2020 Through 2021 Sunseri Email Binder1

From: KAREN SUNSERI
To: Uta von Eckartsberg; uvoneck@icloud.com; fjug@bmr-law.com

Subject: Estate of Elsa Von Eckartsberg | No. 04623 of 22020 | TEAMS Status Conference
Date: Tuesday, October 12, 2021 3:22:58 PM
Attachments: ECKARTSBERG 02 20 04623 Preliminary Order of Court.pdf
Untitled
Please see the attached Order regarding the November 10, 2021 Status Conference at 10:30 p.m. via
remote teleconference for the above captioned matter. Thank you.
Karen Sunseri
Gusty A. E. Sunseri & Associates, P. C
412-968-0210
-----Original Message-----
From: Hofmann,Tiffany <THofmann@alleghenycourts.us>
To: fjug@bmr-law.com <fjug@bmr-law.com>; gusty-sunseri@verizon.net <gusty-sunseri@verizon.net>;
Kushner Gary <GKushner@alleghenycourts.us>
Cc: Coleman Ruth <RColeman@alleghenycourts.us>
Sent: Fri, Oct 1, 2021 1:39 pm
Order attached.
1:30PM ESTATE OF ELSA VON ECKARTSBERG | NO. 04623 OF 22020 | TEAMS STATUS
CONFERENCE | F. JUG, G. SUNSERI
Order attached.
Please Note the Following:
Counsel for the Petitioner is responsible for disseminating this invitation to other
relevant parties.
Videoconference is reserved for counsel and witnesses only. Observers may join via the
phone number below.
Participants should 'join' 10 mins before the scheduled start time.
RSVP’s Only. Please do not reply to this email with questions and/or materials.
Email additional correspondence to rcoleman@alleghenycourts.us and
thofmann@alleghenycourts.us or call Chambers at (412) 350-3595
A TEAMS tutorial is available at https://www.alleghenycourts.us
Best,
Judicial Staff
Eve_5/16
From: jlockwood@sunserilawfirm.com
To: Uta von Eckartsberg
Cc: Gusty Sunseri
Subject: Estate of Elsa Von Eckartsberg
Date: Monday, February 22, 2021 6:40:16 PM
Attachments: Letter to Executor RE Documentation for Inheritance Tax Return (Von Eckartsberg) 2-22-2021.pdf
Uta,
Please see the attached correspondence from Attorney Sunseri regarding the documentation needed for the
Inheritance Tax Return.
If you have any questions, please feel free to call Attorney Sunseri.
Thank you,
Joe
Joseph A. Lockwood III, Esq.

Attorney at Law
jlockwood@sunserilawfirm.com
Gusty A.E. Sunseri & Associates, P.C.

1290 Freeport Road
Pittsburgh, PA 15238
Phone (412) 968-0210
Fax (412) 968-0254
This e-mail and any files transmitted with it are confidential and intended solely for the use of the individual or
entity to which they are addressed. If you have received this e-mail in error, please notify the sender immediately
and delete this e-mail from your system. If you are not the named addressee, you should not disseminate, distribute,
or copy this e-mail. If you are not the intended recipient, you are notified that disclosing, copying, distributing, or
taking any action in reliance on the contents of this information is strictly prohibited.
Eve_5/16
From: jlockwood@sunserilawfirm.com
Cc: Gusty Sunseri
Subject: Estate of Elsa Von Eckartsberg
Date: Thursday, April 15, 2021 4:33:32 PM
Attachments: Letter to Client RE Inheritance Tax Return Documentation (Von Eckartsberg) 4-15-2021.pdf
Letter to Executor RE Documentation for Inheritance Tax Return (Von Eckartsberg) 2-22-2021.pdf
Uta,
Please see the attached correspondence from Attorney Sunseri. If you have any questions, please feel free to call
our office at 412-968-0210.
Thank you,
Joe

Attorney at Law

1290 Freeport Road
Phone (412) 968-0210
Fax (412) 968-0254
This e-mail and any files transmitted with it are confidential and intended solely for the use of the individual or
entity to which they are addressed. If you have received this e-mail in error, please notify the sender immediately
and delete this e-mail from your system. If you are not the named addressee, you should not disseminate, distribute,
or copy this e-mail. If you are not the intended recipient, you are notified that disclosing, copying, distributing, or
taking any action in reliance on the contents of this information is strictly prohibited.
Eve_5/16
From: Gusty A.E. Sunseri
To: Uta Von eckartsberg; Uta Von eckartsberg
Subject: Estate of Elsa von Eckartsberg
Date: Thursday, October 7, 2021 2:14:53 PM
Uta Would you agree to allow me to withdraw as Counsel for the Estate. If you will not
consent, I will have to file a Motion for Leave to Withdraw. which I am in the process of
drafting. Please let me know.
Eve_5/16
From: Uta von Eckartsberg
Bcc: uvoneck@outlook.com
Subject: Export copy of cases probate reviewed Gs
Date: Sunday, May 16, 2021 1:40:10 PM
Attachments: 2021 Mar 20 compare GS other cases probate corr Will , 9.57 PM.pdf
Uta von Eckartsberg, Esq.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended recipient(s)
and may contain confidential and privileged information. If you are not the intended recipient,
please do not read, distribute, or take action in reliance upon the message. If you have received
this message in error, please notify the sender immediately by return e-mail and promptly
delete this message and its attachments from your computer system. Be advised that no
privileges are waived by the transmission of this message.
Eve_5/16
To: Gusty Sunseri
Subject: FU (ACP)
Date: Wednesday, October 14, 2020 12:00:29 PM
Are you in a position to give your opinion on the car title and TIAA tax Q today. I know I
gave you a laundry list of items but at the moment these are a priority. Want to get the MV 39
out today. Thx

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
Eve_5/16
From: uvoneck@outlook.com
To: markpenzel@yahoo.com
Subject: FW: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg -ACP
Date: Thursday, February 18, 2021 7:00:06 PM
Attachments: SCREEN SHOT PUBLIC RECORD EVIDENCE REPRESENTATIVE EXAMPLES .doc
Screenshot evidentiary folders 5600 FRAUD.docx
2.9.2021 FACTS IN STYLE ONE.docx
01.27.2017_email.no.2.pdf
01.27.2017_to.nyro.team.collusive.hedge.funds.etc.._fw~_jrock_ta,_etc._cover.email (1).pdf
FW_ Confidential Update III [SPNGE].pdf
Mark,
When we spoke years ago about my then-works issues, I know you thought I was crazy. The fact is
that unbeknownst to me at the time is that I was the target of retaliatory harassment over the course
of more than a decade for what I now recognize was inadvertent whistleblowing. Such conduct
violates both the federal sector whistleblower protection acts and is a prohibited personnel practice
as a matter of law and fact pursuant federal sector employments which are not at all equivalent to
private sector employment discrimination cases. It was not after I was forced into an early
retirement in retaliation for having run a great investigation and as part the cover-up of the same; that
I began to understand what happened to me and why. All my close friends at the time who
practiced employment law also thought I was crazy so don’t feel bad. I am telling you this only
because I need you to take me seriously as I have asked our probate lawyer to do for my brothers’
sake. My entire family is disabled as in cognitively impaired and has been for a very long time. If
I drop dead tomorrow, I need someone to look out for my brothers. If I am not here or cannot
singlehandedly prevail against separate but related criminal networks which include certain corrupt
insiders at my former agency, I just want you to make sure a good lawyer reviews my evidentiary
records to protect my brothers’ financial future. I have POA whom I trust but she is not a lawyer
and she is not family.
The attached screenshots are simply of my evidentiary records with respect to the instant matter. I
have all my evidentiary records from the SEC as well as of hard evidence of the ongoing retaliatory
that I continue to endure. If you want to why anyone would that care that much about me - trust me
it’s not because I am particularly smart or have any special knowledge. Rather, it’s basically
because after ten minutes of reviewing the applicable SEC filings I can tell you exactly who the
undisclosed control persons of the GameStop are as well as who coordinated touters are on Reddit.
And right now, every single investor has a right to recission under Section 5 of the Securities Act
because at all relevant times the control persons of the issuer sold unregistered securities when no
exemption or safe harbor was available to it. Full stop.

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
DISCLAIMER: This e-mail message is intended only for the personal use of the recipient(s) named
above. This message may be an attorney-client communication and as such privileged and
confidential and/or it may include attorney work product. If you are not an intended recipient, you
may not review, copy or distribute this message. If you have received this communication in error,
please notify us immediately by e-mail and delete the original message and its attachments from
your computer system. Please be advised that no privileges are waived by the transmission of
this message.
Eve_5/16
Sent: Thursday, February 18, 2021 6:13 PM
To: Gusty A.E. Sunseri <gusty-sunseri@verizon.net>
Cc: uvoneck@outlook.com
Subject: RE: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg -ACP
Gusty,
Judge Della Vecchio has major conflicts and should recuse himself. Do you know him? Do you
happen to have a conflict with him? Attached for your information are my backup evidentiary and
research files on 5600 Munhall. What is happening and has happened at this building is a major
fraud. There is no condominium here. And it appears that my mother was a defrauded bona fide
buyer who was sold a fictitious condominium meaning she has been paying rent not HOA fees, etc.
My mother has been defrauded by perhaps millions of dollars. All of this is public record evidence
but not anywhere you could easily find. Just compare my research on the chain of title for my mom
versus what my mom’s so-called deed reflects and what Joe or I could track versus the facts.
Jug’s pleading is a fraud on the Court which I can easily prove by public record. And Jug’s co-
conspirator, Art Goldberg, is responsible for millions if not billions of lost investor funds over the
past three decades and is running a security fraud out of the building. He is a conspirator with
international, mostly Israeli or Russian members of organized criminal networks largely based in
Brooklyn (and Squirrel Hill it seems – who knew?!).. He is also engaging in unauthorized practice
of law and accounting in Pennsylvania which is a felony in New York where he was licensed.
Please do not spend a lot of time looking at this because I have to move the estate funds out of
citizens but wanted to file a criminal complaint first for some of the reasons touched upon in the
draft statement of facts (trust me I have a zillion versions). I need pleading templates. I do not
have software nor the technical skills to create a numbered, captioned pleading.
This building has been the center of a organized criminal network implicating both white collar
racketeering and straight up RICO. The tenants and co-conspirators in this building include Thomas
Skelton who was indicted for multiple murders for hire and then tax fraud after which he allegedly
disappeared. These people preyed on my mother particularly once they knew she had Alzheimer’s
and this building’s defrauded, bona fide purchasers that actually reside here are all over 80 and are
truly at risk. Big picture this is a decades mortgage fraud-type scheme. Do you know DA
Zappala? He is probably the only criminal authority in this area that would probably not be
conflicted out of any criminal investigation of this particular matter. The people in this building are
dangerous so I am literally trusting you with my life given that the bad actors in this building have
no idea of how much I know. Again, I share the attached emails regarding my SEC investigations
as well as my evidentiary records because I need you to take me seriously.
Thanks.
Uta
PS Truist sent a 1099 representing they “forgave” or discharged the fraudulent creditor claim. For
whatever that is worth.
Eve_5/16
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.
From: Gusty A.E. Sunseri <gusty-sunseri@verizon.net>

To: Uta Von eckartsberg <uvoneck@outlook.com>
Subject: Fw: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg
Importance: High
Uta I just received this scheduling order. See below.
From: Law Linda

To: fjug@bmr-law.com ; uvoneck@outlook.com ; gusty-sunseri@verizon.net
Subject: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg
Good afternoon,
Argument on the Emergency Motion for Special Injunction in the above matter will be heard by
Judge Michael A. Della Vecchia on February 24, 2021, at 2:00 p.m. via telephone conference. To
access the argument, please call 1-877-953-7157 and enter conference code 416 7541#
Please feel free to email or call our chambers if you have any questions. We are continuing to work
remotely, but do check voice mail regularly.
Linda Law, Secretary
(412) 350-0281
Eve_5/16
To: Tonio @ Yahoo Rolf-tonio Von eckartsberg; Tobias voneckartsberg; rolf-tonio@hotmail.com; rolf-
tonio@hotmail.com
Subject: FW: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg -ACP
Date: Friday, March 12, 2021 2:17:00 PM
Attachments: SCREEN SHOT PUBLIC RECORD EVIDENCE REPRESENTATIVE EXAMPLES .doc
Screenshot evidentiary folders 5600 FRAUD.docx
2.9.2021 FACTS IN STYLE ONE.docx
01.27.2017_email.no.2.pdf
01.27.2017_to.nyro.team.collusive.hedge.funds.etc.._fw~_jrock_ta,_etc._cover.email (1).pdf
And yet another awesome lawyer not looking out for us…
From: Gus Sunseri <gusty-sunseri@verizon.net>

Sent: Friday, February 19, 2021 9:45 AM
To: Uta von Eckartsberg <uvoneck@outlook.com>
Subject: Re: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg -ACP
When would you be available to talk
Sent from my iPhone
On Feb 18, 2021, at 6:13 PM, Uta von Eckartsberg <uvoneck@outlook.com> wrote:
Gusty,
Judge Della Vecchio has major conflicts and should recuse himself. Do you know
him? Do you happen to have a conflict with him? Attached for your information are
my backup evidentiary and research files on 5600 Munhall. What is happening and
has happened at this building is a major fraud There is no condominium here. And it
appears that my mother was a defrauded bona fide buyer who was sold a fictitious
condominium meaning she has been paying rent not HOA fees, etc. My mother has
been defrauded by perhaps millions of dollars. All of this is public record evidence but
not anywhere you could easily find. Just compare my research on the chain of title for
my mom versus what my mom’s so-called deed reflects and what Joe or I could track
versus the facts.
Jug’s pleading is a fraud on the Court which I can easily prove by public record. And
Jug’s co-conspirator, Art Goldberg, is responsible for millions if not billions of lost
investor funds over the past three decades and is running a security fraud out of the
building. He is a conspirator with international, mostly Israeli or Russian members of
organized criminal networks largely based in Brooklyn (and Squirrel Hill it seems –
who knew?!).. He is also engaging in unauthorized practice of law and accounting in
Pennsylvania which is a felony in New York where he was licensed. Please do not
spend a lot of time looking at this because I have to move the estate funds out of
citizens but wanted to file a criminal complaint first for some of the reasons touched
upon in the draft statement of facts (trust me I have a zillion versions). I need pleading
templates. I do not have software nor the technical skills to create a numbered,
captioned pleading.
Eve_5/16
This building has been the center of a organized criminal network implicating both
white collar racketeering and straight up RICO. The tenants and co-conspirators in
this building include Thomas Skelton who was indicted for multiple murders for hire
and then tax fraud after which he allegedly disappeared. These people preyed on my
mother particularly once they knew she had Alzheimer’s and this building’s defrauded,
bona fide purchasers that actually reside here are all over 80 and are truly at risk. Big
picture this is a decades mortgage fraud-type scheme. Do you know DA Zappala? He
is probably the only criminal authority in this area that would probably not be
conflicted out of any criminal investigation of this particular matter. The people in this
building are dangerous so I am literally trusting you with my life given that the bad
actors in this building have no idea of how much I know. Again, I share the attached
emails regarding my SEC investigations as well as my evidentiary records because I
need you to take me seriously.
Thanks
Uta
PS Truist sent a 1099 representing they “forgave” or discharged the fraudulent creditor
claim. For whatever that is worth.

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
DISCLAIMER: This e-mail message is intended only for the personal use of the
recipient(s) named above. This message may be an attorney-client communication
and as such privileged and confidential and/or it may include attorney work product.
If you are not an intended recipient, you may not review, copy or distribute this
message. If you have received this communication in error, please notify us
immediately by e-mail and delete the original message and its attachments from your
computer system. Please be advised that no privileges are waived by the
transmission of this message.

Subject: Fw: GD 21-001293; Imperial House Condominium Association v Uta Von
Eckartsberg
Importance: High
From: Law Linda
Eve_5/16
Good afternoon,
Argument on the Emergency Motion for Special Injunction in the above matter will be
heard by Judge Michael A. Della Vecchia on February 24, 2021, at 2:00 p.m. via
telephone conference. To access the argument, please call 1-877-953-7157 and enter
conference code 416 7541#
Please feel free to email or call our chambers if you have any questions. We are
continuing to work remotely, but do check voice mail regularly.
(412) 350-0281
Eve_5/16
To: Gusty Sunseri
Subject: FW: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got this. How long do I have to
respond; This injunction is a fraud on the Court.
Attachments: doc00425620210218123024.pdf
IMPERIAL HOUSE PROPOSED ORDER.docx
Importance: High
What is the procedure on this? I want to file a motion for special injunction in response…..l;

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.
From: Fred C Jug <fjug@bmr-law.com>

To: Civilgenmotions@alleghenycourts.us
Cc: 'Uta von Eckartsberg' <uvoneck@outlook.com>; gusty-sunseri@verizon.net
Subject: Imperial House Condominium v. Von Eckartsberg GD 21-001293
Please find attached an Emergency Motion For Special Injunction and a Proposed Order. The
Proposed Order is provided in word format pursuant to the Standard Operating Procedures of
the Court. The Plaintiff would appreciate this matter now be scheduled. The Motion has also
been mailed to the Defendant and the defendant is copied on this email. A courtesy copy is
also being provided to counsel for the estate who is also copied on this email as no appearance
has been entered yet in this case. Your attention to this matter is appreciated.
Fred C. Jug, Jr. Attorney

Brandt, Milnes & Rea, P.C.
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
Email: fjug@bmr-law.com
This electronic message and any attachments transmitted with it contain information that may
Eve_5/16
be privileged and confidential. The information is intended for the use of the intended
recipients only. If you are not an intended recipient, note that any disclosure, copying,
distribution or use of the contents of this message is prohibited. If you have received this
message in error, please contact the above sender and delete this message immediately.
Eve_5/16
To: Gusty Sunseri
Subject: FW: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got this. How long do I have to
Importance: High

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
Eve_5/16
Eve_5/16
Subject: Fw: Estate of Elsa Von Eckartsberg | No. 04623 of 22020 | TEAMS Status Conference
Date: Friday, October 1, 2021 1:54:51 PM
Attachments: ATT00046.ics
ECKARTSBERG 02 20 04623 Preliminary Order of Court.pdf
Uta Please see the attached. I will be filing a Motion for Withdraw next week. Feel free to call
me to discuss.
From: Hofmann,Tiffany
Sent: Friday, October 1, 2021 1:39 PM
To: fjug@bmr-law.com ; gusty-sunseri@verizon.net ; Kushner Gary
Cc: Coleman Ruth
Order attached.
1:30PM ESTATE OF ELSA VON ECKARTSBERG | NO. 04623 OF 22020 | TEAMS STATUS
CONFERENCE | F. JUG, G. SUNSERI
Order attached.
Please Note the Following:
Counsel for the Petitioner is responsible for disseminating this invitation to

other relevant parties.
Videoconference is reserved for counsel and witnesses only. Observers may join
via the phone number below.
Participants should 'join' 10 mins before the scheduled start time.
RSVP’s Only. Please do not reply to this email with questions and/or materials.
Email additional correspondence to rcoleman@alleghenycourts.us and
thofmann@alleghenycourts.us or call Chambers at (412) 350-3595
A TEAMS tutorial is available at https://www.alleghenycourts.us
Best,
Judicial Staff
Eve_5/16
To: Uta Von eckartsberg
Importance: High
From: Law Linda

Good afternoon,
(412) 350-0281
Eve_5/16
Subject: Fw: Imperial House Leak in 309
Date: Tuesday, August 31, 2021 1:13:55 PM
Uta please see the email below.
From: Fred C Jug

Sent: Tuesday, August 31, 2021 11:39 AM
To: Gusty-sunseri@verizon.net
Subject: FW: Imperial House Leak in 309
Dear Gusty: Hope you are doing well. Please see the email below which was forwarded to me
by my client. Since the Unit appears to still be owned by the estate and is an asset of the estate
it would be sincerely appreciated if you would follow up with your client and resolve this
situation before additional damage occurs and further action is necessary. Your prompt
attention to this matter would be sincerely appreciated.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Norman Stankewicz <i.housecondo@att.net>

Date: Tuesday, August 31, 2021 at 8:50 AM
To: Uta Von Eckartsberg <uvoneck@outlook.com>, Uta Von Eckartsberg
<uvoneck@icloud.com>
Cc: Norman Stankewicz <i.housecondo@att.net>
Subject: Imperial House Leak in 309
Good morning Ms. Von Eckartsberg
We have a leak into our office coming from your unit. We have knocked at the door with no
answer. As you can see from the photo, we have buckets collecting the water.
Eve_5/16
We need to have access to your kitchen to determine the source of the leak. We do not have a
key so we were unable to enter the unit.
Please contact us at your earliest convenience so we can make arrangements to address this
leak. If the leak worsens, we will be forced to bring a locksmith in to enter the unit. If there
is an emergency water break and water floods our office, we may have to force the door open
to enter your unit.
I am asking for your help so we can address this issue as soon as possible.
Please call our office at 412-421-4700 or kindly respond to this email message
Thank you for your prompt attention to this matter
Norman
Imperial House Office
Sent from my iPhone
Eve_5/16
Subject: Fw: Imperial House Condominium v. Von Eckartsberg GD 21-001293

Subject: Fw: Imperial House Condominium v. Von Eckartsberg GD 21-001293
Uta The attached was just sent to me. Please call me for discussion.
From: Fred C Jug

Cc: 'Uta von Eckartsberg' ; gusty-sunseri@verizon.net

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
Eve_5/16
Subject: Fw: Von Eckartsberg - Motion to Withdraw Appearance
Date: Monday, October 11, 2021 2:28:32 PM
Attachments: Von Eckartsberg - Motion to Withdraw Appearance FINAL_10112021_000216.pdf
Uta Please see the attached. The same was mailed.
From: paralegal@sunserilawfirm.com
Sent: Monday, October 11, 2021 12:22 PM
To: Gusty A.E. Sunseri
Subject: Von Eckartsberg - Motion to Withdraw Appearance
Scan attached for emails
Eve_5/16
Subject: Fwd: Estate of Elsa Von Eckartsberg
MTF. Today when I told Gusty that about the fact that there was no leak and this was a fraud
on the court. He told me to go along to get along. And this is right after I identified his role as
partner to Cicero and at Mezzo aka First American — see the criminal case. The issue is that
it appears he is engaged or at least accused the same exact that I have reported to him about
others that have preyed on my mother and now me. I am terrified he will get a hit man after
me. And I do not understand why he is not offended at the blatant harrassment and bullying
that I am being subjected to. Nor why he does not feel a responsibility to call Jug out for
professional misconduct. He thinks I should go Along to get along. Then I confronted him
with this? He became very defensive, then said he would quit — he didn’t feel comfortable. I
reminded him that he could not just withdraw.
Now when he knows how overwhelmed I am and how much I have trusted him and counted
on him to have my back, he piling on by sending this shitty letter. This is after I send him a
million emails asking him what I was supposed to do so that I did not miss any deadlines, etc.
There is nothing I have done that he did not tell em was okay. And now he is making it very
clear that he is def not going to help me or have my back. And on top of everything, when we
spoke Friday, he asked me to write agreeing to let them in with limited scope, etc. it was after
that when I confirmed that the whole thing was a blantant lie. Now I will never get anyone
here to represent me or help me in any way whatsoever. I don’t see why everyone in this
town but me had no respect for the rules of professional conduct or integrity. And I am scared
of Gusty. His partner was a good man and they are all under the Relogy bucket — First
American appears to be a subsidiary just like Gemsta my mom’s title insurance.
And

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
Eve_5/16
Begin forwarded message:
From: Uta von Eckartsberg <uvoneck@outlook.com>

Date: February 22, 2021 at 6:57:02 PM EST
To: jlockwood@sunserilawfirm.com
Cc: Gusty Sunseri <gusty-sunseri@verizon.net>
Subject: Re: Estate of Elsa Von Eckartsberg
Thanks so much. Appreciate your help.
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended
recipient(s) and may contain confidential and privileged information. If you are
not the intended recipient, please do not read, distribute, or take action in reliance
upon the message. If you have received this message in error, please notify the
sender immediately by return e-mail and promptly delete this message and its
attachments from your computer system. Be advised that no privileges are waived
by the transmission of this message.
On Feb 22, 2021, at 6:40 PM, jlockwood@sunserilawfirm.com

wrote:
Uta,
Please see the attached correspondence from Attorney Sunseri

regarding the documentation needed for the Inheritance Tax Return.
Thank you,
Joe
Eve_5/16
Attorney at Law

1290 Freeport Road
Phone (412) 968-0210
Fax (412) 968-0254
This e-mail and any files transmitted with it are confidential and
intended solely for the use of the individual or entity to which they
are addressed. If you have received this e-mail in error, please notify
the sender immediately and delete this e-mail from your system. If
you are not the named addressee, you should not disseminate,
distribute, or copy this e-mail. If you are not the intended recipient,
you are notified that disclosing, copying, distributing, or taking any
action in reliance on the contents of this information is strictly
prohibited.
Eve_5/16
Subject: Fwd: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got this. How long do I have to respond; This injunction
is a fraud on the Court.
Date: Monday, March 22, 2021 8:13:30 PM
https://www.pillsburylaw.com/images/content/2/4/v2/2458/0A2CEF551BAAB8AC5609A63540231EA3.pdf
Under Pennsylvania Rule of Civil Procedure 1531(a), a court may issue a preliminary or special injunction
only after written notice and a hearing “unless it appears to the satisfaction of the court that immediate and
irreparable injury will be sustained before notice can be given or a hearing held, in which case the court
may issue a preliminary or special injunction without a hearing or without notice.” Pa. R.C.P. 1531(a).
Although the terms “preliminary injunction” and “special injunction” are not defined in the Rule, it appears
that when an order is issued ex parte and without notice that the order is analogous to the entry of a “special
injunction.” Steel City Group v. Global Online Direct, Inc., 2006 U.S. Dist. LEXIS 86831, at **5-6 (W.D.
Pa. Nov. 30, 2006). A “special injunction” usually seeks relief that is auxiliary to the main relief requested
in the complaint. In re Franklin Township Bd. Of Supervisors, 379 A.2d 874, 879 (Pa. 1977). The state
court Emergency Judge in this case titled his order a Temporary Ex Parte Restraining Order, a term not
used in the Pennsylvania injunction statute. It appears, however, that the TRO is in the nature of a “special
injunction,” and will so be considered by this Court in reviewing the propriety of the issuance of the TRO
on April 22, 2009, and whether it should be dissolve
otherwise be inappropriate.
Injunction clauses still may be useful
Although an injunction clause cannot guarantee injunctive relief,
that does not mean such clauses are worthless. In several ways, an injunction clause may assist a party
seeking an injunction.
Variations on this type of injunction clause are appearing with increa- ing frequency in IP contracts:
It is agreed that the rights and benefits of each of the parties pursuant to this Agreement are uniques and
that no adequate remedy exists at law if any of the parties shall fail to perform, or breaches, any of its
obligations hereunder, that it would be difficult to determine the amount of damages resulting therefrom,
and that such breach would cause irreparable injury to the non-breaching lparties. Therefore, the non-
breaching party shall be entitled to injunc-
tive relief to prevent or restrain any breach of this Agreement.
Contracts containing injunction clauses, in which the parties agree that a court must grant them an
injunction upon request, can often give parties a false sense of security regarding remedies for injunctive
relief. In such clauses, the contracting parties stipulate that a breach of the agreement would meet the
factual requirements for an award of injunctive relief. After having laid a factual groundwork, the parties
declare that an innocent party will be legally entitled to an injunction in the event of a breach.
But do contracting parties really have the authority to compel a court to grant one of them an injunction
upon request? Courts have fre- quently answered that question “no”. Thus, while an injunction clause is of
some use, it cannot guarantee injunctive relief.
No ticket to injunctive relief
Courts examining injunction clauses have made clear that these provisions cannot guarantee an automatic
injunction.
To begin with, the contracting parties have no right to decide whether to grant injunctive relief. Rather, that
decision lies within the court’s discretion.
Courts have also recognised that the recitals in an injunction clause may be inaccurate. At the time the
contract is signed, the parties lack foreknowledge of the nature or consequences of a particular breach.
Even if the anticipated consequences occur, the parties might simply be wrong in characterising the harm
as “irreparable”. For example, in First Health Group Corp v Nat’l Prescription Adm’rs, Inc (MD Pa 2001),
when a medical benefits manager sought to enforce non- competition, non-solicitation and confidentiality
agreements against its former employee, the presence of
Eve_5/16
Pillsbury Winthrop Shaw Pittman LLP

412.207.7742 (PH)
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Date: February 19, 2021 at 4:32:25 PM EST
Subject: Re: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got
this. How long do I have to respond; This injunction is a fraud on the Court.
Go to Fifth Judicial District of Pennsylvania

Go to Civil
Motions and local rules are on the Civil Home page
Sent from my iPhone
On Feb 19, 2021, at 4:25 PM, Uta von Eckartsberg <uvoneck@outlook.com>

wrote:
PS. Can you tell me how to access the court calendar? I want to know whether or
not Judge D. is set as motions court judge this week and next. I do not know how
to access the right calendar... thx

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
Eve_5/16
On Feb 19, 2021, at 3:49 PM, Uta von Eckartsberg

<uvoneck@outlook.com> wrote:
Gusty,
Did you notice that he is doing an end run around @ due process by
filing an equity special injunction which means that I get no due
process whatsoever? And that even a special injunction proceeding
must be filed with motions court not with the Judge of your choosing?
Special injunctive actions under 1531 are to preserve the status quo
once litigation has commenced. It is attached to a “heretofore” filed
action. And absent a lien or dispute as to ownership, it is well-settled
that there is no jurisdiction for the Court to even entertain such an
injunctive action. Furthermore, would be a contested motion which
required compliance with motions court practice as to filing.
Also, in case you didn’t notice he is not asking whether you will
accept service on the baseless injunction but rather he is trying to trick
you or me to waive service on the several pages of paper attached to
the PI motion loosely described a “Complaint” for some cause of
action not intensified, for possible damages related to the “BODs”
year long failure to remedy the leaking of the “electrical” vault into
the basement which of course I am not even minimally responsive for.
He also got someone to enter that baseless “complaint” which does
not even minimally satisfy either rule of court (no affidavit of service,
no cover, no damages, etc.) as if he filed a day before the injunctive
motion. And all of this is simply so that he get before the Judge he
knows will find for him and whom he obviously contacted directly as
if there were an existing litigation which there is not. And it evident
from the fictitious complaint that they are seeking damages. That is a
contract based claim. Furthermore, they are adding me personally as
defendant no reason that they identify in their complaint.
I have no practice experience in Allegheny Court whatsoever so I am

concerned that it is not you and Joe who are pointing this stuff out to
me.
He is seeking the extraordinary remedy of ex parte injunctive relief

for a leak that by his count had been ongoing for two weeks (Feb. 1).
Again, four floors below me. I have no water leak, their offices right
below me have no water leak, the first floor of the garage has no water
leak. This is abuse of process.
Furthermore, I gather that you are not taking my substantive concerns

seriously. Arthur Goldberg is dangerous to me and he is stalking me.
And I can prove that.
Eve_5/16
How is he allowed to simply circumvent requirements for service of a
complaint?
At a bare minimum, can you demand he comply with regular motion

practice and file a contested motion?
Three, what are the consequences of my not waiving service?
By the way, Goldberg literally is stalking me. I get emails, letters,

phone messages almost every day. And I will never negotiate with a
target of my own investigations as if he had any illegitimacy
whatsoever. And I just don’t do dirty lawyers. I prosecute them. I
have respect for the law that these people get paid to circumvent and
abuse.
Four, I have zero interest in participating in a rigged proceeding. I

would prefer to let them go forward and issue the utterly baseless
injunction for which this court has no jurisdiction and simply file an
immediate appeal and restraining order. What exactly are the steps
for appealing a “special injunction” issued in equity and what is the
deadline? Who would hear the appeal?
Gusty, if you were taking me or my situation seriously I just don’t

think your only response would be to treat this as a typical, non-
problematic proceeding when it is anything but that.
At this point, I would like to know the risks and benefits of the
various courses of action that I may take at this time? And I want to
understand step by step how I comply with rules of court, deadlines,
and filing requirements?
Do you have electronic versions of the Rules of Procedure or local

rules or anything at all that I can rent from you? Do you have any
forms that I can use as templates for the various types of pleadings I
have to make? I can rent them.
I do not want to be forced into Court prematurely under these

circumstances and I should not be. And Gusty, why am I telling you
all this stuff. You are a trial lawyer in Pennsylvania and you must
deal with this stuff all the time.
Why am I telling you the difference between a regular injunction or

one in equity? Did you know before this email that he basically tried
to trick me/you into waving service for the complaint?
You must understand Motion Court practice so why aren’t you pissed
off that Jug is overtly circumventing mandatory motions practice. I
should have at least ten days notice. Even special injunctions have to
be filed with motion and have to comply with all pleading and
certification requirements which Jug’s does not and would not be
accepted for motions court at this time.
And furthermore, jug and Goldberg also clearly violated the rules of
professional conduct regarding communications with a represented
party given the self-serving request for you to accept service or waive
on my behalf. Does any of this misconduct strike you as even
remotely offensive or concerning? I would really appreciate your
Eve_5/16
thoughts on this.
Thank you for your kind attention to these matters.
Uta
to addelectrical vault issue 4 floors below me

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of
the intended recipient(s) and may contain confidential and privileged
information. If you are not the intended recipient, please do not read,
distribute, or take action in reliance upon the message. If you have
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by return e-mail and promptly delete this message and its attachments
from your computer system. Be advised that no privileges are waived
On Feb 19, 2021, at 10:12 AM, Gusty A.E. Sunseri

<gusty-sunseri@verizon.net> wrote:

Uta Do you want me to handle this for the Estate? Can
end up costing the Estate $1500 to $1800 plus Jug’s
attorney fees. We definitely need to talk. Is there a leak in
the place?

Eve_5/16
To: Gus Sunseri
Subject: Re: Imperial House Condominium v. Von Eckartsberg
GD 21-001293 I just got this. How long do I have to respond;
This injunction is a fraud on the Court.
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
On Feb 18, 2021, at 6:21 PM, Gus Sunseri <gusty-

sunseri@verizon.net> wrote:
No and no
Sent from my iPhone
On Feb 18, 2021, at 6:14 PM, Uta von

Eckartsberg <uvoneck@outlook.com>
wrote:

Did he call you? Do you know
him?

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
DISCLAIMER: This e-mail

message is intended only for the
personal use of the recipient(s)
named above. This message may
be an attorney-client
communication and as such
privileged and confidential and/or
Eve_5/16
it may include attorney work
product. If you are not an
intended recipient, you may not
review, copy or distribute this
message. If you have received
this communication in error,
please notify us immediately by e-
mail and delete the original
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Please be advised that no
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From: Gusty A.E. Sunseri <gusty-

sunseri@verizon.net>
Sent: Thursday, February 18, 2021
4:16 PM
<uvoneck@outlook.com>
Subject: Re: Imperial House
Condominium v. Von Eckartsberg
GD 21-001293 I just got this. How
long do I have to respond; This
injunction is a fraud on the Court.
I did not accept service for you

or the Estate. I told him that I
would have to speak with you to
see if I would be representing
you in this. Given the nature of
the allegation-potential
continuing water damage-I
would suggest that you contact
him. Or, if you want me to
represent you in this, I can
contact him. Feel free to contact
me.

3:53 PM
To: Gusty Sunseri
Subject: FW: Imperial House
What is the procedure on this? I

want to file a motion for special
injunction in response…..l;

412.207.7742(ph)
Eve_5/16
301.461.7445 ©
724.631.5212 (fax)

privileged and confidential and/or
it may include attorney work
product. If you are not an
please notify us immediately by e-
mail and delete the original
From: Fred C Jug <fjug@bmr-

law.com>
12:48 PM
To:
Civilgenmotions@alleghenycourts.us
Cc: 'Uta von Eckartsberg'
<uvoneck@outlook.com>; gusty-
sunseri@verizon.net
Subject: Imperial House
GD 21-001293
Please find attached an

Emergency Motion For Special
Injunction and a Proposed
Order. The Proposed Order is
provided in word format
pursuant to the Standard
Operating Procedures of the
Court. The Plaintiff would
appreciate this matter now be
scheduled. The Motion has also
been mailed to the Defendant
and the defendant is copied on
this email. A courtesy copy is
also being provided to counsel
for the estate who is also copied
on this email as no appearance
has been entered yet in this case.
Your attention to this matter is
appreciated.
Eve_5/16
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
This electronic message and any

attachments transmitted with it
contain information that may be
privileged and confidential. The
information is intended for the
use of the intended recipients
only. If you are not an intended
recipient, note that any
disclosure, copying, distribution
or use of the contents of this
message is prohibited. If you
have received this message in
error, please contact the above
sender and delete this message
immediately.
Eve_5/16
To: Lockwood Joe
Cc: Sunseri Gusty
Subject: Fwd: Property Developments, Unit Property Act, and Uniform Condominium Act and historical records Deeds (Confidential Atty Client -Estate of EvE)
Date: Friday, January 8, 2021 2:02:27 AM
Attachments: 20201203_Allegheny county ;,Pennsylvania.pdf
Hey Joe — thank you so much! I still really need the dox referenced in the below photo as well as via the hyperlink. Also, I still to get whatever info I can regarding the Kenny Ross bankruptcy and receivership. A bank initiated the action in Allegheny county so apparently
everything was done at county level. I think the bankruptcy was filed in 1974 and was terminated in 1976.
Thanks again for all!!
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended recipient(s) and may contain confidential and privileged information. If you are not the intended recipient, please do not read, distribute, or take action in reliance upon the message. If you have
received this message in error, please notify the sender immediately by return e-mail and promptly delete this message and its attachments from your computer system. Be advised that no privileges are waived by the transmission of this message.

Date: December 29, 2020 at 4:27:00 PM EST
Subject: RE: Property Developments, Unit Property Act, and Uniform Condominium Act and historical records Deeds (Confidential Atty Client -Estate of EvE)

Do you have a tiff viewer? I need to obtain and view the tiff files at the following two Allegheny County property online search website. You can obviously charge the estate for the cost. I really need a copy of all recorded documents associated with these attached two records.
his is urgent. I assume you guys use this site. Thank you.
Hyperlink is as follows:
https://pa_allegheny.uslandrecords.com/palr/controller?
commandflag=getDetails&optflag=DetailsCommand&county=pa003&userid=null&userCategory=7&nameid=979387&ptrno=3554038&partytype=&name=IMPERIAL%2BASSOCIATES&officeid=55&fromdate=01/02/1987&todate=12/22/2020&lastname=IMPERIAL%20ASSOCIATES

412.207.7742(ph)
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724.631.5212 (fax)
DISCLAIMER: This e-mail message is intended only for the personal use of the recipient(s) named above. This message may be an attorney-client communication and as such privileged and confidential and/or it may include attorney work product. If you are not an intended
recipient, you may not review, copy or distribute this message. If you have received this communication in error, please notify us immediately by e-mail and delete the original message and its attachments from your computer system. Please be advised that no privileges are waived
From: jlockwood@sunserilawfirm.com <jlockwood@sunserilawfirm.com>
Sent: Tuesday, December 29, 2020 3:43 PM
Uta,
I can obtain the documents set forth in Schedule B of the Title Insurance Policy tomorrow. I should be able to obtain the Preliminary Injunction and Brief shortly. I will also let you know regarding the status of the McLafferty holding.
Thank you,
Joe
From: "Uta von Eckartsberg" <uvoneck@outlook.com>
Sent: Tuesday, December 29, 2020 2:05pm
To: "jlockwood@sunserilawfirm.com" <jlockwood@sunserilawfirm.com>
Cc: "Gus Sunseri" <gusty-sunseri@verizon.net>
Joe,
Due to technical and equipment limitations, I am very pressed for time Sorry for the delayed response. Attached are cases of material significance that back-up my representations to BOD. Also, I have followed the title chain on my mother's and see confirmation of my conclusion
that this BOD etc., at all relevant times have improperly charged certain unit owners for parking and other limited common elements. The title insurance page identifies material documents which I urgently need;' in particular the document relating to Duq. Light Co. easement. I
also need a copy of the PI Motion and supporting brief filed by DLC in the Longvue case attached. Can you help and how soon? I can speak briefly as necessary. Just let me know when. Please text me at 301.46.7445 with the proposed time. Thx! Also, will you please check to
make sure that McLafferty is still good law. No lexis or westlaw access sucks.
And, Gusty, if you are in this week please let me know if you are familiar with the Valley of Lakes case at your earliest convenience.
Thank you.
Uta
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
Sent: Monday, December 28, 2020 6:18 PM
Uta,
I will review everything. Let's plan on talking tomorrow afternoon. Is there a time that works best for you?
Thank you,
Joe
From: "Uta von Eckartsberg" <uvoneck@outlook.com<mailto:uvoneck@outlook.com>>
Eve_5/16
Sent: Monday, December 28, 2020 12:29pm
To: "jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com>" <jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com>>
Cc: "Gus Sunseri" <gusty-sunseri@verizon.net<mailto:gusty-sunseri@verizon.net>>
Thank you, Joe. Much appreciated. Hope you both a great holiday. As you may be able to tell from my recent emails, I have had better holidays. I need copies of the documents referenced or related to events described in the attached. I think what is attached is consistent with
what I am requesting from the BOD. My mother's chain of title never got to Rosenberg or any predecessor. This building was an apartment building so it was a conversion at some point although I don't know how relevant that is. For what its' worth I have checked properties and
there significant indica of straw purchasers beginning in around 1998 consistent with the cases I cited in my email to the BOD today. I'd like to know if Gus is familiar with the Valley of the Lakes civil rico case....
Feel free to call me at your convenience if you need me to walk you through the attached to ensure we are on the same page before you begin to track down the records.
Thanks!
Uta
412.207.7742(ph)
301.461.7445 (c)
724.631.5212 (fax)
From: jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com> <jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com>>
To: Uta von Eckartsberg <uvoneck@outlook.com<mailto:uvoneck@outlook.com>>
Subject: Re: Property Developments, Unit Property Act, and Uniform Condominium Act and historical records Deeds (Confidential Atty Client -Estate of EvE
Uta,
As to a claimant forcing an accounting, a claimant can petition the Orphan's Court to force an accounting anytime after six months from the first full advertisement. In your case, that would be approximately mid-May.
-Joe
From: "Uta von Eckartsberg" <uvoneck@outlook.com<mailto:uvoneck@outlook.com<mailto:uvoneck@outlook.com%3cmailto:uvoneck@outlook.com>>>
To: "jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com><mailto:jlockwood@sunserilawfirm.com%3cmailto:jlockwood@sunserilawfirm.com%3e>"
<jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com%3cmailto:jlockwood@sunserilawfirm.com>>>
Cc: "Gusty A.E. Sunseri" <gusty-sunseri@verizon.net<mailto:gusty-sunseri@verizon.net<mailto:gusty-sunseri@verizon.net%3cmailto:gusty-sunseri@verizon.net>>>
Excellent!! Will get you the papers and info ASAP. Outstanding Q: "does your practice include issues arising under the above-described laws? If not, do you know anyone who does?"
Also, Gusty, no rush of course but just want to check whether the two brief memos I requested are still on your radar?
And, still waiting on answer to my previous query as to whether or SunTrust can force an accounting in connection with their claim as early as six-months after my mother's death....
Also, please let me know if either your or Gus are-of-pocket over the holiday (ie off for a week or whatever). I don't want to disturb anyone on vacation.
Thanks.
Uta
412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended recipient(s) and may contain confidential and privileged information. If you are not the intended recipient, please do not read, distribute, or take action in reliance upon the message. If you have received
this message in error, please notify the sender immediately by return e-mail and promptly delete this message and its attachments from your computer system. Be advised that no privileges are waived by the transmission of this message.
On Dec 22, 2020, at 3:21 PM, jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com%3cmailto:jlockwood@sunserilawfirm.com>> wrote:
does your practice include issues arising under the above-described laws? If not, do you know anyone who does?
To: Zahir Farhan
Subject: Fwd: von Eckartsberg EIN
Date: Friday, October 2, 2020 12:09:25 PM
Attachments: EIN Eckartsberg Estate.pdf
ATT00001.htm
See attached. Does this work? And no, my day has already gotten ahead of me. I will be
there ASAP and will let you know when I leave. Thanks.

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)

Date: September 29, 2020 at 7:12:03 PM EDT
Subject: Fwd: von Eckartsberg EIN

EIN
Sent from my iPhone
From: "jlockwood@sunserilawfirm.com" <jlockwood@sunserilawfirm.com>

Date: September 29, 2020 at 6:01:27 PM EDT
To: Gusty Sunseri <gusty-sunseri@verizon.net>
Subject: von Eckartsberg EIN
From: KAREN SUNSERI
Subject: Gusty Sunseri & Associates - Amended Claim for Assessments from Imperial House Condo
Date: Wednesday, August 25, 2021 4:18:37 PM
Attachments: Letter to Executor RE Amended Claim from Imperial House 8-20-21.docx
von Eckartsberg - Amended Claim for Assets from Imp House 8-23-21.pdf
Dear Uta:
Attached please find a cover letter regarding our representation as well as a copy of the
Amended Claim for Assessments from Imperial House Condominium Association. Please
contact our office as soon as possible to discuss. Thank you.
Karen Sunseri
Gusty A. E. Sunseri & Associates, P. C.
412-968-0210
From: Fred C Jug
Cc: "Uta von Eckartsberg"; gusty-sunseri@verizon.net

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
To: Gusty Sunseri
Subject: Quick cheat sheet for our call - ACP
Date: Thursday, October 15, 2020 3:07:22 PM
Call you in a couple:
Separate and apart from legal issues, it appears DMV gave me the wrong info on 9/30/2020
They told me to submit Form 34 which is not applicable to the estate situation. See fact sheet
That refers to form 4ST a which also does not appear applicable
Then there is a conflicting statute which applies to me as either a heir or executor Section
1315 which has different seemingly applicable provisions.
Had I been able to establish probate before the registration renewal was due, I could have just
registered the car in the estate’s name. because of the weird timing issue I could not do that.
Maybe the only thing necessary is to apply for an amended registration stmt or something?
——-
In addition to Loan lender and MB potential causes of action under multiple state and federal
laws, the estate may also have a coa against Windstream (phone and internet provider who has
filed for bankruptcy); and,
Waste Management Inc (convicted of one of the largest accounting frauds ever) is now
engaging in the collection of unlawful debt by virtue of blatant double billing and retaliatory,
impermissible fees apparently in retaliation for my having requested information on the
timing of notice of cancellation for the purposes of avoiding cancellation fees, etc.
Finally, there is no doubt in my mind that the estate can demonstrate gross negligence and/or
negligence per se sufficient to meet the standards for a cause of action against each and every
one of my mother’s caretakers during the relevant time period because each violated
mandatory laws imposing civil and criminal liability for failure to report the type of traumatic
injuries my mother, a care-dependent individual suffered. And for the same reasons, the
estate intends to dispute each and every bill submitted for my mother’s care. And in each
instance, I intend to send a notice to preserve documents in anticipation of litigation. And in
many instances, I need to get get out requests for medical information under the Electronic
Health record laws.
And lastly pure estate administration Qs with respect to assistance from your office:
Identification and preparation of probate inventories.

Assisting the Executor or Administrator in payment of debts, expenses and taxes.
Processing income receipts and distributions to beneficiaries.
Preparation and filing of federal estate tax returns, state estate tax returns and state
inheritance tax returns.
Securing of releases of tax liens and handling estate tax audits.
Safekeeping of property.
Assembly of fiduciary income tax data and assistance in post mortem tax planning.
Special services in administering real estate or other kinds of services.
Creating accountings and reports to clients and beneficiaries

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
From: Fred C Jug
To: "Law Linda"; "Uta von Eckartsberg"
Cc: "Charles Gallo"
Subject: RE: CEASE & Desist and Identity fraud (offers and sales of unregistered securities)l
Date: Monday, April 5, 2021 12:19:19 PM
Dear Linda: Pursuant to the attached Order of March 10, 2021 the final Hearing on the
Injunction is scheduled via telephone conference tomorrow at 9:30 am. It would be
appreciated if you let us know if there is a dial in number for the conference. Your attention to
this matter is appreciated

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Law Linda <Linda.Law@alleghenycourts.us>

To: 'Fred C Jug ' <fjug@bmr-law.com>; 'Uta von Eckartsberg' <uvoneck@outlook.com>; 'gusty-
sunseri@verizon.net' <gusty-sunseri@verizon.net>
Importance: High
Good afternoon,
Attached is an Order of Court dated February 25, 2021 regarding the above matter. Please feel free
to email if you have any questions.

Sent: Wednesday, February 24, 2021 2:18 PM
To: 'Uta von Eckartsberg' <uvoneck@outlook.com>
Cc: Law Linda <Linda.Law@alleghenycourts.us>; 'Charles Gallo' <chazgallo@gmail.com>; gusty-
sunseri@verizon.net
External Source Warning!

** This email was sent from an external source. Please be sure you recognize the sender and
use caution when clicking on links or opening attachments. **
- Allegheny Courts' Helpdesk
I informed the Judge of your email earlier today in which you said you were not feeling well.
Rather than proceed today the Judge indicated that he would issue an Order granting you a
postponement until March 10, 2021 at 1:30 pm. We should expect to receive an Order with the
new date. Since Mr. Sunseri was on the original service email as counsel for the Estate I was
directed to again include him and have done so.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

I received your email. The Judge is on the line right now and waiting for you to call in.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Fred C Jug
To: "Uta von Eckartsberg"
Date: Wednesday, March 10, 2021 1:33:23 PM
The Court Proceeding has begun. The Judge is waiting 5 minutes for you to join and will then
start. Please let us know if you plan to join the call and/or oppose the Motion.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

Importance: High
Good afternoon,

sunseri@verizon.net


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Fred C Jug
To: "Law Linda"; "Uta von Eckartsberg"; gusty-sunseri@verizon.net
Thank you Linda. I put this on my calendar.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

Importance: High
Good afternoon,

sunseri@verizon.net


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Fred C Jug
Date: Wednesday, February 24, 2021 12:14:52 PM
Attachments: image001.png
image002.png
The Hearing today was scheduled by the Judge after it was assigned by the General Motions
office. You should be aware of that based on the prior email chain and this establishes that
your prior email about “cherry-picking the Judge” is false and completely without merit. As an
attorney, you also should be award the Hearing which has now been scheduled by the Court
shall remain scheduled until the Judge postpones it. If you wish to request a postponement
then you will need to make that request with a copy to opposing counsel. Finally, my client
remains willing to explore an amicable resolution as I discussed with Mr. Sunseri the other
day. If you share in that goal then please email me your proposal so I can share it with the
Board.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

Sent: Wednesday, February 24, 2021 11:35 AM
To: Arthur Goldberg <artgoldberg@verizon.net>; 'Fred Jug' <fjug@bmr-law.com>; 'Robert Bernstein'
<robert.s.bernstein@gmail.com>; 'Deb Knox' <deb@knox412.com>
Cc: lizhrenda@comcast.net; shandel.gilbert@verizon.net; sylvholland@aol.com;
stlrfanpgh@aol.com; pj92926@gmail.com; ethelweikers1@gmail.com; frisch@duq.edu;
bloberant@yahoo.com; rgrif@cmu.com; nloberant@yahoo.com; stephen.tirone@gmail.com;
antis1209@comcast.net; 1 neil.cosgrove@verizon.net; roblschwartz@aol.com;
reiko.becker@gmail.com; shirleykmeyers@msn.com; dandee26@verizon.com;
mjmckenna42@hotmail.com; maxifish1@aol.com; bunkerc@pitt.edu; william.lindgren@sru.edu;
joeldon@aol.com; danehower@gmail.com; vicky.humphrey23@gmail.com; reneeramo@gmail.com;
johnstonann@att.net; wjjohnston@firstcommand.com; patmiles1@aol.com; nanwm@verizon.net;
jbaccordion@gmail.com; smithkmt@gmail.com; bonnie17961@gmail.com; amq02@comcast.net;
rmolyneauxrmx@gmail.com; sheilaryannp@aol.com; eiko.becker@gmail.com; ritzec@comcast.net;
shirleykmeyers@msn.com; pj92926@gmail.com; hwerstil@aol.com; lew@andrew.cmu.edu;
hellman@pitt.edu; amq02@comcast.net
Importance: High
Attached are exemplars of multiple federal and state regulatory filings relates sales the restricted,
securities of Bellrock from at least 2015 through 2018 where an individual identified as Arthur
Goldberg CFO identified either 815 and/or 1009 5600 as the residence of the control person of the
issuer as its corporate headquarters. I have not yet had the opportunity to check for a reply to my
email but to the extent that this is a criminal imposter, you should know this person seems to have
used your identity to commit mail and/or fraud to offer and sell unregistered securities.
Since you firmly represented to us all that you know nothing about securities, I will do you the
courtesy of explaining that based upon a cursory review of public records, none of the shares sold by
this person were by a registration statement and there was no exemption or safe harbor for the sales
of securities in unregistered transactions allegedly raising in excess of $8 million. Accordingly, in
addition to identity fraud concerns, they would almost certainly be exposed to criminal laicity given
that the this is a essentially a strict liability offense, even in the criminal landscape (state and
federal) given that the Government’s only burden is to prove that the bad actor knew that the
securities not registered and not exempt when sold. And of course most bad actors in this space are
market professionals with no plausible defense.
And speaking as a former prosecutor, the beauty of a case like this that all injured investors have an
immediate right to demand recession for sales of unregistered securities absent an applicable
exemption. Not giving you legal advice or anything, just the benefit of the public record and
historical knowledge. I am copying the FBI and the District Attorney to ensure that no other injured
investors are defrauded. .
Ooops!! Almost forget to mention the most important thing -- this criminal imposter has also
obtained mortgage loans using fictitious property interests in this building – commonly described as
an “air loan.” That can be cause for real concern. I’ll be sure and send the papers to you! Let me
know when you catch up with the criminal folks. Happy to share more detailed info as necessary.
Fictitious loan papers on the way.
Finally, Also, I am quite ill today and request you reasonably accommodate me by withdrawing the
discredited, fraudulent representations furnished to the Court. Given your demonstrated concern for
my good health and wellbeing, I am sure you have already handled this in compliance with the rules
of court, law, and the interests of fair administration of justice.
Also, I am quite ill today and request you reasonably accommodate me the discredited, fraudulent
representations furnished to the Court. Given your demonstrated concern for my good health and
wellbeing, I am sure you have already handled this in compliance with the rules of court, law, and
the interests of fair administration of justice
Uta
301.461.7445 ©
724.631.5212 (fax)
this message.

Sent: Tuesday, February 23, 2021 6:19 PM
To: 'Arthur Goldberg' <artgoldberg@verizon.net>; 'Fred Jug' <fjug@bmr-law.com>; 'Robert
Bernstein' <robert.s.bernstein@gmail.com>; 'Deb Knox' <deb@knox412.com>
stlrfanpgh@aol.com; pj92926@gmail.com; shirleykmeyers@msn.com; ethelweikers1@gmail.com;
frisch@duq.edu; bloberant@yahoo.com; rgrif@cmu.com; nloberant@yahoo.com;
stephen.tirone@gmail.com; antis1209@comcast.net; 1 neil.cosgrove@verizon.net;
roblschwartz@aol.com; reiko.becker@gmail.com; dandee26@verizon.com;
Subject: RE: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court, Unfair Trade
Practices Consumer Protection Law, Fraud, etc. 3 of several
So the person is the attached is not you? If not, then I guess you owe me a big thank you because
you are a victim of identity fraud. And that criminal imposter is using your name to flip units in the
building as well. If that is the case, then you should be thanking me because you need to report the
person to the FBI immediately because that imposter has flipped at three units in the building using
your identity – including Units Unit 1009 (Bellrock), 815 and 807! The unit owner that you
charged thousands of dollars for contracting violations….. . I mean look at how many deeds and
mortgages this person took out in your name together with others of course. I’ll send you all the
securities forms next so you could protect yourself from people like me who get it wrong. Definitely
let me know because I still have a few friends at the FBI. And Bernstein, didn’t forget you. Sorry
but you have no plausible deniability on the systemic violations of the FHA and Pennsylvania’s
Human Rights Act.
.

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.
From: Arthur Goldberg <artgoldberg@verizon.net>

To: 'Uta von Eckartsberg' <uvoneck@outlook.com>; 'Fred Jug' <fjug@bmr-law.com>; 'Robert
Bernstein' <robert.s.bernstein@gmail.com>; 'Deb Knox' <deb@knox412.com>
Subject: RE: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court, Unfair Trade
Practices Consumer Protection Law, Fraud, etc. 3 of several
Ms. von Eckartsberg - You made the decision to spread false information to our neighbors without
verifying that the Arthur Goldberg you were referring to was not me. I have never been in the
securities business and you have accused me without attempting to verify that fact. This person was
not me and you smeared my good name with our neighbors. I am demanding that you immediately
retract these false claims to all those who received your email.
You also fail to admit that you were given numerous opportunities to work with the Association, as
the governing documents require, and this failure is established by the emails attached to the motion
pending in court. You ignored numerous requests from me and the Association attorney to meet in
person or even via email to resolve this without forcing us to go to court.
You have still not arranged for access into your unit which could have avoided the court action from
being necessary and have accused me and the Association’s Attorney of improper conduct which is
not based on the facts or the law. Again, you must cease and desist from this activity.

To: 'Fred Jug' <fjug@bmr-law.com>; Arthur Goldberg <artgoldberg@verizon.net>; 'Robert Bernstein'
<robert.s.bernstein@gmail.com>; Deb Knox <deb@knox412.com>
Subject: FW: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court, Unfair
Trade Practices Consumer Protection Law, Fraud, etc. 3 of several
Importance: High

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

To: 'Fred Jug' <fjug@bmr-law.com>; Arthur Goldberg <artgoldberg@verizon.net>; 'Robert Bernstein'
<robert.s.bernstein@gmail.com>; Deb Knox <deb@knox412.com>
Subject: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court, Unfair Trade
Practices Consumer Protection Law, Fraud, etc.
Importance: High
First, pull the case off the docket. there is no leak. There was never any leak whatsoever
attributable to me. See attached photographic evidence. Second, per the attached evidentiary you
have the unmitigated to seek extraordinary measures ex pare to force me to pay for nonexistent
damages when the attached demonstrate your failure to maintain this property given the abundant
evidence all over the garage and the more than two-years of discussion regarding the leaking electric
vault to P-1. See representative examples of the indisputable evidence of our collective bad faith in
seeking ex parte special injunctive based upon lie upon lie for purely retaliatory and predatory
reasons. And furthermore, you know or are reckless for not knowing that your client is wholly
responsible for the dangerous condition on P-Q are reckless in not knowing that your client
(whomever that may be) is admittedly responsible for the dangerous condition on P-1 (per Exh. to
your so-called complaint) that has gone unaddressed after more than two years. See attached. And,
it appears that this dangerous condition is due to the fact that the right of way granted to Duquesne
Light to the incorporator of “Imperial House Condominium Association, Inc., runs with the owner
not the land. And the owner is the actual and sole incorporator of the IHCA; specifically, Kenny
Ross. See Attached. Given that this building is nine-floors, is sprinkler-free, with an alarm system
that I can barely hear, the failure to address this issue does in fact represent a true risk of imminent
harm. See also, the records of multiple violations due to this BOD’s failure to comply with
applicable regualatios.
Furthermore, as you well know or are reckless in not knowing, the overwhelming evidence that
Arthur Goldberg, a notorious violator of the securities laws and at least an affiliate of the subjects of
my years-long investigation of organized crime on Wall Street, is harassing, extorting, and stalking
me. Since my last direct communication to the BOD, I investigated Mr. Goldberg given the threats
of charging me $1000 per day for a fictious violation of a rule that does not exist after the BOD has
repeatedly denied my requests for a copy of the Rules, Regulations, Bylaws, and the Applicable
Declaration.
And not only did I learn that I am being harassed and bullied by an affiliate and associate of my
five-year investigation into organized criminal networks but also that he is running a securities fraud
from my mother’s building. \ Goldberg persistence escalated as did his baseless attempts to coerce
me to pay money for unlawful debts. Thus, I undertook an investigation of Goldberg only to learn
that he notorious violator of the federal securities laws and a known affiliate, co-conspirator of the
subjects of my years-long investigation of organized crime on Wall Street many of whom are
currently targets of criminal investigations all over the country.
Furthermore, he is running a securities fraud from the building and from at least 2016 to the present
made multiple material false and misleading representation in furtherance of the sale of restricted,
control securities as free trading stock when in fact no exemption was or is available. He falsely
certified Unit 1009 as the corporate headquarters of the issuer even after he flipped the unit in 2016.
Furthermore the regulatory filings contain misrepresentations regarding the location of his
coconspirators. Clearly, he puts our safety at risk and is using the residential only property for a
commercial enterprise. The representative intrastate regulatory filings as well as the corporate are
each subject to criminal penalty for unsworn statement to regulators, false statements and securities
fraud in my opinion. In addition, it appears he is engaging in the unauthorized practice of law in this
jurisdiction. Furthermore, his CPA is inactive and thus he barred from performing any work inside
the scope of accountancy and from representing that he has a license. Similarly, per the attached
public records he definitely holds himself out as lawyer, CPA and attorney for the association.
Your conduct and the conduct of all implicated attorneys violates the integrity of our judicial system
and is directly adverse to our judicial process which I believe is about truth, fairness, and justice.
You subvert the course of justice by filing a frivolous, baseless lawsuit that has caused the estates
thousands of dollars of limited funds all for the purpose of reaping debt. illegal gains. You made a
false certification of service. Attempted to evade any lawful service of process. You knowingly
allowed Goldberg in executing a false verification. Further, you know without a doubt that a court
in equity does not have jurisdiction over a claim for money damages absent an ownership or lien
because such complaint does not sound in equity. You have no damages nor suffered whatsoever
per your per your own spurious complaint which you falsely certified as served on February 2016 –
2 days before you emailed the materially misleading email which is attached as an exhibit. Your
papers are rife with material misstatements.
You overly violate every applicable civil rule governing motions practice to the extent there exists
the optics of your having cherry-picked your Judge given he is not the motions court judge this week
together with the fact that the mattered is mandated to be set for general motions court. With utmost
respect to Judge Dellaveccia, he is not Motions Court judge this week and thus the optics of your
conduct do him no favor. Furthermore, you violate and circumvent every rule of civil procedure
governing process, means of service, false certifications, knowingly false representations, failing to
attach the writings you claim support your utterly deficient excuse for a complaint. which is
disfavored by the Courts. Your complaint is an insult to the integrity of the court. Furthermore,
this would obviously be a contested motion yet I am not afforded even that much due process
because apparently you do not have to comply the rules of court in Allegheny county.
For you, to leverage your knowledge, sophistication, resources, and insider status against pro se,
disabled former public servant who has little to no state court experiences is the epitome of abuse of
process among particularly in the context of ex parte relief With respect to your scurrilous,
defamatory vicious predatory lawsuit, the evidence speaks for itself. Overall, the above described
conduct forms the basis for disciplinary investigation for violation of various Rules of Professional
Responsibility including :
Rule 1.16(a)(1) - A lawyer is prohibited - from representing a client if the representation will result
in violation of the Rules of Professional Conduct or other law; RPC 8.4(a) — A lawyer is prohibited
from violating or attempting to violate the Rules of Professional Conduct, knowingly assist or
inducing another to do so, or do so through the acts of another;
RPC 8.4(b) A lawyer is prohibited from committing a criminal act that reflects dishonesty, a lack
of trustworthiness or fitness as a lawyer; RPC 8.4 (c) — A lawyer is prohibited from engaging in
conduct involving misrepresentation;
RPC 8.4 (d) —- A lawyer is prohibited from engaging in conduct that is prejudicial to the
administration of justice; RPC 8.4(e) — A lawyer is prohibited from exercising, stating, or implying
an ability to improperly influence a government agency or official or to receive results by means
that violate the Rules of Professional Conduct or other law;
RPC 8.4 (f) — A lawyer is prohibited from recklessly or knowingly assisting a judge or judicial
officer in conduct that is a violation of applicable rules of judicial conduct or other law,
RPC 5.5(a) — A lawyer is prohibited from practicing law in a jurisdiction in violation of the

regulation of that jurisdiction (Goldberg); and PC 5.5(b)(2) — A lawyer who is not admitted to
practice in this jurisdiction is prohibited from holding out to the public as being admitted to practice
law in this jurisdiction (and from aiding and abetting the same).

Each of you and others known and not known are at least subject to individual and joint liability to
the estate on multiple fronts including but, not limited, to violations of common law fraud,
conspiracy, defamation, libel, intentional infliction of emotional distress, violations of the Fair Debt
Collection Practices Act, 15 U.S.C. § 1692 et seq. violations of 66 Pa C.S.A.§ 1313) (Price upon
resale of public utility service); Pennsylvania Fair Credit Extension Uniformity Act, 73 Pa.Stat. Ann.
§ 2270 et seq.; the Pennsylvania Unfair Trade Practices and Consumer Protection Law, 73 Pa. Stat.
Ann. § 201–1 et seq. fraud by deception, Punitive damages are expressly permitted under the UCA
and the UPCA for a willful violation of the statute. See UCA § 3412 and UPCA § 5412 Under the
ILSFDA penalties may be imposed for willful violations, including criminal penalties of up to a
$10,000 fine, or up to five (5) years of imprisonment, or both, and civil penalties of up to $1,000 for
each violation.
Note, under the ILSFDA civil penalties can be imposed on anyone who “knowingly and materially”
violates the act, and “knowingly” is defined to mean “having actual knowledge of or acting with
deliberate ignorance of or reckless disregard for the prohibitions” of the act. See ILSFDA §§ 1717
and 1717(a). Furthermore per my emails of December 2020, this association is mandated to
address members' claims of harassment on the basis of race, color, religion, national origin, sex,
familial status, and disability. This includes harassment by other residents, board members,
managers, and vendors. The law requires that boards take prompt steps to investigate and end
harassment. (Code of Fed. Reg. §100.7(a)(1)(iii).) You collectively have escalated your harassment
in response to my claims.
Accordingly, each and every one of you is subject to personal as well joint liability for your utter
disdain and disregard for the rights of particularly members of protected classes, theft common law
fraud, extortion, theft by deception, criminal harassment, sales of harrassment, stalking (Goldberg),
sales of unregistered securities in violation of Section 5 of the Securities Act of 1933, as well as
potential Rico and Rico conspiracy liability in addition to control group liability jointly and severally
for all wrongful conduct of a controlled issuer or entity under the applicable control theories of
liability. I remind that Pennsylvania recognizes the crime/fraud exception to attorney client.
Clearly you are on notice of anticipated litigation and are under a duty to preserve any all relevant
documents, material, etc. This email is the consequence of the pressure and duress you impose
upon me by your inexcusable conduct. I am not able to appear today and I will seek an emergency,
disability accommodation if necessary. Should you proceed with this course of conduct and obtain a
ex parte injunction then so be it.. I will move to dissolve immediately. And I cannot all evidentiary
records due to volume, I will therefore follow up by separate email.
The attached documents speak for themselves but a screenshot of the contents follows:

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.
From: Fred C Jug
Cc: "Law Linda"; "Charles Gallo"; gusty-sunseri@verizon.net
Date: Wednesday, February 24, 2021 2:17:43 PM

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Fred C Jug
To: "Charles Gallo"
Cc: "Law Linda"; "Uta von Eckartsberg"
Was scheduled by the attached Order which I highlighted the language on. Just wanted to
make sure I was not missing the call in number and if needs rescheduled we understand.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Charles Gallo <chazgallo@gmail.com>

Sent: Monday, April 5, 2021 1:00 PM
To: Fred C Jug <fjug@bmr-law.com>
Cc: Law Linda <Linda.Law@alleghenycourts.us>; Uta von Eckartsberg <uvoneck@outlook.com>
Subject: Re: CEASE & Desist and Identity fraud (offers and sales of unregistered securities)l
I don’t believe you guys are on the Judge’s schedule tomorrow and Linda is on vacation this week. I’ll
be at a funeral.
I’m guessing this needs rescheduled when Linda gets back. How was it scheduled? Per order?
C Gallo
On Mon, Apr 5, 2021 at 12:18 PM Fred C Jug <fjug@bmr-law.com> wrote:
appreciated if you let us know if there is a dial in number for the conference. Your attention
to this matter is appreciated
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
This electronic message and any attachments transmitted with it contain information that
may be privileged and confidential. The information is intended for the use of the intended

Importance: High
Good afternoon,
Attached is an Order of Court dated February 25, 2021 regarding the above matter. Please feel
free to email if you have any questions.

sunseri@verizon.net

** This email was sent from an external source. Please be sure you recognize the sender
and use caution when clicking on links or opening attachments. **
postponement until March 10, 2021 at 1:30 pm. We should expect to receive an Order with
the new date. Since Mr. Sunseri was on the original service email as counsel for the Estate I
was directed to again include him and have done so.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Fred C Jug
To: "Charles Gallo"
Thank you Mr. Gallo. I put this on my calendar for 1pm tomorrow. The Constable and
Plumber were there last week and did gain access. I understand the Plumber located and
repaired a leak.
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

The just asked that all parties call in at 1 pm.
Please call:
1-877-953-7157
Pin
416 7541 #
He would also like to know if possession was given and the water was turned off?
C Gallo
On Mon, Apr 5, 2021 at 2:37 PM Charles Gallo <chazgallo@gmail.com> wrote:

Let me call the Judge and let him know. I’ll get back on here shortly....

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
may be privileged and confidential. The information is intended for the use of the
intended recipients only. If you are not an intended recipient, note that any disclosure,
copying, distribution or use of the contents of this message is prohibited. If you have
received this message in error, please contact the above sender and delete this message
immediately.

I don’t believe you guys are on the Judge’s schedule tomorrow and Linda is on vacation this
week. I’ll be at a funeral.
C Gallo
appreciated if you let us know if there is a dial in number for the conference. Your
attention to this matter is appreciated
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
This electronic message and any attachments transmitted with it contain information
that may be privileged and confidential. The information is intended for the use of the
received this message in error, please contact the above sender and delete this
message immediately.

To: 'Fred C Jug ' <fjug@bmr-law.com>; 'Uta von Eckartsberg' <uvoneck@outlook.com>;
'gusty-sunseri@verizon.net' <gusty-sunseri@verizon.net>
Importance: High
Good afternoon,
Attached is an Order of Court dated February 25, 2021 regarding the above matter. Please
feel free to email if you have any questions.

Cc: Law Linda <Linda.Law@alleghenycourts.us>; 'Charles Gallo' <chazgallo@gmail.com>;
gusty-sunseri@verizon.net

** This email was sent from an external source. Please be sure you recognize the
sender and use caution when clicking on links or opening attachments. **
I informed the Judge of your email earlier today in which you said you were not feeling
well. Rather than proceed today the Judge indicated that he would issue an Order
granting you a postponement until March 10, 2021 at 1:30 pm. We should expect to
receive an Order with the new date. Since Mr. Sunseri was on the original service email
as counsel for the Estate I was directed to again include him and have done so.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Fred C Jug
To: "Charles Gallo"
Subject: RE: GD 21-001293
Date: Tuesday, April 6, 2021 11:24:43 AM
Dear Mr. Gallo: Since access has now been obtained attached is a Proposed Order for the
Judge’s consideration at the call this afternoon at 1pm dissolving the Special Injunction and
releasing the Bond. Your attention to this mater is appreciated.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

To: 'Charles Gallo' <chazgallo@gmail.com>
Cc: 'Law Linda' <Linda.Law@alleghenycourts.us>; 'Uta von Eckartsberg' <uvoneck@outlook.com>

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

I don’t believe you guys are on the Judge’s schedule tomorrow and Linda is on vacation this week. I’ll
be at a funeral.
C Gallo

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
Importance: High
Good afternoon,
Attached is an Order of Court dated February 25, 2021 regarding the above matter. Please feel
free to email if you have any questions.

sunseri@verizon.net

postponement until March 10, 2021 at 1:30 pm. We should expect to receive an Order with
the new date. Since Mr. Sunseri was on the original service email as counsel for the Estate I
was directed to again include him and have done so.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: uvoneck@outlook.com
Subject: RE: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg
Perfect. I have to

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

Importance: High
From: Law Linda

Good afternoon,
(412) 350-0281
From: Fred C Jug
To: "Law Linda"; uvoneck@outlook.com; gusty-sunseri@verizon.net

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

To: fjug@bmr-law.com; uvoneck@outlook.com; gusty-sunseri@verizon.net
Importance: High
Good afternoon,
(412) 350-0281
To: Markus Penzel
Date: Friday, February 19, 2021 8:01:00 PM
Understood. Thanks.
Love,
Uta

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.
From: Markus Penzel <markpenzel@yahoo.com>

Sent: Friday, February 19, 2021 5:58 PM
Uta:
Thanks for sharing this with me. However, I feel neither competent nor qualified to get involved. Good luck!
Love,
Mark
On Thursday, February 18, 2021, 8:02:30 PM EST, Uta von Eckartsberg <uvoneck@outlook.com> wrote:
Mark,
Please see below email to my probate lawyer and please also see the attachments to that email as
well the three 2017 emails which I forward only to you. I am sharing this information with you
because I do not have anyone else that can even potentially understand what I describe below and in
the attached historical records. The backstory is that bad actors in my mother’s building filed a
fraudulent motion for injunctive action against me for reasons I cannot detail in an email.
I am sharing this information with you because I need you to take me seriously as I have asked our
probate lawyer to do for my brothers’ sake. My entire family is disabled as in cognitively impaired
and has been for a very long time. If I drop dead tomorrow, I need someone to look out for my
brothers. I just want you to make sure a good lawyer reviews my evidentiary records to protect my
brothers’ financial future. I have POA whom I trust but she is not a lawyer and she is not family.
Also, I stand by everything I wrote to OIG/OPM which was met with more retaliatory conduct
impacting my pay and benefits which continues through the present.
I think you may recall our brief conversation years ago when I sought advice about my then-works
issues, I know you thought I was crazy. As did all my close friends at the time who also practiced
employment law. The fact is that unbeknownst to me at the time is that I was the target of
retaliatory harassment over the course of more than a decade for what I now recognize was
inadvertent whistleblowing. Such conduct violates both the federal sector whistleblower protection
acts and is a prohibited personnel practice as a matter of law and fact pursuant federal sector
employments which are not at all equivalent to private sector employment discrimination cases. It
was not until after I was forced into an early retirement in retaliation for making protected
disclosures which I did not understand or intend to be “whistleblower reports” per se, that I began to
understand the distinctions between federal and private sector employments laws. In fact, I never
heard of prohibited personnel practices or any other federal sector-specific employment laws until
well after I left the SEC. And only because I could not understand what happened and why, I
eventually put most of the pieces together. For the record, I was never a disgruntled employee. In
fact, post-Madoff, I was thrilled that AUSAs were installed to run the SEC and I admired and
respected all of them. I never thought I was doing anything other than supporting my agency and
our mission.
The attached screenshots are simply of my evidentiary records with respect to my current estate-
related investigation. Separately, I have all my evidentiary records from the SEC as well as of hard
evidence of the ongoing retaliatory that I continue to endure. If you want to know why anyone
would that care that much about me - trust me it’s not because I am particularly smart or have any
special knowledge. Rather, it’s basically because after ten minutes of reviewing the applicable SEC
filings I can tell you exactly who the undisclosed control persons of the GameStop are as well as
who coordinated touters are on Reddit. And right now, every single investor has a right to recission
under Section 5 of the Securities Act because at all relevant times the control persons of the issuer
sold unregistered securities when no exemption or safe harbor was available to it. And violation of
the registration provisions of Securities Act is a strict liability offense. Full stop. As touched
upon in Confidential Update III attached, even on the criminal side there is little to no burden to
prove intent.
I am not asking you to get involved in this in any fashion whatsoever. To do so, would likely
jeopardize your job. I just want someone besides my probate lawyer to understand my situation and
to know where my evidentiary records are contained for my brothers’ sake. The only thing that I
ask is that you not just dismiss what I have to say as the ramblings of a crazy women. There is
nothing that I say or allege that is not backed up by direct, hard evidence. Please do not just
dismiss what I write. I can answer any question you have. That said, I have no administrative
support whatsoever and I have never in my legal career ever personally sued anyone. I cannot
singlehandedly package an enormous evidentiary record and have been materially discredited as is
typical for folks in the federal sector who like me become accidental whistleblowers (and the federal
employee antiretaliation laws protect even inadvertent disclosures. Thank you for your kind
attention to this. If its okay, I would like to send you the password info for my dropbox files. Hard
copy records are also in the Condo and at my other’s house in the country. And if you happen to
have any pleading type templates that you can share with me, I would be really grateful. I cannot
even format an affidavit much less a pleading with my software. It’s so basic but a huge issue for
me in terms of being able to package or communicate anything to anyone ….
Love,
Uta
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

Gusty,
Thanks.
Uta
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

Importance: High
From: Law Linda
Good afternoon,

(412) 350-0281
Subject: RE: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got this. How long do I have to
Call me. I am here.

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

Subject: Re: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got this. How long
do I have to respond; This injunction is a fraud on the Court.
Uta I need to know if you want me to represent you in this. If so, we should probably do an
addendum to the engagement letter. Quite honestly, I do not see the harm in allowing them
limited access to the Condo to determine if origins of a leak are happening in that Condo. You
can save a ton of money with not paying me, or Jug’s potential attorney fees, by allowing me
to contact Jug and come to an agreement of giving them limited access ,for a limited time, to
determine the origin or lack of origin in that Condo of a leak. I need to know ASAP. Thanks We
need to talk.

Gusty,
Did you notice that he is doing an end run around @ due process by filing an equity special
injunction which means that I get no due process whatsoever? And that even a special
injunction proceeding must be filed with motions court not with the Judge of your choosing?
Special injunctive actions under 1531 are to preserve the status quo once litigation has
commenced. It is attached to a “heretofore” filed action. And absent a lien or dispute as to
ownership, it is well-settled that there is no jurisdiction for the Court to even entertain such
an injunctive action. Furthermore, would be a contested motion which required compliance
with motions court practice as to filing.
Also, in case you didn’t notice he is not asking whether you will accept service on the baseless
injunction but rather he is trying to trick you or me to waive service on the several pages of
paper attached to the PI motion loosely described a “Complaint” for some cause of action not
intensified, for possible damages related to the “BODs” year long failure to remedy the leaking
of the “electrical” vault into the basement which of course I am not even minimally responsive
for.
He also got someone to enter that baseless “complaint” which does not even minimally
satisfy either rule of court (no affidavit of service, no cover, no damages, etc.) as if he filed a
day before the injunctive motion. And all of this is simply so that he get before the Judge he
knows will find for him and whom he obviously contacted directly as if there were an existing
litigation which there is not. And it evident from the fictitious complaint that they are seeking
damages. That is a contract based claim. Furthermore, they are adding me personally as
I have no practice experience in Allegheny Court whatsoever so I am concerned that it is not

you and Joe who are pointing this stuff out to me.
He is seeking the extraordinary remedy of ex parte injunctive relief for a leak that by his count
had been ongoing for two weeks (Feb. 1). Again, four floors below me. I have no water leak,
their offices right below me have no water leak, the first floor of the garage has no water
leak. This is abuse of process.
Furthermore, I gather that you are not taking my substantive concerns seriously. Arthur
Goldberg is dangerous to me and he is stalking me. And I can prove that.
How is he allowed to simply circumvent requirements for service of a complaint?
At a bare minimum, can you demand he comply with regular motion practice and file a
contested motion?
By the way, Goldberg literally is stalking me. I get emails, letters, phone messages almost
every day. And I will never negotiate with a target of my own investigations as if he had any
illegitimacy whatsoever. And I just don’t do dirty lawyers. I prosecute them. I have respect
for the law that these people get paid to circumvent and abuse.
Four, I have zero interest in participating in a rigged proceeding. I would prefer to let them go
forward and issue the utterly baseless injunction for which this court has no jurisdiction and
simply file an immediate appeal and restraining order. What exactly are the steps for
appealing a “special injunction” issued in equity and what is the deadline? Who would hear
the appeal?
Gusty, if you were taking me or my situation seriously I just don’t think your only response
would be to treat this as a typical, non-problematic proceeding when it is anything but that.
At this point, I would like to know the risks and benefits of the various courses of action that I
may take at this time? And I want to understand step by step how I comply with rules of
court, deadlines, and filing requirements?
Do you have electronic versions of the Rules of Procedure or local rules or anything at all that I
can rent from you? Do you have any forms that I can use as templates for the various types
of pleadings I have to make? I can rent them.
I do not want to be forced into Court prematurely under these circumstances and I should not
be. And Gusty, why am I telling you all this stuff. You are a trial lawyer in Pennsylvania and
you must deal with this stuff all the time.
Why am I telling you the difference between a regular injunction or one in equity? Did you
know before this email that he basically tried to trick me/you into waving service for the
complaint?
You must understand Motion Court practice so why aren’t you pissed off that Jug is overtly
circumventing mandatory motions practice. I should have at least ten days notice. Even
special injunctions have to be filed with motion and have to comply with all pleading and
certification requirements which Jug’s does not and would not be accepted for motions court
at this time.
And furthermore, jug and Goldberg also clearly violated the rules of professional conduct
regarding communications with a represented party given the self-serving request for you to
accept service or waive on my behalf. Does any of this misconduct strike you as even
remotely offensive or concerning? I would really appreciate your thoughts on this.
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
please do not read, distribute, or take action in reliance upon the message. If you have
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On Feb 19, 2021, at 10:12 AM, Gusty A.E. Sunseri <gusty-sunseri@verizon.net>

wrote:

Uta Do you want me to handle this for the Estate? Can end up costing the Estate
$1500 to $1800 plus Jug’s attorney fees. We definitely need to talk. Is there a leak
in the place?

To: Gus Sunseri
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
not the intended recipient, please do not read, distribute, or take action in
reliance upon the message. If you have received this message in error, please
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waived by the transmission of this message.

No and no
Sent from my iPhone


Did he call you? Do you know him?

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of this message.

Subject: Re: Imperial House Condominium v. Von
Eckartsberg GD 21-001293 I just got this. How long do I have
to respond; This injunction is a fraud on the Court.
I did not accept service for you or the Estate. I told him
that I would have to speak with you to see if I would be
representing you in this. Given the nature of the
allegation-potential continuing water damage-I would
suggest that you contact him. Or, if you want me to
represent you in this, I can contact him. Feel free to
contact me.

To: Gusty Sunseri
Subject: FW: Imperial House Condominium v. Von Eckartsberg
What is the procedure on this? I want to file a motion for

special injunction in response…..l;

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
of this message.

Cc: 'Uta von Eckartsberg' <uvoneck@outlook.com>; gusty-
sunseri@verizon.net
Subject: Imperial House Condominium v. Von Eckartsberg
GD 21-001293
Please find attached an Emergency Motion For Special

Injunction and a Proposed Order. The Proposed Order is
provided in word format pursuant to the Standard
Operating Procedures of the Court. The Plaintiff would
appreciate this matter now be scheduled. The Motion has
also been mailed to the Defendant and the defendant is
copied on this email. A courtesy copy is also being
provided to counsel for the estate who is also copied on
this email as no appearance has been entered yet in this
case. Your attention to this matter is appreciated.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
This electronic message and any attachments transmitted

with it contain information that may be privileged and
confidential. The information is intended for the use of
the intended recipients only. If you are not an intended
recipient, note that any disclosure, copying, distribution
or use of the contents of this message is prohibited. If
you have received this message in error, please contact
the above sender and delete this message immediately.

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

I did not accept service for you or the Estate. I told him that I would have to speak with you to
see if I would be representing you in this. Given the nature of the allegation-potential
continuing water damage-I would suggest that you contact him. Or, if you want me to
represent you in this, I can contact him. Feel free to contact me.

To: Gusty Sunseri
Subject: FW: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got this. How long

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.


To: Gusty Sunseri

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
To: Gus Sunseri
Thanks.

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.


Go to Civil
Sent from my iPhone
PS. Can you tell me how to access the court calendar? I want to know whether or not
Judge D. is set as motions court judge this week and next. I do not know how to access
the right calendar... thx

412.207.7742 (PH)
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recipient(s) and may contain confidential and privileged information. If you are not the
intended recipient, please do not read, distribute, or take action in reliance upon the
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Gusty,
Did you notice that he is doing an end run around @ due process by filing
an equity special injunction which means that I get no due process
whatsoever? And that even a special injunction proceeding must be filed
with motions court not with the Judge of your choosing? Special
injunctive actions under 1531 are to preserve the status quo once
litigation has commenced. It is attached to a “heretofore” filed action.
And absent a lien or dispute as to ownership, it is well-settled that there is
no jurisdiction for the Court to even entertain such an injunctive action.
Furthermore, would be a contested motion which required compliance
Also, in case you didn’t notice he is not asking whether you will accept
service on the baseless injunction but rather he is trying to trick you or me
to waive service on the several pages of paper attached to the PI motion
loosely described a “Complaint” for some cause of action not intensified,
for possible damages related to the “BODs” year long failure to remedy
the leaking of the “electrical” vault into the basement which of course I
am not even minimally responsive for.
He also got someone to enter that baseless “complaint” which does not
even minimally satisfy either rule of court (no affidavit of service, no
cover, no damages, etc.) as if he filed a day before the injunctive motion.
And all of this is simply so that he get before the Judge he knows will find
for him and whom he obviously contacted directly as if there were an
existing litigation which there is not. And it evident from the fictitious
complaint that they are seeking damages. That is a contract based claim.
Furthermore, they are adding me personally as defendant no reason that
they identify in their complaint.

concerned that it is not you and Joe who are pointing this stuff out to me.
He is seeking the extraordinary remedy of ex parte injunctive relief for a

leak that by his count had been ongoing for two weeks (Feb. 1). Again,
four floors below me. I have no water leak, their offices right below me
have no water leak, the first floor of the garage has no water leak. This
is abuse of process.

seriously. Arthur Goldberg is dangerous to me and he is stalking me. And
I can prove that.

complaint?

By the way, Goldberg literally is stalking me. I get emails, letters, phone
messages almost every day. And I will never negotiate with a target of my
own investigations as if he had any illegitimacy whatsoever. And I just
don’t do dirty lawyers. I prosecute them. I have respect for the law that
these people get paid to circumvent and abuse.
Four, I have zero interest in participating in a rigged proceeding. I would

prefer to let them go forward and issue the utterly baseless injunction for
which this court has no jurisdiction and simply file an immediate appeal
and restraining order. What exactly are the steps for appealing a “special
injunction” issued in equity and what is the deadline? Who would hear
the appeal?
Gusty, if you were taking me or my situation seriously I just don’t think

your only response would be to treat this as a typical, non-problematic
proceeding when it is anything but that.
At this point, I would like to know the risks and benefits of the various
courses of action that I may take at this time? And I want to understand
step by step how I comply with rules of court, deadlines, and filing
requirements?
Do you have electronic versions of the Rules of Procedure or local rules or

anything at all that I can rent from you? Do you have any forms that I can
use as templates for the various types of pleadings I have to make? I can
rent them.

circumstances and I should not be. And Gusty, why am I telling you all
this stuff. You are a trial lawyer in Pennsylvania and you must deal with
this stuff all the time.
Why am I telling you the difference between a regular injunction or one in

equity? Did you know before this email that he basically tried to trick
me/you into waving service for the complaint?
You must understand Motion Court practice so why aren’t you pissed off
that Jug is overtly circumventing mandatory motions practice. I should
have at least ten days notice. Even special injunctions have to be filed
with motion and have to comply with all pleading and certification
requirements which Jug’s does not and would not be accepted for
motions court at this time.
professional conduct regarding communications with a represented party
given the self-serving request for you to accept service or waive on my
behalf. Does any of this misconduct strike you as even remotely
offensive or concerning? I would really appreciate your thoughts on this.

Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the
intended recipient(s) and may contain confidential and privileged
received this message in error, please notify the sender immediately by
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On Feb 19, 2021, at 10:12 AM, Gusty A.E. Sunseri <gusty-


attorney fees. We definitely need to talk. Is there a leak
in the place?

To: Gus Sunseri
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the

exclusive use of the intended recipient(s) and may
contain confidential and privileged information. If you
are not the intended recipient, please do not read,
distribute, or take action in reliance upon the message. If
you have received this message in error, please notify
the sender immediately by return e-mail and promptly
delete this message and its attachments from your
computer system. Be advised that no privileges are
On Feb 18, 2021, at 6:21 PM, Gus Sunseri

No and no
Sent from my iPhone
On Feb 18, 2021, at 6:14 PM,

Uta von Eckartsberg
wrote:

him?

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

privileged and confidential
and/or it may include attorney
work product. If you are not an
please notify us immediately by
e-mail and delete the original

4:16 PM

would have to speak with you
to see if I would be representing
contact him. Feel free to
contact me.

3:53 PM
To: Gusty Sunseri


412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

law.com>
12:48 PM
To:
Civilgenmotions@alleghenycourts
.us
sunseri@verizon.net
GD 21-001293

has been entered yet in this
case. Your attention to this
matter is appreciated.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

privileged and confidential.
The information is intended for
the use of the intended
recipients only. If you are not
an intended recipient, note that
any disclosure, copying,
distribution or use of the
contents of this message is
prohibited. If you have
received this message in error,
please contact the above sender
and delete this message
immediately.
To: Sunseri Gusty; Lockwood Joe
Subject: Re: ACP. -- Protected Personal/Business financial information - Estate of E Follow-up on Call of Jan. 13, 2021 (ATTACHMENTS ))
Cease & Desist and Notice of Anticipated litigation
Date: Tuesday, January 19, 2021 6:23:42 PM
So I just checked the Estate Account as I have been since Friday. The two charges that are on hold were
pending all weekend. I checked this account multiple times today and the HOA fee was not even
pending. Accoringly, CB intentionally waited until after 4pm to push through and process this unlawful
debit. I just started to write to Jay Luzier but am checking with you to see if you can help. This is illegal
and retaliatory on all sides for all the reasons that I have already described in the several emails to this
bank. My initial draft is below. Thanks.
You made material false statements to me. And you are now arguably a co-conspirator on a civil and
criminal RICO case. You are to reverse this illegal, unauthorized, wholly illegal charge forthwith.
Among other things, I can provide that CB intentionally allowed a usurious, fraudulent charge to go even
before charges that were pending the entire weekend that gave yet to be processed.
Such conduct is illegally and untimely processing and debit credits in a fashion which is in breach of
duties to the estate your customer. The conduct in its entirety is also in violation of all duties of good and
fair dealing as well as multiple rules, regulations and statutes including likely Dodd Frank, Graham Bailey,
etc.
You now have more than sufficient notice of potential litigation and must ensure all records,
communications, statements and all other documents relating to any all contacts with me or any actual or
alleged creditor at all relevant times including from 2016 to present with all accounts

412.207.7742 (PH)
301.461.7445 (C)
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This email message (and any attachments) is for the exclusive use of the intended recipient(s) and may
contain confidential and privileged information. If you are not the intended recipient, please do not read,
distribute, or take action in reliance upon the message. If you have received this message in error, please
notify the sender immediately by return e-mail and promptly delete this message and its attachments from
your computer system. Be advised that no privileges are waived by the transmission of this message.
On Jan 19, 2021, at 4:23 PM, Uta von Eckartsberg <uvoneck@outlook.com> wrote:

Jay, your email server is rejecting all my emails with attachments of communications and
other records all of which are under CB’s possession, custody and control as mandated by
applicable laws, regs, and rules.
Accordingly, please ensure that Farhan Z., Customer Advocacy, and Timothy Balkan secure
their own official records on the account. As stated, Farhan emails will demonstrate that he
had notice of my mother’s death including even the short term cert no later than the Morning
of Oct. 1
With respect to the likely unauthorized ACH withdrawals my instructions and email is
sufficient to put you on notice regarding those entities. More urgently, (1) seek that CB
provide me with information sufficient to identify the originating entity on the Nov and Dec
ACH withdrawals and (2) copies or whatever records provided to you by the originator
forthwith. Again, I would appreciate the courtesy of a written response and confirmation that
CB is acting upon my instructions.
Thank you.
Uta
412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
please do not read, distribute, or take action in reliance upon the message. If you have
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On Jan 19, 2021, at 1:59 PM, Uta von Eckartsberg <uvoneck@outlook.com>

wrote:

Trying again. 2 of 4 attachments. This is initial notice of death

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
On Jan 19, 2021, at 3:10 AM, Uta von Eckartsberg

A
ttached are representative documents illustrating: (1) Citizen’s
Bank by and through its employee knew as of Oct. 1, 2020 that my
mother was dead and that it was required to immediately effect the
DNE – a non-discretionary action; and, (2) a copy of the only
preauthorization from I ever executed which I know to be
insufficient as a matter of law to permit Receiver Bank (Citizens) to
effect the Preauth and certainly days or months after the specified
date – 15th of the month. I don’t know what entity originated the
two allegedly preauthorized ACH withdrawals to date, but that entity
as well as the entity identified on the attached preauthorization, “RJ
Community Management” are subject the Stop Payment Order. As
is any entity d/b/a Arnheim & Neely or RJ Development or any
entity dba Imperial House Condo fees or Imperial House
Condominium Association, Inc. None of the latter entities have any
authorization now or ever and the single pre-authorization I wrote is
now null and void. I need you to provide me whatever information
Citizens received from the originator of the two payments at issue to
date including any proof of preauthorization. I assume that the
originating entity used some sort of Electronic Check Conversion to
effect the ACH withdrawals as I was required to provide a voided
check. Please confirm receipt of this email, the attachments and
that no unauthorized ACH withdrawals will be processed with
respect to any of the above described entities as well as whatever
entity initiated the Nov/Dec. ACH withdrawals. Thank you.

personal use of the recipient(s) named above. This message may be
an attorney-client communication and as such privileged and
confidential and/or it may include attorney work product. If you are
not an intended recipient, you may not review, copy or distribute this
message. If you have received this communication in error, please
notify us immediately by e-mail and delete the original message and
its attachments from your computer system. Please be advised that

Sent: Friday, January 15, 2021 4:55 PM
To: jay.luzer@citizensbank.com
Subject: RE: (Confidential treatment -- Protected Personal/Business
financial information - Estate of Elsa von Eckartsberg) Follow-up on
Call of Jan. 13, 2021
Importance: High
Trying again. Pls see below. Thank you.

To:
jay.luzer@citizensbank.com<mailto:jay.luzer@citizensbank.com>
Cc: uvoneck@outlook.com<mailto:uvoneck@outlook.com>
Subject: (Confidential treatment -- Protected Personal/Business
Importance: High
Jay,
Please see attached. I have confirmed that I acutally provided the
short form cert. on 10.01.2020 – more than one-week before the SSA
ACH deposit. Furthermore, given the email to CB credit card folks, I
had also notifed the bank and closed the credit card on or before Oct.
7. I am requesting an investigation and a reversal of the $3k debit
from the Estate Account that was initiated by Supervisor Lynn M.
immediately after I instructed CB not to process it after my initial
complaint to Citizen Bank’s ROP. Again, with consent I recorded
with Lynn and Saundra. See attached.
More importantly, please confirm and verify that the Stop Payment
Order is in effect. If so, what entity is now barred from attempting
the ACH debits at issue? I have not idea because there is no required
information reflectted on CB statements. I do not see how CB can
stop payment when there is apparently no internal record on the
bank’s end as to the Originator of the two known ACH withdrawals
to date that would be subject to the Stop Payment Order.
Per our conversation, the only identifying info the ACH debit of
$546.00 on 11/27/2020 and $546.00 on 12/09/2020, respectively, for
a total amount of $1092.00 to date is as follows: “Imperial House
HOA Dues.” That constitutes a description of the purpose of the
debit not the originating person which is insufficient as a matter of
law.
As you pointed out during our call, the only entry relates to the
alleged purpose of the ACH withdrawal. I have no idea who is the
originator of these two entries. And when I attempt to review my
online account statements, I can only obtain the first page of any
periodic statement unless I access the website using my PC which is
not my usual practice. I have never received a paper statement nor
a pdf version nor even notice of monthly statements. I never
received a single discloure on this small business account including
with respect to ECF and Regulation E, etc.
Attached is the single authorization I executed and have now

revoked. The origninator idenitified itself as RJ Community
Management. After research and minimal due diligence, even I can
tell that this preauthorization form does not satisfy minimim
requirements for an effective authorization sufficent to allow CB to
simply process the debits without any notice and apparently without
even confirming or indentifying the originator. Specifically: The
minimal info entered by the bank references no entity.
Before my mother’s death, the HOA fees were debited by Arnheim

& Neely. That entity has never been authorized to debit the estate
account. Had I known of statutory issues with respect to mandatory
disclosures required by the originator and the receiving bank –
Citizens, I would have issued a Stop Holder no later than 72 hours
after the payment date passed. And I have complained to the
originator but they ignored my complaints and I let them becaue I did
not know better. The substance of each complaint to the alleged
orignator is information that should have triggered red flags for
Citizen’s Bank including that not one ACH withdraw was remotely
close in time to the specified date of ACH withdrawl – the 5th of
each month. See the most recent false statement by the alleged
originator dated 12.31.2020. There has been no related Ach
withdrawal. See attached.
Public records indicate that RJ Community did not and cannot be the
originating entity for these ACH withdrawals.
I am requesting an investigation on how this could occur. And I am

seeking reversal on both deposits under the circumstances. Among
other things, the authorization was limited to a single date – on or
about the 5th of the month full stop. There is no disclosure on the
originators’ end nor CB as to any applicable laws, regquirements,
governing ECF debits, including but not limited to, Reg. E, Nacha,
FDIC, CFPB, and OCC examination and other informational
materials. Please provide me with all related audit-trails, emails,
and a list of any all affiliates or otherwise with whom Citizen’s Bank
has disclosed, disseminated, or shared any information whatsoever
regarding this account, Elsa or Uta von Eckartsberg. At a bare
minimum, please ensure all records are preserved since absent quick
action, Citizens has liabilty to at least the estate.
And I am sure that I am not using whatever magic words necessary

to trigger a full-blown internal investigation but to ingore this
complaint and my requests for all applicable audit and other paper
trails with respect to these transactions will subject Citizen’s to
liablity to the Estate. I strongly recommend that Citizen’s Bank self-
report to the CFPB given that what I complain of is almost certainly
not specific to just this account or these transactions
Jay, if I am required to fill specific forms then please provide them to

me forthwith. I really do hope that you are the ethical, good guy I
thought you were.
Thank you,
Uta
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)


Sent: Wednesday, January 13, 2021 3:54 PM
To:
jay.luzer@citizensbank.com<mailto:jay.luzer@citizensbank.com>
Subject: FW: Estate of Elsa von Eckartsberg (RtvE and EvE joint
acct ***) Inaccurate Tax info correction assistance requested.
(Confidential treatment of financial account info requested)
Importance: High
Jay, thank again! I appreciate your kind attention to this matter.

Please see attached and please confirm receipt at your convenience.
Uta
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

<uvoneck@outlook.com<mailto:uvoneck@outlook.com>>
Sent: Friday, December 18, 2020 2:47 PM
To:
timothy.balkan@citizens.com<mailto:timothy.balkan@citizens.com>;
Zahir, Farhan Z
<Farhan.Zahir@CITIZENSBANK.com<mailto:Farhan.Zahir@CITIZENSBANK.com>>
Cc: Uta von Eckartsberg
Subject: Estate of Elsa von Eckartsberg (RtvE and EvE joint acct
***) Inaccurate Tax info correction assistance requested.
(Confidential treatment of financial account info requested)
Importance: High
Hello,
Will you please do me the favor of forwarding this email to your

manager, Jay? I seem to have lost his email address. I think the
attachments are self-explanatory. The information reported to Dept
of Tax are inaccurate because by operation of law upon my mother’s
death, my brother who was the joint owner of the account became the
sole owner of the account. I have never had custody, control, or any
direct in this account. I believe your account opening records will
confirm who opened the account and that any interest flowing to me
would only be triggered by the death of the two owners of the
account.
Jay, if you cannot fix this will you please forward to the appropriate
party and copy me? I’d be very grateful for your help.
Hope you are all well and safe.
Kind regards,
Uta

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

its attachmentsfrom your computer system. Please be advised that no
Subject: Re: ACP. -- Protected Personal/Business financial information - Estate of E Follow-up on Call of Jan. 13, 2021
(ATTACHMENTS )) Cease & Desist and Notice of Anticipated litigation
Date: Thursday, February 18, 2021 11:57:54 AM
Uta please give me a call

Sent: Tuesday, January 19, 2021 6:23 PM
To: Sunseri Gusty ; Lockwood Joe
Subject: Re: ACP. -- Protected Personal/Business financial information - Estate of E Follow-up on Call of
Jan. 13, 2021 (ATTACHMENTS )) Cease & Desist and Notice of Anticipated litigation
So I just checked the Estate Account as I have been since Friday. The two charges that are on hold were pending all
weekend. I checked this account multiple times today and the HOA fee was not even pending. Accoringly, CB
intentionally waited until after 4pm to push through and process this unlawful debit. I just started to write to Jay
Luzier but am checking with you to see if you can help. This is illegal and retaliatory on all sides for all the reasons
that I have already described in the several emails to this bank. My initial draft is below. Thanks.

You made material false statements to me. And you are now arguably a co-conspirator on a civil and criminal RICO
case. You are to reverse this illegal, unauthorized, wholly illegal charge forthwith. Among other things, I can
provide that CB intentionally allowed a usurious, fraudulent charge to go even before charges that were pending the
entire weekend that gave yet to be processed.
Such conduct is illegally and untimely processing and debit credits in a fashion which is in breach of duties to the
estate your customer. The conduct in its entirety is also in violation of all duties of good and fair dealing as well as
multiple rules, regulations and statutes including likely Dodd Frank, Graham Bailey, etc.
You now have more than sufficient notice of potential litigation and must ensure all records, communications,
statements and all other documents relating to any all contacts with me or any actual or alleged creditor at all
relevant times including from 2016 to present with all accounts

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended recipient(s) and may contain
confidential and privileged information. If you are not the intended recipient, please do not read, distribute, or take
action in reliance upon the message. If you have received this message in error, please notify the sender
immediately by return e-mail and promptly delete this message and its attachments from your computer system. Be
advised that no privileges are waived by the transmission of this message.

Jay, your email server is rejecting all my emails with attachments of communications and other
records all of which are under CB’s possession, custody and control as mandated by applicable laws,
regs, and rules.
Accordingly, please ensure that Farhan Z., Customer Advocacy, and Timothy Balkan secure their own
official records on the account. As stated, Farhan emails will demonstrate that he had notice of my
mother’s death including even the short term cert no later than the Morning of Oct. 1
With respect to the likely unauthorized ACH withdrawals my instructions and email is sufficient to
put you on notice regarding those entities. More urgently, (1) seek that CB provide me with
information sufficient to identify the originating entity on the Nov and Dec ACH withdrawals and (2)
copies or whatever records provided to you by the originator forthwith. Again, I would appreciate
the courtesy of a written response and confirmation that CB is acting upon my instructions.
Thank you.
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended recipient(s) and
may contain confidential and privileged information. If you are not the intended recipient, please do
not read, distribute, or take action in reliance upon the message. If you have received this message
in error, please notify the sender immediately by return e-mail and promptly delete this message
and its attachments from your computer system. Be advised that no privileges are waived by the


412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
recipient(s) and may contain confidential and privileged information. If you are not
the intended recipient, please do not read, distribute, or take action in reliance upon
the message. If you have received this message in error, please notify the sender

Attached are representative documents illustrating: (1) Citizen’s Bank

by and through its employee knew as of Oct. 1, 2020 that my mother
was dead and that it was required to immediately effect the DNE – a
non-discretionary action; and, (2) a copy of the only preauthorization
from I ever executed which I know to be insufficient as a matter of law
to permit Receiver Bank (Citizens) to effect the Preauth and certainly
days or months after the specified date – 15th of the month. I don’t
know what entity originated the two allegedly preauthorized ACH
withdrawals to date, but that entity as well as the entity identified on
the attached preauthorization, “RJ Community Management” are
subject the Stop Payment Order. As is any entity d/b/a Arnheim &
Neely or RJ Development or any entity dba Imperial House Condo fees
or Imperial House Condominium Association, Inc. None of the latter
entities have any authorization now or ever and the single pre-
authorization I wrote is now null and void. I need you to provide me
whatever information Citizens received from the originator of the two
payments at issue to date including any proof of preauthorization. I
assume that the originating entity used some sort of Electronic Check
Conversion to effect the ACH withdrawals as I was required to provide
a voided check. Please confirm receipt of this email, the
attachments and that no unauthorized ACH withdrawals will be
processed with respect to any of the above described entities as well
as whatever entity initiated the Nov/Dec. ACH withdrawals. Thank
you.
DISCLAIMER: This e-mail message is intended only for the personal

use of the recipient(s) named above. This message may be an
attorney-client communication and as such privileged and confidential
and/or it may include attorney work product. If you are not an
intended recipient, you may not review, copy or distribute this

Importance: High

To: jay.luzer@citizensbank.com<mailto:jay.luzer@citizensbank.com>
Importance: High
Jay,
complaint to Citizen Bank’s ROP. Again, with consent I recorded with
Lynn and Saundra. See attached.
bank’s end as to the Originator of the two known ACH withdrawals to
date that would be subject to the Stop Payment Order.
law.
not my usual practice. I have never received a paper statement nor a
pdf version nor even notice of monthly statements. I never received
a single discloure on this small business account including with
respect to ECF and Regulation E, etc.

Before my mother’s death, the HOA fees were debited by Arnheim &
Neely. That entity has never been authorized to debit the estate
close in time to the specified date of ACH withdrawl – the 5th of each
month. See the most recent false statement by the alleged originator
dated 12.31.2020. There has been no related Ach withdrawal. See
attached.

FDIC, CFPB, and OCC examination and other informational materials.
Please provide me with all related audit-trails, emails, and a list of any
all affiliates or otherwise with whom Citizen’s Bank has disclosed,
disseminated, or shared any information whatsoever regarding this
account, Elsa or Uta von Eckartsberg. At a bare minimum, please
ensure all records are preserved since absent quick action, Citizens
has liabilty to at least the estate.
And I am sure that I am not using whatever magic words necessary to

trigger a full-blown internal investigation but to ingore this complaint
and my requests for all applicable audit and other paper trails with
respect to these transactions will subject Citizen’s to liablity to the
Estate. I strongly recommend that Citizen’s Bank self-report to the
CFPB given that what I complain of is almost certainly not specific to
just this account or these transactions

thought you were.
Thank you,
Uta
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

Subject: FW: Estate of Elsa von Eckartsberg (RtvE and EvE joint acct
***) Inaccurate Tax info correction assistance requested. (Confidential
treatment of financial account info requested)
Importance: High

Uta
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)


To:
Zahir, Farhan Z
Subject: Estate of Elsa von Eckartsberg (RtvE and EvE joint acct ***)
Inaccurate Tax info correction assistance requested. (Confidential
Importance: High
Hello,

death, my brother who was the joint owner of the account became
the sole owner of the account. I have never had custody, control, or
any direct in this account. I believe your account opening records will
account.
Kind regards,
Uta

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

its attachmentsfrom your computer system. Please be advised that
To: uvoneck@outlook.com
Subject: Re: ACP. -- Protected Personal/Business financial information - Estate of E Follow-up on Call of Jan. 13, 2021
(ATTACHMENTS )) Cease & Desist and Notice of Anticipated litigation
Date: Thursday, February 18, 2021 11:57:54 AM
Uta please give me a call

Sent: Tuesday, January 19, 2021 6:23 PM
To: Sunseri Gusty ; Lockwood Joe
Subject: Re: ACP. -- Protected Personal/Business financial information - Estate of E Follow-up on Call of
Jan. 13, 2021 (ATTACHMENTS )) Cease & Desist and Notice of Anticipated litigation
So I just checked the Estate Account as I have been since Friday. The two charges that are on hold were pending all
weekend. I checked this account multiple times today and the HOA fee was not even pending. Accoringly, CB
intentionally waited until after 4pm to push through and process this unlawful debit. I just started to write to Jay
Luzier but am checking with you to see if you can help. This is illegal and retaliatory on all sides for all the reasons
that I have already described in the several emails to this bank. My initial draft is below. Thanks.

You made material false statements to me. And you are now arguably a co-conspirator on a civil and criminal RICO
case. You are to reverse this illegal, unauthorized, wholly illegal charge forthwith. Among other things, I can
provide that CB intentionally allowed a usurious, fraudulent charge to go even before charges that were pending the
entire weekend that gave yet to be processed.
Such conduct is illegally and untimely processing and debit credits in a fashion which is in breach of duties to the
estate your customer. The conduct in its entirety is also in violation of all duties of good and fair dealing as well as
multiple rules, regulations and statutes including likely Dodd Frank, Graham Bailey, etc.
You now have more than sufficient notice of potential litigation and must ensure all records, communications,
statements and all other documents relating to any all contacts with me or any actual or alleged creditor at all
relevant times including from 2016 to present with all accounts

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)

Jay, your email server is rejecting all my emails with attachments of communications and other
records all of which are under CB’s possession, custody and control as mandated by applicable laws,
regs, and rules.
Accordingly, please ensure that Farhan Z., Customer Advocacy, and Timothy Balkan secure their own
official records on the account. As stated, Farhan emails will demonstrate that he had notice of my
mother’s death including even the short term cert no later than the Morning of Oct. 1
With respect to the likely unauthorized ACH withdrawals my instructions and email is sufficient to
put you on notice regarding those entities. More urgently, (1) seek that CB provide me with
information sufficient to identify the originating entity on the Nov and Dec ACH withdrawals and (2)
copies or whatever records provided to you by the originator forthwith. Again, I would appreciate
the courtesy of a written response and confirmation that CB is acting upon my instructions.
Thank you.
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)


412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)

Attached are representative documents illustrating: (1) Citizen’s Bank

by and through its employee knew as of Oct. 1, 2020 that my mother
was dead and that it was required to immediately effect the DNE – a
non-discretionary action; and, (2) a copy of the only preauthorization
from I ever executed which I know to be insufficient as a matter of law
to permit Receiver Bank (Citizens) to effect the Preauth and certainly
days or months after the specified date – 15th of the month. I don’t
know what entity originated the two allegedly preauthorized ACH
withdrawals to date, but that entity as well as the entity identified on
the attached preauthorization, “RJ Community Management” are
subject the Stop Payment Order. As is any entity d/b/a Arnheim &
Neely or RJ Development or any entity dba Imperial House Condo fees
or Imperial House Condominium Association, Inc. None of the latter
entities have any authorization now or ever and the single pre-
authorization I wrote is now null and void. I need you to provide me
whatever information Citizens received from the originator of the two
payments at issue to date including any proof of preauthorization. I
assume that the originating entity used some sort of Electronic Check
Conversion to effect the ACH withdrawals as I was required to provide
a voided check. Please confirm receipt of this email, the
attachments and that no unauthorized ACH withdrawals will be
processed with respect to any of the above described entities as well
as whatever entity initiated the Nov/Dec. ACH withdrawals. Thank
you.


Importance: High

Importance: High
Jay,
complaint to Citizen Bank’s ROP. Again, with consent I recorded with
Lynn and Saundra. See attached.
bank’s end as to the Originator of the two known ACH withdrawals to
date that would be subject to the Stop Payment Order.
law.
not my usual practice. I have never received a paper statement nor a
pdf version nor even notice of monthly statements. I never received
a single discloure on this small business account including with
respect to ECF and Regulation E, etc.

Before my mother’s death, the HOA fees were debited by Arnheim &
Neely. That entity has never been authorized to debit the estate
close in time to the specified date of ACH withdrawl – the 5th of each
month. See the most recent false statement by the alleged originator
dated 12.31.2020. There has been no related Ach withdrawal. See
attached.

FDIC, CFPB, and OCC examination and other informational materials.
Please provide me with all related audit-trails, emails, and a list of any
all affiliates or otherwise with whom Citizen’s Bank has disclosed,
disseminated, or shared any information whatsoever regarding this
account, Elsa or Uta von Eckartsberg. At a bare minimum, please
ensure all records are preserved since absent quick action, Citizens
has liabilty to at least the estate.
And I am sure that I am not using whatever magic words necessary to

trigger a full-blown internal investigation but to ingore this complaint
and my requests for all applicable audit and other paper trails with
respect to these transactions will subject Citizen’s to liablity to the
Estate. I strongly recommend that Citizen’s Bank self-report to the
CFPB given that what I complain of is almost certainly not specific to
just this account or these transactions

thought you were.
Thank you,
Uta
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

Subject: FW: Estate of Elsa von Eckartsberg (RtvE and EvE joint acct
***) Inaccurate Tax info correction assistance requested. (Confidential
Importance: High

Uta
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)


To:
Zahir, Farhan Z
Subject: Estate of Elsa von Eckartsberg (RtvE and EvE joint acct ***)
Inaccurate Tax info correction assistance requested. (Confidential
Importance: High
Hello,

death, my brother who was the joint owner of the account became
the sole owner of the account. I have never had custody, control, or
any direct in this account. I believe your account opening records will
account.
Kind regards,
Uta

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

its attachmentsfrom your computer system. Please be advised that
To: Fred C Jug ; "Law Linda"; "Uta von Eckartsberg"
Linda Kindly please feel to eliminate me from these emails as I never entered my appearance
in this case for the Estate or Uta von Eckartsberg. Thank you
From: Fred C Jug

To: 'Law Linda' ; 'Uta von Eckartsberg' ; gusty-sunseri@verizon.net

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

Importance: High
Good afternoon,

sunseri@verizon.net


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Charles Gallo
To: Fred C Jug
Cc: Law Linda; Uta von Eckartsberg
Please call:
1-877-953-7157
Pin
416 7541 #
C Gallo

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
immediately.

Cc: Law Linda <Linda.Law@alleghenycourts.us>; Uta von Eckartsberg
Subject: Re: CEASE & Desist and Identity fraud (offers and sales of unregistered
securities)l
I don’t believe you guys are on the Judge’s schedule tomorrow and Linda is on vacation
this week. I’ll be at a funeral.
I’m guessing this needs rescheduled when Linda gets back. How was it scheduled? Per
order?
C Gallo
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
immediately.

To: 'Fred C Jug ' <fjug@bmr-law.com>; 'Uta von Eckartsberg'
<uvoneck@outlook.com>; 'gusty-sunseri@verizon.net' <gusty-sunseri@verizon.net>
Subject: RE: CEASE & Desist and Identity fraud (offers and sales of unregistered
securities)l
Importance: High
Good afternoon,
Attached is an Order of Court dated February 25, 2021 regarding the above matter.
Please feel free to email if you have any questions.

Cc: Law Linda <Linda.Law@alleghenycourts.us>; 'Charles Gallo'
<chazgallo@gmail.com>; gusty-sunseri@verizon.net
securities)l
well. Rather than proceed today the Judge indicated that he would issue an Order
granting you a postponement until March 10, 2021 at 1:30 pm. We should expect to
receive an Order with the new date. Since Mr. Sunseri was on the original service email
as counsel for the Estate I was directed to again include him and have done so.
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
immediately.
securities)l
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
immediately.
From: Charles Gallo
To: Fred C Jug
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

securities)l
order?
C Gallo
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
immediately.

securities)l
Importance: High
Good afternoon,

securities)l

well. Rather than proceed today the Judge indicated that he would issue an Order granting
you a postponement until March 10, 2021 at 1:30 pm. We should expect to receive an
Order with the new date. Since Mr. Sunseri was on the original service email as counsel
for the Estate I was directed to again include him and have done so.
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
immediately.

securities)l
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
immediately.
From: Charles Gallo
To: Fred C Jug
C Gallo
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
Importance: High
Good afternoon,

Cc: Law Linda <Linda.Law@alleghenycourts.us>; 'Charles Gallo' <chazgallo@gmail.com>;
gusty-sunseri@verizon.net

you a postponement until March 10, 2021 at 1:30 pm. We should expect to receive an Order
with the new date. Since Mr. Sunseri was on the original service email as counsel for the
Estate I was directed to again include him and have done so.
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Charles Gallo
To: Fred C Jug
Thank you.
Thank you Mr. Gallo. I put this on my calendar for 1pm tomorrow. The Constable and
Plumber were there last week and did gain access. I understand the Plumber located and
repaired a leak.
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

securities)l
Please call:
1-877-953-7157
Pin
416 7541 #
C Gallo
Was scheduled by the attached Order which I highlighted the language on. Just wanted
to make sure I was not missing the call in number and if needs rescheduled we
understand.
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
immediately.

securities)l
I don’t believe you guys are on the Judge’s schedule tomorrow and Linda is on vacation
this week. I’ll be at a funeral.
order?
C Gallo
Dear Linda: Pursuant to the attached Order of March 10, 2021 the final Hearing on
the Injunction is scheduled via telephone conference tomorrow at 9:30 am. It would
be appreciated if you let us know if there is a dial in number for the conference.
Your attention to this matter is appreciated
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
that may be privileged and confidential. The information is intended for the use of
the intended recipients only. If you are not an intended recipient, note that any
disclosure, copying, distribution or use of the contents of this message is prohibited.
If you have received this message in error, please contact the above sender and delete
this message immediately.

To: 'Fred C Jug ' <fjug@bmr-law.com>; 'Uta von Eckartsberg'
<uvoneck@outlook.com>; 'gusty-sunseri@verizon.net' <gusty-sunseri@verizon.net>
securities)l
Importance: High
Good afternoon,
Attached is an Order of Court dated February 25, 2021 regarding the above matter.
Please feel free to email if you have any questions.

securities)l

I informed the Judge of your email earlier today in which you said you were not
feeling well. Rather than proceed today the Judge indicated that he would issue an
Order granting you a postponement until March 10, 2021 at 1:30 pm. We should
expect to receive an Order with the new date. Since Mr. Sunseri was on the original
service email as counsel for the Estate I was directed to again include him and have
done so.
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

securities)l
I received your email. The Judge is on the line right now and waiting for you to call
in.
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
Cc: Gusty Sunseri
Subject: Re: Estate of Elsa Von Eckartsberg
Thanks so much. Appreciate your help.
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
On Feb 22, 2021, at 6:40 PM, jlockwood@sunserilawfirm.com wrote:
Uta,
Please see the attached correspondence from Attorney Sunseri regarding the
documentation needed for the Inheritance Tax Return.
Thank you,
Joe

Attorney at Law
1290 Freeport Road
Phone (412) 968-0210
Fax (412) 968-0254
This e-mail and any files transmitted with it are confidential and intended solely
for the use of the individual or entity to which they are addressed. If you have
received this e-mail in error, please notify the sender immediately and delete this
e-mail from your system. If you are not the named addressee, you should not
disseminate, distribute, or copy this e-mail. If you are not the intended recipient,
you are notified that disclosing, copying, distributing, or taking any action in
reliance on the contents of this information is strictly prohibited.
From: Charles Gallo
To: Fred C Jug
Subject: Re: GD 21-001293
Date: Tuesday, April 6, 2021 1:32:21 PM
Received.
Thank you.
C Gallo
On Tue, Apr 6, 2021 at 11:24 AM Fred C Jug <fjug@bmr-law.com> wrote:
Dear Mr. Gallo: Since access has now been obtained attached is a Proposed Order for the
Judge’s consideration at the call this afternoon at 1pm dissolving the Special Injunction
and releasing the Bond. Your attention to this mater is appreciated.
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
To: 'Charles Gallo' <chazgallo@gmail.com>
Cc: 'Law Linda' <Linda.Law@alleghenycourts.us>; 'Uta von Eckartsberg'
securities)l
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

securities)l
order?
C Gallo
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
immediately.

securities)l
Importance: High
Good afternoon,

securities)l

you a postponement until March 10, 2021 at 1:30 pm. We should expect to receive an
Order with the new date. Since Mr. Sunseri was on the original service email as counsel
for the Estate I was directed to again include him and have done so.
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
immediately.

securities)l
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
immediately.
From: Markus Penzel
Uta:
Thanks for sharing this with me. However, I feel neither competent nor qualified to get involved. Good luck!
Love,
Mark
On Thursday, February 18, 2021, 8:02:30 PM EST, Uta von Eckartsberg <uvoneck@outlook.com> wrote:
Mark,
Please see below email to my probate lawyer and please also see the attachments to that email as
well the three 2017 emails which I forward only to you. I am sharing this information with you
because I do not have anyone else that can even potentially understand what I describe below and in
the attached historical records. The backstory is that bad actors in my mother’s building filed a
fraudulent motion for injunctive action against me for reasons I cannot detail in an email.
I am sharing this information with you because I need you to take me seriously as I have asked our
probate lawyer to do for my brothers’ sake. My entire family is disabled as in cognitively impaired
and has been for a very long time. If I drop dead tomorrow, I need someone to look out for my
brothers. I just want you to make sure a good lawyer reviews my evidentiary records to protect my
brothers’ financial future. I have POA whom I trust but she is not a lawyer and she is not family.
Also, I stand by everything I wrote to OIG/OPM which was met with more retaliatory conduct
impacting my pay and benefits which continues through the present.
I think you may recall our brief conversation years ago when I sought advice about my then-works
issues, I know you thought I was crazy. As did all my close friends at the time who also practiced
employment law. The fact is that unbeknownst to me at the time is that I was the target of
retaliatory harassment over the course of more than a decade for what I now recognize was
inadvertent whistleblowing. Such conduct violates both the federal sector whistleblower protection
acts and is a prohibited personnel practice as a matter of law and fact pursuant federal sector
employments which are not at all equivalent to private sector employment discrimination cases. It
was not until after I was forced into an early retirement in retaliation for making protected
disclosures which I did not understand or intend to be “whistleblower reports” per se, that I began to
understand the distinctions between federal and private sector employments laws. In fact, I never
heard of prohibited personnel practices or any other federal sector-specific employment laws until
well after I left the SEC. And only because I could not understand what happened and why, I
eventually put most of the pieces together. For the record, I was never a disgruntled employee. In
fact, post-Madoff, I was thrilled that AUSAs were installed to run the SEC and I admired and
respected all of them. I never thought I was doing anything other than supporting my agency and
our mission.
The attached screenshots are simply of my evidentiary records with respect to my current estate-
related investigation. Separately, I have all my evidentiary records from the SEC as well as of hard
evidence of the ongoing retaliatory that I continue to endure. If you want to know why anyone
would that care that much about me - trust me it’s not because I am particularly smart or have any
special knowledge. Rather, it’s basically because after ten minutes of reviewing the applicable SEC
filings I can tell you exactly who the undisclosed control persons of the GameStop are as well as
who coordinated touters are on Reddit. And right now, every single investor has a right to recission
under Section 5 of the Securities Act because at all relevant times the control persons of the issuer
sold unregistered securities when no exemption or safe harbor was available to it. And violation of
the registration provisions of Securities Act is a strict liability offense. Full stop. As touched
upon in Confidential Update III attached, even on the criminal side there is little to no burden to
prove intent.
I am not asking you to get involved in this in any fashion whatsoever. To do so, would likely
jeopardize your job. I just want someone besides my probate lawyer to understand my situation and
to know where my evidentiary records are contained for my brothers’ sake. The only thing that I
ask is that you not just dismiss what I have to say as the ramblings of a crazy women. There is
nothing that I say or allege that is not backed up by direct, hard evidence. Please do not just
dismiss what I write. I can answer any question you have. That said, I have no administrative
support whatsoever and I have never in my legal career ever personally sued anyone. I cannot
singlehandedly package an enormous evidentiary record and have been materially discredited as is
typical for folks in the federal sector who like me become accidental whistleblowers (and the federal
employee antiretaliation laws protect even inadvertent disclosures. Thank you for your kind
attention to this. If its okay, I would like to send you the password info for my dropbox files. Hard
copy records are also in the Condo and at my other’s house in the country. And if you happen to
have any pleading type templates that you can share with me, I would be really grateful. I cannot
even format an affidavit much less a pleading with my software. It’s so basic but a huge issue for
me in terms of being able to package or communicate anything to anyone ….
Love,
Uta
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

Gusty,
Thanks.
Uta
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

Importance: High

From: Law Linda
Good afternoon,
(412) 350-0281
To: Fred C Jug ; "Law Linda"; uvoneck@outlook.com
Subject: Re: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg
Date: Monday, February 22, 2021 11:02:27 AM
To All Concerned:
Please be informed that I will not be representing Ms. Von Eckartsberg and the Estate of Elsa
Von Eckarstberg in the above referenced case. My representation is limited to probating the
Estate. Thank you
From: Fred C Jug

To: 'Law Linda' ; uvoneck@outlook.com ; gusty-sunseri@verizon.net

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

To: fjug@bmr-law.com; uvoneck@outlook.com; gusty-sunseri@verizon.net
Importance: High
Good afternoon,
(412) 350-0281
Subject: Re: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got this. How long do I have to
Gusty,
ownership, it is well-settled that there is no jurisdiction for the Court to even entertain such an
injunctive action. Furthermore, would be a contested motion which required compliance with
motions court practice as to filing.
intensified, for possible damages related to the “BODs” year long failure to remedy the
leaking of the “electrical” vault into the basement which of course I am not even minimally
responsive for.

their offices right below me have no water leak, the first floor of the garage has no water leak.
This is abuse of process.
contested motion?
Four, I have zero interest in participating in a rigged proceeding. I would prefer to let them
go forward and issue the utterly baseless injunction for which this court has no jurisdiction and
the appeal?
Do you have electronic versions of the Rules of Procedure or local rules or anything at all that
I can rent from you? Do you have any forms that I can use as templates for the various types
complaint?
at this time.
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)

wrote:

in the place?

To: Gus Sunseri
Good. Thanks.
412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
On Feb 18, 2021, at 6:21 PM, Gus Sunseri <gusty-sunseri@verizon.net> wrote:
No and no
Sent from my iPhone



412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

of this message.

contact me.

To: Gusty Sunseri


412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

of this message.

sunseri@verizon.net
GD 21-001293


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

From: Gus Sunseri
No and no
Sent from my iPhone

wrote:


412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

I did not accept service for you or the Estate. I told him that I would have to speak
with you to see if I would be representing you in this. Given the nature of the
allegation-potential continuing water damage-I would suggest that you contact
him. Or, if you want me to represent you in this, I can contact him. Feel free to
contact me.

To: Gusty Sunseri
Subject: FW: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got
What is the procedure on this? I want to file a motion for special injunction in
response…..l;

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

Please find attached an Emergency Motion For Special Injunction and a Proposed
Order. The Proposed Order is provided in word format pursuant to the Standard
Operating Procedures of the Court. The Plaintiff would appreciate this matter
now be scheduled. The Motion has also been mailed to the Defendant and the
defendant is copied on this email. A courtesy copy is also being provided to
counsel for the estate who is also copied on this email as no appearance has been
entered yet in this case. Your attention to this matter is appreciated.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
This electronic message and any attachments transmitted with it contain

information that may be privileged and confidential. The information is intended
for the use of the intended recipients only. If you are not an intended recipient,
note that any disclosure, copying, distribution or use of the contents of this
message is prohibited. If you have received this message in error, please contact
Rule 1531. Special Relief. Injunctions.

(a) A court shall issue a preliminary or special injunction only after written notice and hearing
unless it appears to the satisfaction of the court that immediate and irreparable injury will be
sustained before notice can be given or a hearing held, in which case the court may issue a
preliminary or special injunction without a hearing or without notice. In determining whether a
preliminary or special injunction should be granted and whether notice or a hearing should be
required, the court may act on the basis of the averments of the pleadings or petition and may
consider affidavits of parties or third persons or any other proof which the court may require.
Official Note
Section 601(b) of the Clean Streams Law, Act of June 22, 1937, P. L. 1987, 35 P. S. § §
691.601(b), relieves the Attorney General, the district attorney or the solicitor of a
municipality from the requirement of bond in injunction proceedings.
Section 7 of the Act of April 11, 1929, P. L. 488, No. 205, 3 P. S. § 297, relating to
certified, inspected or registered seeds, similarly provides that the Attorney General shall not
be required to give bond in injunction proceedings.
(b) Except when the plaintiff is the Commonwealth of Pennsylvania, a political subdivision or
a department, board, commission, instrumentality or officer of the Commonwealth or of a
political subdivision, a preliminary or special injunction shall be granted only if
(1) the plaintiff files a bond in an amount fixed and with security approved by the court,
naming the Commonwealth as obligee, conditioned that if the injunction is dissolved because
improperly granted or for failure to hold a hearing, the plaintiff shall pay to any person injured
all damages sustained by reason of granting the injunction and all legally taxable costs and
fees, or
(2) the plaintiff deposits with the prothonotary legal tender of the United States in an
amount fixed by the court to be held by the prothonotary upon the same condition as provided
for the injunction bond.
Official Note
See Rule 1549(4), (11), (13), (17), (20), (21) and Rule 1550(12), (13), (20), (21), (22), (25),
(26), (27), (29), (30) and (32) for reference to Acts of Assembly containing provisions
relieving the Commonwealth, political subdivisions, and their agencies from the requirement
of bond in injunction proceedings.
(c) Any party may move at any time to dissolve an injunction.
(d) An injunction granted without notice to the defendant shall be deemed dissolved unless a
hearing on the continuance of the injunction is held within five days after the granting of the
injunction or within such other time as the parties may agree or as the court upon cause shown
shall direct.
Official Note
See subdivision (f) of this rule for special provisions relating to injunction restraining
freedom of expression.
If an injunction has been issued without notice, it is optional with the defendant to waive a
hearing on continuance of the injunction under this subdivision and proceed directly to a final
hearing.
(e) After a preliminary hearing, the court shall make an order dissolving, continuing or
modifying the injunction.
(f)(1) When a preliminary or special injunction involving freedom of expression is issued,
either without notice or after notice and hearing, the court shall hold a final hearing within
three days after demand by the defendant. A final order shall be filed in the office of the
prothonotary within twenty-four hours after the close of the hearing. If the final hearing is not
held within the three-day period, or if the final order is not filed within twenty-four hours after
the close of the hearing, the injunction shall be deemed dissolved.
Official Note
The three-day period is the maximum time. In particular cases a shorter period may be
required. The court is ‘‘always open for the transaction of judicial business.’’ See Section 324
of the Judicial Code, 42 Pa.C.S. § 324.
(2) When the defendant demands such a final hearing, no further pleadings shall be required
and Rule 1038(b) and (c) relating to decision in a trial without and Rules 227.1 to 227.3
relating to post-trial relief shall not apply.
(3) The trial judge shall file a written memorandum supporting the final order within five
days after it is filed.

To: Gusty Sunseri

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

To: Gusty Sunseri

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
231 Pa. Code § 1531
Current through Register Vol. 51, No. 7, February 13, 2021

Rule 1531 - Special Relief. Injunctions
(a) A court shall issue a preliminary or special injunction
only after written notice and hearing unless it appears to
the satisfaction of the court that immediate and
irreparable injury will be sustained before notice can be
given or a hearing held, in which case the court may
issue a preliminary or special injunction without a
hearing or without notice. In determining whether a
preliminary or special injunction should be granted and
whether notice or a hearing should be required, the
court may act on the basis of the averments of the
pleadings or petition and may consider affidavits of
parties or third persons or any other proof which the
court may require.
(b) Except when the plaintiff is the Commonwealth of
Pennsylvania, a political subdivision or a department,
board, commission, instrumentality or officer of the
Commonwealth or of a political subdivision, a
preliminary or special injunction shall be granted only if
(1) the plaintiff files a bond in an amount fixed and with
security approved by the court, naming the
Commonwealth as obligee, conditioned that if the
injunction is dissolved because improperly granted or
for failure to hold a hearing, the plaintiff shall pay to any
person injured all damages sustained by reason of
granting the injunction and all legally taxable costs and
fees, or
(2) the plaintiff deposits with the prothonotary legal

tender of the United States in an amount fixed by the
court to be held by the prothonotary upon the same
condition as provided for the injunction bond.
(c) Any party may move at any time to dissolve an

injunction.
(d) An injunction granted without notice to the defendant
shall be deemed dissolved unless a hearing on the
continuance of the injunction is held within five days
after the granting of the injunction or within such other
time as the parties may agree or as the court upon
cause shown shall direct.
(e) After a preliminary hearing, the court shall make an
order dissolving, continuing or modifying the injunction.
(f)
(1) When a preliminary or special injunction involving
freedom of expression is issued, either without notice or
after notice and hearing, the court shall hold a final
hearing within three days after demand by the
defendant. A final order shall be filed in the office of the
prothonotary within twenty-four hours after the close of
the hearing. If the final hearing is not held within the
three-day period, or if the final order is not filed within
twenty-four hours after the close of the hearing, the
injunction shall be deemed dissolved.
231 Pa. Code § 1531

To: Gusty Sunseri

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
your computer system. Please be advised that no privileges are waived by the transmission of this
message.

been mailed to the Defendant and the defendant is copied on this email. A courtesy copy is also
being provided to counsel for the estate who is also copied on this email as no appearance has
been entered yet in this case. Your attention to this matter is appreciated.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
Gusty,
ownership, it is well-settled that there is no jurisdiction for the Court to even entertain such an
injunctive action. Furthermore, would be a contested motion which required compliance with
motions court practice as to filing.
intensified, for possible damages related to the “BODs” year long failure to remedy the
leaking of the “electrical” vault into the basement which of course I am not even minimally
responsive for.

their offices right below me have no water leak, the first floor of the garage has no water leak.
This is abuse of process.
contested motion?

Four, I have zero interest in participating in a rigged proceeding. I would prefer to let them
go forward and issue the utterly baseless injunction for which this court has no jurisdiction and
the appeal?
Do you have electronic versions of the Rules of Procedure or local rules or anything at all that
I can rent from you? Do you have any forms that I can use as templates for the various types
complaint?
at this time.
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)

wrote:

in the place?

To: Gus Sunseri
Good. Thanks.
412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
No and no
Sent from my iPhone



412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

of this message.

contact me.

To: Gusty Sunseri


412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

of this message.

sunseri@verizon.net
GD 21-001293

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

Date: Monday, February 22, 2021 10:12:47 AM
Uta need to know he your exact position and terms on which you would allow an evaluation
of the condo.

To: Gus Sunseri
Subject: RE: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got this. How long
Thanks.

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.


Go to Civil
Sent from my iPhone
PS. Can you tell me how to access the court calendar? I want to know whether or not
Judge D. is set as motions court judge this week and next. I do not know how to access
the right calendar... thx
412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
recipient(s) and may contain confidential and privileged information. If you are not the
intended recipient, please do not read, distribute, or take action in reliance upon the
message. If you have received this message in error, please notify the sender

Gusty,
Did you notice that he is doing an end run around @ due process by filing
an equity special injunction which means that I get no due process
whatsoever? And that even a special injunction proceeding must be filed
with motions court not with the Judge of your choosing? Special
injunctive actions under 1531 are to preserve the status quo once
litigation has commenced. It is attached to a “heretofore” filed action.
And absent a lien or dispute as to ownership, it is well-settled that there is
no jurisdiction for the Court to even entertain such an injunctive action.
Furthermore, would be a contested motion which required compliance
Also, in case you didn’t notice he is not asking whether you will accept
service on the baseless injunction but rather he is trying to trick you or me
to waive service on the several pages of paper attached to the PI motion
loosely described a “Complaint” for some cause of action not intensified,
for possible damages related to the “BODs” year long failure to remedy
the leaking of the “electrical” vault into the basement which of course I
am not even minimally responsive for.
He also got someone to enter that baseless “complaint” which does not
even minimally satisfy either rule of court (no affidavit of service, no
cover, no damages, etc.) as if he filed a day before the injunctive motion.
And all of this is simply so that he get before the Judge he knows will find
for him and whom he obviously contacted directly as if there were an
existing litigation which there is not. And it evident from the fictitious
complaint that they are seeking damages. That is a contract based claim.
Furthermore, they are adding me personally as defendant no reason that
they identify in their complaint.

concerned that it is not you and Joe who are pointing this stuff out to me.
He is seeking the extraordinary remedy of ex parte injunctive relief for a

leak that by his count had been ongoing for two weeks (Feb. 1). Again,
four floors below me. I have no water leak, their offices right below me
have no water leak, the first floor of the garage has no water leak. This
is abuse of process.

seriously. Arthur Goldberg is dangerous to me and he is stalking me. And
I can prove that.

complaint?

messages almost every day. And I will never negotiate with a target of my
own investigations as if he had any illegitimacy whatsoever. And I just
don’t do dirty lawyers. I prosecute them. I have respect for the law that
these people get paid to circumvent and abuse.
Four, I have zero interest in participating in a rigged proceeding. I would

prefer to let them go forward and issue the utterly baseless injunction for
which this court has no jurisdiction and simply file an immediate appeal
and restraining order. What exactly are the steps for appealing a “special
injunction” issued in equity and what is the deadline? Who would hear
the appeal?
Gusty, if you were taking me or my situation seriously I just don’t think

your only response would be to treat this as a typical, non-problematic
proceeding when it is anything but that.
At this point, I would like to know the risks and benefits of the various
courses of action that I may take at this time? And I want to understand
step by step how I comply with rules of court, deadlines, and filing
requirements?

anything at all that I can rent from you? Do you have any forms that I can
use as templates for the various types of pleadings I have to make? I can
rent them.

circumstances and I should not be. And Gusty, why am I telling you all
this stuff. You are a trial lawyer in Pennsylvania and you must deal with
this stuff all the time.
Why am I telling you the difference between a regular injunction or one in

equity? Did you know before this email that he basically tried to trick
me/you into waving service for the complaint?
You must understand Motion Court practice so why aren’t you pissed off
that Jug is overtly circumventing mandatory motions practice. I should
have at least ten days notice. Even special injunctions have to be filed
with motion and have to comply with all pleading and certification
requirements which Jug’s does not and would not be accepted for
motions court at this time.
professional conduct regarding communications with a represented party
given the self-serving request for you to accept service or waive on my
behalf. Does any of this misconduct strike you as even remotely
offensive or concerning? I would really appreciate your thoughts on
this.
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the
intended recipient(s) and may contain confidential and privileged
received this message in error, please notify the sender immediately by
return e-mail and promptly delete this message and its attachments from
your computer system. Be advised that no privileges are waived by the


in the place?

To: Gus Sunseri
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)

distribute, or take action in reliance upon the message. If
you have received this message in error, please notify
the sender immediately by return e-mail and promptly
delete this message and its attachments from your
computer system. Be advised that no privileges are
On Feb 18, 2021, at 6:21 PM, Gus Sunseri

No and no
Sent from my iPhone
On Feb 18, 2021, at 6:14 PM,

Uta von Eckartsberg
wrote:

him?

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)


4:16 PM

contact me.

3:53 PM
To: Gusty Sunseri


412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)


law.com>
12:48 PM
To:
Civilgenmotions@alleghenycourts
.us
sunseri@verizon.net
GD 21-001293


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
immediately.
From: Gus Sunseri

Go to Civil
Sent from my iPhone

wrote:
PS. Can you tell me how to access the court calendar? I want to know whether or
not Judge D. is set as motions court judge this week and next. I do not know how
to access the right calendar... thx

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)

Gusty,
Did you notice that he is doing an end run around @ due process by
filing an equity special injunction which means that I get no due
process whatsoever? And that even a special injunction proceeding
must be filed with motions court not with the Judge of your
choosing? Special injunctive actions under 1531 are to preserve the
status quo once litigation has commenced. It is attached to a
“heretofore” filed action. And absent a lien or dispute as to
ownership, it is well-settled that there is no jurisdiction for the Court
to even entertain such an injunctive action. Furthermore, would be a
contested motion which required compliance with motions court
practice as to filing.
Also, in case you didn’t notice he is not asking whether you will
accept service on the baseless injunction but rather he is trying to
trick you or me to waive service on the several pages of paper
attached to the PI motion loosely described a “Complaint” for some
cause of action not intensified, for possible damages related to the
“BODs” year long failure to remedy the leaking of the “electrical”
vault into the basement which of course I am not even minimally
responsive for.
He also got someone to enter that baseless “complaint” which does
not even minimally satisfy either rule of court (no affidavit of service,
no cover, no damages, etc.) as if he filed a day before the injunctive
motion. And all of this is simply so that he get before the Judge he
knows will find for him and whom he obviously contacted directly as
if there were an existing litigation which there is not. And it evident
from the fictitious complaint that they are seeking damages. That is a
contract based claim. Furthermore, they are adding me personally as

concerned that it is not you and Joe who are pointing this stuff out to
me.
He is seeking the extraordinary remedy of ex parte injunctive relief

for a leak that by his count had been ongoing for two weeks (Feb. 1).
Again, four floors below me. I have no water leak, their offices
right below me have no water leak, the first floor of the garage has no
water leak. This is abuse of process.

seriously. Arthur Goldberg is dangerous to me and he is stalking me.
And I can prove that.

complaint?


By the way, Goldberg literally is stalking me. I get emails, letters,
phone messages almost every day. And I will never negotiate with a
target of my own investigations as if he had any illegitimacy
whatsoever. And I just don’t do dirty lawyers. I prosecute them. I
have respect for the law that these people get paid to circumvent and
abuse.
Four, I have zero interest in participating in a rigged proceeding. I

would prefer to let them go forward and issue the utterly baseless
injunction for which this court has no jurisdiction and simply file an
immediate appeal and restraining order. What exactly are the steps
for appealing a “special injunction” issued in equity and what is the
Gusty, if you were taking me or my situation seriously I just don’t

think your only response would be to treat this as a typical, non-
problematic proceeding when it is anything but that.
At this point, I would like to know the risks and benefits of the
various courses of action that I may take at this time? And I want to
understand step by step how I comply with rules of court, deadlines,
and filing requirements?
Do you have electronic versions of the Rules of Procedure or local

rules or anything at all that I can rent from you? Do you have any
forms that I can use as templates for the various types of pleadings I
have to make? I can rent them.

circumstances and I should not be. And Gusty, why am I telling you
all this stuff. You are a trial lawyer in Pennsylvania and you must
deal with this stuff all the time.
Why am I telling you the difference between a regular injunction or

one in equity? Did you know before this email that he basically tried
to trick me/you into waving service for the complaint?
You must understand Motion Court practice so why aren’t you pissed
off that Jug is overtly circumventing mandatory motions practice. I
should have at least ten days notice. Even special injunctions have to
be filed with motion and have to comply with all pleading and
certification requirements which Jug’s does not and would not be
professional conduct regarding communications with a represented
party given the self-serving request for you to accept service or waive
on my behalf. Does any of this misconduct strike you as even
remotely offensive or concerning? I would really appreciate your
thoughts on this.
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
On Feb 19, 2021, at 10:12 AM, Gusty A.E. Sunseri


in the place?

To: Gus Sunseri
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
by return e-mail and promptly delete this message and its
attachments from your computer system. Be advised that no

No and no
Sent from my iPhone
On Feb 18, 2021, at 6:14 PM, Uta von

Eckartsberg <uvoneck@outlook.com>
wrote:

him?
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)


4:16 PM

contact me.

3:53 PM
To: Gusty Sunseri


412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)


law.com>
12:48 PM
To:
Civilgenmotions@alleghenycourts.us
sunseri@verizon.net
GD 21-001293


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

immediately.
PS. Can you tell me how to access the court calendar? I want to know whether or not Judge
D. is set as motions court judge this week and next. I do not know how to access the right
calendar... thx

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)

wrote:
Gusty,
Did you notice that he is doing an end run around @ due process by filing an
equity special injunction which means that I get no due process whatsoever? And
that even a special injunction proceeding must be filed with motions court not
with the Judge of your choosing? Special injunctive actions under 1531 are to
preserve the status quo once litigation has commenced. It is attached to a
“heretofore” filed action. And absent a lien or dispute as to ownership, it is well-
settled that there is no jurisdiction for the Court to even entertain such an
injunctive action. Furthermore, would be a contested motion which required
compliance with motions court practice as to filing.
Also, in case you didn’t notice he is not asking whether you will accept service on
the baseless injunction but rather he is trying to trick you or me to waive service
on the several pages of paper attached to the PI motion loosely described a
“Complaint” for some cause of action not intensified, for possible damages
related to the “BODs” year long failure to remedy the leaking of the “electrical”
vault into the basement which of course I am not even minimally responsive for.
He also got someone to enter that baseless “complaint” which does not even
minimally satisfy either rule of court (no affidavit of service, no cover, no
damages, etc.) as if he filed a day before the injunctive motion. And all of this is
simply so that he get before the Judge he knows will find for him and whom he
obviously contacted directly as if there were an existing litigation which there is
not. And it evident from the fictitious complaint that they are seeking damages.
That is a contract based claim. Furthermore, they are adding me personally as
I have no practice experience in Allegheny Court whatsoever so I am concerned

that it is not you and Joe who are pointing this stuff out to me.
He is seeking the extraordinary remedy of ex parte injunctive relief for a leak that
by his count had been ongoing for two weeks (Feb. 1). Again, four floors below
me. I have no water leak, their offices right below me have no water leak, the
first floor of the garage has no water leak. This is abuse of process.
Furthermore, I gather that you are not taking my substantive concerns seriously.
Arthur Goldberg is dangerous to me and he is stalking me. And I can prove that.
At a bare minimum, can you demand he comply with regular motion practice and
file a contested motion?
messages almost every day. And I will never negotiate with a target of my own
investigations as if he had any illegitimacy whatsoever. And I just don’t do dirty
lawyers. I prosecute them. I have respect for the law that these people get paid to
circumvent and abuse.
Four, I have zero interest in participating in a rigged proceeding. I would prefer

to let them go forward and issue the utterly baseless injunction for which this
court has no jurisdiction and simply file an immediate appeal and restraining
order. What exactly are the steps for appealing a “special injunction” issued in
equity and what is the deadline? Who would hear the appeal?
Gusty, if you were taking me or my situation seriously I just don’t think your only
response would be to treat this as a typical, non-problematic proceeding when it is
anything but that.
At this point, I would like to know the risks and benefits of the various courses of
action that I may take at this time? And I want to understand step by step how I
comply with rules of court, deadlines, and filing requirements?

anything at all that I can rent from you? Do you have any forms that I can use as
templates for the various types of pleadings I have to make? I can rent them.
I do not want to be forced into Court prematurely under these circumstances and I
should not be. And Gusty, why am I telling you all this stuff. You are a trial
lawyer in Pennsylvania and you must deal with this stuff all the time.
Why am I telling you the difference between a regular injunction or one in equity?
Did you know before this email that he basically tried to trick me/you into
waving service for the complaint?
You must understand Motion Court practice so why aren’t you pissed off that Jug
is overtly circumventing mandatory motions practice. I should have at least ten
days notice. Even special injunctions have to be filed with motion and have to
comply with all pleading and certification requirements which Jug’s does not and
would not be accepted for motions court at this time.
And furthermore, jug and Goldberg also clearly violated the rules of professional
conduct regarding communications with a represented party given the self-serving
request for you to accept service or waive on my behalf. Does any of this
misconduct strike you as even remotely offensive or concerning? I would really
appreciate your thoughts on this.
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)


Uta Do you want me to handle this for the Estate? Can end up
costing the Estate $1500 to $1800 plus Jug’s attorney fees. We
definitely need to talk. Is there a leak in the place?

To: Gus Sunseri
Subject: Re: Imperial House Condominium v. Von Eckartsberg GD 21-
001293 I just got this. How long do I have to respond; This injunction is a
fraud on the Court.
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)

No and no
Sent from my iPhone



412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
DISCLAIMER: This e-mail message is

intended only for the personal use of the
recipient(s) named above. This message may
be an attorney-client communication and as
such privileged and confidential and/or it may
include attorney work product. If you are not
an intended recipient, you may not review,
copy or distribute this message. If you have
received this communication in error, please
notify us immediately by e-mail and delete the
original message and its attachments from
your computer system. Please be advised
that no privileges are waived by the

Subject: Re: Imperial House Condominium v.
Von Eckartsberg GD 21-001293 I just got this.
How long do I have to respond; This injunction
I did not accept service for you or the Estate.
I told him that I would have to speak with
you to see if I would be representing you in
this. Given the nature of the allegation-
potential continuing water damage-I would
suggest that you contact him. Or, if you
want me to represent you in this, I can
contact him. Feel free to contact me.

To: Gusty Sunseri
Subject: FW: Imperial House Condominium v.
How long do I have to respond; This injunction is
a fraud on the Court.
What is the procedure on this? I want to file a

motion for special injunction in response…..l;

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)


sunseri@verizon.net
Subject: Imperial House Condominium v. Von
Eckartsberg GD 21-001293
Please find attached an Emergency Motion
For Special Injunction and a Proposed
Order. The Proposed Order is provided in
word format pursuant to the Standard
Operating Procedures of the Court. The
Plaintiff would appreciate this matter now
be scheduled. The Motion has also been
mailed to the Defendant and the defendant is
copied on this email. A courtesy copy is also
being provided to counsel for the estate who
is also copied on this email as no appearance
has been entered yet in this case. Your
attention to this matter is appreciated.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

attachments transmitted with it contain
information that may be privileged and
confidential. The information is intended
for the use of the intended recipients only.
If you are not an intended recipient, note
that any disclosure, copying, distribution or
use of the contents of this message is
prohibited. If you have received this
message in error, please contact the above
immediately.
Uta I need to know if you want me to represent you in this. If so, we should probably do an
addendum to the engagement letter. Quite honestly, I do not see the harm in allowing them
limited access to the Condo to determine if origins of a leak are happening in that Condo. You
can save a ton of money with not paying me, or Jug’s potential attorney fees, by allowing me
to contact Jug and come to an agreement of giving them limited access ,for a limited time, to
determine the origin or lack of origin in that Condo of a leak. I need to know ASAP. Thanks We
need to talk.

Gusty,
Did you notice that he is doing an end run around @ due process by filing an equity special injunction which means
that I get no due process whatsoever? And that even a special injunction proceeding must be filed with motions
court not with the Judge of your choosing? Special injunctive actions under 1531 are to preserve the status quo
once litigation has commenced. It is attached to a “heretofore” filed action. And absent a lien or dispute as to
ownership, it is well-settled that there is no jurisdiction for the Court to even entertain such an injunctive action.
Furthermore, would be a contested motion which required compliance with motions court practice as to filing.
Also, in case you didn’t notice he is not asking whether you will accept service on the baseless injunction but rather
he is trying to trick you or me to waive service on the several pages of paper attached to the PI motion loosely
described a “Complaint” for some cause of action not intensified, for possible damages related to the “BODs” year
long failure to remedy the leaking of the “electrical” vault into the basement which of course I am not even
minimally responsive for.
He also got someone to enter that baseless “complaint” which does not even minimally satisfy either rule of court
(no affidavit of service, no cover, no damages, etc.) as if he filed a day before the injunctive motion. And all of this is
simply so that he get before the Judge he knows will find for him and whom he obviously contacted directly as if
there were an existing litigation which there is not. And it evident from the fictitious complaint that they are
seeking damages. That is a contract based claim. Furthermore, they are adding me personally as defendant no
reason that they identify in their complaint.
I have no practice experience in Allegheny Court whatsoever so I am concerned that it is not you and Joe who are
pointing this stuff out to me.
He is seeking the extraordinary remedy of ex parte injunctive relief for a leak that by his count had been ongoing for
two weeks (Feb. 1). Again, four floors below me. I have no water leak, their offices right below me have no water
leak, the first floor of the garage has no water leak. This is abuse of process.
Furthermore, I gather that you are not taking my substantive concerns seriously. Arthur Goldberg is dangerous to
me and he is stalking me. And I can prove that.
At a bare minimum, can you demand he comply with regular motion practice and file a contested motion?
By the way, Goldberg literally is stalking me. I get emails, letters, phone messages almost every day. And I will
never negotiate with a target of my own investigations as if he had any illegitimacy whatsoever. And I just don’t do
dirty lawyers. I prosecute them. I have respect for the law that these people get paid to circumvent and abuse.
Four, I have zero interest in participating in a rigged proceeding. I would prefer to let them go forward and issue
the utterly baseless injunction for which this court has no jurisdiction and simply file an immediate appeal and
restraining order. What exactly are the steps for appealing a “special injunction” issued in equity and what is the
Gusty, if you were taking me or my situation seriously I just don’t think your only response would be to treat this as
a typical, non-problematic proceeding when it is anything but that.
At this point, I would like to know the risks and benefits of the various courses of action that I may take at this time?
And I want to understand step by step how I comply with rules of court, deadlines, and filing requirements?
Do you have electronic versions of the Rules of Procedure or local rules or anything at all that I can rent from you?
Do you have any forms that I can use as templates for the various types of pleadings I have to make? I can rent
them.
I do not want to be forced into Court prematurely under these circumstances and I should not be. And Gusty, why
am I telling you all this stuff. You are a trial lawyer in Pennsylvania and you must deal with this stuff all the time.
Why am I telling you the difference between a regular injunction or one in equity? Did you know before this email
that he basically tried to trick me/you into waving service for the complaint?
You must understand Motion Court practice so why aren’t you pissed off that Jug is overtly circumventing
mandatory motions practice. I should have at least ten days notice. Even special injunctions have to be filed with
motion and have to comply with all pleading and certification requirements which Jug’s does not and would not be
And furthermore, jug and Goldberg also clearly violated the rules of professional conduct regarding communications
with a represented party given the self-serving request for you to accept service or waive on my behalf. Does any
of this misconduct strike you as even remotely offensive or concerning? I would really appreciate your thoughts on
this.
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
On Feb 19, 2021, at 10:12 AM, Gusty A.E. Sunseri <gusty-sunseri@verizon.net> wrote:

in the place?

To: Gus Sunseri
Good. Thanks.
412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
No and no
Sent from my iPhone



412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

of this message.

contact me.

To: Gusty Sunseri


412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

of this message.

sunseri@verizon.net
GD 21-001293

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

Date: Friday, February 19, 2021 10:12:01 AM
Uta Do you want me to handle this for the Estate? Can end up costing the Estate $1500 to
$1800 plus Jug’s attorney fees. We definitely need to talk. Is there a leak in the place?

To: Gus Sunseri
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
No and no
Sent from my iPhone


412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
DISCLAIMER: This e-mail message is intended only for the personal use
of the recipient(s) named above. This message may be an attorney-
client communication and as such privileged and confidential and/or it
may include attorney work product. If you are not an intended recipient,
you may not review, copy or distribute this message. If you have
received this communication in error, please notify us immediately by e-
mail and delete the original message and its attachments from your
computer system. Please be advised that no privileges are waived by
the transmission of this message.

fraud on the Court.
I did not accept service for you or the Estate. I told him that I would
have to speak with you to see if I would be representing you in this.
Given the nature of the allegation-potential continuing water
damage-I would suggest that you contact him. Or, if you want me to

To: Gusty Sunseri
Subject: FW: Imperial House Condominium v. Von Eckartsberg GD 21-
fraud on the Court.
What is the procedure on this? I want to file a motion for special


412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
sunseri@verizon.net
Please find attached an Emergency Motion For Special Injunction

and a Proposed Order. The Proposed Order is provided in word
format pursuant to the Standard Operating Procedures of the Court.
The Plaintiff would appreciate this matter now be scheduled. The
Motion has also been mailed to the Defendant and the defendant is
copied on this email. A courtesy copy is also being provided to
counsel for the estate who is also copied on this email as no
appearance has been entered yet in this case. Your attention to this

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
This electronic message and any attachments transmitted with it

contain information that may be privileged and confidential. The
information is intended for the use of the intended recipients only. If
you are not an intended recipient, note that any disclosure, copying,
distribution or use of the contents of this message is prohibited. If
you have received this message in error, please contact the above
sender and delete this message immediately.
To: Gus Sunseri
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
No and no
Sent from my iPhone



412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

fraud on the Court.

To: Gusty Sunseri
fraud on the Court.


412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

sunseri@verizon.net


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

To: Gus Sunseri
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
No and no
Sent from my iPhone



412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

fraud on the Court.

To: Gusty Sunseri
fraud on the Court.


412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

sunseri@verizon.net


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

PS. Can you tell me how to access the court calendar? I want to know whether or not Judge
D. is set as motions court judge this week and next. I do not know how to access the right
calendar... thx

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)

wrote:
Gusty,
Did you notice that he is doing an end run around @ due process by filing an
equity special injunction which means that I get no due process whatsoever? And
that even a special injunction proceeding must be filed with motions court not
with the Judge of your choosing? Special injunctive actions under 1531 are to
preserve the status quo once litigation has commenced. It is attached to a
“heretofore” filed action. And absent a lien or dispute as to ownership, it is well-
settled that there is no jurisdiction for the Court to even entertain such an
injunctive action. Furthermore, would be a contested motion which required
compliance with motions court practice as to filing.
Also, in case you didn’t notice he is not asking whether you will accept service on
the baseless injunction but rather he is trying to trick you or me to waive service
on the several pages of paper attached to the PI motion loosely described a
“Complaint” for some cause of action not intensified, for possible damages
related to the “BODs” year long failure to remedy the leaking of the “electrical”
vault into the basement which of course I am not even minimally responsive for.
He also got someone to enter that baseless “complaint” which does not even
minimally satisfy either rule of court (no affidavit of service, no cover, no
damages, etc.) as if he filed a day before the injunctive motion. And all of this is
simply so that he get before the Judge he knows will find for him and whom he
obviously contacted directly as if there were an existing litigation which there is
not. And it evident from the fictitious complaint that they are seeking damages.
That is a contract based claim. Furthermore, they are adding me personally as
I have no practice experience in Allegheny Court whatsoever so I am concerned

that it is not you and Joe who are pointing this stuff out to me.
He is seeking the extraordinary remedy of ex parte injunctive relief for a leak that
by his count had been ongoing for two weeks (Feb. 1). Again, four floors below
me. I have no water leak, their offices right below me have no water leak, the
first floor of the garage has no water leak. This is abuse of process.
Furthermore, I gather that you are not taking my substantive concerns seriously.
Arthur Goldberg is dangerous to me and he is stalking me. And I can prove that.
At a bare minimum, can you demand he comply with regular motion practice and
file a contested motion?
messages almost every day. And I will never negotiate with a target of my own
investigations as if he had any illegitimacy whatsoever. And I just don’t do dirty
lawyers. I prosecute them. I have respect for the law that these people get paid to
circumvent and abuse.
Four, I have zero interest in participating in a rigged proceeding. I would prefer

to let them go forward and issue the utterly baseless injunction for which this
court has no jurisdiction and simply file an immediate appeal and restraining
order. What exactly are the steps for appealing a “special injunction” issued in
equity and what is the deadline? Who would hear the appeal?
Gusty, if you were taking me or my situation seriously I just don’t think your only
response would be to treat this as a typical, non-problematic proceeding when it is
anything but that.
At this point, I would like to know the risks and benefits of the various courses of
action that I may take at this time? And I want to understand step by step how I
comply with rules of court, deadlines, and filing requirements?
anything at all that I can rent from you? Do you have any forms that I can use as
templates for the various types of pleadings I have to make? I can rent them.
I do not want to be forced into Court prematurely under these circumstances and I
should not be. And Gusty, why am I telling you all this stuff. You are a trial
lawyer in Pennsylvania and you must deal with this stuff all the time.
Why am I telling you the difference between a regular injunction or one in equity?
Did you know before this email that he basically tried to trick me/you into
waving service for the complaint?
You must understand Motion Court practice so why aren’t you pissed off that Jug
is overtly circumventing mandatory motions practice. I should have at least ten
days notice. Even special injunctions have to be filed with motion and have to
comply with all pleading and certification requirements which Jug’s does not and
would not be accepted for motions court at this time.
And furthermore, jug and Goldberg also clearly violated the rules of professional
conduct regarding communications with a represented party given the self-serving
request for you to accept service or waive on my behalf. Does any of this
misconduct strike you as even remotely offensive or concerning? I would really
appreciate your thoughts on this.
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)


Uta Do you want me to handle this for the Estate? Can end up
costing the Estate $1500 to $1800 plus Jug’s attorney fees. We
definitely need to talk. Is there a leak in the place?

To: Gus Sunseri
fraud on the Court.
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)

No and no
Sent from my iPhone



412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)


Subject: Re: Imperial House Condominium v.
How long do I have to respond; This injunction
I did not accept service for you or the Estate.
I told him that I would have to speak with
you to see if I would be representing you in
this. Given the nature of the allegation-
potential continuing water damage-I would
suggest that you contact him. Or, if you
want me to represent you in this, I can
contact him. Feel free to contact me.

To: Gusty Sunseri
Subject: FW: Imperial House Condominium v.
How long do I have to respond; This injunction is
a fraud on the Court.
What is the procedure on this? I want to file a

motion for special injunction in response…..l;

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)


sunseri@verizon.net
Subject: Imperial House Condominium v. Von
Eckartsberg GD 21-001293
Please find attached an Emergency Motion
For Special Injunction and a Proposed
Order. The Proposed Order is provided in
word format pursuant to the Standard
Operating Procedures of the Court. The
Plaintiff would appreciate this matter now
be scheduled. The Motion has also been
mailed to the Defendant and the defendant is
copied on this email. A courtesy copy is also
being provided to counsel for the estate who
is also copied on this email as no appearance
has been entered yet in this case. Your
attention to this matter is appreciated.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

attachments transmitted with it contain
information that may be privileged and
confidential. The information is intended
for the use of the intended recipients only.
If you are not an intended recipient, note
that any disclosure, copying, distribution or
use of the contents of this message is
prohibited. If you have received this
message in error, please contact the above
immediately.
To: Lockwood Joe
Cc: Sunseri Gusty
Subject: Re: Property Developments, Unit Property Act, and Uniform Condominium Act and historical records Deeds (Confidential Atty Client -Estate of EvE)
Date: Friday, January 8, 2021 2:41:49 AM
Attachments: 20201203_Allegheny county ;,Pennsylvania.pdf
Okay, so I just realized that I forget to mention the most important dox. It would be so helpful if you get at your earliest convenience is: Dox described in pic basically dbv 6134, p. 337 (amend Decl.); DB 6063, p. 123 (Code of Regulations): DB 6136 p 644.
Also, there are definitely coal, mineral and mining rights attached to this building which is built in a high-risk of subsistence to the extent I probably have to get insurance. The bad actors created documents/deed for those they victimized which do not comply with the notice
requirements of applicable statutes. The language below is most accurate version although it predates the notice statutes.
Gus, do you how to identify existing rights to the subservient estate? If so, whatever you to track down such info will be greatly appreciated.
Thanks!

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
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On Jan 8, 2021, at 2:02 AM, Uta von Eckartsberg <uvoneck@outlook.com> wrote:
Hey Joe — thank you so much! I still really need the dox referenced in the below photo as well as via the hyperlink. Also, I still to get whatever info I can regarding the Kenny Ross bankruptcy and receivership. A bank initiated the action in Allegheny county so
apparently everything was done at county level. I think the bankruptcy was filed in 1974 and was terminated in 1976.
Thanks again for all!!
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
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Date: December 29, 2020 at 4:27:00 PM EST

Do you have a tiff viewer? I need to obtain and view the tiff files at the following two Allegheny County property online search website. You can obviously charge the estate for the cost. I really need a copy of all recorded documents associated with these attached two
records. his is urgent. I assume you guys use this site. Thank you.
Hyperlink is as follows:
https://pa_allegheny.uslandrecords.com/palr/controller?
commandflag=getDetails&optflag=DetailsCommand&county=pa003&userid=null&userCategory=7&nameid=979387&ptrno=3554038&partytype=&name=IMPERIAL%2BASSOCIATES&officeid=55&fromdate=01/02/1987&todate=12/22/2020&lastname=IMPERIAL%20ASSOCIATES

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
recipient, you may not review, copy or distribute this message. If you have received this communication in error, please notify us immediately by e-mail and delete the original message and its attachments from your computer system. Please be advised that no privileges are
Uta,
I can obtain the documents set forth in Schedule B of the Title Insurance Policy tomorrow. I should be able to obtain the Preliminary Injunction and Brief shortly. I will also let you know regarding the status of the McLafferty holding.
Thank you,
Joe
To: "jlockwood@sunserilawfirm.com" <jlockwood@sunserilawfirm.com>
Cc: "Gus Sunseri" <gusty-sunseri@verizon.net>
Joe,
Due to technical and equipment limitations, I am very pressed for time Sorry for the delayed response. Attached are cases of material significance that back-up my representations to BOD. Also, I have followed the title chain on my mother's and see confirmation of my
conclusion that this BOD etc., at all relevant times have improperly charged certain unit owners for parking and other limited common elements. The title insurance page identifies material documents which I urgently need;' in particular the document relating to Duq. Light
Co. easement. I also need a copy of the PI Motion and supporting brief filed by DLC in the Longvue case attached. Can you help and how soon? I can speak briefly as necessary. Just let me know when. Please text me at 301.46.7445 with the proposed time. Thx! Also,
will you please check to make sure that McLafferty is still good law. No lexis or westlaw access sucks.
And, Gusty, if you are in this week please let me know if you are familiar with the Valley of Lakes case at your earliest convenience.
Thank you.
Uta
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
Sent: Monday, December 28, 2020 6:18 PM
Uta,
I will review everything. Let's plan on talking tomorrow afternoon. Is there a time that works best for you?
Thank you,
Joe
From: "Uta von Eckartsberg" <uvoneck@outlook.com<mailto:uvoneck@outlook.com>>
Sent: Monday, December 28, 2020 12:29pm
To: "jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com>" <jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com>>
Cc: "Gus Sunseri" <gusty-sunseri@verizon.net<mailto:gusty-sunseri@verizon.net>>
Thank you, Joe. Much appreciated. Hope you both a great holiday. As you may be able to tell from my recent emails, I have had better holidays. I need copies of the documents referenced or related to events described in the attached. I think what is attached is consistent
with what I am requesting from the BOD. My mother's chain of title never got to Rosenberg or any predecessor. This building was an apartment building so it was a conversion at some point although I don't know how relevant that is. For what its' worth I have checked
properties and there significant indica of straw purchasers beginning in around 1998 consistent with the cases I cited in my email to the BOD today. I'd like to know if Gus is familiar with the Valley of the Lakes civil rico case....
Feel free to call me at your convenience if you need me to walk you through the attached to ensure we are on the same page before you begin to track down the records.
Thanks!
Uta
412.207.7742(ph)
301.461.7445 (c)
724.631.5212 (fax)
From: jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com> <jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com>>
To: Uta von Eckartsberg <uvoneck@outlook.com<mailto:uvoneck@outlook.com>>
Uta,
As to a claimant forcing an accounting, a claimant can petition the Orphan's Court to force an accounting anytime after six months from the first full advertisement. In your case, that would be approximately mid-May.
-Joe
From: "Uta von Eckartsberg" <uvoneck@outlook.com<mailto:uvoneck@outlook.com<mailto:uvoneck@outlook.com%3cmailto:uvoneck@outlook.com>>>

To: "jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com><mailto:jlockwood@sunserilawfirm.com%3cmailto:jlockwood@sunserilawfirm.com%3e>"
<jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com%3cmailto:jlockwood@sunserilawfirm.com>>>
Cc: "Gusty A.E. Sunseri" <gusty-sunseri@verizon.net<mailto:gusty-sunseri@verizon.net<mailto:gusty-sunseri@verizon.net%3cmailto:gusty-sunseri@verizon.net>>>
Excellent!! Will get you the papers and info ASAP. Outstanding Q: "does your practice include issues arising under the above-described laws? If not, do you know anyone who does?"
Also, Gusty, no rush of course but just want to check whether the two brief memos I requested are still on your radar?
And, still waiting on answer to my previous query as to whether or SunTrust can force an accounting in connection with their claim as early as six-months after my mother's death....
Also, please let me know if either your or Gus are-of-pocket over the holiday (ie off for a week or whatever). I don't want to disturb anyone on vacation.
Thanks.
Uta
412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended recipient(s) and may contain confidential and privileged information. If you are not the intended recipient, please do not read, distribute, or take action in reliance upon the message. If you have
received this message in error, please notify the sender immediately by return e-mail and promptly delete this message and its attachments from your computer system. Be advised that no privileges are waived by the transmission of this message.
On Dec 22, 2020, at 3:21 PM, jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com<mailto:jlockwood@sunserilawfirm.com%3cmailto:jlockwood@sunserilawfirm.com>> wrote:
does your practice include issues arising under the above-described laws? If not, do you know anyone who does?
From: KAREN SUNSERI
Cc: gusty-sunseri
Subject: Re: Withdrawal Order and Final Invoice
Date: Thursday, November 4, 2021 11:32:29 AM
Attachments: von Eckartsberg Final Invoice 11-4-21.pdf
Dear Ms. von Eckartsberg:
Per Gus's request, I have removed all charges from August 2021 forward. You now have a
credit of $436.20. Please forward the mailing address where you wish to have the refund of
your retainer sent. Should I not hear from you in the next 10 days, I will send the refund check
to your last known address. Thank you.
From: KAREN SUNSERI

Sent: Thursday, November 4, 2021 11:04 AM
Cc: gusty-sunseri <gusty-sunseri@verizon.net>
Subject: Withdrawal Order and Final Invoice
Attached please find the Order dated November 4, 2021 withdrawing Gusty Sunseri, Esquire
and Gusty A. E. Sunseri & Associates, P. C. as counsel for the Estate of Elsa von Eckartsberg.
Also attached is your final invoice. Your balance due as of November 4, 2021 is $289.86.
Please contact our office promptly to make final payment. Thank you.
Karen Sunseri
412-968-0210
Cc: Sunseri Gusty
Subject: Re: easement and rights title insurance EvE 2007.pdf (Estate) (ACP)
Thanks. Appreciate it.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
On Jan 5, 2021, at 4:53 PM, jlockwood@sunserilawfirm.com wrote:
Uta,
I should have those documents for you tomorrow.
Thank you,
Joe
Sent: Tuesday, January 5, 2021 4:52pm
To: "Lockwood Joe" <jlockwood@sunserilawfirm.com>, "Sunseri Gusty"
<gusty-sunseri@verizon.net>
Subject: easement and rights title insurance EvE 2007.pdf (Estate) (ACP)
Joe, I don’t recall if I already requested the records referenced below. If not,
please get them for me. The “rights” granted to DLC are material importance in
the short term.
And Gus, in response to Q re: A utility easement running with owner not
land(gross I think the legal language was contained in a historical case per excerpt
below and then confirmed via some public info, representative examples below
for your convenience. The DLC easement if any is a gross easement and absent a
legal assignment sale to a legal successor in interest, there is none.
Thanks!!
Uta
von Eckartsberg, Esq
412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
To: Gus Sunseri
Subject: Re: von Eckartsberg Estate - Creditors Claim (Privileged Attorney Client Communication)
Date: Friday, November 20, 2020 4:59:44 PM
On second thought, no need to interrupt your weekend. Let’s talk Monday afternoon if that
works for you (unless you think it is urgent to speak tomorrow). At this point, I’m not
planning to make a prepayment after all. Thx.

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
On Nov 20, 2020, at 3:34 PM, Gus Sunseri <gusty-sunseri@verizon.net> wrote:
Uta. Not available until tomorrow. What time is good for you.
Sent from my iPhone
No problem
Sent from my iPhone
On Nov 19, 2020, at 1:57 PM, Uta von Eckartsberg

Gusty, I am running @ to medical appointments today. Just got

this. Not sure when I can talk before 5pm. At this point, I am not
sure if it even makes sense to make a prepayment. If you could
respond in writing to my Q about the timing of such payment (i.e.,
postmark or receipt by 23rd), I would be most grateful. I will try to
reach you appts but if we don’t connect hopefully you are available
tomorrow?
Thx

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
On Nov 19, 2020, at 8:37 AM, Gusty A.E. Sunseri <gusty-


Uta are you available around 1:00 today

Sent: Wednesday, November 18, 2020 3:57 PM
To: Gus Sunseri
Subject: Re: von Eckartsberg Estate - Creditors Claim (Privileged Attorney
Client Communication)
Gusty,
Am I correct that the due date for discount on taxes is Nov. 23 (my mother died Aug.
23). If so, does the check need to be in the hands of the applicable office on that
date or is it enough if the check is postmarked on or before Nov. 23?
And can you confirm whether or not the estimated tax payment appropriately
includes deductions in the calculation? Can my estimate include the calculation of
taxes owed after deductions as if I were filing the actual tax return at this time?
In this regard, absent a huge windfall my mother’s personal property is well-below
what I originally believed even though I do not have formal appraisals yet. For
purposes of this type of estimate, what is acceptable (i.e. 25K high?). What is a
typical, average estimate of value of personal property in this situation?
And lastly, even without inclusion of any of billing fees and administrator or lawyer,
my calculations indicate that the deductions might exceed the total tax per my
current estimate. Does that ever happen? Do people end up not paying inheritance
tax after all deductions?
Obviously, a lot can change over the next 9 mos but am trying to figure it out in the
short-term.
Gusty, I can talk this afternoon. Are you free?
Uta

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
Uta. Was out of State until tonight. What time can you talk tomorrow?
Sent from my iPhone
On Nov 16, 2020, at 6:55 PM, Gus Sunseri <gusty-

Joe are her dates correct.
Sent from my iPhone

PS Today while trying to research the creditor claim

issue, I saw that in order to obtain the 5% discount on
the inheritance tax, I only need to make a prepayment
of the estimated tax by check on or before Nov. 23,
2020 (versus filing an tax return). Is my current
understanding accurate?
Please let me know at your earliest convenience since I

seem to have found an accountant and I need to know
exactly what services I need in advance of the
upcoming 3 month deadline. He may need to connect
with you at some point — he is a huge Pitt football fan,
just FYI.
And do you have time to walk me through your

comments below today?
Thanks.

You have to walk me through this. I am have trouble

understanding each inserted reply. Can you talk
today?
Also, is the estate arguably insolvent? If so, I hope

there is not a problem with respect to legitimate debts
paid to date? Because we are funding the estate bank
account the whole thing is a bit confusing to me....
724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)

distribute, or take action in reliance upon the message.
If you have received this message in error, please
notify the sender immediately by return e-mail and
promptly delete this message and its attachments
from your computer system. Be advised that no
privileges are waived by the transmission of this
message.
On Nov 12, 2020, at 1:58 PM, Gusty A.E. Sunseri


What is the procedural status of such a
claim? NO DISTRIBUTION OF ASSETS
TO BENEFICIARIES SHOULD BE MADE
WITH AN OUTSTANDING CLAIM. WE
CAN DISPUTE THE CLAIM IF WE
BELIEVE IT IS NOT VALID. THE
ESTATE CAN NOT BE FINAL SETTLED
Is it equivalent to a civil complaint? KIND
OF- SEE BELOW At one point do they file
a civil complaint? NO DON’T HAVE TO.
SEE YOUR LIABILITY BELOW Are there
deadlines I need to be aware of? NO JUST
HAVE TO NOTIFY CREDITOR OF
FILING THE ESTATE ACCOUNT
In Pennsylvania, fiduciaries are not required

to send notice of
administration to the decedent’s creditors.
However, the personal
representative or the personal
representative’s counsel must publish
notice of the estate administration (see
Notice of Administration).
Creditors have one year from publication to
recover claims against
the personal representative. After the one-
year period, a creditor
can only recover from estate assets that
were not distributed before
receiving notice of the claim. (20 Pa. C.S. §
3532.)
Creditors have the option of filing a claim
against the estate with
the court. A creditor even may file a claim
against an estate before
a grant of letters. A claim is filed by
completing a claim form and
submitting it to the register (see
Pennsylvania Courts Orphans Court
Form OC-07). If a creditor files a claim with
the court, the creditor
preserves the creditor’s right to proceed
against a distributee
(recipient from the estate) of real property
if:
„„Real property is an estate asset.
„„The personal representative does not pay
the claim.
„„The creditor filed the claim within one
year of the decedent’s
death.
(20 Pa. C.S. § 3532(b) and see Distributee
Liability.)
However, except for liens existing at death,
claims against an estate
become unenforceable against a bona fide
purchaser of real property
that bought the property from the heirs or
beneficiaries more than:
One year after the death of the decedent if
no grant of letters is
in effect.
„„During the year following death if no grant
of letters has occurred.
(20 Pa. C.S. § 3385.)
If there is no real property in the estate or if
the creditor is not
otherwise concerned with preserving the
right to proceed against
distributees of real property, a creditor can
instead give written notice
of the creditor’s claim to the personal
representative or the personal
representative’s counsel before the statute
of limitations on the
creditor’s claim has expired, which is
sufficient notice to secure the
claim (20 Pa. C.S. § 3384).
If the creditor presents the claim to the
personal representative or
counsel for the personal representative, the
personal representative
can pay the creditor’s claim if the personal
representative determines
it is valid. If the creditor’s claim is not paid in
full and:
„„The personal representative files a formal
account, the court
assesses the claim during the estate audit
(see Notice to Creditors
of Account and Presentation of Claim at
Audit). In this case, before
audit, the personal representative must
serve the creditor with
notice of the audit and the creditor may
present the creditor’s
claim at audit (20 Pa. C.S. § 3384, 3386, and
3503).
„„The personal representative does not file
a formal account, the
creditor can pursue action directly against
distributees or the
personal representative, except that the
creditor cannot pursue
action directly against the distributee of real
property unless the
claim has been formally filed in the court (20
Pa. C.S. § 3532).
NOTICE TO CREDITORS OF ACCOUNT AND

PRESENTATION
OF CLAIM AT AUDIT
If the personal representative has not paid a
creditor’s claim, the
personal representative must notify the
creditor of the filing of the
estate account (Pa. O.C. Rule 2.5). If the
creditor receives notice of
the filing of the account, the creditor must
present the claim at the
call for audit or the claim may be rendered
unenforceable. Distant
creditors often choose not to present the
claim at audit, resulting in
dismissal of the claim and barring recovery
from the estate (20 Pa.
C.S. § 3386).
FIDUCIARY AT-RISK DISTRIBUTIONS
The personal representative is liable to
creditors for their claims
against the estate if the personal
representative makes distributions:
„„Within one year of advertisement of the
grant of letters.
„„Following receipt of the claim, even if one
year has passed.
(20 Pa. C.S. § 3532.) In either case, the
personal representative is
considered to have made at-risk
distributions.
Distributions made after the one-year
period after published notice
but before notice of the claim has been
received are not at-risk
DISTRIBUTEE LIABILITY
A distributee generally is not liable to the
creditors of the estate, even
for at-risk distributions (see Fiduciary At-Risk
Distributions). However:
„„A distributee of any estate asset other
than real property is liable
to a creditor when:
zzthe creditor presented a claim to the
personal representative
within one year of the advertisement of
letters;
zzthe personal representative did not pay
the claim; and
zzthe personal representative did not file a
formal account (20 Pa.
C.S. § 3532(b)(1)).
„„A distributee of real property is liable to a
creditor when the
creditor filed a claim with the orphans’ court
during the first year
of the estate administration (20 Pa. C.S. §
3532(b)(2), but see
Creditors and 20 Pa. C.S. § 3385).
distributions (20 Pa. C.S. § 3532).
CLASSIFICATION AND ORDER OF PAYMENT

If the estate is insufficient to pay all costs of
administration and
claims in full, the personal representative
must pay them in the
following order, pro rata, subject to any
preference given by law to
claims of the US:
„„Costs of administration (including counsel
fees).
„„The family exemption, which is payable to
the decedent’s spouse
or certain family members in the same
household of the decedent
(20 Pa. C.S. § 3121).
„„The costs of the decedent’s funeral and
burial and medicines
furnished six months before death, medical
and nursing services
performed within that time, hospital
services within that time,
services provided under a medical
assistance program within
that time, and services performed for the
decedent by any of the
decedent’s employees (see 20 Pa. C.S. §
3101).
„„Cost of a grave marker.
„„Rent for the decedent’s residence for the
six months before death.
„„Claims by the state of Pennsylvania.
„„All other claims.
(20 Pa. C.S. § 339
Also, when you attempted to contact these

folks were you able to even leave a message
or reach anyone at all? I assume you have a
phone log or something that we can cite in
the response.... Please advise as to next
steps from Probate perspective.
Thanks and hope all is well!

Sent: Thursday, November 12, 2020 1:28 PM
Subject: Re: von Eckartsberg Estate - Creditors
Claim (Privileged Attorney Client Communication)
Thank you. I have not yet had the time or ability

(computer and WiFi issues at 5600 and 1211 Ross
among many other estate-related issues) to deal with
this although I hope to do so within the week). What
is the procedural status of such a claim? Is it
equivalent to a civil complaint? At one point do they
file a civil complaint? Are there deadlines I need to be
aware of?
Also, when you attempted to contact these folks were

you able to even leave a message or reach anyone at
all? I assume you have a phone log or something that
we can cite in the response.... Please advise as to next
steps from Probate perspective.
Uta

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)

message.
On Nov 12, 2020, at 1:16 PM, Gusty A.E. Sunseri


Uta please see the attached claim.
From: KAREN SUNSERI

To: gusty-sunseri@verizon.net
Subject: von Eckartsberg Estate - Creditors Claim
Attached
Karen Sunseri
412-968-0210
To: Gus Sunseri
Date: Wednesday, November 18, 2020 3:57:17 PM
Gusty,
Am I correct that the due date for discount on taxes is Nov. 23 (my mother died Aug. 23). If
so, does the check need to be in the hands of the applicable office on that date or is it enough if
the check is postmarked on or before Nov. 23?
And can you confirm whether or not the estimated tax payment appropriately includes
deductions in the calculation? Can my estimate include the calculation of taxes owed after
deductions as if I were filing the actual tax return at this time?
In this regard, absent a huge windfall my mother’s personal property is well-below what I
originally believed even though I do not have formal appraisals yet. For purposes of this type
of estimate, what is acceptable (i.e. 25K high?). What is a typical, average estimate of value
of personal property in this situation?
And lastly, even without inclusion of any of billing fees and administrator or lawyer, my
calculations indicate that the deductions might exceed the total tax per my current estimate.
Does that ever happen? Do people end up not paying inheritance tax after all deductions?
Obviously, a lot can change over the next 9 mos but am trying to figure it out in the short-
term.
Uta

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
Uta. Was out of State until tonight. What time can you talk tomorrow?
Sent from my iPhone
Sent from my iPhone

PS Today while trying to research the creditor claim issue, I saw that
in order to obtain the 5% discount on the inheritance tax, I only need
to make a prepayment of the estimated tax by check on or before
Nov. 23, 2020 (versus filing an tax return). Is my current
understanding accurate?
Please let me know at your earliest convenience since I seem to have

found an accountant and I need to know exactly what services I need
in advance of the upcoming 3 month deadline. He may need to
connect with you at some point — he is a huge Pitt football fan, just
FYI.
And do you have time to walk me through your comments below

today?
Thanks.

You have to walk me through this. I am have trouble understanding

each inserted reply. Can you talk today?
Also, is the estate arguably insolvent? If so, I hope there is not a

problem with respect to legitimate debts paid to date? Because we
are funding the estate bank account the whole thing is a bit confusing
to me....

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
On Nov 12, 2020, at 1:58 PM, Gusty A.E. Sunseri <gusty-


What is the procedural status of such a claim? NO DISTRIBUTION
OF ASSETS TO BENEFICIARIES SHOULD BE MADE WITH AN
OUTSTANDING CLAIM. WE CAN DISPUTE THE CLAIM IF
WE BELIEVE IT IS NOT VALID. THE ESTATE CAN NOT BE
FINAL SETTLED Is it equivalent to a civil complaint? KIND OF-
SEE BELOW At one point do they file a civil complaint? NO
DON’T HAVE TO. SEE YOUR LIABILITY BELOW Are there
deadlines I need to be aware of? NO JUST HAVE TO NOTIFY
CREDITOR OF FILING THE ESTATE ACCOUNT
In Pennsylvania, fiduciaries are not required to send notice of

administration to the decedent’s creditors. However, the personal
representative or the personal representative’s counsel must publish
notice of the estate administration (see Notice of Administration).
Creditors have one year from publication to recover claims against
the personal representative. After the one-year period, a creditor
can only recover from estate assets that were not distributed before
receiving notice of the claim. (20 Pa. C.S. § 3532.)
Creditors have the option of filing a claim against the estate with
the court. A creditor even may file a claim against an estate before
a grant of letters. A claim is filed by completing a claim form and
submitting it to the register (see Pennsylvania Courts Orphans Court
Form OC-07). If a creditor files a claim with the court, the creditor
preserves the creditor’s right to proceed against a distributee
(recipient from the estate) of real property if:
„„The personal representative does not pay the claim.
„„The creditor filed the claim within one year of the decedent’s
death.
(20 Pa. C.S. § 3532(b) and see Distributee Liability.)
However, except for liens existing at death, claims against an estate
become unenforceable against a bona fide purchaser of real property
that bought the property from the heirs or beneficiaries more than:
One year after the death of the decedent if no grant of letters is
in effect.
„„During the year following death if no grant of letters has occurred.
(20 Pa. C.S. § 3385.)
If there is no real property in the estate or if the creditor is not
otherwise concerned with preserving the right to proceed against
distributees of real property, a creditor can instead give written
notice
of the creditor’s claim to the personal representative or the personal
representative’s counsel before the statute of limitations on the
creditor’s claim has expired, which is sufficient notice to secure the
claim (20 Pa. C.S. § 3384).
If the creditor presents the claim to the personal representative or
counsel for the personal representative, the personal representative
can pay the creditor’s claim if the personal representative determines
it is valid. If the creditor’s claim is not paid in full and:
„„The personal representative files a formal account, the court
assesses the claim during the estate audit (see Notice to Creditors
of Account and Presentation of Claim at Audit). In this case, before
audit, the personal representative must serve the creditor with
notice of the audit and the creditor may present the creditor’s
claim at audit (20 Pa. C.S. § 3384, 3386, and 3503).
„„The personal representative does not file a formal account, the
creditor can pursue action directly against distributees or the
personal representative, except that the creditor cannot pursue
action directly against the distributee of real property unless the
claim has been formally filed in the court (20 Pa. C.S. § 3532).
NOTICE TO CREDITORS OF ACCOUNT AND PRESENTATION

OF CLAIM AT AUDIT
If the personal representative has not paid a creditor’s claim, the
personal representative must notify the creditor of the filing of the
estate account (Pa. O.C. Rule 2.5). If the creditor receives notice of
the filing of the account, the creditor must present the claim at the
call for audit or the claim may be rendered unenforceable. Distant
creditors often choose not to present the claim at audit, resulting in
dismissal of the claim and barring recovery from the estate (20 Pa.
C.S. § 3386).
The personal representative is liable to creditors for their claims
against the estate if the personal representative makes distributions:
„„Within one year of advertisement of the grant of letters.
„„Following receipt of the claim, even if one year has passed.
(20 Pa. C.S. § 3532.) In either case, the personal representative is
considered to have made at-risk distributions.
Distributions made after the one-year period after published notice
but before notice of the claim has been received are not at-risk
A distributee generally is not liable to the creditors of the estate,
even
for at-risk distributions (see Fiduciary At-Risk Distributions). However:
„„A distributee of any estate asset other than real property is liable
to a creditor when:
zzthe creditor presented a claim to the personal representative
within one year of the advertisement of letters;
zzthe personal representative did not pay the claim; and
zzthe personal representative did not file a formal account (20 Pa.
C.S. § 3532(b)(1)).
„„A distributee of real property is liable to a creditor when the
creditor filed a claim with the orphans’ court during the first year
of the estate administration (20 Pa. C.S. § 3532(b)(2), but see

If the estate is insufficient to pay all costs of administration and
claims in full, the personal representative must pay them in the
following order, pro rata, subject to any preference given by law to
claims of the US:
„„Costs of administration (including counsel fees).
„„The family exemption, which is payable to the decedent’s spouse
or certain family members in the same household of the decedent
(20 Pa. C.S. § 3121).
„„The costs of the decedent’s funeral and burial and medicines
furnished six months before death, medical and nursing services
performed within that time, hospital services within that time,
services provided under a medical assistance program within
that time, and services performed for the decedent by any of the
decedent’s employees (see 20 Pa. C.S. § 3101).
„„Rent for the decedent’s residence for the six months before death.
(20 Pa. C.S. § 339
Also, when you attempted to contact these folks were you able to
even leave a message or reach anyone at all? I assume you have a
phone log or something that we can cite in the response.... Please
advise as to next steps from Probate perspective.

Thank you. I have not yet had the time or ability (computer and WiFi issues at 5600
and 1211 Ross among many other estate-related issues) to deal with this although I
hope to do so within the week). What is the procedural status of such a claim? Is it
equivalent to a civil complaint? At one point do they file a civil complaint? Are there
deadlines I need to be aware of?
Also, when you attempted to contact these folks were you able to even leave a
message or reach anyone at all? I assume you have a phone log or something that
we can cite in the response.... Please advise as to next steps from Probate
perspective.

Uta

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
On Nov 12, 2020, at 1:16 PM, Gusty A.E. Sunseri <gusty-sunseri@verizon.net> wrote:

From: KAREN SUNSERI

Attached
Karen Sunseri
412-968-0210
Date: Monday, November 16, 2020 2:50:53 PM
PS Today while trying to research the creditor claim issue, I saw that in order to obtain the 5%
discount on the inheritance tax, I only need to make a prepayment of the estimated tax by
check on or before Nov. 23, 2020 (versus filing an tax return). Is my current understanding
accurate?
Please let me know at your earliest convenience since I seem to have found an accountant and
I need to know exactly what services I need in advance of the upcoming 3 month deadline.
He may need to connect with you at some point — he is a huge Pitt football fan, just FYI.
And do you have time to walk me through your comments below today?
Thanks.
On Nov 12, 2020, at 4:21 PM, Uta von Eckartsberg <uvoneck@outlook.com> wrote:
You have to walk me through this. I am have trouble understanding each inserted reply. Can
you talk today?
Also, is the estate arguably insolvent? If so, I hope there is not a problem with respect to
legitimate debts paid to date? Because we are funding the estate bank account the whole
thing is a bit confusing to me....

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)

What is the procedural status of such a claim? NO DISTRIBUTION OF ASSETS TO
BENEFICIARIES SHOULD BE MADE WITH AN OUTSTANDING CLAIM. WE CAN
DISPUTE THE CLAIM IF WE BELIEVE IT IS NOT VALID. THE ESTATE CAN NOT BE
FINAL SETTLED Is it equivalent to a civil complaint? KIND OF- SEE BELOW At one
point do they file a civil complaint? NO DON’T HAVE TO. SEE YOUR LIABILITY
BELOW Are there deadlines I need to be aware of? NO JUST HAVE TO NOTIFY
CREDITOR OF FILING THE ESTATE ACCOUNT
In Pennsylvania, fiduciaries are not required to send notice of

administration to the decedent’s creditors. However, the personal
representative or the personal representative’s counsel must publish
notice of the estate administration (see Notice of Administration).
Creditors have one year from publication to recover claims against
the personal representative. After the one-year period, a creditor
can only recover from estate assets that were not distributed before
receiving notice of the claim. (20 Pa. C.S. § 3532.)
Creditors have the option of filing a claim against the estate with
the court. A creditor even may file a claim against an estate before
a grant of letters. A claim is filed by completing a claim form and
submitting it to the register (see Pennsylvania Courts Orphans Court
Form OC-07). If a creditor files a claim with the court, the creditor
preserves the creditor’s right to proceed against a distributee
(recipient from the estate) of real property if:
„„The personal representative does not pay the claim.
„„The creditor filed the claim within one year of the decedent’s
death.
(20 Pa. C.S. § 3532(b) and see Distributee Liability.)
However, except for liens existing at death, claims against an estate
become unenforceable against a bona fide purchaser of real property
that bought the property from the heirs or beneficiaries more than:
One year after the death of the decedent if no grant of letters is
in effect.
„„During the year following death if no grant of letters has occurred.
(20 Pa. C.S. § 3385.)
If there is no real property in the estate or if the creditor is not
otherwise concerned with preserving the right to proceed against
distributees of real property, a creditor can instead give written notice
of the creditor’s claim to the personal representative or the personal
representative’s counsel before the statute of limitations on the
creditor’s claim has expired, which is sufficient notice to secure the
claim (20 Pa. C.S. § 3384).
If the creditor presents the claim to the personal representative or
counsel for the personal representative, the personal representative
can pay the creditor’s claim if the personal representative determines
it is valid. If the creditor’s claim is not paid in full and:
„„The personal representative files a formal account, the court
assesses the claim during the estate audit (see Notice to Creditors
of Account and Presentation of Claim at Audit). In this case, before
audit, the personal representative must serve the creditor with
notice of the audit and the creditor may present the creditor’s
claim at audit (20 Pa. C.S. § 3384, 3386, and 3503).
„„The personal representative does not file a formal account, the
creditor can pursue action directly against distributees or the
personal representative, except that the creditor cannot pursue
action directly against the distributee of real property unless the
claim has been formally filed in the court (20 Pa. C.S. § 3532).
NOTICE TO CREDITORS OF ACCOUNT AND PRESENTATION

OF CLAIM AT AUDIT
If the personal representative has not paid a creditor’s claim, the
personal representative must notify the creditor of the filing of the
estate account (Pa. O.C. Rule 2.5). If the creditor receives notice of
the filing of the account, the creditor must present the claim at the
call for audit or the claim may be rendered unenforceable. Distant
creditors often choose not to present the claim at audit, resulting in
dismissal of the claim and barring recovery from the estate (20 Pa.
C.S. § 3386).
The personal representative is liable to creditors for their claims
against the estate if the personal representative makes distributions:
„„Within one year of advertisement of the grant of letters.
„„Following receipt of the claim, even if one year has passed.
(20 Pa. C.S. § 3532.) In either case, the personal representative is
considered to have made at-risk distributions.
Distributions made after the one-year period after published notice
but before notice of the claim has been received are not at-risk
A distributee generally is not liable to the creditors of the estate, even
for at-risk distributions (see Fiduciary At-Risk Distributions). However:
„„A distributee of any estate asset other than real property is liable
to a creditor when:
zzthe creditor presented a claim to the personal representative
within one year of the advertisement of letters;
zzthe personal representative did not pay the claim; and
zzthe personal representative did not file a formal account (20 Pa.
C.S. § 3532(b)(1)).
„„A distributee of real property is liable to a creditor when the
creditor filed a claim with the orphans’ court during the first year
of the estate administration (20 Pa. C.S. § 3532(b)(2), but see

If the estate is insufficient to pay all costs of administration and
claims in full, the personal representative must pay them in the
following order, pro rata, subject to any preference given by law to
claims of the US:
„„Costs of administration (including counsel fees).
„„The family exemption, which is payable to the decedent’s spouse
or certain family members in the same household of the decedent
(20 Pa. C.S. § 3121).
„„The costs of the decedent’s funeral and burial and medicines
furnished six months before death, medical and nursing services
performed within that time, hospital services within that time,
services provided under a medical assistance program within
that time, and services performed for the decedent by any of the
decedent’s employees (see 20 Pa. C.S. § 3101).
„„Rent for the decedent’s residence for the six months before death.
(20 Pa. C.S. § 339
Also, when you attempted to contact these folks were you able to even leave a message or
reach anyone at all? I assume you have a phone log or something that we can cite in the
response.... Please advise as to next steps from Probate perspective.

Thank you. I have not yet had the time or ability (computer and WiFi issues at 5600 and 1211 Ross among many
other estate-related issues) to deal with this although I hope to do so within the week). What is the procedural
status of such a claim? Is it equivalent to a civil complaint? At one point do they file a civil complaint? Are there
deadlines I need to be aware of?
Also, when you attempted to contact these folks were you able to even leave a message or reach anyone at all? I
assume you have a phone log or something that we can cite in the response.... Please advise as to next steps from
Probate perspective.
Uta

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)

From: KAREN SUNSERI

Attached
Karen Sunseri
412-968-0210
Date: Thursday, November 12, 2020 1:28:59 PM
Attachments: von Eckartsberg Creditor Claim11-4-20.pdf
Thank you. I have not yet had the time or ability (computer and WiFi issues at 5600 and
1211 Ross among many other estate-related issues) to deal with this although I hope to do so
within the week). What is the procedural status of such a claim? Is it equivalent to a civil
complaint? At one point do they file a civil complaint? Are there deadlines I need to be
aware of?
Also, when you attempted to contact these folks were you able to even leave a message or
reach anyone at all? I assume you have a phone log or something that we can cite in the
response.... Please advise as to next steps from Probate perspective.
Uta

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)

From: KAREN SUNSERI

Attached
Karen Sunseri
412-968-0210
From: Gus Sunseri
Date: Wednesday, December 9, 2020 7:35:40 PM
Also, I was not making a suggestion. I was doing nothing more than reporting facts to you.
Period
Sent from my iPhone
On Dec 9, 2020, at 7:33 PM, Gus Sunseri <gusty-sunseri@verizon.net> wrote:
U
ta. There is no “outcome” here. A creditor that filed a claim called to see if we
would consider a compromise. All I did was listen-without a commitment or
acknowledgement of the debt in any way. Again I listened and never engaged and
then reported to you. The Estate was not compromised by me listening in any
way, shape or form.
Sent from my iPhone
On Dec 9, 2020, at 6:52 PM, Uta von Eckartsberg

Gusty, I don’t understand the basis for this suggestion. You saw the
record. What they did including effectively exercising a acceleration
clause that does not exist and defaulting my mother after having
proof that I am the authorized agent of the estate, plus attempting
debits on a closed account after I withdrew authorization to auto-
debit the closed account. And apparently ignored and evaded your
attempts on behalf of the estate to call their “collections”. Plus
every communication to date has been a violation of the Fair Debt
Collection Act as well as PA’s equivalent law. At bare minimum,
we have a breach of contract counterclaim.
I am 100% swamped everyday by endless estate-related hassle that I

have to figure out how to address. I have not had time to deal with
Lightstream but I intend to. And I never answer any calls from them
because I want to deal with them in writing. Respectfully, if you
said anything as an admission of debt on behalf of the estate, that
might be binding on the estate.
You promised me you would have my back. Can you please draft a
short-memo describing your prior attempts to contact them and your
best recollection of your conversation today I including who, what,
where, when. I am an attorney and I have a lot experience on this
type of thing.
I appreciate you meant well but I just don’t understand how you
could have this conversation without talking to me first given the
background. I have no doubt that whatever you said was recorded
and can be used against the estate. We now have to write something
to correct whatever inference they got from your conversation.
Please tell me you did not say anything that can constitute an
admission against the estate.
And at what point exactly can Lightstream attempt to force an audit.

Is it six-months from my mother’s death? This estate has a very
strong counterclaim and/or complaint against all applicable parties.
I have to be prepared. On what date certain can they force an audit or
litigation or whatever? And was the individual you spoke to , Patti
Banks? Please memorialize the conversation as soon as possible.
I have multiple problems I am trying to wade through right now.

And I try to deal with most of it by myself to save legal fees. I have
a billion things that I would to pay you to assist me with with. Now
we have to pay for something that creates more problems, legal fees,
and puts me on a timeline out of control. I respect and appreciate
you deeply but I feel blindsided by this even though I understand that
this outcome was not intended and that you were trying to help.
If you want to call, fine. I never have time to talk to anyone but I
will try to make for you. I do need the memos I described. I am fine
with brevity and I formality but it must detail all material facts.
Please do not speak to any party regarding this bad faith claim
against the estate without speaking to me first.
Thank you for your kind attention to this matter.
Uta

412.683.1591 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
On Dec 9, 2020, at 6:19 PM, Gusty A.E. Sunseri <gusty-


Uta One of the creditors of your Mother’s Estate (Suntrust bank)
reached out to me to see if we would agree on a settlement. Their
claim is $20,074.04. They offered to settle for $16,900 if we could get
it done before the end of the year. I think I can get them lower. Let
me know.

Sent: Friday, November 20, 2020 4:59 PM
To: Gus Sunseri
On second thought, no need to interrupt your weekend. Let’s talk Monday

afternoon if that works for you (unless you think it is urgent to speak tomorrow). At
this point, I’m not planning to make a prepayment after all. Thx.

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
Uta. Not available until tomorrow. What time is good for you.
Sent from my iPhone

No problem
Sent from my iPhone

Gusty, I am running @ to medical appointments

today. Just got this. Not sure when I can talk before
5pm. At this point, I am not sure if it even makes
sense to make a prepayment. If you could respond
in writing to my Q about the timing of such payment
(i.e., postmark or receipt by 23rd), I would be most
grateful. I will try to reach you appts but if we don’t
connect hopefully you are available tomorrow?
Thx

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)

message.
On Nov 19, 2020, at 8:37 AM, Gusty A.E. Sunseri

Uta are you available around 1:00 today

Sent: Wednesday, November 18, 2020 3:57 PM
To: Gus Sunseri
Subject: Re: von Eckartsberg Estate - Creditors
Claim (Privileged Attorney Client Communication)
Gusty,
Am I correct that the due date for discount on taxes is

Nov. 23 (my mother died Aug. 23). If so, does the
check need to be in the hands of the applicable office
on that date or is it enough if the check is postmarked
on or before Nov. 23?
And can you confirm whether or not the estimated tax

payment appropriately includes deductions in the
calculation? Can my estimate include the calculation
of taxes owed after deductions as if I were filing the
actual tax return at this time?
In this regard, absent a huge windfall my mother’s

personal property is well-below what I originally
believed even though I do not have formal appraisals
yet. For purposes of this type of estimate, what is
acceptable (i.e. 25K high?). What is a typical, average
estimate of value of personal property in this
situation?
And lastly, even without inclusion of any of billing fees

and administrator or lawyer, my calculations indicate
that the deductions might exceed the total tax per my
current estimate. Does that ever happen? Do people
end up not paying inheritance tax after all deductions?
Obviously, a lot can change over the next 9 mos but

am trying to figure it out in the short-term.
Uta
724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)

message.

Uta. Was out of State until tonight. What time can you
talk tomorrow?
Sent from my iPhone
On Nov 16, 2020, at 6:55 PM, Gus

Sunseri <gusty-sunseri@verizon.net>
wrote:
Sent from my iPhone
On Nov 16, 2020, at

2:50 PM, Uta von
Eckartsberg
wrote:
PS Today while trying

to research the creditor
claim issue, I saw that in
order to obtain the 5%
discount on the
inheritance tax, I only
need to make a
prepayment of the
estimated tax by check
on or before Nov. 23,
2020 (versus filing an
tax return). Is my
current understanding
accurate?
Please let me know at

your earliest
convenience since I
seem to have found an
accountant and I need
to know exactly what
services I need in
advance of the
upcoming 3 month
deadline. He may need
to connect with you at
some point — he is a
huge Pitt football fan,
just FYI.
And do you have time

to walk me through
your comments below
today?
Thanks.
On Nov 12, 2020, at

4:21 PM, Uta von
Eckartsberg
wrote:
You have to walk me

through this. I am have
trouble understanding
each inserted reply.
Can you talk today?
Also, is the estate
arguably insolvent? If
so, I hope there is not a
problem with respect to
legitimate debts paid to
date? Because we are
funding the estate bank
account the whole thing
is a bit confusing to
me....
Uta von Eckartsberg,

Esq.
724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
This email message (and

any attachments) is for
the exclusive use of the
intended recipient(s)
and may contain
confidential and
privileged information.
If you are not the
intended recipient,
please do not read,
distribute, or take
action in reliance upon
the message. If you
have received this
message in error, please
notify the sender
immediately by return
e-mail and promptly
delete this message and
its attachments from
your computer system.
Be advised that no
privileges are waived by
the transmission of this
message.
On Nov 12, 2020, at
1:58 PM, Gusty A.E.
Sunseri <gusty-
wrote:

What is the
procedural status of
such a claim? NO
DISTRIBUTION
OF ASSETS TO
BENEFICIARIES
SHOULD BE
MADE WITH AN
OUTSTANDING
CLAIM. WE CAN
DISPUTE THE
CLAIM IF WE
BELIEVE IT IS
NOT VALID.
THE ESTATE
CAN NOT BE
FINAL SETTLED
Is it equivalent to a
civil complaint?
KIND OF- SEE
BELOW At one
point do they file a
civil complaint?
NO DON’T
HAVE TO. SEE
YOUR
LIABILITY
BELOW Are there
deadlines I need to
be aware of? NO
JUST HAVE TO
NOTIFY
CREDITOR OF
FILING THE
ESTATE
ACCOUNT
In Pennsylvania,
fiduciaries are not
required to send
notice of
administration to
the decedent’s
creditors. However,
the personal
representative or
the personal
representative’s
counsel must
publish
notice of the estate
administration (see
Notice of
Administration).
Creditors have one
year from
publication to
recover claims
against
the personal
representative.
After the one-year
period, a creditor
can only recover
from estate assets
that were not
distributed before
receiving notice of
the claim. (20 Pa.
C.S. § 3532.)
Creditors have the
option of filing a
claim against the
estate with
the court. A
creditor even may
file a claim against
an estate before
a grant of letters. A
claim is filed by
completing a claim
form and
submitting it to the
register (see
Pennsylvania
Courts Orphans
Court
Form OC-07). If a
creditor files a
claim with the
court, the creditor
preserves the
creditor’s right to
proceed against a
distributee
(recipient from the
estate) of real
property if:
„„Real property is
an estate asset.
„„The personal
representative
does not pay the
claim.
„„The creditor filed
the claim within
one year of the
decedent’s
death.
(20 Pa. C.S. §
3532(b) and see
Distributee
Liability.)
However, except
for liens existing at
death, claims
against an estate
become
unenforceable
against a bona fide
purchaser of real
property
that bought the
property from the
heirs or
beneficiaries more
than:
One year after the
death of the
decedent if no
grant of letters is
in effect.
„„During the year
following death if
no grant of letters
has occurred.
(20 Pa. C.S. § 3385.)
If there is no real
property in the
estate or if the
creditor is not
otherwise
concerned with
preserving the right
to proceed against
distributees of real
property, a creditor
can instead give
written notice
of the creditor’s
claim to the
personal
representative or
the personal
representative’s
counsel before the
statute of
limitations on the
creditor’s claim has
expired, which is
sufficient notice to
secure the
claim (20 Pa. C.S. §
3384).
If the creditor
presents the claim
to the personal
representative or
counsel for the
personal
representative, the
personal
representative
can pay the
creditor’s claim if
the personal
representative
determines
it is valid. If the
creditor’s claim is
not paid in full and:
„„The personal
representative files
a formal account,
the court
assesses the claim
during the estate
audit (see Notice to
Creditors
of Account and
Presentation of
Claim at Audit). In
this case, before
audit, the personal
representative
must serve the
creditor with
notice of the audit
and the creditor
may present the
creditor’s
claim at audit (20
Pa. C.S. § 3384,
3386, and 3503).
„„The personal
representative
does not file a
formal account, the
creditor can pursue
action directly
against distributees
or the
personal
representative,
except that the
creditor cannot
pursue
action directly
against the
distributee of real
property unless the
claim has been
formally filed in the
court (20 Pa. C.S. §
3532).
NOTICE TO
CREDITORS OF
ACCOUNT AND
PRESENTATION
OF CLAIM AT AUDIT
If the personal
representative has
not paid a
creditor’s claim, the
personal
representative
must notify the
creditor of the filing
of the
estate account (Pa.
O.C. Rule 2.5). If
the creditor
receives notice of
the filing of the
account, the
creditor must
present the claim
at the
call for audit or the
claim may be
rendered
unenforceable.
Distant
creditors often
choose not to
present the claim
at audit, resulting
in
dismissal of the
claim and barring
recovery from the
estate (20 Pa.
C.S. § 3386).
FIDUCIARY AT-RISK
DISTRIBUTIONS
The personal
representative is
liable to creditors
for their claims
against the estate if
the personal
representative
makes
distributions:
„„Within one year
of advertisement of
the grant of letters.
„„Following receipt
of the claim, even if
one year has
passed.
(20 Pa. C.S. § 3532.)
In either case, the
personal
representative is
considered to have
made at-risk
distributions.
Distributions made
after the one-year
period after
published notice
but before notice
of the claim has
been received are
not at-risk
DISTRIBUTEE
LIABILITY
A distributee
generally is not
liable to the
creditors of the
estate, even
for at-risk
distributions (see
Fiduciary At-Risk
Distributions).
However:
„„A distributee of
any estate asset
other than real
property is liable
to a creditor when:
zzthe creditor
presented a claim
to the personal
representative
within one year of
the advertisement
of letters;
zzthe personal
representative did
not pay the claim;
and
zzthe personal
representative did
not file a formal
account (20 Pa.
C.S. § 3532(b)(1)).
„„A distributee of
real property is
liable to a creditor
when the
creditor filed a
claim with the
orphans’ court
during the first year
of the estate
administration (20
Pa. C.S. § 3532(b)
(2), but see
Creditors and 20
Pa. C.S. § 3385).
distributions (20
Pa. C.S. § 3532).
CLASSIFICATION
AND ORDER OF
PAYMENT
If the estate is
insufficient to pay
all costs of
administration and
claims in full, the
personal
representative
must pay them in
the
following order, pro
rata, subject to any
preference given by
law to
claims of the US:
„„Costs of
administration
(including counsel
fees).
„„The family
exemption, which is
payable to the
decedent’s spouse
or certain family
members in the
same household of
the decedent
(20 Pa. C.S. § 3121).
„„The costs of the
decedent’s funeral
and burial and
medicines
furnished six
months before
death, medical and
nursing services
performed within
that time, hospital
services within that
time,
services provided
under a medical
assistance program
within
that time, and
services performed
for the decedent by
any of the
decedent’s
employees (see 20
Pa. C.S. § 3101).
„„Cost of a grave
marker.
„„Rent for the
decedent’s
residence for the
six months before
death.
„„Claims by the
state of
Pennsylvania.
(20 Pa. C.S. § 339
Also, when you

attempted to
contact these folks
were you able to
even leave a
message or reach
anyone at all? I
assume you have a
phone log or
something that we
can cite in the
response.... Please
advise as to next
steps from Probate
perspective.
Thanks and hope

all is well!
From: Uta von

Eckartsberg
Sent: Thursday,
November 12, 2020
1:28 PM
To: Gusty A.E.
Sunseri
Subject: Re: von
Eckartsberg Estate -
Creditors Claim
(Privileged Attorney
Client
Communication)
Thank you. I have not

yet had the time or
ability (computer and
WiFi issues at 5600 and
1211 Ross among many
other estate-related
issues) to deal with this
although I hope to do so
within the week). What
is the procedural status
of such a claim? Is it
equivalent to a civil
complaint? At one
point do they file a civil
complaint? Are there
deadlines I need to be
aware of?
Also, when you

attempted to contact
these folks were you
able to even leave a
message or reach
anyone at all? I assume
you have a phone log or
something that we can
cite in the response....
Please advise as to next
steps from Probate
perspective.
Thanks and hope all is

well!
Uta
Uta von Eckartsberg,

Esq.
724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
This email message (and

any attachments) is for
the exclusive use of the
intended recipient(s)
and may contain
confidential and
privileged information.
If you are not the
intended recipient,
please do not read,
distribute, or take
action in reliance upon
the message. If you
have received this
message in error, please
notify the sender
immediately by return
e-mail and promptly
delete this message and
its attachments from
your computer system.
Be advised that no
privileges are waived by
the transmission of this
message.
On Nov 12, 2020, at

1:16 PM, Gusty A.E.
Sunseri <gusty-
wrote:

Uta please see the
attached claim.
From: KAREN SUNSERI

Sent: Thursday,
November 12, 2020
11:28 AM
To: gusty-
sunseri@verizon.net
Subject: von
Eckartsberg Estate -
Creditors Claim
Attached
Karen Sunseri
Gusty A. E. Sunseri &
Associates, P. C.
412-968-0210
Subject: Truist to Gusty
Date: Thursday, April 15, 2021 11:39:30 PM
Attachments: 2021.02.18 UvE to Gusty see response in conduct . E-mail gusty re criminal coconspirator with attachments
ignored. See attachments GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg -
ACP.pdf

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
From: Uta Von eckartsberg
Bcc: uvoneck@icloud.com
Subject: Uta von Eckartsberg (UvE) has shared a file with you using Dropbox
Date: Monday, September 7, 2020 3:55:20 PM
Attachments: retention agmt research templates.pdf
Hi,
Here’s a link to “retention agmt research templates.pdf” in my Dropbox:
https://www.dropbox.com/s/dmcph0s3feapdcq/retention%20agmt%20research%20templates.pdf?
dl=0
<retention agmt research templates.pdf>

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
this message in error, please notify the sender immediately by return e-mail and promptly delete
this message and its attachments from your computer system. Be advised that no privileges are

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
From: Uta Von eckartsberg
Subject: Uta von Eckartsberg (UvE) has shared a file with you using Dropbox
Date: Monday, September 7, 2020 3:57:01 PM
Attachments: retention agmt research templates.pdf
Hi,
Here’s a link to “retention agmt research templates.pdf” in my Dropbox:
https://www.dropbox.com/s/dmcph0s3feapdcq/retention%20agmt%20research%20templates.pdf?
dl=0
<retention agmt research templates.pdf>

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)

724.763.8885 (h)
301.461.7445 (c)
724.631.5212 (fax)
From: KAREN SUNSERI
Cc: gusty-sunseri
Subject: Withdrawal Order and Final Invoice
Date: Thursday, November 4, 2021 11:05:06 AM
Attachments: von Eckartsberg - Withdrawal Order and Final Invoice.pdf
Attached please find the Order dated November 4, 2021 withdrawing Gusty Sunseri, Esquire
and Gusty A. E. Sunseri & Associates, P. C. as counsel for the Estate of Elsa von Eckartsberg.
Also attached is your final invoice. Your balance due as of November 4, 2021 is $289.86.
Please contact our office promptly to make final payment. Thank you.
Karen Sunseri
412-968-0210
To: Lockwood Joe; Sunseri Gusty
Subject: easement and rights title insurance EvE 2007.pdf (Estate) (ACP)
Attachments: easement and rights title insurance EvE 2007.pdf
image11.png
Joe, I don’t recall if I already requested the records referenced below. If not, please get them
for me. The “rights” granted to DLC are material importance in the short term.
And Gus, in response to Q re: A utility easement running with owner not land(gross I think the
legal language was contained in a historical case per excerpt below and then confirmed via
some public info, representative examples below for your convenience. The DLC easement if
any is a gross easement and absent a legal assignment sale to a legal successor in interest,
there is none.
Thanks!!
Uta
von Eckartsberg, Esq
412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
Subject: just fyi, you have to zoom in to see the titles of the evidentiary folders I sent you. Thx ACP

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.
Subject: just fyi, you have to zoom in to see the titles of the evidentiary folders I sent you. Thx ACP

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

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From: KAREN SUNSERI

To: Uta von Eckartsberg; uvoneck@icloud.com; fjug@bmr-law.com

Please Note the Following:

Joseph A. Lockwood III, Esq.

Gusty A.E. Sunseri & Associates, P.C.

Joseph A. Lockwood III, Esq.

Gusty A.E. Sunseri & Associates, P.C.

Uta von Eckartsberg, Esq.

Uta von Eckartsberg, Esq.

Uta von Eckartsberg, Esq.

From: Gusty A.E. Sunseri <gusty-sunseri@verizon.net>

Uta I just received this scheduling order. See below.

From: Law Linda

From: Gus Sunseri <gusty-sunseri@verizon.net>

When would you be available to talk

Sent from my iPhone

Uta von Eckartsberg, Esq.

From: Gusty A.E. Sunseri <gusty-sunseri@verizon.net>

Uta I just received this scheduling order. See below.

From: Law Linda

Uta von Eckartsberg, Esq.

From: Fred C Jug <fjug@bmr-law.com>

Fred C. Jug, Jr. Attorney

Uta von Eckartsberg, Esq.

From: Fred C Jug <fjug@bmr-law.com>

Fred C. Jug, Jr. Attorney

Please Note the Following:

Counsel for the Petitioner is responsible for disseminating this invitation to

Uta I just received this scheduling order. See below.

From: Law Linda

Uta please see the email below.

From: Fred C Jug

Fred C. Jug, Jr. Attorney

From: Norman Stankewicz <i.housecondo@att.net>

Good morning Ms. Von Eckartsberg

Thank you for your prompt attention to this matter

Sent from my iPhone

From: Gusty A.E. Sunseri

From: Fred C Jug

Fred C. Jug, Jr. Attorney

Uta Please see the attached. The same was mailed.

Scan attached for emails

Uta von Eckartsberg, Esq.

From: Uta von Eckartsberg <uvoneck@outlook.com>

﻿ Thanks so much. Appreciate your help.

Uta von Eckartsberg, Esq.

On Feb 22, 2021, at 6:40 PM, jlockwood@sunserilawfirm.com

Please see the attached correspondence from Attorney Sunseri

Gusty A.E. Sunseri & Associates, P.C.

Uta von Eckartsberg, Esq.

Begin forwarded message:

From: Gus Sunseri <gusty-sunseri@verizon.net>

﻿ Go to Fifth Judicial District of Pennsylvania

Sent from my iPhone

On Feb 19, 2021, at 4:25 PM, Uta von Eckartsberg <uvoneck@outlook.com>

Uta von Eckartsberg, Esq.

On Feb 19, 2021, at 3:49 PM, Uta von Eckartsberg

I have no practice experience in Allegheny Court whatsoever so I am

He is seeking the extraordinary remedy of ex parte injunctive relief

Furthermore, I gather that you are not taking my substantive concerns

At a bare minimum, can you demand he comply with regular motion

Three, what are the consequences of my not waiving service?

By the way, Goldberg literally is stalking me. I get emails, letters,

Four, I have zero interest in participating in a rigged proceeding. I

Thanks so much. Appreciate your help.

Go to Fifth Judicial District of Pennsylvania