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Stanley J. Caterbone
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
_________________________________________________________________________
IN THE SUPREME COURT OF PENNSYLVANIA
MIDDLE DISTRICT
__________________________________________________________________________________
IN THE MATTER OF
FULTON BANK
:
:
:
:
:
:
:
:
Respondent
v.
STANLEY J. CATERBONE
Petitioner
AND NOW on this 20th day of July, 2007, I Stanley J. Caterbone, APPELLANT, do hereby petition
the Supreme Court of Pennsylvania to reconsider the ORDER for the Petition for Allowance of Appeal
dated July 6, 2007.
Parties:
Fulton Bank
One Penn Square
Lancaster, PA 17602
Shawn Michael Long, Esquire, Attorney of Record
Barley Snyder, LLC
126 East King Street
Lancaster, PA 17603
The Honorable Michael A. Georgelis
Court of Common Pleas
Of Lancaster County, Pennsylvania
50 North Duke Street
Lancaster, PA 17602
Respectfully submitted,
______________________________
Stanley J. Caterbone, Pro Se Litigant
1250 Fremont Street
Lancaster, PA 17603
amgroup01@msn.com
www.amgglobalentertainmentgroup.com
Page 1 of 12
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reasons why this Court must consider due process2 and the inherent implications to the
Commonwealth of Pennsylvania.
The PETITIONER will show cause that these activities are to disrupt, deter,
and undermine the PETITIONERS Constitutional right to due process and access to the
Courts4.
Commonwealth v. Haggentstaller, 699 A. 2d 767 (Pa Superior, 1997), Pro Se Appellant sought review of
Conviction for violation of County for violation of County ordinance with Rule of Appellant Procedure, court
conducted a thorough, independent review of the record, and found sufficient evidence to sustain the conviction.
Hempfield Township v. Hapchuck 153 Pa. Comwlth. 173620 A. 2d. 668 (1993) Pro Se Brief failed to comply with
Pa. Rules of Appellate Procedure, but the failure to comply did not substantially impede the Courts ability to
review the issues presented and therefore considered the merits of the case.
2
In Pederson v. South Williamsport Area School District, the courts interpreted due process, as Essentially
fundamental fairness is exactly what due process means. Furthermore, the United States District Courts in Perry
v. Coyler (1978, 524 F 2d. 644) have concluded the following: Even the probability of unfairness can result in a
defendant being deprived of his due process rights.
3
Under Pennsylvania Law, conspiracy may be proved by circumstantial evidence that is by acts and circumstances
sufficient to warrant an inference that the unlawful combination has been in front of facts formed for the purpose
charged. See Walcker v. North Wales Boro, 395 F. Supp. 2d. 219. In the same case the following was supported:
Arrestees allegations that the township (Conestoga) and its police officers were acting in concert and conspiracy
and with the purpose of violating arrestees constitutional rights by subjecting him to unreasonable force, arrest,
search, and malicious prosecution and the two (2) or more officers acted together in throwing arrestee to the
ground (April 5th, 2006 and August 4th, 2006) and forcing him to take two (2) blood tests and holding him in
custody. The preceding pleaded civil conspiracy claims under Pennsylvania Law.
4
1983 Civil Rights Acts and 18 U.S.C.A. Acts state the following: The underlying purpose of the scheme of
protecting constitutional rights are to permit victims of constitutional violations to obtain redress, to provide for
federal prosecution of serious constitutional violations when state criminal proceedings are ineffective for purpose
of deterring violations and to strike a balance between protection of individual rights from state infringement and
protection from state and local government from federal interference, 18 U.S.C.A. 241, 242; U.S.C.A. Const.
Case No. MAL 248 2007
Page 2 of 12
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3. These activities, when effectively reviewed and examined, will prove to be the reason
that the PETITIONER has difficulty filing any appeals on a timely basis, and any court
related filing without technical difficulties.
large, has legal and financial exposure with regards to the PETITIONERS Federal False
Claims Act5 and Whistle-Blowing activities in the case of International Signal & Control,
Plc, (ISC) that dates back to 1987.
4. Since the PETITIONER filed his complaint in the United States District Court for the
Eastern District of Pennsylvania (Case No. 05-2288), these activities were increased in
both occurrences and arrogance.
between
Department
of
Corrections
employees
and
inmates."
Judge
McLaughlin also found that a former prison superintendent and official "fostered an
attitude of acquiescence toward such pervasive misconduct."
6. The PETITIONER filed an Affidavit to Ms. Christina Rainville, the pro bono counsel for
Lisa Michelle Lambert, in 1998 that will prove the PETITIONERS past attempts at
justice regarding the issues presented to this Court as being both a motive of his
perpetrators and a record of this continued misconduct and criminal activity to deny
the PETITIONER his right to due process and access to the courts.
In totality this
Art. 2, 53; Amend. 13, 14, 5, 15, 2: 42 U.S.C.A. 1981-1982, 1985, 1988, Fed. Rules Civil Proc. Rule 28,
U.S.C.A.
3729. False claims; 3730. Civil actions for false claims; 3731. False claims procedure; 3732.
False claims jurisdiction; 3733. Civil investigative demands; 3729. False claims.
Page 3 of 12
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will be proven
my
shareholder
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
Page 4 of 12
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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
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.
Case No. MAL 248 2007
Page 5 of 12
Defendants
07/20/2007
and
commercial
enterprises
had
financial
interests.
The
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.
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.
towards
the
plaintiffs
activities
and
actions
are
matter
of
record,
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
Case No. MAL 248 2007
of
the
plaintiffs
alleged
intellectual
Page 6 of 12
capacity.
The
plaintiff
07/20/2007
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 (RICO)6.
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.
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
6
The Racketeer Influenced and Corrupt Organizations Act (commonly referred to as RICO) is a United States
federal law which provides for extended penalties for criminal acts performed as part of an ongoing criminal
organization. RICO was enacted by section 901(a) of the Organized Crime Control Act of 1970, Pub. L. No. 91452, 84 Stat. 922 (Oct. 15, 1970). RICO is codified as Chapter 96 of Title 18 of the United States Code, 18 U.S.C.
1961 through 18 U.S.C. 1968.
Case No. MAL 248 2007
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PETITIONER has had 27 criminal citations withdrawn, Nolle Pros, or overturned since
1987, and most in the past six months. The PETITIONER has successfully litigated a
majority as a pro se litigant.
10. Furthermore, in the past week, the Commonwealth of Pennsylvania and the Lancaster
County District Attorneys Office had impugned its own integrity and obstructed justice
in the two cases Commonwealth of Pennsylvania v. Stanley J. Caterbone CP-36-CR0004771-2006; CP-36-CR-0003179-2006.
In CP-36-CR-0004771-2006 a negotiated
agreement to nolle pros the charges on July 2, 2007 by Assistant District Attorney with
the PETITIONERS attorney, Paul G. Campbell, were completely ignored and delayed
until the September trial court term for malicious and political reasons. This tactic has
left the PETITIONER under bail supervision and under the confines of Lancaster
County, which precludes the PETITIONER from visiting the Federal Courthouse in
Philadelphia and Reading to continue his civil litigation.
Page 8 of 12
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moving to issue a retrial. This can be verified when the Probation and Parole Office
discontinued efforts for the Pre Sentence Investigation and canceled a psychological
evaluation for the PETITIONER. The tandem effect is that after several motions by the
PETITIONER for Judge Cullen to recuse himself from case no. CP-36-CR-00031792006, which is also contained in the Post Trial Motion to Acquit, Judge James P. Cullen
has essentially obstructed justice due to the fact that he is a defendant in this case.
Judge Cullen also continues to place the PETITIONER as a Defendant in criminal
proceedings by not making a ruling on the Post Trial Motion to Acquit after both sides
presented written arguments.
himself from any and all cases when a clear conflict of interest is present.
12. Another instance where the Commonwealth of Pennsylvania impugned its own
integrity is found in the case no. 360234927-002M Stanley J. Caterbone v. the
Department of Public Welfare and the Bureau of Appeals and Hearings.
In this
instance Administrative Law Judge Robert S. Rosen ruled against the PETITIONER in a
challenge to the DPW discontinuance of Food Stamp Benefits and cited that the
PETITIONER had failed to supply documents to the ALJ Rosen.
The PETITIONER
produced a United States Postal Priority Mail Confirmation that proved ALJ Rosen had
misrepresented the truth. Further Arrogance by the Commonwealth of Pennsylvania
was demonstrated when on July 2, 2007, the Department of Public Welfare DENIED
the PETITIONERS appeal for rehearing and reconsideration in a clear and overt effort
to cover up ALJ Rosens blatant disregard for the truth and the law.
13. Another instance of judicial misconduct and contempt was cited on July 12, 2007. The
PETITIONER received a Adjudication DISMISSAL Order today for an Appeal Hearing
that was scheduled for July 2, 2007.
available, nor did the Appellant provide good cause for not being available. Because
the Appellant has failed to pursue the appeal, it will be dismissed in accordance with
55 Pa. Code 275.4(e)(6)(iii)(A)(9I 94).
mailed in the Reply to Bureau of Hearings and Appeals and that contained the
following: I will not be available for the hearing because:
LANCASTER COUNTY
Page 9 of 12
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14. In July of 2006 the PETITIONER emailed the President of the United States, President
George W. Bush.
As soon as I frame my
arguments for a petition for your Impeachment, I will forward to your Attorney
General. I am tired of living in a county and state where there is no Rule of Law.
15. The PETITIONER was sending a message about the dire nature of the obstruction of
justice and the fact that the PETITIONER had justified suspicion of the Administrations
possible overt intimidation in the PETITIONERS Federal Chapter 11 Bankruptcy Case
No. 05-23059 and continued wrongdoing by the Department of Justice Office of the
Trustee. These allegations are described in various Federal Court filings and briefs.
16. On July 3, 2007, in an American Research Group Poll presented on the FOX News
Network, 45% of those polled favored the start of impeachment proceedings against
the President, while only 46% did not favor starting impeachment proceedings.
For
Vice President Dick Cheney, 54% of those polled favored the start of impeachment
proceedings.
and must not be intimidated and retaliated against for such views and opinions.
Complacency by Law Enforcement and Justice Officials in upholding the PETITIONERS
Constitutional and Civil Rights may be construed is some courts as being a violation of
RICO statutes, among others.
17. The Pennsylvania Constitution and the United States Constitution both guarantee the
PETITIONER a right to the Courts to resolve the allegations and complaints through
discovery and interrogatories and upon merit a right to trial by jury.
It is these
The Federal RICO statutes address the false arrests and the
participation) laws can be applied in an attempt to curb alleged abuses of the legal
system by individuals or corporations who utilize the courts as a weapon to retaliate
against whistle blowers, victims, or to silence another's speech. RICO could be alleged
Page 10 of 12
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if it can be shown that lawyers and/or their clients conspired and collaborated to
concoct fictitious legal complaints solely in retribution and retaliation for themselves
having been brought before the courts. These laws also apply to victims of clergy
abuse where statute of limitations has run out.
19. The ABA Model Code of Professional Responsibility (1983) ETHICAL CONSIDERATIONS
7-21 states The civil adjudicative process is primarily designed for the settlement of
disputes between parties, while the criminal process is designed for the protection of
society as a whole. Threatening to use, or using, the criminal process to coerce
adjustment of private civil claims or controversies is a subversion of that process;
further, the person against whom the criminal process is so misused may be deterred
from asserting his legal rights and thus the usefulness of the civil process in settling
private disputes is impaired. As in all cases of abuse of judicial process, the improper
use of criminal process tends to diminish public confidence in our legal system.
20. Over the years, the PETITIONER has solicited some 20 attorneys to help defend the
PETITIONER from the intimidation and abuse, and to seek a resolution to the issues.
However, the political implications and the alleged violations of the PETITIONERS civil
and constitutional rights made it impossible for the PETITIONER to secure private
counsel.
Respectfully submitted,
______________________________
Stanley J. Caterbone, Pro Se Litigant
1250 Fremont Street
Lancaster, PA 17603
amgroup01@msn.com
www.amgglobalentertainmentgroup.com
Page 11 of 12
07/20/2007
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing MOTION FOR A
CONTINUANCE has been served this 20th day of July, 2007, by first class mail, Postage
prepaid, by electronic mail upon, or by hand delivery:
Respectfully submitted,
______________________________
Stanley J. Caterbone, Pro Se Litigant
1250 Fremont Street
Lancaster, PA 17603
amgroup01@msn.com
www.amgglobalentertainmentgroup.com
Page 12 of 12
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