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
Exactly 20 years ago this morning, Yunkin drove Lambert and Buck to Laurie's
mom's East Lampeter Township condominium.
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
http://lancasteronline.com/news/laurie-is-never-far-from-their-minds/artic...
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
http://lancasteronline.com/news/laurie-is-never-far-from-their-minds/artic...
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
http://lancasteronline.com/news/laurie-is-never-far-from-their-minds/artic...
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
http://lancasteronline.com/news/laurie-is-never-far-from-their-minds/artic...
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
www.amgglobalentertainmentgroup.com
infor@amgglobalentertainmentgroup.com
717.731.8184 Phone
717.427-1621 Fax
In 1987 This Plaintiff Had Unjustly Lost His Freedoms, His Rights, And His
Pursuit Of Life, Liberty And Justice.
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
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.
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.
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.
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
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
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 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 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
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.
Page 10 of 18
04.11.2007
January January
Sunday
22, 201722, 2017
Page 16 of 2301
1299
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.
entrepreneurship , and after building the foundation for FMG, he set out to take
advantage of its resources and its synergism.
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.
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.
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.
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
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
Stan J. Caterbone
ADVANCED MEDIA GROUP
Page 1 of 91
January January
Sunday
22, 201722, 2017
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
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
Page 2 of 91
January January
Sunday
22, 201722, 2017
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
Page 27 of 2301
8/8/2016 8:01 AM
'He got off light': Students ponder verdict after Millersville University's fi... http://lancasteronline.com/insider/he-got-off-light-students-ponder-verdic...
2 of 6
Page 28 of 2301
8/8/2016 8:01 AM
'He got off light': Students ponder verdict after Millersville University's fi... http://lancasteronline.com/insider/he-got-off-light-students-ponder-verdic...
3 of 6
Page 29 of 2301
8/8/2016 8:01 AM
'He got off light': Students ponder verdict after Millersville University's fi... http://lancasteronline.com/insider/he-got-off-light-students-ponder-verdic...
4 of 6
Page 30 of 2301
8/8/2016 8:01 AM
'He got off light': Students ponder verdict after Millersville University's fi... http://lancasteronline.com/insider/he-got-off-light-students-ponder-verdic...
5 of 6
Page 31 of 2301
8/8/2016 8:01 AM
'He got off light': Students ponder verdict after Millersville University's fi... http://lancasteronline.com/insider/he-got-off-light-students-ponder-verdic...
6 of 6
Page 32 of 2301
8/8/2016 8:01 AM
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
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
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
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
Page 35 of 2301
8/8/2016 7:57 AM
4 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
Page 36 of 2301
8/8/2016 7:57 AM
5 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
Page 37 of 2301
8/8/2016 7:57 AM
6 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
Page 38 of 2301
8/8/2016 7:57 AM
7 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
Page 39 of 2301
8/8/2016 7:57 AM
8 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
Page 40 of 2301
8/8/2016 7:57 AM
9 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
Page 41 of 2301
8/8/2016 7:57 AM
1 of 2
http://www.dailylocal.com/general-news/20160607/chester-springs-man-...
Page 42 of 2301
6/14/2016 2:00 AM
2 of 2
http://www.dailylocal.com/general-news/20160607/chester-springs-man-...
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
6/14/2016 2:00 AM
Page 44 of 2301
Page 1 of 63
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
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.
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
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
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
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
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
Page 5 of 18
04.11.2007
Page 53 of 2301
Page 10 of 63
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
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
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.
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
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
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
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
Page 65 of 2301
Page 22 of 63
Page 18 of 18
04.11.2007
Page 66 of 2301
Page 23 of 63
Stan J. Caterbone
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
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
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/___________
Stan J. Caterbone, Pro Se Litigant
Advanced Media Group
www.amgglobalentertainmentgroup.com
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
Page
Page22ofof29
Monday,
Sunday, January 25,
24, 2016
Page 68 of 2301
Page 25 of 63
Stan J. Caterbone
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
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
Letter to Lisa Michelle Lambert
Document: 003112153497
Filed: 12/14/2015
Page 71 of 2301Page: 1 StanDate
J. Caterbone
LAMBERT CASE FILE
Page 28 of 63
www.amgglobalentertainmentgroup.com
scaterbone@live.com
717-669-2163
Stanley J. Caterbone, APPELLANT, Pro Se
Advanced Media Group
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.
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
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?
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
KEISLING: Palace coup: what the Kathleen Kane prosecution is really ...
2 of 3
http://newslanc.com/2015/12/09/keisling-palace-coup-what-the-kathleen...
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
KEISLING: Palace coup: what the Kathleen Kane prosecution is really ...
3 of 3
Newslanc
Op
Ed Letter
Letter
re Kathleen
to the Editor
Kane
http://newslanc.com/2015/12/09/keisling-palace-coup-what-the-kathleen...
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
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
http://triblive.com/state/pennsylvania/9844432-74/state-political-budget?...
Page 76 of 2301
Page 33 of 63
1/25/2016 5:22 AM
3 of 3
http://triblive.com/state/pennsylvania/9844432-74/state-political-budget?...
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
(.
'
(
4
<=* .
.
(.
-
(.
$ "#
%
&
"
"
"
#
(
"
"
&
"
"
"
'
"
? ?
2
7
'
(
(
"
(
8
'
B1
)
!
!
<( $
C
<
(
(
&
D
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
Stan J. Caterbone LAMBERT CASE FILE
Page 41 of 63
Saturday, May 28, 2016
!
'
" #$ $ %
)'
&
%
%)
*++
!
$
'
"
"
'
8 '
(922
(
2'
"!
( )%
"% .
"
"## $"
-$
&
0
$
$
$
$"
$
$
%,11
/
$
1
2$
!%
!%$
!%+
!%$
%
$
1
1
$) ! !
$
$
$
1
&
%
-! ) * . *++
-! ) . *++
/0
'
'
2
*
5 #$ '
69
"
*
"# - /
0
*
1%
"
!%
Page 1 of 16
%&
&
, - .$
"
%' ( )*+*
'
'
%
',%
)' +
#
2
6
(34
0
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 85 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 42 of 63
Saturday, May 28, 2016
,
-$
%!
""
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 !
"
/!
** )
"!
" "
,
'
"
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 86 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 43 of 63
Saturday, May 28, 2016
"#. "
) "' "
8"%
88'
'
"
. "
#"4.
%% %
) "
@""
:!
!/
%
/!
!
"'
%
9
&
"
#$ $
*
=
!
%
)
;
%
)
) .
)
"
"
!
8 2.
"!
" /
"
1
)
"
8 >
!
"
<
'
"
9$
"
3 %
/3"#
%
<
":# )*6)*
9
% ;
) -
<
-! )
) <
! )
.
$
"
.
":#6 /
1
"
>
?
"
& # %/"#.
"
)
" = %
"
'
: !
"
B
. "
"
&
" '
#$ $
&". "
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;
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 87 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 44 of 63
Saturday, May 28, 2016
%
%
%
B
?%
"%/
) -
+;++ H 6
%
) !
"
%
6
"
.
) #$ $
B
-
*++
B
.
%
!
2$
<
>
""
!
.
<
)
<
< "
!
.
% $
)$
!%
<
<
". !% !
5! )
$
"
"
!%
"
"
"
;!%,
)
%
-$
"
) "
(4
7?
%
"
)%
!%
"
"
%
!
)
)
"
)
"
< %!
"
"
% %!
"
! <
"
<
"
; !
< "
!%
!
/!
"
"
$
.
$
!
!
). "
)
""
%
1 %
"
)
5!
#$ $
"
! $
) "
" 6
!)
"
$.
)
%! !
)
Page 4 of 16
$
.
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 88 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 45 of 63
Saturday, May 28, 2016
,
)
"
. "
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
-$
!
:/ .&% :
." ! #" :/
"
'
& . # 8""
& )
"
.
!
$ +D;*3+D $
"
!
5 )**?
'
# !!"##5
%%
"&
& &"#/#
(=8@>( $
# 0*(<>>(>2 /
./# ! #" /# # /
5 ";/&" !"
**
#$ $
'
' %
-$
"!
) %
%
"
$ :
J 2
!%
"
"
) "
$ '!
"
*++D
"
) '
!
!
5!
" !
; @
"
?
%
2
)
7
@
$
!
"
?
"
%!
!
+A
-$
Page 5 of 16
" "
) %
.
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 89 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 46 of 63
Saturday, May 28, 2016
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
)
!
!
$
$ :
$
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 90 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 47 of 63
Saturday, May 28, 2016
."%
"
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 .
. - $.
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 91 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 48 of 63
Saturday, May 28, 2016
$
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.
" $
? %
$
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 92 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 49 of 63
Saturday, May 28, 2016
"%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
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 93 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 50 of 63
Saturday, May 28, 2016
%%
"
"
." 3"
) 7 ++.+++
."
"
" <
";/":
"
9! )$
. ./#
%'
%"! %&#
@ *
)"
%
9! 2 )
%!
&
"
K
!
:
<
+ 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
"
"
!
:
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 94 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 51 of 63
Saturday, May 28, 2016
"
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
&
!
% %
<
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 95 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 52 of 63
Saturday, May 28, 2016
,
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" #"
# !
."
%"
'
/"#
#"& /
' = )**?
# :/ .
"3
./# . # %"!"
#
5 ./# :%/ / $
'
" ";/#/
% &/
/;"
.'#/!/#
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 96 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 53 of 63
Saturday, May 28, 2016
-$
&
!%
*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 .
#$ $
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 97 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 54 of 63
Saturday, May 28, 2016
'
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
)
"
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 98 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 55 of 63
Saturday, May 28, 2016
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 )
$
Advanced Media Group Executive Summary, July 28, 2009 - Copyright 2009
Page 99 of 2301
Stan J. Caterbone LAMBERT CASE FILE
Page 56 of 63
Saturday, May 28, 2016
)
!
!% 5!
"
!
%
8
)"
+
B" !
2 !% )
"
.
.
3.
2
2; ;%
-$
$
$
$
$"
$
$
%,11
/
$
$
$
!%
!%$
!%+
1
2$
!%$
%
$
1
1
$) ! !
$
$
!
"
>
D$
"
&
0
$.
$
1
1%
"
!%
Page 16 of 16
.=
1 of 1
http://newslanc.com/2016/04/24/letter-lnp-remains-a-lily-white-newspaper/
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
Stan J. Caterbone
ADVANCED MEDIA GROUP
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.
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.
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.
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.
In 1985 I was elected Vice President of the Central Pennsylvania Chapter of the International
Association of Financial Planners, and helped build that chapter by increasing membership 3to 4 times.
We had personally retained the nationally acclaimed and nationally syndicated Financial Planner, Ms.
Alexandria Armstrong of Washington D.C.; to host a major fundraiser. More than 150 professionals
attended the dinner event that was held at the Eden Resort & Conference Center. Ms. Armstrong
discussed financial planning and how all of the professions needed to work together in order to be most
effective for their clients. We attracted a wide variety of professionals including; brokers, lawyers,
accountants, realtors, tax specialists, estate planners, bankers, and investment advisors. Today, it has
become evident that financial planning was the way of the future. In 1986 executives approached us
from Blue Ball National Bank to help them develop a Financial Planning department within their bank.
In 1984 I had helped to develop strategic planning for Sandy Weill, former President of Citi Group (the
largest banking entity in the U.S). We were one of several associates asked to help advise on the future
of Financial Planning and how it would impact the brokerage and the investment industry at large. Mr.
Weil was performing due diligence for the merger of American Express and IDS (Investors Diversified
Services). We were at that time a national leader in the company in delivering Fee Based Financial
Planning Services, which was a new concept in the investment community and mainstream investors.
That concept is now widely held by most investment advisers.
Stan J. Caterbone, Pro Se Litigant
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
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:
www.amgglobalentertainmentgroup.com
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
Advanced Media Group
www.amgglobalentertainmentgroup.com
Against All Odds - And Always A Winner
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.
'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
8/8/2016 8:01 AM
'He got off light': Students ponder verdict after Millersville University's fi... http://lancasteronline.com/insider/he-got-off-light-students-ponder-verdic...
2 of 6
8/8/2016 8:01 AM
'He got off light': Students ponder verdict after Millersville University's fi... http://lancasteronline.com/insider/he-got-off-light-students-ponder-verdic...
3 of 6
8/8/2016 8:01 AM
'He got off light': Students ponder verdict after Millersville University's fi... http://lancasteronline.com/insider/he-got-off-light-students-ponder-verdic...
4 of 6
8/8/2016 8:01 AM
'He got off light': Students ponder verdict after Millersville University's fi... http://lancasteronline.com/insider/he-got-off-light-students-ponder-verdic...
5 of 6
8/8/2016 8:01 AM
'He got off light': Students ponder verdict after Millersville University's fi... http://lancasteronline.com/insider/he-got-off-light-students-ponder-verdic...
6 of 6
8/8/2016 8:01 AM
1 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
8/8/2016 7:57 AM
2 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
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
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
8/8/2016 7:57 AM
4 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
8/8/2016 7:57 AM
5 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
8/8/2016 7:57 AM
6 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
8/8/2016 7:57 AM
7 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
8/8/2016 7:57 AM
8 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
8/8/2016 7:57 AM
9 of 9
http://lancasteronline.com/insider/remembering-karlie-hall-student-s-dea...
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:.[)
JAN 1~ 2016
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:
~
i
MCI Framingham
P.O. Box 9007
Framingham, MA 01701
00
Stan J. Caterbone
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
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
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.
http://www.lancasteronline.com/pages/news/local/4/13713
LancasterOnline Keyword
Go
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
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
http://www.lancasteronline.com/pages/news/local/4/13713
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
http://www.lancasteronline.com/pages/news/local/4/13713
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!!!
3 of 3
4/21/2005 8:35 PM
1 of 2
https://us-mg6.mail.yahoo.com/neo/launch?.rand=27j1k00gflnuc#81115...
Subject:
From:
To:
stan.caterbone@yahoo.com;
Date:
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:
EXECUTIVE SUMMARY
copyright 2009
Ya know what, I
difficulty understanding
Extreme Terrorism is to
seems to talk about that
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
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
2 of 2
https://us-mg6.mail.yahoo.com/neo/launch?.rand=27j1k00gflnuc#81115...
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.
Date Completed:
Date Initiated:
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>
Stan J. Caterbone, Pro Se Litigant
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
Stan J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
717-459-7588 Fax
78224
Respectfully,
Stan J. Caterbone
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)
RESULT: (DI) Deception Indicated
R3. Are you being truthful today that you are a victim of US mind control?
ANSWER (YES)
RESULT: (DI) Deception Indicated
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.
P
usps.com
Click-N-Ship
1 lb 0 oz
08/12/15
0006
B100
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
SHIP
TO:
EPIC CARD
PO BOX 245998
USPS TRACKING #
Instructions
USPS TRACKING # :
From:
To:
344928754
08/11/2015
08/12/2015
$5.25
$5.25
08/14/2015
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
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
June 7, 2015
Stanley J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
Stanley J. Caterbone
cc: file
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.
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
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.
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mi...
1 of 11
http://www.globalresearch.ca/PrintArticle.php?articleId=7123
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
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mi...
2 of 11
http://www.globalresearch.ca/PrintArticle.php?articleId=7123
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
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mi...
3 of 11
http://www.globalresearch.ca/PrintArticle.php?articleId=7123
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
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mi...
4 of 11
http://www.globalresearch.ca/PrintArticle.php?articleId=7123
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
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mi...
5 of 11
http://www.globalresearch.ca/PrintArticle.php?articleId=7123
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
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mi...
6 of 11
http://www.globalresearch.ca/PrintArticle.php?articleId=7123
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
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mi...
7 of 11
http://www.globalresearch.ca/PrintArticle.php?articleId=7123
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
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mi...
8 of 11
http://www.globalresearch.ca/PrintArticle.php?articleId=7123
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
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mi...
9 of 11
http://www.globalresearch.ca/PrintArticle.php?articleId=7123
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
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mi...
10 of 11
http://www.globalresearch.ca/PrintArticle.php?articleId=7123
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
On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mi...
11 of 11
http://www.globalresearch.ca/PrintArticle.php?articleId=7123
9/24/2010 9:25 PM
scaterbone@live.com
www.amgglobalentertainmentgroup.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
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
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.
Stanley J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
717-669-2163
scaterbone@live.com
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
Advanced Media Group
www.amgglobalentertainmentgroup.com
Page 1 of 55
Page 1 of 55
05.15.2009
05.18.2009
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
RQID:L~~~~~C646~~~
DOCTYPE:~075
SSN:200460959
SITE:V4~
RF:D CS:7df4
DR:S
20090507500039
SSN: XXX-XX-0959
INSERT THIS PAGE INTO THE W7NDOW ENVELOPE PROVIDED W7TH THE ADDRESS
BELOW SHOWING.
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
dill
11111 1111111111111111111111111111111111111111111
20090507500039
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.
Enclosures:
Adult Function Report
Return Envelope
D2103/mr116
Page 4 of 55
05.18.2009
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.
Page 5 of 55
05.18.2009
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.
Page 6 of 55
05.18.2009
Fonn AIJproved
OMS No. 0960-0681
~~--~----~~
~~==~~~~~
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
I]Ii1OOse
o Shelter
0
0
Apartment
Grcq> Home
o Message Number
"""'
0 WIth Family
YJith Frfends
6. , Describe what you do from the time you wake up until going to bed.
SEe
.fA"e
11
Page 1
Page 7 of 55
Page 7 of 55
05.1~.2Q09
.
!',.
,
.
05.18.2009
Dves
liNO
Dves
rz(No
If "VES," for whom do you care, and what do you do for them?
Dves
..:::::-
a;v;4467Vr/~I'-~
~
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 _________________________________________
------------------------------------
------~-------------------------------
Feed self_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Use the toilet
-------------------------------------~
CXher?________________________________________________
Page 2
Page 8 of 55
05.18.2009
,IZf No
--------------------------------
Dyes
Dyes
E1No
------------------------------~--------
13. MEALS
IfYes
No
If "Yes," what kind of food do you prepare? (For example. sandwiches. frozen dinners, or complete
meals with several courses). ___________________________________________
An&nges
b. H~ much time
A. IJ V E
Ihv ~
lC~
,<1A-t,L./
E,r
{;;n;L
ttl'.(t::-
",,"';l1:t1Jt!.,
,f)0
I~-+t /~.
-------------------------------------~--Page 3
Page 9 of 55
05.18.2009
.~.
-------------------------------
_....:!oo[)~(:.....::i:.....'1:.....t-~~tt:..---------------------------
-----------------------------------
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) _ _ _ _ _ _ _ _ _ _ _ __
.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
N~s
By mail
..... 4 J
() IVL-
- d:=,-Jlkll~
~"- J3As/~
;;'tJ
o By computer
_-=/I;....-.;~;;..."'_~.:.._..___7/~----J,at---f;4-J---~"""./:.....--'r-~--r(.;...;;;:.....----l
17. MONEY
a. Are you able to:
Pay bills
Count change
ONo
DNo
DNo
No;
Page 4
Page 10 of 55
05.18.2009
aYes
No
A~~_~__,_~
___e_r____
,,
....,A-17..
~t/.
J.
/. trt-.t
77 #fA yo
k../i)
~N c-
"-
O~/
9--..+t1 AJC7J
Ves
No
-------------------------------------
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
DVes
------------------------------
Dves
/Sot..
DNo
~tJtA.J
Page 5
Page 11 of 55
05.18.2009
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
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
q Using Hands
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?
--------------------------
,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_______________
Page 6
Page 12 of 55
05.18.2009
1
!
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
(!)~ (P
14;
L To . CZ>
&t~cA- /;z:::~~
iN
v"f1.,C64
dl'-ll'A
~v~
Dves
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
---------------------------------------------------
Page 7
Page 13 of 55
05.18.2009
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.
----------------------------------~----------------------------~
-sr~Le-
Address (Hum
/ :; 57J
City
1'1-4- .
#l1l0?
and Street)
)(e'IIu 4/
f :5-r.
:1~~~
Page 8
Page 14 of 55 _ _ _ __
Page 14 of 55
05.15.2009
05.18.2009
Stanley J. Caterbone
1250 Fremont Street
Lancaster, PA 17603
717-669-2163
scaterbone@live.com
SOCIAL SECURITY ADMINISTRATION
Office of Medical and Vocational Expertise
Post Office Box 17786
Baltimore, Me 21235-7786
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.
Page 15 of 55
Page 15 of 55
05.15.2009
05.18.2009
Stan J. Caterbone
Advanced Media Group
-----~---------
---
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.
Page 16 of 55
Page 16 of 55
05.15.2009
05.18.2009
,;4".
,d"'y
,l)4i:/'A--4. e- ~"" ~
i3~b4'( hH r
,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.
fit /114/ h
,/l.
j7
~~4. A/~
.
,
.
~ t?i~v~/c.A'fl"..J
/.~" w~~.
I. .. '~R7f /.v
~
lAS't!hrt-A ~ 4.lt/~~~ /f,G'7n';""'-; ~rzvt4"~
u ..
Stanley J. Caterbone Case No. 0514869
A4.4-'.t~r;
Page 17 of 55
;-t...
0-
h-;~~/,.(.dVe-
05.18.2009
~'ht.+rCt:.;G3,4L
/. i
tz; "fl.
en I-~
~ ;!,Ac.-/G
t>.
..
;t~.;""~,,, /II,JI!:J'/~/e;-,7
/I"''"L/N7.; .... 1
Ib
~~, .~~/~M'~
"'-MH"'- &.... 4.47-~ .
7.
IV!~(/S ~~~ff
1iA.- !3<Jd/C.
:'t.
Page 18 of 55
Page 18 of 55
'.
05.15.2009
05.18.2009
www.amgglobalentertainmentgroup.com
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
Stanley J. Caterbone
Advanced Media Group
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
Page 1 of2
Page 19 of 55
December 3, 2007
05.18.2009
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
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
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
05.18.2009
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.
By Carole Smith of Global Research
Page 2 of 13
Page 22 of 55
05.18.2009
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).
By Carole Smith of Global Research
Page 3 of 13
Page 23 of 55
05.18.2009
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)
Page 4 of13
Page 24 of 55
October 18.2007
05.18.2009
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
05.18.2009
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
05.18.2009
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.
Page 7 of 13
Page 27 of 55
05.18.2009
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
By Carole Smith of Global Research
Page 8 of13
Page 28 of 55
05.18.2009
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.
Page 9 of 13
Page 29 of 55
05.18.2009
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
By Carole Smith of Global Research
Page 10 of 13
Page 30 of 55
05.18.2009
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
By Carole Smith of Global Research
Page 11 of13
Page 31 of 55
05.18.2009
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
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.
By Carole Smith of Global Research
Page 12 of 13
Page 32 of 55
05.18.2009
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
Page 13 of 13
Page 33 of 55
05.18.2009
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#
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
Page 34 of 55
Page 34 of 55
05.15.2009
05.18.2009
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
Advanced Media Group
Page 2 of9
Page 35 of 55
December 1, 2007
05.18.2009
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:
What follows is a succinct identification and description of the constituent agencies in each of the five
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
Page 30f9
Page 36 of 55
December 1. 2007
05.18.2009
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
Advanced Media Group
Page4of9
Page 37 of 55
Oec:ember 1, 2007
05.18.2009
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
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
Advanced Media Group
Page 5 of9
Page 38 of 55
December 1, 2007
05.18.2009
among
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
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
u) National Aeronautics and Space Administration (NASA) (which operates covert space-defense,
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;
x) Project MIlSTAR (development and deployment of WW III [space war] command, control,
ee) Project Cobra Mist (SOl energy-beam (plasmold?) weapon research); and
dd) Project Cold Witness (SOl weapons-classified), etc.
Page 7 019
Page 40 of 55
December 1, 2007
05.18.2009
f) Bechtel Corporation (CIA's "ditch-digger" for covert projects and off-the-books underground bases);
i) Aerojet (Genstar Corp.):{ makes DSP-l Star Wars battle satellites for the NRO);
I) Northrop Corporation (makes U.S. antigravity craft, back-engineered from Star Visitor technology,
p) BDM Corporation (CIA contractor, involved in UFO back-engineering and psychotronic projects,
etc.);
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,
Advanced Media Group
Page 8 of9
Page 41 of 55
December 1, 2007
05.18.2009
Dr. Richard Boylan is a behavioral scientist, university instructor, certified clinical hypnotherapist, and
Post Office Box 1009, Diamond Springs California 95619, United States of America.
E-mail: drboylan@sbcglobal.net
WEBSITE: htW:/lwww.drboylan.com
You are invited to join his UFOFacts internet reports-and-ET/UFO/Experiencers
Posted by Stewart at
:/;'
;
.
,
'
a(i!i
,-
<'
Y'
nced
edia Group
terbone
www.amgglobalentertainmentgroup.com
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 $1 Billion Fraud In 1992). Unfortunately we are forced to
defend our reputation and the truth without the aid of law enforcement and the media, which would normally prosecute and expose
public corruption. We utilize our communications to thwart further libelous and malidous attacks on our person, our property, and our
business. We continue our fight for justice through the Courts, and some communications are a means of proteCting our rights to
continue our pursuit of justice. Advanced Media Group is also a member of the media. Reply if you wiSh to be removed from our Contact
Ust. Number 7.
Page9of9
Page 42 of 55
Oecember 1. 2007
05.18.2009
amgrouD01@msn.com
www.amgglobalentertainmentgroup.com
Important Matters
I.
For approximately
'have"had th!e ,ability. to <communlcate
telepathically. .1IjaYE!spe
this' abllltythrQ~QhevarloustnfeIUgen~~
agendes dec/ass.
.... rnellts.
,
;g>.rinected2a pers,on (Sheryl
Crowl that Is co
when I am
litigating ciV11.andCfim
mproroised.
I. do notknow'flOwl
wledge ,and or
consent. lneed,:tos
elp in
that isconneGtedtome
subjects me to a brutal.arraYQfmen2
,'V~.betltt'letl1attheyare
being usedasa medlum;1f{)f" this purpose.
yJS$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
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
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
Page 2 of 36
Page 44 of 55
07/1612007
05.18.2009
amaI"QUoOl@msn.a>m
www.amgglobalentertainmentgroup.a>m
PlililL I
I.' '\
Re:
Important Matters
For
telepath1ca
agencies c:lel:ta~;Slfl
Crow) that -Is:
litigating
"
I,donot
Pagel 0'36
Page 45 of 55
Page 45 of 55
0711612007
05.15.2009
05.18.2009
cc:
.1/
Enclosures
Page 4 of 36
Page 46 of 55
0711612007
05.18.2009
amgroup01@msn.com
www.amgglobalentertainmentgroup.com
Lorita O'Leary
Hollywood, CA 90028
Re:
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
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
I am also enclosing my resume, and suggest that you visit my website at:
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
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
1 ABC News 20/20 episodes that investigated and reported on the ISC scandal. I will forward
Page 20 of 36
Page 47 of 55
07/1612007
05.18.2009
cc:
Enclosures
Page 21 of 36
Page 48 of 55
07/1612007
05.18.2009
IIJSIbf. Hotn"
amgroup01@Il1SI1.com
Fram :
Sent:
To :
webmaster-dso@darpa.mil
Subject:
Programs
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
Page 7 of 36
Page 49 of 55
Page 49 of 55
07/1612007
05.15.2009
05.18.2009
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]
THE ADVANCED MEDIA GROUP
Page 22 of 36
Page 50 of 55
07/1612007
05.18.2009
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
Page 23 of 36
Page 51 of 55
(717) 291-8083
forthcoming
07/16/2007
05.18.2009
Name, Phone (All parties below have supported and or fabricated allegations of insanity, and or
psychiatric treatment)
Page 24 of 36
Page 52 of 55
07/1612007
05.18.2009
Give the sequence of the abuse in detail from the beginning to end, providing the dates for all
Date
Occurrence
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
Loss of Patent and intellectual property rights of Financial Management Group, Ltd., and Digital technologies, induding
Page 6 of S
-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
Page 25 of 36
Page 53 of 55
07116/2007
05.18.2009
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
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
1 of 7
http://www.nytimes.com/1997/12/27/us/judging-justice-special-report-fe...
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.
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
http://www.nytimes.com/1997/12/27/us/judging-justice-special-report-fe...
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
http://www.nytimes.com/1997/12/27/us/judging-justice-special-report-fe...
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
http://www.nytimes.com/1997/12/27/us/judging-justice-special-report-fe...
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
http://www.nytimes.com/1997/12/27/us/judging-justice-special-report-fe...
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
http://www.nytimes.com/1997/12/27/us/judging-justice-special-report-fe...
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
http://www.nytimes.com/1997/12/27/us/judging-justice-special-report-fe...
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
Stan J. Caterbone LAMBERT CASE FILE
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...
1 of 1
4/26/2006 7:50 PM
Page 1 of 76
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
CIVIL ACTION
NO.
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 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 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 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 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 :
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)
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 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.
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 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
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).
day
, 1998
Notary Public
Notary Public of :
My commission expires:
Page 8 of 76
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
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
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.
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.
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
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.
Stan Caterbone & Mike Caterbone (Joint Title) settle on the real estate deal, with a $100,000 loan from Parent Federal.
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.
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.
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.,
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
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
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.
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.
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.
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.
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.
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.
The FMG, Ltd., Board of Directors, at the request and advise of Robert Kauffman, vote to approve a loan of $25,000 to
Page
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.
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.,
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.
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
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.
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.
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.
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.
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
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.
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.
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.
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
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.
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.
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.
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.
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 -
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).
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
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.
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.
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:
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 -
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
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.
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.
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.
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
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.
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
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.
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.
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
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.
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.
Attorney Joseph Roda invoices Stan Caterbone $527.00 for the time and services of July 1 & 2, 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.,.
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.
A Philadelphia-based grand jury begins a our year probe into illegal activities surrounding Chem-Con and its
executives, including Guerin.
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
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".
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".
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".
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.
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.
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
19
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.
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
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.
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
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.
September 29, 1987 -
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.
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.
Stan Caterbone survives a near death collision on the New Danville Pike, when a driver ran through a stop sign at the
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.
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.
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.
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.
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.
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
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.
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.
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
24
THE YEAR
1988
January 11, 1988 -
Stan Caterbone receives the transcripts and the original tapes from Secritar-AlI.
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.
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".
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 -
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.
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
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.
McDade refuses the governments request to release records in the Chem Con investigation.
Christian confirms his cooperation into the federal investigations into Chem Con, Guerin, and Wedteck, since his
company's files were subpoenaed in 1987.
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.
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)
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.
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.
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.
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.
-
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.
Guerin secretly plots to move his personal holding company, Parent Industries Inc., to Fort Myers, Fla., near his second
home in
Naples.
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.
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 -
British Labor unions urge Ferranti to drop all ISC-related companies, claiming job loss in Scotland alone could exceed
8,000 workers.
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
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
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
28
THE YEAR
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.
Guerin and Clark appear to settle their dispute, with the escrowed cash to be dispersed on March 30.
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.
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
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.
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.
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
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.
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
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
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.
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.
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.
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.
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::
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:
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.
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
ABC News 20/20 features the story "Weapons Sales to Iraq" about the ISC/Cardoen
how it got to Saddam Hussain.
-
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.
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.
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
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 -
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.
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
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.
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.
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.
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.
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".
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
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
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.
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.
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.
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
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.
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.
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".
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 -
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
38
Stan Caterbone responds by facsimile to Ted Koppel, as to his question concerning the "story line"
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.
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.
Robert Shireman, ISC financial executive pleads his guilt in the ISC $billion fraud and scandal.
Anthony Stagq, ISC executive in charge of Singapore operations, pleads guilty in the Arms Export violations.
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
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.
Stan Caterbone finally requests that his residence be vacated by Michelle and Jason Miller.
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".
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.
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.
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
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
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
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.
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.
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
43
THE YEAR
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.
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
44
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
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
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
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
Southern Regional Police Department
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
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
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.
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
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
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
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
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
53
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
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
Page
55
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
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
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
58
June 2, 2005
Stanley J. Caterbone
220 Stone Hill Road
Conestoga, PA 17516
Commonwealth of Pennsylvania
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
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
60
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
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)
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
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
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,
Stanley J. Caterbone
Convicted killer Lisa Michelle Lambert claims prosecutor believed her '...
1 of 2
http://lancasteronline.com/news/local/convicted-killer-lisa-michelle-lamb...
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...
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
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
_________________________________________________________________
*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
Philadelphia, PA 19103
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
Philadelphia, PA 19103
Richard A. Sprague, Esquire
Alvin B. Lewis, Jr., Esquire
Edward R. Kennett, Esquire
1 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
2 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
3 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
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;
Error not to grant a mistrial when the request for supplemental
discovery of Hazel Show was not granted;
Error not to grant a mistrial when the request for 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. 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
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
5 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
6 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
7 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
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
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
9 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
10 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
11 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
12 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
13 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
14 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
15 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
16 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
17 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
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
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
19 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
20 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
21 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
22 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
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
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
24 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
25 of 26
6/1/2006 3:04 AM
http://vls.law.vill.edu/Locator/3d/Dec1997/97a1764p.txt
Stan J. Caterbone LAMBERT CASE FILE
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
LancasterOnline.com:
News
Lambert sex case back in court Page 387 of 2301
Sunday January
22, :2017
http://local.lancasteronline.com/6/206525
Stan J. Caterbone
LAMBERT CASE FILE
2 of 3
7/6/2007 3:38 PM
LancasterOnline.com:
News
Lambert sex case back in court Page 388 of 2301
Sunday January
22, :2017
http://local.lancasteronline.com/6/206525
Stan J. Caterbone
LAMBERT CASE FILE
3 of 3
7/6/2007 3:38 PM
v.
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
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.
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.
B. Post Verdict Motions
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.
C. State Court Appeals
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).
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.
III. THE POST CONVICTION RELIEF ACT PETITION
A. Procedural History: Motions, Petitions, Conferences, Orders
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
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
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.
a. Constitutional violations: prosecutorial misconduct and Brady
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
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.
b. Ineffective assistance of counsel
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
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).
2. "Finally litigated" and waiver under the PCRA
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).
3. This court's role
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
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
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.
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
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.
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
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.
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.
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
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.
V. STATE COURT AND FEDERAL COURT
A. A Comity of Errors
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
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"),
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.
B. What Does "Actual Innocence" Actually Mean?
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-
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
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.
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
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
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
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.
VII. LISA MICHELLE LAMBERT'S CASE: ISSUES AND DISCUSSION
A. Laurie Show's Dying Declaration
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
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,
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
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
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
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
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.
B. The "29 Questions"
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,
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
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,
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
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,
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.
2. Allegation of gang rape
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
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.
(Commonwealth Exhibit 10 (emphasis in original).)
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
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.
3. Cambridge Springs
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
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.
D. Tabitha Buck's Involvement
1. The scratch on Tabitha Buck's face
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.
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?
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
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
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:
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.
E. Lawrence Yunkin's Involvement
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
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
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
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.
3. Truth-determining process
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
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.
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
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
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.
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.
Commonwealth v. Lambert, July 19, 1994, slip op. at 22-23.
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
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?
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.
(Petitioner's Exhibit 2090.)
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
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.
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
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.
(N.T., Trial at 673.)
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
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
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
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.
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.
(N.T., Trial at 207.)
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.
(N.T., Trial at 208.)
Mr. Shirk cross-examined Mr. Yunkin and Mr. Yunkin confirmed that Ms. Lambert
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
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.
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.
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.
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.
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
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.
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
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
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
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.
N. The Pearl Earring
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 Exhibit 1190.)
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
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
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.
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
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
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
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
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.
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.
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.
T. Brady/Giglio Violations
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.
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
There was no evidence offered at the PCRA hearing on this claim.
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.
43. Failed to disclose that Mr. Yunkin claimed he was not working on
December 20th
There was no evidence offered at the PCRA hearing on this claim.
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.
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.
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.
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.
(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
There was no evidence offered at the PCRA hearing on this claim.
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
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
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
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
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
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
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
There was no evidence offered at the PCRA hearing on this claim.
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
There was no evidence offered at the PCRA hearing on this claim.
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.
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
There was no evidence offered at the PCRA hearing on this claim.
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.
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.
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
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
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.
82. Failed to disclose that Ms. Buck admitted that her hands hurt on the
morning after the murder
See discussion of Brady/Giglio claim 81, supra.
85. Failed to disclose that Hazel Show saw Mr. Yunkin drive away from the
scene in the complex
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,
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
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
See discussion of Brady/Giglio claim 72, supra.
91. Failed to disclose that the rope purported to be found at the crime
scene was 22 feet 5 inches
See discussion of Brady/Giglio claim 72, supra.
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
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
There was no evidence offered at the PCRA hearing on this claim.
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
There was no evidence offered at the PCRA hearing on this claim.
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.
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.
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
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.
IN THE COURT OF COMMON PLEAS
OF LANCASTER COUNTY, PENNSYLVANIA
CRIMINAL
COMMONWEALTH OF : No. 0423 - 1992
PENNSYLVANIA:
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
Peter S. Greenberg, Esquire
Christy H. Fawcett, Esquire
ADDENDUM TO OPINION
Footnotes :
(Return to Table of Contents)
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
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
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
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,
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
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.
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:
At the end of her dramatic testimony. . .Mrs. Show reiterated her belief
that her daughter said, "Michelle did it.". . . We have not the slightest
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.
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.
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
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.
...
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.'
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.
(Petitioner's Exhibit 1661.)
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.
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
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.
Stan J. Caterbone
ADVANCED MEDIA GROUP
Freedom From Covert Harassment &
Surveillance,
Registered in Pennsylvania
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
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.
1 of 2
http://www.dailylocal.com/general-news/20160607/chester-springs-man-...
6/14/2016 2:00 AM
2 of 2
http://www.dailylocal.com/general-news/20160607/chester-springs-man-...
URL: http://www.dailylocal.com/general-news/20160607/chester-springs-man-co-authors-murder-novel
6/14/2016 2:00 AM
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.
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
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.
I Rem ain,
St an J. Cat erbone
Enclosure CD- ROM
2 of 3
http://www.abqtrib.com/news/2007/mar/28/court-tightens-rules-whistle-...
National-World
search abqtrib.com
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 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.
Today's Headlines
Richardson's Quest
LoboZone
TribVid
Events Calendar
Restaurant Guide
Podcasts
Alerts
Comics
Password:
(Forgotten your password?)
Comment:
3/28/2007 8:35 PM
1 of 19
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
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
HOME | HELP
CLASSIFIEDS
Join now!
RENTALS
SHOPPING
search
i
j
k
l
m
n
Site
j
k
l
m
n
Web
Go
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)
6/4/2005 9:58 AM
2 of 19
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
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
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
6/4/2005 9:58 AM
4 of 19
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
6/4/2005 9:58 AM
5 of 19
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
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
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
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
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
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
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
"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
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
"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
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
6/4/2005 9:58 AM
11 of 19
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
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
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
"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
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
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
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
"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
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
6/4/2005 9:58 AM
16 of 19
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
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
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
6/4/2005 9:58 AM
18 of 19
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
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
http://pqasb.pqarchiver.com/latimes/22547542.html?MAC=2e836ead823c7c1440fb92de137c...
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
1 of 1
http://www.azcentral.com/news/articles/0328Scotus-WhistleBlower0328...
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
(Slip Opinion)
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.
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
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-
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.
No. 051272
_________________
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
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
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).
10
11
12
5 The
13
14
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,
16
6 It
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
18
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.
20
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.
No. 051272
_________________
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
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 1
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 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 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 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 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
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.
Page 1 of 2
April 7, 1998
Letter to Matt Samley of Xakellis Reese & Pugh re ISC Opinion and Invoice
I remain,
Stan J. Caterbone
cc: Samleyfile
Page 2 of 2
April 7, 1998
P
usps.com
Click-N-Ship
1 lb 0 oz
07/25/15
0006
C000
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
SIGNATURE REQUIRED
SHIP
WATERBURY VT 05671-9800
Instructions
1. Each Click-N-Ship label is unique. Labels are to be
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.
343261455
07/25/2015
07/25/2015
07/28/2015
$50.00
$5.05
$0.00
$2.45
$7.50
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
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.
Thank you for shipping with the United States Postal Service!
Check the status of your shipment on the USPS Tracking page at usps.com
TAKEN BY:
BEFORE:
DATE:
PLACE:
APPEARANCES:
MARSHALL, DENNEHEY, WARNER, COLEMAN & GOGGIN
BY: CHRISTOPHER M. REESER, ESQUIRE
FOR - ALLSTATE INSURANCE COMPANY
Page 1 of 51
June 9, 2016
WITNESSES
NAME
STANLEY J. CATERBONE
EXAMINATION
5
6
7
8
9
10
11
12
EXHIBITS
13
14
CATERBONE EXHIBIT
15
1.
LIST OF ITEMS
13
16
17
18
19
20
21
22
23
24
25
Page 2 of 51
June 9, 2016
1
2
3
4
EXAMINATION
BY MR. REESER:
Stan.
Stan, okay.
10
You can
call me Chris.
11
All right.
12
13
14
15
16
17
18
19
No.
spreadsheet --
20
Okay.
21
22
All right.
23
24
25
Page 3 of 51
June 9, 2016
Okay.
I've had --
Go ahead.
Go ahead.
policies with the same types of claims, and I've never been
10
Okay.
11
-- on the record.
12
So noted.
13
Okay.
14
15
16
All right.
17
18
All right.
19
20
Okay.
22
Sure.
23
21
24
25
Well --
This
is --
Page 4 of 51
June 9, 2016
1
2
Okay.
Great.
Okay.
the claim.
claim.
Okay.
So --
10
11
Go.
12
-- to put it in perspective?
13
Yeah.
14
I am a federal whistleblower.
Go.
I blew the whistle
15
16
17
18
1987 they --
19
I'm sorry.
20
Yes.
21
operations.
22
Okay.
23
They were
24
courts, hired various attorneys from '87 all the way up.
25
Page 5 of 51
June 9, 2016
litigant.
Okay.
Okay.
I became a
control technologies.
around.
10
11
period of time.
Now, these
12
Okay.
13
14
15
16
ordinary claim.
17
18
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
23
whistleblower?
24
25
A
that.
It could
Page 6 of 51
June 9, 2016
Okay.
Okay.
10
11
All right.
12
Harleysville
13
14
15
These are all the reports from the past year on Geek Squad
16
17
But
18
Okay.
19
20
21
22
23
24
Okay.
25
Page 7 of 51
June 9, 2016
Locally?
No.
No.
No.
Okay.
10
11
12
Complaints --
13
Okay.
14
15
16
harassment.
17
Okay.
18
19
20
21
22
23
24
25
Page 8 of 51
Now,
June 9, 2016
describing.
Okay.
10
11
12
13
14
15
They were
16
17
I don't know.
18
door.
19
20
I'm trying
to understand this.
21
Okay.
22
23
24
25
pain.
Page 9 of 51
June 9, 2016
10
Okay.
officer.
The second is
10
11
Administration.
12
read them.
You can
13
Okay.
14
15
16
No.
17
Okay.
18
19
20
21
22
23
24
Okay.
25
Page 10 of 51
June 9, 2016
11
How --
Okay.
7
8
9
10
awaiting decisions.
Q
Superior Court?
11
12
Okay.
13
They dismissed it --
14
Okay.
15
16
Oral
17
Okay.
18
Both cases
19
20
21
before them.
22
23
Okay.
24
No.
25
Okay.
Page 11 of 51
June 9, 2016
12
Yes.
Okay.
he is?
Are you
documented, verified.
10
Huh.
11
12
Okay.
13
for that?
Is it --
14
15
I have.
16
Yeah.
17
Okay.
18
19
applied in '09.
20
21
22
23
24
25
Okay.
bit.
Page 12 of 51
June 9, 2016
13
Okay.
Okay.
Yeah.
No.
Okay.
Here.
That's updated.
MR. REESER:
13
1.)
14
BY MR. REESER:
16
Okay.
on there?
12
15
missing.
10
11
All right.
17
Yeah.
18
19
You're
20
Right.
21
22
23
24
25
Page 13 of 51
June 9, 2016
Yes.
All right.
14
Freemont Street.
Yes.
Okay.
No.
All right.
10
11
claim.
12
13
number of grantees.
14
My brothers.
15
Okay.
16
No.
17
18
policy?
19
20
Okay.
21
Yeah.
22
Okay.
23
24
No.
25
Okay.
Page 14 of 51
June 9, 2016
Right.
Okay.
15
a 302 petition, but what they did was they broke into my
to pay for all the locks and the door, but they didn't.
8
9
10
11
Okay.
12
13
All right.
14
15
do.
302 petition?
16
What do they --
17
18
19
20
Okay.
21
22
23
to pin on you?
24
Oh, yeah.
25
What?
Page 15 of 51
June 9, 2016
16
4
5
6
What year?
name it.
Q
Okay.
institutionalized --
Oh, yeah.
one in July?
10
11
12
13
14
15
Then they
16
Okay.
17
It started
18
in '87.
19
20
21
22
studios.
23
24
25
Page 16 of 51
But in 1987 I
I rented a home
June 9, 2016
17
Okay.
Okay.
I stood
10
11
Part of?
12
Where
13
are they?
14
15
pages.
16
17
18
19
This one.
No.
These
20
Okay.
21
22
in '08.
23
24
25
Page 17 of 51
June 9, 2016
18
I want.
Okay.
5
6
Yeah.
10
11
Yeah.
12
Okay.
13
Yeah, I do.
14
it store.
15
16
17
18
19
No.
20
21
For Humanity.
22
Habitat?
23
24
25
Page 18 of 51
June 9, 2016
19
Reuse it.
Greenfield.
Yeah.
8
9
10
11
12
13
14
15
16
I see.
17
18
Okay.
19
20
21
22
23
$20.
24
$20?
25
Yes.
Each
I apologize if I
Page 19 of 51
June 9, 2016
20
Yeah.
Wizard.
Wizard.
Locks.
Yeah.
Yeah.
10
11
circumstances --
12
13
14
15
complaints.
16
to sue them.
17
Okay.
18
19
20
21
investigate or...
22
23
24
25
Page 20 of 51
June 9, 2016
21
No.
Okay.
5
6
Right.
'05 or '06.
Okay.
10
11
All right.
12
13
Yeah.
14
15
16
Okay.
17
18
Okay.
19
20
were expensive.
21
Yeah.
22
No.
23
-- just an iPod?
24
25
Page 21 of 51
This was --
June 9, 2016
1
2
22
button.
Okay.
Oh, boy.
fall of '15.
Okay.
No.
10
Why not?
11
Why?
12
14
15
Okay.
16
I bought a replacement.
17
Okay.
13
18
19
20
21
22
23
No.
No.
I --
I mean --
24
25
questions.
Page 22 of 51
June 9, 2016
1
2
23
Okay.
All right.
It's funny.
11
Okay.
12
Right.
13
How old --
14
15
16
Oh, yeah.
17
Okay.
18
I don't remember.
19
20
21
I'm just
10
or four stolen.
Q
Okay.
When?
In the past year.
I had three
22
Oh, no.
23
Oh, okay.
24
25
No, it doesn't.
No.
Well, no.
Page 23 of 51
June 9, 2016
not a quantity.
24
that.
be three.
No.
Let me see
That should
All right.
Shack.
10
11
really not.
12
is harassment.
13
14
I'm
15
16
Okay.
17
18
19
Okay.
20
I document everything.
21
I'm an expert in
information technologies.
22
23
24
25
Page 24 of 51
I was one
June 9, 2016
25
business.
were stolen?
Yeah.
10
basement.
Okay.
I know my
Yeah.
11
12
13
about that.
14
15
about these --
16
17
Okay.
18
19
20
21
official report.
22
All right.
23
24
25
Page 25 of 51
June 9, 2016
26
Okay.
All right.
After what?
Let me think.
Okay.
10
11
12
Yeah.
Yeah.
took them?
A
everybody.
13
Okay.
14
Yes.
15
16
17
it worked.
18
buy a replacement.
One day
19
20
21
22
23
24
No.
25
Page 26 of 51
Maybe '08.
June 9, 2016
Yeah.
All right.
27
if it could be fixed?
No.
How much?
How much.
Oh, boy.
9
10
I probably paid -- I
11
Okay.
12
-- on eBay.
13
14
Yeah.
15
16
17
18
of it?
19
Harbor Freight?
20
Harbor Freight.
21
drill.
22
Okay.
24
What is it?
25
Maybe 100?
23
Harbor Tools.
so --
Page 27 of 51
June 9, 2016
28
Maybe.
Okay.
Reciprocating saw.
Yeah.
It just --
sawing.
Okay.
10
11
12
13
It used to
replacement one?
14
The replacement.
15
16
Harbor Tools.
17
Harbor Freight?
18
Harbor Freight.
19
Okay.
20
23
24
25
When did
21
22
A
'06.
'05.
Q
Oh, boy.
Let's see.
'05, '06.
Okay.
Page 28 of 51
June 9, 2016
No.
Okay.
No.
No.
No.
No.
29
No.
8
9
10
11
12
two-week span.
Q
Yeah.
college.
13
All right.
14
15
16
assuming --
17
Right.
18
19
20
21
22
I mean, I'm
a do-it-yourselfer.
Q
Well, no.
23
Oh, I do.
24
-- don't.
25
I do.
Page 29 of 51
June 9, 2016
1
2
Okay.
30
I'm
trying to understand.
I do.
I don't.
Okay.
No.
10
I use my tools.
11
12
I use my stuff.
13
Fair enough.
I understand.
14
15
16
Uh-huh.
17
18
Yeah.
19
Okay.
20
that up?
21
No.
22
Okay.
23
24
25
No.
I'm not
Okay.
Page 30 of 51
June 9, 2016
31
Broken.
When?
of last year.
Okay.
So I put it on eBay.
10
11
12
electronic funds.
13
the money.
Right.
Right.
14
15
What's that?
16
Or a PayPal account.
17
PayPal account.
18
Okay.
19
20
21
22
account.
23
Uh-huh.
24
25
Page 31 of 51
Right.
Now, in my
June 9, 2016
32
judgment.
So eBay
Uh-huh.
Okay.
10
11
12
Right.
My PACER account
13
14
15
So
16
Okay.
17
18
19
20
my cases.
Q
Let me go back.
at some point.
21
Okay.
22
23
phone?
24
25
Page 32 of 51
June 9, 2016
you?
33
Okay.
So I replaced it.
of Apple.
I got out
How old --
service about it, and they had harassed me, and I had to
10
11
Radio Shack, and under Sprint's program they would pay your
12
13
have a Samsung.
14
15
So I went to
How old was the phone at the time that you tried
16
17
Okay.
18
19
20
21
22
or --
23
24
25
Okay.
Page 33 of 51
June 9, 2016
34
Yeah.
I can't buy
Okay.
Okay.
10
11
12
13
What happen?
14
15
I think January.
16
Of this year?
17
Yes, '16.
18
19
I think January.
General's Office or --
20
Oh.
21
22
23
Okay.
24
25
Page 34 of 51
June 9, 2016
35
everything to me.
Okay.
Service me everything.
8
9
A
the NSA.
Okay.
I mean, if
10
11
He said
12
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.
17
Uh-huh.
18
Okay.
19
information on file.
20
21
22
Office.
23
Okay.
24
25
Page 35 of 51
June 9, 2016
36
Uh-huh.
They'd work.
Oh, yeah.
Yes.
Well, supposedly.
10
didn't work.
11
Okay.
12
Lowe's.
13
14
Yeah.
15
Yes.
16
17
Okay.
18
19
I'm sorry.
Foam
memory mattress.
A
On the record,
20
21
say '98 I've been going to the doctors on and off for it.
22
23
24
25
Page 36 of 51
Since I'd
So I got a
June 9, 2016
37
Okay.
excruciating pain.
6
7
Yes.
10
Thank you.
11
12
13
Okay.
14
15
magnets.
16
17
All right.
18
19
21
No.
22
All right.
24
25
You ask
the questions.
20
23
So
the mattress?
A
No.
Page 37 of 51
June 9, 2016
Other nights...
3
4
Okay.
38
No.
10
11
12
chiropractor.
A
being effective.
13
Okay.
14
15
to Medicare.
16
house.
17
medicines.
18
19
Okay.
And pain
20
21
22
there.
23
24
25
If not,
Page 38 of 51
June 9, 2016
39
MR. REESER:
THE WITNESS:
with me.
BY MR. REESER:
Okay.
If I know what?
10
11
12
13
That's fine.
14
15
I can't.
I went to -- okay.
16
17
18
19
March 23rd
May 10th
20
21
22
It gets severe.
I have to use
23
24
25
Family Health
Clinic.
Page 39 of 51
June 9, 2016
1
2
3
4
40
That's a medical
doctor?
A
Okay.
treatments.
the NFL.
10
11
12
13
14
15
Okay.
16
17
I put it on there?
18
19
20
Okay.
21
Oh, yeah.
22
a -- it vibrates.
23
24
25
Full.
Page 40 of 51
June 9, 2016
41
Perfectly normal.
Yeah.
All right.
Yeah.
10
Okay.
11
12
13
14
it?
Laptop computers.
15
16
Let me see.
17
How
aren't in there.
18
Yeah.
19
Let me see.
20
21
be right.
Two.
22
Okay.
23
24
right.
25
That's about
Page 41 of 51
June 9, 2016
HP.
42
Oh, boy.
usually.
6
7
Compaq.
Viruses
Oh, yeah.
10
Yeah.
It's not --
11
12
13
an old processor.
14
15
sometimes --
16
No, I -- I understand.
The economics of it
17
18
Squad.
19
The laptops --
20
21
Okay.
22
23
Oh, no.
24
Okay.
25
No.
Page 42 of 51
June 9, 2016
43
Maybe 2012.
2013.
8
9
Compaq, '15.
No.
11
-- last month?
12
No.
13
it in bulk.
14
litigation.
15
16
document.
18
Okay.
I do
19
Right.
20
21
Maybe
10
17
The
computers?
22
Yeah.
23
The --
24
25
Page 43 of 51
June 9, 2016
44
We talked
about the HP and the Compaq, and then you said you bought a
by --
A Lenovo.
Right.
Denovo?
Lenovo.
10
Lenovo?
11
L-e-n-o-v-o.
12
13
14
have repaired?
A
Yeah.
Yeah, I had it
15
16
17
18
19
He had a computer
20
21
22
23
No.
24
Yeah.
25
Let me see.
He just
I think he moved
Page 44 of 51
June 9, 2016
45
hacking.
years.
Okay.
A Plus on Columbia
Avenue.
the detective.
Okay.
I met with
10
11
He
You're
12
Okay.
13
He never -- I guess
14
15
16
17
18
19
Yes.
20
21
Three or four.
22
23
24
Okay.
25
repairs?
Page 45 of 51
June 9, 2016
I'm sorry?
Okay.
No.
Why not?
Oh, sure.
10
11
12
items.
13
14
15
Okay.
16
17
46
And I take it
18
19
Great.
20
21
No, I can't.
22
23
24
25
Let me see.
Page 46 of 51
June 9, 2016
47
Okay.
That's $160.
5
6
Here's one.
technical people.
Okay.
A Plus.
Okay.
Here's A Plus.
10
receipt.
11
Avenue.
12
13
computer.
14
Let's see.
Here's
Okay.
That's on Columbia
I want to put
15
16
17
19
Sure.
20
21
items?
22
23
18
24
25
that?
Sure.
Do you have
I don't know.
Page 47 of 51
June 9, 2016
piece of paper.
A
48
Let's see.
Let me go
Here's a receipt.
This is a Verizon.
10
11
12
Okay.
13
I believe.
14
Geek Squad.
No,
concerned.
15
16
17
18
I don't know.
19
Okay.
20
I don't know.
21
22
23
24
25
Page 48 of 51
June 9, 2016
49
Okay.
I got people
BY MR. REESER:
Okay.
them back?
10
11
Sure.
12
13
continue it or not.
14
15
A
fine.
Okay.
16
Okay.
17
18
19
20
Yeah, that'd be
21
Why?
22
23
24
25
office?
Q
Okay.
Page 49 of 51
June 9, 2016
Or we can do it at my house.
It's nice.
50
All right.
Okay.
Roughly an hour.
started.
10
11
12
Yeah.
13
MR. REESER:
14
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
COUNTY OF DAUPHIN
51
2
3
: SS
COMMONWEALTH OF PENNSYLVANIA
8
9
10
11
12
13
14
15
16
17
18
19
20
21
said witness.
22
23
24
_______________________
Diane F. Foltz, RMR
Notary Public
25
Page 51 of 51
June 9, 2016
Stan J. Caterbone
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
stancaterbone@gmail.com
______________________________________
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
Page 1 of 183
173
Stan J. Caterbone
ADVANCED MEDIA GROUP
__________________________________
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
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
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.
Page 4 of 183
173
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
Mind Control Transcripts
Page 5 of 183
173
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.
Mind Control Transcripts
Page 6 of 183
173
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?
Mind Control Transcripts
Page 7 of 183
173
Speakers are Amy Anderson, Jesse Beltrand, Dr. John Hall, Dr. Edward Spencer, Ben
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
Mr. Mayor, City Council, thank you. Thank you for attacking this very difficult problem. And
Page 9 of 183
173
Page 10 of 183
173
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
Mind Control Transcripts
Page 11 of 183
173
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,
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
Mind Control Transcripts
Page 12 of 183
173
Page 13 of 183
173
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
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 grand- children. 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:
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
Mind Control Transcripts
Page 15 of 183
173
Page 16 of 183
173
Page 17 of 183
173
Page 18 of 183
173
1 of 1
http://richmondstandard.com/2015/05/richmond-council-passes-resolutio...
More
Page 19 of 183
173
1 of 1
http://www.eastbaytimes.com/portlet/article/html/fragments/print_article....
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
Stan J. Caterbone
ADVANCED MEDIA GROUPFreedom From
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.
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
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.
Page 22 of 183
173
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
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
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
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
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
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.
Page 28 of 183
173
Karen Stewart: In my career, promotions were always hard to come by, meted out perhaps every
Mind Control Transcripts
Page 29 of 183
173
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.
Page 30 of 183
173
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
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
1NSA Whistleblower Comes Out of the Shadows Into the Light Karen Stewarty
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
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
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
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
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
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
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
StanJ. Caterbone
ADVANCED MEDIA GROUP
Freedom From Covert Harassment &
Surveillance,
Registered in Pennsylvania
1250Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
stancaterbone@gmail.com
717-669-2163
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
(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
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
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
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
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
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
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
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
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
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
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
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
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
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 53 of 183
173
1
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
2
3
Mind Control:
4
5
DR. BEGICH:
here and thank you to Peter and the rest of the team for
8
9
In the back?
Good.
10
All right.
11
12
13
14
For
15
16
17
18
19
20
Congress.
21
22
23
24
25
Page 54 of 183
173
He was
He had a
2
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
At
DC.
10
11
planes disappeared.
12
13
second term.
14
15
office.
16
moved up again.
17
18
And then one of the old Manson women from the Charles
19
20
21
Ford
22
23
24
25
Nixon
Page 55 of 183
173
3
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
happened there.
in Washington, DC.
10
it seems like.
11
12
13
14
15
at a crash site.
16
17
18
19
20
there were.
21
Conspiracies are
22
23
24
25
Page 56 of 183
173
4
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
happen.
revealed.
do it with fear.
years.
10
I don't
In fact, that
11
12
HAARP?
13
Okay.
14
to be.
15
16
17
All right.
18
19
20
21
22
presentation.
23
24
subject.
25
I don't
Page 57 of 183
173
5
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
They're
antennas.
small space.
shine that against the wall, the beam starts out small,
10
11
source.
12
13
14
15
16
17
18
They have
19
20
21
energy.
22
23
24
25
Page 58 of 183
173
6
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
application.
9
10
And so
11
12
13
efficient.
14
15
16
17
18
19
into space.
20
If you
21
22
they would come from the earth, they'd bounce off of us,
23
24
large distances.
25
Page 59 of 183
173
7
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
8
9
10
11
12
13
politically engaged.
14
15
16
17
18
19
And when you think about big projects, you know, you
20
21
22
23
24
25
And I did.
Page 60 of 183
173
I picked up maybe
8
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
back in 1994.
10
These are
11
12
13
14
15
16
17
18
energy.
19
20
21
22
23
effect.
24
25
Page 61 of 183
173
9
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
around it.
10
11
12
13
14
shield.
15
And as a
16
17
18
19
20
21
22
23
24
25
these that are not so relevant -- was the idea that you
Page 62 of 183
173
10
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
a better example.
ringing a bell.
10
11
12
13
14
15
16
17
18
19
20
underground structures.
21
They're
22
23
24
following response.
25
Because ELF
Page 63 of 183
173
11
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
You can use flickering light, you can use binaural beat,
signal that the human body will join with, will couple
10
11
12
effect.
13
14
15
16
We heard that
It's
17
18
Brzezinski.
19
20
Columbia University.
21
22
23
24
25
Page 64 of 183
173
This is around
12
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
blueprint, in fact.
It's the
convoluted style.
English to understand.
10
accuracy.
11
prediction.
12
13
14
15
control technology.
16
17
geophysicist at UCL.
18
19
20
21
22
23
24
25
Page 65 of 183
173
13
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
But we
But
10
11
12
13
You
And I'll
14
15
16
17
Society".
18
19
20
21
Toward a Psychocivilized
Those
They had
22
23
24
25
graduated in 1950.
He
Electrophysiology, as a degree
Page 66 of 183
173
14
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
10
11
12
13
14
15
16
17
18
19
And then he
20
21
22
23
24
25
Page 67 of 183
173
Was it a quintillion?
15
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
earlier.
discover?
10
kind of activity.
11
12
13
on a radio.
14
15
16
17
18
19
20
21
22
Whether
23
24
25
Page 68 of 183
173
25,000 sources, I
16
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
25,000 sources
body.
A lot of
10
11
science.
12
13
14
body.
15
16
our medicine.
17
18
19
20
21
22
23
But
24
25
Page 69 of 183
173
17
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
incurable.
10
11
12
13
14
15
16
17
18
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
22
23
24
25
Page 70 of 183
173
You could
18
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
By
lot about, sort of, the conclusions and there are things
10
11
12
13
And
14
15
16
17
18
19
20
21
22
23
That's
24
25
Page 71 of 183
173
19
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
tertiary sources.
surplus book room, and I'm telling this guy that I know,
10
11
12
13
This is
14
15
16
17
18
19
20
21
changed.
22
The LSD
23
24
25
Page 72 of 183
173
20
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
All
10
11
12
13
14
15
torture them.
16
17
18
19
criminals.
20
21
It's a government of
22
23
24
iceberg.
25
Page 73 of 183
173
21
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
8
9
It was prepared by
And it was talking
10
11
12
modification in animals.
13
14
category.
15
happening in 1984.
16
17
fields.
18
19
20
21
22
23
24
25
A lot of money
It was a
Page 74 of 183
173
22
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
it remotely.
Mind control.
Yeah, 2002.
"The Economist".
Cover story.
Some of
10
11
12
13
credible publication.
14
story.
15
16
17
18
document.
19
human experiments.
20
21
22
23
approve them.
24
25
I'll
You know,
Page 75 of 183
173
23
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
Naval Intelligence
beings.
"Technology Horizons".
issue.
10
controlled effects.
11
The first
12
13
14
15
operate.
16
17
18
19
20
that you can disrupt the software, then you disrupt the
21
22
23
human operator.
24
25
Page 76 of 183
173
24
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
What does
the norm?
from warfare.
10
11
12
13
14
15
16
17
18
19
Some people
Wars need to be
20
21
22
23
gone.
24
publication.
25
Page 77 of 183
173
25
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
military affairs.
And this
10
11
12
13
14
15
Or conversely,
16
17
18
considered dangerous.
19
example.
20
21
22
get sick.
23
You'll
24
25
Page 78 of 183
173
26
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
poisoning.
not there.
Mystery illness.
10
simple way.
11
12
13
14
publication.
15
the -- I believe it was the Fall 1998, but you can look
16
17
18
19
20
technology today.
21
22
23
"Parameters".
There was an
It's
24
25
Page 79 of 183
173
27
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
of the population.
of different ways.
It was called
"Undercurrents".
participate in.
10
mind control.
11
12
13
14
15
16
they did in the White House, but they could talk about
17
18
19
was the idea that you could -- you could create, sort
20
21
signal.
22
cake.
23
24
of Europe as well.
25
Page 80 of 183
173
28
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
broadcast this.
15-year-old technology.
10
And DARPA
11
Tony Tether
12
13
14
15
16
telepathy.
17
18
19
20
21
22
23
24
25
Okay.
Electronic
Page 81 of 183
173
29
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
area.
10
11
12
the other.
13
They
14
15
16
work for DARPA at the time and we had talked about him
17
18
19
20
21
22
23
24
25
Page 82 of 183
173
And
30
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
family.
So a very wealthy
10
11
kinds of technologies.
12
13
14
All of us
15
have it.
16
do today.
17
18
been wrong.
19
about it.
20
21
22
23
24
25
Page 83 of 183
173
And
31
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
provided it.
bought my books.
I mean, the
10
11
12
out my work.
13
book.
14
15
two and a half million dollars and I spent that two and
16
17
I published my
18
A VOICE:
19
(Applause.)
20
DR. BEGICH:
Thank you.
21
educate.
22
23
24
25
Page 84 of 183
173
Okay.
And the
32
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
an hour.
on your board.
10
I said, okay.
11
12
13
14
(Applause.)
15
DR. BEGICH:
16
17
18
19
20
diligence again.
21
23
me a number of ways.
24
Do your due
22
25
Go research
It's
Page 85 of 183
173
33
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
situation economically.
children at home.
foundation.
10
11
12
13
14
15
I want
And I want
We decided that I
16
could do this.
17
18
19
public.
20
21
22
And it was to
23
24
25
Page 86 of 183
173
He was well
34
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
10
11
12
13
14
A&M.
15
16
17
18
19
20
21
22
23
24
25
Okay.
Garth
He taught over a
Page 87 of 183
173
He formed a
35
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
difficult circumstances.
conference.
And he was
Makayla.
applications of lasers.
Quite brilliant.
10
She's an electrophysiologist.
She serves on
She's an electrophysiologist.
We invited her.
11
12
passed.
13
physicist, biologist.
14
15
16
17
18
19
20
21
22
23
24
25
Okay.
Does anyone
A few.
Rosalie's
But she
Page 88 of 183
173
36
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
platform.
Kaivarainen.
He was
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Page 89 of 183
173
And what
So he was invited to
We
37
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
not even use these things, but I think people feel more
And I jump
I used to
10
11
12
13
14
15
16
17
18
19
the cranium they will cancel each other out and leave a
20
21
15,000, 15,007.
22
23
24
drives to.
25
Within
Page 90 of 183
173
38
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
8
9
This is
10
11
12
13
14
15
16
17
18
19
20
21
of your dreams.
22
23
24
25
that.
Page 91 of 183
173
39
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
supposed to work.
of ours.
You know, I
10
11
12
13
radio engineer.
14
15
16
17
18
19
He
So he
20
21
series.
22
binaural beat.
23
24
25
He developed a whole
Page 92 of 183
173
40
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
the comparison.
8
9
He developed a
10
11
12
13
14
15
16
17
18
over the course of many, many, many, many years, and now
19
20
21
22
23
24
25
A whole array of
Page 93 of 183
173
41
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
little energy.
So very
10
11
12
states.
13
14
15
somebody else.
16
This is
17
18
19
20
21
22
23
24
25
Page 94 of 183
173
42
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
match.
10
11
channels.
12
13
14
15
16
17
18
years.
19
20
21
22
23
24
25
Page 95 of 183
173
43
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
other people over here and ten other groups over there
10
Now, the US
You know,
Okay.
very expensive.
11
12
13
14
method.
15
16
connect.
17
18
19
20
21
22
23
24
25
dangerous.
Page 96 of 183
173
44
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
manipulate it.
They did
10
11
scalars.
12
13
It's always
14
15
they have a very quick rise time and a very fast drop.
16
17
18
19
20
21
carrier.
22
Those
23
first Bush War, and you remember how the Iraqi Army just
24
25
Page 97 of 183
173
45
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
United States.
10
and prayers.
11
12
Unbeknownst
13
14
15
16
And
17
18
19
20
21
22
23
24
25
Page 98 of 183
173
46
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
10
11
12
13
Yet, men
14
15
consciousness?
16
17
18
states of consciousness.
19
20
21
22
23
24
25
Page 99 of 183
173
47
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
scattered in patterns.
rhythmic patterns.
love and they -- you know the saying, and I looked into
10
11
way.
12
long enough.
13
synchronize.
14
15
16
17
18
television.
19
20
uncomfortable.
21
Now, we heard
22
someone talk about the 6:00 news and how that kind of
23
works.
24
25
already fatigued.
Most
They're
48
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
right?
Nobody's listening.
No one's hearing.
Because
If you
10
11
12
the advertising.
13
14
15
16
advertising?
17
18
19
That's why
20
21
22
23
24
that agitation.
25
49
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
not right.
Unease.
that way.
10
11
12
13
14
15
16
17
18
19
inform.
20
Very
21
22
23
public.
24
25
neutral news.
come on.
50
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
what doesn't.
the news?
up.
10
Occasionally.
11
12
13
14
15
alluded to.
16
17
It had 144
18
19
20
21
22
23
has advanced.
24
25
51
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
Wow.
increased.
10
11
computer.
12
13
14
15
16
could do in a second.
17
18
19
20
21
22
there.
23
What will
24
25
as a concept.
52
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
right?
10
11
12
13
14
15
But everyone
16
17
18
19
It has nothing
20
21
22
that resolution.
23
24
25
hours.
We
53
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
point.
And over time that flaw will amplify to where it's big
flaws.
The Internet.
10
11
12
13
14
15
16
17
PBS, our
It doesn't
18
19
20
21
22
23
I
Our
You
24
25
54
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
on was the idea -- and this was Rosalie Bertell, the nun
and physicist, and she said that the next leap is going
8
9
10
11
12
13
14
15
not possible.
Do
It's physiologically
16
17
18
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
22
ago.
23
24
25
changed.
Nothing's
55
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
10
11
other people.
12
13
14
15
16
17
18
sense.
19
And I heard it
20
21
22
of research.
23
24
25
Some of you
56
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
source.
less.
10
privacy issues.
11
12
13
2000, and you'll see the same things, because the old
14
15
16
17
18
19
20
21
Parliament.
22
23
in this.
24
25
A gentleman by the
So we had a conversation.
Somebody had
And at my expense,
57
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
look at.
8
9
10
11
12
13
14
in the US.
15
16
17
invitation to come.
18
In the European
You
19
20
21
22
23
24
25
58
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
to follow along.
10
11
12
session.
13
We
14
day.
15
16
17
18
19
20
21
22
23
there.
24
25
And then I
59
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
of these things.
seizures.
a problem, right?
Some say
10
11
12
13
fresh.
14
It was
15
16
17
18
19
20
21
22
23
24
25
60
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
hear this voice in their head and nobody else would hear
it.
them up.
10
11
12
13
14
15
16
right?
17
18
demonstration.
19
Now,
20
21
22
23
24
25
61
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
machine, L-i-d-a.
kinds of areas.
War.
10
11
12
13
14
1960s.
15
16
17
18
19
20
21
22
23
24
25
62
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
that risk.
Nobody does.
Because insurance
that.
It's as simple as
10
11
harmful.
12
13
all of a sudden.
14
15
16
a powerful adversary.
17
18
19
controversy.
20
21
22
study.
23
Brain cancer.
Big
Congress
24
25
All right.
He issues his
63
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
report.
himself.
5
6
You know,
He got to spend
A VOICE:
DR. BEGICH:
A VOICE:
10
George Carlo.
Which one is it?
George Carlo.
DR. BEGICH:
And
11
12
book.
13
14
15
damage to skulls.
16
17
18
19
Ten-year-old,
20
21
22
efficient with the battery and the energy with even more
23
leakage.
24
25
it.
They're almost
64
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
impossible to find.
one day.
radiation has been the cause and the root to most of the
10
11
12
13
14
15
and then you add this on top of it, and now you have a
16
17
18
downloading of that.
19
achieve?
20
Blap.
21
22
23
kind of education.
24
programming.
25
thinking involved.
There's your 12
Just
No critical
Curriculum
65
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
risk.
This is the
What does
10
11
12
13
14
15
16
17
that?
18
There
Because
19
20
21
federal employees.
22
23
24
25
For what?
66
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
right?
want people that are smart enough to look good, but not
10
11
12
political outcomes.
13
14
voting.
15
Some people
16
17
18
19
they're informed.
20
So
21
22
social programs you've got running and you say, you will
23
24
25
them.
Whoever can
The moment they walk into the booth, they go, ah,
67
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
claim internally.
Because you
Everybody
10
11
12
13
14
15
16
wouldn't it?
17
I mean, if
18
19
20
21
22
23
confidence.
24
25
It
68
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
right and true and you step into it on the idea that you
are doing good work otherwise step back, do what you can
10
here.
11
12
13
They
14
15
16
17
18
19
20
21
22
the time.
23
24
25
Yeah, it was at
69
Stan J. Caterbone LAMBERT CASE FILE
June
June 14, 2016
forward.
standing up as an adult.
10
11
change.
12
13
(Applause.)
14
15
16
17
18
19
20
21
22
23
24
25
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
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
"# $
%" "&##'(
#$
" "
*
#)
/ * .
.
/-
.
*
! #!" ! !
+
% &!
- / * )
0
) . ) 0
3
-
. /
-
9::;
0
)
)
*
'
,
)
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
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
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
"
%
"
/
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
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
. >>>
&
*
-
/ .
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
) .- 0
/ - )
)
0
)
0
/ - ) - -
?
/
/
) -
)
)
? 0
00
)
)
) 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
/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 *
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
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
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
!
"
#
$
& #
'
"
"
# )
* ()+
"
,
/
."
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
.'
'
%
#
#
"
"
"
()
%'
;
"
%
<=
#
"
"
5%1%
9
"
"
!
@
()
"
"
%
(
(
!;
.
!
# %
,
-1
.
511
"
""
"
1
()
#
"
,
(
A 1
"
%
"
"
%
"
#
.
%
,
"
4
%-
.
%'
$
#
4
)
;
#
#
-4 ,
>?
#
5%1%
"
%B
"
#
5%1%
%
4
#
#
@
#
"
"
C%%
%.
)
"
'
-:
% -@ ;
%'
.)
"
%@
%4,
"
"
%.
D $
2
!
) $&
Advanced
Stan
15-03984
Mind
Stan
J.
Control
Caterbone
J.Motion
Medi
Media
Caterbone
Transcripts
Group
Grop
Group
For
Executive
Reconsideration
Executive
Press
PressSummary
Executive
Release
Release
Summary
Summary
C%
Page
Page
Page
Page
Page
Page
Page
Page
132
10
16
17
19
10
10
910
10
of
of
of
9of
51
172
173
174
176
50
of
51
51
173
183
51
51
E
Tuesday,
Thursday,
Tuesday,
Friday,
Tuesday,
March
Tuesday,
Sunday,
March
December
15,
March
April
2016
June
15,
3/15/2016
2016
17,
12,
15,
11,
5, 2015
2016
!
)
"
& '(
*
+ &$ #
*
$'' ,&
./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	/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,
!
'
" #$ $ %
)'
%)
&
%
*++
!
"
#
"
"
&
'
)' +
"# - /
*
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,
)( )*+,
)*+,
.
"%-
"
!
3
"
% )
)4
"
.
.
*+ /
3
"
3
$ -
/ 1
-" $%
1-"%
"
5"%"
5!
#' .
"&
5"
3
!
!%$
.
!
-""
).
)?
-""
#$ $
! !
5/# 4
5" ! #" /#
#"
)*+6
%!
# %
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
# 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" / $
&
&"
&$"
4 #
"4
# $$"# "&
% 01"
5"
& !
9 <
5"
! %"
/# %/!
5" ! #"
4 - #"&
/#!
&
2 4"."%
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 /$
<
7$
/# %/!
"## ! %% - %
/!"
-'
# "%
"./&" !"
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 %
"
#"
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,
"%-
)4 )
"
!
"/
0! )
!
%
<
!
!
"
5#
"
4 )
)
$ -
"
"
! ! .
C!
"
0$
) 5
D
B. *+ /
%
!%
.
!
! !
% #
"
"
<
"
& 9"&"%
0$
%
"
"
.4
3 5
%
)
#/
. *+ /. '
% $% 1 -
1"
0$
%
! /
5
%"
!/./
"
<
" 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,
%
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
/!
)
!
/&"
.
!
"
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,
2
0$
%!
""
F
"
1!
)
1
""
! $
"
$.
&1. <
.
! )
!
$
9
"
"
5"
1!
""
"
"
.
3
.&
"
7
/
"
)
%
&"%
&
"
"
)H
"
"
8 ** )
"
%
+? $ -
%
%!
$&
). %
0$
"
C "%%
'-'
"%/
7
%!
"
>
).
).
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,
"#. "
) "' "
-"%
--'
'
%!
""
#$ $ 4
'
,
'
"
"
" '
)
"
. "
'
&
#$ $
&". "
#"05
!
%% %
%
.
. "
!
"E
"
#5. "
$
"
"
.
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,
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,
!
)
%
. "
C!
) .
"
*++/
) "
'!
>
"
$ 6
!
"
"!
"!
"
"
" %
% 8
"
"
)
>
" C!
$ 5
= %!
! %
3 )! %
0$
".
'
"4
$
"%00"
#"
" /
9 "%
-"%
9 )**F
"0 "1-"%
B. *++/
3
#
.
%%
5
3 !% )
"
'
'
!
& 5 # -""
# !!"##9
9 )**F
9
3 !% )
-" !
"
$.
$ +/9
-' 0
5/%&
/%! /
"&
0$
"
4
%
"
"
& )
"
/99
0$
!
5"
9 ; # /!"
#
%
4/ 5&% 4
/ $ /
-# % ! /
) 4
5" ! #" 4/
.
!
$ +/9*F+/ $
"
!
"&
%%
<
& &"#/#
(=5->( $
# ?*(>66(6@ /
5/# ! #" /# # /
9 "./&" !"
&
*++/
**
'
#$ $
0$
' %
) %
%
"
L 3
!%
"
2
)
"
) '
"
%
!
!
" !
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,
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,
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,
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
%
"
!
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,
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$
"!
"
"
3 E *.+++ "
!
"
'
" ! %
3 )
"
! "
$
77
"
!
5"%@
"< '"
%
>
< 'M
) "
" ? %
"
"
"%-
5)
0$
!%
5 1 #
"
% )
!
. 4
! C
*$
3 )
"
" " ! % )
5
!
"
D.
"
""
! "
D.
<
*/.
!
0$
"'
"
4!
"
)1
) 1
&@ #< = $
"
"
+$
" !
< ' 8%
"
A!
"
5"%@
*F.
*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,
"%-
" /#
%"1
"
8
!
%
$ <
"
).
" ./"4"% ?
%
#$ $
8%
3 )
"
+$
M'
&
7!
!%. <
)
!
E*+.+++
"
"
5"
5 5/#
"
"
"
"
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,
" <
. 4
#$ $ '
"
"
'
"
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,
2
PP
-""
#/ $
"1
9 "
"
"!%"
/K"& -' ! %0 %
-%
&! #
% "&
J "&/ 1J
"1
5/#
D2
"
# !
9 1 #
"E0"%/1"
#"!%" /." 9 % #
&% 1
" 5
/"4"%#
5" ".
/# /10 %
! 11"%!/
/"4"%
"
9 5/# 4%/ / $
1"%/!
& !"%
# 9 % %" &
'#/#
"!5
$/"# - %
9 5"
&
5" %"#
5/# 5 # %"!"
/ $
' -""
# #" #
#
& "E0"%
"!5
$ "#
"# /9/"&
"
/"4/ $ 5 # %"!"
" ,** ! 10
"0 % 1"
$/!
&.
#
!"1"
%'
5/# # 1"
"
%"
5/# /#
"9" #"
# !
5"
'
/"#
#"& /
' 8 )**F
# 4/ 5
"1
'
" "./#/
% &/
/."
5'#/!/#
'
, 0! ) * . *++
0$
&
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,
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,
"
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
)
'
)$
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,
<
% )
%%
)?$
!
5
"
"
" '
&
%)
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,
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,
! "
%& '
%
%
#$
"
" (
* '
"
&
$#
( -
&
'
* '
#
% ((
"
( ''
'
)( #""
"
'
''
"
''
( "
* !
'
&
%
! "
#$
'#
'
+ %
%&
% % $
'
&
( "
'
#'
'' '
'
%) *
'
+ '
+ '
%
)
<
'
%
#
$
% + $
"
#%
%
(
! &
''
'
&
'
"
&
"
%'
./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
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
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
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
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
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
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 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
< ('
2
"
3 ('
('
4
./,/ ' 4
< 3 ('
(#
(&
&
#
./,/ ' 4
1
>
(
1
&
$
'
.0 ./,/
#
&
)
( #
.6 ./,/
(%
+
*
(
<
& %
#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
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
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,
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
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,
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
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,
! "
"
$% &
!
" #
%
"&#
(
'
!
(
,
"
"
")
"
""
-
)
!
! "
!
'
%
" !
"
!
)
+
!
" *
"
"
,
,
,
*
%
*
(
%
!
/"0
1
1 ,
"
"
4
!
"
"
!
!
#
.
.
&,,0
%
1 ,
2"3
!
)
** ! "
&,,..$/
&,,
%
&,,
%
&
, "
"
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,
<
1
1
* "
!
"
C#
"$
"
<
*
&, ,
24
#9
; "
&,,@(&,,= A
3
24
5
!
%
&,,0 4
! %3
"
"
!
&,,
'
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
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,
)
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
=
@,
"
&,
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,
&
, * "
&&
*#
"
&:
;!
&<
:
%
$
&, ,
$
&,,-
!-
,
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
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,
"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,
") !
"
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,
E DD
)
*
"E
!"
, "
"
1 ,"
DD
*)
PPPPPPP "
>7
%#
'?
Stan J. Caterbone
# PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
"
Stan J. Caterbone
# PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
"
Pennsylvania
PPPPPPPPPPPPPPPPPPPPPPPPPP
$
Lancaster
PPPPPPPPPPPPPPPPPPPPPPPPPPPPP
19
PPPPPPP
15
June
PPPPPPPPPPPPPPPPPPPPPPP
&,PP
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
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,
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
THE ADVANCED MEDIA GROUP
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
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
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
THE ADVANCED MEDIA GROUP
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
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
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
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,
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
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,
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
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,
"
!
#"
!
)
* ++
,*
+
+,$ !
$% &
+
%
$% &
$% &
1"&&$&&& !
. -
'
'
'
'
. '
$% &
'
'
+
'
!'
/
- ,
'
% *
%
*
%
.
'
'
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
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
"
!
#"
%%$ %&"'
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
' 0 *
'
% '
#7
. *
'
! J $%
* '
'
J'
% '
'
'
'
. ## E 0
*
% % ' %
*
1+A8)E %
' '
%
'
' '
'*
'
'
' $ . ,
!
' % *
'
* 6
K /
' !
'
'
% *
.
%
' % A018
%
.
.
%*
% J? ' 8 ' , . J
% '
LLLLLLLLLLLLLF FLLLLLLLLLLL
$
9
!
*** . +
+
.
/
%
0 %
*
!
#7 E %
#7 E
/
/
,
!
9
*
%
*#
'
'
' '
,
-
, +
-
- !!
,
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
::
$
-"%;& :
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
**
**
-
'
.
!
/
'
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
% !
!
*
' '
* 9
' '
. %
&
M >
'
'.
.*
'
*
'
%
F*
' ?
* !
'
!
'
'
% %
'.
'
'*B
+8+
1% *
* 1
.
" M
**
NC
'
'
! !
' !
'
'
$
'O
*
' %
&
'
.*
'
' !
'
'
'
%
.
!
*
'.
%
;
'
. 0 '
%
' *
'
'
* %
'
L' 'L;
&
* % &
+ *
'
" M
'
' $ *
' >
** ' !
! !
'
!
'
F' 'F'
* %
%
: *
!
'
**
''
0 %
9>> : >
'
'!'
% !
F'
3FF
0 '!'
'
%
.
*+ *
0 % !
&
A %
* %
'
'
' !
% >
4-
'
!
'
'
'
'
'
0
.
.%
%
% '
$%
* + *
+
*
% .
'
'
'
3
"<
"<
"<
5 9 /D $%
/ /
/ 99
"< "
-
'
'
.
"< %
'
'
% *
C 9
%
.
' '
. -
+ +
$%
%
'
;
:
:
! .
"< % "
! !
%
'
*
'
'
;
:
;
. 9
.
'
' %
4.
%.
/
. %
;
% %
;
'
. !
Affidavit
AFFIDAVIT
Mind Control
of Stan
of Transcripts
Stan
JJ.Caterbone
Caterbone
J. Caterbone
re
reState-of-Affairs
Current
re State-of-Affairs
State-of-Affairs
Page
Page
Page
Page
179
666of
of
of
of113
183
23
27
23
Tuesday,
Sunday,
March
June22,
5, 2016
"< % %
'
2!
'
'
'
'
% *
+ +
+ +1
'
* %
* %
%
"< % < B .
&
'
'
'
*
' >
'
A814+&A4
% *
'
>
% %
4-
+ +
'
'
'
'
'
/
.
' %
;
.
% %
+
*
*
%
0%
,
!!
!
,
% 0
HHHHHHHHHHHHHHHHHHHHHHHHHHHHHHHH$
-
, +
- 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
KEISLING: Palace coup: what the Kathleen Kane prosecution is really ...
1 of 4
http://newslanc.com/2015/12/09/keisling-palace-coup-what-the-kathleen...
December 9, 2015
!
!
"
"#
$
%
'
&
)*$
"#
"#
&
,
-
"
.
$/
$
$
&
,
"#
"
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
KEISLING: Palace coup: what the Kathleen Kane prosecution is really ...
2 of 4
http://newslanc.com/2015/12/09/keisling-palace-coup-what-the-kathleen...
"#
$
$
&
"#
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
KEISLING: Palace coup: what the Kathleen Kane prosecution is really ...
3 of 4
http://newslanc.com/2015/12/09/keisling-palace-coup-what-the-kathleen...
&.
"# .
&
$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
Stan J. Caterbone
ADVANCED MEDIA GROUP
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.
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.
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.
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.
In 1985 I was elected Vice President of the Central Pennsylvania Chapter of the International
Association of Financial Planners, and helped build that chapter by increasing membership 3to 4 times.
We had personally retained the nationally acclaimed and nationally syndicated Financial Planner, Ms.
Alexandria Armstrong of Washington D.C.; to host a major fundraiser. More than 150 professionals
attended the dinner event that was held at the Eden Resort & Conference Center. Ms. Armstrong
discussed financial planning and how all of the professions needed to work together in order to be most
effective for their clients. We attracted a wide variety of professionals including; brokers, lawyers,
accountants, realtors, tax specialists, estate planners, bankers, and investment advisors. Today, it has
become evident that financial planning was the way of the future. In 1986 executives approached us
from Blue Ball National Bank to help them develop a Financial Planning department within their bank.
In 1984 I had helped to develop strategic planning for Sandy Weill, former President of Citi Group (the
largest banking entity in the U.S). We were one of several associates asked to help advise on the future
of Financial Planning and how it would impact the brokerage and the investment industry at large. Mr.
Weil was performing due diligence for the merger of American Express and IDS (Investors Diversified
Services). We were at that time a national leader in the company in delivering Fee Based Financial
Planning Services, which was a new concept in the investment community and mainstream investors.
That concept is now widely held by most investment advisers.
Stan J. Caterbone, Pro Se Litigant
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
LancasterOnline.com:
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
Stan J. Caterbone LAMBERT CASE FILE
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
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
1 of 3
6/10/2006 8:31 AM
LancasterOnline.com:
search for lisa michelle lambert
A...873 of
http://nl.newsbank.com/nl-search/we/Archives?p_product=LC&p_...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on Decem ber 30, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:31 AM
LancasterOnline.com:
search for lisa michelle lambert
A...874 of
http://nl.newsbank.com/nl-search/we/Archives?p_product=LC&p_...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
3 of 3
6/10/2006 8:31 AM
LancasterOnline.com:
search for lisa michelle lambert
A...875 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for com plet e art icle, ( 573 words)
Article 12 of 348, 1997364209
Published on Decem ber 30, 1997, Lancast er New Era ( PA)
1 of 3
6/10/2006 8:32 AM
LancasterOnline.com:
search for lisa michelle lambert
A...876 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on Decem ber 30, 1997, Lancast er New Era ( PA)
2 of 3
6/10/2006 8:32 AM
LancasterOnline.com:
search for lisa michelle lambert
A...877 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
Click for com plet e art icle, ( 480 words)
Article 19 of 348, 1997362286
Published on Decem ber 28, 1997, Sunday News ( Lancast er, PA)
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
Click for com plet e art icle, ( 634 words)
Article 20 of 348, 1997361195
Published on Decem ber 27, 1997, Lancast er New Era ( PA)
3 of 3
6/10/2006 8:32 AM
LancasterOnline.com:
search for lisa michelle lambert
A...878 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
The following is a look back at local news events during the past week.
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
Click for com plet e art icle, ( 539 words)
Article 22 of 348, 1997355353
Published on Decem ber 21, 1997, Sunday News ( Lancast er, PA)
1 of 3
6/10/2006 8:33 AM
LancasterOnline.com:
search for lisa michelle lambert
A...879 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Click for com plet e art icle, ( 736 words)
Article 25 of 348, 1997348360
Published on Decem ber 14, 1997, Sunday News ( Lancast er, PA)
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
Click for com plet e art icle, ( 534 words)
Article 26 of 348, 1997348361
Published on Decem ber 14, 1997, Sunday News ( Lancast er, PA)
2 of 3
6/10/2006 8:33 AM
LancasterOnline.com:
search for lisa michelle lambert
A...880 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on Decem ber 11, 1997, Lancast er New Era ( PA)
3 of 3
6/10/2006 8:33 AM
LancasterOnline.com:
search for lisa michelle lambert
A...881 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
The following is a look back at local news events during the past week.
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
Click for com plet e art icle, ( 483 words)
Article 33 of 348, 1997341345
Published on Decem ber 7, 1997, Sunday News ( Lancast er, PA)
1 of 3
6/10/2006 8:34 AM
LancasterOnline.com:
search for lisa michelle lambert
A...882 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Click for com plet e art icle, ( 677 words)
Article 35 of 348, 1997341324
Published on Decem ber 7, 1997, Sunday News ( Lancast er, PA)
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
Click for com plet e art icle, ( 568 words)
Article 38 of 348, 1997340175
Published on Decem ber 6, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:34 AM
LancasterOnline.com:
search for lisa michelle lambert
A...883 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
3 of 3
6/10/2006 8:34 AM
LancasterOnline.com:
search for lisa michelle lambert
A...884 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:35 AM
LancasterOnline.com:
search for lisa michelle lambert
A...885 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
2 of 3
6/10/2006 8:35 AM
LancasterOnline.com:
search for lisa michelle lambert
A...886 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Click for com plet e art icle, ( 738 words)
Article 48 of 348, 1997310001
Published on Novem ber 6, 1997, Lancast er New Era ( PA)
3 of 3
6/10/2006 8:35 AM
LancasterOnline.com:
search for lisa michelle lambert
A...887 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:35 AM
LancasterOnline.com:
search for lisa michelle lambert
A...888 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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)
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
Click for com plet e art icle, ( 447 words)
Article 57 of 348, 1997295181
Published on Oct ober 22, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:35 AM
LancasterOnline.com:
search for lisa michelle lambert
A...889 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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)
3 of 3
6/10/2006 8:35 AM
LancasterOnline.com:
search for lisa michelle lambert
A...890 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:36 AM
LancasterOnline.com:
search for lisa michelle lambert
A...891 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on Oct ober 8, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:36 AM
LancasterOnline.com:
search for lisa michelle lambert
A...892 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
3 of 3
6/10/2006 8:36 AM
LancasterOnline.com:
search for lisa michelle lambert
A...893 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 4
6/10/2006 8:38 AM
LancasterOnline.com:
search for lisa michelle lambert
A...894 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on Sept em ber 24, 1997, I nt elligencer Journal ( Lancast er,
PA)
2 of 4
6/10/2006 8:38 AM
LancasterOnline.com:
search for lisa michelle lambert
A...895 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
3 of 4
6/10/2006 8:38 AM
LancasterOnline.com:
search for lisa michelle lambert
A...896 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Term s of Service Privacy Policy
4 of 4
6/10/2006 8:38 AM
LancasterOnline.com:
search for lisa michelle lambert
A...897 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:39 AM
LancasterOnline.com:
search for lisa michelle lambert
A...898 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on Sept em ber 5, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:39 AM
LancasterOnline.com:
search for lisa michelle lambert
A...899 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
3 of 3
6/10/2006 8:39 AM
LancasterOnline.com:
search for lisa michelle lambert
A...900 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:40 AM
LancasterOnline.com:
search for lisa michelle lambert
A...901 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on August 14, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:40 AM
LancasterOnline.com:
search for lisa michelle lambert
A...902 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on August 9, 1997, I nt elligencer Journal ( Lancast er, PA)
3 of 3
6/10/2006 8:40 AM
LancasterOnline.com:
search for lisa michelle lambert
A...903 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:41 AM
LancasterOnline.com:
search for lisa michelle lambert
A...904 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on August 5, 1997, Lancast er New Era ( PA)
2 of 3
6/10/2006 8:41 AM
LancasterOnline.com:
search for lisa michelle lambert
A...905 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on August 1, 1997, I nt elligencer Journal ( Lancast er, PA)
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
Click for com plet e art icle, ( 425 words)
Article 110 of 348, 1997213253
Published on August 1, 1997, Lancast er New Era ( PA)
3 of 3
6/10/2006 8:41 AM
LancasterOnline.com:
search for lisa michelle lambert
A...906 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:42 AM
LancasterOnline.com:
search for lisa michelle lambert
A...907 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
2 of 3
6/10/2006 8:42 AM
LancasterOnline.com:
search for lisa michelle lambert
A...908 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Click for com plet e art icle, ( 916 words)
Article 118 of 348, 1997204477
Published on July 23, 1997, I nt elligencer Journal ( Lancast er, PA)
3 of 3
6/10/2006 8:42 AM
LancasterOnline.com:
search for lisa michelle lambert
A...909 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:42 AM
LancasterOnline.com:
search for lisa michelle lambert
A...910 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on July 17, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:42 AM
LancasterOnline.com:
search for lisa michelle lambert
A...911 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on July 12, 1997, I nt elligencer Journal ( Lancast er, PA)
3 of 3
6/10/2006 8:42 AM
LancasterOnline.com:
search for lisa michelle lambert
A...912 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:43 AM
LancasterOnline.com:
search for lisa michelle lambert
A...913 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
2 of 3
6/10/2006 8:43 AM
LancasterOnline.com:
search for lisa michelle lambert
A...914 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
3 of 3
6/10/2006 8:43 AM
LancasterOnline.com:
search for lisa michelle lambert
A...915 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:45 AM
LancasterOnline.com:
search for lisa michelle lambert
A...916 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on June 19, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:45 AM
LancasterOnline.com:
search for lisa michelle lambert
A...917 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
3 of 3
6/10/2006 8:45 AM
LancasterOnline.com:
search for lisa michelle lambert
A...918 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:46 AM
LancasterOnline.com:
search for lisa michelle lambert
A...919 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
2 of 3
6/10/2006 8:46 AM
LancasterOnline.com:
search for lisa michelle lambert
A...920 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Click for com plet e art icle, ( 285 words)
Article 158 of 348, 1997157363
Published on June 6, 1997, I nt elligencer Journal ( Lancast er, PA)
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
Click for com plet e art icle, ( 625 words)
3 of 3
6/10/2006 8:46 AM
LancasterOnline.com:
search for lisa michelle lambert
A...921 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:47 AM
LancasterOnline.com:
search for lisa michelle lambert
A...922 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on June 4, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:47 AM
LancasterOnline.com:
search for lisa michelle lambert
A...923 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
3 of 3
6/10/2006 8:47 AM
LancasterOnline.com:
search for lisa michelle lambert
A...924 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:47 AM
LancasterOnline.com:
search for lisa michelle lambert
A...925 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on June 2, 1997, Lancast er New Era ( PA)
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
Click for com plet e art icle, ( 761 words)
Article 177 of 348, 1997151062
Published on May 31, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:47 AM
LancasterOnline.com:
search for lisa michelle lambert
A...926 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for com plet e art icle, ( 502 words)
Article 180 of 348, 1997149095
Published on May 29, 1997, I nt elligencer Journal ( Lancast er, PA)
3 of 3
6/10/2006 8:47 AM
LancasterOnline.com:
search for lisa michelle lambert
A...927 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:48 AM
LancasterOnline.com:
search for lisa michelle lambert
A...928 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
2 of 3
6/10/2006 8:48 AM
LancasterOnline.com:
search for lisa michelle lambert
A...929 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
3 of 3
6/10/2006 8:48 AM
LancasterOnline.com:
search for lisa michelle lambert
A...930 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:48 AM
LancasterOnline.com:
search for lisa michelle lambert
A...931 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
2 of 3
6/10/2006 8:48 AM
LancasterOnline.com:
search for lisa michelle lambert
A...932 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
3 of 3
6/10/2006 8:48 AM
LancasterOnline.com:
search for lisa michelle lambert
A...933 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:50 AM
LancasterOnline.com:
search for lisa michelle lambert
A...934 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
2 of 3
6/10/2006 8:50 AM
LancasterOnline.com:
search for lisa michelle lambert
A...935 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for com plet e art icle, ( 245 words)
Article 210 of 348, 1997124075
Published on May 4, 1997, Sunday News ( Lancast er, PA)
3 of 3
6/10/2006 8:50 AM
LancasterOnline.com:
search for lisa michelle lambert
A...936 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
The following is a look back at local news events during the past week.
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
Click for com plet e art icle, ( 533 words)
Article 213 of 348, 1997122096
Published on May 2, 1997, I nt elligencer Journal ( Lancast er, PA)
1 of 3
6/10/2006 8:50 AM
LancasterOnline.com:
search for lisa michelle lambert
A...937 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
2 of 3
6/10/2006 8:50 AM
LancasterOnline.com:
search for lisa michelle lambert
A...938 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for com plet e art icle, ( 197 words)
Article 219 of 348, 1997121067
Published on May 1, 1997, Lancast er New Era ( PA)
3 of 3
6/10/2006 8:50 AM
LancasterOnline.com:
search for lisa michelle lambert
A...939 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:51 AM
LancasterOnline.com:
search for lisa michelle lambert
A...940 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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.
Click for com plet e art icle, ( 99 words)
Article 227 of 348, 1991173046
Published on April 27, 1997, Sunday News ( Lancast er, PA)
2 of 3
6/10/2006 8:51 AM
LancasterOnline.com:
search for lisa michelle lambert
A...941 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for com plet e art icle, ( 1146 words)
Article 230 of 348, 1991173044
Published on April 27, 1997, Sunday News ( Lancast er, PA)
3 of 3
6/10/2006 8:51 AM
LancasterOnline.com:
search for lisa michelle lambert
A...942 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:52 AM
LancasterOnline.com:
search for lisa michelle lambert
A...943 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on April 25, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:52 AM
LancasterOnline.com:
search for lisa michelle lambert
A...944 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on April 25, 1997, Lancast er New Era ( PA)
3 of 3
6/10/2006 8:52 AM
LancasterOnline.com:
search for lisa michelle lambert
A...945 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for com plet e art icle, ( 147 words)
Article 244 of 348, 1991133093
1 of 3
6/10/2006 8:53 AM
LancasterOnline.com:
search for lisa michelle lambert
A...946 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on April 23, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:53 AM
LancasterOnline.com:
search for lisa michelle lambert
A...947 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on April 23, 1997, Lancast er New Era ( PA)
3 of 3
6/10/2006 8:53 AM
LancasterOnline.com:
search for lisa michelle lambert
A...948 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 4
6/10/2006 8:54 AM
LancasterOnline.com:
search for lisa michelle lambert
A...949 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on April 22, 1997, I nt elligencer Journal ( Lancast er, PA)
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
Click for com plet e art icle, ( 735 words)
Article 255 of 348, 1991122069
Published on April 22, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 4
6/10/2006 8:54 AM
LancasterOnline.com:
search for lisa michelle lambert
A...950 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Click for com plet e art icle, ( 889 words)
Article 258 of 348, 1991122075
Published on April 22, 1997, I nt elligencer Journal ( Lancast er, PA)
3 of 4
6/10/2006 8:54 AM
LancasterOnline.com:
search for lisa michelle lambert
A...951 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
PO Box 1328, Lancast er PA 17608, ( 717) 291- 8811
Term s of Service Privacy Policy
4 of 4
6/10/2006 8:54 AM
LancasterOnline.com:
search for lisa michelle lambert
A...952 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:55 AM
LancasterOnline.com:
search for lisa michelle lambert
A...953 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on April 22, 1997, Lancast er New Era ( PA)
2 of 3
6/10/2006 8:55 AM
LancasterOnline.com:
search for lisa michelle lambert
A...954 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for com plet e art icle, ( 2400 words)
Article 270 of 348, 1991111846
Published on April 21, 1997, Lancast er New Era ( PA)
3 of 3
6/10/2006 8:55 AM
LancasterOnline.com:
search for lisa michelle lambert
A...955 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:56 AM
LancasterOnline.com:
search for lisa michelle lambert
A...956 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on April 22, 1997, Lancast er New Era ( PA)
2 of 3
6/10/2006 8:56 AM
LancasterOnline.com:
search for lisa michelle lambert
A...957 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for com plet e art icle, ( 2400 words)
Article 270 of 348, 1991111846
Published on April 21, 1997, Lancast er New Era ( PA)
3 of 3
6/10/2006 8:56 AM
LancasterOnline.com:
search for lisa michelle lambert
A...958 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for com plet e art icle, ( 932 words)
Article 274 of 348, 1991103150
1 of 3
6/10/2006 8:57 AM
LancasterOnline.com:
search for lisa michelle lambert
A...959 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on April 20, 1997, Sunday News ( Lancast er, PA)
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.
Click for com plet e art icle, ( 1830 words)
Article 277 of 348, 1991103145
Published on April 20, 1997, Sunday News ( Lancast er, PA)
2 of 3
6/10/2006 8:57 AM
LancasterOnline.com:
search for lisa michelle lambert
A...960 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on April 19, 1997, I nt elligencer Journal ( Lancast er, PA)
3 of 3
6/10/2006 8:57 AM
LancasterOnline.com:
search for lisa michelle lambert
A...961 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:58 AM
LancasterOnline.com:
search for lisa michelle lambert
A...962 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on April 18, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:58 AM
LancasterOnline.com:
search for lisa michelle lambert
A...963 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
3 of 3
6/10/2006 8:58 AM
LancasterOnline.com:
search for lisa michelle lambert
A...964 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for com plet e art icle, ( 151 words)
Article 294 of 348, 1991072088
1 of 3
6/10/2006 8:58 AM
LancasterOnline.com:
search for lisa michelle lambert
A...965 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on April 17, 1997, I nt elligencer Journal ( Lancast er, PA)
2 of 3
6/10/2006 8:58 AM
LancasterOnline.com:
search for lisa michelle lambert
A...966 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday JanuaryArchives
22, 2017
Page
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on April 17, 1997, Lancast er New Era ( PA)
3 of 3
6/10/2006 8:58 AM
LancasterOnline.com:
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
Stan J. Caterbone LAMBERT CASE FILE
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
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
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.
M a rk et pla ce
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
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
12/25/2007 10:16 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 968 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
2 of 4
12/25/2007 10:16 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 969 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 1 6 0 w or d s)
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.
Cl i c k f o r c o m p l e t e a r t i c l e , ( 2 1 8 w or d s)
3 of 4
12/25/2007 10:16 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 970 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Article 131 of 149, 1996030196
Go
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"
Cl i c k f o r c o m p l e t e a r t i c l e , ( 4 3 6 w or d s)
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
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 5 2 1 w or d s)
12/25/2007 10:36 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 971 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
2 of 3
12/25/2007 10:36 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 972 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 2 0 6 w or d s)
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
LancasterOnline.com:
Archives
search for isc AND date(all) Page 973 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Article 121 of 149, 1997044280
Go
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
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 6 2 6 w or d s)
12/25/2007 10:35 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 974 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
2 of 3
12/25/2007 10:35 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 975 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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 10:35 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 976 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Article 111 of 149, 1991203248
Go
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
Co y o t e T r a i l s
$ 6 9 .0 0
R e a l M e n Fr y T u r k e y s
Ap r on
S t e r m e r B r o t h e r s $ 0 .0 0
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 1 7 5 w or d s)
1 4 - k t . Ye l l o w G o l d
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 2 0 0 w or d s)
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
12/25/2007 10:34 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 977 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 9 5 0 w or d s)
2 of 4
12/25/2007 10:34 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 978 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
3 of 4
12/25/2007 10:34 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 979 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Article 101 of 149, 1998198117
Go
M a rk et pla ce
" 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
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
12/25/2007 10:33 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 980 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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,
Cl i c k f o r c o m p l e t e a r t i c l e , ( 5 5 9 w or d s)
2 of 3
12/25/2007 10:33 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 981 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
Cl i c k f o r c o m p l e t e a r t i c l e , ( 6 8 6 w or d s)
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 10:33 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 982 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Article 91 of 149, 1998261094
GUERIN REVISITED
Go
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 6 1 5 w or d s)
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
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 1 3 5 7 w or d s)
12/25/2007 10:32 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 983 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
2 of 3
12/25/2007 10:32 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 984 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Jour nal ( Lancast er , PA)
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 10:32 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 985 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Article 91 of 149, 1998261094
GUERIN REVISITED
Go
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 6 1 5 w or d s)
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
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 1 3 5 7 w or d s)
12/25/2007 10:31 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 986 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
2 of 3
12/25/2007 10:31 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 987 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Jour nal ( Lancast er , PA)
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 10:31 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 988 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Go
M a rk et pla ce
Visit t he
M ark et place > >
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
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
12/25/2007 10:29 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 989 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
2 of 3
12/25/2007 10:29 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 990 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Pu blish ed on Oct ober 1 3 , 1 9 9 8 , I n t elligen cer
Jour nal ( Lancast er , PA)
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 10:29 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 991 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 1 8 3 9 w or d s)
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
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.
Cu st om er
Service
Sit e Map
Keyword
I ndex
RSS Feeds
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.
Liv e Suppor t
Sit e
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
Displaying 10 articles
Go
Cl i c k f o r c o m p l e t e a r t i c l e , ( 1 4 5 4 w or d s)
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.
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 2 7 6 5 w or d s)
12/25/2007 10:28 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 992 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
2 of 4
12/25/2007 10:28 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 993 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 8 7 3 w or d s)
3 of 4
12/25/2007 10:28 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 994 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Article 61 of 149, 1999362111
Go
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
D i a b e t i c B r u i s e Re l i e f
$ 1 9 .9 9
Cl i c k f o r c o m p l e t e a r t i c l e , ( 3 0 3 0 w or d s)
12/25/2007 10:26 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 995 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
Cl i c k f o r c o m p l e t e a r t i c l e , ( 1 8 0 w or d s)
2 of 3
12/25/2007 10:26 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 996 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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 10:26 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 997 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Article 51 of 149, 2000071143
Go
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
S p i n n e r Ri n g - S i z e 1 2
$ 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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 1 0 7 4 w or d s)
12/25/2007 10:24 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 998 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 5 6 4 w or d s)
2 of 3
12/25/2007 10:24 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 999 ofhttp://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on Januar y 3 , 2 0 0 0 , I nt elligencer
Jour nal ( Lancast er , PA)
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 10:24 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1000 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Article 41 of 149, 2000341190
Go
M a rk et pla ce
Min n et on k a
Sh eep sk in
An k le Boot
# 3451
Co y o t e T r a i l s
$ 6 4 .9 9
Z i p p o Lo g o Li g h t er s Mp l
S t e r m e r B r o t h e r s $ 0 .0 0
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 5 2 8 w or d s)
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 1 0 7 0 w or d s)
12/25/2007 10:22 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1001 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
2 of 3
12/25/2007 10:22 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1002 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Pu blish ed on Au gu st 3 , 2 0 0 0 , I n t elligen cer
Jour nal ( Lancast er , PA)
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 10:22 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1003 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Article 41 of 149, 2000341190
Go
M a rk et pla ce
Min n et on k a
Sh eep sk in
An k le Boot
# 3451
Co y o t e T r a i l s
$ 6 4 .9 9
Z i p p o Lo g o Li g h t er s Mp l
S t e r m e r B r o t h e r s $ 0 .0 0
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 5 2 8 w or d s)
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 1 0 7 0 w or d s)
12/25/2007 10:21 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1004 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
2 of 3
12/25/2007 10:21 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1005 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Pu blish ed on Au gu st 3 , 2 0 0 0 , I n t elligen cer
Jour nal ( Lancast er , PA)
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 10:21 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1006 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Article 31 of 149, 2001154125
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
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 4 5 0 w or d s)
O l d e M i l l H o u s e $ 0 .0 0
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 2 7 0 w or d s)
Feat u r es
Celebrat ions
Obit uaries
Special
Sect ions
Colum ns
I nt er est s
Go
12/25/2007 10:20 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1007 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 5 8 8 w or d s)
2 of 3
12/25/2007 10:20 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1008 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Published on Decem ber 6 , 2 0 0 0 , I nt elligencer
Jour nal ( Lancast er , PA)
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 10:20 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1009 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
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
Co y o t e T r a i l s
$ 9 8 .9 9
R e a l M e n Fr y T u r k e y s
Ap r on
S t e r m e r B r o t h e r s $ 0 .0 0
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 7 6 2 w or d s)
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 9 7 3 w or d s)
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 7 2 5 w or d s)
12/25/2007 10:19 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1010 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
2 of 3
12/25/2007 10:19 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1011 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Pu blish ed on Oct ober 1 5 , 2 0 0 1 , Lan cast er New
Er a ( PA)
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 10:19 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1012 of
http://nl.newsbank.com/nl-search/we/Archives?p_product=LC&p_...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 10 articles
Robert E. Meck
Go
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 1 3 7 w or d s)
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
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 2 9 7 w or d s)
12/25/2007 10:17 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1013 of
http://nl.newsbank.com/nl-search/we/Archives?p_product=LC&p_...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
Cl i c k f o r c o m p l e t e a r t i c l e , ( 8 8 7 w or d s)
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 7 7 8 w or d s)
2 of 4
12/25/2007 10:17 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1014 of
http://nl.newsbank.com/nl-search/we/Archives?p_product=LC&p_...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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)
3 of 4
12/25/2007 10:17 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1015 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Displaying 9 articles
Article 141 of 149, 1995126035
Go
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 6 8 5 w or d s)
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
1 0 - k t . Ye l l o w G o l d
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"?
Cl i c k f o r c o m p l e t e a r t i c l e , ( 4 2 8 w or d s)
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
12/25/2007 10:39 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1016 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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
Cl i c k f o r c o m p l e t e a r t i c l e , ( 8 2 9 w or d s)
2 of 3
12/25/2007 10:39 AM
LancasterOnline.com:
Archives
search for isc AND date(all) Page 1017 of
http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
Sunday January
22, 2017
2301
Stan J. Caterbone LAMBERT CASE FILE
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)
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 10:39 AM
Stan J. Caterbone
MOVANT
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
717-459-7588 Fax
The affidavit
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
https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?121153035547044-L_1_0-1
LAMBERT v. BISSONETTE et al
Assigned to: HONORABLE PAUL S. DIAMOND
Cause: 28:2254 Petition for Writ of Habeas Corpus (State)
Petitioner
LISA MICHELLE LAMBERT
V.
Respondent
LYNN BISSONETTE
SUPERINTENDENT, MCI-FRAMINGHAM
Respondent
THE DISTRICT ATTORNEY OF LANCASTER
COUNTY, PENNSYLVANIA
Respondent
THE ATTORNEY GENERAL OF PENNSYLVANIA
V.
Movant
STANLEY J. CATERBONE
AND ADVANCED MEDIA GROUP
1 of 2
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
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
https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?121153035547044-L_1_0-1
Docket Report
Billable Pages: 2
2 of 2
0.20
8/19/2015 1:16 AM
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
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.
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
Confidential
Page 3
6/12/2006
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..
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.
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
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.
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. .
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
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
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
January January
Sunday
22, 201722, 2017
Page 4 of 91
January January
Sunday
22, 201722, 2017
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
Amount expected
next month
You
Spouse
You
Spouse
Employment
Self-employment
Gifts
Alimony
Child Support
Unemployment payments
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
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
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
Type of account
Members1st
TD Ameritrade
Checking
Money Market
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 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 7 of 91
January January
Sunday
22, 201722, 2017
You
Transportation (not including motor vehicle payments)
Your spouse
100.00
200.00
$
$
Homeowners or renters
Life
Health
Motor Vehicle
Other:
Office/Computer/Copying/Printing/Postage
300.00
Motor Vehicle
Credit card(s)
Department store(s)
Other:
Other (specify):
500.00
2,658.00
(specify):
Installment payments
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 9 of 91
January January
Sunday
22, 201722, 2017
No.
IN THE
STANLEY J. CATERBONE
PETITIONER
(Your Name)
vs.
RESPONDENT(S)
Stanley J. Caterbone
(Your Name)
1250 Fremont Street
(Address)
Lancaster, PA 17603
(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
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.
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 12 of 91
January January
Sunday
22, 201722, 2017
TABLE OF CONTENTS
12
OPINIONS BELOW ........................................................................................................ 1
13
JURISDICTION...................................................................................................................
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
CASES
PAGE NUMBER
Pointer v. Texas, 380 U.S. 400, 85 S.Ct. 1065, 13 L.Ed.2d 923 (1965);
Appendix B -
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
IN THE
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
to
[ ] reported at
; or,
[ ] has been designated for publication but is not yet reported; 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,
[ ] has been designated for publication but is not yet reported; or,
[ ] is unpublished.
The opinion of the
appears at Appendix
court
to the petition and is
[ ] reported at
; or,
[ ] has been designated for publication but is not yet reported; 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
JURISDICTION
[ ] A timely petition for rehearing was thereafter denied on the following date:
, and a copy of the 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. 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
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
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
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 " `a 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
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
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
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
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 `incorporation'
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
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
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
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
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.
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
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.
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
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
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;
wrongdoings in this case.
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;
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 30 of 91
January January
Sunday
22, 201722, 2017
Page 31 of 91
January January
Sunday
22, 201722, 2017
PROOF OF SERVICE
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
October 2015
OFFICE OF THE CLERK
WASHINGTON, D. C. 20543
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)
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
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).
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
I.
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
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
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
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
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
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
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
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
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
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
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
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
scaterbone@live.com
717-669-2163
Re:
IMPORTANT
/S/
Stan J. Caterbone, Pro Se APPELLANT
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
REQUEST FOR COMMUTATION
Page
Page1089
87 ofof
1299
2301
OF
THE 09/14/15
SENTENCE
Stan J. Caterbone
OF LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
:
:
:
:
:
:
:
:
ORDER
I previously dismissed Petitioners pro se motion for habeas relief so that she could file a
counseled motion.
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
REQUEST FOR COMMUTATION
Page
Page1090
88 ofof
1299
2301
OF
THE 09/14/15
SENTENCE
Stan J. Caterbone
OF LISA
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
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.)
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
REQUEST FOR COMMUTATION
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.
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
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
REQUEST FOR COMMUTATION
Page
Page1093
91 ofof1299
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Petitioner
v.
LYNN BISSONETTE, SUPERINTENDENT,
MCI-FRAMINGHAM,
and
CRAIG STEDMAN, THE DISTRICT ATfORNEY OF LANCASTER
COUNTY, PENNSYLVANIA
and
KATHLEEN KANE, THE ATfORNEY GENERAL OF PENNSYLVANIA,
Respondents
S 17=n
F uu~t:
lY
SEP - 3 2D15
MICHAELE. KUNZ, Clerk
By
Dep. Clerk
(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
REQUEST FOR COMMUTATION
Page
Page1094
92 ofof1299
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
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
REQUEST FOR COMMUTATION
Page
Page1095
93 ofof1299
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
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, 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~.,
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.
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
REQUEST FOR COMMUTATION
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
said perpetrators violating common laws governing intellectual property rights.
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
REQUEST FOR COMMUTATION
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
REQUEST FOR COMMUTATION
Page
Page1098
96 ofof1299
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
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
http://store.aetv.com/html/product/index.jhtml?id=75922
REQUEST FOR COMMUTATION
Page
Page1100
98 ofof1299
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
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:
A Teenage Murder Mystery DVD
-->
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
ADVANCED MEDIA GROUP
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
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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 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.
"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 pink bag, then waving the camera off.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
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.
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.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
"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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
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.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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."
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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. . . . "
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 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."
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."
"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
Advanced Media Group
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
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 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
Advanced Media Group
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
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.
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.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
"How often do you get to do this?" Hazel observed.
"I think we made an impact," John offered.
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. . . . "
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
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;
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
062S0000000314
Click-N-Ship
11/16/2016
0006
C000
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
SHIP
WASHINGTON DC 20500-0003
USPS TRACKING #
Instructions
USPS TRACKING # :
From:
To:
389217451
11/16/2016
11/16/2016
$6.45
$6.45
11/18/2016
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
BARACH OBAMA
THE WHITE HOUSE
1600 PENNSYLVANIA AVE NW
WASHINGTON DC 20500-0003
* 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.
Thank you for shipping with the United States Postal Service!
Check the status of your shipment on the USPS Tracking page at usps.com
January January
Sunday
22, 201722, 2017
Page
Page1118
116 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1119
117 of
of1299
2301
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
https://www.supremecourt.gov/search.aspx?filename=/docketfiles/16-68...
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
Stanley J. Caterbone
Advanced Media Group
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
:
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.
Office of
Of the
TheCircuit
CircuitExecutive
Executive- Petition For Review
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.
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.
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
Executive- Petition For Review
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
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
Executive- Petition For Review
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.
Office of
Of the
TheCircuit
CircuitExecutive
Executive- Petition For Review
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,
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
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.
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
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
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
Executive- Petition For Review
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.
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.
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
Executive- Petition For Review
Page
Page
Page888of
of
of65
69
8
January January
Sunday
22, 201722, 2017
Page
Page1132
130 of
of1299
2301
26th
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:
It is clear that the intentions of the Honorable Judge Paul S. Diamond was only to discredit
the APPELLANT and prejudice the Court.
explanation.
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
Executive- Petition For Review
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.
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
Executive- Petition For Review
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
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:
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
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
Executive- Petition For Review
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
Executive- Petition For Review
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
Office of
Of the
TheCircuit
CircuitExecutive
Executive- Petition For Review
Page
Page 14
14 of
of 14
65
69
January January
Sunday
22, 201722, 2017
Page
Page1138
136 of
of1299
2301
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
https://www.scribd.com/stan5j.5caterbone
Stan J. Caterbone
Advanced Media Group
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
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
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.
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
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
2. Dirty bomb drill in Richmond alarms conspiracy theorists, including Alex Jones
Comments
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
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
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
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
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 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:
Date Completed:
Date Initiated:
Stan J. Caterbone
Advanced Media Group
scaterbone@live.com
www.amgglobalentertainmentgroup.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
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
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.
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.
In fact a working theory was filed that suggested that the East Lampeter
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.
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.
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
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.
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.
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.
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.
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?
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.
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
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.
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
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 Viewers may have attempted to connect in a more direct and continuous way
without success.
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 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.
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
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.
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.
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
Bellefonte, Pennsylvania, his hunting pants caught fire trying to stay warm.
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.
landscaping business before joining forces with John DePatto of United Financial Services and
selling residential mortgages.
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.
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.
$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.,;
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.
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
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
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.
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
Lancaster, Pennsylvania 17603
Derrick Robinson
Freedom From Covert Harassment and Surveillance
P.O. Box 9022
Cincinnati, Ohio 45209
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
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
Advanced Media Group
scaterbone@live.com
www.amgglobalentertainmentgroup.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
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
www.amgglobalentertainmentgroup.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
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
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.
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
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
# PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
"
Stan J. Caterbone
# PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
"
Pennsylvania
PPPPPPPPPPPPPPPPPPPPPPPPPP
$
Lancaster
PPPPPPPPPPPPPPPPPPPPPPPPPPPPP
19
PPPPPPP
15
June
PPPPPPPPPPPPPPPPPPPPPPP
&,PP
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
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
THE ADVANCED MEDIA GROUP
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
THE ADVANCED MEDIA GROUP
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
Commonwealth of Pennsylvania
v.
Kathleen Granahan Kane
Appellant
CASE INFORMATION
Initiating Document:
Notice of Appeal
Case Status:
Active
Journal Number:
Case Category:
Criminal
Case Type(s):
Criminal Conspiracy
Other
Perjury
CONSOLIDATED CASES
RELATED CASES
Docket No / Reason
Type
Related
SCHEDULED EVENT
Appellant
Kane, Kathleen Granahan
Pro Se:
No
IFP Status:
No
Attorney:
Minora, Amil Michael
Minora, Minora, Colbassani, Krowiak, Mattioli & Munley
Law Firm:
Address:
700 Vine St.
Scranton, PA 18510
Phone No:
(570) 961-1616
Fax No: (570) 963-1691
Attorney:
Address:
Phone No:
Attorney:
Address:
Shargel, Gerald L.
Winston & Strawn, LLP
200 Park Avenue
New York, NY 10166
(212) 294-2637
Neither the Appellate Courts nor the Administrative Office of Pennsylvania Courts assumes any liability
for inaccurate or delayed data, errors or omissions on the docket sheets.
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
Fax No:
Amicus
Caterbone, Stan J.
Pro Se:
Yes
IFP Status:
Pro Se:
Stan J. Caterbone
Address:
1250 Street
Lancaster, PA 17603
Phone No:
(717) 669-2163
Fax No:
Appellee
Commonwealth of Pennsylvania
Pro Se:
No
IFP Status:
Attorney:
Steele, Kevin R.
Address:
Montgomery County District Attorney's Office
PO Box 311
Norristown, PA 19404-0311
Phone No:
(610) 278-3098
Fax No:
Attorney:
Law Firm:
Address:
Phone No:
Fee Dt
Fee Name
04/21/2016
Notice of Appeal
Receipt No
Receipt Amt
2016-SPR-E-000686
Court Below:
County:
Order Appealed From:
Documents Received:
Order Type:
OTN(s):
CP-46-CR-0006239-2015
Lower Ct Judge(s):
Demchick-Alloy, Wendy
Judge
Neither the Appellate Courts nor the Administrative Office of Pennsylvania Courts assumes any liability
for inaccurate or delayed data, errors or omissions on the docket sheets.
85.50
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
Filed Date
Content Description
None
None
DOCKET ENTRY
Filed Date
Participant Type
Filed By
Appellant
May 2, 2016
May 5, 2016
Commonwealth of Pennsylvania
Amicus
Caterbone, Stan J.
Amicus
Caterbone, Stan J.
Other
Neither the Appellate Courts nor the Administrative Office of Pennsylvania Courts assumes any liability
for inaccurate or delayed data, errors or omissions on the docket sheets.
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
:
COMMONWEALTH OF PENNSYLVANIA :
v.
KATHLEEN KANE
2. In support of any other relief this Court deems just and proper.
The following Amicus should provide this Court with the proper jurisdiction for legal standing
to consider this Amicus according to Rule 531 of the Pennsylvania Rules of Procedure.
Page 1 of 2
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
_____
Stanley J. Caterbone, Pro Se
Freedom From Covert Harassment and Surveillance
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com
scaterbone@live.com
(717) 669-2163
Page 2 of 2
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
COMMONWEALTH OF PENNSYLVANIA :
v.
KATHLEEN KANE
saying she is in a battle with the 'old boys' network' of Pennsylvania and the MOVANT has written
extensively about this same select group over the years beginning in 1998. In an interview with
Brian Taff of WPVI on February 16, 2016 the Attorney General is quoted as saying Everybody
Page 1 of 48
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.
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.
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
/S/
Stanley J. Caterbone, Pro Se
Freedom From Covert Harassment and Surveillance
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com
scaterbone@live.com
(717) 669-2163
Page 3 of 48
Thursday,
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
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 (Stan J. Caterbone) 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 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
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.
_________________________________________________
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
/S/
Stanley J. Caterbone, Pro Se
Freedom From Covert Harassment and Surveillance
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com
scaterbone@live.com
(717) 669-2163
Page 16 of 48
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
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
Stan J. Caterbone
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane
Page 18 of 48
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
ADVANCED MEDIA GROUP
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
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.
Stan J. Caterbone/Advanced
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
In 2004 I embarked on our past endeavors in the music and entertainment industries with an emphasis
on assisting for the fair and equitable distribution of artists rights and royalties in the fight against
electronic piracy. We have attempted to assist in developing new business models to address the
convergence of physical and electronic mediums; as it displaces royalties and revenues for those
creating, promoting, and delivering a range of entertainment content via wireless networks.
In 2000 to 2002 I developed an array of marketing and communication tools for wholesalers of the
AIM Investment Group and managed several communication programs for several of the company
wholesalers throughout the United States and Costa Rica. We also began a Day Trading project that
lasted until 2004 with success.
In 1999 I developed a comprehensive business plan to develop the former Sprecher Brewery, known as
the Excelsior Building on E. King Street, in Lancaster, Pennsylvania. This plan was developed in
conjunction with the Comprehensive Economic Development Plan for the Revitalization of Downtown
Lancaster and the Downtown Lancaster Convention Center for the former Watt & Shand building.
In 1999 I contributed to the debate, research, and implementation of strategies to counter the effects
of the global Y2K threat to the worlds computer technologies. I attended the U.S. Sponsored Y2K
symposium and Conference in Washington, D.C. hosted by the Senate Y2K Subcommittee and Senator
William Bennett.
In 1998 I had began to administer the charity giving of Toms Project Hope, a non-profit organization
promoting education and awareness for mental illness and suicide prevention. We had provided funding
for the Mental Health Alliance of Lancaster County, Contact Lancaster (The 24/7 Suicide Prevention
Hotline), The Schreiber Pediatric Center, and other charitable organizations and faith based charities.
The video "Numbers Don't Lie" have been distributed to schools, non profit organizations, faith based
initiatives, and municipalities to provide educational support for the prevention of suicide and to bring
awareness to mental illness problems.
In 1996 I had done consulting for companies under KAL, Inc., during the time that I was controller of
Pflumm Contractors, Inc., I was retained by Gallo Rosso Restaurant and Bar to computerized their
accounting and records management from top to bottom. I had also provided consulting for the
computerization of accounting and payroll for Lancaster Container, Inc., of Washington Boro. I was
retained to evaluate and develop an action plan to migrate the Informations Technologies of the Jay
Group, formally of Ronks, PA, now relocated to a new $26 Million Dollar headquarters located in West
Hempfield Township of Lancaster County. The Jay Group had been using IBM mainframe technologies
hosted by the AS 400 computer and server. I was consulting on the merits of migrating to a PC based
real time networking system throughout the entire organization. Currently the Jay Group employees
some 500 employees with revenues in excess of $50 Million Dollars per year.
In 1993 I was retained by Pflumm Contractors, Inc., as controller, and was responsible for saving the
company from a potential bankruptcy. At that time, due to several unpaid contracts, the company was
facing extreme pressure from lenders and the bonding insurance company. We were responsible for
implementing computerized accounting, accounting and contract policies and procedures, human
resource policies and procedures, marketing strategies, performance measurement reporting, and
negotiate for the payment of unpaid contracts. The bonding company was especially problematic, since
it was the lifeline to continue work and bidding for public contracts. The Bank of Lancaster County
demanded a complete accounting of the operations in order to stave off a default on the notes and loans
it was holding. We essentially revamped the entire operation. Within 3 years, the company realized an
increase in profits of 3 to 4 times its previous years, and record revenues.
Stan J. Caterbone/Advanced
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
In 1991 I was elected to People to People International and the Citizen Ambassador Program, which
was founded by President Dwight D. Eisenhower in 1956. The program was founded to To give
specialists from throughout the world greater opportunities to work together and effectively
communicate with peers, The Citizen Ambassador program administers face-to-face scientific, technical,
and professional exchanges throughout the world. In 1961, under President John F. Kennedy, the State
Department established a non-profit private foundation to administer the program. We were scheduled
to tour the Soviet Union and Eastern Europe to discuss printing and publishing technologies with
scientists and technicians around the world.
In 1990 I had worked on developing voice recognition systems for the governments technology think
tank - NIST (National Institute for Standards & Technology). I co-authored the article Escaping the Unix
Tar Pit with a scientist from NIST that was published in the magazine DISC, then one of the leading
publications for the CD-ROM industry. Today, most all call centers deploy that technology whenever you
call an 800 number, and voice recognition is prevalent in all types of applications involving
telecommunications.
In 1989 I had founded Advanced Media Group, Ltd., and was one of only 5 or 6 U.S. domestic
companies that had the capability to manufacture CD-ROM's. We did business with commercial
companies, government agencies, educational institutions, and foreign companies. I performed services
and contracts for the Department of Defense, NASA, National Institution of Standards & Technology
(NIST), Department of Defense, The Defense Advanced Research Projects Agency (DARPA), and the
Defense Mapping Agency, Central Intelligence Agency, (CIA), IBM, Microsoft, AMP, Commodore
Computers, American Bankers Bond Buyers, and a host of others. I also was working with R.R,
Donnelly's Geo Systems, which was developing various interactive mapping technologies, which is now a
major asset of Map Quest. Map Quest is the premier provider of mapping software and applications for
the internet and is often used in delivering maps and directions for Fortune 500 companies. We had
arranged for High Industries to sell American Helix, the manufacturer of compact discs, to R.R. Donnelly.
We had brokered a deal and the executives from Donnellys Chicago headquarters flew to Lancaster to
discuss the deal and perform due diligence of the manufacturing facility located in the Greenfield
Industrial Park.
In 1987 Power Station Studios of New York and Tony Bongiovi retained me as executive producer
of a motion picture project. The theatrical and video release was to be delivered in a digital format; the
first of its kind. We had originated the marketing for the technology, and created the concept for the
Power Station Digital Movie System (PSDMS), which would follow the copyright and marketing formula
of the DOLBY technology trademark.
We had also created and developed marketing and patent research for the development and
commercialization of equipment that we intended to manufacture and market to the recording industry
featuring the digital technology. Sidel, Gonda, Goldhammer, and Abbot, P.C. of Philadelphia was the lead
patent law firm that We had retained for the project. Power Station Studios was the brainchild of Tony
Bongiovi, a leading engineering genius discovered by Motown when he was 15. Tony and Power Station
Studios was one of the leading recording studios in the country, and were responsible for developing Bon
Jovi, a cousin. Power Station Studios clients included; Bruce Springsteen, Diana Ross, Cyndi Lauper,
Talking Heads, Madonna, The Ramones, Steve Winwood, and many others. Tony and Power Station
Studios had produced the original Sound Track for the original Star Wars motion picture. It was
released for distribution and was the number one Sound Track recording of its time.
Tony Bongiovi was also active in working and researching different aerospace technologies. * We had
developed and authored a Joint Venture Proposal for SONY to partner with us in delivering the Digital
Movie and its related technologies to the marketplace. The venture was to include the commercialization
of technologies, which Tony Bongiovi had developed for the recording industry simultaneously with the
release of the Digital Movie.
Stan J. Caterbone/Advanced
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
I also created the concept for the PSDMS trademark, which was to be the Trademark logo for the
technology, similar to the DOLBY sound systems trademark. The acronyms stand for the Power Station
Digital Movie System. Today, DVD is the mainstay for delivering digital movies on a portable medium, a
compact disc.
In 1987 I had a created and developed FMG Mortgage Banking, a company that was funded by a major
banking firm in Houston Texas. We had the capability to finance projects from $3 to $100 million dollars.
Our terms and rates were so attractive that we had quickly received solicitations from developers across
the country. We were also very attractive to companies that wanted to raise capital that include both
debt and equity. Through my company, FMG, we could raise equity funding through private placements,
and debt funding through FMG Mortgage Banking. We were retained by Gamillion Studios of Hollywood,
California to secure financing of their postproduction Film Studio that was looking to relocate to North
Carolina. We had secured refinancing packages for Norris Boyd of and the Olde Hickory and were in the
midst of replacing the current loan that was with Commonwealth National Bank. We had meetings and
discussions with Drew Anton of the Eden Resort, for refinancing a portion of his debt portfolio. We were
quickly seeking commitments for real estate deals from New York to California. We also had a number of
other prominent local developers seeking our competitive funding, including Owen Kugal, High
Industries, and the Marty Sponougle a partner of The Fisher Group (owner of the Rt. 30 Outlets). We
were constantly told that our financing packages were more competitive than local institutions.
In 1986 I had founded Financial Management Group, Ltd (FMG); a large financial services organization
comprised of a variety of professionals operating in one location. We had developed a stock purchase
program for where everyone had the opportunity for equity ownership in the new firm. FMG had
financial planners, investment managers, accountants, attorneys, realtors, liability insurance services,
tax preparers, and estate planners operating out of our corporate headquarters in Lancaster. In one
year, we had 24 people on staff, had approximately 12 offices in Pennsylvania, and
several satellite offices in other states. We had in excess of $50 million under management, and our
advisors were generating almost $4 million of commissions, which did not include the fees from the
other professionals. We had acquired our own Broker Dealer firm and were valued at about $3 to $4
million.
In 1985 I developed the Easter Regional Free Agent Camp, the first Free Agent Camp for the
Professional Football industry; which was videotaped for distribution to the teams scouting departments.
(See Washington Post page article of March 24, 1985) Current camps were dependant on the team
scouts to travel from state to state looking for recruits. We had developed a strategy of video taping the
camp and the distributing a copy, free of charge to the teams, to all of the scouting departments for
teams in all three leagues FL, CFL and WFL. My brother was signed at that camp by the Ottawa
Roughriders of the CFL, and went on to be a leading receiver while J.C. Watts was one of the leagues
most prominent quarterbacks. My brother also played 2 years with the Miami Dolphins while Dan Marino
was starting quarterback. We were a Certified Agent for the National Football League Players
Association. Gene Upshaw, the President of the NFLPA had given me some helpful hints for my camp,
while we were at a Conference for agents of the NFL. The Washington Post wrote a full-page article
about our camp and associated it with other camps that were questionable about their practices.
Actually, that was the very reason for our camp. We had attended many other camps around the
country that were not very well organized and attracted few if any scouts. We had about 60 participants,
with one player coming from as far away as Hawaii. We held the camp at Lancaster Catholic, with a
professional production company filming the entire camp, while I did the editing and produced the video.
The well respected and widely acclaimed professional football scout, Gil Brandt, of the Dallas Cowboys,
had given me support for my camp during some conversations We had with him and said he looked
forward to reviewing the tapes for any hopeful recruits.
Stan J. Caterbone/Advanced
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
In 1985 I was elected Vice President of the Central Pennsylvania Chapter of the International
Association of Financial Planners, and helped build that chapter by increasing membership 3to 4 times.
We had personally retained the nationally acclaimed and nationally syndicated Financial Planner, Ms.
Alexandria Armstrong of Washington D.C.; to host a major fundraiser. More than 150 professionals
attended the dinner event that was held at the Eden Resort & Conference Center. Ms. Armstrong
discussed financial planning and how all of the professions needed to work together in order to be most
effective for their clients. We attracted a wide variety of professionals including; brokers, lawyers,
accountants, realtors, tax specialists, estate planners, bankers, and investment advisors. Today, it has
become evident that financial planning was the way of the future. In 1986 executives approached us
from Blue Ball National Bank to help them develop a Financial Planning department within their bank.
In 1984 I had helped to develop strategic planning for Sandy Weill, former President of Citi Group (the
largest banking entity in the U.S). We were one of several associates asked to help advise on the future
of Financial Planning and how it would impact the brokerage and the investment industry at large. Mr.
Weil was performing due diligence for the merger of American Express and IDS (Investors Diversified
Services). We were at that time a national leader in the company in delivering Fee Based Financial
Planning Services, which was a new concept in the investment community and mainstream investors.
That concept is now widely held by most investment advisers.
Stan J. Caterbone, Pro Se Litigant
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
Stan J. Caterbone/Advanced
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page27
6 of 48
6
Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016
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
ADVANCED MEDIA GROUP
Stan J. Caterbone
Superior
Superior
Court
CourtNo.
1164
8423-15
Story
Amicus
and
Amicus
Evidence
re Kathleen
of Kane
a TI
Targeted
Page
Page
Individual
291of
of48
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
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
Circuit Court of Appeals and in February of 2016 Lisa Michelle Lambert published her book titled
Corruption in Lancaster County My Story, which is available in bookstores and on Amazon.com. I
am in frequent contact with her co-author, Dave Brown of Philadelphia, Pennsylvania.
In 2009 I Proposed an ORGANIZED STALKING AND DIRECTED ENERGY WEAPONS HARASSMENT
BILL to Pennsylvania House of Representative Mike Sturla (Lancaster, Pennsylvania) and City of
Lancaster Mayor Richard Gray in 2009. The draft legislation is the work of Missouri House of
Representative Jim Guest, who has been working on helping victims of these horrendous crimes for
years. The bill will provide protections to individuals who are being harassed, stalked, harmed by
surveillance, and assaulted; as well as protections to keep individuals from becoming human research
subjects, tortured, and killed by electronic frequency devices, directed energy devices, implants, and
directed energy weapons. I again reintroduced the bill to the Pennsylvania General Assembly in 2015
and frequented the Pennsylvania Capitol trying to find support and a sponsor; which I still do to this
day.
In 2005 I, as a Pro Se Litigant filed several civil actions as Plaintiffs in the United
States District Court for the Eastern District of Pennsylvania, the United States Third District
Court of Appeals, the Pennsylvania Supreme Court, The Pennsylvania Superior Court, the
Commonwealth Court of Pennsylvania, The Court of Common Pleas of Lancaster County,
Pennsylvania. These litigations included violations of intellectual property rights, anti-trust
violations, and interference of contracts relating to several business interests, harassment,
extortion, fraud, etc.,. . Central to this litigation is the Digital Movie, Digital Technologies,
Financial Management Group, Ltd,/FMG Advisory, Ltd., and its affiliated businesses along
with a Federal False Claims Act or Federal Whistleblowers Act regarding the firm of
International Signal and Control, Plc., (ISC) the $1Billion Dollar Fraud and the Export
violations of selling arms to South Africa and Iraq. This litigation dates back to 1987. In
1987 I microfiched some 10,000 pages of documents that prove this story without any doubt.
I also have recorded conversations of persons and government officials.
Stan J. Caterbone, Pro Se Litigant
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
Stan J. Caterbone
Superior
Superior
Court
CourtNo.
1164
8423-15
Story
Amicus
and
Amicus
Evidence
re Kathleen
of Kane
a TI
Targeted
Page
Page
Individual
302of
of48
29
Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
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
Stan J. Caterbone Affidavit
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
Stan J. Caterbone Affidavit
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
Stan J. Caterbone Affidavit
! "
"
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
Stan J. Caterbone Affidavit
<
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
Stan J. Caterbone Affidavit
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
Stan J. Caterbone Affidavit
&
, * "
&&
*#
"
&:
;!
&<
:
%
$
&, ,
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
Stan J. Caterbone Affidavit
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
Stan J. Caterbone Affidavit
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
Stan J. Caterbone Affidavit
!
* , "
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
"
Pennsylvania
PPPPPPPPPPPPPPPPPPPPPPPPPP
$
Lancaster
PPPPPPPPPPPPPPPPPPPPPPPPPPPPP
19
PPPPPPP
15
June
PPPPPPPPPPPPPPPPPPPPPPP
&,PP
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
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
THE ADVANCED MEDIA GROUP
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
THE ADVANCED MEDIA GROUP
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
Sammy Caterbone (Brother) Affidavit
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
Sammy Caterbone (Brother) Affidavit
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
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
ALTERNATIVES
TAKE ACTION
ORDER
< ;
$$!##!
($
))
* #
!
(
Restoring Human Rights and
Dignity to the Field of Mental
Health
'#/
, #!
About Us
Accomplishments
Message from the President
Board of Advisors
)#+
'
'#/
) . )! ! / (
'!
# % ##
#!
(
//
))
! (
$ !
$( )
!
! ! #!
'
!#
)!
!
(
#!# (
))
#+
'
.
,! #
')
!
$ !
#
! (
&
! (
))
#+
0 '#/
* !
, #
.! !
)+
!. #
'
#
' )! !
#+
!#)
)
.
))/ '
.!#
.
$
# /
')
#+ )
!# # *
!#
!
(
/$
!#
!# #+ ) */
!
! ))/ ! (
( 1#/
#
#!
6# 7
#+
( ##
!#9 2 '
#!
# ))
!#0# (
$
* /
'! !
!#
# 5
'! !
3'
#!
0!
) ( 4 !#
+ % & ))
( #
# ( * '#/
!# #+ '#/
!# (
.! *+ %7&
# !,
'
$
#
# ) )/
!.!)
!#
))
)8
0
*
$ , #!.
+*
# / #
!# #
)/ #0 !(
% &
)!
)
)# (
,)
, !
#+ # !
!# * ,#!
# #
)3
# $
( ##!
!.!
#*
!# #+
!" !
$ ) !,!))!
0
$
(!
#+ !
## '
') (
,! )
' !
#+ ,
What is CCHR?
'
)!
$
( #
' !
, #! !
)
#+ # !
(! $
!#0# ( '#/
'
+ ( )) ! (
)+ !.!)
! 3'
#+
#!#+
!$ *
!
! #
$$!##!
,/
# # ) )/ #
)# !
)! !
)!$!
!. #
#!
,/
Order a Free
Citizens Commission on
Human Rights Information Kit
" #"
( ))
+,
!
$ #
& !#
) )
( ##!
/ ( '#/
#2
# !''
'
+!
#%
- ) *# '
#)
)
! !$
)) . !) ,) $
)'!
!. '
(! )
$
#!,) (
$ !
()!
, !
%2&
$( )
Leadership
#*
CCHR Financials
! (
$ !
$!
#(
( )) ! (
!
# *!
'#/
. #
#
!
!
!
(! )
($
# #
# ! 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
Stanley J. Caterbone
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
__________________________________________________________________________
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
__________________________________________________________________________________
_________/s/_______________
Date: February 20, 2007
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1299
297 of
of1299
2301
__________________________________________________________________
TABLE OF CONTENTS
_____________________________________________________________
I.
II.
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.
shareholder in 1987 involving the United States Defense Contractor International Signal & Control,
Plc., known as ISC. In 1992, International Signal & Control was indicted and found guilty of among
other things a Billion Dollar Fraud and export violations concerning illegally shipping cluster bomb
technologies, missile defense systems, and other defense systems to foreign interests including South
Africa, Iraq and Saddam Hussein. Cluster bombs and related technologies are known to have been
exported to Iraq by the Chilean Arms Dealer Carlos Cardoen, a joint venture partner of International
Signal & Control.
program to arm Iraq during the 1980s with close ties to International Signal & Control, which
allegedly included the help of the National Security Agency, a former end user of International Signal &
Control technologies under the early 1980s program Project X. A Presidential Finding in 1984 by the
Bush Administration was executed to implement the program of arming Saddam Hussein and Iraq with
the cluster bomb technologies. Serious allegations of these programs were the focus of investigations
that included the knowledge and supervision of then appointed nominee for the Director of Central
Intelligence Agency, Robert M. Gates.
Since 1987, Stanley J. Caterbone has been the victim of vast civil conspiracy that started in
1987 to cover-up allegations of fraud within International Signal & Control during the negotiations and
merger of International Signal & Control and Ferranti International of England. Stanley J. Caterbone
alleges that warrantless surveillance was used to obstruct justice and moot his constitutional rights in
an effort to divert attention away from his allegations of fraud within International Signal & Control
back in 1987, and afterwards to the present as a means to deny his access to the courts for remedy
and relief, and Federal False Claims Act violations. The business of Advanced Media Group has been
greatly compromised and intellectual property stolen during the late 1980s and early 1990s that
included information technology contracts with the United States Government.
In January of 2006, Stanley J. Caterbone was detained at every airport security check point,
which was during a policy of random checks, and taken out of line during travel from Philadelphia,
Pennsylvania, to Houston, Texas, and on to Puerto Vallarta, Mexico. At the Houston Airport, Stanley J.
Caterbone was falsely accused of carrying plastics explosives and taken to an interview room by
Homeland Security officials. Stanley J. Caterbone was also detained for three days in Mexico, and was
not provided with an opportunity to gain access to a flight out of the country by Mexican Officials.
Page 3 of 20
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.
universally applied to all government officials in all branches of government. The Federal False Claims
Act and its provisions protect individuals from abuse of power, while providing relief and remedies for
those that were wronged and those that had the courage to cite a wrong.
It is too easy for present and future administrations to abuse their power and utilize
warrantless surveillance as a means of subverting and obstructing justice for those that are engaged in
Whistle-Blowing cases that concern National Security.
review, a Whistle Blower can be place on terrorist lists for malicious reasons without the knowledge or
just cause. This is in direct conflict with keeping our democracy free of corruption while adhering to
the spirit of the constitution in the manner our founding fathers envisioned.
Page 4 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1302
300 of
of1299
2301
__________________________________________________________________________
__________________________________________________________________
Background Information: The following transcripts from National Broadcast Television, ABC News
Nightline and ABC News 20/20; provide material information as to the activities of International Signal
& Control and the importance of these matters with regard to National Security.
ABC NEWS 20/20 FEBRUARY 1, 1991
[Lynn Sherr ABC News 20/20 Correspondent] This is the story of how this deadly weapon,
designed for the U.S. military made its way form this country to Iraq. And how American Soldiers may
face the devastation of a cluster bomb if a ground war breaks out in the Persian Gulf. Federal Officials
believe Saddam Hussein got his arsenal thru a lethal combination bureaucratic foul ups in the U.S.
Government and simple greed.
Here is how the cluster bomb works. An artillery shell, an airplane, or a rocket launcher sends the
bombs toward their targets.
grenades. Cluster bombs can be used against ground troops or tanks, and can even scatter mines to
lie dormant for days. The bombs can spray thousands of pounds of sharp objects pins or even razor
blades. The shrapnel can rip through anyone or anything in its way, causing massive casualty among
civilians or ground troops.
You can see the destruction in these buildings in Lebanon after a cluster
bomb attack.
How did Iraq obtain the cluster bombs and the ability to make their own? It was incredibly simple.
Investigators believe it started with International Signal & Control, A government contractor with
5,000 employees based in Pennsylvania, which build key components of cluster bombs in a subsidiary
in California. 20/20 has learned Federal Investigators believe ISC provided the technology, that is the
plans, to this man, Carlos Cardoen, Chilean arms dealer.
If the cluster bomb technology actually left the county, that is illegal
without U.S. Government permission, investigators say ISC never got. It is also illegal for a foreigner,
like Cardoen, to take the plans out of the United States without a license, which sources tell us, he
never obtained. The man who opened the door to Iraq for Cardoen, was this man Nasser Bedouin. He
is a Lebanese born middleman for Cardoen who is based in the United States. Bedouin traveled often
to Bagdad, and arranged for sale cluster bombs and other military hardware to Saddam Husseins
army. In his first television interview, he told us about the business of dealing in deadly weapons.
Page 5 of 20
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.
willing to take its share in helping Iraq in its time of need. We can provide you with our cluster bombs
at the lowest possible price. According to these contracts the sale of cluster bombs to Iraq was an
extremely lucrative business. February 24, 2984 3,000 cluster bombs sent to Saddam Husseins army
worth $21 million dollars.
dollars.
A few months later, another 3,000 cluster bombs, another $21 million
The supply of cluster bombs eventually totaled more than $400 million dollars.
In fact,
That was one of the first attacks by the military when the attack began.
Its unknown
But why didnt they find out about him sooner? He has been selling cluster
bombs to Iraq for nearly a decade. The U.S. Patent Office knew about Cardoen back in 1986. But
they didnt tell anyone else in the Federal Government about them. In a move that went apparently
unchecked in the highest levels of the government, Cardoen applied for his own patent for cluster
bombs in 1986. Based on some changes on previous designs, he received the patent two years later.
Getting the Patent is not illegal. But at a time when U.S. shipments of arms to Chile were banned, as
to all sales to Iraq, Why didnt the Patent Office raise any questions why was this foreigner dealing in
U.S. arms?
Page 6 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1304
302 of
of1299
2301
State, and Defense, are supposed to control arms sales, and communicate with one another.
[Anthony Cordazman, Correspondent] - Even today, the same squabbling goes on, every day
within the Commerce, State, and Defense. The Administration can never agree on what
kinds of laws
weapons are wrong. But they are a fact. And we have to live with facts.
The former head of ISC, James Guerin, who dealt with Chilean, said he did not provide anything to Cardoen to build
weapons. But Nasser Bedouin tells a different story.
[Nasser Bedouin, Arms Dealer] I believe that Dr. Carlos Cardoen got the plans to build the
cluster bombs from the United States.
[Lynn Sherr ABC News 20/20 Correspondent] Questions about the cluster bombs come at a
time when questions are being focused on how so many American designed weapons got into the
hands of Saddam Hussein. Senator John McCain.
[Senator John McCain] Theres not just one Saddam Hussein on this globe. Theres lots and lots
of them who at this time as we speak are acquiring technologies to give them the capabilities of
weapons of mass destruction because its a way of gaining victory on the cheap.
[Lynn Sherr ABC News 20/20 Correspondent] McCain has introduced legislation that would
severely penalize and company or countries that would sell weapons illegally or harbor arms dealers.
[Senator John McCain] To provide many of the kinds of weapons that we have today to many
nations, which are clearly offensive in nature, and are clearly far exceed their requirements to defend
themselves, is frankly unconscionable and must be brought to a stop.
[Lynn Sherr, ABC News 20/20 Correspondent] Basically what you are saying is hit them in the
pocketbook.
Page 7 of 20
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
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.
Precisely so that
Page 10 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1308
306 of
of1299
2301
His
connection with Robert Gates has not. By the mid 1980s Cardoen was the largest private supplier of
weapons to Iraq.
In all he has believed to ship a half billion dollars worth of arms and advanced
technologies to Bagdad.
thousands of bombs and other equipment, absolutely essentially to Iraq during its eight year war with
Iran.
The material would be loaded aboard regular Iraqi airway flights flown from Santiago to Bagdad.
Cardoen did not simply ship weapons, he set up entire factories capable of producing bombs and other
explosives the components would be shipped from all over the world and then assembled in Iraq. One
of those factories turned out Cluster Bombs.
As we first reported on the 24th of May, much of the sophisticated military technology that Cardoen
was shipping to Iraq came from the United States. This company in sleepy Lancaster, Pennsylvania, is
believed to be the source for some of the Cluster Bomb technology. But there was more.
Nasser
Bedouin is also an arms dealer. He acted as a middleman between Carlos Cardoen and Iraq.
[Nasser Bedouin on Video] I am aware of Carlos Cardoen getting some type of technology from
the air fuel bomb from the United States. I believe Iraq has a viable fuel air explosive.
[Ted Koppel] These explosives are designed to explode just above ground level like miniature
atomic bombs, literally sucking all available oxygen out of the air. It is clear that Carlos Cardoens
special relationship with the United States was not known by all Departments. When the Commerce
Department inquired about that relationship in early 1987, it received a cable from the U.S.
Ambassador to Chile saying although Cardoen is involved with the sale of armaments, and he has
made his fortune from it, he is considered to be a responsible recipient of U.S. products. In fact by
1987, the covert relationship between the CIA and Cardoen was already well established.
In 1983 the Reagan Administration had become alarmed at how poorly the Iraqi military was doing
against Iran. A decision was made at the highest level of Government to begin helping Iraq.
Indeed ABC News has learned only today, that around that time, in 1983 Ronald Reagan issued a
highly classified Presidential Finding stating that it was important to the National Interests that arms
and technical assistance be covertly funneled to Iraq
More on the
Page 11 of 20
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.
Program to Iraq, the CIA took over. In effect the former CIA operative told us the covert operation
amounted to here is what we want you to do, and we really dont want to know too much about how
you do it.
Our source tells us that he has at least one meeting in 1986 in Florida between Robert Gates and
Carlos Cardoen, the Chilean Arms Dealer. Other sources have told us of other such meetings. Here in
the United States and in Europe. Which brings us to an unsolicited statement that was telephoned in
to Nightline from the Central Intelligence Agency almost a month ago on June 17th. Allegations, the
statement read that Robert Gates facilitated illegal shipments to Iraq during the 1980s are totally
without basis. Since we had never requested a statement of Mr. Gates, we didnt know quite what to
make of it at the time. But then today we learned of that Presidential Finding, authorizing the Covert
shipment of arms to Iraq.
It would be true then that Robert Gates did not facilitate illegal shipments to Iraq, under the
Presidential Finding, the shipments would have been quite legal.
confirmation hearings, back in 1987, Robert Gates assured the Senate Confirmation Committee that he
would always keep the Committee current on ongoing covert operations. Indeed the CIA is supposed
to provide the Intelligence Committee with quarterly reports. According to well-informed sources on
the Committee it has had no briefings on the Covert arms pipeline to Iraq.
the Committee would be a total breach of trust. What would it do to the Gates Nomination? I asked.
It would probably be enough said the Senator, to derail the Nomination.
Again, an excerpt from Mr. Gates Testimony before the Senate Intelligence Committee in 1987:
[Robert Gates 1987 on video] If you cannot have a system in which you can have some
confidence between A the branches of government, and confidence between the senior officials of the
Government, A that they abide by the rules, and B that they will deal with one another honestly, then
I think the system begins to collapse.
Page 12 of 20
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.
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.
House, the people in that room representing the President argued for a policy that assisted Saddam
Hussein in getting dual use technologies. We had Congressman Rose who I know has been on your
show testifying about the grain sales being tied up with funding weapons to Iraq as well. So across
the government, this thing went on. Its hard to believe that somebody like Mr. Gates in his position
didnt know about it.
[Ted Koppel] We are suggesting a lot more that he knew about it. Were suggesting that he was
actively involved in it let me just pass on a little information that we have gathered today, having to
do with the Confirmation Hearings and was told earlier this afternoon. Alan Fryers, Senior Officer with
the CIA and Clair George are not likely to be testifying voluntarily, indeed Alan Fryers said he will not
be testifying before the Senate Intelligence Committee.
throughout the day is putting on some pressure to get those Hearings underway before the August
recess, August 2nd, of course, the Senate goes into recess. Ah, and there are indications now that a
week from Monday, indeed the Hearings will begin, Mr. Gates will be asked to testify at that time, but
Ive been also told that there is no way that the Hearing will no way be completed before the August
recess.
And that Mr. Gates will be told that he will be recalled again
testified, after the August recess. So these Hearing now, are destined to go into September.
[House Representative Sam Gejdenson of the House Foreign Affairs Committee] I think that
is terribly important, because we have to what we have to remember here, unlike other appointees of
the President, what the head of the CIA does is not transparent. If youre the Secretary of Housing,
like Jack Kemp is, and I disagree with one of his programs, not only do I know about it, but the
average citizen knows about what Jack Kemps doing. Sometimes you agree with it and sometimes
you disagree with him. In the case of the Director of the CIA, as is clear from repeated experiences,
often times even the people in Congress were suppose to know about these activities are not
informed. This has to do with National Security the standard ought not be somebody that can get by
the Hearing process with White House pressure. The White House ought to be with us on this one, we
ought to make sure that we have someone fully discloses what is going on to the appropriate
committees and to Congress. Not someone involved in Iran Contra and not someone who hasnt told
the entire truth. And not someone who is in question about these activities. This has to be a definitive
decision by the Congress, that this individual will come clean with the Congress and fulfill not just the
letter of the law, but the spirit of the law.
Page 15 of 20
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.
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.
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.
Management Group, Ltd., and President of FMG Advisory, Ltd.,] - Chem Con is the big local
minority-held corporation that was doing a lot of Defense contracts-it was associated with ISC. They
went under last spring, beginning of the summer, and there was a lot of criminal allegations made,
none of them substantiated. And I was connected with that. They sent a board member in to see me a
week before this happened. Why. I don't know. Jim Christian owned it - now I hear rumors that I was
tied to ISC and I am close to several people in that organization. Why they sent someone in to
California to see me, I don't know. They wouldnt answer me. They wanted me to talk to a guy from
D.C., New York, a guy from the Caribbean. I don't know what the hell is going on.
[Mr. Robert Byer, Criminal Attorney for Stanley J. Caterbone] the supposition was - I don't
know how true it was a front for ISC.
[Stanley J.
Management Group, Ltd., and President of FMG Advisory, Ltd.,] - It was, I'll tell you why.
Because when Chem Con was started, back to their inception, you look at ISC's books. They didn't
have any money. Well, the fist thing Chem Con did was they went and got all that free money from
the government and you look where that money went. I bet I know where it went. This guy named
Guerin, James Guerin. And I know that they were selling contracts back. He runs ISC and he also has
his fingers pretty deeply into Chem Con. He's the one who started Chem Con, Guerin is the one who
started it.
[Mr. Millard (Bill) Johnson, Client of Mr. Stanley J. Caterbone] - Wasn't there some allegations
about a tie to Wedtech? (Defense Contractor of New York)
[Stanley J.
Management Group, Ltd., and President of FMG Advisory, Ltd.,] - You bet. They were tied, you'd
better believe they were tied with Wedtech. The same guys in Wedtech were invoked with ISC and
Chem Con.
ISC is sold over the London Exchange. (I bought my shares from Pennsylvania State
Senator Gibson Armstrong) I owned a thousand shares. I sold it when things started to hit the fanthey just did a multimillion dollar merger with a company in London. They probably think this is going
to cover their tracks. What they did was, they fronted all that money and started the contracts, went
bankrupt, and now the government is stuck for $18,000,000.
viewpoint, I stole money, I am insane, and I am a lunatic I tell you I will not condemn Jim Christian
until he tells to my face what happened. "I was framed and set up. I dont know maybe Jim Christian
doesn't have the money. Maybe Guerin has it or somebody else has it.
Advanced Media Group
Page 18 of 20
02/21/2007
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,
Washington, DC 20005
(202) 580-6920
Donald B. Verrilli, Jr.
JENNER & BLOCK LLP
S. 800 Suite 1200 South
Washington, DC 20005
(202) 639-6095
JENNER & BLOCK LLP
330 N. Wabash Avenue
N. W. Chicago, IL 60611
(312) 222-9350
Randy Gainer
Davis Wright Tremaine LLP
1501 Fourth Avenue, Suite 2600
Seattle, WA 98101 - 1688
Douglas N. Letter
Thomas N. Bondy
Anthony A. Yang
Attorneys, Appellate Staff
Washington, DC 20530
Civil Division, Room 7513
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530
____________/s/________________
Stanley J. Caterbone, Pro Se Litigant
1250 Fremont Street
Lancaster, PA 17603
717-427-1821 facsimile
Page 20 of 20
02/21/2007
January January
Sunday
22, 201722, 2017
Page
Page1318
316 of
of1299
2301
BAUSMAN MPO
Product
Descri p t i on
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.
x
X
St
Issue PVI :
Total :
Paid by:
Cash
Change Due:
Bi l I # : 1000200788239
Clerk: 03
January January
Sunday
22, 201722, 2017
Page
Page1319
317 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1320
318 of
of1299
2301
www.amgglobalentertainmentgroup.com
mailto:amgroup01@msn.com
717.427-1621 Fax
Stanley J. Caterbone
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
Respectfully,
Stan J. Caterbone
Pro Se Lititgant
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
Stan J. Caterbone LAMBERT CASE FILE
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
Stan J. Caterbone LAMBERT CASE FILE
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
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
:
:
CD 6 208A
Respectfully Submitted:
__________________
__________________
SSS
Stanley J. Caterbone, Pro Se
Project Hope Foundation
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com
Page 1 of 35
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
Page 8
Page 11
5. CERTIFICATE OF SERVICE
Page 12
6. EXHIBITS ___
Page 13
Page 13
Page 16
Page 29
f.
Page 22
Page 24
Page 28
Page 33
Page 2 of 35
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.
known law expert and constitutional scholar Jonathan Turnley on December 19, 2007 days after
the conclusion of the trial. Jonathan Turley, like other national experts, had posted an opinion on
the Lippiatt case after the verdict and conclusion of the trial. The response is EXHIBIT A.
CATERBONE has been involved with Project Hope Foundation for more than 10 years and
has conducted extensive research in the field of mental illness and has been an advocate for
mental illness for almost 3 decades.
1960s and has been an extremely challenging dilemma resulting in the untimely and suspicious
deaths of two brothers in their 30s.
Christmas day of 1984 with the death being ruled a suicide, but now known to have been a
murder. In 1996 his youngest brother, Tom had committed suicide and the circums tances are
currently being litigated in the federal courts as a wrongful death complaint.
CATERBONE has
researched and investigated the causes of both deaths as it relates to the issue of mental illness
and has conducted research and instigations into his own malicious diagnosis of his own mental
health record. His father, Samuel, has a history of mental health records however; he too has a
history of psychic phenomena and a history of suspicious activities with the United States
Government and the Lancaster community. His mental health record is also in dispute. He was a
very successful businessman and had served in the U.S. Navy as a radioman and graduated from
gunner school with honors. He also developed new technologies for the Dry Cleaning industry. He
has also conducted extensive research into areas concerning U.S. Government activities.
CATERBONE has developed relationships with mental health professionals for his work with
Project Hope and has been the main person responsible for coordinating and administrating the
mission of creating awareness and education to the community-at-large with the distribution of
Project Hopes video Numbers Dont Lie; including to the Mental Health and Retardation
Department of the County of Lancaster this past year. CATERBONE has worked extensively with
Contact Lancaster, the Mental Health Alliance of Lancaster County, and other mental health
organizations as well faith based organizations.
professionals and organizations in the field; especially since C. EvreTt Koop, the former U.S.
Surgeon General and Tipor Gore made mental health awareness a top priority in 1998. Tipor Gore
also received the Project Hope video for distribution as a resource for other non-profit
organizations. CATERBONES research includes national and local trends of suicides; symptomatic
Page 3 of 35
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,
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:
www.amgglobalentertainmentgroup.com
PROJECT HOPE
Project Hope Foundation was founded in 1996 after the untimely suicide of Thomas P. Caterbone,
brother of Stanley J. Caterbone.
W. Caterbone of Austin Texas, and other friends and relatives that wanted to continue the legacy
of Tom Caterbone and make a contribution to the community-at-large in dealing with mental
health issues and mental health awareness.
In 1996 Project Hope Foundation produced the extremely successful instructional video Numbers
Dont Lie for helping teenagers deal with suicide and help them to identify kids which may be at
risk. The video was produced and directed by Dr. Phil Caterbone & Psychologist Craig Crabtree,
both of Austin, Texas. The video is a approximately 20 minutes and is accompanied by an
instructional workbook for the monitors and a workbook for the students. "Numbers Don't Lie"
has been sold to the Texas School Board of Education to pay for its development and production.
The video has been provided to other Faith Based non-profit organizations, school districts, church
groups, and municipalities by CATERBONE and Advanced Media Group over the past 10 years.
The video can be viewed online at: www.advancedmediagroup.youtube.com and clic king on the
Numbers Dont Lie video.
Project Hope provided funding for the Mental Health Alliance of Lancaster County, Contact/Lifeline
of Lancaster (The 24/7 Suicide Hotline), The Schreiber Pediatric Center, and other charitable
organizations and faith based charities. In 1999 Project Hope donated and constructed a soccer
field on the new Headquarters of the Schreiber Pediatric Center on Goods Road, in Lancaster.
Tom's Project Hope is funded by an annual golf tournament on the 1st Saturday in August, called
the Tommy Caterbone Memorial Golf Tournament.
The Lancaster County Mental Health/Mental Retardation department is currently using the video
as a resource Mental Health/Mental Retardation Department.
ADVANCED MEDIA GROUP
In 1989 CATERBONE founded Advanced Media Group, Ltd., which was one of only 4 or 65
U.S. domestic companies that had the capability to manufacture CD-ROM's.
Advanced Media
Group also developed tools, applic ations, and provided consulting to information technologies.
Page 5 of 35
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.
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
SECTION 304 OF THE PENNSYLVANIA MENTAL HEALTH PROCEDURES ACT P.S. 7304 IS
OPEN TO THE PUBLIC.
2. DID THE COURT GIVE DUE CONSIDERATION TO THE CLAIMS BY MEGHAN LIPPIATT
REGARDING RETALIATION BY THE PUBLIC DURING AND AFTER A PUBLIC HEARING ON
THE ISSUES.
Geoge M. Parker, MD Under conditional release, such acquittees are released into the
community with various conditions imposed; for example, they are often required to live in
specified housing and not to use illegal drugs. They remain under the jurisdiction of a criminal
judge or a central monitoring agency, such as a psychiatric security review board. Adherence to
mental health treatment in the community is almost always a condition of release. As leverage,
this type of mandated community treatment uses both avoidance of jail and avoidance of
hospitalizationboth a brief jail stay and rehospitalization are possible consequences of
violation of the conditions of release, depending on the state. See Exhibit B.
3
See Exhibits A thru D.
Page 7 of 35
January January
Sunday
22, 201722, 2017
Page
Page1383
381 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1384
382 of
of1299
2301
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
CONCLUSION
The Lippiatt case is apparently precedent in the County of Lancaster of a person being found
not guilty by reason of insanity. That being the case, the court should take extra precaution in
protecting all parties in all related matters and should be careful when reaching opinions and
conclusion that will be precedent to future and similar parties that will come before the courts.
Judge Cullens ORDER and OPINION of July 11, 2008 fails to protect the rights of Ms. Lippiatt
and others that may come before the courts, but does so unnecessarily. Closing the hearing to
the general public would not diminish the public interest, nor would it make the general public
safer. Only a conclusion of an involuntary commitment of Ms. Lippiatt IF she does now possess a
mental health illness that does pose a threat or danger to others.
__________________
__________________
Respectfully Submitted:
Page 11 of 35
January January
Sunday
22, 201722, 2017
Page
Page1387
385 of
of1299
2301
CERTIFICATE OF SERVICE
Service was made on this 21s t day of July 2008 upon the following by way of electronic
mails; first class U.S. mails; or personal delivery at the addresses set forth below:
__________________
__________________
Respectfully Submitted:
Page 12 of 35
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
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
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
Advanced Media Group
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
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
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
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
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
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
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
2:16-mc-00049-EGS Page
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
2:16-mc-00049-EGS Page
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
2:16-mc-00049-EGS Page
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
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
https://www.supremecourt.gov/search.aspx?filename=/docketfiles/16-68...
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
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
Amount expected
next month
You
Spouse
You
Spouse
Employment
Self-employment
Gifts
Alimony
Child Support
Unemployment payments
Public-assistance
(such as welfare)
Other (specify):
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
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
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
Type of account
Members1st
TD Ameritrade
Checking
Money Market
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 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
You
Transportation (not including motor vehicle payments)
Your spouse
100.00
200.00
Homeowners or renters
Life
Health
Motor Vehicle
Other:
Office/Computer/Copying/Printing/Postage
300.00
Motor Vehicle
Credit card(s)
Department store(s)
Other:
Other (specify):
500.00
2,658.00
(specify):
Installment payments
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
No.
IN THE
STANLEY J. CATERBONE
PETITIONER
(Your Name)
vs.
RESPONDENT(S)
Stanley J. Caterbone
(Your Name)
1250 Fremont Street
(Address)
Lancaster, PA 17603
(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
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.
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?
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
TABLE OF CONTENTS
12
OPINIONS BELOW ........................................................................................................ 1
13
JURISDICTION...................................................................................................................
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
CASES
PAGE NUMBER
Pointer v. Texas, 380 U.S. 400, 85 S.Ct. 1065, 13 L.Ed.2d 923 (1965);
Appendix B -
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
IN THE
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
to
[ ] reported at
; or,
[ ] has been designated for publication but is not yet reported; 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,
[ ] has been designated for publication but is not yet reported; or,
[ ] is unpublished.
The opinion of the
appears at Appendix
court
to the petition and is
[ ] reported at
; or,
[ ] has been designated for publication but is not yet reported; 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
JURISDICTION
[ ] A timely petition for rehearing was thereafter denied on the following date:
, and a copy of the 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. 1257(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
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."
Page 14 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1439
437 of
of1299
2301
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
Page 15 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1440
438 of
of1299
2301
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 " `a 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
Page 16 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1441
439 of
of1299
2301
Page 17 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1442
440 of
of1299
2301
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
Page 18 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1443
441 of
of1299
2301
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
Page 19 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1444
442 of
of1299
2301
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 `incorporation'
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
Page 20 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1445
443 of
of1299
2301
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
Page 21 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1446
444 of
of1299
2301
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.
Page 22 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1447
445 of
of1299
2301
Page 23 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1448
446 of
of1299
2301
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.
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
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.
Page 24 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1449
447 of
of1299
2301
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.
Page 25 of 88
62
70
Wednesday
Tuesday October 12,
10, 2016
January January
Sunday
22, 201722, 2017
Page
Page1450
448 of
of1299
2301
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;
wrongdoings in this case.
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;
Michelle Lambert's meritorious plight for RELIEF and RELEASE from Prison can then be
accomplished, as it should.
Page 26 of 88
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
xxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxx
Page 29 of 88
70
January January
Sunday
22, 201722, 2017
Page
Page1454
452 of
of1299
2301
October 2015
OFFICE OF THE CLERK
WASHINGTON, D. C. 20543
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)
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
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).
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
I.
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
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
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
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
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
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
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
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
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
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
scaterbone@live.com
717-669-2163
Re:
IMPORTANT
/S/
Stan J. Caterbone, Pro Se APPELLANT
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
:
:
:
:
:
:
:
:
ORDER
I previously dismissed Petitioners pro se motion for habeas relief so that she could file a
counseled motion.
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
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
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.)
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. 16-1149 To US Supreme Court
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
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.
Page 3 of 3
U.S.C.A. 16-1149 To US Supreme Court
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.
LYNN BISSONETTE, SUPERINTENDENT,
MCI-FRAMINGHAM,
and
CRAIG STEDMAN, THE DISTRICT ATfORNEY OF LANCASTER
COUNTY, PENNSYLVANIA
and
KATHLEEN KANE, THE ATfORNEY GENERAL OF PENNSYLVANIA,
Respondents
S 17=n
F uu~t:
lY
SEP - 3 2D15
MICHAELE. KUNZ, Clerk
By
Dep. Clerk
(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
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
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. 16-1149 To US Supreme Court
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
"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~.,
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.
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
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
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
said perpetrators violating common laws governing intellectual property rights.
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. 16-1149 To US Supreme Court
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
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. 16-1149 To US Supreme Court
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
http://store.aetv.com/html/product/index.jhtml?id=75922
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
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:
A Teenage Murder Mystery DVD
-->
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.
Page 72 of 88
Page 1 of 4
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
Page 74 of 88
Page 1 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1499
497 of
of1299
2301
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 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.
"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 pink bag, then waving the camera off.
Page 75 of 88
Page 2 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1500
498 of
of1299
2301
Page 76 of 88
Page 3 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1501
499 of
of1299
2301
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.
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.
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.
Page 77 of 88
Page 4 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1502
500 of
of1299
2301
Page 78 of 88
Page 5 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1503
501 of
of1299
2301
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.
"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
Page 79 of 88
Page 6 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1504
502 of
of1299
2301
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.
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
Page 80 of 88
Page 7 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1505
503 of
of1299
2301
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.
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.
Page 81 of 88
Page 8 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1506
504 of
of1299
2301
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."
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
Page 82 of 88
Page 9 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1507
505 of
of1299
2301
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. . . . "
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 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."
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."
"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
Page 83 of 88
Page 10 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1508
506 of
of1299
2301
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 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."
Page 84 of 88
Page 11 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1509
507 of
of1299
2301
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.
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.
Page 85 of 88
Page 12 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1510
508 of
of1299
2301
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.
"How often do you get to do this?" Hazel observed.
"I think we made an impact," John offered.
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. . . . "
Page 86 of 88
Page 13 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1511
509 of
of1299
2301
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.
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;
Page 87 of 88
Page 14 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1512
510 of
of1299
2301
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
Stan J. Caterbone
ADVANCED MEDIA GROUP
Page 1 of 91
January January
Sunday
22, 201722, 2017
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
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
Page 2 of 91
January January
Sunday
22, 201722, 2017
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
January January
Sunday
22, 201722, 2017
Page 4 of 91
January January
Sunday
22, 201722, 2017
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
Amount expected
next month
You
Spouse
You
Spouse
Employment
Self-employment
Gifts
Alimony
Child Support
Unemployment payments
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
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
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
Type of account
Members1st
TD Ameritrade
Checking
Money Market
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 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 7 of 91
January January
Sunday
22, 201722, 2017
You
Transportation (not including motor vehicle payments)
Your spouse
100.00
200.00
$
$
Homeowners or renters
Life
Health
Motor Vehicle
Other:
Office/Computer/Copying/Printing/Postage
300.00
Motor Vehicle
Credit card(s)
Department store(s)
Other:
Other (specify):
500.00
2,658.00
(specify):
Installment payments
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 9 of 91
January January
Sunday
22, 201722, 2017
No.
IN THE
STANLEY J. CATERBONE
PETITIONER
(Your Name)
vs.
RESPONDENT(S)
Stanley J. Caterbone
(Your Name)
1250 Fremont Street
(Address)
Lancaster, PA 17603
(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
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.
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 12 of 91
January January
Sunday
22, 201722, 2017
TABLE OF CONTENTS
12
OPINIONS BELOW ........................................................................................................ 1
13
JURISDICTION...................................................................................................................
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
CASES
PAGE NUMBER
Pointer v. Texas, 380 U.S. 400, 85 S.Ct. 1065, 13 L.Ed.2d 923 (1965);
Appendix B -
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
IN THE
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
to
[ ] reported at
; or,
[ ] has been designated for publication but is not yet reported; 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,
[ ] has been designated for publication but is not yet reported; or,
[ ] is unpublished.
The opinion of the
appears at Appendix
court
to the petition and is
[ ] reported at
; or,
[ ] has been designated for publication but is not yet reported; 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
JURISDICTION
[ ] A timely petition for rehearing was thereafter denied on the following date:
, and a copy of the 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. 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
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
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
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 " `a 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
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
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
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
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 `incorporation'
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
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
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
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
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.
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
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.
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
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
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;
wrongdoings in this case.
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;
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 30 of 91
January January
Sunday
22, 201722, 2017
Page 31 of 91
January January
Sunday
22, 201722, 2017
PROOF OF SERVICE
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
October 2015
OFFICE OF THE CLERK
WASHINGTON, D. C. 20543
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)
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
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).
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
I.
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
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
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
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
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
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
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
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
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
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
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
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
scaterbone@live.com
717-669-2163
Re:
IMPORTANT
/S/
Stan J. Caterbone, Pro Se APPELLANT
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
REQUEST FOR COMMUTATION
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
:
:
:
:
:
:
:
:
ORDER
I previously dismissed Petitioners pro se motion for habeas relief so that she could file a
counseled motion.
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
REQUEST FOR COMMUTATION
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
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.)
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
REQUEST FOR COMMUTATION
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
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.
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
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
REQUEST FOR COMMUTATION
Page
Page1581
579 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Petitioner
v.
LYNN BISSONETTE, SUPERINTENDENT,
MCI-FRAMINGHAM,
and
CRAIG STEDMAN, THE DISTRICT ATfORNEY OF LANCASTER
COUNTY, PENNSYLVANIA
and
KATHLEEN KANE, THE ATfORNEY GENERAL OF PENNSYLVANIA,
Respondents
S 17=n
F uu~t:
lY
SEP - 3 2D15
MICHAELE. KUNZ, Clerk
By
Dep. Clerk
(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
Filed
Page
2 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
REQUEST FOR COMMUTATION
Page
Page1582
580 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
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
Filed
Page
3 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
REQUEST FOR COMMUTATION
Page
Page1583
581 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
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, 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~.,
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.
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
Filed
Page
4 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
REQUEST FOR COMMUTATION
Page
Page1584
582 of
of91299
2301
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
said perpetrators violating common laws governing intellectual property rights.
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
Filed
Page
5 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
REQUEST FOR COMMUTATION
Page
Page1585
583 of
of91299
2301
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
Filed
Page
6 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
REQUEST FOR COMMUTATION
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
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
http://store.aetv.com/html/product/index.jhtml?id=75922
REQUEST FOR COMMUTATION
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
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:
A Teenage Murder Mystery DVD
-->
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
ADVANCED MEDIA GROUP
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
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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 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.
"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 pink bag, then waving the camera off.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
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.
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.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
"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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
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.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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."
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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. . . . "
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 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."
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."
"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
Advanced Media Group
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
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 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
Advanced Media Group
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
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.
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.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
"How often do you get to do this?" Hazel observed.
"I think we made an impact," John offered.
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. . . . "
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
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;
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
062S0000000314
Click-N-Ship
11/16/2016
0006
C000
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
SHIP
WASHINGTON DC 20500-0003
USPS TRACKING #
Instructions
USPS TRACKING # :
From:
To:
389217451
11/16/2016
11/16/2016
$6.45
$6.45
11/18/2016
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
BARACH OBAMA
THE WHITE HOUSE
1600 PENNSYLVANIA AVE NW
WASHINGTON DC 20500-0003
* 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.
Thank you for shipping with the United States Postal Service!
Check the status of your shipment on the USPS Tracking page at usps.com
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
USPS Tracking
Features:
Priority Mail
USPS Tracking
Available Actions
Up to $50 insurance included
Text Updates
Restrictions Apply
Email Updates
DATE & TIME
STATUS OF ITEM
LOCATION
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.
LANCASTER, PA 17603
LANCASTER, PA 17604
Acceptance
LANCASTER, PA 17604
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
https://www.supremecourt.gov/search.aspx?filename=/docketfiles/16-68...
Page
Page1609
607 of
of1299
2301
12/10/2016 1:43 PM
2 of 2
January January
Sunday
22, 201722, 2017
https://www.supremecourt.gov/search.aspx?filename=/docketfiles/16-68...
Page
Page1610
608 of
of1299
2301
12/10/2016 1:43 PM
1 of 1
January January
Sunday
22, 201722, 2017
https://www.supremecourt.gov/search.aspx?filename=/docketfiles/16-68...
Page
Page1611
609 of
of1299
2301
11/17/2016 4:39 AM
January January
Sunday
22, 201722, 2017
Page
Page1612
610 of
of1299
2301
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.
January January
Sunday
22, 201722, 2017
Stan J. Caterbone
ADVANCED MEDIA GROUP
Page 1 of 91
January January
Sunday
22, 201722, 2017
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
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
Page 2 of 91
January January
Sunday
22, 201722, 2017
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
January January
Sunday
22, 201722, 2017
Page 4 of 91
January January
Sunday
22, 201722, 2017
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
Amount expected
next month
You
Spouse
You
Spouse
Employment
Self-employment
Gifts
Alimony
Child Support
Unemployment payments
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
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
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
Type of account
Members1st
TD Ameritrade
Checking
Money Market
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 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 7 of 91
January January
Sunday
22, 201722, 2017
You
Transportation (not including motor vehicle payments)
Your spouse
100.00
200.00
$
$
Homeowners or renters
Life
Health
Motor Vehicle
Other:
Office/Computer/Copying/Printing/Postage
300.00
Motor Vehicle
Credit card(s)
Department store(s)
Other:
Other (specify):
500.00
2,658.00
(specify):
Installment payments
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 9 of 91
January January
Sunday
22, 201722, 2017
No.
IN THE
STANLEY J. CATERBONE
PETITIONER
(Your Name)
vs.
RESPONDENT(S)
Stanley J. Caterbone
(Your Name)
1250 Fremont Street
(Address)
Lancaster, PA 17603
(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
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.
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 12 of 91
January January
Sunday
22, 201722, 2017
TABLE OF CONTENTS
12
OPINIONS BELOW ........................................................................................................ 1
13
JURISDICTION...................................................................................................................
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
CASES
PAGE NUMBER
Pointer v. Texas, 380 U.S. 400, 85 S.Ct. 1065, 13 L.Ed.2d 923 (1965);
Appendix B -
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
IN THE
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
to
[ ] reported at
; or,
[ ] has been designated for publication but is not yet reported; 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,
[ ] has been designated for publication but is not yet reported; or,
[ ] is unpublished.
The opinion of the
appears at Appendix
court
to the petition and is
[ ] reported at
; or,
[ ] has been designated for publication but is not yet reported; 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
JURISDICTION
[ ] A timely petition for rehearing was thereafter denied on the following date:
, and a copy of the 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. 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
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
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
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 " `a 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
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
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
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
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 `incorporation'
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
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
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
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
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.
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
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.
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
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
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;
wrongdoings in this case.
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;
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 30 of 91
January January
Sunday
22, 201722, 2017
Page 31 of 91
January January
Sunday
22, 201722, 2017
PROOF OF SERVICE
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
October 2015
OFFICE OF THE CLERK
WASHINGTON, D. C. 20543
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)
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
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).
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
I.
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
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
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
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
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
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
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
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
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
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
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
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
scaterbone@live.com
717-669-2163
Re:
IMPORTANT
/S/
Stan J. Caterbone, Pro Se APPELLANT
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
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
REQUEST FOR COMMUTATION
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
:
:
:
:
:
:
:
:
ORDER
I previously dismissed Petitioners pro se motion for habeas relief so that she could file a
counseled motion.
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
REQUEST FOR COMMUTATION
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
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.)
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
REQUEST FOR COMMUTATION
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
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.
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
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
REQUEST FOR COMMUTATION
Page
Page1680
678 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
Petitioner
v.
LYNN BISSONETTE, SUPERINTENDENT,
MCI-FRAMINGHAM,
and
CRAIG STEDMAN, THE DISTRICT ATfORNEY OF LANCASTER
COUNTY, PENNSYLVANIA
and
KATHLEEN KANE, THE ATfORNEY GENERAL OF PENNSYLVANIA,
Respondents
S 17=n
F uu~t:
lY
SEP - 3 2D15
MICHAELE. KUNZ, Clerk
By
Dep. Clerk
(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
Filed
Page
2 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
REQUEST FOR COMMUTATION
Page
Page1681
679 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
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
Filed
Page
3 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
REQUEST FOR COMMUTATION
Page
Page1682
680 of
of91299
2301
OF
THE09/03/15
SENTENCE
Stan J. Caterbone
OF LISA
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
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, 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~.,
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.
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
Filed
Page
4 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
REQUEST FOR COMMUTATION
Page
Page1683
681 of
of91299
2301
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
said perpetrators violating common laws governing intellectual property rights.
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
Filed
Page
5 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
REQUEST FOR COMMUTATION
Page
Page1684
682 of
of91299
2301
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
Filed
Page
6 ofLAMBERT
6
January January
Sunday
22, 201722,Case
2017 5:14-cv-02559-PD
REQUEST FOR COMMUTATION
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
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
http://store.aetv.com/html/product/index.jhtml?id=75922
REQUEST FOR COMMUTATION
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
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:
A Teenage Murder Mystery DVD
-->
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
ADVANCED MEDIA GROUP
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
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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 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.
"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 pink bag, then waving the camera off.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
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.
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.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
"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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
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.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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."
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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. . . . "
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 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."
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."
"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
Advanced Media Group
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
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 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
Advanced Media Group
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
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.
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.
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
"How often do you get to do this?" Hazel observed.
"I think we made an impact," John offered.
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. . . . "
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
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.
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;
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
U.S.C.A.
To
President
16-1149
Obama
To US
re Lisa
Supreme
Lambert
Court
Advanced Media Group
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
062S0000000314
Click-N-Ship
11/16/2016
0006
C000
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
SHIP
WASHINGTON DC 20500-0003
USPS TRACKING #
Instructions
USPS TRACKING # :
From:
To:
389217451
11/16/2016
11/16/2016
$6.45
$6.45
11/18/2016
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
BARACH OBAMA
THE WHITE HOUSE
1600 PENNSYLVANIA AVE NW
WASHINGTON DC 20500-0003
* 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.
Thank you for shipping with the United States Postal Service!
Check the status of your shipment on the USPS Tracking page at usps.com
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
USPS Tracking
Features:
Priority Mail
USPS Tracking
Available Actions
Up to $50 insurance included
Restrictions Apply
Text Updates
Email Updates
DATE & TIME
STATUS OF ITEM
LOCATION
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.
LANCASTER, PA 17604
LANCASTER, PA 17604
LANCASTER, PA 17603
LANCASTER, PA 17604
Acceptance
LANCASTER, PA 17604
1 of 2
11/17/2016 6:39 PM
January January
Sunday
22, 201722, 2017
Page
Page1706
704 of
of1299
2301
Page 1 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1707
705 of
of1299
2301
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 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.
"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 pink bag, then waving the camera off.
Advanced Media Group
Page 2 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1708
706 of
of1299
2301
Page 3 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1709
707 of
of1299
2301
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.
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.
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.
Advanced Media Group
Page 4 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1710
708 of
of1299
2301
Page 5 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1711
709 of
of1299
2301
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.
"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
Advanced Media Group
Page 6 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1712
710 of
of1299
2301
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.
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
Advanced Media Group
Page 7 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1713
711 of
of1299
2301
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.
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.
Page 8 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1714
712 of
of1299
2301
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."
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
Advanced Media Group
Page 9 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1715
713 of
of1299
2301
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. . . . "
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 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."
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."
"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
Advanced Media Group
Page 10 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1716
714 of
of1299
2301
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 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."
Page 11 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1717
715 of
of1299
2301
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.
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.
Advanced Media Group
Page 12 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1718
716 of
of1299
2301
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.
"How often do you get to do this?" Hazel observed.
"I think we made an impact," John offered.
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. . . . "
Page 13 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1719
717 of
of1299
2301
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.
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;
Advanced Media Group
Page 14 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1720
718 of
of1299
2301
Page 15 of 15
10/20/2007
January January
Sunday
22, 201722, 2017
Page
Page1721
719 of
of1299
2301
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
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
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
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
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
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
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
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
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
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
http://lancasteronline.com/news/local/in-a-killer-s-words-lisa-michelle-l...
Page
Page1735
733 of
of1299
2301
Page 1 of 151
143
In a killers words: Lisa Michelle Lambert, nearly 25 years since Laurie ...
January January
Sunday
22, 201722, 2017
http://lancasteronline.com/news/local/in-a-killer-s-words-lisa-michelle-l...
Page
Page1736
734 of
of1299
2301
Page 2 of 151
143
In a killers words: Lisa Michelle Lambert, nearly 25 years since Laurie ...
January January
Sunday
22, 201722, 2017
http://lancasteronline.com/news/local/in-a-killer-s-words-lisa-michelle-l...
Page
Page1737
735 of
of1299
2301
Page 3 of 151
143
In a killers words: Lisa Michelle Lambert, nearly 25 years since Laurie ...
January January
Sunday
22, 201722, 2017
http://lancasteronline.com/news/local/in-a-killer-s-words-lisa-michelle-l...
Page
Page1738
736 of
of1299
2301
Page 4 of 151
143
In a killers words: Lisa Michelle Lambert, nearly 25 years since Laurie ...
January January
Sunday
22, 201722, 2017
http://lancasteronline.com/news/local/in-a-killer-s-words-lisa-michelle-l...
Page
Page1739
737 of
of1299
2301
Page 5 of 151
143
In a killers words: Lisa Michelle Lambert, nearly 25 years since Laurie ...
January January
Sunday
22, 201722, 2017
http://lancasteronline.com/news/local/in-a-killer-s-words-lisa-michelle-l...
Page
Page1740
738 of
of1299
2301
Page 6 of 151
143
In a killers words: Lisa Michelle Lambert, nearly 25 years since Laurie ...
January January
Sunday
22, 201722, 2017
http://lancasteronline.com/news/local/in-a-killer-s-words-lisa-michelle-l...
Page
Page1741
739 of
of1299
2301
Page 7 of 151
143
In a killers words: Lisa Michelle Lambert, nearly 25 years since Laurie ...
January January
Sunday
22, 201722, 2017
http://lancasteronline.com/news/local/in-a-killer-s-words-lisa-michelle-l...
Page
Page1742
740 of
of1299
2301
Page 8 of 151
143
In a killers words: Lisa Michelle Lambert, nearly 25 years since Laurie ...
January January
Sunday
22, 201722, 2017
http://lancasteronline.com/news/local/in-a-killer-s-words-lisa-michelle-l...
Page
Page1743
741 of
of1299
2301
Page 9 of 151
143
In a killers words: Lisa Michelle Lambert, nearly 25 years since Laurie ...
January January
Sunday
22, 201722, 2017
http://lancasteronline.com/news/local/in-a-killer-s-words-lisa-michelle-l...
Page
Page1744
742 of
of1299
2301
Page 10 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1745
743 of
of1299
2301
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
(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.
1
LNP Lisa Michelle Lambert Book
New Book
Rebuttal
Page 11 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1746
744 of
of1299
2301
2
LNP Lisa Michelle Lambert Book
New Book
Rebuttal
Page 12 of 151
143
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
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 digi tal 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 & 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 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 Common wealth of Pennsylvania, and the County of Lancaster administer justice, United States troops may have
3
LNP Lisa Michelle Lambert Book
New Book
Rebuttal
Page 13 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1748
746 of
of1299
2301
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 disclo sures 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.
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 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
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
4
LNP Lisa Michelle Lambert Book
New Book
Rebuttal
Page 14 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1749
747 of
of1299
2301
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 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
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 peo ples 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 in tegrity 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 democ racy and impugning the Constitution of the United States. The plaintiff must be restored to whole.
5
LNP Lisa Michelle Lambert Book
New Book
Rebuttal
Page 15 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1750
748 of
of1299
2301
Page 16 of 151
143
1 of 2
January January
Sunday
22, 201722, 2017
https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?735197255373405-L_1_0-1
Page
Page1751
749 of
of1299
2301
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)
Petitioner
LISA MICHELLE LAMBERT
V.
Respondent
LYNN BISSONETTE
SUPERINTENDENT, MCI-FRAMINGHAM
Respondent
THE DISTRICT ATTORNEY OF LANCASTER COUNTY,
PENNSYLVANIA
Respondent
THE ATTORNEY GENERAL OF PENNSYLVANIA
V.
Movant
STANLEY J. CATERBONE
AND ADVANCED MEDIA GROUP
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
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)
Page 17 of 151
143
2 of 2
January January
Sunday
22, 201722, 2017
https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?735197255373405-L_1_0-1
Page
Page1752
750 of
of1299
2301
09/09/2015
11
09/09/2015
12
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
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)
am6446:3514696:0
Description:
Docket Report
Search Criteria:
5:14-cv-02559-PD
Billable Pages:
Cost:
0.20
Client Code:
Page 18 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1753
751 of
of1299
2301
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
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.
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:
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:
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 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)
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
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.
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
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.
11.
13.
Executive Summary
14.
15.
16.
17.
Family History
18.
19.
20.
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.
22.
23.
Redacted Version
24.
25.
26.
27.
29.
30.
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
Prior Cases:
None
Current Cases:
None
v.
SUPERINTENDENT FRAMINGHAM MCI
Defendant - Appellee
-----------------------------STANLEY J. CATERBONE
Not Party - Appellant
14-02559
Lambert Lambert
Habeus Corpus
LNP Lisa Michelle
New Book
Book
Rebuttal
Stanley J. Caterbone
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
https://ecf.ca3.uscourts.gov/cmecf/servlet/TransportRoom
January January
Sunday
22, 201722, 2017
Page
Page1769
767 of
of1299
2301
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
https://ecf.ca3.uscourts.gov/cmecf/servlet/TransportRoom
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)
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)
ECF FILER: DOCUMENTS by Appellant Mr. Stanley J. Caterbone titled Submissions as Exhibits.
Certificate of Service dated 11/03/2015.--[Edited 11/03/2015 by CJG] (SJC)
ECF FILER: DOCUMENT by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit. Certificate of
Service dated 11/04/2015.--[Edited 11/05/2015 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 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)
ECF FILER: DOCUMENT by Appellant Stanley J. Caterbone titled Submission as Exhibit. Certificate of
Service dated 11/06/2015.--[Edited 11/10/2015 by CJG] (SJC)
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)
ECF FILER: DOCUMENT filed by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit.
Certificate of Service dated 11/10/2015.--[Edited 11/10/2015 by CJG] (SJC)
91 pg, 21.28 MB
ECF FILER: DOCUMENT filed by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit.
Certificate of Service dated 11/10/2015.--[Edited 11/10/2015 by CJG] (SJC)
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
ECF FILER: DOCUMENT by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit. Certificate of
Service dated 11/13/2015.--[Edited 11/16/2015 by CJG] (SJC)
91 pg, 37.06 MB
ECF FILER: DOCUMENT by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit. Certificate of
Service dated 11/16/2015.--[Edited 11/16/2015 by CJG] (SJC)
ECF FILER: 3DOCUMENT filed by Appellant Mr. Stanley J. Caterbone titled submission as exhibit.
Certificate of Service dated 11/17/2015.--[Edited 11/19/2015 by CJG] (SJC)
807 pg, 79 MB
ECF FILER: DOCUMENT filed by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit.
Certificate of Service dated 11/18/2015.--[Edited 11/19/2015 by CJG] (SJC)
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
https://ecf.ca3.uscourts.gov/cmecf/servlet/TransportRoom
January January
Sunday
22, 201722, 2017
Page
Page1771
769 of
of1299
2301
ECF FILER: DOCUMENT filed by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit.
Certificate of Service dated 11/19/2015.--[Edited 11/19/2015 by CJG] (SJC)
ECF FILER: DOCUMENT filed by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit.
Certificate of Service dated 11/20/2015.--[Edited 11/23/2015 by CJG] (SJC)
69 pg, 17 MB
ECF FILER: DOCUMENT filed by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit.
Certificate of Service dated 11/21/2015.--[Edited 11/23/2015 by CJG] (SJC)
ECF FILER: DOCUMENT filed by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit.
Certificate of Service dated 11/22/2015.--[Edited 11/23/2015 by CJG] (SJC)
3 pg, 1.86 MB
ECF FILER: Motion filed by Appellant Mr. Stanley J. Caterbone for 30 Day Continuance. Certificate of
Service dated 11/22/2015.--[Edited 11/23/2015 by CJG] (SJC)
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)
ECF FILER: DOCUMENT filed by Appellant Mr. Stanley J. Caterbone titled Submission as Exhibit.
Certificate of Service dated 11/25/2015.--[Edited 11/25/2015 by CJG] (SJC)
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
MARCIA M. WALDRON
CLERK
TELEPHONE
215-597-2995
Website: www.ca3.uscourts.gov
October 9, 2015
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,
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
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
scaterbone@live.com
717-669-2163
Re:
/S/
Stan J. Caterbone, Pro Se APPELLANT
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
scaterbone@live.com
717-669-2163
Page 40 of 151
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
2.
_________________________________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:
Stanley J. Caterbone
District Attorney Lancaster County
Jeremy H.G. Ibrahim, Sr., Esq.
A True Copy :
Page 41 of 151
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
www.amgglobalentertainmentgroup.com
scaterbone@live.com
717-669-2163
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
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
/S/
Date: January 13, 2016
15-3400
LNP
LisaLambert
MichelleAppeal
Lambert
re Book
J. Michael
Fisher
Rebuttal
Recusal
Fisher RecusalPage
Page
432ofof151
75
78
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
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
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
George W. Bush
Preceded by
Tom Ridge
Preceded by
Tom Corbett
Succeeded by
Jerry Pappert
Political career
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
David Brightbill
Succeeded by
David Brightbill
Jay Wells
Succeeded by
Frank Marmion
Personal details
2 of 3
15-3400
January January
Sunday
22,Case:
201722,
2017
https://en.wikipedia.org/wiki/D._Michael_Fisher
Document: 003112180452
Page: 5 StanDate
Filed: 01/15/2016
Page
Page1780
778 of
of1299
2301
J. Caterbone
LAMBERT CASE FILE
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%.
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
3 of 3
15-3400
January January
Sunday
22,Case:
201722,
2017
https://en.wikipedia.org/wiki/D._Michael_Fisher
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
Succeeded by
Frank Marmion
Succeeded by
Tim Murphy
Succeeded by
David Brightbill
Preceded by
William Scranton
Succeeded by
Harold Mowery
Preceded by
Ernie Preate
Succeeded by
Tom Corbett
Preceded by
Tom Ridge
Succeeded by
Lynn Swann
Legal offices
Preceded by
Tom Corbett
Succeeded by
Jerry Pappert
Preceded by
Carol Los Mansmann
Incumbent
15-3400
LNP
LisaLambert
MichelleAppeal
Lambert
re Book
J. Michael
Rebuttal
Fisher RecusalPage
Page
476ofof151
78
January January
Sunday
22, 201722, 2017
Page
Page1782
780 of
of1299
2301
Page 48
40 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1783
781 of
of1299
2301
Page 49
41 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1784
782 of
of1299
2301
Page 50
42 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1785
783 of
of1299
2301
Page 51
43 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1786
784 of
of1299
2301
Page 52
44 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1787
785 of
of1299
2301
Page 53
45 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1788
786 of
of1299
2301
Page 54
46 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1789
787 of
of1299
2301
Page 55
47 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1790
788 of
of1299
2301
Page 56
48 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1791
789 of
of1299
2301
Page 57
49 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1792
790 of
of1299
2301
Page 58
50 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1793
791 of
of1299
2301
Page 59
51 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1794
792 of
of1299
2301
Page 60
52 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1795
793 of
of1299
2301
Page 61
53 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1796
794 of
of1299
2301
Page 62
54 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1797
795 of
of1299
2301
Page 63
55 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1798
796 of
of1299
2301
Page 64
56 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1799
797 of
of1299
2301
Page 65
57 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1800
798 of
of1299
2301
Page 66
58 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1801
799 of
of1299
2301
Page 67
59 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1802
800 of
of1299
2301
Page 68
60 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1803
801 of
of1299
2301
Page 69
61 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1804
802 of
of1299
2301
Page 70
62 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1805
803 of
of1299
2301
Page 71
63 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1806
804 of
of1299
2301
Page 72
64 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1807
805 of
of1299
2301
Page 73
65 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1808
806 of
of1299
2301
Page 74
66 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1809
807 of
of1299
2301
Page 75
67 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1810
808 of
of1299
2301
Page 76
68 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1811
809 of
of1299
2301
Page 77
69 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1812
810 of
of1299
2301
Page 78
70 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1813
811 of
of1299
2301
Page 79
71 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1814
812 of
of1299
2301
Page 80
72 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1815
813 of
of1299
2301
Page 81
73 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1816
814 of
of1299
2301
Page 82
74 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1817
815 of
of1299
2301
Page 83
75 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1818
816 of
of1299
2301
Page 84
76 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1819
817 of
of1299
2301
Page 85
77 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1820
818 of
of1299
2301
Page 86
78 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1821
819 of
of1299
2301
Page 87
79 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1822
820 of
of1299
2301
Page 88
80 of 151
143
January January
Sunday
22, 201722, 2017
Page
Page1823
821 of
of1299
2301
Stan J. Caterbone
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
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
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
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/___________
Stan J. Caterbone, Pro Se Litigant
Advanced Media Group
www.amgglobalentertainmentgroup.com
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
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
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
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
www.amgglobalentertainmentgroup.com
scaterbone@live.com
717-669-2163
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.
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
KEISLING: Palace coup: what the Kathleen Kane prosecution is really ...
1 of 3
January January
Sunday
22, 201722, 2017
December 9, 2015
http://newslanc.com/2015/12/09/keisling-palace-coup-what-the-kathleen...
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
KEISLING: Palace coup: what the Kathleen Kane prosecution is really ...
2 of 3
January January
Sunday
22, 201722, 2017
http://newslanc.com/2015/12/09/keisling-palace-coup-what-the-kathleen...
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
KEISLING: Palace coup: what the Kathleen Kane prosecution is really ...
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
http://newslanc.com/2015/12/09/keisling-palace-coup-what-the-kathleen...
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
http://triblive.com/state/pennsylvania/9844432-74/state-political-budget?...
Page
Page1832
830 of
of1299
2301
(https://twitter.com/BBumsted_Trib)
Page 98
90 of 151
143
2 of 3
January January
Sunday
22, 201722, 2017
http://triblive.com/state/pennsylvania/9844432-74/state-political-budget?...
Page
Page1833
831 of
of1299
2301
Page 99
91 of 151
143
3 of 3
January January
Sunday
22, 201722, 2017
http://triblive.com/state/pennsylvania/9844432-74/state-political-budget?...
Page
Page1834
832 of
of1299
2301
Page
Page100
92 of
of143
151
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
https://www.scribd.com/stan5j.5caterbone
Stan J. Caterbone
Advanced Media Group
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
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
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
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
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
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
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
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
(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.
January January
Sunday
22, 201722, 2017
Page
Page1842
840 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
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
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
2. Dirty bomb drill in Richmond alarms conspiracy theorists, including Alex Jones
Comments
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
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
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
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
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
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 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:
Date Completed:
Date Initiated:
Stan J. Caterbone
Advanced Media Group
scaterbone@live.com
www.amgglobalentertainmentgroup.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
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
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.
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.
In fact a working theory was filed that suggested that the East Lampeter
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
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.
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.
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
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
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.
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
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
In 1987 Stan J. Caterbone went public with allegations of fraud within International Signal
and Control, or ISC as they were commonly referred.
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.
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.
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
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
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?
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.
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
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.
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
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
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
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
Remote Viewers may have attempted to connect in a more direct and continuous way
without success.
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 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.
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
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
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
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
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
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.
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.
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
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
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
Bellefonte, Pennsylvania, his hunting pants caught fire trying to stay warm.
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.
landscaping business before joining forces with John DePatto of United Financial Services and
selling residential mortgages.
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
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
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.
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.
$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.,;
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
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
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.
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
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
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.
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
Lancaster, Pennsylvania 17603
Derrick Robinson
Freedom From Covert Harassment and Surveillance
P.O. Box 9022
Cincinnati, Ohio 45209
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
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
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
"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
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
Advanced Media Group
scaterbone@live.com
www.amgglobalentertainmentgroup.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
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
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
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
www.amgglobalentertainmentgroup.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
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
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.
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
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
# PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
"
Stan J. Caterbone
# PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
"
Pennsylvania
PPPPPPPPPPPPPPPPPPPPPPPPPP
$
Lancaster
PPPPPPPPPPPPPPPPPPPPPPPPPPPPP
19
PPPPPPP
15
June
PPPPPPPPPPPPPPPPPPPPPPP
&,PP
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
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
THE ADVANCED MEDIA GROUP
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
THE ADVANCED MEDIA GROUP
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
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
____________________________________________________
BRIEF ON BEHALF OF AMICI CURIAE STANLEY J. CATERBONE
and ADVANCED MEDIA GROUP
IN SUPPORT OF LISA MICHELLE LAMBERT'S HABEAU CORPUS
____________________________________________________
_________/s/_______________
Stanley J. Caterbone, Pro Se Litigant
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
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
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.
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.
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.
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.
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
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 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
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
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,
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
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.
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, 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,
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. 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
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.
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.
Advanced Research Project Agency, or DARPA, with the National Institute of Standards and
Technology, or NIST called TIMIT.
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.
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) -
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
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
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
38
January January
Sunday
22, 201722, 2017
Page
Page1924
922 of
of1299
2301
CERTIFICATE OF SERVICE
I hereby certify that on June 20, 2015 I have mailed by U.S. Postal Service the foregoing paper to the following :
_________/s/_______________
Stanley J. Caterbone, Pro Se Litigant
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
Stan J. Caterbone LAMBERT CASE FILE
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...
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
Stan J. Caterbone LAMBERT CASE FILE
1 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1928
926 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
2 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1929
927 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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
928 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
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
929 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
RU4Real....."Everything gets reported?"..... You didn't really say that did you?
Unfortunately, I think you did. There are so many unreported, missing women, even dead women, it's freakin epidemic.
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
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?
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
930 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
RU4Real....."Everything gets reported?"..... You didn't really say that did you?
Unfortunately, I think you did. There are so many unreported, missing women, even dead women, it's freakin epidemic.
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
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?
Good grief - the multimillion dollar police station is two blocks north of LNP. So much for accuracy on your part.
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
931 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
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
932 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
RU4Real....."Everything gets reported?"..... You didn't really say that did you?
Unfortunately, I think you did. There are so many unreported, missing women, even dead women, it's freakin epidemic.
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
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?
Good grief - the multimillion dollar police station is two blocks north of LNP. So much for accuracy on your part.
8 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1935
933 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
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
934 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
10 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1937
935 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
HMM...
" LA TIMES"...
BERNARD STEIN OR STERN
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
936 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
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
937 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
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.
13 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1940
938 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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
939 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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
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.
15 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1942
940 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
Good night.
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
941 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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
yep - annother "bannation day" on the way. Keep it up Heather, you haven't fooled anyone.
17 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1944
942 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
QUOTE
If someone is offering to take you into the 21st century, please, allow them to do so.
Why?
Free Lance writer....I was under the impression that you had to be published and paid to be a free lance writer.
Posted by: Kasey1 Oct 5 2004, 11:38 AM
18 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1945
943 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
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
944 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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
945 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
21 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1948
946 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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."
22 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1949
947 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
23 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1950
948 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
The most famous they got , they hadn't planned on. Lisa Lambert and the Amish drug bust, back in 1998....It was brief.
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.
24 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1951
949 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
25 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1952
950 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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
951 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
Posted by: Kasey1 Oct 9 2004, 08:00 PM
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.
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.
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.
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.
27 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1954
952 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
28 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1955
953 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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?
Posted by: lancasterlover Oct 23 2004, 02:57 AM
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
954 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
30 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1957
955 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
31 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1958
956 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
32 of 33
7/20/2008 8:02 PM
TalkBack
[Powered
by Invision
Power Board]
January
Sunday
January
22, 2017
22, 2017
Page
Page1959
957 http://talkback.lancasteronline.com/index.php?s=3cc4245408b958f25a872a6b876be43b&act=...
of
of1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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.
33 of 33
7/20/2008 8:02 PM
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
January January
Sunday
22, 201722, 2017
New
Page
Page1960
958 of
of1299
2301
Hotmail
Reply
Spaces
OneCare
Reply all
Forward
Delete
Junk
Web
Move to
Junk
Drafts
Sent
Options
Americom
Andale
Deleted
BargainLand
Barnstormers
Craigs List
DE Communications
amgroup01@
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
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
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
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
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.
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
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
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.
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.
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
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
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
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 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
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
4 of 14
10/20/2007 1:12 PM
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
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 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
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
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
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
January January
Sunday
22, 201722, 2017
Page
Page1966
964 of
of1299
2301
planner from
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
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
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
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
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.
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
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
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.
10 of 14
10/20/2007 1:12 PM
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
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.
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
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
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 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
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-of-affairs within SONY, and after his proposal was completed, SONY publicly
12 of 14
10/20/2007 1:12 PM
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
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,
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. 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
most remarkable demonstrations of his keen sense of perception.
[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
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.
13 of 14
10/20/2007 1:12 PM
http://bl108w.blu108.mail.live.com/mail/ReadMessageLight.aspx?Aux...
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
v.
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
January January
Sunday
22, 201722, 2017
Page
Page1975
973 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1976
974 of
of1299
2301
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.
B. Post Verdict Motions
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.
C. State Court Appeals
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).
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.
III. THE POST CONVICTION RELIEF ACT PETITION
A. Procedural History: Motions, Petitions, Conferences, Orders
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
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
January January
Sunday
22, 201722, 2017
Page
Page1985
983 of
of1299
2301
January January
Sunday
22, 201722, 2017
Page
Page1986
984 of
of1299
2301
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.
a. Constitutional violations: prosecutorial misconduct and Brady
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
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.
b. Ineffective assistance of counsel
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
January January
Sunday
22, 201722, 2017
Page
Page1991
989 of
of1299
2301
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).
2. "Finally litigated" and waiver under the PCRA
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).
3. This court's role
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
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.
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
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
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
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.
V. STATE COURT AND FEDERAL COURT
A. A Comity of Errors
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.
B. What Does "Actual Innocence" Actually Mean?
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
January January
Sunday
22, 201722, 2017
Page 2009
1007 of 2301
1299
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.
VII. LISA MICHELLE LAMBERT'S CASE: ISSUES AND DISCUSSION
A. Laurie Show's Dying Declaration
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
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
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.
B. The "29 Questions"
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
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
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
(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
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!. . .
(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,
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.
2. Allegation of gang rape
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.
(Commonwealth Exhibit 10 (emphasis in original).)
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.
3. Cambridge Springs
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.
D. Tabitha Buck's Involvement
1. The scratch on Tabitha Buck's face
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
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
January January
Sunday
22, 201722, 2017
Page 2037
1035 of 2301
1299
January January
Sunday
22, 201722, 2017
Page 2038
1036 of 2301
1299
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
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
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.
E. Lawrence Yunkin's Involvement
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
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
January January
Sunday
22, 201722, 2017
Page 2049
1047 of 2301
1299
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.
3. Truth-determining process
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.
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.
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.
Commonwealth v. Lambert, July 19, 1994, slip op. at 22-23.
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?
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.
(Petitioner's Exhibit 2090.)
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
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
January January
Sunday
22, 201722, 2017
Page 2062
1060 of 2301
1299
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.
(N.T., Trial at 673.)
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
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.
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.
(N.T., Trial at 207.)
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.
(N.T., Trial at 208.)
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
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
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.
January January
Sunday
22, 201722, 2017
Page 2073
1071 of 2301
1299
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
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
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.
January January
Sunday
22, 201722, 2017
Page 2079
1077 of 2301
1299
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
January January
Sunday
22, 201722, 2017
Page 2084
1082 of 2301
1299
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.
N. The Pearl Earring
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 Exhibit 1190.)
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
January January
Sunday
22, 201722, 2017
Page 2090
1088 of 2301
1299
January January
Sunday
22, 201722, 2017
Page 2091
1089 of 2301
1299
January January
Sunday
22, 201722, 2017
Page 2092
1090 of 2301
1299
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
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
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.
January January
Sunday
22, 201722, 2017
Page 2096
1094 of 2301
1299
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.
January January
Sunday
22, 201722, 2017
Page 2098
1096 of 2301
1299
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.
T. Brady/Giglio Violations
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.
January January
Sunday
22, 201722, 2017
Page 2100
1098 of 2301
1299
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
There was no evidence offered at the PCRA hearing on this claim.
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.
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
There was no evidence offered at the PCRA hearing on this claim.
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.
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.
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
There was no evidence offered at the PCRA hearing on this claim.
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
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
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
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
There was no evidence offered at the PCRA hearing on this claim.
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
There was no evidence offered at the PCRA hearing on this claim.
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
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
There was no evidence offered at the PCRA hearing on this claim.
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.
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
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.
82. Failed to disclose that Ms. Buck admitted that her hands hurt on the
morning after the murder
See discussion of Brady/Giglio claim 81, supra.
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
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
See discussion of Brady/Giglio claim 72, supra.
91. Failed to disclose that the rope purported to be found at the crime
scene was 22 feet 5 inches
See discussion of Brady/Giglio claim 72, supra.
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
There was no evidence offered at the PCRA hearing on this claim.
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
There was no evidence offered at the PCRA hearing on this claim.
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.
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.
IN THE COURT OF COMMON PLEAS
OF LANCASTER COUNTY, PENNSYLVANIA
CRIMINAL
COMMONWEALTH OF : No. 0423 - 1992
PENNSYLVANIA:
January January
Sunday
22, 201722, 2017
Page 2122
1120 of 2301
1299
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
Peter S. Greenberg, Esquire
Christy H. Fawcett, Esquire
ADDENDUM TO OPINION
Footnotes :
(Return to Table of Contents)
January January
Sunday
22, 201722, 2017
Page 2123
1121 of 2301
1299
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
January January
Sunday
22, 201722, 2017
Page 2126
1124 of 2301
1299
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
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.
January January
Sunday
22, 201722, 2017
Page 2133
1131 of 2301
1299
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:
January January
Sunday
22, 201722, 2017
Page 2135
1133 of 2301
1299
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.
January January
Sunday
22, 201722, 2017
Page 2137
1135 of 2301
1299
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.
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
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.
(Petitioner's Exhibit 1661.)
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
03/09/2016
0006
C000
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
SIGNATURE REQUIRED
SHIP
WASHINGTON DC 20500-0003
Instructions
Trans. #:
Print Date:
Ship Date:
Expected
Delivery Date:
Insured Value:
From:
To:
367860978
03/08/2016
03/09/2016
03/11/2016
$50.00
$6.45
$0.00
$2.45
$8.90
STAN CATERBONE
AMG
1250 FREMONT ST
LANCASTER PA 17603-6812
PRESIDENT BARRACK OBAMA
THE WHITE HOUSE
1600 PENNSYLVANIA AVE NW
WASHINGTON DC 20500-0003
* 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.
Thank you for shipping with the United States Postal Service!
Check the status of your shipment on the USPS Tracking page at usps.com
January January
Sunday
22, 201722, 2017
Page 2148
1146 of 2301
1299
March 8, 2016
The White House
1600 Pennsylvania Avenue NW
Washington, DC 20500
Re:
________________________________________
Stan J. Caterbone, Pro Se Litigant
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
scaterbone@live.com
717-669-2163
Notary:
Page 1 of 59
March 9, 2016
January January
Sunday
22, 201722, 2017
Page 2149
1147 of 2301
1299
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.
Page 2 of 59
March 9, 2016
January January
Sunday
22, 201722, 2017
Page 2150
1148 of 2301
1299
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
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
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
Page 7 of 59
March 9, 2016
January January
Sunday
22, 201722, 2017
Page 2155
1153 of 2301
1299
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/___________
Stan J. Caterbone, Pro Se Litigant
Advanced Media Group
www.amgglobalentertainmentgroup.com
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
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
https://www.scribd.com/stan5j.5caterbone
Stan J. Caterbone
Advanced Media Group
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
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
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
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
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
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
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
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
(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.
January January
Sunday
22, 201722, 2017
Page 2163
1161 of 2301
1299
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
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
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
2. Dirty bomb drill in Richmond alarms conspiracy theorists, including Alex Jones
Comments
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
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
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
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
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
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 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:
Date Completed:
Date Initiated:
Stan J. Caterbone
Advanced Media Group
scaterbone@live.com
www.amgglobalentertainmentgroup.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
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
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.
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.
In fact a working theory was filed that suggested that the East Lampeter
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
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.
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.
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
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
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.
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
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
In 1987 Stan J. Caterbone went public with allegations of fraud within International Signal
and Control, or ISC as they were commonly referred.
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.
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.
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
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
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?
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.
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
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.
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
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
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
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
Remote Viewers may have attempted to connect in a more direct and continuous way
without success.
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 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.
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
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
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
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
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
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.
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.
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
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
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
Bellefonte, Pennsylvania, his hunting pants caught fire trying to stay warm.
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.
landscaping business before joining forces with John DePatto of United Financial Services and
selling residential mortgages.
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
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
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.
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.
$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.,;
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
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
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.
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
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
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.
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
Lancaster, Pennsylvania 17603
Derrick Robinson
Freedom From Covert Harassment and Surveillance
P.O. Box 9022
Cincinnati, Ohio 45209
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
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
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
"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
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
Advanced Media Group
scaterbone@live.com
www.amgglobalentertainmentgroup.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
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
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
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
www.amgglobalentertainmentgroup.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
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
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
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
# PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
"
Stan J. Caterbone
# PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
"
Pennsylvania
PPPPPPPPPPPPPPPPPPPPPPPPPP
$
Lancaster
PPPPPPPPPPPPPPPPPPPPPPPPPPPPP
19
PPPPPPP
15
June
PPPPPPPPPPPPPPPPPPPPPPP
&,PP
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
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
THE ADVANCED MEDIA GROUP
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
THE ADVANCED MEDIA GROUP
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,
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
http://nl.newsbank.com/nl-search/we/Archives?p_product=LC&p_...
January January
Sunday
22, 2017
22, 2017
Page
1205 of
2207
1299
2301
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:31 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
http://nl.newsbank.com/nl-search/we/Archives?p_product=LC&p_...
January January
Sunday
22, 2017
22, 2017
Page
1206 of
2208
1299
2301
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:31 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
http://nl.newsbank.com/nl-search/we/Archives?p_product=LC&p_...
January January
Sunday
22, 2017
22, 2017
Page
1207 of
2209
1299
2301
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:31 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
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
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for complete article, (573 words)
Article 12 of 348, 1997364209
Published on December 30, 1997, Lancaster New Era (PA)
1 of 3
6/10/2006 8:32 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1209 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2211
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:32 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1210 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2212
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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.
Click for complete article, (480 words)
Article 19 of 348, 1997362286
Published on December 28, 1997, Sunday News (Lancaster, PA)
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
Click for complete article, (634 words)
Article 20 of 348, 1997361195
Published on December 27, 1997, Lancaster New Era (PA)
3 of 3
6/10/2006 8:32 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1211 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2213
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
The following is a look back at local news events during the past week.
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
Click for complete article, (539 words)
Article 22 of 348, 1997355353
Published on December 21, 1997, Sunday News (Lancaster, PA)
1 of 3
6/10/2006 8:33 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1212 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2214
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
Click for complete article, (736 words)
Article 25 of 348, 1997348360
Published on December 14, 1997, Sunday News (Lancaster, PA)
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
Click for complete article, (534 words)
Article 26 of 348, 1997348361
Published on December 14, 1997, Sunday News (Lancaster, PA)
2 of 3
6/10/2006 8:33 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1213 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2215
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:33 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1214 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2216
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
The following is a look back at local news events during the past week.
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
Click for complete article, (483 words)
Article 33 of 348, 1997341345
Published on December 7, 1997, Sunday News (Lancaster, PA)
1 of 3
6/10/2006 8:34 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1215 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2217
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
"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
Click for complete article, (677 words)
Article 35 of 348, 1997341324
Published on December 7, 1997, Sunday News (Lancaster, PA)
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
Click for complete article, (568 words)
Article 38 of 348, 1997340175
Published on December 6, 1997, Intelligencer Journal (Lancaster, PA)
2 of 3
6/10/2006 8:34 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1216 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2218
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:34 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1217 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2219
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:35 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1218 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2220
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:35 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1219 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2221
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:35 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1220 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2222
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:35 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1221 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2223
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
Click for complete article, (447 words)
Article 57 of 348, 1997295181
Published on October 22, 1997, Intelligencer Journal (Lancaster, PA)
2 of 3
6/10/2006 8:35 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1222 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2224
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:35 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1223 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2225
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:36 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1224 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2226
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:36 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1225 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2227
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:36 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1226 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2228
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 4
6/10/2006 8:38 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1227 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2229
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 4
6/10/2006 8:38 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1228 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2230
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 4
6/10/2006 8:38 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1229 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2231
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
Terms of Service Privacy Policy
4 of 4
6/10/2006 8:38 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1230 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2232
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:39 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1231 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2233
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:39 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1232 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2234
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:39 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1233 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2235
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:40 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1234 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2236
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:40 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1235 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2237
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:40 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1236 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2238
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:41 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1237 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2239
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:41 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1238 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2240
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
Click for complete article, (425 words)
Article 110 of 348, 1997213253
Published on August 1, 1997, Lancaster New Era (PA)
3 of 3
6/10/2006 8:41 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1239 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2241
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:42 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1240 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2242
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:42 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1241 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2243
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
mother. Not her closest friends.. Until she was told that the man, Robert S.
Reed, 38, of 314 Greenland Drive, had been
Click for complete article, (916 words)
Article 118 of 348, 1997204477
Published on July 23, 1997, Intelligencer Journal (Lancaster, PA)
3 of 3
6/10/2006 8:42 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1242 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2244
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:42 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1243 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2245
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:42 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1244 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2246
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:42 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1245 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2247
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:43 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1246 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2248
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:43 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1247 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2249
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:43 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1248 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2250
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:45 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1249 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2251
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:45 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1250 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2252
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:45 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1251 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2253
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:46 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1252 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2254
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:46 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1253 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2255
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
Click for complete article, (625 words)
3 of 3
6/10/2006 8:46 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1254 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2256
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:47 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1255 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2257
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:47 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1256 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2258
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:47 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1257 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2259
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:47 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1258 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2260
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
Click for complete article, (761 words)
Article 177 of 348, 1997151062
Published on May 31, 1997, Intelligencer Journal (Lancaster, PA)
2 of 3
6/10/2006 8:47 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1259 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2261
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
Click for complete article, (502 words)
Article 180 of 348, 1997149095
Published on May 29, 1997, Intelligencer Journal (Lancaster, PA)
3 of 3
6/10/2006 8:47 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1260 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2262
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:48 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1261 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2263
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:48 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1262 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2264
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:48 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1263 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2265
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:48 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1264 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2266
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:48 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1265 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2267
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:48 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1266 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2268
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:50 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1267 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2269
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:50 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1268 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2270
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
Click for complete article, (245 words)
Article 210 of 348, 1997124075
Published on May 4, 1997, Sunday News (Lancaster, PA)
3 of 3
6/10/2006 8:50 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1269 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2271
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
The following is a look back at local news events during the past week.
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
Click for complete article, (533 words)
Article 213 of 348, 1997122096
Published on May 2, 1997, Intelligencer Journal (Lancaster, PA)
1 of 3
6/10/2006 8:50 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1270 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2272
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:50 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1271 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2273
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
Click for complete article, (197 words)
Article 219 of 348, 1997121067
Published on May 1, 1997, Lancaster New Era (PA)
3 of 3
6/10/2006 8:50 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1272 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2274
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:51 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1273 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2275
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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.
Click for complete article, (99 words)
Article 227 of 348, 1991173046
Published on April 27, 1997, Sunday News (Lancaster, PA)
2 of 3
6/10/2006 8:51 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1274 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2276
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
Click for complete article, (1146 words)
Article 230 of 348, 1991173044
Published on April 27, 1997, Sunday News (Lancaster, PA)
3 of 3
6/10/2006 8:51 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1275 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2277
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:52 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1276 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2278
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:52 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1277 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2279
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:52 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1278 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2280
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for complete article, (147 words)
Article 244 of 348, 1991133093
1 of 3
6/10/2006 8:53 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1279 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2281
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:53 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1280 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2282
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:53 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1281 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2283
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 4
6/10/2006 8:54 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1282 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2284
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
Click for complete article, (735 words)
Article 255 of 348, 1991122069
Published on April 22, 1997, Intelligencer Journal (Lancaster, PA)
2 of 4
6/10/2006 8:54 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1283 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2285
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
Stewart Dazell who is at fault. While few wanted their names published,
many were quick to put their feelings on the
Click for complete article, (889 words)
Article 258 of 348, 1991122075
Published on April 22, 1997, Intelligencer Journal (Lancaster, PA)
3 of 4
6/10/2006 8:54 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1284 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2286
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
PO Box 1328, Lancaster PA 17608, (717) 291-8811
Terms of Service Privacy Policy
4 of 4
6/10/2006 8:54 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1285 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2287
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:55 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1286 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2288
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:55 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1287 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2289
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
Click for complete article, (2400 words)
Article 270 of 348, 1991111846
Published on April 21, 1997, Lancaster New Era (PA)
3 of 3
6/10/2006 8:55 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1288 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2290
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:56 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1289 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2291
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:56 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1290 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2292
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
Click for complete article, (2400 words)
Article 270 of 348, 1991111846
Published on April 21, 1997, Lancaster New Era (PA)
3 of 3
6/10/2006 8:56 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1291 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2293
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for complete article, (932 words)
Article 274 of 348, 1991103150
1 of 3
6/10/2006 8:57 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1292 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2294
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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.
Click for complete article, (1830 words)
Article 277 of 348, 1991103145
Published on April 20, 1997, Sunday News (Lancaster, PA)
2 of 3
6/10/2006 8:57 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1293 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2295
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:57 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1294 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2296
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
1 of 3
6/10/2006 8:58 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1295 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2297
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:58 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1296 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2298
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:58 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1297 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2299
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
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
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
Click for complete article, (151 words)
Article 294 of 348, 1991072088
1 of 3
6/10/2006 8:58 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1298 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2300
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
2 of 3
6/10/2006 8:58 AM
LancasterOnline.com:
Archives
search for lisa michelle lambert
A...
January January
Sunday
22, 2017
22, 2017
Page
1299 http://nl.newsbank.com/nl-search/we/Archives?p_action=list&p_to...
2301
of 2301
1299
Stan J. Caterbone LAMBERT CASE FILE
3 of 3
6/10/2006 8:58 AM