the PCRA hearing, this is an
area on which experts sharply disagree. We have had the opportunity to consider
the testimony of Dr. Larson in this case. We find that there is no reasonable
probability that the outcome of the proceeding would have been different had Mr.
Shirk called Dr. Larson or an expert in Dr. Larson's
field to testify at the trial. For a more complete discussion of the impact of expert
testimony on the issue of Laurie Show's dying declaration, see Section VII.A, supra.
4. Failing to use an expert on abuse and rape trauma
Mr. Shirk cannot be ineffective for failing to call an expert on a subject that is not
relevant under Pennsylvania law. Had Mr. Shirk presented Dr. Burgess or a similar
expert at trial, she/he would not have been permitted to testify. See discussion of
this issue in Section VII.C, supra.
5. Failing to use an expert in pathology
In fact, Mr. Shirk did use an expert in pathology. Dr. Mihalakis was unable to
determine whether the major vessels in Laurie Show's neck were cut. As we have
seen, Dr. Penades, who performed the autopsy, and Dr. Annese, a throat surgeon
who attended the autopsy, testified that the major vessels were not cut.
Specifically, petitioner is referring to the carotid artery. Drs. Baden and Smialek,
world renowned forensic pathologists called by petitioner at the PCRA hearing,
could not offer an opinion as to whether the carotid artery was cut. All the
information made available to them would have been available to a pathologist
retained by Mr. Shirk at the time of trial. Drs. Burton and Ross offered opinions
based upon the autopsy photographs and the autopsy report that the carotid was
not cut.
We find that no expert, EMT or board certified forensic pathologist, could have
countered the clear and unequivocal testimony of Drs. Penades and Annese that
the carotid artery was intact.
6. Failing to use an expert in crime scene photography
Petitioner contends that her expert in crime scene photography, Stephen Hale, has
demonstrated that the prosecution has destroyed evidence. We have not been able
to make that finding based upon the testimony of Stephen Hale. Mr. Hale basically
testified that he would have done a better job than Troopers Suber and Reeves.
That does not establish that the state police or the East Lampeter Township police
destroyed evidence. There is no merit to this claim.
January January
Sunday
22, 201722, 2017
Page 2092
1090 of 2301
1299
7. Failing to use an expert in document authenticity

This is an interesting claim in light of William Ries's testimony that he could not
determine whether Ms. Lambert's statement was altered or fabricated. Mr. Ries was
the document expert called by petitioner in this PCRA hearing. Upon examination of
the five and one-half typewritten pages and the one and one-half handwritten
pages, Mr. Ries could not say whether Ms. Lambert's signature was placed on the
statement before or after the statement was prepared.
The wild assertion that Ms. Lambert's statement was fabricated is simply contrary
to the evidence. We discussed this issue in Section VII.L, supra. In light of Ms.
Lambert's testimony at trial that her statement contains that which she told
Corporal Solt, in light of Mr. Shirk's testimony at the PCRA hearing that he went
over the statement with her very carefully and in light of her letter of December 23,
1991, where she adopts the portion of the statement which is handwritten, an
attack on the authenticity of her statement at trial would have been a peculiar
move indeed for Mr. Shirk.
8. Failing to give Ms. Lambert her statement to review
There is no merit to this claim. See Section VII.L, supra.
9. Failing to attack Detective Barley about the pink bag
Mr. Shirk viewed the edited river search video, which shows a pink bag embedded
in ice. He was present for Detective Barley's testimony at trial that the police did
not find the trash bag. Mr. Shirk did not confront Detective Barley about this
inconsistency. There are three possible explanations for this: (1) Mr. Shirk did not
make the connection and missed an opportunity to impeach Detective Barley; (2)
Mr. Shirk did not find there to be anything of evidentiary value about the pink trash
bag; or (3) Mr. Shirk was aware that a bag was found but chose not to highlight
this issue as it was strongly suggestive of Ms. Lambert's involvement in the
murder.
Given the level of Mr. Shirk's preparation for trial and his understanding of the
factual and legal issues, it is unlikely that he simply "missed" an opportunity to
impeach Detective Barley. It is more likely that he chose to keep his client as far
away from the trash bag as possible because of the implications arising from her
knowledge of or disposal of the bag. It is equally likely that he, in essence, agreed
with Detective Barley that there was nothing of evidentiary value found in the bag.
In the event that Mr. Shirk considered the pink trash bag a collateral issue, he
showed good sense and effective trial strategy by not impeaching Detective Barley
on a collateral issue.
10. Failing to have Ms. Lambert and her family testify about the "29
questions"
Mr. Shirk made a strategic decision as to the use of the "29 questions" at trial. It
was his purpose to use the document to demonstrate Mr. Yunkin's involvement in
the murder. The "29 questions" did nothing to exculpate Ms. Lambert. In fact, in
January January
Sunday
22, 201722, 2017
Page 2093
1091 of 2301
1299
that suspect document, she refers to "our prank," she refers to "Laurie's scary dead
eyestare," and she acknowledges participating in the conspiracy and the cover up.
(See Petitioner's Exhibit 1119; Addendum to this Opinion.) To open the door
through Ms. Lambert's testimony to these issues would have served no purpose.
There has been no showing here by petitioner that anyone in the Lambert family
had any light to shed on the "29 questions."
11. Failing to get an expert to replace Dr. Mihalakis
Petitioner contends that Mr. Shirk should have sought a continuance or obtained an
expert to replace Dr. Mihalakis. This issue is the subject of the discussion in Section
VII.H, supra.
With the considerable testimony on Laurie Show's ability to speak, the damage
done to Laurie Show's neck and her physical condition following the assault that
morning, we know that the subject matter of Dr. Mihalakis's testimony is a subject
matter upon which experts disagree. We have had the benefit of three well
qualified experts who offered their opinions that Laurie Show could not have
spoken. We have the benefit of three experts who say that Laurie Show could have
spoken. As we noted in Section VII.A, supra, "Laurie Show's Dying Declaration,"
this is an area where the expert testimony is one factor to be considered on the
question of Mrs. Show's credibility as to the "dying declaration."
With the benefit of all the expert discussion at the PCRA hearing, we can say with
confidence that Mr. Shirk's finding an expert to replace Dr. Mihalakis would not
have changed the outcome of this proceeding. Our conclusion now is the same as
our conclusion then. The additional mountain of expert opinions, pro and con, has
not changed that finding.
12. Failing to present evidence available that showed Mr. Yunkin's
involvement
Here petitioner is referring specifically to the statement made by Mr. Yunkin to
Hector Feliciano as he (Yunkin) was leaving work the week before the murder. The
out-of-court statement by Mr. Yunkin to Mr. Feliciano is hearsay. Mr. Shirk is not
ineffective for failing to elicit hearsay from a witness. In fact, Mr. Shirk articulated a
legitimate tactical reason for keeping the Feliciano statement out of evidence. See
discussion of Brady/Giglio claim 12, infra.
13. Failed to have John Balshy look at other writings in blood at the scene
John C. Balshy testified at trial that the letters "T" and "B" were written in blood on
the closet door. (N.T., Trial at 956.) This court viewed the photographs at trial and
did not agree with Mr. Balshy's "findings."
It is interesting to note that at the PCRA hearing, Mr. Shirk's own investigator,
Richard Jeffries, felt the same way. In fact, it was Mr. Jeffries who contacted Mr.
Balshy in 1992. When Mr. Balshy contacted Mr. Jeffries about his "finding" the
letters written in blood, Mr. Jeffries disagreed with him. Mr. Jeffries testified at the
PCRA hearing that he continues to believe that those letters are not written in blood
on the closet door. (N.T., PCRA at 7694.) This court found Mr. Balshy less than
January January
Sunday
22, 201722, 2017
Page 2094
1092 of 2301
1299
credible on that point. See Section VII.M, supra.

Mr. Shirk is not ineffective for failing to ask Mr. Balshy to look at other writings in
blood at the scene given the fact that his testimony as to the writings he "found"
was incredible. It certainly did not undermine the truth-determining process.
14. Failed to recognize that the last part of Ms. Lambert's statement was
altered
This issue has been considered in Section VII.L, supra, and in our discussion of
allegation of ineffective assistance 7, supra, in this section.
Two brief points bear repeating. One, Ms. Lambert acknowledged in her testimony
at trial that her statement was accurate. Two, Ms. Lambert wrote a letter on
December 23, 1991, to Mr. Yunkin where she adopted the information contained in
the last page of her statement. There is no evidence whatsoever in this or any
other record that the last page of her statement was "obviously altered."
15. Failed to present available evidence that Mr. Yunkin was lying about
what Ms. Lambert wore during the murder
Petitioner contends that Mr. Shirk was ineffective because he failed to present
available evidence that Mr. Yunkin was lying about what Ms. Lambert wore during
the murder.
Mr. Shirk cross-examined Mr. Yunkin on his recollection of what Ms. Lambert was
wearing. Mr. Shirk made a point of arguing to this court that Mr. Yunkin must have
been lying in that testimony. All of the "inconsistent" statements made by Mr.
Yunkin regarding Ms. Lambert's attire that morning were available to Mr. Shirk. Mr.
Shirk fully and completely litigated this issue in the trial. There is no merit to the
claim set forth in the petition on this point.
16. Failed to present available corroborating evidence about the date rape
Petitioner claims that Mr. Shirk was ineffective in that he failed to present evidence
corroborating the Yunkin date rape of the victim. In the first place, the police
reports are hearsay and would not have been admissible at trial. There does not
appear to be any credible evidence that there was, in fact, such a date rape. There
were suggestions and references made as to this possibility in police reports. That
is not competent evidence. Mr. Shirk was not ineffective for the failure to offer
hearsay at trial.
17. Failed to point out the time of death as listed on the autopsy report
The autopsy report notes the time of death as 7:15 a.m. This is simply contrary to
a significant amount of evidence. Perhaps Mr. Shirk understood that the time on
the autopsy report was an approximation. Perhaps Mr. Shirk was aware that the
911 call had been made at 7:35 a.m. and that persons on the scene saw signs of
life after the call. Whether Mr. Shirk was aware of that or not in 1992, we are
January January
Sunday
22, 201722, 2017
Page 2095
1093 of 2301
1299
certainly aware of those facts today. There is no merit to the claim.
18. Failed to present evidence that Ms. Lambert was not jealous
To suggest that Ms. Lambert was not jealous of Mr. Yunkin's involvement with
Laurie Show in the summer of 1991 would be a significant departure from reality.
At trial, there was, as Mr. Shirk described, a "parade" of teenage witnesses who
described the animosity from Ms. Lambert to Laurie Show at that time. Mrs. Show
testified as to specific incidents in which Ms. Lambert acted in an irrational,
hysterical and jealous rage.
The fact that Michelle Lambert might have been sexually active with another man
during the summer of 1991 does not establish a lack of jealousy. It would probably
not have been effective trial strategy for Mr. Shirk to enhance his client's
outrageous behavior in the summer of 1991 with proof of some sexual promiscuity.
In any event, this contention has no merit.
19. Failed to present evidence in news video footage that Ms. Lambert did
not appear pregnant
20. Failed to present evidence of Mr. Yunkin's scratches and bruises

As with so many of these issues, petitioner never really presented any evidence in
support of this contention. After nearly nine weeks of hearing testimony, we do not
know whether there exists any "news footage" showing that Mr. Yunkin had
scratches and/or bruises on his face. What we do know is that the prison records
show that he had no bruises or scratches upon his commitment to Lancaster
County Prison on December 21, 1991. (Commonwealth's Exhibit 49.) The nurse
who did his intake physical examination at the prison on December 21 testified that
he had no scratches or bruises. (N.T., PCRA at 6354.) There is no merit to this
contention.
21. Failed to present evidence of "another Michelle"
The contention that there was "another Michelle" who had been "involved with the
victim" is very misleading. There certainly was no person at any time material to
this case who was "involved with the victim" to the extent that Lisa Michelle
Lambert was "involved with the victim." To suggest that Laurie Show might have
known another girl named Michelle is of no consequence. The inference here is that
Laurie Show was referring to this other Michelle in her dying declaration. Given the
history between Ms. Lambert and Laurie Show, given what we know of Ms.
Lambert's participation that morning by her own admission, and given the
demonstrated fear Ms. Show had of Michelle Lambert during the summer and fall of
1991, to suggest that the dying declaration may have referred to another Michelle
has no basis in fact.
January January
Sunday
22, 201722, 2017
Page 2096
1094 of 2301
1299
22. Failed to get Ms. Lambert's statement suppressed due to a violation of

Pennsylvania's six hour rule
The "six hour rule" issue did not surface until Detective Solt was testifying in the
PCRA hearing on May 20, 1998. Detective Solt testified that he took a statement
from Ms. Lambert and that at around 4 o'clock in the morning on December 21,
1991, he telephoned Assistant District Attorney Kenneff to consult with him. (N.T.,
PCRA at 3076-77.) The subject matter of this consultation was whether the
questioning could proceed in light of the "six hour rule." Displaying some confusion
over this issue, petitioner's counsel asked Detective Solt to explain. He went on to
explain to them that a person in custody must be arraigned within six hours and
that a statement taken beyond this six hour period from the time of arrest might
well be illegal. (N.T., PCRA at 3079-80.)
The second amended petition was submitted to the court by petitioner on June 10,
1998, during the hearing and after Detective Solt's testimony. This amended
petition contains this allegation of ineffective assistance based on the "six hour
rule." This "learn as you go" approach has led to yet another frivolous issue
introduced into this hearing. We will address the issue because it has been raised.
In Commonwealth v. Davenport, 471 Pa. 278, 370 A.2d 301 (1977), the
Pennsylvania Supreme Court ruled that a statement taken from a defendant more
than six hours after arrest may be suppressed. This rule was qualified in
Commonwealth v. Duncan, 514 Pa. Super. 395, 525 A.2d 1177 (1987). Our
courts have since held that the Duncan/Davenport rule is not to be applied in a
mechanistic fashion. Voluntary statements given by a defendant and initiated within
six hours after arrest may not be suppressed just because the process of obtaining
the statement runs over six hours. Commonwealth v. Odrick, 410 Pa. Super.
245, 599 A.2d 974 (1991). See also Commonwealth v. Bond, 539 Pa. 299, 652
A.2d 308 (1995).
Detective Solt's candid testimony about his concerns for the Duncan/Davenport
rule were intended to explain why he bro ke off the interview. Mr. Kenneff advised
him that he could take no new information but that he could obtain clarifications
and confirmations of information he had already taken from Ms. Lambert.
Mr. Shirk was asked by petitioner's counsel why he did not have the statement
suppressed. He testified that he was familiar with the Duncan/Davenport rule
and that he felt it would be a fruitless exercise to seek to have the statement
suppressed. He noted that Ms. Lambert all but confirmed the contents of her
statement in the letter of December 23,1991, to Mr. Yunkin. Second, he was aware
that recent developments in the law would probably have supported the use of the
statement because Ms. Lambert had begun the statement within the six hour
period of time. Further, the last part of the statement, where she changed her story
as to her attire at the time of the murder, was apparently given voluntarily and not
in response to questions.
Mr. Epstein, a specialist in criminal law from Philadelphia and Ms. Lambert's
appellate counsel, testified that he did not think there was any merit to a
suppression issue based on the Duncan/Davenport rule.
January January
Sunday
22, 201722, 2017
Page 2097
1095 of 2301
1299
Mr. Shirk stated a clear tactical reason for not seeking to suppress the statement.
He certainly had a reasonable basis for his course of conduct. The content of Ms.
Lambert's statement, even if the statement itself had been suppressed, would have
been admitted through her subsequent letters and statements to others.

Ms. Lambert contends that Mr. Epstein was ineffective. Mr. Epstein was hired as
appellate counsel to pursue the issues raised on appeal by Mr. Shirk. Mr. Epstein
was given permission to expand on these issues in his amended post verdict
motions. Petitioner contends that he was ineffective for failing to address "the
many irregularities in the record." This allegation is too vague to merit any
response. The court is uncertain as to these "irregularities" and dismisses this
contention as having no merit.
Petitioner contends that Mr. Epstein was ineffective for failing to call the experts
that petitioner's counsel called at the federal habeas hearing. In fact, Mr. Epstein
was pursuing an appeal to the Pennsylvania Superior Court. Typically, expert
witnesses do not testify in the appellate courts. Mr. Epstein may also have
recognized that expert testimony is not after-discovered evidence and chose not to
call these experts in the post verdict hearing. There simply is no merit to the claim
that he should have called experts during the appeal process.
Petitioner's contention that he failed to raise all the claims contained in the petition
for writ of habeas corpus and that he failed to move for discovery is misguided. Mr.
Epstein was pursuing a remedy in a different forum. He was pursuing a direct
appeal to the Pennsylvania Superior Court. Perhaps had the Lambert family
retained him to file a Post Conviction Relief Act petition after the direct appeals had
been exhausted, this might have been a different story. His appeal to the
Pennsylvania Superior Court would not have been the appropriate place to move for
discovery or to raise the various issues raised in the petition for writ of habeas
corpus.
Mr. Epstein was certainly not ineffective for failing to raise the "six hour rule." He
made a reasonable judgment there was no Duncan/Davenport issue. We
discussed this issue in the section above regarding Mr. Shirk. The same analysis
applies.
Finally, the contention that Mr. Epstein was ineffective for failing to preserve issues
raised by Mr. Shirk has no merit. He chose to proceed with those issues he found to
be meritorious. This was within his professional judgment. Petitioner has not
demonstrated that he was without a reasonable basis for his course of conduct.

Petitioner contends that the District Attorney of Lancaster County has gone on
record as agreeing that she is entitled to relief. This argument appears throughout
January January
Sunday
22, 201722, 2017
Page 2098
1096 of 2301
1299
her pleadings and briefs in this and other courts.

This issue arises from a discussion which took place during the habeas corpus
proceeding following Mrs. Show's testimony in the district court's chambers. At that
time, Mrs. Show informed the court and counsel of her new recollection about
seeing Mr. Yunkin's car in the condominium complex on the morning of December
20, 1991. After Mrs. Show's in-chambers testimony, District Attorney
Madenspacher conceded that "some relief. . . is justified in this particular case."
(N.T., Habeas Hearing at 2701.) The district court then asked: "So, are we agreed
that the Petitioner will tonight be released into the custody of Ms. Rainville?" To
which Mr. Madenspacher replied, "I don't see how I can object to that, your Honor."
This "concession" has been offered as justification, in and of itself, of Ms. Lambert's
entitlement to the habeas, and now PCRA, relief. To contend that the
Commonwealth has somehow agreed that Ms. Lambert should be released, should
be given a new trial or should be declared innocent, ignores Mr. Madenspacher's
actions on the record of the federal habeas proceeding the very next day. When
court convened, Mr. Madenspacher made an oral motion for reconsideration and a
stay of the district court's order of the previous day granting relief to Ms. Lambert:
MR. MADENSPACHER: . . . .
Yesterday, you Ordered the interim relief of petitioner.
THE COURT: With the consent of the Commonwealth.
MR. MADENSPACHER: Your Honor, I agree I agreed to that. In retrospect, I was
wrong.
I reviewed carefully last night the testimony of what went on inside Chambers, and
I said I still feel that certain significant things have happened regarding Mrs. Show,
and I had an obligation to make that clear to the Court.
But in reading it carefully, you said that: This testimony is totally consistent with
what Miss Lambert has said since 1992.
In retrospect, when I consider that, that is wrong, your Honor.
Miss Lambert consistently since her trial, and even in this proceeding, has
maintained that she was never in that apartment complex.
The significance of Mr. Madenspacher's statement on the day after the "concession"
is that he retracted his statement of the previous day. The Third Circuit took pains
to point this out. In the Third Circuit's opinion on the subject of the District
Attorney's "concession," the court pointed out that the district court "did not
recognize that the Commonwealth withdrew this concession the very next day."
134 F.3d 511 n.11. The Court of Appeals clarified, and this court believes, that the
"concession," to the extent there ever was a concession, to relief, was withdrawn
January January
Sunday
22, 201722, 2017
Page 2099
1097 of 2301
1299
on the record at the next available opportunity. We find no basis in this record to
grant relief on the basis of any agreement or concession by the Commonwealth.
In the most recently amended PCRA petition, petitioner sets forth a catalog of
Brady/Giglio violations under the general heading of "A Miscarriage of Justice was
Caused by Many Acts of Intentional Prosecutorial Misconduct." (Exhibit A, Section
B.) These begin at page 14 of Exhibit A and the numbering begins with the number
32 in a series of allegations of intentional prosecutorial misconduct. To address
these Brady/Giglio claims, we will follow the numbering system in the petition. A
discussion of the legal issues raised by these Brady/Giglio claims can be found in
Section III.B.1.a and Section VII.F.2, supra.
We will refer to these as Brady claims, unless otherwise noted. Brady requires the
disclosure of exculpatory material to the defense. Giglio extends Brady to include
material pertinent to the credibility of witnesses.
32. Failed to disclose the identify of the medical people at the crime scene
Corporal Renee Schuler's report of December 31, 1991, contains two references to
ambulance vehicles present on the scene that morning. (Petitioner's Exhibit 1607,
Commonwealth's Exhibit 4.)(104) This report was turned over to Mr. Shirk in
discovery prior to the trial. Mr. Shirk had every opportunity to obtain the identity of
each person from the investigating police officers or from the Community Hospital
or East Lampeter Township Ambulance Departments, interview them and determine
whether to call them as witnesses at trial. They were not kept secret. Brady does
not require that the Commonwealth do the investigative work for defense counsel.
There was no question and no secret about the fact that emergency personnel were
all over the crime scene that morning. As to the allegation that three "medical
people" determined that the victim's carotid artery was severed, that is, in fact, a
miscasting of the evidence. Mr. Zeyak is certain it was severed, Ms. Harrison
testified that she was influenced by Mr. Zeyak's recollection and Mr. May believes it
was severed. This issue is addressed more completely in Section VII.A., supra.
33. Failed to disclose that the Chapmans were at the scene prior to the
medical people
1991. (Petitioner's Exhibit 1607; Commonwealth's Exhibit 4.) Mr. Shirk was aware
that he had been in the condominium and had every right and opportunity to
interview him and call him as a witness.
34. Failed to disclose that victim's carotid artery was severed
See Section VII.A, supra.
35. Failed to disclose that Tom Chapman made a call to 911

January January
Sunday
22, 201722, 2017
Page 2100
1098 of 2301
1299
1991. (Petitioner's Exhibit 1607; Commonwealth's Exhibit 4.)

Mr. Chapman's identity and his presence at the scene that morning were known to
the police and, through the discovery process, known to Mr. Shirk. In fact, the
report identifies Mr. Chapman as the person making the 911 call.
36. Failed to disclose that Ms. Berry saw Hazel Show leave the school at
7:25
Corporal Renee Schuler's report of January 2, 1992, (Petitioner's Exhibit 2081),
indicates that Mrs. Show spoke to a secretary at Conestoga Valley Junior High
School on the mo rning of December 20, 1991. There has been no showing that the
investigating police officer knew the identity of the secretary or attached any
importance to the identity of the secretary with whom Mrs. Show spoke. There is
no evidence in this hearing of an intentional failure to disclose that name. In fact,
the report reflects that there was a conversation between Mrs. Show and a
secretary and certainly the identity of the secretary could have been easily
determined had defense counsel chosen to contact Conestoga Valley.
This was not a Brady violation. Mr. Shirk was aware from the January 2, 1992,
report that Mrs. Show spoke to a secretary immediately before leaving the school.
The report was among the documents produced to him in discovery. (See
Commonwealth's Exhibit 4.) In her testimony in this court, Ms. Berry testified that
Mrs. Show left the school at "approximately 7:25 a.m." (N.T., PCRA at 52.) It was
necessary for Ms. Berry to review a police report to refresh her recollection. (See
Petitioner's Exhibit 2035) She did not recall looking at the clock. She admitted: "I
don't remember anything definite about what time she left." (N.T., PCRA at 53.)
She recalls that Mrs. Show left prior to the arrival of the secretary who gets in at
7:30 a.m. (Id.) This is far from precise. It is the best recollection available to Ms.
Berry and her testimony was credible to this court. Did the secretary who gets in at
7:30 get in five minutes early or five minutes late? Did Mrs. Show leave ten
minutes before that secretary arrived? Fifteen minutes? Five minutes?
From the various times described by various witnesses in 1992 and at the 1998
PCRA hearing, it is likely that many of these times were approximations and
estimates. There is no evidence that all relevant parties had coordinated their
watches or any testimony that each was going by a certain clock. The only time
that appears to be in any way certain was the time the 911 call was received by
Lancaster County Wide Communications, that is, 7:35 a.m. Given the fact that Ms.
Berry's testimony about time was an approximation and given the fact that there
are variables affecting the time line that morning, Ms. Berry's testimony as
presented to this court in the PCRA hearing was not material in the sense that
there is no showing that it would have changed the outcome of the case in 1992.
37. Failed to disclose interview of a neighbor, Lena Fisher, wherein she

stated she heard screams and saw a man leave at 7:15
In fact, this "man" appears to have been Brad Heisler. What were not "disclosed"
were Corporal Renee Schuler's own personal notes from her interviews and
discussions during the early stage of the investigation. There is absolutely no duty
under Brady or under Rule 305 for a prosecuting officer or investigating officer to
January January
Sunday
22, 201722, 2017
Page 2101
1099 of 2301
1299
disclose his or her personal notes. In fact, the subject matter of these "notes" could
reasonably been have viewed as included in the various police reports regarding
the events of that morning. There are reports noting that Brad Heisler was on the
scene, but the reports vary in terms of the timing and location of his presence.
From the various reports, we can conclude that Mr. Heisler came to pick Laurie
Show up for school and that he went into the condominium very briefly after the
Kleinhans went in but before the police arrived. This would be entirely consistent
with Lena Fisher's observations as noted by Corporal Schuler.
Lieutenant Renee Schuler testified at the PCRA hearing that her notes, taken in
shorthand, confirmed an observation by Ms. Fisher, that she saw Brad and another
man "stop and leave." (N.T., PCRA at 3827-28.) She never wavered from this
testimony. If this was Ms. Fisher's recollection, then that would be consistent with
Mr. Heisler's brief visit to the condominium that morning.
Petitioner's argument that this is a failure to disclose material information is
premised on an assumption that the "man" was Lawrence Yunkin and that Corporal
Renee Schuler recorded in shorthand that Ms. Fisher saw the man "stand up and
leave." To accept this version, we must accept the expert testimony on shorthand
from Leola Bennett and of two secretaries from Schnader Harrison Segal & Lewis
that Corporal Schuler actually wrote "stand up and leave" and not "stop and leave."
Lieutenant Schuler testified unequivocally at the PCRA hearing that she used her
own system of shorthand based on what she learned in school and that the symbol
she used was her symbol for "stop" not "stand up." (N.T., PCRA at 3828.)
38. Failed to disclose that Jim and Craig Ellis denied seeing Mr. Yunkin at
McDonald's
39. Failed to disclose that Ms. Bayan saw Mr. Yunkin driving his car on a
street he said he was not on
40. Failed to disclose that Mr. Yunkin said he drove by "twice"

41. Failed to disclose that Ms. Bayan saw the three suspects in the car at
the condominium
42. Failed to disclose that Ms. Bayan saw Mr. Yunkin drive the getaway car
"fast"
January January
Sunday
22, 201722, 2017
Page 2102
1100 of 2301
1299
43. Failed to disclose that Mr. Yunkin claimed he was not working on
December 20th
44. Failed to disclose that Mr. Yunkin saw a male student waiting for the
bus and that no one was waiting for the bus that morning
Jay M. Garber testified at the PCRA hearing that he dropped his grandson off at the
bus stop at the entrance to the Oaks Condominium complex that morning. (N.T.,
PCRA at 6082.) This establishes that there was someone waiting for the bus that
morning. There is no proof that the police failed to disclose that Mr. Yunkin told
them he saw a male standing waiting for the bus.
45. Failed to disclose that there were multiple blood stains in the hallway
by the front door
Photographs taken by the Pennsylvania State Police at the Show condominium the
morning of the murder were available for inspection by defense counsel. At the
1992 trial, there was testimony about blood spatter on the wall in the hallway by
the front door.
The only photographs introduced at the PCRA hearing showing blood on the floor in
the hallway were from Compleat Restorations, a company retained to perform
clean-up at the Show condominium. Compleat Restorations came into the
condominium on December 23, 1991, the third day after the murder. In the
interim, police, family, medical personnel, neighbors and friends who assisted in
cleaning up the condominium were in and out of the premises.
To say that the "stains" or "spots" on the floor in the hallway are indicative of
bloody footprints left by the murderer is patently unreliable. Those footprints could
have been placed there by anyone who entered the condominium and walked in the
vicinity of the bedroom.
See Section VII.M., supra.
46. Failed to disclose that the front hallway showed signs of an obvious
struggle
Photographs introduced at the 1992 trial and at the 1998 PCRA hearing clearly
show evidence of some blood spatter on the wall in the hallway. The amo unt of
blood was relatively insignificant in relation to the amount of the blood in the
bedroom. There was testimony at the trial and argument by counsel as to the
amount of blood in the hallway and as to the significance. There was also testimony
regarding markings on the wall. Finally, Trooper Suber's videotape clearly shows
markings on the wall on the inside of the front door consistent with a struggle. This
court finds no evidence of a Brady violation on this point.
January January
Sunday
22, 201722, 2017
Page 2103
1101 of 2301
1299
47. Failed to disclose that Mr. Kleinhans went upstairs and saw the blood
in the hallway
Petitioner has produced no evidence that Mr. Kleinhans told the police that he saw
blood in the hallway that morning. He testified in his deposition and he testified in
the PCRA hearing that he saw blood in the front hallway. Mr. Kleinhans testified at
trial but was not asked, by either side, about what he saw in the Show residence.
Mr. Kleinhans is not the only person who observed the front hallway. There has
never been any question that there was some blood in the hallway. Mr. Kleinhans
had nothing to add on this subject.
48. Failed to disclose the unedited video of the river search

It is clear that there were two videos made of the river search, one recorded by
"Smokey" Roberts containing sound and lasting approximately 13 minutes and
another, also recorded by Mr. Roberts from his original tape, lasting approximately
8 minutes and containing no sound.
It is equally clear that the editing to the tape was done by Mr. Roberts before he
gave the tape to the police. See Section VII.K, supra. There is no proof that the
police cut, edited, changed or altered the videotape of the river search. It appears
that Mr. Roberts made the decision to remove the sound.
This court had the opportunity to view the edited and the unedited videotapes on
several occasions during the hearing. We viewed the footage of Detective Barley
bending over and looking at what appears to be a pink trash bag. We heard the
statement, "What do you got, a bag?" and we saw Detective Barley wave at the
camera at that time. To this court, sitting as fact finder, there is nothing about the
unedited, longer tape which appears to be in any way sinister or problematic.
Detective Barley's "wave" seemed to be little more than an indication that there
was nothing of significance. It was not the hurried "let's keep the cameras away
from this important evidence" gesture as argued by petitioner. All that the unedited
tape shows is that Detective Barley found a bag and that it appeared to be a pink
trash bag. The edited version, viewed by Mr. Shirk prior to trial shows a pink bag
as well. The edited tape was provided to Mr. Shirk and he testified that he viewed
that tape. (N.T., PCRA at 3363.) He was, therefore, aware that there was a tape
made of the river search and that a pink bag was found during the course of that
search. A police report produced to him referred to the tape as "edited."
(Petitioner's Exhibit 1295; Commonwealth's Exhibit 4.)
Mr. Shirk could have asked to see the unedited tape. His failure to do so was not
ineffective or negligent. The bottom line is he knew that a pink trash bag was
located by the police and if he thought there was some significance to that, he
could have pursued the issue in further discovery or in questioning witnesses at
trial.
Petitioner's counsel would have the court believe that a pink bag was discovered
containing incriminating evidence (presumably to Mr. Yunkin) which was then
emptied of its contents (inculpatory to Mr. Yunkin; exculpatory to Ms. Lambert) and
then repacked in ice so that someone (presumably Detective Barley) could be
January January
Sunday
22, 201722, 2017
Page 2104
1102 of 2301
1299
filmed digging around the bag with the tip of his shoe and a stick to demonstrate
that the bag was embedded in ice. There is simply no proof that this took place.
There are only the bald assertions of petitioner's counsel.
The important facts are that Mr. Shirk knew there was a search of the river, knew
who was involved, knew that a tape was made, knew that the tape had been
edited, viewed that tape, knew that a pink bag was found and had every
opportunity to question police witnesses, Mr. Yunkin, and his client, and to develop
the significance of those points at trial.
49. Failed to disclose that the phone cord was broken in half
In fact, photographs taken by the state police at the crime scene show the phone
cord broken in half. This is neither consistent nor inconsistent with Ms. Lambert's
testimony. The fact that Ms. Buck threw the phone across the room does not
necessarily mean the phone cord snapped. The fact that the cord was snapped does
not necessarily mean that the phone was thrown. It appears clear that the phone
cord snapped or was broken during the course of the struggle that morning. The
struggle was described by both Ms. Lambert and Ms. Buck, each with a different
perspective. Photographs of the victim's bedroom showing her legs and feet clearly
depict a torn telephone cord. (See Petitioner's Exhibits 1742, 1747, 1749, 1749-A.)
See Section VII.M, supra.
50. Failed to disclose that a sneaker was found by the river

A sneaker was found in the Pequea Creek, which empties into the Susquehanna
River. This was well described at the PCRA hearing. (N.T., PCRA at 823-24.) The
sneaker found was a canvas sneaker packed with mud and showing signs of what
was described as "black rot." This black rot suggested to Detective Barley that the
sneaker had been a denizen of the deep for longer than two or three days.
Detective Barley made the decision that the sneaker was of no evidentiary value
and, as would be common practice with anything, fish or otherwise, caught in a
river and determined to have no value, he threw it back. The police are not
required under Brady or any other authority to disclose to the defense every
insignificant item disclosed during a search. Does Brady require that the police, in
making a search of a creek and river bed and banks, catalog and save every item
located? There is nothing to indicate that the sneaker found in the creek had any
evidentiary value at all. Nothing learned in the PCRA hearing would suggest that
Detective Barley found a sneaker that had any significance to this case. That is the
bottom line for a Brady analysis.
51. Failed to disclose that a clump of hair was found precisely where Ms.
Lambert testified Ms. Buck threw it
The "finding" of a clump of hair "precisely where Ms. Lambert testified Tabitha Buck
threw it" resulted from petitioner's counsel's enlargement of a photograph and their
opinion that an item in that enlarged photograph constitutes a clump of hair.
January January
Sunday
22, 201722, 2017
Page 2105
1103 of 2301
1299
(Petitioner's Exhibit 1785.) The clump of hair was not visible on the small
photograph. The photograph was produced to Mr. Shirk in 1992. This is really a
claim that Mr. Shirk was not as diligent as Ms. Rainville in having the photograph
enlarged so as to identify a clump of hair. There is no merit to this as a Brady
violation or as an ineffective assistance of counsel claim.
More importantly, there was hair, or clumps of hair, found on the floor of Laurie
Show's bedroom in the course of the investigation. In fact, Mr. Shirk went to the
trouble, and the County went to the expense, of hiring a hair and fiber expert to
testify at the 1992 trial. The expert testified that the hair was cut, not pulled or
torn. (N.T., Trial at 980.)
It is difficult to imagine that a clump of hair, conclusively established by the
defense at the 1992 trial to have been cut by a knife, would fall anywhere
"precisely" where someone threw it during the kind of struggle described by all
participants. Mr. Shirk knew there was hair on the floor of the bedroom and he
made every effort to make use of that testimony in his defense of Ms. Lambert at
trial. His use of expert testimony and his arguments were in an effort to confirm
Ms. Lambert's story that Ms. Buck went after Laurie Show with a knife and cut off
pieces of her hair. (105) The expert confirmed that the hair was cut with a sharp
object. (N.T., Trial at 980.) There certainly was no Brady violation here.
52. Failed to disclose that a bloodhound found the rope based on Ms.
Buck's scent
See Section VII.D.3, supra.
53. Failed to disclose that Scott Hershey told the prosecution that Laurie
wanted to get even with Michelle and Brad had heard rumors Lawrence
was going to beat him up
54. Failed to disclose Officer Fassnacht's report of Mr. Yunkin's rape of Ms.
Show
Two East Lampeter Township police reports refer to the allegation that Lawrence
Yunkin raped Laurie Show. These reports were each produced to Mr. Shirk. (See
Commonwealth's Exhibit 4.)
The first report was Corporal Renee Schuler's report dated January 2, 1992. At
page 7 of that report, Officer Schuler related the facts of a previous harassment
incident which occurred at Root's Market in September 1991. The report contains
the following sentence: "This was the first time Hazel mentioned to Lambert that
Laurie was raped by Yunkin." On page 8 of the same report, Officer Schuler related
a conversation John and Hazel Show had with their daughter regarding her
involvement with Mr. Yunkin. Page 8 of Officer Schuler's January 2, 1992, contains
the following sentence: "Hazel then spoke to Laurie about this and Laurie indicated
January January
Sunday
22, 201722, 2017
Page 2106
1104 of 2301
1299
she had been raped by Yunkin."

Commo nwealth's Exhibit 4 contains a copy of another East Lampeter Township
police report dated August 10, 1991. It concerns Incident No. 3648-1991 which
apparently was an investigation of an ongoing harassment by Ms. Lambert of Laurie
Show. The report is prepared by an officer who is not identified on the report. The
officer refers to working with Officer Abram but does not identify himself or herself
on the report. This report was produced to Mr. Shirk and contains the following
sentence: "Show only last night told her mother that Yunkin raped her in the end of
June, while they were in Yunkin's van. After that, she left him." (See
Commonwealth's Exhibit 4.) The record of this case proves that there was no
Brady violation.
55. Failed to disclose that Larry Ware heard Mr. Yunkin say he would be in
jail for murder
In Corporal Renee Schuler's report dated January 10, 1992, at page 3, there is a
reference to a discussion involving Larry Ware and Hector Feliciano. This refers to
Mr. Yunkin's speaking of not being at work on December 23, 1991, because he
would "be in jail." This report was provided to Mr. Shirk during discovery. Whether
there was a specific disclosure about Mr. Ware actually hearing Mr. Yunkin say he
would be in jail for the murder is unclear. Certainly the report identifies Mr. Ware,
identifies Mr. Feliciano and refers to the conversation in question. Had Mr. Shirk
wished to pursue this, this information was available during discovery.
As to whether this was a Brady violation, the question of "materiality" warrants
discussion. Mr. Shirk testified at the PCRA hearing that he specifically stayed away
from this area of testimony at trial. He did not put Mr. Feliciano on the stand to
testify as to Mr. Yunkin's statement. Mr. Shirk described in clear terms that he
wanted to avoid associating any of the three participants with any evidence of
premeditation or specific intent. (N.T., PCRA at 3474-75.) Mr. Shirk explained that
had he established that Mr. Yunkin was expressing an intention to kill someone,
then that "specific intent" could have been ascribed to his own client. Ms. Lambert
was constantly in Mr. Yunkin's company and undoubtedly was in Mr. Yunkin's
company on the morning of December 20, 1991.
It appears that the information which is the subject of this alleged Brady violation
was made known to Mr. Shirk. It does not appear that it was in any way "material"
to the defense. In fact, Mr. Shirk was aware of the information, was aware of the
conversation in which Mr. Yunkin is reported to have stated that he was going to
kill someone, and specifically chose not to use that information. There certainly was
no Brady violation here.
56. Failed to disclose that Mr. Kenneff told the Yunkins to stop sending
money to Ms. Lambert
In fact, there is no evidence that Mr. Kenneff told Lawrence Yunkin's parents to
stop sending money to Ms. Lambert. It has been established through the testimony
January January
Sunday
22, 201722, 2017
Page 2107
1105 of 2301
1299
of Mr. Cody, counsel for Mr. Yunkin in 1992, that it was Mr. Cody who told the
Yunkins to cease any further contact with Ms. Lambert when she was in prison. This
was confirmed by Lawrence Yunkin's mother, Johnnie May Yunkin. (N.T., PCRA at
6462, 7592.)
57. Failed to disclose that the prosecution found a license plate in the back
of Yunkin's car
During an inventory search of the Yunkin car, a license p, late was discovered. The
license plate corresponded with a license number contained in Officer Bowman's
notes.
Petitioner's theory of the case is that Mr. Yunkin drove in the condominium complex
in a vehicle with a license number YHM-028 and that later in the day to hide this
fact, he changed the license plate and left the YHM-028 license plate in his car. The
specific Brady claim is that the police knew he was seen in the condominium
complex with the YHM-028 license plate and that they later found the incriminating,
material license plate in his car and failed to disclose this to Mr. Shirk.
In fact, Ms. Lambert testified in the PCRA hearing that she was with Mr. Yunkin the
entire day.(106) Ms. Lambert at no time observed Mr. Yunkin changing a license
plate on his car. Further, the license plate on the brown Mercury which was driven
by Mr. Yunkin that morning and the YHM-028 license plate found inside the car
were both registered to Mr. Yunkin. Detective Savage testified that he or Officer
Bowman ran the license plate found in the car and found that it was registered to
Mr. Yunkin. (N.T., PCRA at 4428-31.) Its use as perhaps hiding Mr. Yunkin's
presence in the condominium was eliminated. Why would Mr. Yunkin place a license
plate on his car, registered to another vehicle in his name, to mislead the
authorities as to his presence that morning?(107)
58. Failed to disclose that at least one eyewitness reported seeing this
license plate at the crime scene on the morning of the murder
59. Failed to disclose Mr. Yunkin's letters to Shawn Lapp
Petitioner claims that these letters demonstrate that Mr. Yunkin was lying to Ms.
Lambert in his letters to her in prison, demonstrate that Ms. Lambert believed Mr.
Yunkin was a rapist, and demonstrate that Laurie Show had filed charges for rape
against Mr. Yunkin. Petitioner has not established any relevance or materiality of
this information. This evidence links to Ms. Lambert's "Burgess theory" that she
was manipulated by Mr. Yunkin, abused by Mr. Yunkin and afraid of criminal
January January
Sunday
22, 201722, 2017
Page 2108
1106 of 2301
1299
charges from Laurie Show.

Further, the "Burgess" evidence is relevant only to a very limited issue which, as
the case has developed, is not being pursued by the Commonwealth. The Shawn
Lapp letters are only material to the extent that they relate to the expert opinion of
Dr. Burgess, i.e., that Mr. Yunkin manipulated Ms. Lambert. This opinion is not
relevant under Pennsylvania law. Therefore, the letters are not material. There has
been no showing of materiality necessary to establish a Brady violation.
60. Failed to disclose that the victim had identified the killers by writing in
her own blood
Petitioner makes the claim that the Commonwealth should have disclosed
something that was never there. At the 1992 trial, Mr. Shirk argued that Laurie
Show had written the initials "TB" for Tabitha Buck and "B" for Buck. At the federal
hearing, petitioner's counsel added the initials "BY" for "Butch" Yunkin. Mr. Shirk
argued that Laurie Show's dying act was not to identify "Michelle" but rather to
write "TB" on the closet door. This was the subject of expert testimony by John C.
Balshy, a crime scene investigator who first "discovered" the "TB" initials in blood.
This court had every opportunity to view at trial the photographs referre d to by
Messrs. Shirk and Balshy and found that the initials were not there. The court did
not accept Mr. Shirk's argument on this point and did not accept Mr. Balshy's
expert testimony that the initials were written in blood on the closet door.
Ms. Lambert contends it is a constitutional violation for the Commonwealth not to
anticipate a creative and ultimately unsuccessful argument based upon an
interpretation of evidence to create an issue that might possibly distract, confuse or
miscast the truth in the interest of raising a reasonable doubt at trial. In fact, Mr.
Shirk made a valiant effort to argue the existence of something that really was not
there. He did that in good faith to make every possible use of every possible item
of evidence in Ms. Lambert's defense. He based his argument on the "findings" of
Mr. Balshy, which this court, or fact finder, considered and did not accept. There is
no indication anywhere that the initials "BY" appear anywhere in Laurie Show's
bedroom, let alone on the carpet or the closet door.
To demonstrate the problems with this claim, we look to the testimony of Richard
W. Jeffries at the PCRA hearing. Mr. Jeffries is a licensed private investigator who
was court appointed to assist Mr. Shirk in the defense of Lisa Michelle Lambert in
1992. (108)
In the PCRA hearing, Mr. Jeffries testified in the Commonwealth's case about the
"TB" initials. He stated that Mr. Balshy contacted him in 1992 with the "revelation"
that he had found Tabitha Buck's initials in blood on the closet door. Mr. Jeffries
demonstrated that his ability to analyze evidence was not colored by the side he
represented when he candidly acknowledged that he did not agree with Mr. Balshy.
He did not agree with Mr. Shirk's use of Mr. Balshy as a witness in 1992. In fact,
Mr. Jeffries testified before us in 1998 that he looked at the photographs which had
been enlarged by Mr. Balshy and determined that the initials "seen" by Mr. Balshy
on enlargement would have, in fact, been one- half to three-quarters of an inch
high. Mr. Jeffries found it unlikely, and this court completely agrees, that a person
in the condition of Laurie Show after her killers left the condominium could have
January January
Sunday
22, 201722, 2017
Page 2109
1107 of 2301
1299
been capable of crawling across the floor and inscribing in rather minu, te
characters several initials of her killers on the closet door. (109) (N.T., PCRA at 7693.)
61. Failed to disclose Mr. Yunkin's admission that he sometimes wore the
earring found at the crime scene
There is no evidence that Mr. Yunkin wore the earring found at the crime scene.
There was evidence that Mr. Yunkin wore an earring similar to that earring. In fact,
it appears that there are many, many earrings similar to that which was found on
the floor of the condominium.
At trial, Mr. Shirk was aware and questioned Mr. Yunkin about the fact that Mr.
Yunkin wore a similar earring on occasion. This was an important point of Mr.
Shirk's defense and was fully litigated and fully argued to this court. This issue is
more fully developed in Section VII.N, supra. The possibility that the earring found
in the Show condominium was worn by Mr. Yunkin at the time of the murder was
well presented to this court. It did not affect the outcome of the trial. That, in itself,
is proof that the information was not material for Brady purposes.
62. Failed to disclose that Pat Fry described the two suspects as having
"broad shoulders or bulky clothes"
Officer Jere Schuler of the West Lampeter Township Police Department interviewed
Fred Fry at his residence on the day of the murder. Officer Schuler's report is dated
January 2, 1992, and was one of the police reports provided to Mr. Shirk in
discovery. (See Commonwealth's Exhibit 4.)
In the report, Officer Schuler related a description given of the two suspects who
Mr. Fry saw at approximately 7:12 a.m.: "Both appeared to be between 5'5" and
5'8"." He described both as being "none too slim." He felt they both had "bulky
clothing on."
A report of Officer Bowman's meeting with Mr. and Mrs. Fry on December 22, 1991,
was also contained in the materials provided to Mr. Shirk in discovery. This report
describes a meeting where Officer Bowman showed various items of clothing which
had been recovered during the investigation. The Frys felt that the Miami Dolphins
jacket looked familiar but were unable to identify any of the other items of clothing
with any degree of certainty.
Officer Jere Schuler also interviewed Pat Fry on the morning of December 20, 1991.
Mrs. Fry described two individuals who she believed were female wearing hooded
sweatshirts or jackets. This report was dated January 2, 1992, and was provided to
Mr. Shirk in discovery. (See Commonwealth's Exhibit 4.)
63. Failed to disclose that the Frys thought the two people they saw wer, e
Hispanic
The e, thnic origin of the two people seen by the Frys was never an issue
January January
Sunday
22, 201722, 2017
Page 2110
1108 of 2301
1299
and would certainly not have effected the outcome of the trial. Officer Jere
Schuler interviewed Mr. and Mrs. Fry. His report of January 2, 1992,
contained a summary of the interview and was produced to Mr. Shirk. (See
Commonwealth's Exhibit 4.) Neither Mr. nor Mrs. Fry could provide a
description of the faces of the two people they observed. The reference to
"appearing Hispanic" comes from Sergeant Carl Harnish's narrative
account of what he heard from various police officers that morning. There
is no report of the Frys making this statement to anyone.
64. Failed to disclose that the Gladfelters were two of only eight people on
Yunkin's visitor list in prison
There is no obligation on the part of the Commonwealth to disclose a
material witness's prison visitor list. Failure to disclose that which defense
counsel can access on his own is not a Brady violation.
65. Failed to disclose that Mr. Fry said it was "too dark" to see
66. Failed to disclose that Laura Thomas had made a false kidnaping report
Ms. Thomas never made a false report to law enforcement regarding a
kidnaping. See Section VII.I, supra.
67. Failed to disclose that Pat Fry said the person wearing the Miami
Dolphins jacket was wearing black sweatpants
68. Failed to disclose that neither Laura Thomas nor her father, Floyd
Thomas, said anything about "slit her throat" in their initial interviews
All the police reports involving discussions with Laura Thomas and Floyd
Thomas were disclosed. If there were inconsistencies between early
reports and subsequent reports, these inconsistencies were available to
defense counsel for cross-examination purposes. In fact, Mr. Shirk made
good use of these inconsistencies.
Commonwealth Exhibit 4 contains a report of Officer Bowman's interview
of Laura Thomas on January 2, 1992. Interestingly, this report describes
one of the plots to kidnap Laurie Show: "Lambert would then take Show,
tie her to a phone pole and shave her head and 'slit' Laurie's throat."
Certainly, Mr. Shirk was aware of this interview by virtue of the
Commonwealth's response to his discovery request.
January January
Sunday
22, 201722, 2017
Page 2111
1109 of 2301
1299
This report is somewhat inconsistent with Corporal Renee Schuler's report

of January 10, 1992, regarding an interview with Laura Thomas on January
5, 1992. Ms. Thomas at that time related Ms. Lambert's plans to do harm to
Laurie Show but did not mention anything about "slitting her throat."
Again, this document was available to Mr. Shirk. To the extent that there
was an inconsistency between the two reports, he was in a position to
question Ms. Thomas about her interviews with the police. There was no
failure to disclose. For further discussion of this issue, see Section VII.I,
supra.
69. Failed to disclose that Tabby had admitted her prior involvement in a
murder in Alaska
There was no evidence offered at the PCRA hearing on this claim. This
evidence would not be admissible at trial.
70. Failed to disclose that Woody Woodward knew that Tabby had fought
Laurie
71. Failed to disclose that Rick Lentz saw Tabby fight Laurie and heard
Tabby tell Laurie that she was "going to get her"
This claim involves evidence of Tabitha Buck's animus or bad acts prior to
the murder. The Commonwealth has no duty to discover, uncover or relate
to the defense negative information about a co-defendant. In fact, the
Commonwealth at all times asserted that Tabitha Buck was involved in the
killing. Evidence which would establish Ms. Buck's motive or conduct
would in no way exculpate Ms. Lambert. Such evidence simply would not
be material to this case. See Section VII.D.2, supra.
72. Failed to disclose that the rope found around the body was 12 feet
long, not 23- feet or 24-1/2 feet as testified to, and not 22' 5" as the
rope in evidence appears to be
The rope was at all times available to defense counsel to be measured. The
significance of mistakes in measurement or discrepancies between reports
about the lengths of the various ropes seems questionable at best. After
extensive testimony and argument, this court does not find the
inconsistencies to be material. We do not believe Brady places an
affirmative duty to disclose the respective lengths of the various ropes.
The Commonwealth produced these ropes to defense counsel for
inspection. They could have been tested, compared and measured in the
discretion of defense counsel. The Commonwealth certainly met its duty of
disclosure as to the ropes.
January January
Sunday
22, 201722, 2017
Page 2112
1110 of 2301
1299
73. Failed to disclose that someone fabricated a story that Hazel Show had
called home and spoken to Laurie from the school, and that Laurie had told
her mother that Michelle was there or on her way over
This is one version of the events of that morning which is reflected in
Sergeant Harnish's report. (Petitioner's Exhibit 1351.) It is likely that this
version reflects a misunderstanding that was communicated during the
course of the confusion that morning. This information is not in any way
exculpatory or favorable to petitioner.
74. Failed to disclose that Officer Weaver was not dispatched to crime
scene
The dispatch reports were available to defense counsel, as they were
available to counsel for the Commonwealth. In fact, Officer Weaver was
not specifically directed to report to the condominium. However, he heard
the call over his radio, was in the vicinity and followed proper procedure
and responsible conduct in responding to the call.
This "fact " is material only to the conspiracy theory which first surfaced at
the federal habeas hearing and was a significant part of the PCRA hearing.
Under the conspiracy theory, Robin Weaver went to the condominium
without being officially dispatched so as to begin his "frame up" of Ms.
Lambert. The conspiracy theory was never even suggested by the defense
at trial. Simply stated, there was absolutely no significance at trial as to
whether Officer Weaver was dispatched to the scene. The information was
not "material" under Brady and Giglio.
75. Failed to disclose that Ms. Lambert's telephone records showed no

telephone calls to the Show residence
During the period of time when Ms. Lambert was making the many
harassing and threatening phone calls to the Show residence, she was
making them from her apartment on Route 340 in Bridgeport. This is
within the same township as the Show home and then would have been
local calls. Detective Savage testified that he looked into telephone records
and determined that the telephone company did not keep records of local
calls. (N.T., PCRA at 4343-4350.) When Ms. Lambert and Mr. Yunkin moved
to Pequea, a rural township on the southwest of Lancaster City, they had
no telephone. It appears that there were no records to disclose.
76. Failed to disclose that the dispatch records show that Detective Savage
arrived on the scene at 9:17
There was testimony that the recorded time of Detective Savage's and two
other police officers' arrival at the scene was made arbitrarily. It is clear
that this record does not accurately reflect the time when any of them
arrived or left. (N.T., PCRA at 4690-4725) Lancaster County Wide
January January
Sunday
22, 201722, 2017
Page 2113
1111 of 2301
1299
Communications relies upon the officers to report their time of arrival.

Detective Savage, Officer Bowman and Corporal Schuler were all recorded
by Lancaster County Wide Communications as arriving at 9:17 a.m. In fact,
they each arrived earlier than 9:17 a.m. It seems likely that one of the
group, or someone else, reported them as present at 9:17 a.m. The time
coincides with the report by Officer Jan Fassnacht that he left the scene at
9:17 a.m.
77. Failed to disclose that Hazel Show failed to tell many people at the
murder scene that Laurie spoke until two hours after the murder
All police reports regarding what Mrs. Show said and what Mrs. Show did
not say on the morning of the murder were available to defense counsel.
Defense counsel had every available opportunity to raise these
discrepancies. In fact, petitioner's contention is not true. Mrs. Show told
Lisa Hinkle Billiter almost immediately after Laurie's death that Laurie had
spoken to her. See discussion of Laurie Show's Dying Declaration, Section
VII.A, supra.
78. Failed to disclose the postcard that Mr. Yunkin wrote Hazel Show
immediately after the murder, setting up Ms. Lambert
The phrase "setting up Lambert" is purely a product of petitioner's
counsel's argument. The postcard from a material witness to the mother of
the victim, having been reviewed by the court, does not appear to be
material. In fact, Mr. Shirk testified that the postcard was not exculpatory.
The contents of the postcard are reprinted in Section VII.G, supra. Further,
Mr. Shirk testified at the PCRA hearing that the postcard was not
exculpatory as to Ms. Lambert. (N.T., PCRA at 3520-21.)
79. Failed to disclose that the tip of the knife was in Buck's jacket
There is no clear evidence as to the location of the tip of the knife. Ms.
Buck testified that she put the tip of the knife in the pocket of her Dolphins
jacket and that she later discarded the tip at the Lambert/Yunkin
residence. Judge Cullen, then court-appointed counsel to Ms. Buck in 1992,
testified that he felt something sharp and metallic when he reached into
the jacket pocket during his closing argument in the Buck trial. He never
looked into the pocket and only assumed it was the tip of the knife. (N.T.,
PCRA at 7713.) Even if the tip of the knife was in Ms. Buck's jacket, that
does not exculpate Ms. Lambert in any way. It is, in fact, consistent with
Ms. Buck's story that Ms. Lambert at some point handed her the tip of the
knife and she put it in her jacket pocket. The Dolphins jacket was available
for inspection by Mr. Shirk at all times. There is no testimony to establish
that the Commonwealth ever knew that the knife tip was in the jacket
pocket. It stands to reason that the Commonwealth would have used the
knife tip as evidence at both the Lambert and Buck trials.
80. Failed to disclose that witnesses saw Ms. Buck wearing her sweatshirt
January January
Sunday
22, 201722, 2017
Page 2114
1112 of 2301
1299
inside-out at school
Carol Blackburn testified that Ms. Buck was wearing a white or gray or offwhite sweatshirt turned inside out when she reported to school after the
murder. (N.T., PCRA at 1119.) She was as available to defense counsel as
she was to the Commonwealth for an interview before trial. It is not a
Brady violation to fail to disclose information that is readily available to
the defense.
81. Failed to disclose that Ms. Buck's hands were swollen

Donna Mallik testified at the PCRA hearing that Ms. Buck's hands seemed
swollen. (N.T., PCRA at 3677.) She also testified at the 1992 trial, (N.T.,
Trial at 601-06), and could certainly have been cross-examined as to her
observations of Ms. Buck's hands. Again, Ms. Buck's involvement in the
murder, the conditions of her hands, the identity of her clothing, the
condition of her face and anything else which might implicate her does
nothing to exculpate Ms. Lambert. At all times, the Commonwealth offered
its theory of the case that both girls were present in the condominium and
both girls participated in the murder.
See Section VII.D, supra.
82. Failed to disclose that Ms. Buck admitted that her hands hurt on the
morning after the murder
83. Failed to disclose Officer Flory's interview with Laura Thomas

of the murder. There is a brief account of the discussion in Officer Flory's
report of January 17, 1992. The report does not contain Brady material.
Further, Mr. Shirk's cross-examination of Laura Thomas at trial
demonstrated that he was well aware of the facts related by Ms. Thomas
to Officer Flory.
84. Failed to disclose Officer Flory's interview with Brad Heisler

of the murder and was described by Officer Flory in his report of January
17, 1992. The report of the discussion does not contain Brady material.
85. Failed to disclose that Hazel Show saw Mr. Yunkin drive away from the
scene in the complex
January January
Sunday
22, 201722, 2017
Page 2115
1113 of 2301
1299
It is unclear that Mrs. Show saw Mr. Yunkin drive away from the complex
that morning. Her recollection, to the extent that she had one in 1991 and
1992, was communicated to Detective Savage. She was not able to give
him any specific information. From these facts, it is difficult to determine
exactly what Detective Savage should have disclosed. Mrs. Show did
testify that Detective Savage told her to let him know if her memory about
seeing a car that morning became clearer. See discussion of Hazel Show's
Recollection, in Section VII.G, supra.
86. Failed to disclose that Ms. Buck's sweatshirt had Laurie's blood on it
Petitioner has failed to establish that the white sweatshirt in evidence was
Ms. Buck's sweatshirt. The white sweatshirt which was marked Petitioner's
Exhibit 1002 was also introduced at the trial of this case in 1992. It is
identified on the evidence envelope as "white sweatshirt with blood stain
located on floor to victim's right side." It was examined by Donald Bloser
on March 13, 1992.
Ms. Buck has acknowledged that she was wearing a white sweatshirt at
the time of the murder. She also testified that she wore her Miami
Dolphins jacket in the Show condominium that morning. (N.T., PCRA at
6665-66.) This fact alone would make it highly unlikely that the white
sweatshirt worn by Ms. Buck would have any blood on it since it was
covered by a heavy jacket. Petitioner has asked the court to make a leap
from Ms. Buck's testimony about wearing a white sweatshirt to the
conclusion that the white sweatshirt in evidence was Ms. Buck's.
Petitioner's counsel showed the white sweatshirt, turned inside out, to
Carol Blackburn, the attendance officer at Penn Manor High School, during
the PCRA hearing. Ms. Blackburn acknowledged that the white sweatshirt,
worn inside out on Ms. Buck when she reported to school on December 20,
1991, was similar. She also acknowledged that there was nothing unique
about the sweatshirt and it was not unlike any other "whitish" sweatshirt.
(N.T., PCRA at 1123.)
In order to establish a Brady/Giglio violation on this issue, petitioner
should first establish that the white sweatshirt that "had Laurie's blood on
it" was, in fact, Ms. Buck's. She has not done this. She, therefore, has not
established a Brady violation.
See Section VII.M.3, supra.
87. Failed to disclose that Ms. Buck's sweatshirt had cuts in it made by a
sharp object
Ms. Buck testified at the PCRA hearing as to the appearance of the
sweatshirt she was wearing on the morning of the murder: A. It's white,
long sleeved with blue decorating glue that I had used, made it myself,
January January
Sunday
22, 201722, 2017
Page 2116
1114 of 2301
1299
had my name in the upper left hand corner and on the back it had 1992.
Q. So it had your name, Tabby, on it?
A. Yes.
Q. And it had 1992 on the back.
A. Yes.
Q. That was printing you placed on the sweatshirt yourself?
A. Yes.
(N.T., PCRA at 6625.)
Ms. Buck did not leave her sweatshirt in the Show condominium when she
and Ms. Lambert left that morning. When questioned as to what she was
wearing when she went to school later that morning, she testified:
Q. When you arrived at school that day, what were you wearing on the
upper part of your body?
A. The same sweatshirt I was wearing that morning.
Q. That's the same sweatshirt you described to us?
A. Yes.
(N.T., PCRA at 6659-60.)
By Ms. Buck's description, her sweatshirt was different from the one that
was entered into evidence in 1992. There has never been any proof that
the sweatshirt found at the crime scene was, in fact, Ms. Buck's
sweatshirt. Ms. Lambert contends that the police obtained Ms. Buck's
white sweatshirt during the investigation and then brought it back to the
condominium to put in the "staged" crime scene photographs. There really
is no proof of this, however. In fact, Ms. Buck describes a sweatshirt that
is different from the sweatshirt which was found in the condominium and
which appeared in the photographs. There can be no Brady/Giglio violation
on this point because there is no proof that the sweatshirt was, in fact, Ms.
Buck's.
88. Failed to disclose that Ms. Buck's sweatshirt appeared in the "faked"
crime scene photos
Whether the crime scene photographs were "faked" is discussed in Section
VII.M, supra. Regardless of whether the photographs were real or "faked,"
a white garment appears next to the body of Laurie Show. These
January January
Sunday
22, 201722, 2017
Page 2117
1115 of 2301
1299
photographs were available to the Commonwealth and to the defense

before and during trial. It is difficult to imagine how there could be a Brady
violation for failing to disclose what appears on a photograph produced to
defense counsel.
89. Failed to disclose that the rope obtained by police at K- Mart came in a
bag with a picture of a man pulling a Christmas tree
The package of the new rope which was introduced at trial to show the
similarity between the rope at the crime scene and the rope purchased by
Ms. Lambert at K- Mart showed a man pulling an evergreen tree, for
whatever relevance that might have. The rope was obtained in the course
of the Commonwealth's trial preparation. It does not constitute Brady
material.
90. Failed to disclose that the rope found at the river was 24" long, not
24.5 feet, as testified to by Detective Savage to Lambert's trial
91. Failed to disclose that the rope purported to be found at the crime
scene was 22 feet 5 inches
92. Failed to disclose that Ms. Buck's jacket had blood on it
In fact, in the testing done on the jacket prior to the Lambert trial, no
blood was found on the Buck jacket. Donald Bloser, of the Pennsylvania
State Police crime lab, testified that he took samples from discreet
sections of Ms. Buck's Miami Dolphins jacket and found no blood. (N.T.,
Trial at 609; N.T., PCRA at 194.) After the Lambert trial and in preparation
for the Buck trial, Mr. Bloser examined the jacket more thoroughly for
blood and found some blood in the area of the hood. The Commonwealth
was not aware that there was blood on the Buck jacket prior to the
Lambert trial. There was, therefore, nothing to disclose. In any event, this
information is not material for purposes of a Brady analysis.
93. Failed to disclose that Dr. Annese (a) worked with Hazel Show, (b) had
Mrs. Show over to his home for a party, (c) treated Laurie, (d) had treated
patients referred to him by Dr. Show, and (e) had received financial
benefits from Dr. Show's referrals
No testimony or any other evidence at the PCRA hearing established that
the Commonwealth had any knowledge of any relationship between Dr.
Annese and the Show family prior to the 1992 trial. Dr. Annese testified in
1992 and was available for cross-examination by the defendant as to the
basis for his opinions and as to any bias, interest or motive. At the PCRA
hearing, petitioner failed to establish that Dr. Annese's minimal
January January
Sunday
22, 201722, 2017
Page 2118
1116 of 2301
1299
involvement with the Show family in any way colored his trial testimony.
This is not a Brady violation for two reasons: (1) the information is not
"material" as that term is defined for Brady purposes; and (2) there is no
proof that the Commonwealth was aware of any relationship prior to trial.
94. Failed to disclose that Mr. Kleinhans saw Brad Heisler enter the
apartment prior to the police or medical personne l
95. Failed to disclose that the front door of the Show condominium was
"wide open" for Mr. Heisler and Mr. Kleinhans to enter and thus the door
neither closed nor locked automatically
96. Failed to disclose that Mr. Yunkin described the woman who waited on
him at McDonald's as white, older and with grayish hair, when he was
interviewed by the police in early 1992
Mr. Yunkin testified at the PCRA that he told the police that the person who
waited on him at the McDonald's was "an older woman and that she was
white." (N.T., PCRA at 4515.) This was not in a report provided to defense
counsel. Petitioner appears to contend that this information would have
been impeachment material for Yvette Rodriquez at trial. Ms. Rodriquez
testified that she was the manager at the McDonald's that morning and
that she observed Mr. Yunkin. She was not sure that she served him. (N.T.,
Trial at 592.) An inconsistency between Mr. Yunkin's description of the
person who served him and the actual appearance of Ms. Rodriquez is not
Brady material. There is nothing about this information which is
exculpatory or favorable to Ms. Lambert, nothing which would affect the
outcome of the case and nothing of any consequence which would impugn
the credibility of either Mr. Yunkin or Ms. Rodriquez.
97. Failed to disclose that the person who took the 7:35 a.m. call to 911
determined that Laurie Show was unconscious from the information
provided in the telephone call, and had training to make that
determination
According to the testimony of Richard Harrison of Lancaster County Wide
Communications, the 911 operators did not have formal training in
classifying calls as "unconscious person" or some other classification.
(N.T., PCRA at 4703-04.) He testified that "back in 1991 it was more or
less our in-house training and on-the-job experience at that time." (N.T.,
PCRA at 4704.)
The inference here is that a 911 operator/dispatcher made a diagnosis
that Laurie Show was "unconscious" based upon information give to
him/her with the benefit of sufficient training to make that determination.
January January
Sunday
22, 201722, 2017
Page 2119
1117 of 2301
1299
It appears from Mr. Harrison's testimony that there was not this kind of
training. It also appears from his testimony that "unconscious person" is
their highest level of priority and is a code used when someone is in a life
threatening condition. Whether Laurie Show was conscious or unconscious
when the 911 call was made, there is no question that she was in a very
serious and life threatening condition.
In any event, the 911 dispatch records were available to defense counsel
in 1992 if he believed these were material. There can be no Brady violation
for the failure to disclose information that could have been obtained by
defense counsel.

Petitioner contends that she must be released and cannot be retried under
Smith. In Section III.B.1.a, supra, we discussed the legal impact of Smith
in this case. Essentially, if the conduct of the prosecution in this case was
intentionally undertaken to prejudice Lisa Michelle Lambert to the point
that she was denied a fair trial, then Smith would apply and double
jeopardy would bar any subsequent retrial on these charges.
At various points in Section VII, supra, we discussed the allegations of
prosecutorial misconduct. We reviewed the claims regarding the "29
questions," Lawrence Yunkin's statement, Kathleen Bayan's story, the
involvement of Dr. Mihalakis, the river search, Ms. Lambert's statement,
and the crime scene photographs. In addition, we reviewed 66 allegations
of discovery or Brady/Giglio violations. We have considered all of these
points in our analysis of whether there was prosecutorial misconduct
under the PCRA, new evidence exculpatory to petitioner, or constitutional
violations of the Commonwealth's duty of disclosure. We have also
considered each of these allegations insofar as they might establish
intentional prosecutorial misconduct undertaken to prejudice defendant to
the point of the denial of a fair trial.
This is not a Smith case. There is not one item raised by petitioner and
proven by competent evidence which compares to the intentional acts of
misconduct in the Smith case. We find no evidence of any intentional
conduct by the District Attorney's Office or by the investigating police
officers which would establish conduct intentionally undertaken to
prejudice Lisa Michelle Lambert to the point of a denial of a fair trial.
VIII. CONCLUSION: THE QUESTION OF INNOCENCE
We are left with the question posed by our first reference in this opinion to
the elements of a PCRA claim: Was this a "fundamentally unfair"
conviction? Is Lisa Michelle Lambert an innocent woman wrongly
convicted? We have referred throughout this opinion to facts which
established guilt and which have been resolved in the post verdict stage
and in the PCRA proceeding. Many important facts were established in the
1992 trial and have been unshaken throughout the many petitions,
January January
Sunday
22, 201722, 2017
Page 2120
1118 of 2301
1299
motions, hearings and court orders entered across the history of this case.
We know that in the spring, summer and fall of 1991, Lisa Michelle
Lambert demonstrated, time and again, hostility and aggression toward
Laurie Show. We know of the many hysterical phone calls, the menacing
language and the relentless, threatening conduct. There is no question
that Ms. Lambert contemplated, over an extended time period, the
possibility of doing physical harm to Laurie Show. We find that Ms.
Lambert discussed killing Laurie Show on at least two occasions.
The witnesses in this case have established that Ms. Lambert enlisted
others to kidnap and assault Laurie Show, and that Ms. Lambert assaulted
Laurie Show at the East Towne Mall. We know that credible witnesses,
among them Hazel Show, Laura Thomas, Floyd Thomas, Rose Metzger, and
George Haas, established beyond any doubt that Ms. Lambert hated Laurie
Show and that Laurie Show was terrified of Ms. Lambert.
We find credible Tabitha Buck's testimony that Ms. Lambert came to her
home the night before the murder and arranged for Ms. Buck to
accompany her to Laurie Show's home. We find Ms. Buck's testimony that
Ms. Lambert arranged for Mrs. Show to be out of the condominium that
morning to be credible and we find there to be no question at all that Ms.
Lambert's purpose in going to the condominium that morning was to inflict
serious harm to Laurie Show.
In 1992, we found that Ms. Lambert bought a rope, ski masks, and gloves
and took these items, along with a knife from her kitchen, to the Show
condominium that morning. We reject the preposterous suggestion that
these items were for the purpose of cutting a Christmas tree.
We know that Ms. Lambert planned the events of December 20, 1991, and
we know that she participated in the assault leading to Laurie Show's
death. There are several versions of exactly what happened at or about
7:00 a.m. in the Show condominium that morning, but we have never
wavered from our belief as to the truth of that morning. It was our belief
in 1992, and remains our belief today, that Ms. Lambert went to that
condominium that morning to assault Laurie Show or to kill Laurie Show.
Even if her purpose had been "only" to assault Laurie, at some point
during the assault, Ms. Lambert formed the specific intent to kill. Injuries
such as those inflicted on Laurie Show were not inflicted accidentally. The
injuries to Laurie Show demonstrate that the person who inflicted them
had a specific intent to kill. We saw no reason in 1992 to believe that after
all the harassment, stalking, and threatening behavior that preceded
December 20, 1991, after enlisting Ms. Buck, planning the trip to the Show
condominium and obtaining the materials used for the crime, that Lisa
Michelle Lambert suddenly turned into a passive, terrified observer in the
condominium. Consistent with her actions toward Laurie Show in the
months before the murder and her activities on the day before the killing,
Ms. Lambert went to that condominium with a plan. Once inside, she
carried out that plan.
These are the facts as this court viewed them in 1992. Yet, there is a fall
January January
Sunday
22, 201722, 2017
Page 2121
1119 of 2301
1299
back position. What if Ms. Lambert had been telling the truth at trial and
the killer was really Tabitha Buck? Under the facts as testified to by Ms.
Lambert at trial, she was guilty of first degree murder on an accomplice
basis. Under Ms. Lambert's version of that morning, as presented at trial,
she planned to go to the Show condominium and she enlisted Ms. Buck to
go with her. She took certain items with her consistent with an intent to
inflict bodily harm to Laurie Show. She participated in the assault and, at
one point, held Laurie Show's legs down while Ms. Buck cut her throat. She
then fled the scene and took no steps to report this incident to the
authorities. When arrested, she presented an alibi story which she had
discussed with Mr. Yunkin and Ms. Buck. Ms. Lambert would be an
"accomplice" if she had the intent of promoting or facilitating the murder
and if she aided or agreed or attempted to aid Ms. Buck in planning or
committing the murder. 18 Pa. C.S. Section 306. From Ms. Lambert's
description of holding down Laurie's legs while Ms. Buck slit Laurie's
throat, we could reasonably conclude that she had the intent of
"promoting or facilitating" the killing and that she planned, or aided, or
attempted to aid Ms. Buck. In fact, we do not believe that is what
happened. Yet, based upon the story Ms. Lambert presented at trial, a
verdict of first degree murder on an accomplice basis would have been
supported by the evidence.
We know that Ms. Lambert then fled the scene. Regardless of whether she
was picked up in the condominium complex by Mr. Yunkin or whether she
was picked up by Mr. Yunkin on Oak View Road, Lisa Michelle Lambert fled
the murder in haste and did not look back.
In his closing argument, Mr. Kenneff suggested that whoever committed
this murder was guilty of first degree murder. This court believed that to
be true at the time and believes it to be true today. The crime scene
photographs, the autopsy photographs, the condition of the condominium,
and the condition of the body of Laurie Show led this court to one
inescapable conclusion: whoever performed these acts did so with a level
of rage completely inconsistent with any accidental killing or a death
incidental to a "prank." We firmly believed in 1992 that Lisa Michelle
Lambert drew the knife across the throat of Laurie Show, causing her
death. She was the only person with the level of emotion, the focus of
purpose and the clear opportunity to have performed that dreadful act.
There is no question that Ms. Lambert is not, and never will be, "innocent"
of this crime.
CRIMINAL
COMMONWEALTH OF : No. 0423 - 1992
PENNSYLVANIA:
January January
Sunday
22, 201722, 2017
Page 2122
1120 of 2301
1299
v.: Post Conviction Relief Act

LISA MICHELLE LAMBERT:
ORDER
AND NOW, this 24th day of August, 1998, upon consideration of the
petition filed under the Post Conviction Relief Act, 42 Pa. C.S.A. Section
9541, et seq. (1998 Supp.), the evidence admitted at the hearing and the
arguments of counsel, and for the reasons set forth in the attached
opinion, this court finds that petitioner has failed to prove that she is
entitled to relief under the Act. Therefore, her petition shall be denied.
BY THE COURT:
LAWRENCE F. STENGEL
JUDGE
ATTEST:
Copies to: Christina Rainville, Esquire
Christy H. Fawcett, Esquire
ADDENDUM TO OPINION
1. List of Documents Filed with the Court in this Case

2. The "29 Questions" - Petitioner's Exhibit 1119
Footnotes :
(Return to Table of Contents)
January January
Sunday
22, 201722, 2017
Page 2123
1121 of 2301
1299
1. Ms. Lambert's petition is governed by the PCRA, as amended on

November 17, 1995. The amended Act is applicable to all petitions filed
after January 16, 1996.
2. Brady v. Maryland, 373 U.S. 83 (1963).
3. The issues for consideration in Ms. Lambert's post verdict motions
included: error to deny defendant's motion for change of venue and/or
venire; error to deny the motion for sanctions relative to the alleged
prosecutorial misconduct in contacting defense expert, Dr. Isidore
Mihalakis; error to admit the statement of co-defendant Tabitha Buck;
error to allow the trier of fact to take notes during trial and potentially use
them during deliberation; error to affirm and read the Commonwealth's
points for charge Nos. 3 and 4; error not to grant a mistrial when the
request for supplemental discovery of Laura Thomas was not granted;
error not to grant a mistrial when the request for supplemental discovery
of Mrs. Show was not granted; error not to grant a mistrial when the
supplemental discovery of Richard Kleinhans was not granted; error not to
grant a mistrial when the prosecution withheld evidence that a jergo was
discarded and that they were aware of its location; error to qualify Dr.
Enrique Penades as an expert in forensic pathology since he was not board
certified; error not to grant a mistrial when the prosecution withheld from
discovery a portion of Yunkin's statement of February 4, 1992; error not to
grant a mistrial when the assistant district attorney asked defendant's
expert witness, Dr. Samuel J. Golub, two questions beyond his area of
expertise; and insufficient evidence existed to sustain the verdict.
4. The post verdict motions were filed on July 28, 1992. The last trial
transcript was filed on September 23, 1992, and a briefing schedule was
issued by the trial court on October 23, 1992. Counsel for defendant, at the
request of Ms. Lambert's family, requested additional time to file an
amended or supplemental brief in support of post verdict motions. Given
the gravity of charges and the many issues raised on appeal, the court
granted all of these requests for extensions of time. Defendant's last
motion was submitted to the court on June 3, 1994, and the matter was
ripe for disposition at that time.
5. There will be reference throughout this opinion to "the trial," "the post
verdict hearing," "the federal habeas hearing," and "the PCRA hearing."
The trial took place in July 1992 and resulted in a verdict of guilty of first
degree murder. The post verdict hearing was held on November 18 and 21,
1994, on defendant's claims of ineffective assistance of counsel and afterdiscovered evidence. The federal habeas hearing took place in the United
States District Court for the Eastern District of Pennsylvania in April 1997.
The PCRA hearing began on April 30, 1998, and continued through June
24, 1998.
6. The procedural posture of the case permitted the taking of testimony to
supplement the record on these two new issues. Ms. Lambert was
convicted of first degree murder and criminal conspiracy to commit
murder. At the time of sentencing, it was agreed between the assistant
district attorney and the defense attorney that the Commonwealth would
January January
Sunday
22, 201722, 2017
Page 2124
1122 of 2301
1299
seek a sentence on the first degree murder conviction only. Because the
first degree murder conviction carried a mandatory life sentence, the court
was not requested to impose a sentence on the criminal conspiracy charge.
Technically, defendant had never been sentenced on the criminal
conspiracy and, therefore, her appeal period from a judgment of sentence
from that charge had not yet expired. This accommodation to defendant at
the time of formal sentencing on the first degree murder charge resulted in
a "loophole" through which the defense sought to introduce new evidence
in the hope of obtaining a new trial. It appeared to the court at that time
that all parties recognized that the loophole existed, that the loophole was
not the result of inadvertence either by any of the parties or by the court,
and that it existed because of an accommodation to Ms. Lambert. It was on
this basis, then, that the court had the capacity to receive new evidence
and consider defendant's request for a new trial at the time of the post
verdict hearing in November 1994.
7. Ms. Lambert enjoyed the benefit of two court-appointed attorneys and
one court-appointed criminal investigator. Mr. Shirk was appointed within
a day or two of Ms. Lambert's arrest for the murder of Laurie Show. He
requested the appointment of Alan G. Goldberg, Esquire, to assist him in
the case with the death penalty phase, if necessary. Both are experienced,
respected members of the Lancaster County bar who specialize in criminal
defense cases. Mr. Goldberg participated in the defense effort throughout
the investigation and trial. Mr. Shirk conducted the bulk of the defense on
guilt at trial. Mr. Goldberg assisted in arguing points of law to the court
and in the examination of some witnesses. Mr. Goldberg handled the death
penalty phase of the trial exclusively. Mr. Shirk appeared as a witness on
Ms. Lambert's behalf at the death penalty phase.
8. Prior to the Lambert trial, Mr. Yunkin entered into a plea agreement with
the Commonwealth. Essentially, the Commonwealth offered a plea of guilty
to obstruction of justice in exchange for testimony at the Lambert trial and
at the trial of Ms. Lambert's co-conspirator, Tabitha Buck. The condition of
the plea agreement was that Mr. Yunkin testify truthfully. After the
Lambert trial and after the Buck trial, Mr. Yunkin entered a plea, not to
obstruction of justice, but to third degree murder. The Commonwealth
indicated that it was justified in seeking the more serious charge because
Mr. Yunkin was not truthful in his testimony at the Lambert trial.
9. The evidence presented in the district court in very large part was
obtained through federal discovery and had previously been unavailable in
state court. For example, the Commonwealth was compelled to produce
the working notes of the prosecutor from the 1992 trial. Habeas
petitioners, unlike usual civil litigants in federal court, are not entitled to
discovery as a matter of ordinary course. Rule 6 of the Federal District
Court Rules Governing Habeas Corpus Cases provides that any party may
utilize the processes of discovery available under the Federal Rules of Civil
Procedure (Rules 26-37) if, and to the extent that, the judge allows such
discovery upon a showing of good cause. In the Advisory Committee Notes
to Rule 6, mention is made of the fact that Rule 6 is consistent with the
Supreme Court pronouncement in Harris v. Nelson, 394 U.S. 286 (1969),
regarding discovery in federal habeas proceedings: "[I]t is clear that there
January January
Sunday
22, 201722, 2017
Page 2125
1123 of 2301
1299
was no intention to extend to habeas corpus, as a matter of right, the

broad discovery provisions
. . .of the new [Federal Rules of Civil Procedure]."
10. Petitioner's pleadings and briefs frequently characterize the
proceedings which occurred in the federal district court as a "trial" and
also refer to "pretrial" conferences. (See, e.g., Petitioner's Motion to File
the Federal Record at paras. 24-25, 28-29, 31-32.) There was no "trial" in
the district court; rather, the court held a habeas corpus hearing pursuant
to 28 U.S.C. Section 2254. The only trial ever held in Ms. Lambert's case
took place in the Court of Common Pleas of Lancaster County. That trial
resulted in a guilty verdict and sentence of life imprisonment for Ms.
Lambert's murder of Laurie Show.
11. The district court did not address other grounds raised in Ms.
Lambert's petition regarding ineffective assistance of counsel and afterdiscovered evidence.
12. In the habeas corpus proceeding, the Commonwealth was represented
by the Lancaster County Office of the District Attorney.
13. For the purpose of appealing from the grant of habeas corpus relief,
the District Attorney's Office retained private counsel.
14. Petitioner was free from April 21, 1997, until February 4, 1998,
approximately ten months.
15. On May 6, 1998, the PCRA proceeding was interrupted when the court
received an opinion from a two-judge motions panel of the Third Circuit
remanding the Fed. R. App. P. 23 application to the district court "with
instruction to grant the motion for release with such conditions as the
court considers appropriate" pending the disposition of Ms. Lambert's
petition for writ of certiorari. This order was immediately followed by an
order on May 6, 1998, from the Eastern District Court scheduling a hearing
in Philadelphia for May 8, 1998, directing the Commonwealth to
"immediately deliver Ms. Lambert to the custody of the Court." Ms.
Lambert was transported from the Lancaster County Prison to federal
court on May 7, 1998, pursuant to a further order from the district court
specifically setting forth the procedure for transfer of custody. Also on May
7, 1998, the Commonwealth made an emergency application to stay the
Third Circuit order which was granted the same day by the same motions
panel, pending the Commonwealth's application for rehearing if filed in a
timely fashion. On May 8, 1998, the Commonwealth filed an application for
rehearing with a suggestion for rehearing en banc which was granted by
the Court. Despite the Third Circuit's stay of its May 6, 1998, order on May
7, 1998, the district court nonetheless required the parties to be present at
the "release" hearing on May 8, 1998, as previously scheduled. Following
the hearing, upon stipulation of counsel, Ms. Lambert was returned to the
Lancaster County Prison and the PCRA hearing resumed on May 11, 1998.
The Commonwealth's petition for rehearing en banc was subsequently
granted followed by an order by the Chief Judge on May 15, 1998, vacating
January January
Sunday
22, 201722, 2017
Page 2126
1124 of 2301
1299
the Motions Panel's order and opinion of May 6, 1998.

16. Ms. Lambert's counsel filed a petition with the Pennsylvania Supreme
Court for the exercise of plenary jurisdiction and emergency motion for
writ of prohibition to prevent reincarceration on January 28, 1998. On
January 30, 1998, the Supreme Court denied Ms. Lambert's petition and
emergency motion, without prejudice to her right to refile, as there was no
matter pending before any tribunal within the Commonwealth. Thereafter,
the PCRA petition was filed.
17. Given the number of complex factual and legal issues and the lengthy
nature of the proceeding, this court requested, on June 9, 1998, an
additional 60 days to dispose of this matter. Petitioner filed a four-page
objection to this court's request for extension. We were notified on June
18, 1998, by letter from the Prothonotary of the Pennsylvania Supreme
Court, that the Supreme Court had granted the request for a 60-day
extension to conclude this PCRA matter, the time being calculated from
June 25, 1998.
18. The court actually received a copy of the original order dated February
25, 1998, and a revised order dated February 25, 1998.
19. The motion to compel was ultimately filed with the Office of the Clerk
of Courts on March 9, 1998. During this PCRA proceeding, the court
permitted the parties to submit motions, petitions and briefs via facsimile.
This was done to accommodate the expedited schedule imposed by the
Pennsylvania Supreme Court and to allow the court to consider the parties'
filings as soon as possible. It was our procedure then t hat the originals be
filed by regular mail with the Clerk of Courts. Attached to this opinion is an
addendum which lists the documents filed in this case with a listing of the
date each document was received in chambers as well as the official filing
date with the Clerk of Courts. This addendum is attached to facilitate
review of the record by the appellate courts.
20. These Rules have been adopted by the Pennsylvania Supreme Court
and govern the conduct of any attorney practicing in Pennsylvania.
21. On March 17, 1998, Philadelphia Newspapers, Inc., t/a The
Philadelphia Inquirer, filed an action in the United States District Court for
the Eastern District of Pennsylvania seeking an injunction lifting the "gag"
order. See Philadelphia Newspapers, Inc., publisher of The Philadelphia
Inquirer v. Lancaster County Court of Common Pleas and The Honorable
Lawrence F. Stengel, Civil Action No. 98-CV-1393 (1998). After a hearing
on the matter, Philadelphia Newspapers' request for a temporary
restraining order was denied. The court referred to the litigation in the
Lancaster County Court of Common Pleas and noted that principles of
"common sense and comity" mandated that the objections to the order be
raised first before the judge who entered the order.
22. When the Third Circuit vacated the district court's order of April 21,
1997, the proceedings before the district court were rendered void ab
initio. See Stern v. Williams, 970 F.2d 1043, 1054-55 (2d Cir. 1992), cert.
January January
Sunday
22, 201722, 2017
Page 2127
1125 of 2301
1299
denied, 508 U.S. 906 (1993) ("judgment [which has been vacated] or set
aside has no preclusive effect"); United States v. Williams, 904 F.2d 7, 8
(7th Cir. 1990) (vacated judgment "place[s] the parties in the position of
no trial having taken place at all"); Rushton Mining Co. v. Morton, 520 F.2d
716, 719 (3d Cir. 1975) (by definition, vacatur renders lower court's order
"void ab initio "). The Third Circuit's decision vacating the district court's
judgment not only found the district court's hearing was invalid because it
was without any authority to conduct that proceeding but it expressly
refused to give any weight to the district court's determinations: "[W]e do
not give weight to the district court's factual findings in this appeal." 134
F.3d at 509 n.1. The merits panel said that "[r]esolution of these difficult
questions must. . .await the appropriate forum." Id. at 524-25. Among the
"difficult questions" identified were "serious factual issues concerning the
district court's finding that Lambert was actually innocent of first degree
murder." Id. at 524. The "appropriate forum" referred to is "the state
courts." Id.
23. See Section VII.P on admissions, infra.
24. The court held that as Ms. Lambert had been found guilty of an offense
punishable by life in prison, Rule 4009 of the Rules of Criminal Procedure
clearly prohibits any entitlement to bail. There was simply no basis in law
or fact for this court to grant the request for bail.
25. Rule 1502 of the Pennsylvania Rules of Criminal Procedure entitled,
"CONTENT OF PETITION FOR POST-CONVICTION COLLATERAL RELIEF;
REQUEST FOR DISCOVERY," was amended in 1997 to address requests for
discovery in PCRA petitions. Specifically, Paragraph (a)(16) requires that a
request for discovery be included in the petition: "(a) A petition for postconviction collateral relief. . .shall contain substantially the following
information:. . .(16) if, applicable, any request for discovery." Paragraph
(e) sets forth the standards for permitting discovery. Except as provided in
Rule 1502(e)(2) for death penalty cases, no discovery is permitted at any
stage of the proceedings, except upon leave of court with a showing of
exceptional circumstances. Pa. R. Crim. P. 1502(e)(1). This language
implements 42 Pa. C.S.A. Section 9545(d)(2): "No discovery, at any stage
of proceedings under this subchapter, shall be permitted except upon
leave of court with a showing of exceptional circumstances." Ms. Lambert
submitted nothing which demonstrated, in any substantive manner, that
any truly exceptional circumstances warranted granting her request for
discovery. The "proof" of "exceptional circumstances" was the same
phrase which pervades her filings in this court and elsewhere, that she is
"the victim of the worst prosecutorial misconduct in the history of the
English-speaking world." Such a conclusory characterization, by itself, was
insufficient to meet the requirements of Rule 1502(e). Ms. Lambert's
situation is neither different from, nor more substantive than, that which
any PCRA petitioner might be expected to claim, namely, that he or she
"didn't do it." Moreover, much of what Ms. Lambert sought to obtain in
discovery was otherwise available to her.
26. These arguments were heard via a speaker phone in the courtroom to
accommodate the interest of the public and because of security concerns
January January
Sunday
22, 201722, 2017
Page 2128
1126 of 2301
1299
voiced by petitioner's counsel.

27. The motion for sanctions was filed with the Clerk of Courts one day
after the April 14, 1998, amended order limiting publicity was entered. The
persons who were the subject of petitioner's motion for sanctions were
subject to restrictions which were removed by the amended gag order.
28. This court is cognizant of Rule of Criminal Procedure 1504 which
requires the appointment of counsel for a defendant on her first post
conviction relief petition if the court is satisfied that "the defendant is
unable to afford or otherwise procure counsel." Pa. R. Crim. P. 1504(a)
(emphasis added). Under the circumstances of this case, we found that
petitioner was able to "otherwise procure counsel."
In Commonwealth v. Duffey, No. 156 Capital Appeal Docket (May 21,

1998) (to be reported at: 713 A.2d 63), the Supreme Court considered the
question of whether the appellant's pro se status was a "fiction" given the
fact that attorneys filed and signed notices of appeal from two trial court
orders. The Court cited Rule 9020 of the Pennsylvania Rules of Criminal
Procedure which states that all motions for relief shall be made by written
motion and shall be signed by the person or attorney making the motion.
The signature of an attorney "s hall constitute a certification that the
attorney has read the motion, that to the best of the attorney's knowledge,
information, and belief there is good ground to support the motion, and
that it is not interposed for delay." Pa. R. Crim. P. 9020(b)(1). The
Supreme Court held that nothing in Rule 9020 permits an attorney to sign
pleadings for pro se defendants. "To the contrary, an attorney's signature
is a legal certification that gives good cause to support the pleading, and
an attorney cannot avoid that certification through the addition of creative
language describing the attorney as a mere 'preparer' on behalf of a pro se
defendant. Thus, when an attorney signs and files a pleading for an
unrepresented defendant, that attorney will be deemed to represent that
defendant. We do not condone counsel's attempts to file a notice of appeal
without entering an appearance in this case." The Supreme Court
concluded that the attorneys who signed the notices of appeal became the
defendant's attorneys of record for the appeal when they filed the notices
with the court. (Slip op. at 11-12.) Likewise, the attorneys in this case,
Christina Rainville and Peter Greenberg, signed the PCRA petition, and
every other document filed with the court, as counsel for Ms. Lambert.
These attorneys became Ms. Lambert's attorneys of record for this PCRA
proceeding when they filed the petition with this court on February 2,
1998. Clearly, petitioner was able to "otherwise procure counsel" and did
not require court appointment of counsel in this case.
29. Acknowledging the need for a showing of exceptional circumstances to
justify discovery in this PCRA, petitioner claimed that discovery was
warranted because "the Commonwealth is presenting new witnesses
against Petitioner and neither Petitioner nor her counsel have the slightest
idea who these individuals are, what there [sic] testimony is going to be,
January January
Sunday
22, 201722, 2017
Page 2129
1127 of 2301
1299
whether deals or other promises have been made in exchange for the
testimony, or whether they are withholding other evidence favorable to
Petitioner." The court did not find these ci, rcumstances to be exceptional.
30. Giglio v. United States, 405 U.S. 150 (1972).
31. The case law indicates that there is no requirement that the
Commonwealth furnish investigative services to PCRA petitioners. See
Commonwealth v. Strong, 522 Pa. 445, 563 A.2d 479 (1989);
Commonwealth v. Woods, 394 Pa. Super. 223, 575 A.2d 601 (1990). See
also Commonwealth v. Gelormo, 327 Pa. Super. 219, 475 A.2d 765 (1984)
("There is no constitutional mandate, either federal or state, that experts
be appointed at public expense to assist in preparation of a defense
whenever requested by one accused of a crime").
32. Petitioner's counsel indicated on the record at the time of argument on
this motion that the motion in limine to exclude the testimony of Dr.
Burton was withdrawn.
33. See Section VII.C, infra.
34. The testimony in the federal district court of Professor Wolfram
involved the ex parte communication of Assistant District Attorney John A.
Kenneff with Dr. Isidore Mihalakis in connection with Ms. Lambert's civil
trial in 1992. Specifically, this expert testified that such conduct, that is,
contacting an expert witness for the defense without the consent of
defense counsel, was a "no-brainer." (Notes of Testimony ("N. T."), Habeas
Hearing at 1007.) The interpretation of the Rules of Professional Conduct
and the Rules of Criminal Procedure is a legal issue to be decided by a
court, for which use of an expert would be wholly inappropriate. A court
may not abdicate its role to determine the ultimate issue by allowing
expert testimony. See Commonwealth v. Neal, 421 Pa. Super. 478, 481,
618 A.2d 438, 439 (1992) (improper for court to admit testimony of an
attorney addressing the legal issue to be decided by the court). For these
reasons, this court granted the Commonwealth's motion in limine.
35. The court issued an order on April 13, 1998, scheduling the PCRA
hearing to begin on Monday, April 27, 1998. In furtherance of that order,
on April 14, 1998, a writ of habeas corpus was issued directing the
superintendent at the Edna Mahan Correctional Facility for Women in New
Jersey to produce Ms. Lambert at the PCRA hearing in Lancaster on April
27, 1998. Petitioner resisted any effort to effectuate her transfer to
Lancaster County Prison. Ms. Lambert's counsel went so far as to send a
letter to New Jersey Assistant Attorney General Ronald Bollheimer
essentially advising him that Ms. Lambert was protesting being moved,
pursuant to the writ issued by this court, from the New Jersey prison,
where she was ordinarily confined, to the Lancaster County Prison, and
threatening to hold New Jersey officials responsible for what she claimed
would be compliance with an illegal order. The strong inference in
counsel's correspondence, if not an o utright demand, was that New Jersey
should refuse to obey the court's order. On April 22, 1998, the court
received a letter from petitioner's counsel informing it of Ms. Lambert's
January January
Sunday
22, 201722, 2017
Page 2130
1128 of 2301
1299
filing of her petition for writ of certiorari and motion for release from
custody pursuant to Fed. R. App. P. 23. In this letter, counsel referred to
Supreme Court Rule 36(1), which they claimed applied to Ms. Lambert so
long as she remained in custody. Rule 36 governs the custody and release
of federal and state prisoners pending appellate review of a decision in a
federal habeas corpus proceeding. Specifically, Rule 36(1) provides that
pending review of a decision in a federal habeas corpus proceeding, "the
person having custody of the prisoner shall not transfer custody to another
person" without the permission of the court, justice, or judge rendering
the decision that is under review. Petitioner's counsel claimed that no such
authorization existed for the transfer of Ms. Lambert from the Edna Mahan
Correctional Facility to the Lancaster County Prison for purposes of the
PCRA proceeding which was to commence on April 27, 1998. Through a
series of telephone calls and letters, the Pennsylvania Department of
Corrections confirmed for the court that Ms. Lambert is and always has
been in the custody of the Pennsylvania Department of Corrections and
that, although convicted in Pennsylvania, is incarcerated in the New Jersey
facility pursuant to the provisions of the Interstate Corrections Compact,
61 P.S. Section 1061 et seq. (1998 Supp.). Ms. Lambert's official status is
as a prisoner of the Pennsylvania state system. Therefore, the
Pennsylvania Department of Corrections is the "custodian" of Ms. Lambert.
Based upon this information, the hearing was rescheduled for April 29,
1998, and again a writ of habeas corpus issued directing the
superintendent at the Edna Mahan Correctional Facility to produce Ms.
Lambert at the hearing on April 29, 1998. Once the status of custodian was
confirmed, an application, pursuant to Rule 36.2, was filed by the
Commonwealth with the Third Circuit seeking authorization for Ms.
Lambert's transfer to the Pennsylvania prison authorities. That
authorization was obtained on April 29, 1998. An order was entered on
April 29, 1998, again directing the superintendent to produce Ms. Lambert.
She was transferred to Lancaster on the evening of April 29, 1998. As the
hearing was scheduled to begin on April 29, 1998, the court heard oral
argument on several outstanding motions on April 29, 1998, but heard no
testimony in t he case until petitioner was present in the courtroom on
April 30, 1998.
36. The 1995 amendments substituted the word "changed" for the word
"affected." This amendment appears to have substituted a more strict test
from what had been in place before.
37. Renee L. Schuler is currently a lieutenant with the East Lampeter
Township Police Department. In 1991-1992, she had the rank of corporal
with the same department.
38. Counsel for petitioner miscited and misr, epresented the law when
presenting legal argument to the court on many occasions. See, e.g.,
petitioner's reliance on Commonwealth v. Wells, 322 Pa. Super. 380, 469
A.2d 672 (1983), appeal after remand, 345 Pa. Super. 623, 496 A.2d 855,
rev'd, 513 Pa. 463, 521 A.2d 1388 (1987), in support of her motion to file
the federal habeas record as the record of this PCRA proceeding,
Commonwealth v. Bonaparte, 366 Pa. Super. 182, 530 A.2d 1351 (1987)
(plurality), in support of her motion for bail, and Commonwealth v. Reese,
January January
Sunday
22, 201722, 2017
Page 2131
1129 of 2301
1299
444 Pa. Super. 38, 663 A.2d 206 (1995), in support of her motion to
exclude the expert testimony of Dr. Levin and all evidence not introduced
at the 1992 trial and to limit the Commonwealth's witnesses.
39. The notes of testimony for this PCRA proceeding were lodged with the
Clerk of Courts on August 3, 1998. There are more than 8,000 pages of
testimony contained in 36 bound volumes. Counsel requested 30 days to
review the notes of testimony and file objections to the transcript with the
court. Given the enormity of the record, this request was granted on
August 11, 1998. Therefore, citations in this opinion will be to the
"unofficial" notes of testimony which are subject to change at a later date.
40. Detective Solt is presently employed by the Lancaster County District
Attorney's Office. In 1991 and 1992 he was a corporal with the
Pennsylvania State Police and assisted in the investigation of the Show
murder.
41. Ronald W. Savage was a detective with the East Lampeter Township
Police Department in 1991-1992. At the time of the PCRA hearing, he was
a district justice.
42. A federal court has offered the following definition: "A 'hostile'
witness, in the jargon of evidence law, is not an adverse party but a
witness who shows himself or herself so adverse to answering questions,
whatever the source of the antagonism, that leading questions may be
used to press the questions home." Rodriquez v. Banco Central Corp., 990
F.2d 7, 12-13 (1st Cir. 1993).
43. The assumption, of course, is that the federal investigating authorities
will be moved by what is decided here. It is already clear that the federal
courts disregarded findings of fact made by this court in the 1992 trial,
e.g., the dying declaration and the import of the "29 questions." It is
already clear that Mr. Greenberg has taken a position that no court should
give any deference to this court's findings and it is clear that whatever
investigation is being done is at the request of the federal district court
and by federal authorities, and not at the behest of any state court or by
state authorities.
44. In the July 19, 1994, opinion, this court erroneously stated that the
murder took place on the morning of December 21, 1991. In , fact, the ,
murder took place on D, ecember 20, 1991. The questioning of the
suspects took place in the early morning hours of December 21, 1991. For
the sake of clarity, we corrected the date in the material quoted above.
The mistake remains in the original.
45. Now referred to as the "29 questions."
46. It appears that the district court had reservations about the credibility
of Mr. Kleinhans's testimony. In the habeas corpus opinion, the district
court discussed this court's findings of fact as set forth in the slip opinion
cited above. Where this court's discussion of Mr. Kleinhans is quoted in the
January January
Sunday
22, 201722, 2017
Page 2132
1130 of 2301
1299
federal court opinion, the district court included a footnote which reads as
follows:
We note, although this does not play a part in our decision, the following
excerpts from Mr. Kleinhans's testimony at the habeas hearing:
Q. I noticed in here that you have a little hard time hearing what is being
said.
A. Yes.
Q. Back in '91, did you also have a hard time hearing as well?
A. Not as much as now, no.
Q. Was it okay then?
A. It wasn't okay. But -Q. It was not okay?
A. No.
Lambert v. Blackwell, 962 F. Supp. at 1524 n.7.
The only possible purpose to include a reference to Mr. Kleinhans's

testimony in federal district court about his ability to hear would be to cast
doubt on this court's reliance on Mr. Kleinhans in 1992. In fact, this court
had every opportunity to observe Mr. Kleinhans as he testified and counsel
for defense had every opportunity to cross-examine Mr. Kleinhans on his
ability to see, to hear or to know the things about which he testified. His
ability to hear what was going on on December 20, 1991, was a part of our
assessment of his credibility. The federal district court's reference to this
could have only been intended to cast doubt on our finding that Mr.
Kleinhans was credible. The proper place to assess Mr. Kleinhans's
credibility in this case was in 1992, not retrospectively in 1997.
47. Subsequent attempts at the state court PCRA hearing in 1998 to use
January January
Sunday
22, 201722, 2017
Page 2133
1131 of 2301
1299
these depositions for impeachment purposes evidenced poorly focused

questioning which provided more obfuscation than explication of the
issues.
48. For the reader who suspects that this court is attempting to match the
hyperbole of the federal habeas proceeding, one might question why the
federal district court was referring to the 1992 trial as the "alleged trial"
on the fourth day of a three-week hearing. (See N.T., Habeas Hearing at
949.)
49. Exhibit A to the PCRA petition, which will be referred to throughout
this opinion, was attached to Petitioner's Second Motion for Leave to
Amend, which was filed with the court on June 10, 1998, and granted on
June 16, 1998. Exhibit A contains the listing of petitioner's claims.
50. Actual innocence is actually a creation of federal case law, not the
habeas statute. A commentator has noted: "The habeas statute, of course,
makes no mention of 'actual innocence' as a criterion for gaining access to
a habeas forum. Thus, the pervasive role that innocence currently occupies
in the jurisprudence illustrates the Court's common-law approach to
defining the scope of the writ." Jordan Steiker, Innocence and Federal
Habeas, 41 U.C.L.A. L. Rev. 303, 388 (1993).
51. The "ward" is an unofficial, pejorative designation for a large area of
downtown Lancaster.
52. Later, under oath in a courtroom, Ms. Lambert testified that this was,
in fact, her plan. Her only quarrel was that she never told the kids that she
was going to "slit Laurie's throat." Much later, in a federal courtroom,
where Michelle, now called Lisa and represented by two lawyers from
Philadelphia, said that the "slit her throat" language in a police report was
a fabrication and a violation of her constitutional rights.
53. Recently, at the PCRA hearing, Ms. Buck testified that she knew the
night before the murder that Mrs. Show was going to be gone. She had
said under oath last year that she did not know it until the morning of the
murder.
54. If Michelle had really helped Laurie get out of the condo, there must
have been blood all over the floor. The police had to clean the blood up to
prove Michelle was lying.
55. Dr. Larson's opinions as to the possibility of speech were, in effect,
medical conclusions.
56. It is interesting to note that the federal district court sought to
discredit the trial testimony of Dr. Penades by reference to an interview he
gave to a reporter from the Lancaster New Era and reported in that
newspaper on April 1, 1997. It appears that the reporter, Andrea S. Brown,
testified in the habeas proceeding as to her conversation with Dr. Penades.
The district court noted that Dr. Penades "may well have retracted most or
January January
Sunday
22, 201722, 2017
Page 2134
1132 of 2301
1299
all of his trial testimony" in that interview. See Lambert v. Blackwell, 962
F. Supp. at 1528-29 n.13. The testimony of Ms. Brown was offered by
petitioner in this case. We ruled that Ms. Brown's testimony as to an outof-court statement made to her by Dr. Penades, and, offered for its truth,
was hearsay.
57. There is little question that Dr. Larson appeared as much as an
advocate as he was an expert witness. In the federal proceeding, he took a
somewhat more aggressive posture. There, Dr. Larson offered an opinion
that the carotid artery was cut and went on to say that this meant, in
short, that Laurie Show could not possibly have spoken. (N.T., Habeas
Hearing at 54, 61, 73.) It was enough of a stretch for him to say that the
carotid was cut. He went completely beyond his realm of expertise into the
realm of medical opinion by testifying on the significance of the cut
carotid. (N.T., Habeas Hearing at 73-74.) Perhaps because the evidentiary
standards are different from federal to state court, Dr. Larson was not
asked about the significance of the cut carotid artery at the PCRA hearing.
In addition, when asked by Mr. Madenspacher in federal district court how
he reconciled his testimony with the testimony of the two physicians who
actually looked into the neck of Laurie Show and observed that the carotid
was intact, Dr. Larson simply stated that he believed they were not telling
the truth. (N.T., Habeas Hearing at 112-13.)
58. In fact, he testified that he did not review the report and noted that he
really meant to say that the victim was Laurie Show. (N.T., PCRA at 3158.)
59. Dr. Burton expressed serious reservations about Dr. Baden's judgment
in making that statement. He stated, when asked about Dr. Baden's
willingness to rely on the diagnosis made by an EMT: "My belie f is that
testimony will haunt Dr. Baden." (N.T., PCRA at 6980.)
60. In fact, what Mr. Zeyak identified as the severed carotid artery was
later identified by Roger J. Levin, M.D., as musculature, which was partly
torn by the knife.
61. Dr. Levin testified at the PCRA hearing and in federal court that, at
least theoretically, the injury to Laurie Show's neck could have been
repaired. He acknowledged the difficulty transferring her to a competent
trauma center and does not believe the failure of medical personnel to
resuscitate her was in any way remiss. Simply by way of comparing this
wound to other damage to the throat and neck which he has observed in
surgery, he offered the opinion that under ideal circumstances, a
correction could have been made. The medical school professor and throat
surgeon was then questioned:
THE COURT: So it is your testimony you could have fixed this?
January January
Sunday
22, 201722, 2017
Page 2135
1133 of 2301
1299
THE WITNESS: Sure.

THE COURT: That it would all be -- just like that (snapping fingers)?
THE WITNESS: Oh, not like that, but a tracheostomy, but it is certainly
repairable. BY MR. GREENBERG:
Q. Well, is it your testimony that we don't need you to fix it, that it
would just fix by itself?
THE COURT: Heal by itself, like a wound on the fingers?
THE WITNESS: No. I think it needed to be closed, but I think had it not
been closed, over time it would have closed, assuming she could have
breathed.
THE COURT: And it would all grow back together and she'd be normal.
THE WITNESS: Yes. Essentially.
THE COURT: Do you also think that severed limbs regenerate
themselves?
THE WITNESS: No, they don't.

62. This statement was admitted under the "excited utterance" exception
to the hearsay rule.
63. The federal district court, in support of its conclusion that the vagus
and laryngeal nerves were severed thereby making speech impossible,
dismissed Mrs. Show's testimony of the dying declaration as the rantings
of a hysterical woman in such emotional upheaval that she could not
accurately recall whether, in fact, her daughter spoke to her before her
death or whether some unscrupulous policemen exploited the situation for
their good by suggesting that her daughter spoke. The court stated:
At the end of her dramatic testimony. . .Mrs. Show reiterated her belief
that her daughter said, "Michelle did it.". . . We have not the slightest
January January
Sunday
22, 201722, 2017
Page 2136
1134 of 2301
1299
doubt that this constitutes Mrs. Show's sincere belief. But amid the
maelstrom of emotions that day, it is not hard to see how she could be
mistaken--or, worse, suggested--into this belief. The earliest accounts
by East Lampeter Police, as confirmed by their testimony before us,
was that Hazel Show, understandably hysterical, repeated over and
over, 'It was a setup! Michelle did it!' . . . It was at this world-ending
time a small step to make her deduction into a recollection that her
daughter said those words. And it is a measure of the depressing
record before us that we cannot exclude the possibility that some law
enforcement official suggested this small step to her.
962 F. Supp. at 1529 n.13 (citations omitted).

64. The document actually contained 31 questions and answers, but only
29 of these are numbered. During the 1992 trial and the post verdict
hearing and arguments, the document was referred to as the
"questionnaire." During the PCRA hearing, counsel and the witnesses
referred to this document as the "29 questions" and that designation will
continue in this discussion.
65. In the federal habeas proceeding, the district court appeared to find
something wrong with this argument. In fact, it is an elementary tenet of
the law that a fact finder is always free to accept all or part or none of the
evidence offered. See Pa. SSJI (Crim) No. 4.17(1) ("[Y]ou must judge the
truthfulness and accuracy of each witness's testimony and decide whether
to believe all or part or none of that testimony"), citing Commonwealth v.
Williams, 323 Pa. Super. 512, 521-22, 470 A.2d 1376, 1381 (1984);
Commonwealth v. Dolny, 235 Pa. Super. 241, 250-51, 342 A.2d 399, 404
(1975). To somehow suggest that the prosecutor was dishonest for
making this argument or that the court was less than alert for accepting
the argument is simply to misunderstand basic criminal trial practice.
67. Petitioner's Exhibit 1474 appears to have surfaced with Ms. Lambert's
federal habeas petition and was not involved in any prior proceeding.
68. The Federal Rules of Evidence do not seem to provide for expert
January January
Sunday
22, 201722, 2017
Page 2137
1135 of 2301
1299
testimony on the subject of witness credibility. The federal district court's

opinion contains no citation to any authority, statute, case or otherwise,
which would support admission of such testimony. The best we have is the
court's description of the testimony as "dramatic." In state court criminal
cases, the term "dramatic" is not a synonym for "relevant" or
"admissible."
69. See Commonwealth v. O'Searo, 466 Pa. 224, 352 A.2d 30 (1976)
(expert testimony of clinical psychologist to substantiate and corroborate
the defendant's version of the critical events and the case was prohibited);
Commonwealth v. Evans, 412 Pa. Super. 332, 603 A.2d 608 (1992)
(reversible error to admit detective's testimony as to child sexual abuse
accommodation syndrome as such testimony was proffered solely to
enhance the witness's credibility after defense counsel pointed out that
the children did not immediately report abuse); Commonwealth v. Purcell,
403 Pa. Super. 342, 589 A.2d 217 (1991) (expert testimony on dynamics
of child sexual abuse may not be used by Commonwealth to bolster
credibility of alleged victim of child abuse; child had not reported alleged
sexual abuse until six and one-half years after the first incident);
Commonwealth v. Smith, 389 Pa. Super. 626, 567 A.2d 1080 (1989)
(counsel ineffective for not objecting to expert's opinion as to the truth
telling capabilities of a seven year old child); Commonwealth v. Newman,
382 Pa. Super. 220, 555 A.2d 151 (1989) (defendant not permitted to offer
expert witness opinion that defendant was hexed where defendant
believed himself to be a victim of Voodoo).
70. They were not offered for the truth of the matters set forth in the
letters but as an expression of the state of mind of the reader and the
writer. For a classic definition of the term "hearsay," see generally Baird v.
Unemployment Compensation Board, 30 Pa. Cmwlth. 118, 121, 372 A.2d
1254, 1257 (1977) (hearsay constitutes statements made outside of court
offered for the truth of the matter(s) contained therein).
71. The charge against Sergeant Bowman characterized the tone of much
of petitioner's case. There was no question at the outset of this hearing
that Sergeant Bowman was considered by petitioner's counsel to be one of
the gang rapists. So much so, that they subpoenaed his bank records for a
three month period in 1991, when Sergeant Bowman asserted that he was
in Virginia Beach, Virginia, with his wife on their honeymoon at the time of
the alleged rape, i.e., June 17, 1991. At oral argument in the courtroom on
the motion to compel the production of these bank records, petitioner's
counsel, Christina Rainville, Esquire, informed the court that Ms. Lambert
was no longer accusing Sergeant Bowman of being a rapist. However, Ms.
Rainville allowed, Sergeant Bowman was welcome to come into court and
clear his name of this allegation. (N.T., PCRA at 3460.) The court informed
Ms. Rainville at that time that this is not how the system works. One does
not cast serious and harmful accusations out into the public place and then
invite the "accused" to come in and clear his name. This approach to
investigation, discovery and litigation shows the kind of paranoia that
appears to motivate the petitioner and certainly follows in the wake of her
counsel's efforts. Despite the fact that Mr. Bowman was never identified as
a rapist, never placed at the scene, never connected in any way with the
January January
Sunday
22, 201722, 2017
Page 2138
1136 of 2301
1299
alleged rape, it was necessary for him to come into court, with his wife,
and testify as to their whereabouts, their activities and their expenditures
on their honeymoon seven years ago.
72. The corrections officer at the state correctional institution at
Cambridge Springs was charged with and convicted of each of the
following crimes: aggravated indecent assault, formerly codified at 18 Pa.
C.S.A. Section 3125(5); indecent assault, formerly codified at 18 Pa. C.S.A.
Section 3126(a)(5); and official oppression, see 18 Pa. C.S.A. Section
5301. As to none of these offenses was forcible sexual conduct an element.
(N.T., PCRA at 7578-79.)
73. In testimony at the PCRA hearing, Ms. Lambert contrasted he r
involvement with Mr. Epstein as her attorney with how helpful she has
been to Ms. Rainville and Mr. Greenberg. She testified that in the first
telephone call she had with Ms. Rainville, she told Ms. Rainville that she
needed to hire a "clothing expert about the jergo, speech expert, a
pathologist, an expert on handwriting, every -- everything that you asked
me I said that we could get an expert for it." (N.T., PCRA at 5162.) It
appears that Ms. Lambert even assisted in writing the reports of her own
expert witnesses. To this end, she gave the following testimony:
Q. In the federal proceeding, what, if anything, did you ask to see of drafts
of expert reports?
A. As soon as an expert gave a draft, I asked you to send it to me and I
would read it right away.
Q. And what, if anything, did you do after you read it?
A. I would look at it and then I would write down questions for you to ask
the expert.
Q. And did we make changes to the expert reports based on your
comments?
A. Yes. I would ask you to ask them a question and give their best opinion
to a degree of scientific certainty and then you would ask them and
whatever they said would be included in the reports.
(N.T., PCRA at 5168-69.)
January January
Sunday
22, 201722, 2017
Page 2139
1137 of 2301
1299
Ms. Lambert would have this court believe that once safe in the confines of
the Edna Mahan Correctional Facility in New Jersey, she was able not only
to assist her attorneys but to participate in the writing of expert reports.
Normally, experts write their own reports. The blithe acknowledgment by
petitioner and petitioner's counsel to the act of participation in the writing
of expert reports provides considerable insight into a number of issues in
this case.
74. The "loop" is an unofficial designation of a large block composed of
several streets and extending over eight or nine city blocks in downtown
Lancaster. It has long been a hang out for teenagers in cars or on foot.
75. There was considerable testimony at the PCRA hearing regarding
certain scratches on Ms. Buck's shoulder and back. Photographs were
taken of her at the time of her arrest and Lieutenant Renee Schuler
testified as to observing those scratches. The scratches were discernible
on the photographs admitted into evidence. Ms. Buck was asked about
these scratches and was unable to provide any explanation fo r them. She
does not believe she sustained those scratches on the morning of
December 20 because she was wearing a sweatshirt and her Miami
Dolphins jacket over top of the sweatshirt at all times. She believes she did
them herself by scratching her back. (N.T., PCRA at 6665.)
76. The letter to Mr. Pugh was written four days after her deposition. Ms.
Buck testified that she sent the letter from the Lancaster County Prison
before being returned to the State Correctional Institution at Muncy. (N.T.,
PCRA at 6692.)
77. The fact that the warrant was issued in the office of District Justice
Savage is more coincidence than anything else. District Justice Savage's
office happens to have jurisdiction over the area where Ms. Bayan resided.
78. The distinction between exculpatory evidence and favorable evidence
is that exculpatory evidence extrinsically tends to establish a defendant's
innocence of the crimes charged, contrasted to that which, albeit
favorable, is merely collateral or impeaching. Commonwealth v. Hudgens,
400 Pa. Super. 79, 97-98, 582 A.2d 1352, 1361 (1990); Commonwealth v.
Redmond, 395 Pa. Super. 286, 577 A.2d 547, 552 (1990); Commonwealth
v. Hicks, 270 Pa. Super. 546, 550, 411 A.2d 1220, 1222 (1979). The
evidence suppressed in Redmond was the identity of a confidential
informant who gave information concerning an alternative suspect in a
murder case, where the prosecution's case rested on the testimony of only
one police officer. Redmond, 395 Pa. Super. at 298, 577 A.2d at 552. The
court opined that t he evidence was both exculpatory and material, as there
was reasonable probability that the evidence might have made a difference
in the outcome of the case. Id. at 299, 577 A.2d at 553.
79. During the federal habeas corpus hearing, Mrs. Show informed District
Attorney Madenspacher that she recalled seeing a car of brownish color
the morning of the murder as she reentered the condominium complex.
Her memory was refreshed as she sat in the courtroom listening to the
testimony of former Detective Savage. This was immediately brought to
January January
Sunday
22, 201722, 2017
Page 2140
1138 of 2301
1299
the attention of the federal judge, who conducted a hearing in chambers

on April 16, 1997. Mrs. Show's recollection was then made a part of the
federal record.
81. See Lambert v. Blackwell, 962 F. Supp. at 1546.
82. This argument was accepted by the district court. Lambert v.
Blackwell, 962 F. Supp. at 1546.
83. The district court found that Mr. Kenneff's "violation" of an ethical duty
in contacting Dr. Mihalakis was a "no-brainer," which is an interesting
characterization of an issue which required expert testimony. This finding
is just not true. At least three bar association ethical committees have
concluded that the Rules of Professional Conduct do not expressly prohibit
a lawyer from contacting an expert retained by opposing counsel and that
the resolution of the issue is "fact sensitive." See Philadelphia Bar
Association Professional Guidance Comm., Guidance Op. 94-22 (1995). See
also ABA Comm. on Ethics and Responsibility, Formal Op.93-378 (1993);
New York State Bar Ass'n, Comm. on Professional Ethics, Ethical Op. 577
(1986).
84. This is a concept which does not appear to have been lost on the
district court. See Lambert v. Blackwell, 962 F. Supp. at 1547 n.39.
85. The Reed report, Petitioner's Exhibit 1299, is not contained in
Commonwealth's Exhibit 4, a compilation of all reports given to Mr. Shirk
in discovery.
86. Only recently, in the 1995 amendments to the Juvenile Act, can an
offender's juvenile record be used for impeachment purposes, much like
an adult record. 42 Pa. C.S.A. Section 6354(b)(4) (1998 Supp.) This was
not the state of the law in 1992.
87. Petitioner tends to define "perjury" as "information which does not
help her." Or, petitioner points to evidence which she finds incredible or
with which she disagrees and labels it "perjury." See, e.g., Lambert v.
Blackwell, 962 F. Supp. at 1531 (Mr. Yunkin's testimony about the "29
questions"), 1535 (Mr. Yunkin's statement about picking up Ms. Lambert
and Ms. Buck on Oak View Road), 1545 n.35 (Mr. Savage's testimony about
Mr. Yunkin's recorded statement), and 1542 (Detective Solt's testimony
about taking the statement from Ms. Lambert).
88. Testimony at the PCRA hearing established that Ms. Lambert gave the
first part of her statement to Corporal Solt sitting at a desk in the East
Lampeter Township police station. Thereafter, she was moved to another
portion of the station, where she sat in the open squad room. Lieutenant
Renee Schuler testified that from that vantage point, Ms. Lambert was able
to hear the ongoing broadcast over the police radio about the progress of
the efforts to locate the bag Ms. Lambert and Mr. Yunkin threw into the
January January
Sunday
22, 201722, 2017
Page 2141
1139 of 2301
1299
dumpster behind the K-Mart after the murder. (N.T., PCRA at 3838-39,
3840-41.) It is entirely likely and believable that Ms. Lambert heard the
transmission that the bag had been found and, at that point, chose to come
clean with Corporal Solt about what she was wearing that morning.
89. The closest petitioner can come would be the closing argument of
James P. Cullen, Esquire, (now Judge Cullen) defense counsel in the Buck
trial. Mr. Cullen referred to the clothing worn by Ms. Lambert on the
morning of the murder and argued that it was ridiculous to think that she
would be wearing that clothing. He was clearly attempting to implicate Mr.
Yunkin in the murder. His reference was to an oversized flannel shirt and
he did not specifically refer to the sweatpants.
90. We should bear in mind that this theory is generated by the creative
machinery which would have us believe that Ms. Lambert's incriminating
statement was actually the result of a truth serum injection, that Ms.
Lambert's admission to wearing clothing found in the dumpster was
actually the result of a fabricated statement, that the crime scene
photographs were actually taken after the body was carried back into the
condominium by crooked police officers under the cover of night, and that
the dying declaration was really the result of a cunning detective's
suggestion to a distraught mother that she lie through two preliminary
hearings and two homicide trials to support a "frame up" that would
presumably convict defendant, who said she was once gang raped by three
police officers.
91. Of course, the best way to address this issue would have been to ask
Mr. Yunkin to try the pants on during his testimony. Neither side suggested
this step.
92. The federal testimony by Mr. Roberts, after viewing both videotapes,
was that he had, in fact, edited the video before giving it to the police:
Q. Is it possible that you edited those items out when you made this?
A. Sure. I probably did. I don't think anybody had anything to do with that
but me.
...
THE COURT: I'm a little confused based on that last answer you gave,
couple answers ago to Mr. Madenspacher.
THE WITNESS: Sure.
January January
Sunday
22, 201722, 2017
Page 2142
1140 of 2301
1299
...
THE COURT: You have no reason to believe that when you made the copy
originally, that you gave it to them in an edited form?
THE WITNESS: I think it was in an edited form when I gave it to them,
yes. I think now -THE COURT: And it was edited?
THE WITNESS: -- after seeing it, I -THE COURT: Why would it have been edited?
THE WITNESS: By me.
THE COURT: Why would you have edited it? It might have been an
important thing.
THE WITNESS: To cut out the walking and to cut out something else. But
nothing -- it wasn't an important situation at all to me.
THE COURT: It is now.
THE WITNESS: I know.
THE COURT: So I want you to be very careful. You're being 'very sloppy' in
your answers, so let's try this again. Go ahead. I'm not going to let you
leave here until we find the truth. That's the purpose of this. You
understand that?
THE WITNESS: Well, I would not lie on the stand.
THE COURT: And you understand that you're under oath, don't you?
THE WITNESS: Yes, I do, and I would -THE COURT: Good. And I want you to be -THE WITNESS: And I would not lie on this stand.
THE COURT: I want you to be 'very careful.'
January January
Sunday
22, 201722, 2017
Page 2143
1141 of 2301
1299
93. The federal district court concluded that a sneaker was found inside a
plastic bag. See Lambert v. Blackwell, 962 F. Supp. at 1543. However, a
review by this court of both videotapes of the river search confirms that
the pink bag and the other bag were both empty. A conclusion that one of
these bags contained a sneaker re quires a leap from the premise that Mr.
Yunkin's sneakers were put in a plastic bag to the conclusion that because
plastic bags were found, they must have contained sneakers and those
sneakers were then destroyed by the police. This "leap" requires reliance
on another unfounded assumption: that the police within a day or two
after the murder, were doing everything possible to destroy proof of Mr.
Yunkin's involvement. This is contrary to the credible testimony of both Mr.
Madenspacher and Mr. Kenneff that the Commonwealth was very
interested in any evidence which would tie Mr. Yunkin into the murder.
Further, this "leap" assumes that the police ignored another reality: that a
bag containing Mr. Yunkin's sneakers but discarded by Ms. Lambert would
have been further evidence of her involvement in the murder or in the
conspiracy. Moreover, a sneaker was found but not until the second search
conducted on December 23, 1991. Mr. Roberts was not present on
December 23, 1991, and no videotape was done of that search.
94. On cross-examination Ms. Lambert explained that the items were first
placed in a white bag and it was when they arrived at the river that Mr.
Yunkin took the white bag and placed it inside a red trash bag weighted
down with rocks. Ms. Lambert then threw the red bag into the river. (N.T.,
Trial at 1154-55.) Mr. Yunkin testified that the bag thrown into the river
was white. (N.T., Trial at 262-63.)
95. Petitioner's Exhibit 1016-A is a 16-page Pennsylvania State Police
Investigative Report by Corporal Solt concerning his interviews with Ms.
Lambert on December 21, 1991. Attached to the report is a photocopy of
the seven page "Solt Statement" signed by Ms. Lambert, five and one-half
typed pages and one and one-half handwritten pages. The body of the 16
page report contains a summary and quotes from the 7 page statement.
96. This is a story created by Ms. Lambert, Ms. Buck and Mr. Yunkin in
preparation for possible questioning by the police.
97. At this point, Corporal Solt began to take a second statement from her,
i.e., the "Solt Statement." He asked Corporal Renee Schuler of East
Lampeter to assist him by taking notes as Ms. Lambert talked. Corporal
Solt then typed out the statement and gave it to Ms. Lambert for her
review and approval. This is Petitio ner's Exhibit 1023.
98. Mr. Yunkin had, in fact, signed his statement the very same way.
99. We note that the federal district court found that the statement was a
"fabrication." See Lambert v. Blackwell, 962 F. Supp. at 1541-1542. There
is no mention in the district court's analysis of the December 23, 1991,
letter from Ms. Lambert to Mr. Yunkin nor is there any reference to Mr.
January January
Sunday
22, 201722, 2017
Page 2144
1142 of 2301
1299
Shirk's testimony about his reviewing the statement very carefully with
Ms. Lambert prior to trial. Nor is there any reference to Ms. Lambert's clear
testimony at trial about the accuracy of the "Solt Statement." Perhaps had
these important facts been made available to the district court, the leap
from "unique" to "fabricated" would have been approached with
somewhat more caution. We do not accept the conclusion that Detective
Solt's testimony about the statement was "perjury" based upon Mr. Ries's
weak testimony that the statement was "unique."
100. Indeed, according to Dr. Smialek, the stab wound to the back would
have caused death within a matter of minutes.
101. It is worth considering that the charge of "fabricating" crime scene
photographs of the hallway concerns police conduct at the time of the
investigation or within the next day. At that point, Ms. Lambert had told
the police that Ms. Buck went crazy in the condominium and that she
(Lambert) turned away in horror. The story about grabbing Laurie Show's
wrists and attempting to pull her from the bedroom into the hallway did
not materialize until the trial. Yet, Ms. Lambert contends that the police
altered or staged photographs on December 20 or 21, 1991, to discredit a
story they would not hear until July 1992 in a courtroom.
102. At the start of the hearing, on April 30, 1998, petitioner's counsel
called Lieutenant Renee Schuler to the stand. Lieutenant Renee Schuler
was shown some 35 items of evidence which had been marked for
identification by petitioner's counsel. Normally, the court reporter would
mark exhibits but because of the large number of exhibits and because
many of these exhibits had been used previously by petitioner's counsel,
the court believed that the best system would be for them to use their own
numbering system. After 30 some exhibits had been shown to Lieutenant
Schuler, counsel for the Commonwealth pointed out that two items had
been marked Exhibit 883, two items had been marked Exhibit 900, none of
the exhibits marked had any dates or initials as to who marked them, and
that at least one empty envelope that came with an exhibit was no longer
attached to the exhibit. (N.T., PCRA at 137.) We took a recess and
determined that the safest course would be for the court reporter to mark
the exhibits. A substantial portion of the afternoon of April 30 and nearly
all of the morning of May 1, 1998, were consumed with the remarking and
organization of these exhibits. This substantial delay was caused by the
lack of any true organization of these important exhibits despite the good
efforts of petitioner's counsel. This is testimony itself to the difficulty in
managing large numbers of exhibits in a complex case where problems
arise from these circumstances without any dishonest or otherwise bad
motive.
103. As a practical matter, we believed and expressed to counsel at that
time that possible sanctions for his conduct in the Lambert investigation
imposed by the federal courts or any possible contempt citation for failure
to answer questions at the PCRA hearing would be of little concern to Mr.
Reed. He had just been convicted of five sex offenses. At the time this
discussion was taking place on May 11, 1998, Mr. Reed faced a substantial
state prison sentence. On July 6, 1998, Mr. Reed received a sentence of 9
January January
Sunday
22, 201722, 2017
Page 2145
1143 of 2301
1299
to 18 years.
104. Commonwealth's Exhibit 4 is a compilation of police reports produced
to Mr. Shirk in discovery in 1992.
105. Ms. Buck, in her testimony at the PCRA hearing, confirmed that
Laurie's hair was cut with the knife. She recalls that Ms. Lambert cut
Laurie's hair.
106. She was emphatic about this because to establish her reason for not
seeking help for Laurie Show or contacting the authorities regarding the
brutal murder, she stated she was watched all day by Mr. Yunkin "like a
hawk." (N.T., PCRA at 5569.)
107. This is yet another example of an issue which on superficial analysis
looks bad. Upon careful consideration of what the license plate was, what
steps were taken by the police and what it ultimately might mean, what
looked bad has really no significance. An analysis of this issue which
proceeds beyond the superficial establishes no Brady violation.
108. Mr. Jeffries was listed as a Commonwealth witness in the PCRA case.
Despite this, and without leave of court or discussion with the
Commonwealth, petitioner's counsel retained Mr. Jeffries as their own
investigator. They did this despite the fact that Mr. Jeffries worked closely
with Mr. Shirk in 1992 and Mr. Shirk is the object of some 25 counts of
ineffective assistance of counsel.
109. We need not develop, but should note, that this theory is completely
at odds with the Baden/Smialek/Larson expert triumvirate which opined
that Ms. Show was dead anywhere from one minute (with the carotid
severed) to five minutes (under the best of conditions) after her wounds
were inflicted. Petitioner's counsel would have this court believe, by virtue
of Baden/Smialek/Larson that Ms. Show was dead almost immediately.
Yet, she was able to move across the floor to the closet door and inscribe
initials on the door. It appears that this would have taken much more
effort, thought and fine motor skill than the breathy, hoarse whisper she
uttered to her mother as she died.
Copyright 1997,1998, County of Lancaster, Pennsylvania. All Rights
Reserved.
January January
Sunday
22, 201722, 2017
Page 2146
1144 of 2301
1299
January January
Sunday
22, 201722, 2017
Page 2147
1145 of 2301
1299
P
usps.com
062S0000000313
Click-N-Ship
Mailed from 17603
9407 8036 9930 0023 5041 49 0089 0000 0022 0500

$8.90
US POSTAGE
Flat Rate Env

Signature
Confirmation
03/09/2016
0006
C000
PRIORITY MAIL 2-DAY
STAN CATERBONE
AMG
1250 FREMONT ST
SIGNATURE REQUIRED
SHIP
TO: PRESIDENT BARRACK OBAMA

THE WHITE HOUSE
USPS SIGNATURE TRACKING #
9407 8036 9930 0023 5041 49
Cut on dotted line.
Instructions


the package.
Signature Confirmation / Insurance Number:
9407 8036 9930 0023 5041 49
Trans. #:
Print Date:
Ship Date:
Expected
Delivery Date:
Insured Value:
From:
To:
367860978
03/08/2016
03/09/2016
03/11/2016
$50.00

Insurance Fee
Signature Confirmation
(Electronic Rate)
Total
$6.45
$0.00
$2.45
$8.90
STAN CATERBONE
AMG
1250 FREMONT ST
THE WHITE HOUSE
January January
Sunday
22, 201722, 2017
Page 2148
1146 of 2301
1299
Stan J. Caterbone, Pro Se, MOVANT

Appellant
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-826-5354
717-669-2163 cell
March 8, 2016
The White House
1600 Pennsylvania Avenue NW
Re:
Formal Request to Commute the State Life Sentence of the following:

Tabitha Buck
See the following U.S. District of Eastern Pennsylvania 04-02559
See the following U.S. Third Circuit Court of Appeals 15-3400; 16-1149
See the following Attachments
Executive Summary of Stan J. Caterbone
Office of the Executive of the U.S. Third Circuit Opinion
Working Theory for Tabitha Buck
________________________________________
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
Notary:
ACTIVE COURT CASES

POTUS - Lambert Coummutation Request
Page 1 of 59
March 9, 2016
January January
Sunday
22, 201722, 2017
Page 2149
1147 of 2301
1299


Page 2 of 59
March 9, 2016
January January
Sunday
22, 201722, 2017
Page 2150
1148 of 2301
1299
Will file Appeal for Reconsideration to 3 Third

Circuit Judge Panel by April 6, 2016; as instructed
in person by Margaret A. Wiegand Agent in
Philadelphia on March 7, 2016 at U.S. Federal
Courthouse!
Page 3 of 59
March 9, 2016
January
Sunday
January
22,Circuit
201722,
2017
Will take
U.S. Third
Appeal
16-1149 to U.S. Supreme Court by
May 16, 2016 (90 Day Window by
U.S. Supreme Court Rules of
Procedure for Pro Se)
Page 2151
1149 of 2301
1299
Page 4 of 59
March 9, 2016
January January
Sunday
22, 201722, 2017
Page 2152
1150 of 2301
1299
Page 5 of 59
March 9, 2016
January January
Sunday
22, 201722, 2017
Page 2153
1151 of 2301
1299
Page 6 of 59
March 9, 2016
January January
Sunday
22, 201722, 2017
Page 2154
1152 of 2301
1299
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
January 22, 2016
Page 7 of 59
March 9, 2016
January January
Sunday
22, 201722, 2017
Page 2155
1153 of 2301
1299
_____________/S/___________
ACTIVE COURT CASES
Page 8 of 59
March 9, 2016
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Group
Coummutation
Press
PressRelease
Release
Request
Page 2156
1154 of 2301
1299
Page
Page
Page119ofof
of51
51
59
Thursday, December
March17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Page 2157
1155 of 2301
1299

scaterbone@live.com
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
(717)669-2163
PRESS RELEASE
_________________________________________________
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page
Page
110
2
2ofof
1of
50
51
51
59
Thursday,
Friday, December
March11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page 2158
1156 of 2301
1299
Page
Page
Page3
211
3ofofof
50
51
51
59
Thursday,
Friday, December
March11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Page 2159
1157 of 2301
1299
Capitol Office
State Capitol
Jefferson City Mo.
573-751-0246
District Office
Second Street
King City Mo.
660-535-6664
May 21, 2009

Sincerely,
Rep. Jim Guest
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page4
312
4ofofof
50
51
51
59
Thursday,
Friday, December
March11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Page 2160
1158 of 2301
1299
Bill
A) Findings
Convention.
B) Purpose
or four years.
**
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page
Page
413
5
5ofof
2of
50
51
51
59
Thursday,
Friday, December
March11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Page 2161
1159 of 2301
1299
telepathy devices.
one year..
in good faith.
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page
Page
514
6
6ofof
3of
50
51
51
59
Thursday,
Friday, December
March11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Page 2162
1160 of 2301
1299
(c)
recipient.

Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page
Page
615
7
7ofof
4of
50
51
51
59
Thursday,
Friday, December
March11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Page 2163
1161 of 2301
1299
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page
Page
716
8
8ofof
5of
50
51
51
59
Thursday,
Friday, December
March11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Page 2164
1162 of 2301
1299

weapons
May 20, 2015

FacebookTwitterMore
9 comments
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page
Page
817
9
9ofof
8of
50
51
51
59
Thursday,
Friday, December
March11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Page 2165
1163 of 2301
1299

Related posts:

weapons
Comments

Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page
Page
Page
10
910
18
of
of
9of
of
50
51
51
59
Thursday,
Friday, December
March11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Page 2166
1164 of 2301
1299
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
October 10, 2015
and
Executive Summary
I remain,
Stan J. Caterbone
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page11
10
19of
ofof
of41
50
51
51
59
Page
111
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2167
1165 of 2301
1299

&
STAN J. CATERBONE
EXECUTIVE SUMMARY
copyright 2009
do you believe in?
Date Updated:
October 10, 2015
Date Completed:
Date Initiated:
July 28, 2009

July 8, 2009
Stan J. Caterbone
scaterbone@live.com
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page12
11
20of
ofof
of41
50
51
51
59
Page
212
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2168
1166 of 2301
1299

The
By
the
end
of
the
summer
of
2010
every
social
media
site,
including
the

And Again, the
Since August 1,

Lambert.

Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page13
12
21of
ofof
of41
50
51
51
59
Page
313
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2169
1167 of 2301
1299
no
$600.00.
Common Pleas.
Pennsylvania.
The
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page14
13
22of
ofof
of41
50
51
51
59
Page
414
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2170
1168 of 2301
1299

Stan J. Caterbone.
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page15
14
23of
ofof
of41
50
51
51
59
Page
515
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2171
1169 of 2301
1299
HISTORY
local laws.
This
ISC was a
INTERNATIONAL
States as of 1992.
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page16
15
24of
ofof
of41
50
51
51
59
Page
616
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2172
1170 of 2301
1299
Agency (CIA).
Directors?

scandal.
Patent Office.
subsidiaries.
Carlos Cardoen.
believe him.


Lancaster, County.
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page17
16
25of
ofof
of41
50
51
51
59
Page
717
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2173
1171 of 2301
1299



possible.

Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page18
17
26of
ofof
of41
50
51
51
59
Page
818
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2174
1172 of 2301
1299

Mind Control.
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page19
18
27of
ofof
of41
50
51
51
59
Page
919
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2175
1173 of 2301
1299

WEAPONS.
topic.
without success.
This
more information.
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page10
19
20
20
28of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2176
1174 of 2301
1299
FAMILY HISTORY
the following:
business.

Samuel Caterbone,
subprograms.
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page11
20
21
21
29of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2177
1175 of 2301
1299
solvents.
His
In 1973 Samuel P.
account.
his record online.
He was in perfect
Julianne McKinney,
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page12
21
22
22
30of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2178
1176 of 2301
1299
By his own
suicide.
It left him in the
The
The Schizophrenia
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page13
22
23
23
31of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2179
1177 of 2301
1299
School.
Over the
were sold.
very short fashion.
Record:
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page14
23
24
24
32of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2180
1178 of 2301
1299
Pennsylvania.
THE PUBLIC RECORD

courts.

court filings.

Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page15
24
25
25
33of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2181
1179 of 2301
1299


Stan J. Caterbone
scaterbone@live.com
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page16
25
26
26
34of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2182
1180 of 2301
1299
September 7, 2009
Stan J. Caterbone
Advance Media Group
1250 Fremont Street
Derrick Robinson
P.O. Box 9022
Phone 1-800-571-5618
Fax 1-866-433-4170
Derrick,
see
attached.
ISC.
Dollar Fraud.
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page17
26
27
27
35of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2183
1181 of 2301
1299

Wikipedia.
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page18
27
28
28
36of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2184
1182 of 2301
1299
James Cross
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page19
28
29
29
37of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2185
1183 of 2301
1299
Stan J. Caterbone
scaterbone@live.com
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page20
29
30
30
38of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2186
1184 of 2301
1299
AFFIDAVIT
The
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page31
21
30
31
39ofof
of51
41
50
51
59
Thursday,
Saturday,
Friday, December
October
March10,
11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page 2187
1185 of 2301
1299
Page
Page
Page32
31
32
40ofof
of51
50
51
59
Thursday,
Friday, December
March11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page 2188
1186 of 2301
1299
Page
Page
Page33
32
33
41ofof
of51
50
51
59
Thursday,
Friday, December
March11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page 2189
1187 of 2301
1299
Page
Page
Page34
33
34
42ofof
of51
50
51
59
Thursday,
Friday, December
March11,
17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Page 2190
1188 of 2301
1299
scaterbone@live.com
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603

December 6, 2015
Work-In-Progress

Advanced
POTUS
- Lambert
Medi Group
Media
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page35
35
43ofof
of51
51
59
Thursday, December
March17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Page 2191
1189 of 2301
1299

Formal Notice
Officer.
Wordpress Blog.
Debra Hoeckler
26.Pennsylvania Liquor Control Board, Nortwest Office Building, November 23, 2015,
Dated: December 6, 2015
Advanced
POTUS
- Lambert
Medi Group
Media
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page36
36
44ofof
of51
51
59
Thursday, December
March17,
9, 2015
2016
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page 2192
1190 of 2301
1299
Page
Page
Page27
36
37
37
45of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page 2193
1191 of 2301
1299
Page
Page
Page28
37
38
38
46of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page 2194
1192 of 2301
1299
Page
Page
Page29
38
39
39
47of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
! "
Page 2195
1193 of 2301
1299
"
$% &
!
" #
%
"&#
(
'
!
(
,
"
"
")
"
""
-
)
!
! "
!
'
%
" !
"
!
)
+
!
" *
"
"
,
,
,
*
%
*
(
%
!
/"0
1
1 ,
"
"
4
!
"
"
!
!
#
.
.
&,,0
%
1 ,
2"3
!
)
** ! "
&,,..$/
&,,
%
&,,
%
&
, "
"
00
"
!,
"
6
7
7 , !
&,,-
8,
:
(
$;$
"2
! " ,
, ,
** !
;
5
$
!
&,,@
,
.
&<;=
>
1
9
,
&,,=
$
,
>
A
1 B3
.+
&,,=
1 B3
2
>
%
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page30
39
40
40
48of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
<
Page 2196
1194 of 2301
1299
1
1
* "
!
"
C#
"$
"
<
*
&, ,
24
#9
; "
&,,@(&,,= A
3
24
5
!
%
&,,0 4
! %3
"
"
!
&,,
%
!
4
'
5
4
D
%
%
"
""
,! "
0 =
0 =9
9
00&9 00
:
9
&,,-
&, , $
!
%
!
D
%
%
=
F
!
))
+
/4
),
"
0 =
/
$
G
3
%
00
3
3
"
%#
$
$
&, ,
&,,4
!- "
.
&,,@
,
*
&,,<
E
&,,
-) !
/ 4
24
/
$
D
&, ,
D
$
&,,-
&,,0
%
D
!
D
D %
7F !
>
!
D
$
A
8F
$
%
;
D
.
%
&,,3
E
$
*
00=; 00
$
5
! 7
0 =
00
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page31
40
41
41
49of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
)
A
Page 2197
1195 of 2301
1299
24
$;$
00
(F
&
%
B
5
00 9
" * <
00=( 00 9
:#
> ) "" ""

$
;3
#, " !
&,,-
"
"
"
0 =
&, ,
/
.
$
B
3
3
=
0 =
) "
.
&,,1
0 =
24
" "
3
"
&,,@
" E
""
B
$
<
&,,1
.
&,,-
,-(&&
2
=
@,
"
&,
3
&,,!
&,,@
&,,@
0 =
@, 1
&,,@
9
!
@,
#" !,
0 =
" "1 ,
"
"*
":
" E
F
&,,-
!
B
/
!
"
00=( 00 9
B
:
9
$
'
.
&,,1
9
0 =
&, ,
/
.
00 9
/
&,,9
&,
( "
!
.
00
$
!
&, ,
F
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
3
7
8
!
&,,
&, ,
Page
Page
Page32
41
42
42
50of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
&
, * "
&&
*#
Page 2198
1196 of 2301
1299
"
&:
;!
&<
:
%
$
&, ,
$
&,,-
!-
,
5
%
"
>
$
$
< !-
24
? "
;
>
&,,0
B
&,,%
(
$
&, ,
&-
A
.+ $
&@
! :
&,,$
: , *
&, ,
* @
&,,@
"
E
3
&,,
"
&,,0
7 "!
7 "
0 =
*
&=
) "
":
)"
&,,@
"
&
&0
!
< ")
+
9 &,,@
:
9
&, ,
&,,
00
:,
!6
"
"
" .
9 &,,0
0 = "&#
, *
&,,@
/
" F
0 =
;A
0 =
F
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
0 =
Page
Page
Page33
42
43
43
51of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2199
1197 of 2301
1299
!
3
"
$
+
0 =
I $
$
0 =
"2
'
+$;F
D
"$
&,;&,
3
A
00
'
$ 24
"1E1# $
K
E
A
00&
>
L
F
F
B
F
+
0=,K
A
$
$
1
+
>
1
$
>
B
!
3
F
1
00
) % 3
&,,-
!
>
! A !
00,K
1 B3
>
F
F
& 1
F
8
! 4
'
A
! 4
A
0=,K
F
00,K
0 ,K
0<,K
3
/
>
%
&,,
) %$
D 1
"
$
0 <9 F
0@,K
0@,K
$
2!
A? D!B
#
*
$
7
+
00
D 18
.
E
$
M 1
00= E
0 =
%
0 ,K
$
0 =
M
00
!
&,,9
(
9
!
1
,-(
$ !2B+EF2
(&&
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page34
43
44
44
52of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2200
1198 of 2301
1299
") !
"
7!
N
.
!
5
F
(
(
5
G
*
A'
, ?
*
? 1
!,
A
(
> "
!, '!
,
B
A
" " * #" !, " "
$C
* #" !, D
73
8
* 7
,
"
"
&
"
#
.
"
#(
5
7
9
'
5
%
7A
8 !
8 !
'
!
7D .2
O
% 8
'
7
'
(
(
%
%
4
K
K
M %
%
K
'
7E
(
8
"
%
'
%(
(
(
4
;
(
7
7
87
(
(
8
8
- 7 > !,
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page35
44
45
45
53of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Page 2201
1199 of 2301
1299
* , "
!
B
B
B
B
B
B
B
B
.
.
&
B
B
B
B
B
@
E
@
E
&. @
DD
@
. DD
"
@
& DD
@
. DD
@
& DD
@
$ DD
@
DD
@
E
DD
@
EB& DD
@
EB DD
@
& B DD
@
DD
@
& DD
@
DD
@
& DD
@
DD
B@
)
B@
DD
!
!
))
1"
)
*
!
")
1
3
1
"
)
)
, "
*"
"
, "
!
*
"
")
"
7
"!
"
*
!
*
")
!
6, "
1
5
)
>
' "
*
, "
1 ,!
, "
)
!
"
"
!
!
1
"": !
1 , 1
"": !
"
1
"": !
!
"
! * !
)
*
"E
DD
")
E DD
%
,
!
!"
, "
"
"
"
1 ,"
DD
*)
PPPPPPP "
>7
%#
'?
Stan J. Caterbone
"
Stan J. Caterbone
"
June 19, 2015

Pennsylvania
$
Lancaster
19
PPPPPPP
15
June
&,PP

F
SJC
I
.
I
&, ,
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page
Page
Page36
45
46
46
54of
of
of51
50
51
59
Page
of
41
Don't Know When
24
$
$
Q &, , "!
I
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page 2202
1200 of 2301
1299
Page
Page
Page37
46
47
47
55of
of
of51
50
51
59
Page
of
41
Page 35 of 41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
06/10/2007
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page 2203
1201 of 2301
1299
Page
Page
Page38
47
48
48
56of
of
of51
50
51
59
Page
of
41
Page 36 of 41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
06/10/2007
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page 2204
1202 of 2301
1299
Page
Page
Page39
48
49
49
57of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page 2205
1203 of 2301
1299
Page
Page
Page40
49
50
50
58of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
January January
Sunday
22, 201722, 2017
Advanced
POTUS
- Lambert
Medi Group
Media
Grop
Group
Coummutation
Press
PressRelease
Release
Request
Page 2206
1204 of 2301
1299
Page
Page
Page41
50
51
51
59of
of
of51
50
51
59
Page
of
41
Thursday,
Friday, December
March
11,
17,
9, 2015
2015
2016
Saturday,
October
10,
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
1205 of
2207
1299
2301
Local News & Sports | Classifieds | Customer Care Center
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Lancaster Online Keyword
Go
348 articles matching lisa michelle lambert AND date(1997)

were found.
Article 1 of 348, 1997365478
Published on December 31, 1997, Intelligencer Journal (Lancaster, PA)
LAMBERT'S LAWYER ASSAILS RULING

Lisa Michelle Lambert's attorney Tuesday denounced an appellate court's
decision to effectively reinstate his client's 1992 first-degree murder
conviction, saying he will do whatever he can "to get it undone.". Peter S.
Greenberg, a Philadelphia lawyer, spoke by telephone from Vermont, where
he's on vacation. It was Greenberg's first detailed remarks about Monday's
ruling by the U.S. Court of
Click for complete article, (797 words)
Article 2 of 348, 1997365331
Published on December 31, 1997, Lancaster New Era (PA)
LAMBERT INVESTIGATORS WAITING, WONDERING

Lisa Michelle Lambert finds herself back in court and now her investigators
want their day there as well.. The prosecutors in her case have been under
investigation by state and federal officials since last spring. U.S. Judge
Stewart Dalzell ordered the investigation, after saying that prosecutors
tampered or hid evidence during their prosecution of Lambert. Now that a
panel of three federal judges has reinstated Lambert's conviction, some of
those prosecutors say they would like
Article 3 of 348, 1997364268
AUTHORS OF LAURIE BILL APPLAUD COURT RULING

Now that a federal appeals court has sided with its authors, it remains to be
seen whether the Laurie Bill is worth pursuing.. The pending legislation
seeks to limit the power of federal judges, keeping them from ever barring a
retrial on the state level, other than on constitutional grounds. Bill
Wichterman, chief of staff to U.S. Rep. Joseph Pitts, said the fate of the bill
depends on the reasons behind Monday's ruling by the U.S. Court of
Appeals, which vacated the decision by
Article 4 of 348, 1997364262
1 of 3
6/10/2006 8:31 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
1206 of
2208
1299
2301
COUNTY RESIDENTS REACT TO LAMBERT RULING

A court's decision to overturn a federal judge's ruling that freed Lisa
Michelle Lambert was good news to most as word spread throughout the
county Monday afternoon.. "I think his decision to let her go was wrong,"
said Lisa Kemper of Lancaster. "She was guilty. Why would she be there
that day (at the murder scene) in the first place?" Finding people who
agreed with the U.S. Court of Appeal's action to throw
Article 5 of 348, 1997364269

OVERTURNS RULING IN LAMBERT CASE //
PROSECUTORS CELEBRATE DECISION
The gloom that has hung over the Lancaster County District Attorney's
Office since the release of Lisa Michelle Lambert in April lifted Monday..
District Attorney Joseph C. Madenspacher, swamped in a sea of pink
message slips, sat at his desk and smiled for what he said felt like the first
time since Lambert was set free by U.S. District Judge Stewart Dalzell.
Dalzell's controversial decision was overturned Monday by the U.S. Court of
Appeals for the 3rd Circuit..
Article 6 of 348, 1997364279
LAMBERT CASE HAS FAR TO GO

The Lisa Michelle Lambert case is far from over.. Despite Monday's ruling
by a three-judge panel of the U.S. Court of Appeals for the 3rd Circuit Court
in Philadelphia, Lambert's claims of innocence and wrongful prosecution
could be tied up in state and federal courts for years to come. The following
is the best information available Monday on where the case goes now..
Brad Baldus, a 3rd Circuit court clerk, said Lambert's attorneys have 14
days from
Article 7 of 348, 1997364278

OVERTURNS RULING IN LAMBERT CASE
A federal appellate court Monday overturned a federal judge's decision to
free Lisa Michelle Lambert.. The court ordered Lambert to take her claims
of innocence and wrongful prosecution back to where she started: the state
courts, beginning with Lancaster County Court. A three-judge panel of the
U.S. Court of Appeals for the 3rd Circuit in Philadelphia wiped out an April
decision by U.S. District Judge Stewart Dalzell. He freed Lambert, who was
convicted in 1992 of first-degree
2 of 3
6/10/2006 8:31 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
1207 of
2209
1299
2301

Article 8 of 348, 1997364277
CHRONOLOGY OF SHOW MURDER CASE

Show murder case chronology:. `Dec. 20, 1991 - Laurie Show, 16, found
dead in her East Lampeter home. `Dec. 21, 1991 - Tabitha Faith Buck, 17,
Lisa Michelle Lambert, 19, and Lawrence Yunkin, 20, are charged in the
killing.. `July 20-21, 1992 - Lambert is convicted of first-degree murder after
a two-week trial and later sentenced to life in prison.. `July 31, 1992 - Buck
agrees to be tried as adult, and the DA agrees not to seek death penalty..
Àug. 7, 1992 - Buck granted change of
Article 9 of 348, 1997364276
DECISION OF THE CIRCUIT COURT IN THE LAMBERT

CASE
Editor's note: The following is an edited version of the decision by U.S.
Court of Appeals for the Third Circuit in the Lisa Michelle Lambert case.
Most of what was deleted were case citations and discussion by the court in
support of its decision. An ellipsis (...) appears where substantive material
was dropped. Footnotes were moved to the point in the text where they
apply and were placed in parenthesis.. Filed December 29, 1997 UNITED
STATES COURT OF APPEALS FOR THE THIRD
Article 10 of 348, 1997364272
'ALL I WANT IS SOME CLOSURE TO THIS'

Though many had reason to celebrate the reversal of a federal judge's
decision to free Lisa Michelle Lambert, the ruling was especially sweet for
Hazel and John Show, the parents of 16-year-old murder victim Laurie
Show.. "The whole process has been so draining from the beginning to the
end," Mrs. Show said. "Now there's a joy at knowing we're back on the right
track." Mr. Show said,

Content may not be republished without permission.

3 of 3
6/10/2006 8:31 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
1208 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2210
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 11 of 348, 1997364275
APPEALING DECISION
In a narrow ruling to a complex case, the Third Circuit Court on Monday
found that Lisa Michelle Lambert failed to exhaust her murder conviction
appeals at the state level and that state, not federal, courts should therefore
hear her request for relief.. While the ruling does not directly address
Lambert's guilt or innocence, it documents procedural errors on the part of
Federal District Judge Stewart Dalzell, who freed Lambert in April after
ruling that she had been the victim
Article 12 of 348, 1997364209
FOR SHOWS, DA'S OFFICE, COURT'S RULING BRINGS

RELIEF
When John Show heard Monday that a federal appeals court was about to
announce a decision affecting Lisa Michelle Lambert's newfound freedom,
he paused.. "I was scared," Show said. "I didn't trust the system." That's
understandable.. Lambert had been convicted in Lancaster County Court of
stabbing Show's 16-year-old daughter Laurie to death in December 1991..
After a hearing in April,
Article 13 of 348, 1997364211
COUNTY MAY ASK PA. PROSECUTORS TO STEP IN

When Lisa Michelle Lambert's murder case eventually returns to a
courtroom, she could be prosecuted by the state Attorney General's office
and not by the Lancaster County District Attorney.. That possibility was
raised today by the county commissioners, who said that they are preparing
to ask state prosecutors to get involved in the case in the future. The
reason, the commissioners said, is because of claims raised during
Lambert's appeal before U.S.
Article 14 of 348, 1997364210
1 of 3
6/10/2006 8:32 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2211
of 2301
1299
DA CONFIDENT LAMBERT WILL RETURN TO JAIL

County officials said today that they expect Lisa Michelle Lambert to be
returned to prison sometime in the next several months, in the wake of
Monday's federal court decision reinstating her conviction.. "I'm confident
she will go back to jail at some point," said Lancaster County District
Attorney Joseph C. Madenspacher. "As it stands right now, it's not a
question of if, but when." A federal appeals court
Article 15 of 348, 1997363267
THE YEAR IN QUOTES

January. "He has a nice round face and he's a good eater for me." Mrs.
Lenard Zimmerman, Ephrata, whose son, Leon, was 1997's first baby.. "Let
me say to the entire House that two years ago when I became the first
Republican speaker in 40 years, to the degree to which I was too brash, too
self-confident, or too pushy, I apologize. To whatever degree and in any
way that I brought controversy or inappropriate attention to the
Article 16 of 348, 1997363214
LISA LAMBERT'S PARENTS ANSWER NEW YORK

TIMES
Editor, New Era:. The following letter was sent to the New York Times, and
we are asking the Lancaster New Era also to print it: We are responding to
but a few of the statements in the New York Times article which appeared
in the Saturday, December 27, edition of Lancaster's Intelligencer Journal
and which was reported on by the Lancaster New Era, as well as
statements made elsewhere regarding the case involving our daughter, Lisa
Michelle Lambert. There are a number of points we
Article 17 of 348, 1997363191
COUNTY WINS LAMBERT APPEAL

PHILADELPHIA _ Lancaster County won its appeal today over a federal
judge's decision to free once-convicted murderer Lisa Michelle Lambert..
However, it was not immediately known if Lambert would be returned to
prison. The ruling by the 3rd Circuit Court, announced early this afternoon,
overturns a decision by U.S. Judge Stewart Dalzell in April in which he freed
Lambert, declaring her "actually innocent" of the murder of 16-year-old
Laurie Show.. In
Article 18 of 348, 1997362270
2 of 3
6/10/2006 8:32 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2212
of 2301
1299
Published on December 28, 1997, Sunday News (Lancaster, PA)
SUNDAY. Dec. 21 - Marilyn Porter, 58, Lancaster, was arrested and
charged with taking $9,000 in jewelry from one of her nursing patients.
MONDAY Dec. 22 - With the holiday shopping season winding down,
merchants said it has been a good, but not great, season. Many stores had
also started discounting over the last weekend.. A mix of snow, sleet and
freezing rain caused some traffic problems on back roads. TUESDAY.
Article 19 of 348, 1997362286
AN UNSETTLING YEAR
It was a year when many important things just didn't go according to plan.. If
a habeas corpus hearing had ended the way Lancaster Countians expected
it to, Lisa Michelle Lambert would still be in jail, still convicted of murdering
16-year-old Laurie Show. If city politics hadn't changed, Harrisburg Area
Community College would still be planning to move into the old Watt &
Shand building.. If, if, if ..... But because those best-laid plans went
Article 20 of 348, 1997361195
RETRIAL THREAT TERRIFIES LAMBERT

The possibility of being retried for the murder of Laurie Show terrifies Lisa
Michelle Lambert, The New York Times reported today.. In her first public
comments on her controversial case, Lambert wondered why Lancaster
County prosecutors are continuing to pursue her: "Why do they want to
keep doing this to me?" she asked.. The Times, in a lengthy page-one story,
describes how Lambert was freed in April by federal judge Stewart Dalzell
and how the rare case is


3 of 3
6/10/2006 8:32 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2213
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 21 of 348, 1997355339
SUNDAY. Dec. 14 - Edwin Morris, 84, was found dead in the basement of
his Salisbury Township home after fire destroyed the dwelling. He died of
smoke inhalation. Kerosene lanterns, the only source of artificial light in the
house, were blamed for the fire. MONDAY. Dec. 15 - Oprah! Television talk
show queen Oprah Winfrey was at the Landis Valley Museum to film scenes
for her new movie
Article 22 of 348, 1997355353
BOTTLE BILL HELPS IN RECYCLING AND DESERVES

SUPPORT
I am handling more bottles and cans in an incredibly expensive and
inefficient manner. Markets are flat. We pay to get rid of commingled cans,
jars and bottles. I have the cost of running two trucks and two crews five
days a week, which adds more cost to the operation.. A report in Recycling
Resource magazine (a recycling industry publication) reported the recycling
methods in all 50 states. Forty-three states that collected bottles and cans
through a hauler or municipal recycling method had
Article 23 of 348, 1997352309
DISTURBED BY MOVIE PROSPECT

To the Editor:. I, for one, do not want a movie made of Lisa Michelle
Lambert's life. The families involved in this tragedy have suffered enough.
Why can't the movie producers have sympathy for the families. Lisa
Michelle Lambert is not the victim. The movie producers are only interested
in making money off of other people's heartaches. Estell Haines Strasburg
Article 24 of 348, 1997352261
LAMBERT HELPS PHILA. LAWYERS HONOR
1 of 3
6/10/2006 8:33 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2214
of 2301
1299
RAINVILLE
Christina Rainville was honored this week by her fellow young Philadelphia
attorneys for championing the freedom of Lancaster County's Lisa Michelle
Lambert.. And it was Lambert - once convicted of murder, now declared
free and actually innocent - who introduced Rainville at the annual banquet
for the Young Lawyers Division of the Philadelphia Bar Association on
Tuesday. Lambert was convicted of first-degree murder and sentenced to
life in prison for slitting the throat of
Article 25 of 348, 1997348360
A FALSE PREMISE
Too many Lancaster Countians must have been watching Oliver Stone
flicks.. Why else would folks believe that everyone is out to get us over the
Lisa Michelle Lambert case? The conspiracy theories started when federal
Judge Stewart Dalzell threw out Ms. Lambert's conviction for the 1991
murder of Laurie Show. They intensified when the Los Angeles Times ran a
series, republished in the Sunday News, on why the decision may tilt the
balance of power between federal and state
Article 26 of 348, 1997348361
LAMBERT: WE WILL NEVER KNOW THE TRUTH

With the news that a film company has bought the rights to the story of Lisa
Michelle Lambert, the conversation is once again all about the case that
seems to have carved a scar right across Lancaster County.. Around my
desk I can hear: She is guilty. She is not. The prosecutors are corrupt. Or
they are not. And the sudden hush that comes with the rare mention of
another name: Laurie Show. Last week, the talk turned to macabre humour.
Who will play whom in this upcoming movie, this story in
Article 27 of 348, 1997348339
SERVICE KEEPS MEMORIES ALIVE

John Show had been planning his sixth annual Remembrance Service at
Mellinger's Mennonite Church for several months.. He'd recently brought in
a Christmas tree and trimmed it with white lights and a red bow. His
girlfriend, Doris Knier, had written a program decorated with a drawing of a
dove.. Friends had contributed the slender white candles that would be
handed out to participants.. On Saturday night, it all came together better
than Show could have
Article 28 of 348, 1997345240
2 of 3
6/10/2006 8:33 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2215
of 2301
1299
FIRM FORCED TO UNVEIL STUDY ON INCINERATOR

FIRE
After two men were killed in an explosion at the Lancaster County
incinerator in 1995, the company hired an independent firm to determine
what caused the blast so it would never happen again.. But now, defending
itself in a lawsuit from the family of one of the men, company officials have
balked at revealing the results of the study, saying it was done in
preparation of litigation. A Lancaster County judge isn't buying that. Last
week, he gave the Ogden Corporation 10 days to
Article 29 of 348, 1997344559
IS HIKE TOO HIGH?

If you're a homeowner caught up in the holiday shopping rush, here's a
sobering thought for you - better save a little, because in less than a month,
your county real estate tax bill may soar by nearly 30 percent.. If that
bothers you, then you might want to consider taking a little time tonight to let
the Lancaster County Commissioners know what you think about it. The
commissioners are holding a rare nighttime meeting at 7:30 at the
Lancaster Farm & Home
Article 30 of 348, 1997344423
THE COUNTY BUDGET IS SOLID, BUT IS EVERYTHING

NECESSARY?
Lancaster County officials have good reasons for boosting the 1998 budget
by 29 percent. Good reasons or not, it's still a 29 percent increase. It's still
going to cost the average homeowner an additional $70 to live in Lancaster
County next year.. County Commissioners say they are caught between
rising costs and declining revenues and have no choice but to raise taxes by
an exceptional amount. The facts seem to support that argument. But no
budget is entirely without


3 of 3
6/10/2006 8:33 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2216
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 31 of 348, 1997344421
LAMBERT REMAINS GUILTY OF CRIME

Editor, New Era:. On Dec. 20, 1991, someone lured Hazel Show from her
home via a phone call, sending Mrs. Show on a "wild goose chase." When
she left the apartment, someone entered the home and attacked and fatally
wounded Mrs. Show's 16-year-old daughter, Laurie.. Who committed this
horrible crime? There are only three people with any connection to this
vicious act, and only two of these suspects have a clearcut motive for
committing such a heinous
Article 32 of 348, 1997341327
SUNDAY. Nov. 30 - Vandals worked their way through Lancaster Township
and the city, smashing about 20 car windows. Roger Lee Mattingly, 50,
Elkton, Md., was the second Maryland man arrested in the shooting death
of a Chester County woman, Anna Weaver, 77, and the wounding of her
son-in-law in an apparent burglary attempt at her East Nottingham
Township home the week before. MONDAY. Dec. 1 - Two officers who
settled
Article 33 of 348, 1997341345
PURSUIT OF JUSTICE IS COSTLY

Nearly $1 million and counting.. That's how much the Lisa Michelle Lambert
appeal has cost Lancaster County. And the price tag likely will increase..
The expensive appeal, which began when federal Judge Stewart Dalzell
agreed to hear Lambert's case last February, was a factor in the county's
recent decision to hike taxes by nearly 30 percent, according to county
officials.. It wasn't the only reason for the increase, but the unexpected
Article 34 of 348, 1997341353
REACTION TO SERIES ON LISA LAMBERT TRIAL
1 of 3
6/10/2006 8:34 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2217
of 2301
1299
"Shame on you," the letter read.. Shame on us? All we had done was
publish, in two parts, a massive story on the Lisa Michelle Lambert case
which was written by a Los Angeles Times reporter.. It was perhaps the
most complete and incisive story anyone has written on the case. Although
we in the local media have long been covering the story day-by-day, we
never had the chance to - or never thought to - take a step back and see the
big picture in this way.. Perhaps
Article 35 of 348, 1997341324
CANDLES ILLUMINATE FAMILY MEMORIES

It began six years ago.. One man's effort to heal his own hurting heart and
the hearts of others. Now, John Show has organized the sixth
"Remembrance Service," a candlelight vigil to memorialize loved ones who
have died.. "I want people to know that this is for anybody - anybody - who
has lost somebody," Show said recently.. The service will be held at 7 p.m.
Saturday, Dec. 13, at Mellinger's Mennonite Church, 1916
Article 36 of 348, 1997340176
JUDGE DALZELL'S DECISION MIRRORS JUSTICE

A gross miscarriage of justice. This phrase has been used to describe the
April decision by Federal Judge Stewart Dalzell to free Lisa Michelle
Lambert from prison in the Laurie Show murder case. For the past eight
months, Dalzell has been berated by thousands of Lancaster County
residents. Much of this ranting, raving, and scalp-hunting is unfounded in
the belief that Dalzell unfairly condemned the conduct of Lancaster County
investigators during the case.. During Lambert's
Article 37 of 348, 1997340251
MOVIE VERSION
It should come as no surprise that Hollywood has stumbled onto the Lisa
Michelle Lambert story.. After all, some would say it is the stuff movies are
made of: An innocent girl from the wrong side of the tracks is railroaded into
a murder conviction by a narrow-minded community bent on avenging a
horrible crime.. In prison she is subjected to inhuman horrors and
degradations.. But in the end she is saved only by her own pluck and the
skill of an aggressive female lawyer able to convince
Article 38 of 348, 1997340175
JUSTICE MARRED BY JUDGES' DECISION
2 of 3
6/10/2006 8:34 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2218
of 2301
1299
Justice has been compromised. Her character, once lustrous, is now

tarnished by the radical decisions made by the judges in the cases of Louise
Woodward and Lisa Michelle Lambert.. In both trials, these women were
charged with murder. Woodward's second-degree murder charge was
reduced to manslaughter and she is now free. Lambert's charge was of
first-degree murder; she is now free. The precedent set by these two judges
is not exemplary of justice.
Article 39 of 348, 1997339376
FILM STUDIO BUYS RIGHTS TO TELL LAMBERT

STORIES
Actor Will Smith and Universal Pictures in Hollywood plan to produce a
movie based on Lisa Michelle Lambert's murder conviction five years ago
and her dramatic release from jail in April.. The movie, if it's made, will be
based on a two-part series about the Lambert case that was published in
the Los Angeles Times in November. The series also appeared in the
Lancaster Sunday News. If the script follows the reporting, Lancaster
County isn't going to look as
Article 40 of 348, 1997332044
Published on November 28, 1997, Lancaster New Era (PA)
DEFENSE LAWYERS ARE WRONG TO CHALLENGE

'LAURIE BILL'
Editor, New Era:. I am writing in response to the Pennsylvania Criminal
Defense Lawyers and their opposition to the "Laurie Bill." We need a bill like
this one and we need it now! We need to stop judges from having so much
power. Judge Dalzell had no right to set Lisa Michelle Lambert free saying
that she was innocent because she was framed by county prosecutors. As I
recall, Lambert admitted that she was in the Show apartment the day Laurie
died; that alone makes her


3 of 3
6/10/2006 8:34 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2219
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 41 of 348, 1997327076
Published on November 23, 1997, Sunday News (Lancaster, PA)
WGAL PROVIDES MEANINGFUL COVERAGE BEYOND

CRIME NEWS
This is in response to the Clyde conversation in the Sunday News Nov. 16..
As a local broadcaster, WGAL would never advocate anyone not
subscribing to or reading a daily newspaper. It is disturbing to us to learn
that fewer people are reading. But when you write about television's
limitations, you should not forget its advantages. When news happens,
television brings it to you almost instantly. Coverage of election returns,
life-threatening weather, earthquakes and other
Article 42 of 348, 1997326061
Published on November 22, 1997, Intelligencer Journal (Lancaster, PA)
STATE LAWYER GROUP DEFENDS DALZELL'S

RULING ON LAMBERT
Tough cases make bad laws.. So says the Pennsylvania Association of
Criminal Defense Lawyers (PACDL), which held a press conference Friday
to oppose a proposed bill which would limit the power of federal judges. The
so-called "Laurie Bill" was drafted in the wake of a federal judge's decision
to free Lisa Michelle Lambert, who was convicted in 1992 of killing
16-year-old Laurie Show. "We have found that when a piece of legislation is
proposed
Article 43 of 348, 1997325109
DEFENSE ATTORNEYS GROUP RAPS 'LAURIE BILL'

The Pennsylvania Association of Criminal Defense Lawyers has come out in
opposition to a federal bill introduced in September aimed at limiting the
power of federal judges.. The bill was drafted by Pennsylvania legislators in
reaction to a federal judge's decision to free Lisa Michelle Lambert, who
was convicted in 1992 of killing 16-year-old Laurie Show. The lawyers
organization, which is meeting this weekend in Lancaster County, is
scheduled to hold a press conference today at
1 of 3
6/10/2006 8:35 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2220
of 2301
1299
Article 44 of 348, 1997322068

RAINVILLE AGAIN CLAIMS MCCRACKEN

CONVICTION IS UNJUST
Attorneys for Darrell McCracken continue to dispute prosecutors' claims
their client had the level of malice necessary for a murder conviction when
the truck he was driving killed a family of three.. In fact, McCracken's lead
attorney, Christiana Rainville of Philadelphia, now claims her client
"probably did not even cause the accident." Rainville's assertions were filed
Monday with the state Superior Court as McCracken attempts to
Article 45 of 348, 1997320082
AU PAIR AND LAMBERT: REMEMBER VICTIMS

Reading the stories, it was hard not to think about Lisa Michelle Lambert..
Yes, there are differences in the cases of Ms. Lambert, the then-19-year-old
Lancaster County woman convicted in 1992 of murdering 16-year-old Laurie
Show, and Louise Woodward, the 19-year-old British au pair convicted this
month of murdering 8-month-old Matthew Eappen in Massachusetts. In
both, though, a judge overruled a verdict and stunned the victim's family by
letting the defendant walk out of
Article 46 of 348, 1997311113
COUNTY COULD BE LOOKING AT BUDGET DEFICIT

Lancaster County Commissioners are struggling to narrow an $11.4 million
gap between projected expenditures and revenue as they work on the 1998
budget.. "The budget looks right now like a tax increase budget," Terry
Kauffman, chairman of the County Commissioners, said during a Thursday
work session. When county departments first submitted their individual
budgets for 1998, there was an $18.8 million deficit. That number was
lowered to $11.4 million after the
Article 47 of 348, 1997311094
COUNTY ASKS STATE SUPERIOR COURT TO UPHOLD

CASSEL CONVICTION
When Nathan Cassel and two of his friends sat outside 12-year-old Kenneth
Rodriguez Jr.'s home one February day in 1996, they were armed with
deadly weapons and a "coldness of heart," intending to exact revenge on
the boy's older brother.. Those facts alone, said Lancaster County
prosecutors, prove malice, the underpinning they needed to convict Cassel
and the others of third-degree murder for killing Kenneth on Feb. 28, 1996.
2 of 3
6/10/2006 8:35 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2221
of 2301
1299
The facts also

Article 48 of 348, 1997310001
DA: LET CASSEL SENTENCE STAND

A Lancaster County jury's conviction and the judge's stiff sentence for a
man accused in the "horrendous violent crime" that claimed the life of a
12-year-old boy were correct, prosecutors insist.. Responding today to the
court appeal of Nathan D. Cassel, now 19, of Lititz, the county district
attorney's office asked state Superior Court to uphold the man's conviction
and sentence in the death of Kenneth Rodriguez Jr.
Article 49 of 348, 1997308083
SPECTER VOWS CONTINUED SUPPORT FOR 'LAURIE

BILL'
Under fire for a proposal to limit the power of federal judges in the wake of
the Lisa Michelle Lambert case, the three local congressmen who
introduced the bill now differ on whether it should move toward passage..
On Monday, New York Times columnist Anthony Lewis criticized the bill and
the congressmen who introduced it for launching an "assault" on the
independence of federal judges. Arlen Specter, an influential member of the
Senate Judiciary Committee, responded
Article 50 of 348, 1997306070

SUNDAY. Oct. 26 - Eleni Papadopoulos, 36, Lancaster, and her 15-year-old
son George, a 10th grader at Conestoga Valley, were killed in a traffic
accident on the Pennsylvania Turnpike in Chester County. The newly
refurbished McCaskey High School building was dedicated.. Charles H.
Turner, 65, was struck by a car as he tried to cross Route 30. The Elmer,
N.J., man died of injuries the next day. MONDAY. Oct. 27 - It


3 of 3
6/10/2006 8:35 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2222
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 51 of 348, 1997305084
COUNTY CALLS MCCRACKEN APPEAL 'VICIOUS'

Lancaster County is asking the state to uphold Darrell McCracken's murder
conviction and reject his appeal as a "vicious and unjustified attack" on the
three people he was convicted of killing.. McCracken was sentenced in
February after a jury convicted him of third-degree murder and vehicular
homicide in the crash that killed Geoffrey Pywell, his wife, Susan
Davies-Pywell, and their son, Nathaniel Pywell, 11. The accident occurred in
September 1995, when
Article 52 of 348, 1997305015
DA OFFICE REFUTES APPEAL BY MCCRACKEN

Not only is Darrell McCracken guilty of murder, prosecutors say, but the
"sheer audacity" of his appeal is a "vicious and unjustified attack" on three
"innocent individuals: Geoffrey, Susan and young Nathaniel Pywell.".
McCracken, 33, of 623 Hilton Drive was convicted in a trial in January of
killing the Franklin & Marshall professor, his wife and their 11-year-old child
in a traffic accident in September
Article 53 of 348, 1997303093
Published on October 30, 1997, Intelligencer Journal (Lancaster, PA)
ANTI-JUDICIAL ACTIVISM EFFORT TOUTS LAMBERT

CASE
U.S. District Judge Stewart Dalzell's decision to free Lisa Michelle Lambert
has drawn the ire of a conservative special-interest group based in
Washington, D.C.. Under its Judicial Selection Monitoring Project, the Free
Congress Foundation's Center for Law and Democracy is circulating a
videotape denouncing judicial activism in the federal courts. And Judge
Dalzell and his decision to free Lambert are the group's prime targets..
"Judge
Article 54 of 348, 1997299065
1 of 3
6/10/2006 8:35 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2223
of 2301
1299
Published on October 26, 1997, Sunday News (Lancaster, PA)

SUNDAY. Oct. 19 - A bipartisan analysis of campaign pledge costs found
that Republican mayoral candidate Charlie Smithgall's campaign promises
could cost the city up to $28 million. Smithgall scoffed at the analysis. At a
forum on Tuesday, the race heated up further when McCaskey students
asked Lyons whether he had ever used drugs, and Lyons refused to
answer. Lyons accused the Smithgall campaign of being
Article 55 of 348, 1997296103
TWISTS, TURNS STILL AHEAD IN LAMBERT CASE

Following Tuesday's court hearing in Philadelphia, Lisa Michelle Lambert's
fate now rests in the hands of the U.S. Circuit Court of Appeals, a federal
court just a step below the U.S. Supreme Court.. Legal experts said
Wednesday that the impact of the court's eventual decision will be felt
nationwide. "It has monumental implications for criminal proceedings
throughout all 50 states," said Joseph Roda, a Lancaster lawyer who has
Article 56 of 348, 1997296110
CONFIDENT IN SYSTEM
We hope those who want Lisa Michelle Lambert to be returned to jail - or at
least face a new murder trial - do not become overly optimistic after
Tuesday's hearing before the U.S. 3rd Circuit Court of Appeals in
Philadelphia.. The best way to view the proceeding is as a sort of catharsis the first time the matter has been aired in a courtroom since Lambert was
freed last spring. It's something that community - riven by this case like no
other - needed. Yes, the
Article 57 of 348, 1997295181
JUDGES HAMMER LAMBERT'S ATTORNEY AT

APPEAL HEARING
PHILADELPHIA - An attorney for Lancaster County Tuesday urged three
federal appeals court judges to allow the state court system to decide if Lisa
Michelle Lambert should remain free or be retried for the 1991 murder of
Laurie Show.. Lambert was convicted of first-degree murder in 1992, but
her conviction was reversed last April by a federal judge. Lawyer Richard A.
Sprague argued that U.S. District Judge Stewart Dalzell trampled state and
federal laws by freeing Lambert from life
2 of 3
6/10/2006 8:35 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2224
of 2301
1299
Article 58 of 348, 1997295049

Published on October 22, 1997, Lancaster New Era (PA)
SHOWS, LOCAL LAWYERS UPBEAT AFTER HEARING

PHILADELPHIA - Cautious optimism.. That's the mood today among
Lancaster County officials and the parents of murdered teen-ager Laurie
Show, after a hearing Tuesday to determine the fate of the woman who has
become their nemesis. Lisa Michelle Lambert was convicted in county court
of Miss Show's murder in 1992. In April, U.S. District Judge Stewart Dalzell
overturned the conviction and freed Lambert.. The county appealed
Dalzell's decision. At
Article 59 of 348, 1997295050
LAMBERT INNOCENT? JUDGES ASK TOUGH

QUESTIONS ABOUT SLAYING
PHILADELPHIA - Lisa Michelle Lambert's fate is once again in judges'
hands.. This time, three federal circuit court judges will decide whether she
goes back to jail in the murder of 16-year-old Laurie Show or remains free.
One of the judges was especially brutal in questioning Lambert's attorney
during a hearing Tuesday held at the request of Lancaster County attorneys,
who are appealing Lambert's release in April.. "I started to
Article 60 of 348, 1997294081
LAMBERT APPEAL TO BE HEARD BY JUDICIARY

PANEL TODAY
Lancaster County's court appeal of Lisa Michelle Lambert's release from life
imprisonment will be heard this afternoon by a panel of three federal judges
in Philadelphia.. The hearing before a panel of U.S. Circuit Court of Appeals
judges will begin at 2 p.m. in the ceremonial courtroom on the first floor of
the U.S. Courthouse at 6th and Market streets. The hearing is open to the
public, but because of the interest in Lambert's case, seating will be


3 of 3
6/10/2006 8:35 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2225
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 61 of 348, 1997293047
COUNTY TRIES TO RE-JAIL LAMBERT

After six months of preparation, Lancaster County's appeal of Lisa Michelle
Lambert's release from prison will finally be heard Tuesday in federal court..
Three judges from the U.S. Circuit Court of Appeals have allotted attorneys
on either side a maximum of 25 minutes to argue their case, with a promise
of not interrupting them only for the first 10 minutes. The hearing will be
held in the same ceremonial courtroom in Philadelphia where Lambert was
declared
Article 62 of 348, 1997285074

SUNDAY Oct. 5 - Thousands packed Long's Park to hear country music acts
at the WIOV/Turkey Hill Fall Music Fest.. `Bird-in-Hand firefighters and
neighbors helped to save the home of the Christ Beiler family on Miller Lane
after a fire started at 3 a.m.. `Warm, summer-like weather set in, with
temperatures rising well into the 80s.. MONDAY. Oct. 6 - Jurors heard from
the mother of victim Daryl
Article 63 of 348, 1997282104
LAWYERS CLAIM CASSEL TREATED UNFAIRLY AT

TRIAL RAINVILLE APPEALS CONVICTION
Attorneys for a Lancaster teen-ager convicted in the 1996 shooting death of
a 12-year-old Mary Street boy are appealing the conviction on the grounds
he was not given a fair trial.. The appeal was filed Tuesday in state Superior
Court on behalf of Nathan Cassel, 19, of Lititz, who was convicted with two
youths of killing Kenneth Rodriguez Jr. Feb. 28, 1996, as he stood at his
bedroom window. Philadelphia attorney Christina Rainville alleges
Lancaster County Judge Louis J. Farina erred in not
Article 64 of 348, 1997281071
1 of 3
6/10/2006 8:36 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2226
of 2301
1299
LEWIS TO QUIT AS CITY GOP CHIEF

Alvin B. Lewis Jr. is stepping down as Lancaster city Republican chairman
sometime after the Nov. 4 election.. Lewis, who has led the city GOP since
1994, said he told other party leaders of his intentions last spring, but it
wasn't until last week that he informed rank and file committee people. He
said Tuesday that the demands of his legal practice prompted his decision..
"My practice was growing, and I had to make a decision between business
and the party and
Article 65 of 348, 1997281053
RAINVILLE HITS THE DEFENSE IN MARY ST. DEATH

TRIAL
A state court should overturn a Lititz teen's conviction for the murder of a
Mary Street boy due to insufficient evidence, errors by his trial attorney and
his overly heavy sentence, according to an appeal filed Tuesday.. Christina
Rainville, a Philadelphia attorney, entered the appeal in state Superior Court
on behalf of Nathan Cassel, 19, of Lititz. It is Rainville's third appeal of a
local murder case. "The record in this case is so devoid of
Article 66 of 348, 1997278069

SUNDAY. Sept. 28 - Gloria J. Hargis, 48, Ephrata, was killed in a two-car
crash at Clay and East Newport roads. MONDAY Sept. 29 - Commonwealth
Security Systems Inc., sold less than a year ago to Republic Industries, was
sold again to Ameritech. Commonwealth was founded by Patrick Egan, who
sold the company to Republic for $36.5 million in stock. TUESDAY. Sept. 30
- About 119,000 PP&L customers signed up
Article 67 of 348, 1997278085
37,000 AGREE WITH CRUSADE TO IMPEACH JUDGE

DALZELL
This is in response to the Sunday News editorial of Sept. 28, titled "The
wrong path," regarding John and Hazel Show's crusade to impeach Judge
Stewart Dalzell and to present a national petition for further legislation
regarding federal judges and their powers. The editor cannot endorse the
crusade; however, along with many congressmen, there are at least 37,000
individuals who wholeheartedly agree with this crusade, as evidenced by
the signed petitions..
2 of 3
6/10/2006 8:36 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2227
of 2301
1299
Article 68 of 348, 1997275105

LAMBERT APPEAL COULD HINGE ON RECENT

RULING
Attorneys handling Lancaster County's appeal of Lisa Michelle Lambert's
release from life imprisonment believe a federal court ruling two weeks ago
in a Luzerne County murder case will be pivotal in helping their appeal.. The
three 3rd U.S. Circuit Court of Appeals judges assigned to hear the county's
appeal in Philadelphia on Oct. 21 on Tuesday asked lawyers for Lambert
and Lancaster County to submit written arguments comparing Lambert's
case
Article 69 of 348, 1997275060
MCCRACKEN TRIAL WAS UNFAIR, SAYS RAINVILLE

Daryl McCracken's trial just wasn't fair, his attorney maintains.. "No
reasonable juror would have convicted McCracken had the trial been fair,"
Christina Rainville wrote to the state Superior Court Wednesday. "This case
involves a tragic fatal accident which left three people dead. It is all the
more tragic because the aftermath of the accident was a prosecution of an
innocent man.". The worst of numerous offenses,
Article 70 of 348, 1997274042

The panel of judges has been appointed. The time has been set.. About
three weeks from today, the lawyers in the Lisa Michelle Lambert case will
get exactly 15 minutes each to argue their positions before a federal
appeals court. The attorneys will appear at 2 p.m. Tuesday, Oct. 21, in the
federal courthouse in Philadelphia.. Hearing them will be a panel of three
judges: Carol Los Mansmann, 55, of Pittsburgh; Morton I. Greenberg, 64, of
Philadelphia; and Arthur R. Alarcon, 72, of


3 of 3
6/10/2006 8:36 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2228
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 71 of 348, 1997274044

The lawyers arguing over Lisa Michelle Lambert's freedom may have just
been given a hint of what the three judges deciding the case want to hear..
Did Lambert exhaust all her appeals in Pennsylvania's courts before she
turned to a federal court judge for help? Last spring, U.S. District Judge
Stewart Dalzell freed Lambert from her life prison sentence for the murder
of 16-year-old Laurie Show of East Lampeter Twp.. In their appeal of that
decision, attorneys
Article 72 of 348, 1997271078
Published on September 28, 1997, Sunday News (Lancaster, PA)
THE WRONG PATH

No one, except another parent who has lost a child, can understand how
John and Hazel Show feel.. Like most other Lancaster Countians, we can
only sympathize with the Shows and their pain, these six years after the
horrible murder of their 16-year-old daughter Laurie. But we can't endorse
their crusade against the federal judge who freed Miss Show's convicted
murderer, Lisa Michelle Lambert, from jail.. The Shows want Judge Stewart
Dalzell to be impeached - removed
Article 73 of 348, 1997267138
Published on September 24, 1997, Intelligencer Journal (Lancaster,
PA)
MYSTERIES WILL BE TOPIC OF 5 LECTURES

According to writer Neil Albert, mysteries are really morality plays.. "The
killer gets caught, he pays his price, society is safe and the world is okay,"
he said. Albert, an attorney with Zimmerman, Pfannebecker and Nuffort, is
the author of six detective thrillers featuring David Garrett, a disbarred
attorney, caught taking the bar exam for his wife.. The Unitarian Universalist
Center's Beacon Program of Leisure Learning will be featuring Neil Albert
Article 74 of 348, 1997267179
1 of 4
6/10/2006 8:38 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2229
of 2301
1299

PA)
MU STUDENT REPUBLICANS ELECT OFFICERS

New officers have been elected to lead the Millersville University College
Republicans.. Kristin McGeary, sister of Jeff McGeary, last year's candidate
for chairman of the Pennsylvania College Republicans, was re-elected
chairman for the 1997-98 school year. Other offices are: James Senft, vice
chairman; Tara Tomlinson, secretary; and alumnus Dean Lee Evans, public
relations coordinator. James Jolly, history professor, is the academic
adviser.. The group's current
Article 75 of 348, 1997267033
Published on September 24, 1997, Lancaster New Era (PA)
PASS 'LAURIE BILL' TO CURB POWER OF FEDERAL

JUDICIARY
Some may consider the "Laurie Bill" a congressional attempt to subvert the
power of the federal judiciary. Count us among those who look at this
legislation as a simple effort to balance judicial activism with reasoned
regulation.. The bill, formally known as the Victim Protection Act, was
introduced last month in the Senate by Sen. Arlen Specter and in the House
by Reps. George Gekas and Joseph Pitts. The bill would prohibit federal
judges in most cases from barring
Article 76 of 348, 1997264062

SUNDAY Sept. 14 - A speeding car slammed into a buggy in West
Hempfield, injuring six members of the Melvin Petersheim family. The driver
drove away and then abandoned his car. Members of the family were
treated and released. On Monday, a Lebanon man called police and
admitted he was the driver.. MONDAY. Sept. 15 - The cameras began
rolling at Landis Valley Museum for two days of shooting on the movie
Article 77 of 348, 1997261094
PA)
SHOWS TAKE THEIR CASE TO CAPITOL

WASHINGTON - The parents of murder victim Laurie Show crisscrossed
Capitol Hill Wednesday, presenting 11 Pennsylvania legislators with
petitions asking them to probe the conduct of a federal judge and reform the
federal court system.. Wednesday marked the official kickoff of John and
Hazel Shows' national campaign to have U.S. District Judge Stewart Dalzell
impeached and to have legislation enacted curtailing the power of federal
judges. U.S. Sen. Arlen Specter and U.S. Reps.
2 of 4
6/10/2006 8:38 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2230
of 2301
1299

Article 78 of 348, 1997261047
SHOWS TAKE FIGHT TO CONGRESS

WASHINGTON - Five months after their daughter's alleged killer was freed
from federal prison after an appeal, John and Hazel Show arrived here
Wednesday to ask 11 members of Congress for help.. Armed with petitions
containing the signatures of some 37,000 Lancaster County residents, the
Shows met all day with lawmakers to try to enlist support for their cause.
The petitions ask for the impeachment of the federal judge who freed the
alleged killer of their 16-year-old daughter,
Article 79 of 348, 1997257058

SUNDAY Sept. 7 - Elizabethtown police said the shooting deaths on
Saturday, Sept. 6, of Edward Brenner Jr., 52, and Michael C. MacDonald,
45, both of Elizabethtown, may have been a murder-suicide.. MONDAY.
Sept. 8 - Citing technical concerns, the Manor Township Planning
Commission voted 4-3 to reject Wal-Mart's revised plan for a superstore on
Centerville Road. The county planning commission will have
Article 80 of 348, 1997253192
PA)
RAINVILLE MAY BE IN TROUBLE AT HER OWN LAW

FIRM
Christina Rainville's legal work to free Lisa Michelle Lambert from life
imprisonment enraged many in Lancaster County.. And she didn't win many
fans here when she agreed to represent Darrell McCracken, who was
convicted of third-degree murder for causing a traffic accident that killed a
Franklin & Marshall College professor, his wife and their 11-year-old son.
Now it appears that her continued legal representation of Lambert and her
subsequent work on

3 of 4
6/10/2006 8:38 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2231
of 2301
1299
4 of 4
6/10/2006 8:38 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2232
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 81 of 348, 1997252024
MCCRACKEN EVIDENCE WAS 'RIGGED,' APPEAL

SAYS
Will Darrel McCracken walk out of prison a free man because of misconduct
by Lancaster County prosecutors?. He should, said McCracken's attorney,
Christina Rainville, because he was wrongly convicted by the prosecutors'
intentional "manipulation of the evidence." McCracken, 33, of 623 Hilton
Drive, was convicted of third-degree murder for a traffic accident that
claimed the life of Franklin & Marshall College professor Geoffrey
Article 82 of 348, 1997249070
Published on September 6, 1997, Intelligencer Journal (Lancaster, PA)
PYWELLS BLAMED FOR OWN DEATHS IN

MCCRACKEN CASE
Attorneys representing Darrel McCracken in his appeal to have his
third-degree murder conviction overturned are claiming his victims' car was
going 99 miles per hour when it was struck by McCracken's truck.. In her
state Superior Court filing late Thursday, attorney Christina Rainville and
two colleagues claim a police report of the Sept. 3, 1995, accident clearly
states the car driven by Geoffrey Pywell was speeding before the collision
that night with McCracken at
Article 83 of 348, 1997248085
MCCRACKEN PASSENGER PLANS TO SUE

A passenger riding in a truck driven by Darryl McCracken the night he ran a
traffic light and killed a Lancaster family has filed notice that he plans to sue
McCracken, a fellow passenger and the dead family's estate.. George
Snook, 922 High St., through his Philadelphia attorney, Robert Land, filed
the notice, called a Writ of Summons, in Lancaster County Court on
Wednesday. The filing names as defendants McCracken, 623 Hilton Drive;
the second passenger, Archer Morgan III, 846
1 of 3
6/10/2006 8:39 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2233
of 2301
1299
Article 84 of 348, 1997248090

ATTORNEYS BATTLE OVER MCCRACKEN EVIDENCE

A county judge Thursday ordered Darryl McCracken's trial attorney to turn
over all documents related to the case to the attorneys handling
McCracken's appeal of a third-degree murder conviction.. Judge Paul K.
Allison, acting on a motion filed by attorney Christina Rainville of
Philadelphia, gave Lancaster attorney Roy D. Shirk five days to comply with
his order. In her filing, Rainville, who gained notoriety here for winning the
freedom of Lisa Michelle Lambert, said
Article 85 of 348, 1997246029
MCCRACKEN APPEAL STALLS AS RAINVILLE VIEWS

DOCUMENTS
Darrel McCracken's appeal process has been delayed until his new
Philadelphia attorney can look at video tapes, documents and evidence
from his Lancaster County trial.. McCracken was convicted in January of
killing Franklin and Marshall College professor Geofffrey Pywell, Pywell's
wife, Susan Davies-Pywell, and their 11-year-old son, Nathaniel, in a traffic
accident in September 1995. A jury found McCracken guilty of third-degree
murder for intentionally not stopping
Article 86 of 348, 1997244100
PARENTS OF MURDERED TEEN-AGER LAUNCH

CRUSADE AGAINST JUDGE
EDITOR'S NOTE: This is the fourth in a series of articles on the Lisa
Michelle Lambert case and its implications. The occasional series will use
her overturned murder conviction as a touchstone to show how state and
federal courts work. Today's story focuses on Hazel and John Show, the
parents of murder victim Laurie Show, and their campaign to have U.S.
District Judge Stewart Dalzell impeached.. Hazel and John Show, a
divorced Lancaster County couple, have united to
Article 87 of 348, 1997237220
Published on August 25, 1997, Lancaster New Era (PA)
MOUNTVILLE MAN LEADS YOUNG GOP

New officers have been elected to lead the Lancaster County Young
Republicans.. Serving as chairman is Bruce Gadbois of Mountville. Other
officers are Aaron Ranck, vice chairman; Karen Johnson, secretary; and
Dean Lee Evans, treasurer. The group's current activities include helping
the Lancaster mayoral campaign of Charlie Smithgall, the borough
councilcampaign of Gadbois, and the petition drive to oust the federal judge
who overturned the murder conviction of Lisa Michelle
2 of 3
6/10/2006 8:39 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2234
of 2301
1299

Article 88 of 348, 1997236348
Published on August 24, 1997, Sunday News (Lancaster, PA)
SCOTT OBERHOLTZER ENJOYS CALLING HIS OWN

SHOTS
Even as a kid, Scott K. Oberholtzer envisioned a call-your-own-shots type of
career.. "Originally," he says, "I wanted to be a research scientist." But law
was his strong suit. Since he started practicing in Lancaster 15 years ago,
Oberholtzer, the county's first assistant public defender, has handled four
death penalty cases and half a dozen more murder trials.. He has recently
become known as a legal analyst, offering his views
Article 89 of 348, 1997235143
RAINVILLE PARTNER (AND SPOUSE) TAKES LEAD

ROLE
When Lisa Michelle Lambert's case for freedom comes before a federal
appeals court in October, she'll have Philadelphia attorney Peter S.
Greenberg in her corner arguing her case.. Although attorney Christina
Rainville became known as the leader of the eight-member legal team that
won Lambert's release from a life prison sentence in April, Greenberg has
worked beside her from the start. Greenberg, 53, is a partner in the
200-member Philadelphia law firm of
Article 90 of 348, 1997231177
PHILA. ATTORNEY TO ARGUE LAMBERT APPEAL

A Philadelphia attorney will be arguing the county's appeal in the Lisa
Michelle Lambert case in federal court in October.. Richard A. Sprague, of
Sprague & Lewis, 116 E. King St., and Sprague & Sprague, Philadelphia, is
now preparing to argue the case before the 3rd U.S. Circuit Court of
Appeals in Philadelphia, said his local law partner Alvin B. Lewis Jr. The
court has tentatively marked Oct. 20 as the date it will listen to arguments
from attorneys on


3 of 3
6/10/2006 8:39 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2235
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 91 of 348, 1997230276
Published on August 18, 1997, Intelligencer Journal (Lancaster, PA)
TAXPAYERS SHOULDN'T PAY COST OF LAWYERS

To the Editor: Why should the taxpayers in Lancaster County have the
burden to pay outrageous lawyer fees for the district attorneys and others
who created this problem with the Lisa Michelle Lambert case.. They are
the guilty ones who did unethical technicalities and are guilty in this
situation. The money should come out of their pockets and not out of the
pockets of the poor in Lancaster County. So now lawyers are getting rich at
the expense of Lancaster County citizens. Judge Dalzell did
Article 92 of 348, 1997229335

SUNDAY Aug. 10 - DeeDee Carolann Null, Lancaster, was killed when the
motorcycle on which she was a passenger crashed into a tree in Martic
Township. The 27-year-old was the mother of four children.. The highway
carnage continued Tuesday when Donald Dorwart, 42, Book Road, was
killed in an early-morning crash on Route 222 in Manheim Township that
closed the road for nearly five hours.. Eighteen hours later in West
Article 93 of 348, 1997227262
COURT TO CONSIDER STATES' ARGUMENTS IN

LAMBERT CASE
Lancaster County's bid to return Lisa Michelle Lambert to prison got a boost
Thursday when a federal appeals court agreed to allow six states to formally
support the county's challenge of her freedom.. The 3rd U.S. Court of
Appeals on Thursday permitted attorneys general from Pennsylvania,
Delaware, California, Oklahoma, Louisiana and South Carolina to make
legal arguments on behalf of the county's appeal of a judge's decision to
free Lambert
Article 94 of 348, 1997226306
1 of 3
6/10/2006 8:40 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2236
of 2301
1299
MCCRACKEN RAISES MISCONDUCT ISSUE

The Philadelphia lawyer who helped Lisa Michelle Lambert win her freedom
said in court papers filed Wednesday that Darrell McCracken should be
released from jail for the same reason - prosecutorial misconduct.. Christina
Rainville, who is handling McCracken's court appeal, told the state Superior
Court that her client was denied a fair trial in Lancaster County Court earlier
this year. In the court filing, Rainville accuses county prosecutors of
misconduct; says
Article 95 of 348, 1997226254
COURT ACCEPTS STATES' BRIEF IN LAMBERT CASE

The federal judges who will decide whether Lisa Michelle Lambert remains
free have decided to accept a "friend of the court" brief filed by six attorneys
general in support of Lancaster County.. The news is a shot in the arm for
the county's appeal of a federal judge's decision to free Lambert and bar
efforts to retry her for the 1991 killing of a teen-age Lancaster girl. It means
the 3rd U.S. Circuit Court of Appeals will factor the
Article 96 of 348, 1997223332
TIME TO ALTER THE JUDICIAL SYSTEM IN US

To the Editor:. Dalzell does not walk with God. Your recent article on the
power that federal courts possess (Intell, Aug. 1) supports the key
ideological philosophy that drove Timothy McVey to kill 168 people. That is
that government is too big, too intrusive to the rights of law-abiding
Americans and downright dangerous. I do not support what McVey did, but
we tend to be shortsighted and one-sided in our views. We do not see why
McVey did what he did, we only saw the dead babies. At least
Article 97 of 348, 1997222311

SUNDAY Aug. 3 - PennDOT said it will meet with the prime contractor to
develop a plan to get the Route 30 widening project back on schedule..
`Fires destroyed the Instant Amish Photo Gallery in Intercourse and
damaged a home in Strasburg.. MONDAY. Aug. 4 - While their children
played outside their Mountville home, Charles and Lisa Mock argued inside.
Manor Township police said Charles then shot his wife with a
Article 98 of 348, 1997221193
2 of 3
6/10/2006 8:40 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2237
of 2301
1299
DATE SET TO HEAR ARGUMENTS IN LAMBERT

APPEAL
Michelle Lambert's freedom has tentatively scheduled time in late October
for lawyers to present verbal arguments in front of a panel of judges.. The
3rd U.S. Court of Appeals expects to hear from attorneys for the county and
Lambert in court on Tuesday, Oct. 21, said Brad Baldus, a circuit court law
clerk assigned to the Lambert case. Alvin B. Lewis Jr., a Lancaster lawyer
who represents the
Article 99 of 348, 1997221205
COUNTY'S BILLS IN LAMBERT CASE TOP $500,000

The cost of challenging Lisa Michelle Lambert's release has topped half a
million dollars and will rise considerably, according to the chairman of the
county commissioners.. Outside lawyers hired by Lancaster County have
submitted bills totaling $540,000 for legal work on the case, chairman Terry
Kauffman said. The money will come from taxpayers. So far, the county has
been able to pay the fees through belt-tightening rather than by dipping into
cash reserves. No county employees
Article 100 of 348, 1997220250
COUNTY APPEAL IN LAMBERT CASE SLATED FOR

OCT. 20
The federal appellate court has tentatively marked Oct. 20 as the date it will
listen to legal arguments from attorneys on either side of the Lisa Michelle
Lambert case.. Officials with the 3rd U.S. Circuit Court of Appeals said they
will reveal, 10 days before that date, the identity of the three federal judges
who will hear the arguments. Lancaster County began the appeal process
after U.S. Judge Stewart Dalzell freed Lambert in April and forbade
prosecutors from trying her again for the


3 of 3
6/10/2006 8:40 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2238
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 101 of 348, 1997220256
WAS TRAFFIC LIGHT BROKEN DURING CRASH?

Just days after Darrel McCracken struck and killed a family of three at a city
intersection, the traffic light there malfunctioned.. City repairmen were
called out to repair the light twice on Sept. 8, 1995, five days after
McCracken struck a station wagon and killed Franklin and Marshall College
Professor Geoffrey Pywell, his wife, Susan Davies-Pywell, and their
11-year-old son, Nathaniel. In January, a jury found McCracken guilty of
third-degree murder. He was sentenced to 10 to 20 years
Article 102 of 348, 1997219246
6 STATES DEFEND FILING FOR LAMBERT

They want what is fair and they have the right to support the county in its
appeal of the freeing of Lisa Michelle Lambert.. So said the attorneys
general of six states Wednesday in an attempt to uphold their right to file a
"friend of the court brief" in the Lambert case. "Justice must be done to both
Lambert and the Commonwealth," the attorneys general stated in their
latest filing in the case.. Pa. Attorney General Mike Fisher and the
Article 103 of 348, 1997218429
NO MATTER WHAT, BUCK HELPED KILL LAURIE, DA

SAYS
Prosecutors are not admitting they made mistakes in the investigation of
16-year-old Laurie Show's murder.. But, even if they did, convicted killer
Tabitha Buck does not deserve another chance in court, the Lancaster
County District Attorney's office wrote recently. "Even if errors occurred,"
John A. Kenneff, first assistant district attorney, wrote in a new legal filing,
Buck does not deserve "relief" in the case,
Article 104 of 348, 1997217163
1 of 3
6/10/2006 8:41 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2239
of 2301
1299
RENO: SENATE TOO SLOW IN OK OF JUDGES

From Staff and Wire Reports. Attorney General Janet Reno today accused
the Senate of an "unprecedented slowdown" in confirming President
Clinton's nominees for federal judgeships, saying the delay is harming the
justice system. "Surely the (Constitution's) framers did not intend Congress
to obstruct the appointment of much-needed judges, but rather simply to
ensure that well-qualified individuals were appointed to the federal
Article 105 of 348, 1997215338

SUNDAY July 27 - The death of Mark Groner, 25, a band instructor in
Hempfield schools, was reported. He was involved in a traffic accident
Friday and died Saturday.. MONDAY. July 28 - Traffic was snarled on Route
30 after a cement-mixing truck hit an overpass at rush hour, jamming
eastbound traffic for four hours.. Lancaster County planners, as expected,
turned down Wal-Mart's plan for a store on
Article 106 of 348, 1997214220
LAMBERT LAWYERS BLAST ATTEMPT TO APPEAL

STATE COURT'S DECISION
Lisa Michelle Lambert's lawyers blasted an attempt by six state attorneys
general to support Lancaster County's court appeal of Lambert's freedom,
urging a federal appeals court to disallow the states' effort.. Led by
Pennsylvania Attorney General Mike Fisher, attorneys general from
Delaware, Louisiana, South Carolina, Oklahoma and California asked the
3rd U.S. Circuit Court of Appeals to allow the group to support the county's
Article 107 of 348, 1997213301
FEDERAL JUDGES DON'T ANSWER TO PUBLIC

EDITOR'S NOTE: This is the third in a series of articles on the Lisa Michelle
Lambert case and its implications. The series will use her overturned murder
conviction as a touchstone to show how state and federal courts work.
Today's story focuses on the power of federal judges.. It's been said that
federal judges are the closest thing to God because they are not
accountable to anyone. Once the president appoints someone to the federal
bench,
Article 108 of 348, 1997213304
2 of 3
6/10/2006 8:41 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2240
of 2301
1299
LEGISLATORS AIM TO CURB FEDERAL JUDGES'

POWER
WASHINGTON - A bill aimed at limiting the power of federal judges, which
was drafted in reaction to the Lisa Michelle Lambert case, isn't expected to
be considered by Congress until next year, the three legislators who
introduced it said Thursday.. U.S. Sen. Arlen Specter and U.S. Reps.
Joseph R. Pitts and George W. Gekas collaborated on the legislation, which
would prohibit federal judges in most cases from barring the retrial of a
person convicted in a state court. It will be
Article 109 of 348, 1997213306
A RATIONAL RESPONSE
Until now, the reaction to Judge Stewart Dalzell's decision to free Lisa
Michelle Lambert has produced much heat but little light.. With the
introduction of legislation aimed at curbing the power of federal judges, we
are beginning to see some light. U.S. Sen. Arlen Specter and U.S. Reps.
Joe Pitts and George Gekas unveiled the Victim Protection Act of 1997
Thursday, which is designed to prohibit federal judges in most cases from
barring the retrial of a person convicted in a
Article 110 of 348, 1997213253
ATTORNEYS FOR LAMBERT RIP STATES' FILING

Lisa Michelle Lambert's attorneys fired back Thursday at a brief attacking
Lambert's freedom filed by the state attorney general and supported by the
attorneys general of five other states.. Not only was the brief filed late,
Lambert's attorneys said, it is highly improper because the state has two
distinct conflicts of interest in the case. "This state, with all of its resources,
apparently will go to any length - lawful or unlawful, ethical


3 of 3
6/10/2006 8:41 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2241
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 111 of 348, 1997212323
Published on July 31, 1997, Intelligencer Journal (Lancaster, PA)
BILL WOULD LIMIT POWER OF FEDERAL JUDGES

Sparked by a federal judge's decision to free Lisa Michelle Lambert, three
federal legislators will introduce legislation today that would limit the power
of federal judges.. U.S. Sen. Arlen Specter and U.S. Reps. Joseph R. Pitts
and George W. Gekas will unveil the Victim Protection Act of 1997 at 1:30
p.m., during a press conference on the east steps of the U.S. Capitol in
Washington, D.C. If the act passes the Senate and House of
Representatives and is eventually signed into
Article 112 of 348, 1997212280
Published on July 31, 1997, Lancaster New Era (PA)
BILL TO LIMIT POWER OF FEDERAL JUDGES

UNVEILED
Local lawmakers were introducing legislation in Washington today "on
behalf of Laurie Show" that would limit the power of federal judges.. The
legislation would forbid federal judges from barring retrials of convicted
criminals - just like a Philadelphia federal judge did when he freed Lisa
Michelle Lambert in April. U.S. Reps. Joseph R. Pitts and George W.
Gekas, along with U.S. Sen. Arlen Specter, were to unveil the amendment
at a press conference..
Article 113 of 348, 1997211511
LAMBERT LAWYER FIRES OPENING ROUND IN

ANOTHER MURDER CASE
The same Philadelphia lawyer who helped Lisa Michelle Lambert win her
freedom maintains that a teen-ager convicted of killing a 12-year-old city
boy did not receive a fair trial in Lancaster County Court.. Christina Rainville
and her associate, James D. Crawford, are representing Nathan Cassel, a
19-year-old Warwick High School dropout who is serving a 15-to-40-year
prison sentence. Cassel was one of three teen-agers convicted of killing
Kenneth Rodriguez while he stood by a second-floor
1 of 3
6/10/2006 8:42 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2242
of 2301
1299
Article 114 of 348, 1997210239

COURT SETS TIMES TO HEAR LAMBERT APPEAL

Michelle Lambert's freedom has tentatively scheduled time for attorneys to
present their arguments in front of a panel of judges.. The 3rd U.S. Circuit
Court of Appeals in Philadelphia has notified lawyers representing Lambert
and the county that oral arguments regarding the county's appeal will be
heard in court on one of five days in October or November. The possible
days are
Article 115 of 348, 1997208371
Published on July 27, 1997, Sunday News (Lancaster, PA)

SUNDAY July 20 - The week opened with dry, hot weather continuing, but
then rain of up to a half-inch fell Monday night in scattered areas of the
county.. By early Wednesday, as remnants of Hurricane Danny stalled over
the area, the parched region got what it needed - a soaking rain. The rains
continued off and on through Thursday. In short order, the area went from a
drought watch to a flood watch; rains in some
Article 116 of 348, 1997207218
LATEST LAMBERT DISPUTE: LIES IN BUCK'S

TESTIMONY
Attorneys on both sides of Lisa Michelle Lambert's appeal have fired a
volley of new assaults at one another.. This time, the controversy centers on
Tabitha Buck, Lambert's accused conspirator in the murder of 16-year-old
Laurie Show in December 1991. Both Buck and Lambert, who were 17 and
19 respectively at the time of the murder, were convicted of killing the
Conestoga Valley High School sophomore and sentenced to life in prison.
In April, Lambert was freed after a
Article 117 of 348, 1997206240
SUBURB POLICEMAN FACES TRIAL ON CHILD

MORALS CHARGES
For years, beginning when the girl was about 8 years old, she watched
pornographic videos with him.. Then the man, an East Lampeter Township
police officer, began fondling her, the girl told a district justice today,
touching her body and bribing her to perform oral sex on him. Finally, they
had sexual intercourse.. She never told anyone, she testified.. Not her
2 of 3
6/10/2006 8:42 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2243
of 2301
1299
mother. Not her closest friends.. Until she was told that the man, Robert S.
Reed, 38, of 314 Greenland Drive, had been
Article 118 of 348, 1997204477
ATTORNEYS HAGGLE ON BUCK DEPOSITION

Private attorneys handling Lancaster County's federal court appeal of Lisa
Michelle Lambert's freedom and Lambert's lawyers on Tuesday continued a
war of words over whether one sentence should be stricken from the court
record.. That sentence is: "Respondents (Lancaster County and the
Commonwealth of Pennsylvania) could just as easily ask this court to
supplement the record with the deposition testimony of one of Lambert's
Article 119 of 348, 1997204478
6 STATES WANT A SAY IN LAMBERT CASE

Six states have asked to intervene on behalf of Lancaster County's appeal
of Lisa Michelle Lambert's freedom.. The attorneys general from
Pennsylvania, Delaware, California, Louisiana, Oklahoma and South
Carolina have asked the 3rd U.S. Circuit Court of Appeals to let them
support the county's effort to retry Lambert for a 1991 murder. The states
joined Monday to file "friend of the court" legal papers supporting the
Article 120 of 348, 1997203184
PENNA., 5 OTHER STATES JOIN COUNTY IN LAMBERT

APPEAL
Lancaster County has six powerful, new "friends," who support its objection
to the freeing of Lisa Michelle Lambert.. They are the attorneys general
from Pennsylvania, California, Delaware, Louisiana, Oklahoma and South
Carolina. The six states joined in a "friend of the court" brief filed Monday on
behalf of Lancaster County in federal court in Philadelphia.. The states filed
the brief because they believe that the decision to free Lambert


3 of 3
6/10/2006 8:42 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2244
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 121 of 348, 1997201311

SUNDAY July 13 _ Hot, humid weather settled over the area. On Monday,
the high at Millersville University's weather station was 95. Rainfall also
continued to be below normal, with July 1.75 inches under as of Monday..
By Tuesday, municipalities were asking residents to voluntarily limit their
use of water. By the end of the week, it was no longer voluntary in some
places.. Tuesday's
Article 122 of 348, 1997200275
PITTS SAYS ROUTE 23 STUDY WILL BE LAUNCHED

NEXT MONTH
A new $1.5 million study of what should be done to improve the Route 23
corridor between Lancaster and New Holland will begin next month and will
take 1 1/2 to 2 years to complete, U.S. Rep. Joseph R. Pitts announced
Friday.. Pitts made the announcement to about 40 people gathered for a
town meeting he held at New Holland Borough Hall. He said about $1.2
million for the study is coming from the federal government. The remainder
will come from the state and the county. The congressman said
Article 123 of 348, 1997198349
LAMBERT LAWYERS GET $252,000 IN LEGAL FEES

Lawyers who helped Lisa Michelle Lambert win her freedom have been
granted $252,000 in court-appointed legal fees.. The fees will be paid from
U.S. taxpayer money set aside for such purposes. U.S. District Judge
Stewart Dalzell, who overturned Lambert's first-degree murder conviction
and freed her in April from life in jail, recommended the fee payment for
attorney Christina Rainville and seven of her colleagues at the Philadelphia
law firm Schnader Harrison Segal &
Article 124 of 348, 1997198346
1 of 3
6/10/2006 8:42 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2245
of 2301
1299
COUNTY LAWYERS MAKE FINAL APPEAL TO COURT

Lawyers representing Lancaster County Wednesday again asked a federal
appeals court to allow the retrial of Lisa Michelle Lambert for the 1991
murder of Laurie Show.. The county's lawyers, Richard A. Sprague in
Philadelphia and Alvin B. Lewis Jr. in Lancaster, made the request to the
3rd U.S. Court of Appeals in their final court papers before the court issues
a decision in this case. The appellate court has the option of allowing
attorneys on both sides of the Lambert case to
Article 125 of 348, 1997198296
LAMBERT'S ATTORNEYS AWARDED $252,000

Lawyers for Lancaster County probably will not appeal a judge's awarding
of $252,000 in legal fees to the defense attorneys who helped to free Lisa
Michelle Lambert.. The fees, which were awarded Wednesday, will be paid
in the next week to Christina Rainville and her colleagues at the
Philadelphia law firm of Schnader Harrison Segal & Lewis. The money will
come from federal taxpayers. Rainville and her colleagues helped Lambert
win her freedom in April in a hearing
Article 126 of 348, 1997198297
COUNTY APPEAL: LAMBERT LAWYERS

DISREGARDED FACTS
Lisa Michelle Lambert was convicted of murder by "overwhelming
evidence," Lancaster County lawyers charge, yet her attorneys "disregarded
the facts and disregarded the law" in the crusade to free their client.. In the
county's latest effort, filed late Wednesday, lawyers asked a federal appeals
court to reverse Judge Stewart Dalzell's decision to free Lambert. Or at
least, the county said, the court should order that she
Article 127 of 348, 1997194353

SUNDAY July 6 - Jose Berley, 24, of Columbia, died from wounds he
received when he was shot in the leg by a Columbia policeman on June 21.
State police investigated the shooting, which is now under review by the
Lancaster County District Attorney's office.. MONDAY. July 7 - A
200-year-old Manor Township barn owned by state Rep. John Barley and
his brother, Abe Barley, was destroyed by a two-alarm fire.
2 of 3
6/10/2006 8:42 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2246
of 2301
1299
Article 128 of 348, 1997193220

ATTORNEYS NOW SEEKING $284,000 IN LAMBERT

FEES
Lawyers who helped Lisa Michelle Lambert win her freedom Thursday
made a formal request to a federal judge to be paid more than $280,000 in
taxpayer money for Lambert's legal fees.. Philadelphia attorney Christina
Rainville filed a fee voucher asking U.S. District Judge Stewart Dalzell to
approve payment of $283,988 in fees for 5,019 hours of legal work for
Lambert from Oct. 4, 1996, to April 21. It was on April 21 that Dalzell
overturned Lambert's murder conviction
Article 129 of 348, 1997191288
COUNTY LAWYERS WANT LONG CHAT WITH

JUDGES
Lawyers representing Lancaster County in its appeal of Lisa Michelle
Lambert's release from prison on Wednesday urged a federal appellate
court to schedule a longer-than-usual open court session so they can
verbally argue their points in front of a panel of judges.. The county's
lawyers, Richard A. Sprague in Philadelphia and Alvin B. Lewis Jr. in
Lancaster, asked the 3rd U.S. Circuit Court of Appeals to allow them 30
minutes to present their oral arguments. The
Article 130 of 348, 1997191289
FOLLOWING LAMBERT'S FOOTSTEPS

Tabitha F. Buck wants a judge to set her free and block authorities from
retrying her for the 1991 murder of Laurie Show.. Three months ago Lisa
Michelle Lambert, the other woman convicted in 1992 of killing Show, was
released from jail by a federal judge and cleared of the killing. The judge
barred county prosecutors from trying Lambert again for Show's murder.
Now Buck, using some of the information that transpired in the Lambert
hearing, has begun the same process that Lambert


3 of 3
6/10/2006 8:42 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2247
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 131 of 348, 1997190405
TABITHA BUCK IS SEEKING FREEDOM IN SHOW

MURDER
Now, it's Tabitha Buck's turn.. Five years ago, she and Lisa Michelle
Lambert were sentenced to life in prison for murdering 16-year-old Laurie
Show. In April, a federal judge freed Lambert forever, saying Lancaster
County prosecutors fabricated evidence and lied to earn the conviction..
Now Buck is asking for her freedom, too.. Her reason? Prosecutorial
misconduct.. Buck claims county prosecutors tampered with or did not
disclose physical evidence and did
Article 132 of 348, 1997187345

MONDAY. June 30 - Armstrong World Industries and Worthington Industries
announced they will build a $9 million facility in Benton Harbor, Mich., to
build ceiling grids. The jobless rate for Lancaster County in May was
reported as 2.7 percent, the lowest in the state.. The Manheim Township
commissioners voted 3-1 for an intermunicipal agreement to allow the
building of Red Rose Commons, a large shopping center on the
Article 133 of 348, 1997187374
MYSTERY BOOK MAKES GOOD LISTENING AUDIO

REVIEW
"Alias Grace," by Margaret Atwood. Bantam Doubleday Dell Audio
Publishing, 360 minutes, $24.95.. I started listening to "Alias Grace" about
midway through the Lisa Michelle Lambert federal appeal hearing. And after
a while, the book gave me an eerie feeling - as if Margaret Atwood were
clairvoyant. In 1843, in a gentleman's home near Toronto, Canada, a
16-year-old Irish immigrant named Grace Marks is arrested for the murder
of her
1 of 3
6/10/2006 8:43 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2248
of 2301
1299
Article 134 of 348, 1997184391

COUNTY APPEALS TO RAINVILLE

Contrary to rumors, the district attorney is not planning to hand over the
keys to Lancaster County Prison to Christina Rainville so she can release
whomever she feels is innocent - even though it might save taxpayers a
fortune in legal fees spent on appeals. If she wants to release any other
locally convicted prisoners, she'll have to work for it.. Rainville is the
Philadelphia attorney who successfully defended Lisa Michelle Lambert,
who had been convicted and imprisoned for
Article 135 of 348, 1997184335
LAMBERT TAKES AIM AT COUNTY

PHILADELPHIA _ Attorneys for Lisa Michelle Lambert continued to defend
their client's newfound innocence in a document filed in federal appeals
court Thursday.. In doing so, the lawyers hope to block Lancaster County's
ongoing attempt to have their client retried, or sent back to prison, for the
1991 murder of Laurie Show. This most recent motion was filed on
Lambert's behalf by Christina Rainville and her husband / partner, Peter
Greenberg, of the
Article 136 of 348, 1997184320
LAMBERT TO U.S. COURT: REJECT APPEAL

Lisa Michelle Lambert's freedom should not be revoked, her attorneys
maintain, because she has always been "absolutely truthful" in her account
of 16-year-old Laurie Show's murder.. That, combined with the "shocking
and unprecedented" misconduct of Lancaster County prosecutors, her
attorneys say, justified a federal judge's decision to free Lambert from a
sentence of life imprisonment. In addition,
Article 137 of 348, 1997183430
YOU HAD TO BE THERE TO CRITICIZE LAMBERT

HEARING
Editor, New Era:. There are people who have made opinions that Judge
Dalzell heard all the facts of the Laurie Show murder, then complied with
the law to warrant Lambert's release. Unless you sat in the courtroom during
Lambert's appeal hearing and noticed the judge's total disregard for our
entire case and the demeanor he had towards the prosecution and all
witnesses for the commonwealth, no one has the knowledge to make an
opinion about the way the case
2 of 3
6/10/2006 8:43 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2249
of 2301
1299

Article 138 of 348, 1997181247
Published on June 30, 1997, Intelligencer Journal (Lancaster, PA)
LAMBERT BEAT INCREDIBLE ODDS TO WIN

FREEDOM
EDITOR'S NOTE: This is the second in a series of articles on the Lisa
Michelle Lambert case and its implications.. The series will use her
overturned murder conviction as a touchstone to show how state and
federal courts work. Today's article deals with the habeas corpus process
that led to Lambert's release and the uniqueness of her case. Other articles
will appear in the coming months.. Three strikes and you're out. On the
baseball field,
Article 139 of 348, 1997180361
Published on June 29, 1997, Sunday News (Lancaster, PA)

SUNDAY. June 22 - It was learned that Chris Strader, 18, Annapolis, Md.,
was stricken and died Saturday, June 21, while bicycling in a race at Mount
Nebo. Cause of death was ruled a hemorrhage in the brain. Ralph M.
Barley, a retired attorney and civic leader, died at 85 on Saturday, June 21.
MONDAY. June 23 - Pressing its hostile effort to take over Domco Inc.,
Armstrong World Industries Inc. asked regulators in
Article 140 of 348, 1997178260
Published on June 27, 1997, Lancaster New Era (PA)
SHOWS COLLECT 18,000 ANTI-JUDGE SIGNATURES

The count is at more than 18,000 and growing.. That's how many signatures
John and Hazel Show have collected on a petition seeking "corrective
action" against U.S. District Judge Stewart Dalzell, who freed Lisa Michelle
Lambert in April. Lambert had been convicted of the 1991 stabbing murder
of the Shows' 16-year-old daughter, Laurie, in East Lampeter Township.
Dalzell declared Lambert "actually innocent" and barred her


3 of 3
6/10/2006 8:43 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2250
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 141 of 348, 1997175259
LAMBERT LAWYER TO HANDLE TEEN'S MURDER

APPEAL
freedom in April is handling the criminal appeal of another Lancaster County
person who was convicted of murder.. Lawyer Christina Rainville said
Monday she will enter her appearance Thursday in Pennsylvania Superior
Court to appeal the third-degree murder conviction of 19-year-old Nathan
Cassel of Lititz. Cassel, a Warwick High School dropout, was sentenced last
month in county court by Judge Louis J. Farina to 15 to 40
Article 142 of 348, 1997174250
RAINVILLE WILL HANDLE A 3RD LOCAL APPEAL

Lisa Michelle Lambert's attorney has taken on her third appeal of a
Lancaster County murder case.. Christina Rainville, who won freedom for
Lambert during a federal hearing in April, has been hired by one of the
families of three teens convicted of killing a 12-year-old Mary Street boy in
February 1996. Rainville, a Philadelphia attorney, is representing Nathan
Cassel of Lititz in his appeal of his third-degree murder conviction before
state Superior Court. She also is
Article 143 of 348, 1997173435
DETECTIVE NOVEL AUTHOR SOLVES A REAL-LIFE

MYSTERY
Not being who he once thought he was is no joke to Lancaster lawyer Neil
Albert.. After sleuthing worthy of his fictional character Dave Garrett, star of
his six detective thrillers, the novelist now knows several new things about
himself. Those things are tangled, inextricably, in the plot of his newest
Garrett novel, "Tangled in June." Raised Jewish, Albert now knows he's
probably not.. After 47 years of celebrating his birthday on May 12, he now
1 of 3
6/10/2006 8:45 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2251
of 2301
1299
Article 144 of 348, 1997170309

ATTORNEYS: COUNTY OUT FOR REVENGE

Lisa Michelle Lambert's attorneys Wednesday accused Lancaster County of
seeking "revenge and retribution" when it asked a federal judge last week to
block their request for hundreds of thousands of dollars in legal fees..
Attorneys handling the county's appeal of a judge's decision to free Lambert
urged U.S. District Judge Stewart Dalzell to reject Lambert's lawyers'
request for $560,000. Because Lambert was
Article 145 of 348, 1997169569
SHOWS PLAN PUSH TO LIMIT POWER OF FEDERAL

JUDGES
Hazel and John Show will soon kick off a national campaign asking
Congress to pass legislation limiting the power of federal judges.. Mrs.
Show and her ex-husband are mounting the campaign in reaction to an
April decision by a federal judge in Philadelphia to free a woman who was
convicted in 1992 of killing their daughter, 16-year-old Laurie Show. "We
have to do everything possible to see that other criminals are not set free
because of one man's
Article 146 of 348, 1997167307
DEBATE RAGES ABOUT RAMIFICATIONS OF

LAMBERT DECISION
EDITOR'S NOTE: This is the first of a series of articles the Intelligencer
Journal will publish on the Lisa Michelle Lambert case and its implications..
The series will use the overturned murder verdict against Lambert as a
touchstone to show how the state and federal courts work.. More than just a
simple rehash of events and emotions, the series aims to use this historic
decision to educate Lancaster County citizens about the law, the courts and
the police and how they work
Article 147 of 348, 1997166386

SUNDAY. June 8 - Twenty-two students graduated from the Lancaster
County Academy at Park City Center. The school gives dropouts a second
chance to finish school. MONDAY June 9 - Armstrong World Industries
announced an unsolicited takeover bid for Domco Inc., a Quebec-based
flooring manufacturer that is in the process of being sold by its
French-based owner to a German floor manufacturer, Tarkett. Armstrong is
offering to
2 of 3
6/10/2006 8:45 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2252
of 2301
1299

Article 148 of 348, 1997166390
'WE WERE FRAMED, SET US FREE'

They have been convicted of heinous crimes.. Their victims, according to
the court verdicts, are a mother, shot five times in the chest and abdomen.
Two tourists, struck and killed on Route 30. An elderly brother and sister,
left to starve to death on the living room floor of their home. But since Lisa
Michelle Lambert was set free, at least three convicted killers, and likely
more, have claimed that they, too, were the victims of a corrupt Lancaster
County judicial system.. On one hand,
Article 149 of 348, 1997165166
4,800 HOURS, 58 WITNESSES, A BIG BILL

Lisa Michelle Lambert's attorneys worked hard - that's apparent from the
4,800 hours they devoted to her case.. They were thorough - that's apparent
from the 58 witnesses they interviewed for Lambert's federal appeal hearing
in April. They were well-prepared - that's apparent from the thousands of
documents they copied, photographs they analyzed, legal points they cited
and experts they obtained.. But are those services worth
Article 150 of 348, 1997164290
COUNTY TRIES TO STOP LAMBERT'S LAWYERS

FROM COLLECTING FEES
Lawyers representing Lancaster County Thursday asked the federal judge
who freed Lisa Michelle Lambert to deny her attorneys' request for
$560,000 in legal fees. The county maintains Lambert's attorneys were
improperly appointed by the court.. The county's attorneys urged U.S.
District Judge Stewart Dalzell to allow the county to formally object in "the
interest of justice" to the bill for legal fees and expenses submitted by


3 of 3
6/10/2006 8:45 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2253
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 151 of 348, 1997164232
RAINVILLE PICKED DESPITE NOT BEING ON COURT

LIST
Christina Rainville's name does not appear on a list of about 200 attorneys
approved to represent indigent clients in federal district court under the
Criminal Justice Act.. But District Judge Stewart Dalzell went outside the list
to appoint her and her Philadelphia law firm of Schnader Harrison Segal &
Lewis to represent Lisa Michelle Lambert in her recent federal hearing on
the 1991 murder of 16-year-old Laurie Show. He has that right, Lancaster
County's
Article 152 of 348, 1997160315
NEW TRIALS? UNCONSCIONABLE

To the Editor:. First Lisa Michelle Lambert and now Darrell E. McCracken!
(Attorney) Christina Rainville obviously has no conscience at all! These two
people were convicted of murder and Ms. Rainville feels the need to have
their convictions overturned, supposedly on technicalities. It seems to me
that Ms. Rainville could better serve her country by using her "name"
constructively. Maybe she could raise money for victims' rights or lead a
fight against
Article 153 of 348, 1997159342
LAPSES IN CASE AGAINST DRIVER? VEHICLES

INVOLVED IN MCCRACKEN CRASH THAT KILLED
FAMILY OF THREE WERE DESTROYED BEFORE
DEFENSE EXAMINED THEM.
It seems clear-cut.. Just after midnight on Sept. 3, 1995, Darrel McCracken
ran a red light in Lancaster, slammed into a car, and killed three people:
Franklin & Marshall College professor Geoffrey Pywell, his wife, Susan, and
their son, Nathaniel. In January, a jury found McCracken guilty of the worst
crime they could: third degree murder. They believed he ran a red light with
malice in his heart toward fellow human beings.. But the case may not be as
simple as it seems - at
1 of 3
6/10/2006 8:46 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2254
of 2301
1299

Article 154 of 348, 1997159346

SUNDAY. June 1 - Larry Dean Mowrer, 36, Lititz, was arrested for strangling
and killing his former girlfriend, April Smith, 23, also of Lititz, with an
electrical cord in a Lititz garage. MONDAY June 2 - Racing to beat the
deadline, attorneys for Lancaster County filed a 70-page appeal to the 3rd
U.S. Circuit Court of Appeals to overrule the decision of Judge Stewart
Dalzell in freeing Lisa Michelle Lambert. The appeal
Article 155 of 348, 1997158217
COUNTY MAY CONTEST LAMBERT'S LEGAL FEES

Lancaster County officials on Friday said they are considering mounting a
challenge to legal costs Lisa Michelle Lambert's attorneys are trying to
recoup from the county.. Lambert's Philadelphia lawyers asked U.S. District
Judge Stewart Dalzell Thursday to permit them to be reimbursed up to
$560,000 in taxpayers money for representing Lambert through April 21, the
day Dalzell freed her from life in jail. In the alternative, the lawyers
requested reimbursement of at
Article 156 of 348, 1997158175
DOES 'PRO BONO' REALLY MEAN 'CHARGE

WHATEVER YOU LIKE'?
Our Latin teacher told us that "pro bono publico" meant "for the public
good.". Our dictionary says "pro bono" means "done or donated without
charge." So why are Lisa Michelle Lambert's lawyers asking the federal
court for legal fees ranging from $300,000 to $650,000 for a case they took
on a pro bon. o basis?. Not too many weeks ago, Lancastrians would have
been called cynics
Article 157 of 348, 1997157368
LAWYERS PUT LAMBERT BILL AT $650,000

Lisa Michelle Lambert's lawyers are asking for $650,000 in taxpayers
money to help offset their legal bill of $890,000 for representing Lisa
Michelle Lambert through April 21, the day she was freed.. Philadelphia
lawyers Christina Rainville and Peter S. Greenberg were appointed by
federal Judge Stewart Dalzell to represent Lambert. Their law firm took her
as a "pro bono" client, but the firm is entitled by law to recoup some of its
2 of 3
6/10/2006 8:46 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2255
of 2301
1299
losses. The request was

Article 158 of 348, 1997157363
LAMBERT APPEAL GETS GREEN LIGHT FROM U.S.

COURT
Lancaster County learned Thursday that its appeal of a judge's decision to
free Lisa Michelle Lambert won't be dismissed before it is fully argued.. The
3rd U.S. Circuit of Appeals referred a motion by Lambert's attorneys to
dismiss the county's appeal to the "merits panel" of circuit judges, who won't
rule on it until after the appeal is litigated. Also, the court denied requests by
Lambert's
Article 159 of 348, 1997156396
LAMBERT'S LAWYERS RENEW ATTACK ON

COUNTY'S APPEAL
A phrase in the county's 70-page appeal of a federal judge's decision to free
Lisa Michelle Lambert has prompted her attorneys to again ask a U.S.
appeals court to dismiss the county's action.. Lambert's Philadelphia
attorneys told the 3rd U.S. Circuit of Appeals Tuesday that an admission in
the county's appeal "confirms beyond any possible argument" that it would
violate her constitutional protection against
Article 160 of 348, 1997156405
APPEALING APPEAL
At some point, we suspect, taxpayers will begin to squirm over the cost of
appealing U.S. District Judge Stewart Dalzell's decision to free Lisa Michelle
Lambert for the 1991 murder of Laurie Show.. For the moment, however,
the public appears to be largely behind the county's efforts to either jail or
retry Lambert - as well they should. The appeal, filed Monday in
Philadelphia, addresses major issues that were either ignored or overlooked
by Dalzell. It raises


3 of 3
6/10/2006 8:46 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2256
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 161 of 348, 1997156331
LAMBERT'S LAWYERS' BILL MAY HIT $650,000

Lisa Michelle Lambert's attorneys are asking the federal court for legal fees
and costs ranging from $300,000 to $650,000 for their work leading to the
freeing of Lambert in April.. The court-appointed Philadelphia firm of
Schnader Harrison Segal & Lewis planned to file a motion for the funds
today. The firm took Lambert's federal appeal on a "pro bono" basis,
volunteering their time to the case, but the firm is entitled by law to
Article 162 of 348, 1997156342
SAVE DRUNK DRIVING CONVICTION

Editor, New Era:. First Lisa Michelle Lambert and now Darrell E.
McCracken! Defense attorney Christina Rainville obviously has no
conscience at all! These two people were convicted of murder and Ms.
Rainville feels the need to have their convictions overturned, supposedly on
technicalities. It seems to me that Ms. Rainville could better serve her
country by using her "name" constructively. Maybe she could raise money
for "victims'
Article 163 of 348, 1997155562
LAMBERT CASE COSTS MAY HIT $500,000

If the Lisa Michelle Lambert appeal goes all the way to the U.S. Supreme
Court, and officials believe it will, Lancaster County taxpayers could face up
to a half million dollars in legal fees, the chairman of the county
commissioners said Tuesday.. County Commissioner Terry L. Kauffman,
who chairs the county's governing triumvirate, said the county has already
received legal bills totaling over $100,000 for work done in preparing an
appeal to the 3rd Circuit Court of Appeals.
Article 164 of 348, 1997155533
1 of 3
6/10/2006 8:47 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2257
of 2301
1299
COUNTY CLAIMS JUDGE ERRED IN FREEING

LAMBERT
Article 165 of 348, 1997155561
LOCAL ATTORNEYS EVALUATE APPEAL

Lancaster County's appeal of a court decision to free Lisa Michelle Lambert
zeroes in on two themes: A federal judge went too far by overturning her
murder conviction and blocking a retrial and Lambert's own testimony
makes her at least an accomplice to a killing.. Just before midnight Monday,
the county's attorneys, Alvin B. Lewis Jr. in Lancaster and Richard A.
Sprague in Philadelphia, filed the appeal with the 3rd U.S. Court of Appeals
in Philadelphia.
Article 166 of 348, 1997155419
ADDITIONAL TEXT FROM LAMBERT-CASE APPEAL

(Editor's note: This block of type was omitted in some editions of Tuesday's
New Era, through computer error, from the text of Lancaster County's
appeal of the Lisa Michelle Lambert decision. This type is the final section
of that appeal. The New Era apologizes for the omission.). A. The District
Court Erred In Addressing Lambert's Claims. In Wainright v. Sykes, 433
U.S. 72 (1972), the Court established the cause-and-prejudice test for
Article 167 of 348, 1997154300
COUNTY'S LAMBERT APPEAL TARGETS JUDGE

DALZELL
PHILADELPHIA - Lawyers representing Lancaster County late Monday
night appealed a federal judge's decision to free Lisa Michelle Lambert,
accusing the judge of making numerous errors during an April hearing in
which they claim he put county law enforcement officials on trial.. Barely
beating the court's midnight deadline, the county's lawyers urged the 3rd
U.S. Circuit Court of Appeals in Philadelphia to overrule Judge Stewart
Dalzell's
2 of 3
6/10/2006 8:47 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2258
of 2301
1299
Article 168 of 348, 1997154252

HOLD ALL JUDGES ACCOUNTABLE

Editor, New Era:. I am writing in response to the outcome of the Lambert
case. In 1991 Lisa Michelle Lambert was convicted of the murder of Laurie
Show. The recent hearing of Lambert's appeal was presided over by the
"honorable" Judge Stewart Dalzell. The investigation in 1991 was shown to
be flawed by detective Ronald Savage who led a witness and tampered
with evidence in order to make the prosecution's case
Article 169 of 348, 1997154253
DECISION IN LAMBERT CASE MUST BE CLEAR AS

MCVEIGH'S
There was cause to worry about the jury's verdict in the Timothy McVeigh
trial. That so many Americans were concerned that McVeigh might
somehow avoid a guilty verdict speaks to the extent to which our justice
system has been threatened by misguided judgments, especially in the first
Simpson trial.. Clever lawyers and lenient judges have allowed some
defendants to get away with murder. Timothy McVeigh will never leave
prison following the jury's guilty verdicts on 11
Article 170 of 348, 1997154242
COUNTY STATES THE BASIS FOR AN APPEAL



3 of 3
6/10/2006 8:47 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2259
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 171 of 348, 1997154249
COUNTY APPEAL CLAIMS JUDGE WAS HOSTILE AND

PREJUDICED
Citing a federal judge's offensive hostility and prejudice against Lancaster
County, attorneys have appealed to a higher court, arguing that the judge
freed a "properly convicted" murderer.. In a 70-page appeal filed minutes
before a midnight deadline Monday in Philadelphia, the county's lawyers
urged the 3rd U.S. Circuit Court of Appeals to overrule Judge Stewart
Dalzell's decision to free Lisa Michelle Lambert. The appeal refutes
Article 172 of 348, 1997153255
LAMBERT'S STORY IS EERIE MIRROR IMAGE OF

BUCK'S ACCOUNT
The stories were almost identical.. On the morning Laurie Show was
murdered - one young woman wildly attacked the 16-year-old girl, cutting
her hair, stabbing her repeatedly and slitting her throat. The assailant's
stunned accomplice stood by in shock, even as the victim reached out to
her, begging for help.. Lisa Michelle Lambert, now 24, said it was Tabitha
Buck who brutally attacked the Conestoga Valley High School sophomore..
Buck, now 23, said she didn't
Article 173 of 348, 1997153264
THE LAURIE SHOW MURDER: "...THAT'S NOT NOW IT

HAPPENED."
Editor's note: We've heard Lawrence Yunkin's side of the story - that he was
eating breakfast at McDonald's while Lisa Michelle Lambert and Tabitha
Buck killed Laurie Show. We've heard Lisa Lambert's side of the story - that
she tried to stop Tabitha Buck from killing Show. But the public has never
before heard a full account from the third person involved in the brutal
attack on the 16-year-old girl. In April, a select
1 of 3
6/10/2006 8:47 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2260
of 2301
1299
Article 174 of 348, 1997153265

LAMBERT LIED 'OVER AND OVER,' APPEAL SAYS

A federal judge's order freeing Lisa Michelle Lambert "is akin to a
get-out-of-jail-free card in the game of Monopoly," according to Lancaster
County's appeal of the decision that will be filed today.. "But this is not a
game ... Laurie Show was the victim of a cruel torture murder and a person
convicted of her murder now walks free," the appeal states. The county is
appealing a federal judge's decision to
Article 175 of 348, 1997152412

SUNDAY. May 25 - People who had to cancel Memorial Day celebrations
didn't care much for it, but farmers were ecstatic about an all-day soaking
rain. The annual Smith Barney/Rotary International Cycling Festival did go
on in the downtown, with plenty of cyclists spilling on wet roads. MONDAY
May 26 - The sun did shine on Memorial Day as local communities honored
their war dead and others took to recreation
Article 176 of 348, 1997152518
THE PRETENDERS
Stand by your man, Tammy Wynette said.. She'd obviously never been to
East Lampeter Township. Even Ms. Wynette would have second thoughts
about sticking up for the East Lampeter police.. Township officials are
desperately following the song's advice, insisting that the string of
sensational allegations about their law enforcers - sexual misbehavior, rape,
corrupting a minor, perjury, tampering with evidence - is just, well, an image
problem.. What East Lampeter
Article 177 of 348, 1997151062
Published on May 31, 1997, Intelligencer Journal (Lancaster, PA)
LAMBERT ATTORNEY TO REPRESENT MCCRACKEN

IN MURDER APPEAL
freedom is representing another convicted murderer from Lancaster County:
Darrell E. McCracken.. Christina Rainville said Friday she and an associate
have been retained by McCracken's family to represent him on an appeal of
a third-degree murder conviction. McCracken was convicted in January of
killing Geoffrey Pywell, 42, his wife, Susan Davies-Pywell, 43, and their
11-year-old son, Nathaniel, when his pickup
2 of 3
6/10/2006 8:47 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2261
of 2301
1299
Article 178 of 348, 1997150112

COUNTY FIGHTS FOR LAMBERT APPEAL

Attorneys for Lancaster County told a federal appeals court Thursday that
they have every right to appeal the release of Lisa Michelle Lambert. They
asked the court to deny a request by Lambert's attorneys to dismiss the
county's pending appeal, which is expected to be filed Monday.. Lambert's
attorneys launched a legal preemptive strike last week when they asked the
U.S. 3rd Circuit Court of Appeals to block the county's appeal of a federal
Article 179 of 348, 1997150100
COSTLY COUNSEL
The costs are beginning to mount.. Now the county has hired a second law
firm to handle fallout from the Lisa Michelle Lambert case. William Lamb, a
former Chester County district attorney and member of the West Chester
law firm of Lamb, Windle and McErlane, will represent Lancaster County
First Assistant District Attorney John A. Kenneff in a disciplinary
investigation being conducted by the state Supreme Court.. Documents
relating to Kenneff's prosecution of Lambert for the
Article 180 of 348, 1997149095
SUPREME COURT ARM OPENS KENNEFF PROBE

John A. Kenneff's handling of the criminal prosecution of Lisa Michelle
Lambert is now officially under investigation by an arm of the Pennsylvania
Supreme Court.. Kenneff, Lancaster County's first assistant district attorney,
said Wednesday that he has received an informal inquiry from the state
Supreme Court's Office of Disciplinary Council. The council requested
documents from Kenneff concerning the Lambert case, he said. "I intend to
fully


3 of 3
6/10/2006 8:47 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2262
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 181 of 348, 1997149047
Published on May 29, 1997, Lancaster New Era (PA)
SHOWS TO PRINT PETITION SEEKING OUSTER OF

JUDGE
The parents of murdered 16-year-old Laurie Show will seek public support
in their effort to oust a federal judge by publishing a petition in Lancaster
newspapers Friday.. Hazel and John Show want "corrective action" taken
against U.S. Judge Stewart Dalzell, who released Lisa Michelle Lambert
last month. Lambert, now 24, was convicted in Lancaster County Court of
first-degree murder in the case and sentenced to life in prison. Dalzell threw
out that conviction, saying
Article 182 of 348, 1997149051
JUDGE IS NOT A 'KING,' LAWYERS ARGUE IN

LAMBERT CASE APPEAL
Lancaster County has the right to ask a higher court to review a federal
judge's decision, its attorneys charged today, because the judge otherwise
"becomes a king.". Lancaster County's attorneys, in appealing last month's
decision by U.S. Judge Stewart Dalzell to release Lisa Michelle Lambert,
filed a motion before the U.S. 3rd Circuit Court of Appeals today citing legal
arguments as to why they deserve to be heard.
Article 183 of 348, 1997148041
COUNTY HIRES LAWYER TO AID KENNEFF ON

ETHICS CHARGES
First Assistant District Attorney John A. Kenneff now has a separate
attorney to represent him in the investigations spurred by the Lisa Michelle
Lambert case.. The county commissioners on Tuesday approved the hiring
of a West Chester law firm at $190 an hour to represent Kenneff, the lead
prosecutor in the case, before the state Disciplinary Board of the state
Supreme Court. Commissioners Chairman Terry Kauffman said today that
the county expects the firm of Lamb, Windle and McErlane will
1 of 3
6/10/2006 8:48 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2263
of 2301
1299
Article 184 of 348, 1997146100

FAIR TRIAL A KEYSTONE OF OUR SYSTEM

To the Editor:. Let me get this straight: a Lancaster police officer in the
Rineer-Pasker case omitted from his report statements from one of the
defendants and also a witness, because he "didn't want to confuse the
issue." And District Attorney Joseph Madenspacher thinks this omission is a
"hyper-technicality"? I'm no cop, but even I know that police officers are
supposed to collect evidence, not begin doing the jobs of
Article 185 of 348, 1997145051
Published on May 25, 1997, Sunday News (Lancaster, PA)

SUNDAY. May 18 - Six people - three men and three women - were
wounded after a shootout on South Duke Street following an argument and
fight at a dance. One was in critical condition. At the end of the week, police
were seeking David Lee Pilgrim, 23, who had been wounded, as the man
who fueled the fight. MONDAY May 19 - Michael R. Baksa, 42, was hired as
principal of Conestoga Valley High School, replacing Joseph E.
Article 186 of 348, 1997144083
COUNTY'S TAPE APPEAL IS REJECTED

A federal appeals court has ended the great debate over audio tapes of the
court hearing that freed Lisa Michelle Lambert from a life sentence for
murder.. The 3rd U.S. Circuit Court of Appeals Friday rejected a motion by
lawyers for Lancaster County to preserve tape recordings of the Lambert
hearing. The county claims the tapes would show a federal judge was
biased when he ruled Lambert should be freed. But in a one-page order, the
circuit court said the county "has made no
Article 187 of 348, 1997143113
LAMBERT SEEKING TO KO APPEAL BY COUNTY

Lisa Michelle Lambert's attorneys Thursday asked a federal appeals court to
reject a appeal by Lancaster County that, if approved, would reinstate her
murder conviction and send her back to jail.. The action took the form of a
sort of legal preemptive strike since the Lancaster County District Attorney's
office hasn't yet filed its formal appeal papers in the matter. Lawyers for the
county have told the U.S. 3rd Circut Court of Appeals court that they plan
2 of 3
6/10/2006 8:48 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2264
of 2301
1299
Article 188 of 348, 1997143065

PETITION DRIVE, MAILING NEXT FOR THE SHOWS

Laurie Show's parents are wielding a pen to battle the freeing of the woman
they say killed their 16-year-old daughter.. Hazel and John Show are
handing out petitions and preparing a national mailing to elected officials,
including the president. Both the petitions and the mailing criticize the
recent ruling by U.S. District Judge Stewart Dalzell, who last month released
Lisa Michelle Lambert, 24, from her life sentence for the 1991 killing in East
Lampeter Township.. Both
Article 189 of 348, 1997142106
ATTORNEYS WANT COURT TO RESOLVE TAPE FLAP

Lawyers representing the Lancaster County District Attorney's office asked
a federal appeals court Wednesday to help them determine if audio tapes of
the hearing that led to Lisa Michelle Lambert's freedom still exist.. The
attorneys - Alvin B. Lewis Jr. of Lancaster and Richard A. Sprague of
Philadelphia - filed an emergency request with the 3rd U.S. Circuit Court of
Appeals in Philadelphia. They asked the court to order that any existing
tapes of
Article 190 of 348, 1997141194
COUNTY'S ATTORNEYS OUTLINE APPEAL OF

LAMBERT RULING
Attorneys representing the Lancaster County District Attorney's Office
outlined their appeal of a federal judge's decision to free Lisa Michelle
Lambert in court papers filed Tuesday.. The county's lawyers, Alvin B. Lewis
Jr. of Lancaster and Richard A. Sprague of Philadelphia, said the appeal
will emphasize evidence already on record that they say shows Lambert is
guilty of first-degree murder in the stabbing death of Laurie Show. The court
papers were


3 of 3
6/10/2006 8:48 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2265
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 191 of 348, 1997141026
TECHNICAL POINTS FORM BASIS OF LAMBERT

APPEAL
Most of the issues raised by Lancaster attorneys in their appeal of Lisa
Michelle Lambert's release are legal technicalities.. But one key issue
stands out among the rest: Local attorneys maintain that Lambert is guilty of
first-degree murder in the stabbing death of 16-year-old Laurie Show in
December 1991.. The county's lawyers, Alvin B. Lewis Jr. of Lancaster and
Richard A. Sprague of Philadelphia, filed the statement of issues on
Tuesday with the 3rd U.S.
Article 192 of 348, 1997140098
LAMBERT JUDGE WANTS DECISION ON TAPES

REQUEST
The legal debate over audio tapes of Lisa Michelle Lambert's federal
appeals hearing in Philadelphia continued Monday.. U.S. District Judge
Stewart Dalzell, who overturned Lambert's first-degree murder conviction for
the 1991 stabbing death of Laurie Show, ordered lawyers representing the
Lancaster County District Attorney's Office to decide by May 27 whether
they will withdraw a motion seeking preservation of the tapes. Also, Dalzell
gave the
Article 193 of 348, 1997140034
COUNTY LAWYERS LIST 5 ISSUES FOR APPEAL OF

LAMBERT RULING
Lancaster County's lawyers have outlined the key issues on which they
intend to appeal the release of Lisa Michelle Lambert, who had been
convicted of murder.. The lawyers plan to present evidence that they say
proves Lambert is guilty of first-degree murder in the stabbing death of
16-year-old Laurie Show, not "actually innocent" of the crime as a federal
judge decreed last month, attorney Alvin B. Lewis Jr. said this morning.
Lewis listed five
1 of 3
6/10/2006 8:48 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2266
of 2301
1299
Article 194 of 348, 1997139035

VOTE IN THE PRIMARY

Because of Lancaster County's lopsided Republican registration - there are
2 1/2 GOP registrants for every Democrat - primaries are critical for
Republicans in so-called "off-year" or "local" elections.. Most of the
Republicans who win Tuesday's primary will go on to win November's
election against outnumbered Democrats. In some cases, the Democratic
Party will not be running anyone in November, so this
Article 195 of 348, 1997139050
CLOSE RACES EXPECTED FOR MAYOR, JUDGE

To supporters of Leslie Gorbey, the race for county judge is about electing
the best-qualified of two politically similar candidates.. Backers of Melinda
Fisher Nowak say the race is a philosophical battle to elect the most
conservative of two equally qualified attorneys. To an academic analyst, it is
this year's version of a much-broader political struggle between Republican
conservatives and moderates.. "This election is this year's manifestation of
Article 196 of 348, 1997138068
EAST LAMPETER BLUES

Last week, East Lampeter Township police officer Robert Reed was
arrested and charged with sexually assaulting a 13-year-old girl under his
care.. But according to public records, this may not have been the first time
Reed has had sex with young girls or women through his job. And senior
members of the East Lampeter Police Department knew that Reed had a
history of questionable sexual conduct. According to testimony from Ronald
Savage, a former East Lampeter police sergeant, Reed was accused
Article 197 of 348, 1997138063

SUNDAY. May 11 - Troy David Ludwig, 29, Denver, died in Reading after he
was shot in the face the day before in what police said was an attempted
drug deal. Keith Allen Tyler, 30, of Reading was charged with homicide.
More than $100,000 was raised during Make-A-Wish Foundation's annual
truck convoy day. MONDAY. May 12 - Manheim Township commissioners
approved the building of an $18 million, 2,600-seat
2 of 3
6/10/2006 8:48 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2267
of 2301
1299
Article 198 of 348, 1997137073

LAMBERT ATTORNEYS ON ATTACK

Lisa Michelle Lambert's attorneys said Friday that even if the judge who
freed their client from her murder sentence was rude to Lancaster County
prosecutors, that's not enough to reverse his decision.. Lambert's lawyers
Friday filed a response to a request by the county district attorney to turn
over audio tapes of a federal hearing in April that resulted in Lambert being
freed of a first-degree murder sentence. In their response, one of
Article 199 of 348, 1997136093
ANOTHER CASE THROWN OUT IN COUNTY COURT

The case against a city man charged after a brawl with two sheriff's
deputies was thrown out of court Thursday.. Lancaster County Judge
Lawrence F. Stengel dismissed two simple assault charges against Gary
William Dimitris, 37, of the 700 block of Columbia Avenue. Stengel cited
Pennsylvania's Rule 1100, which guarantees a speedy trial for anyone
accused of a crime. City police said Dimitris entered county offices at 40 E.
King St. on May 8, 1995, and fought with two
Article 200 of 348, 1997136094
POLICE OFFICER CHARGED WITH SEX ASSAULT

Criminal agents with the state attorney general's office Thursday arrested an
East Lampeter Township policeman for sexually assaulting a juvenile over a
four-year period.. Officer Robert Stanley Reed, 37, who is also under
investigation by the U.S. Attorney in Philadelphia for allegedly perjuring
himself last month at the Lisa Michelle Lambert federal court hearing, was
charged with allegedly sexually assaulting a young girl under his care at his
314 Greenland Drive home in East


3 of 3
6/10/2006 8:48 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2268
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 201 of 348, 1997136042
EAST LAMPETER COP CHARGED WITH YOUNG GIRL'S

SEXUAL ASSAULT
An East Lampeter Township Police officer was charged Thursday with
sexually assaulting a young girl in his care from 1992 to 1996.. The state
Attorney General's office Thursday brought the charges against Robert
Stanley Reed, 37, of 314 Greenland Drive. His victim was between the ages
of 8 and 12 at the time of the assault, which allegedly included oral sex,
sexual intercourse and fondling.. Reed specifically was charged with one
count each of statutory rape, involuntary
Article 202 of 348, 1997134188
LAMBERT CASE CITED IN MISTRIAL HERE

The same mistake cited by a federal judge in his decision to free Lisa
Michelle Lambert last month has helped clear two Lancaster men of
criminal charges in Lancaster County Court.. County Judge Paul K. Allison
Tuesday declared a mistrial in the case of Larry Rineer and Charles Pasker,
saying prosecutors failed to turn over to their defense lawyers evidence in
the men's favor. Allison threw out aggravated assault, burglary and criminal
conspiracy charges against the men, who were
Article 203 of 348, 1997134002
POLICE CHIEF FEARS 'TREND' AFTER NEW MISTRIAL

DECLARED
Will the Lambert case haunt local police officers for years to come?. That
was the concern among police today after a county judge threw out a
burglary case and declared a mistrial Tuesday, saying prosecutors and city
police failed to turn over evidence to defense attorneys that favored the
defendants. In making the decision, Lancaster County Judge Paul K. Allison
referred to a federal judge's recent decision to free Lisa Michelle Lambert,
who had been convicted in the 1991
1 of 3
6/10/2006 8:50 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2269
of 2301
1299
Article 204 of 348, 1997131071


SUNDAY. May 4 - According to a state report, Lancaster County public
schools had 1,302 incidents of violence in 1995-96, including three involving
firearms. MONDAY May 5 - Nathan Cassel, Eric Griffith and Luis Alicea,
three teens convicted in the shooting death of a 12-year-old boy, were each
sentenced to 15-40 years in prison. Alicea fired the shot.. W. Michael
Strube, 47, of West Hempfield Township, was indicted on
Article 205 of 348, 1997130088
LAMBERT WILL REMAIN FREE DURING APPEAL

A federal appeals court Friday denied a motion by the Lancaster County
district attorney to either send Lisa Michelle Lambert back to jail or place
her on bail while a judge's decision to free her is appealed.. The three
judges that make up the Third Circuit Court of Appeals said returning
Lambert to jail was not proper since "the commonwealth has not
demonstrated that it is likely to prevail on the merits of its appeal." Lambert,
24, had been serving a
Article 206 of 348, 1997127067
LAMBERT'S LAWYER QUESTIONS COUNTY'S HIRING

OF LAW FIRM
Lawyers for Lisa Michelle Lambert may ask an appellate court to disqualify
a Lancaster law firm hired by Lancaster County to help with the appeal of a
federal judge's decision to release Lambert from life in prison.. Christina
Rainville, one of Lambert's attorneys, said Tuesday she believes it's
improper under Pennsylvania law for the firm of Sprague and Lewis to help
the county district attorney's office with its appeal. The county should only
Article 207 of 348, 1997127028
LAMBERT LAWYERS OBJECT TO COUNTY HIRING

OUTSIDE ATTORNEYS
Lisa Michelle Lambert's attorneys are objecting to the county hiring outside
attorneys to help with the appeal of a federal judge's decision to release
Lambert from prison.. Christina Rainville said that she may ask an appelate
court to disqualify the attorneys. The county should only be able to ask the
state attorney general's office for help, she said. The attorney general's
office has also been enlisted by the county to help with the Lambert
2 of 3
6/10/2006 8:50 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2270
of 2301
1299

Article 208 of 348, 1997126040
LAW FIRM BEGINS WORK ON APPEAL OF LAMBERT

CASE
Lisa Michelle Lambert "was and is guilty of murder," one of the new
attorneys handling the county's appeal of her release said today.. "I expect
to argue that forcefully," said Alvin B. Lewis Jr., who was hired Monday by
Lancaster County to handle the appeal of the Lambert case in federal court.
"The woman is guilty of murder and she's been convicted, and her
conviction has been sustained by all of the state
Article 209 of 348, 1997124087
WE DESERVE ACCOUNTABILITY
Now that the shock of the Lisa Michelle Lambert ruling has begun to wear
off, it's time to take a hard look at the charges leveled against Lancaster
County law enforcement by federal Judge Stewart Dalzell.. While some of
those hard looks will likely come from the U.S. attorney's office and the
state Judicial Conduct Board - Judge Dalzell has referred allegations of
prosecutorial wrongdoing to those agencies - that doesn't absolve county
and East Lampeter
Article 210 of 348, 1997124075
FOR LAMBERT INVESTIGATORS, THE HEAT IS ON

Two weeks ago, a federal judge found what he believed was evidence that
eight Lancaster County law enforcement officers are criminals.. Last week,
the U.S. Attorney in Philadelphia, in a tersely worded statement, said he will
begin a "preliminary investigation." Behind the legal words issued from the
22-story black glass federal courthouse in Philadelphia are these realities:.
This is the first time since 1978 the U.S. Attorney in Philadelphia has seen
fit to


3 of 3
6/10/2006 8:50 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2271
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 211 of 348, 1997124086
WHAT'S NEXT FOR DALZELL - MANSON?

Well, now that U.S. District Judge Stewart Dalzell has decided to release
Lisa Michelle Lambert from jail, why stop at this case? Let's have him look
at the Charlie Manson trial for the murders of Sharon Tate and the other
victims. I recall it was proven that Old Charlie Boy was not even at the
murder scene but merely organized and recruited the killers.. Whatever
happened that day at Laurie Show's home resulted in her violent death. I
guess "accessory to
Article 212 of 348, 1997124062
SUNDAY. April 27 - Harry J. Shaub Jr., former president and general
manager of WGAL-TV, died unexpectedly. He held numerous community
leadership posts. MONDAY April 28 - Lancaster and city police officers
agreed on a new contract that would provide raises of 3, 2 1/2 and 3
percent for police over the next three years. Mayor Janice Stork said she
was pleased with the contract, which will allow the city to continue on its
Article 213 of 348, 1997122096
U.S. WILL PROBE LAMBERT CASE

The U.S. Attorney's Office in Philadelphia has launched a criminal
investigation into the actions of the Lancaster County law enforcement
officials who prosecuted Lisa Michelle Lambert.. Lancaster County officials
said they welcome the investigation and promised to cooperate fully. The
probe comes at the request of U.S. District Judge Stewart Dalzell, who last
week freed Lambert, 24, and overturned her conviction for the murder of
16-year-old Laurie Show. Dalzell also barred
Article 214 of 348, 1997122088
THE PROBE OPENS
1 of 3
6/10/2006 8:50 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2272
of 2301
1299
The decision by the U.S. Attorney in Philadelphia to open a formal

investigation into the conduct of Lancaster County police and prosecutors
involved in the murder trial of Lisa Michelle Lambert is both expected and
welcome.. It's expected because U.S. District Judge Stewart Dalzell, in
freeing Lambert last month, leveled grave charges of perjury and
obstruction of justice against authorities here. It would have been difficult for
the U.S. Attorney to ignore Dalzell's
Article 215 of 348, 1997122033
MORE ATTORNEYS SOUGHT TO AID PROSECUTORS

HERE
Local prosecutors are preparing to bring in outside attorneys to help them
with their appeal of a judge's decision to free convicted murderer Lisa
Michelle Lambert.. In recent court documents, prosecutors indicated they
needed more time in meeting an upcoming filing deadline because they are
bringing in new attorneys to help with the appeal to the 3rd U.S. Circuit
Court of Appeals. District Attorney Joseph Madenspacher, who has been
handling the appeal, was out of town and could
Article 216 of 348, 1997122037
POLICE AND PROSECUTORS UNDERMINED LAMBERT

CASE
Article 217 of 348, 1997121130
JUDGES GATHER, BUT TALK AVOIDS DALZELL'S

RULING
The Lancaster Bar Association couldn't have picked a better time for a
public forum on the role of judges - the week after a federal judge jolted the
community by freeing convicted murderer Lisa Michelle Lambert.. The bar
association and Pennsylvania Conference of State Trial Judges assembled
six state and federal court judges Wednesday to explain the independence
and accountability of judges. Although the audience, mostly lawyers, came
hoping to hear the judges'
2 of 3
6/10/2006 8:50 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2273
of 2301
1299
Article 218 of 348, 1997121124

WHERE IS JUSTICE?
To the Editor:. What is happening to justice in the U.S.A.? I was amazed
that Lisa Michelle Lambert was declared innocent of the murder by a
federal judge and released from prison.. Three people - Lambert, (Tabitha)
Buck and (Lawrence) Yunkin, first lured the mother away from the building,
then illegally entered the home of Laurie Show. Then they go into her home
carrying a deadly weapon. When they leave the room, Show is dead. They
they accuse each other of who did the murder.. It is
Article 219 of 348, 1997121067
PROBERS BROADEN PRELIMINARY LOOK AT

LAMBERT CASE
The U.S. Attorney's office announced today that it is broadening its
"preliminary investigation" into the actions of Lancaster County prosecutors
in the Lisa Michelle Lambert case.. "We are conducting a preliminary
investigation," U.S. Attorney Michael Stiles said this morning, based on U.S.
Judge Stewart Dalzell's recommendation when he released Lambert last
week. Previously, the U.S. Attorney's office
Article 220 of 348, 1997121068
PRICE TAG IN LAMBERT CASE: $34,500 AND STILL

GROWING
It cost the federal government at least $34,500 to hold the 15-day hearing
that led to the freedom of Lisa Michelle Lambert on April 21.. That
preliminary figure was announced today by Michael E. Kunz, clerk of court
for the U.S. District Court in Philadelphia, where the hearing was held
beginning March 31 before Judge Stewart Dalzell. But the costs could go
much higher after fees for Lambert's attorneys and expert witnesses are
added in. Those bills are still pending.. The


3 of 3
6/10/2006 8:50 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2274
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 221 of 348, 1991203086
Published on April 30, 1997, Lancaster New Era (PA)
DESPITE CHARGES, POLICE, PROSECUTORS STILL ON

JOB
Local police and prosecutors have resumed their normal routines, the week
after a convicted murderer was freed by a federal judge.. "We are not doing
anything differently," said East Lampeter Township Police Chief Dale
Jerchau. U.S. District Judge Stewart Dalzell released Lisa Michelle
Lambert, 24, from prison for the 1991 killing of 16-year-old Laurie Show in
East Lampeter Township. Dalzell said prosecutors lied about, concealed or
tampered with evidence in
Article 222 of 348, 1991181818
Published on April 28, 1997, Intelligencer Journal (Lancaster, PA)
OUR SICK SYSTEM

To the Editor:. How are we to fight crime when criminals are set free? When
are victims going to be given their constitutional rights?. Judge's rules are
overturned. In O. J. Simpson's trial the L.A. Police Department was put on
trial. In Lancaster, Pa., the police and district justice will suffer the same fate
as the L.A.P.D.. O. J. walks, Lisa Michelle Lambert walks and three people
are dead. What is happening to our judicial system? Ann Rimko New
Holland
Article 223 of 348, 1991181763
THE FACTS AND THE LAW LED THE JUDGE TO HIS

DECISION
Editor, New Era:. I commend your newspaper for printing the full text of
Judge Stewart Dalzell's Opinion in the case of Lisa Michelle Lambert. For all
who recognize how fragile is the grasp of the right to freedom anywhere in
the world, and even here, his opinion is not merely an explanation of why
one woman must be freed, but it is a call, particularly to the people of
Lancaster County, to examine the assumptions upon which their rights truly
rest. And more than that, it is a
1 of 3
6/10/2006 8:51 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2275
of 2301
1299
Article 224 of 348, 1991173058

Published on April 27, 1997, Sunday News (Lancaster, PA)
CAN LISA MICHELLE CARRY THE WEIGHT OF

BLOOD?
Editor's note: "In My Opinion" is a column of guest commentaries by Sunday
News readers on topical subjects. Send submissions to Helen Colwell
Adams, Sunday News, P.O. Box 1328, Lancaster, Pa. 17608-1328.
Commentaries will be published at the discretion of the editors.. The justice
system has failed. It has failed horribly, drowning in a sea of red-ink
technicalities and dying with the final slash of a federal judge's pen. Justice
has
Article 225 of 348, 1991173042
COURTING EXPERTS TO MAKE A CASE

The chance to help free a wrongly convicted woman came unexpectedly to
Dr. Charles Larson.. Larson had never given expert testimony in court. He'd
never heard of Lisa Michelle Lambert until he was contacted by her
attorney, Christina Rainville. But his expert testimony lent weight to Judge
Stewart Dalzell's decision last week to release Lambert from prison, where
she was serving a life sentence for the murder of Laurie Show.. Larson got
involved in the case by
Article 226 of 348, 1991173043
CORRECTIONS
The Sunday News, in a synopsis last Sunday of the Lisa Michelle Lambert
appeal, incorrectly reported that East Lampeter Township police officer
Robert Reed was one of the men identified as a rapist by Lambert.. If you
have a correction or clarification, call the responsible section editor, or
phone the news desk, 291-8788.
Article 227 of 348, 1991173046

MONDAY. April 21 - Lisa Michelle Lambert, convicted in 1992 of the murder
of 16-year-old Laurie Show and sentenced to life in prison, was freed by a
federal judge who said the trial "was corrupted from start to finish" and that
Lancaster County officials had engaged in "such gross prosecutorial
misconduct" that she cannot be retried. The judge also recommended that
members
2 of 3
6/10/2006 8:51 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2276
of 2301
1299
Article 228 of 348, 1991173032

ATTORNEY TO TALK ON LAMBERT CASE

On Tuesday, April 29, Scott Oberholtzer, a local attorney, will speak to the
Lancaster Kiwanis Club about "The Trial of Lisa Michelle Lambert - What
Happened" at the club's weekly luncheon meeting at noon at Andy's
Catering, 1106 Millersville Pike.
Article 229 of 348, 1991173057
BLIND JUSTICE
"In the end, Laurie Show's murder ... wasn't just a story about a jealous
lover seeking revenge.. "It was about a town making a snap judgment
against the accused, Lisa Michelle Lambert, a woman whose friends even
considered "trailer trash.' About a police department going to great lengths
to pin the crime on her. About a prosecutor who, a judge said, bent the law
to win a first-degree murder conviction rather than
Article 230 of 348, 1991173044
JUDGE'S REBUKE STINGS COUNTY

It was a week of shattered beliefs.. Before Lisa Michelle Lambert's hearing
in federal court began, everything was neat and tidy. She was guilty of
murdering Laurie Show, and was sent to jail. Police and prosecutors were
heroes. Justice had been served. U.S. District Court Judge Stewart Dalzell
changed all that.. In a decision that shook Lancaster County to its roots,
Dalzell last Monday set Lambert free, declaring her innocent. But that was
hardly all.. In his 90-page


3 of 3
6/10/2006 8:51 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2277
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 231 of 348, 1991161659
READERS OPPOSE DALZELL RULING

Intelligencer Journal staff report. Most Intell readers responding to this
week's People Poll disagreed with a federal judge's decision to free Lisa
Michelle Lambert. Yet a slimmer majority of readers think an investigation of
the prosecutors and police involved in the case is warranted. U.S. District
Judge Stewart Dalzell decided Monday to free Lambert and bar a retrial.
She had been serving life in prison for the 1991 murder of teen-ager Laurie
Show in her East
Article 232 of 348, 1991161612
EAST LAMPETER TOWNSHIP OFFICIALS SHOULD

INVESTIGATE
Editor, New Era:. I find it appalling that Lisa Michelle Lambert has been
released from prison. At the very minimum, there should be a retrial. It is
also obvious to me, however, that East Lampeter Township is more
interested in protecting its own than in protecting the community from the
unprofessional conduct of the police department. One of the police officers
has been suspended for the second time, for alleged sexual misconduct.
Why was he reinstated after the first incident? Is this the
Article 233 of 348, 1991151862
IN SHOW CASE, THE TRUTH KEEPS SLIPPING AWAY

I don't know if Lisa Michelle Lambert killed Laurie Show. What I do know,
from years of court reporting, is that getting at the truth is slippery business..
If the Rodney King case proved anything, it's that even a videotape offers
only a version of the truth. When U.S. District Judge Stewart Dalzell Monday
freed Lambert from a life sentence, he issued a 90-page explanation, an
"official" version of the truth.. According to this
Article 234 of 348, 1991151881
1 of 3
6/10/2006 8:52 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2278
of 2301
1299
LAMBERT DECISION STILL ECHOES

Intelligencer Journal columnist Jeff Hawkes - who covered the murder trial
of Lisa Michelle Lambert five years ago - talks with the victim's mother,
Hazel Show, about the controversial case and a federal judge's decision to
free Lambert.. Mrs. Show tells Hawkes that Judge Stewart Dalzell
misunderstood her when she told him she now remembered seeing a car
leaving her condominium complex on the morning her daughter was killed.
And she fears the judge gave great weight
Article 235 of 348, 1991151820
PROSECUTORS HERE WON'T DISCUSS CASE

Lancaster County's top prosecutors in the Laurie Show murder case have
declined to be interviewed this week about their reaction to a federal judge's
decision to release Lisa Michelle Lambert.. District Attorney Joseph
Madenspacher has filed a notice of his intention to appeal U.S. Judge
Stewart Dalzell's decision with the 3rd Circuit Court of Appeals and said it
would be inappropriate to comment while the case is still pending. First
Assistant District
Article 236 of 348, 1991151822
DALZELL CALLED OUTSPOKEN AND DEMANDING

It was not the sort of exchange you'd hear in every courtroom.. U.S. District
Judge Stewart Dalzell was berating one of the county's top prosecutors,
John Kenneff, with a flurry of sarcasm. "The U.S. Constitution. The
Fourteenth Amendment. Due process of law. Ever hear of it, Mr. Kenneff?
That's what we're talking about here. Got it? Understand?" roared Dalzell.. It
was just one of numerous acidic salvos fired by
Article 237 of 348, 1991151819
'HE'S VERY MUCH A LAW-AND-ORDER PERSON'

Here's something that Lancaster Countians might find hard to swallow:. U.S.
District Judge Stewart Dalzell is known as a law-and-order guy. That's the
view of two Philadelphia attorneys who have practiced law in his courtroom
on numerous occasions.. Dalzell sparked outrage here by freeing convicted
murderer Lisa Michelle Lambert on Monday, declaring her innocent and
saying prosecutors denied her a fair trial.. "For him to have that kind of
reaction
Article 238 of 348, 1991151829
2 of 3
6/10/2006 8:52 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2279
of 2301
1299
JUDGE DALZELL AND THE ATTORNEYS DID THEIR

JOB
Article 239 of 348, 1991151823
A NIGHTMARE: SIMPSON, RAMSEY, NOW LAMBERT

Editor, New Era:. I can't believe an accomplice to murder, Lisa Michelle
Lambert, was set free. She admitted being at the murder scene the day
Laurie Show was murdered! Oh, that's right, she tried to save Laurie's life,
that's how she got blood all over her. That's why she was there! She should
have stayed in prison to await a new trial, not be cut loose.. Why doesn't
Judge Dalzell let the woman-beater, Lawrence
Article 240 of 348, 1991151828
THE LESSON FOR CHILDREN IS: GET A GOOD

LAWYER
Editor, New Era:. I just received the news of Lisa Michelle Lambert's release
for the killing of Miss Show in '91. I am outraged that our justice system no
longer works for the victim but for the criminal. Since the O.J. trial, everyone
has gotton on the bandwagon and hired expensive lawyers to tear down the
evidence and make a mockery of our justice system. I am so fed up and
tired of the victim's loss of rights and the supposed rights of the criminals,


3 of 3
6/10/2006 8:52 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2280
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 241 of 348, 1991142203
DO YOU AGREE WITH LAMBERT RULING?

U.S. Judge Stewart Dalzell freed Lisa Michelle Lambert for the murder of
Laurie Show and barred a retrial on the grounds that the prosecution
manipulated evidence and used perjured testimony to convict her.
Lancaster County District Attorney Joseph C. Madenspacher contends there
was no criminal wrongdoing on the part of the prosecution and has filed an
appeal to have the judge's ruling overturned.!6+. Do you agree or disagree
with Judge Dalzell's decision to free Lisa
Article 242 of 348, 1991142208
SHOWS CAN'T SUE LAMBERT OVER DEATH

Time has run out for the family of murder victim Laurie Show to bring a civil
lawsuit against Lisa Michelle Lambert, who was cleared of the killing by a
federal judge.. U.S. District Judge Stewart Dalzell freed Lambert Monday
from a life sentence, ruling that prosecutors framed her to get a conviction
during a non-jury trial in 1992. William Atlee, a veteran civil litigator in
Lancaster, said the two-year time limit has expired for the Shows to sue
Lambert for the wrongful death of their
Article 243 of 348, 1991142138
CORRECTIONS
Air Force Airman Michael D. Rosiere, son of Janice Rosiere, Old
Philadelphia Pike, recently graduated from basic training at Lackland Air
Force Base, San Antonio, Texas.. He is a 1996 graduate of Solanco High
School. Another serviceman's name was placed under his picture in
Tuesday's editions. The New Era regrets the error.. The New Era incorrectly
reported that East Lampeter Township Police Officer Robert Reed was one
of the men identified as a rapist by Lisa
Article 244 of 348, 1991133093
1 of 3
6/10/2006 8:53 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2281
of 2301
1299
PROBES ARE IN ORDER

Although we disagree with U.S. District Court Judge Stewart Dalzell's
decision to free Lisa Michelle Lambert and bar her retrial for murder, a
reading of the judge's 90-page opinion should leave any Lancaster Countian
with questions about the activities of the district attorney's office and some
local police.. At this point these are just questions. As Dalzell said last week
- after he accused Ronald Savage, a current district justice and former East
Article 245 of 348, 1991133100
HAZEL SHOW WANTS FEDERAL JUDGE OFF BENCH

Hazel Show said Tuesday night she is mounting a public crusade to oust a
federal judge who freed a woman convicted in 1992 of murdering her
16-year-old daughter.. "We have to get this judge (U.S. District Judge
Stewart Dalzell) off the bench," Show said Tuesday night during a
telephone interview from her East Lampeter Township home. "There is not
one bit of justice in him." In another development, the office of the U.S.
Attorney said it will
Article 246 of 348, 1991132959
SHOWS PUSH TO OUST JUDGE FROM BENCH

Laurie Show's parents are turning their anger into action this week, trying to
remedy a judge's release of their daughter's convicted killer.. "I can't let this
die," Show's father, John, said today. "We have to keep it alive until
something happens. I don't want this to happen to anyone else down the
road." Among the actions being taken by Show and his ex-wife, Hazel, are
Article 247 of 348, 1991132951
JUDGE DALZELL'S ALLEGATIONS MUST BE

PUBLICLY ANSWERED
Federal Judge Stewart Dalzell has verbally whipped Lancaster County and
its justice system beyond the point of embarrassment. In unrestrained,
melodramatic pronouncements, he has portrayed the people of Lancaster
County as partners in a rush to judgment led by scheming, lying law
enforcers.. He points to the "solidarity and compassion" this community
showed to John and Hazel Show when their daughter Laurie was brutally
murdered. "But then what was a social
Article 248 of 348, 1991132949
2 of 3
6/10/2006 8:53 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2282
of 2301
1299
LISA LAMBERT IS FREE BECAUSE OF U.S.

CONSTITUTION
Editor, New Era:. I'm writing about the Lisa Michelle Lambert case. After
comparing the reactions of lawyers with those of regular "folks," I came to
the conclusion that Lancaster Countians still don't get it. Prosecutorial and
police misconduct isn't just for the Rodney Kings and O.J. Simpsons of this
country. They aren't "L.A. and New York'' issues. They happen everywhere
and they
Article 249 of 348, 1991132960
NOW MIRACK FAMILY WONDERS: WAS OUR CASE

MISHANDLED?
As Laurie Show's family watched attorneys pick apart the police
investigation of her murder over the last three weeks, another family was
watching the proceedings with growing unease.. For Vince and Gerry
Mirack, the past several weeks have been an unsettling time. Their
daughter, Christy, 25, was murdered in her East Lampeter Township
townhouse a year and a day after Show's murder in her East Lampeter
condominium. East Lampeter police have never solved the school
Article 250 of 348, 1991122072
LAMBERT 'WILL NEVER STEP FOOT AGAIN' IN

COUNTY
PHILADELPHIA - Lisa Michelle Lambert "will never step foot again in
Lancaster County," her attorney predicted Monday, two hours after a federal
district court judge freed her from life imprisonment for a murder committed
six years ago.. It was a day filled with joy for Lambert and her family
Monday. For Laurie Show's family, it was a day filled with sorrow. Two
families brought together in a federal courtroom in Philadelphia because of
a tragedy five years


3 of 3
6/10/2006 8:53 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2283
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 251 of 348, 1991122087
COUNTY COMMISSIONERS HAVE 'CONFIDENCE' IN

DA'S OFFICE
In the face of accusations of gross prosecutorial conduct in the handling of
the Lisa Michelle Lambert case, two of Lancaster County's three
commissioners said Monday they stand behind District Attorney Joseph
Madenspacher and his office.. Commissioner Ron Ford said he has "every
confidence in the legal justice system here in Lancaster County." Likewise,
Paul Thibault said he "has the highest regard for the people in our district
Article 252 of 348, 1991122070
'LISA LAMBERT SHOULD BE IMMEDIATELY

RELEASED'
This is the decision of U.S. District Court Judge Stewart Dalzell in the case
of Lisa Michelle Lambert as released by his office on Monday.. Lisa
Lambert has petitioned this Court for a writ of habeas corpus, alleging,
among other things, that she is actually innocent of the first degree murder
for which she was convicted in July of 1992, and that she was the victim of
wholesale prosecutorial misconduct in connection with the prosecution of
her case. As a result of her being raped by a
Article 253 of 348, 1991122071
A STARTLING OUTCOME, BUT ROOTED IN THE

CONSTITUTION, LAWYER SAYS
Back in 1993, a well-known defense attorney said the decision by Lisa
Michelle Lambert's attorney to pursue a non-jury trial here in Lancaster
made it "absolutely less likely" that there would be an appeal based on court
error.. But an appeal based on misconduct by the prosecutor? It was made,
and it succeeded in federal court Monday. And Lambert, the convicted
murderer of Laurie Show, has been set free.. "It's extremely
1 of 4
6/10/2006 8:54 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2284
of 2301
1299
Article 254 of 348, 1991122084

MIXED MESSAGES
Judge Stewart Dalzell clearly intended to send a message when he freed
Lisa Michelle Lambert, who was serving a life sentence for the 1991 first
degree murder of Laurie Show. He claimed that the means - a trail of
evidence he said was tainted and compromised - did not justify the ends
(her conviction.). That said, the judge did no better. His means - freeing a
woman whose own testimony implicates her in the murder, and denying the
prosecution the opportunity to retry her - hardly justifies
Article 255 of 348, 1991122069

CLEARING LAMBERT OF MURDER / / DA WON'T QUIT,
VOWS TO APPEAL
KENNEFF. PHILADELPHIA - Stung by a federal judge's decision Monday to
free Lisa Michelle Lambert, Lancaster County District Attorney Joseph C.
Madenspacher said he would appeal the case today to the 3rd U.S. Circuit
Court of Appeals. Madenspacher told reporters part of his appeal will focus
on the judge's decision last week to release Lambert conditionally to her
attorneys before the state presented its case against her.. "We will take this
case as far
Article 256 of 348, 1991122073
SOME LOCAL LAWYERS EXPRESS OUTRAGE, OTHERS

PONDER THE FALLOUT
The shock had passed. By Monday evening, some local attorneys found
their feelings over the outright release of Lisa Michelle Lambert had turned
to plain anger.. Once a convicted killer, Lambert was now called "innocent"
by a federal judge. "It's outrageous," said Stephen R. Gibble, a lawyer who
formerly chaired the county GOP. "The whole thing is awful. To say there
won't be a new trial, that takes my breath
Article 257 of 348, 1991122074
AROUND EAST LAMPETER, ANGER AT JUDGE,

SYMPATHY FOR SHOWS
The decision to free Lisa Michelle Lambert, the convicted killer of
16-year-old Laurie Show, left many people with mixed emotions.. People
attending Monday's school board meeting at Conestoga Valley High School,
where Show, Lambert and co-defendant Tabitha Buck attended school,
agreed that justice was ill-served. But they say it's U.S. District Judge
2 of 4
6/10/2006 8:54 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2285
of 2301
1299
Stewart Dazell who is at fault. While few wanted their names published,
many were quick to put their feelings on the
Article 258 of 348, 1991122075

CLEARING LAMBERT OF MURDER / / DALZELL
FORBIDS RETRIAL, CALLS FIRST TRIAL 'RIGGED'
PHILADELPHIA - Calling her a victim of corrupt prosecutors, a federal judge
Monday cleared Lisa Michelle Lambert of murder, barred a retrial and called
for an investigation of prosecutor John A. Kenneff, District Justice Ronald
W. Savage and six police officers.. "The fact is the commonwealth rigged
the proceedings in (Lambert's) trial to such an extent that it was a trial in
name only," said U.S. District Court Judge Stewart Dalzell, freeing Lambert
from
Article 259 of 348, 1991122005
LAMBERT TO 'MAKE UP LOST TIME WITH HER

FAMILY'
After 64 months in prison, Lisa Michelle Lambert walked away from a life
sentence and into the arms of the parents from whom she once rebelled..
Together, the family begins an uncertain future veiled in secrecy and laden
with fear of retribution from those angered by Lambert's freedom. The only
thing for sure, said the 24-year-old's attorney, is that Lisa Lambert "will
never set foot again in Lancaster County.". "I think
Article 260 of 348, 1991122007
LAWYERS EXPECT APPEAL WILL FAIL

"We've got to resign ourselves to the fact this girl is not going back to jail. ".
Those are the words of local defense attorney Robert Beyer, commenting
today on the Lisa Michelle Lambert case. U.S. District Court Judge Stewart
Dalzell released Lambert Monday from her lifetime prison sentence for the
1991 murder of Laurie Show and barred a retrial. Lancaster County District
Attorney Joseph C. Madenspacher is appealing the decisionl. "I

3 of 4
6/10/2006 8:54 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2286
of 2301
1299
4 of 4
6/10/2006 8:54 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2287
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 261 of 348, 1991122002

Article 262 of 348, 1991122004

Article 263 of 348, 1991122000

'WITNESS'?
Article 264 of 348, 1991122013
1 of 3
6/10/2006 8:55 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2288
of 2301
1299

THESE QUESTIONS?
Article 265 of 348, 1991122006

Article 266 of 348, 1991122012

COUNTRY
Article 267 of 348, 1991111938

TODAY
2 of 3
6/10/2006 8:55 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2289
of 2301
1299
Article 268 of 348, 1991111885


Article 269 of 348, 1991111845
LAMBERT FREED
while the
Article 270 of 348, 1991111846



3 of 3
6/10/2006 8:55 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2290
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 261 of 348, 1991122002

Article 262 of 348, 1991122004

Article 263 of 348, 1991122000

'WITNESS'?
Article 264 of 348, 1991122013
1 of 3
6/10/2006 8:56 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2291
of 2301
1299

THESE QUESTIONS?
Article 265 of 348, 1991122006

Article 266 of 348, 1991122012

COUNTRY
Article 267 of 348, 1991111938

TODAY
2 of 3
6/10/2006 8:56 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2292
of 2301
1299
Article 268 of 348, 1991111885


Article 269 of 348, 1991111845
LAMBERT FREED
while the
Article 270 of 348, 1991111846



3 of 3
6/10/2006 8:56 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2293
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 271 of 348, 1991103147
LAURIE'S LOSS CHANGED LIFE OF BOYFRIEND

For more than five years, Brad Heisler has been the forgotten man.. He was
Laurie Show's boyfriend, a Conestoga Valley sophomore in the midst of a
typical teen-age relationship. Then, on Dec. 20, 1991, Show was beaten,
stabbed and left to die with a slit throat on her bedroom carpet. Heisler was
probably the second person to arrive at the scene of her murder, but what
he saw there is still in dispute.. His story of the murder and the toll it has
taken on his life has never
Article 272 of 348, 1991103142
RECAP OF A VERY DRAMATIC WEEK

Following is a synopsis of last week's events in the Lisa Michelle Lambert
murder appeal hearing in federal court in Philadelphia.. SUNDAY, APRIL
13: County officials announced that they had hired Lancaster attorneys Alvin
Lewis and Richard Sprague to represent county prosecutors, detectives and
others at the hearing. MONDAY, APRIL 14: Former state policeman John
Balshy testified that Laurie Show appeared to have written the initials "TB"
and
Article 273 of 348, 1991103148
TRYING TIMES
Balding on top but with long, flowing white hair in back, U.S. District Judge
Stewart Dalzell looks a little like Henry Fonda, and acts a lot like John
Wayne.. On Thursday, for example, when Lancaster District Attorney
Joseph Madenspacher asks him to reconsider his decision to release Lisa
Michelle Lambert to the custody of her lawyers, Madenspacher has barely
finished speaking before Dalzell brushes his concern aside with: "OK, that's
denied. What's
Article 274 of 348, 1991103150
1 of 3
6/10/2006 8:57 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2294
of 2301
1299

MONDAY. April 14 - The federal appeal hearing for Lisa Michelle Lambert,
seeking a new trial or freedom on her conviction in the murder of Laurie
Show, restarted in Philadelphia. Lambert is serving a life sentence, along
with Tabitha Buck, while Lambert's boyfriend, Lawrence Yunkin, is serving
10-20 years as an accessory.. The case broke wide open Wednesday,
when the judge released Lambert into the custody
Article 275 of 348, 1991103143
ATTORNEYS FEEL PAIN OF THEIR COLLEAGUES

U.S. Judge Stewart Dalzell's harsh words about some of Lancaster's top
lawyers have reverberated through the legal circles here.. Lancaster's legal
community, about 650 lawyers strong, is small enough that many lawyers
know each other on a first-name basis. The men Dalzell has accused of
perjury, concealing evidence and obstruction of justice in the Lisa Michelle
Lambert murder investigation aren't just district attorneys and a district
Article 276 of 348, 1991103144
TRYING TIMES
On the stand, Ronald Savage absorbs verbal body blow after verbal body
blow from attorney Christina Rainville, who is accusing him of lying, of
withholding evidence, of trying to frame Lisa Michelle Lambert in the 1991
murder of Laurie Show.. Savage seems defenseless, answering nearly
every question with "I don't know," or "I can't recall." He is only emphatic
when Rainville directly accuses him of perjury.
Article 277 of 348, 1991103145
MRS. SHOW SAYS JUDGE WAS UNFAIR

Evil seemed to turn to good last week, and good to evil.. In a Philadelphia
house, a convicted killer ate pizza and listened to piano music, while the
people who carry the trust of the justice system on their shoulders went on
trial, and seemingly lost. Hazel Show is spending the weekend praying that
U.S. Judge Stewart Dalzell will order a new trial and not set Lisa Michelle
Lambert free.. "The transcripts of the last trial ... should give him the light of
Article 278 of 348, 1991091785
2 of 3
6/10/2006 8:57 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2295
of 2301
1299
SHOW INSISTS LAURIE FINGERED LAMBERT

PHILADELPHIA - Hazel Show insisted Friday in federal court that her
daughter identified Lisa Michelle Lambert as her killer.. "I lifted her and saw
her throat was cut," Show said in testimony before U.S. District Judge
Stewart Dalzell, who is presiding at a hearing in which Lambert is seeking
freedom from a life sentence for killing Show's daughter. "I tried to keep her
together. I told her I am sorry and it was a setup," Show said.
Article 279 of 348, 1991091784
DA BACKS NEW TRIAL FOR LAMBERT

PHILADELPHIA - A lawyer for convicted murderer Lisa Michelle Lambert
urged a federal judge Friday to free her client permanently, but the
Lancaster County district attorney asked to be able to retry her on 1991
murder charges.. Christina Rainville, Lambert's lawyer, proclaimed in
closing remarks at her client's federal appeals hearing, "The truth is out.
Lisa Lambert is innocent, innocent of murder and innocent of conspiracy." A
hearing on
Article 280 of 348, 1991091737
SHOWS FEAR THE 'WORST' IN JUDGE'S RULING

PHILADELPHIA - In two days, a federal judge will decide whether Lisa
Michelle Lambert goes free or gets a new trial for the Dec. 20, 1991, murder
of 16-year-old Laurie Show.. John Show said today that he and his ex-wife,
Hazel, are almost certain that their daughter's convicted killer will be set free
on Monday. "I just felt all along that the judge has his mind made up," Show
said. "It's going to be a terrible


3 of 3
6/10/2006 8:57 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2296
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 281 of 348, 1991091739
LAWYER: SHE'S INNOCENT

PHILADELPHIA - "Justice requires that Miss Lambert be released," a
Philadelphia attorney argued here Friday in federal court.. Christina
Rainville, a lawyer for Lisa Michelle Lambert, said Lancaster County
prosecutors convicted Lambert of the 1991 murder of Laurie Show by lying
and fabricating evidence. "The truth is out. Lisa Lambert is innocent.
Innocent of murder. Innocent of conspiracy," Rainville said in a closing
statement Friday
Article 282 of 348, 1991082170
LAMBERT CASE COULD IMPACT ON FUTURE

CANDIDACIES
The curious and bizarre court proceedings in Philadelphia that may yet
produce the release of convicted killer Lisa Michelle Lambert could also
produce some political detours among local Republican politicians, while
putting some others on the fast track to advancement.. There have already
been some speed bumps in the GOP's road this year. The Republican
committee people, impressed by his steadfast willingness to volunteer for
just about any task, endorsed Dennis E. Reinaker for
Article 283 of 348, 1991082177
DA ASKS JUDGE BE REMOVED FROM CASE

This is a slightly edited text of District Attorney Joseph Madenspacher's
motion asking that Judge Stewart Dalzell be removed from the Lambert
case.. Motion for Recusal of District Court Judge Stewart Dalzell Appellants,
Respondents below, respectfully move for Recusal of U.S. District Court
Judge Stewart Dalzell for the Eastern District of and in support thereof state
as follows:. 1. On April 2, 1997, during the direct testimony of Ronald
Barley, The Honorable Judge Stewart
Article 284 of 348, 1991082180
1 of 3
6/10/2006 8:58 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2297
of 2301
1299
LAWYER ACCUSES SAVAGE OF TRYING TO FRAME

TEEN
PHILADELPHIA - An attorney seeking to free Lisa Michelle Lambert
accused District Justice Ronald W. Savage, chief investigator in Laurie
Show's murder, of trying to frame a teen-ager in the killing of a teacher a
year and a day after 16-year-old Show was stabbed to death.. Savage, who
also headed the investigation into the 1992 murder of teacher Christy
Mirack, came under fire again Thursday in a federal hearing where Lambert
is seeking freedom from her 1992 conviction in
Article 285 of 348, 1991082176
STATEMENT FROM LAMBERT LAWYERS

The following is a statement issued Wednesday by Peter Greenberg and
Christina Rainville, lawyers for Lisa Michelle Lambert.. We're shocked,
offended and indeed saddened by motions filed by the Commonwealth and
the attitudes expressed today. The evidence produced in this courtroom has
quite literally defied belief. None of us could imagine that in America in the
1990's a perversion of justice like this could have taken place and this
conduct has continued in the
Article 286 of 348, 1991082185
LAMBERT STAYS OUT OF PRISON

PHILADELPHIA - Convicted murderer Lisa Michelle Lambert beamed and
hugged her parents late Thursday afternoon after a prosecutor's bid to block
her conditional release was rejected by a federal appeals panel.. Acting
swiftly, a three-judge panel of the 3rd U.S. Circuit Court of Appeals upheld
U.S. District Judge Stewart Dalzell's decision Wednesday to release
Lambert to the custody of her attorneys while a hearing on alleged
misconduct by prosecutors continues. The
Article 287 of 348, 1991082119
COURTHOUSE BANS ARE PRECAUTION

Better safe than sorry, U.S. District Judge Stewart Dalzell believes.. His
unusual order on Wednesday - directing a prosecutor, police and others
who handled the Lisa Michelle Lambert murder case to stay out of the
courthouse and stay away from him, his family and his staff - is apparently
just a precaution. Courthouse personnel knew of no threats against the
Philadelphia judge, his family or his staff.. Dalzell is hearing a bid by
Lambert, convicted of the 1991 killing of East Lampeter
2 of 3
6/10/2006 8:58 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2298
of 2301
1299
Article 288 of 348, 1991082117

NEXT: TABITHA BUCK'S APPEAL TO GO FEDERAL?

Lisa Michelle Lambert will not be the only defendant to seek a new trial, or
release from prison, as a result of alleged police and prosecutor
misconduct.. The attorney for co-defendant Tabitha Buck said today he will
use those same issues to seek to overturn her 1992 conviction of
participating in the stabbing death of teen-ager Laurie Show. "To the extent
that Tabitha Buck's case is similar to Lambert's case and Lambert's case is
tainted,
Article 289 of 348, 1991082118
RELAXED LAMBERT: 'CAN YOU TAKE ME TO

DISNEYLAND?'
Convicted murderer Lisa Michelle Lambert returned to court today, calm
and relaxed after a second day out of jail.. Dressed in a dark-green suit and
beige blouse, Lambert strolled casually to the defense table, talked briefly
with her attorneys and then walked unescorted through a rear door behind
the judge's bench. She returned a few minutes later to hear the first of five
witnesses whom Lancaster County District Attorney Joseph Madenspacher
intended to present in an effort to
Article 290 of 348, 1991082115
LAWYER SUGGESTS SAVAGE TRIED TO FRAME

WITNESS
District Justice Ronald W. Savage is conducting "business as usual" today
in his Leola office, after enduring days of accusations in Philadelphia's
federal court questioning his integrity and investigative skills.. In December
1991, Savage was an East Lampeter Township police sergeant leading the
investigation and police prosecution of Lisa Michelle Lambert for the murder
of 16-year-old Laurie Show. This week, as the convicted murderer seeks
her freedom in


3 of 3
6/10/2006 8:58 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2299
of 2301
1299
Home
Features
Weather
Classifieds
Talk Back
Apartments
Shopping
Special
Sections
Visit Lancaster
Travel
Personals
Archive
News
Local News
Top Stories
Site
Site Map
Keyword Index
RSS Feeds
Need A
WebSite?
Contact Us
Go

were found.
Article 291 of 348, 1991082070
VICTIM'S MOTHER ACCUSES LAMBERT

PHILADELPHIA _ Laurie Show's mother took the stand today in a bid to
keep her daughter's convicted murderer, Lisa Michelle Lambert, in prison..
"Nothing has changed...Laurie told me that Michelle did it, and there's no
other truth than that," Hazel Show said today before she testified. Mrs.
Show is the key witness for Lambert's prosecutors, who are arguing to
refute Lambert's bid for freedom in a federal
Article 292 of 348, 1991072085

PHILADELPHIA - A federal judge lambasted East Lampeter Township
District Justice Ronald Savage Wednesday for allegedly lying under oath on
the witness stand and obstructing justice in the Laurie Show murder case..
U.S. District Judge Stewart Dalzell told Lancaster County District Attorney
Joseph Madenspacher to contact the Pennsylvania Supreme Court and
insist on having Savage removed from the bench. Dalzell's remarks came
during a series of extraordinary events at a federal
Article 293 of 348, 1991072089
TRANSCRIPT OF HEARING
U.S. District Court Judge Stewart Dalzell's decision to conditionally release
Lisa Michelle Lambert came after an extraordinary hearing in the judge's
chambers Wednesday afternoon.. The session brought together the
Lancaster County district attorney and lawyers for Lambert and heard new
testimony from Hazel Show, the mother of murder victim Laurie Show. After
hearing what Mrs. Show had to say, Dalzell accused the chief police
prosecutor of the case, now a district
Article 294 of 348, 1991072088
1 of 3
6/10/2006 8:58 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2300
of 2301
1299
JUDGE: 'I DON'T WANT HER TO GO BACK TO PRISON'

This is the transcript of a hearing in the chambers of U.S. District Judge
Stewart Dalzell held Wednesday afternoon. Participating were the judge
("The Court"); Joseph Madenspacher, Lancaster County district attorney;
Peter Greenberg, attorney for Lisa Michelle Lambert; Christina Rainville,
attorney for Lambert; Alvin Lewis, attorney for Lancaster County officials;
and Hazel Show, mother of murder victim Laurie Show.. AFTERNOON
SESSION (Reconvened in Chambersat 1:40
Article 295 of 348, 1991072086
LAMBERT CASE DEVELOPMENTS SHOCK LAWYERS

Local attorneys Wednesday expressed shock over the conditional release of
convicted killer Lisa Michelle Lambert.. And one attorney said Wednesday's
action is likely a prelude to Lambert's outright freedom. Scott Oberholtzer, a
defense attorney, said he would not be surprised if U.S. District Judge
Stewart Dalzell frees Lambert today. "For the judge to go ahead and let her
go ahead tonight, he must have made up his mind to do something,"
Article 296 of 348, 1991072087

This story was written by Intelligencer Journal reporter Paul Bomberger and
reported by Bomberger, Intelligencer Journal reporters Jennifer Kopf and
Jeff Hawkes and correspondent Lee Linder.. PHILADELPHIA - A federal
judge released Lisa Michelle Lambert to the custody of her lawyers
Wednesday afternoon, after the mother of murder victim Laurie Show
testified she had been instructed by police in 1992 to withhold crucial
evidence. Lambert celebrated her first night of freedom in six years
Article 297 of 348, 1991072035
'DAZED' LAMBERT AWAITS RULING ON FREEDOM,

TRIAL
Lisa Michelle Lambert spent her first night of freedom in 5 1/2 years sitting
in a Philadelphia townhouse, eating pizza and listening to piano music while
guarded by federal marshals.. Lambert was left "dazed" by the sudden turn
of events Wednesday, when a federal judge released her to the custody of
her attorneys after ruling that prosecutors violated her right to a fair trial.
Lambert, 24, had been in prison since her arrest the evening of Dec. 20,
1991 on charges
2 of 3
6/10/2006 8:58 AM
Archives
A...
January January
Sunday
22, 2017
22, 2017
Page
2301
of 2301
1299
Article 298 of 348, 1991072040

OTHERS MAY BE GUILTY, BUT LAMBERT IS NOT

INNOCENT
Lisa Michelle Lambert is not the victim.. The victim is 16-year-old Laurie
Show, in her grave. And Lambert is not innocent - how could she be?. A
county Commonwealth Court and a state Superior Court ruled she is not.
The state Supreme Court, after reviewing these decisions, refused to hear
her appeal.. Now, even with newly revealed evidence that supports her
claims, Lambert is still irrevocably involved in the events that led to Laurie
Show's murder.. These facts must
Article 299 of 348, 1991072032
MURDER VICTIM'S MOTHER SAYS SHE'S ALWAYS

TOLD TRUTH
The mother of murder victim Laurie Show is sticking by her court testimony,
which included statements that her dying daughter told her "Michelle did it.".
Hazel Show did not respond to interview requests today, in the wake of her
dramatic revelation Wednesday that she suddenly recalled that police told
her to withhold crucial evidence after the Dec. 20, 1991, murder. But
through a spokeswoman, Mrs. Show said today that she has always told the
truth about events
Article 300 of 348, 1991072034
EXPERT: JUDGE'S MOVE UNUSUAL, CLEARLY

ALLOWED
U.S. District Judge Stewart Dalzell's decision to release Lisa Michelle
Lambert is unusual but clearly allowed under federal law, a San Francisco
expert in such proceedings says.. Timothy J. Foley, a Harvard-educated
attorney who specializes in federal-release hearings, said Wednesday night
that a federal judge does have the right to free a defendant when he
believes the state court system has violated the individual's constitutional
rights to a fair trial.


3 of 3
6/10/2006 8:58 AM

STAN J. CATERBONE AND THE LISA MICHELLE LAMBERT CASE January 22, 2017 PDF

Diunggah oleh

Informasi Dokumen

Judul Asli

Hak Cipta

Format Tersedia

Bagikan dokumen Ini

Bagikan atau Tanam Dokumen

Opsi Berbagi

Apakah menurut Anda dokumen ini bermanfaat?

Apakah konten ini tidak pantas?

Hak Cipta:

Format Tersedia

STAN J. CATERBONE AND THE LISA MICHELLE LAMBERT CASE January 22, 2017 PDF

Diunggah oleh

Hak Cipta:

Format Tersedia

Laurie is never far from their minds - LancasterOnline: News

Stan J. Caterbone LAMBERT CASE FILE

Laurie is never far from their minds

Laurie is never far from their

Decorations adorn Laurie Show's gravesite

Laurie is never far from their minds - LancasterOnline: News

Stan J. Caterbone LAMBERT CASE FILE

Laurie is never far from their minds - LancasterOnline: News

Stan J. Caterbone LAMBERT CASE FILE

Laurie is never far from their minds - LancasterOnline: News

Stan J. Caterbone LAMBERT CASE FILE

Laurie is never far from their minds - LancasterOnline: News

Stan J. Caterbone LAMBERT CASE FILE

Stan J. Caterbone LAMBERT CASE FILE

Advanced Media Group

HAD LANCASTER COUNTY (Pennsylvania) LOST ITS

Each time a man stands up for an ideal, or acts to

The following report (most identities purposely omitted from this

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

Judge Dalzalls extremely controversial findings were responsible for

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

Fortunately, this victims story is laced with a thread of faith, a faith in

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

This story was perpetuated through a gross miscarriage of justice: a

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

Investigation (FBI), the Internal Revenue Service (IRS), the Department of

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

intervention into the commercial enterprise, or organization, circumventing the

This victim was a shareholder of record of International Signal & Control

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

The emotional response to the truth of this story is compelling, to say

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

The heart of this victims legal dogma is best described as follows: If a

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

impoverished. He had an undivided aspiration to someday make a difference to

In 1986, after serving on the Board of Directors for the Central

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

The company had developed satellite offices throughout Pennsylvania and

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

and legal administrator of the organization, in addition to building his own

Many of his friends were involved, and in Lancaster, everyone knows

In 1987, his business affairs were reaching a point of incredible success.

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

The victim prided himself on his

By June of 1987, the victim had developed a fairly substantial mortgage

There was a uniqueness to his capabilities that was very appealing to

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

Given the complex nature of the victims design of FMG, internal

ADVANCED MEDIA GROUP

Stan J. Caterbone LAMBERT CASE FILE

The psychiatrist had diagnosed the victim as having Bi Polar Mood