IN THE SUPERIOR COURT OF PENNSYLVANIA

Commonwealth of Pennsylvania

Appellant
v.
Kathleen Granahan Kane

PROOF OF SERVICE
1164 EDA 2016

- DRAFT
áUR x:

HAY
a,. t
X5 ?016

EASTERN DISTRICT

I hereby certify that this 2nd day of May, 2016, I have served the attached document(s) to the persons on the date(¡) and

in the manner(s) stated below, which service satisfies the requirements of Pa.R.A.P. 121:

Service

Served: Amil Michael Minora

Service Method: Email
Email: amil.minora @gmail.com
Service Date: 5/2/2016
Address:
Phone: 570 -961 -1616
Representing: Appellant Kathleen Granahan Kane

Served: Amil Michael Minora

Service Method: eService
Email: amil.minora @gmail.com
Service Date:
Address: 700 Vine Street
Scranton, PA 18510
Phone: 570 --96 -1 -1616
Representing: Appellant Kathleen Granahan Kane

Served: Assistant Counsel Seth C. Farber

Service Method: Email
Email: sfarber @winston.com
Service Date: 5/2/2016
Address:
Phone: 212- 294 -6700
Representing: Appellant Kathleen Granahan Kane

PACFile 1001 Page 1 of 3 Print Date: 5/2/2016 11:33 am

 IN THE SUPERIOR COURT OF PENNSYLVANIA

PROOF OF SERVICE - DRAFT

(Continued)

Served: Gerald L. Shargel

Service Method: Email
Email: sfarber @winston.com
Service Date: 5/2/2016
Address:
Phone: 212- 294 -2637
Representing: Appellant Kathleen Granahan Kane

Served: Kevin R. Steele

Service Method: Email
Email: ksteele @montcopa.org
Service Date: 5/2/2016
Address:
Phone: 610-278 -3098
Representing: Appellee Commonwealth of Pennsylvania

Served: Robert Martin Falin

Service Method: Email
Email: rfalin @montcopa.org
Service Date: 5/2/2016
Address:
Phone: 610- 278 -3102
Representing: Appellee Commonwealth of Pennsylvania

Served: Robert Martin Falin

Service Method: eService
Email: rfalin @montcopa.org
Service Date:
Address: Montgomery County Courthouse
P.O. Box 311
Norristown, PA 19404 -0311
Phone: 610- 278 -3104
Representing: Appellee Commonwealth of Pennsylvania

Served: Ross Mitchell Kramer

Service Method: Email
Email: sfarber @winston.com
Service Date: 5/2/2016
Address:
Phone: --
Representing: Appellant Kathleen Granahan Kane

PACFile 1001 Page 2 of 3 Print Date: 5/2/2016 11 :33 am

 IN THE SUPERIOR COURT OF PENNSYLVANIA

PROOF OF SERVICE - DRAFT

(Continued)

Courtesy Copy

Served: Stan J. Caterbone

Service Method: Email
Email: stancaterbone @gmail.com
Service Date: 5/2/2016
Address:
Phone: 717 -669 -2163
Pro Se: Amicus Stan J. Caterbone

(Signatur :: of Person Serving)

Person Serving:
Attorney Registration No:
Law Firm:
Address:

PACFile 1001 Page 3 of 3 Print Date: 5/2/2016 11133 am

 : o

Report Date: 05/02/2016 Submission Status: Not Submitted

Filing Package
Tracking Number: WSPRED00082210 Filing Type: Ancillary
Description: Superior Court of Pennsylvania Case No. ED Total Fees Due:

Pre -Submission Status

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Case Information
Intermediate Court Cases
Docket Number: 1164 EDA 2016 (Lead) Case Caption: Com. v. Kane, K.
Case Status: Active Event Track: Appeal Program Status:

Filers
Filer Name: IFP Status:
Role: Counsel:
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Filing Name: Amicus Curiae Brief Required: Yes Filing Fee: $0.00
Document Name: Amicus Curiae Brief.pdf Upload Date/Time: 5/2/2016 11:19AM

PACFile 2100 1 Printed: 5/2/2016 11:32:11 AM

 Stanley J. Caterbone, Pro Se
Freedom From Covert Harassment and Surveillance, Registered in the State of Pennsylvania
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603

IN THE SUPERIOR COURT OF PENNSYLVANIA

EASTERN DISTRICT

IN RE: Case NO. 1164 EDA 2016

Montgomery Courte Case No.

Docket No. 8423 -15:
COMMONWEALTH OF PENNSYLVANIA :

v.
KATHLEEN KANE

AMICUS CURIAE IN SUPPORT OF KATHLEEN KANE'S (ATTORNEY GENERAL)

MOTION TO QUASH BASED ON SELECTIVE AND VINDICTIVE PROSECUTION

TO THE HONORABLE, THE JUDGES OF THE SAID COURT:

AND NOW comes before the said court Stanley J. Caterbone, appearing Pro Se, and Advanced
Media Group, as Movant, to file an Amicus in the above captioned case.

The Movant has an interest in this case as also being a victim of "SELECTIVE AND
VINDICTIVE PROSECUTION by the Commonwealth of Pennsylvania and the Lancaster Count4li
District Attorney's Office dating back to the myriad of prosecutions by the Commonwealth of
Pennsylvania in 1987, 2005, and 2006 while a resident of the County of Lancaster, Pennsylvaniai.
Most of which have been dismissed without any convictions, most without any trials, which according
to law are false arrests and false imprisonments. The MOVANT was a Federal Whistleblower in the
United States v. International Signal and Control, Plc., case of 1991.

This amicus provides a voice for the Movant as well as providing another perspective and
opinion that should benefit the courts; the parties; and the public-at- large. The matters presented in
this amicus have a direct relevancy in the disposition of this case as it does in the Attorney General's
(Kathleen Kane) fight to restore integrity and equity to the Judicial System of Pennsylvania, which
affects all of the residents of the COMMONWEALTH. The Attorney General has been quoted as
saying she is in a battle with the 'old boys' network' of Pennsylvania and the MOVANT has written
extensively about this same select group over the years beginning in 1998. In an intrview with
Brian Taff of WPVI on February 16, 2016 the Attorney General is quoted as saying "Everybody

Superior Court 1164 Amicus re Kathleen Kane Page 1 of 48 Thursday, April 28, :t 016
 makes mistakes. I knew there was a good old boy network, everyone does. I had no idea
how deep and how powerful that network actually ran. The fact that I took it on and I
wasn't silent about it and that I am determined to tear that down, I think that's what my
legacy will show."

In a "This story was pierpetuated

1998 narrative the MOVANT wrote the following
through a gross miscarriage of justice: a tenure of malicious wrongdoing by both the law
enforcement community of Lancaster County and the Commonwealth of Pennsylvania, as
well as community leaders. A process that continues to obstruct Stan Caterbone's rights
for justice. It's mannerisms reach into the inner soul of political and judicial corruption. All
in the name of greed, and all in the honor of continuing the status quo of the "Good Ole
Boy's" club of Lancaster County. A process obsessed with keeping it's disclosure from
escaping beyond the confines of "Pandora's Box ". It's a tenure of power that evolved frorin
the days of this country's earliest settlers, but an evolution that has somewhere strayed
away from the intent of our constitution; with total disregard for the law, in total
disrespect for the Constitution, and void of many of our civil liberties. This atrocity,
like the Lambert case, would have made our founding forefathers revel in disgust and
bellow in despair. In fact, their spirits and energies probably are!"

In 2009 Opednews.com printed the narrative in full and the MOVANT wish0 this said
court to consider it's content in it's final deliberations in support of dismissing all prosecutions
against the Attorney General of Pennsylvania. In addition attached are supporting, documents
to advanced the credibility and integrity of the MOVANT. These documents are attached as
EXHIBITS.

Diary: Lancaster County, The CIA, and U.S. Sponsored Mind Control,

http://www.opednews.com/populum/diarypagem.php?f= Lancaster -County -The-

i

CIA -by -Stan- Caterbone- 091125- 169.html

In addition the MOVANT wrote to the ATTORNEY GENERAL on November 12, 2015 and
stated the following "Back in 1998 I had a meeting with an NSA (National Security
Agency, Ft. Meade, Md) operative in parking lot of a former car dealer in York, PA. I
a
had just attended a job fair and he approached me as I was about to get into my car.
He introduced himself as being from the NSA and I questioned him about why the y
would not leave me alone. His response was "It is not US (NSA) it's the Good Ole
Boys". I also have a huge problem with modified, stolen, and planted documents. W
parted ways in an amicable fashion."

Superior Court 1164 Amicus re Kathleen Kane Page 2 of 48 Thursday, April 28, 2016
 The ATTORNEY GENERAL returned a letter the following day that stated "Dear M

Caterbone, Thank You for your correspondence to the Office of Attorney General, we.
will keep your information in our files ". These are attached as EXHIBITS.

Date: April 28, 2016 St., ley '

Freedom From
. Cater. ' e, Pro Se
vert Harassment and Surveillance
Advanced Medi. Group
1250 Fremont Street
Lancaster, PA 17603
www. amgglobalentertainmentgroup.com
scaterbone(@live.com
(717) 669-2163

Superior Court 1164 Amicus re Kathleen Kane Page 3 of 48 Thursday, April 28, 2016
 HAD LANCASTER COUNTY (Pennsylvania) LOST IT'S SOVEREIGNTY BEFORE IT Lost-
IT'S SOUL ?1
Authored in May of 1998
Í

"Each time a man stands up for an ideal, or acts to improve the lot of others, or
strikes out against injustice, he sends forth a tiny ripple of hope. And crossing each
other from a million different centers of energy and daring, those ripples build a
current which can sweep down the mightiest walls of oppression. ".
by Robert F Kennedy

In 1987 This Plaintiff (Stan J. Caterbone) Had Unjustly Lost His Freedoms, His Rights, And His
Pursuit Of Life, Liberty And Justice.

The following report (most identities purposely omitted from this version) is an amazingly true
and factual account of an extraordinarily bizarre tragedy that has turned one man's life into arts

eleven (11)2 year free fall into "Dante's Hell ".

On the surface, this is a story of a victim (Stan J. Caterbone) struggling to seek the, truth, but
in reality, the evidence will conclude that this is a victim, literally, held hostage by v rtue of his
truth. Later, the preponderance of evidence that Stan Caterbone has amassed and his
obsession for meticulously documenting his ordeal might seem eccentric, yet his demonstrated
ability to react to events before they unfold appears mystical. And this was his manner in which
he tactfully defended and protected his life. It is these actions that have painted the landscape
with dire vengeance for his ruin. His actions will ultimately serve to protect, preserve, and
a

foster the truth of his story, incriminating the culpability of his many perpetrators, while at the
same time being twisted and tainted in a relentless manner to attack his credibility.
This is a story of a human being endearing for his rights, living in fear of his life, and the
remedial actions required for the truth to set him free. A victim (Stan J. Caterbone) forever)
believing in his accomplishments and his visions, yet forced to adhere to a lifie of their)
diversions. Fatefully, ten years after being taken as a "political hostage ", with the aid of
numerous arrests and false imprisonment's conveniently falling short convictions, a Federal
Judge, Judge Stuart Dalzali, of the Eastern District Court of Pennsylvania, opened a 'Pandora's
Box" into the true colors of the inner workings and politics of ultra conservative Lancaster
County, Pennsylvania, a supposedly "God's" country. His findings reeled a drai-natic and
emotional response from the Lancaster County community that was akin to the assassination of

Superior Court 1164 Amicus re Kathleen Kane Page 4 of 48 Thursday, April 28, 2016
 JFK. A community where "obstructions of justice" strikes a startling and stark contrast to thle
image it so desperately embraces. A community proud of it's "tough on crime' judges, a
community of "plain folks" and Amish, and a community settled in a beautiful landscapie
abundant in an agricultural bounty. This is not a community of compromising integrity. Or so vt

has been perceived.

Judge Dalzall's extremely controversial findings were responsible for Pennsylvania's own
crafting of the "Laurie Bill ", the retaliation by the Commonwealth of Pennsylvania intended tI
curb the Federal Courts interference within the respective state's own jurisdilctions and
proceedings. Or was it a political maneuver to close the lid on "Pandora's Box "? The
Pennsylvania Attorney General and the Lancaster County District Attorney have both thrown aÍl
their might and all their muscle at turning the tides of Judge Dalzall's findings. This story an(''i

Stan Caterbone's rights have been violated and abused by some of the very same principal;
that were responsible for Judge Dalzall's unsettling revelations. Lancaster County prosecutors
were found to have engaged in one of the grossest acts of prosecutorial misconduct "found inl
the English speaking language ", which allegedly occurred in this now famous Lisa Michelle
Lambert case, a murder trial which began in the summer of 1992. Subsequently, it is now i

the midst of a treacherous appeal process convened by Judge Dalzall. And if so, by fate, in
Philadelphia, Pennsylvania; the home of the "Freedom Fighters ".

It is this public disclosure, that casts a new light and sudden hope for freedom into Star
Caterbone's unbelievable and horrid story, that begun just four years prior to the murder of

Laurie Show. It is the decisive similarities of how both victims were subjected to a

calculated and politically motivated attempts to "frame" and "fabricate circumstances" to obtain
the results that justified the means for illicit self- serving interests. This very same conduct,
committed by public servants, elected and enlisted to enforce the law, to which Judge Dalzell
found so appalling. Conduct, which violated the very same rights their respective IlOffices ar
commissioned to protect. Conduct, which strikes the meaning of "We The People', from ours

nation's very own Constitution.

I !,

Fortunately, Stan Caterbone's story is laced with a thread of faith, a faith in God. And because
of his faith, Stan Caterbone will forever regard Lisa Michelle Lambert' and Laurie Show as hisl
little "Angels of Justice ", a Godsend. An answer to his many prayers, that for the firist time in
ten years provided a small glimmer of hope, and a few moments of solitude that have
materially justified his own tragic experience. The realization that the truth is that rrimuch more
believable because of the trials and tribulations of Lisa Michelle Lambert. Unfortunately, this
revelation came at the unfortunate and untimely death of Laurie. However, it just may be God's
intentions of a Higher Purpose.

Superior Court 1164 Amicus re Kathleen Kane Page 5 of 48 Thursday, April 28, 2016
 This story was perpetuated through a gross miscarriage of justice: a tenure off malicious
wrongdoing by both the law enforcement community of Lancaster County and the
Commonwealth of Pennsylvania, as well as community leaders. A process that continues to
obstruct Stan Caterbone's rights for justice. It's mannerisms reach into the inner soul if
political and judicial corruption. All in the name of greed, and all in the honor of continuing the
status quo of the "Good Ole Boy's" club of Lancaster County. A process obsessed with keepinga
it's disclosure from escaping beyond the confines of "Pandora's Box ". Its a tenure of power that
evolved from the days of this country's earliest settlers, but an evolution that has somewhere
strayed away from the intent of our constitution;

with total disregard for the law, in total disrespect for the Constitution, and void of many of our
civil liberties. This atrocity, like the Lambert case, would have made our founding ,forefathers
revel in disgust and bellow in despair. In fact, their spirits and energies probably are!)

AT ISSUE

The central issue in this story is a cover up, a cover up of mass proportions, and of perplexing
-I
design, with national consequences. The fact of the matter is that this cover up has had
ramifications throughout this world; specifically the Middle East The cover up would beie
emphatically unbelievable without the wealth of evidence, especially the recorded conversations
with Pennsylvania officials. A cover up that permeates from what will later emerge as the 4ttl
largest financial fraud (Billion Dollars) in the history of the United States coupled with they
covert sales of arms to Iraq. And five years after this cover up began, these same munitions¡
were used against our own troops in the Persian Gulf War. And of course, there are admitted
ties to the Central Intelligence Agency (CIA) and the National Security Agency (NSA).. And this ,

cover up and story, which began in June of 1987, in Lancaster County, preceded criminal
indictments by the United States Attorney General, the Federal Bureau of Investigation (FBI),
the Internal Revenue Service (IRS), the Department of Justice and Commerce, and more. A
vast array of criminal activities conspired from the ultra conservative Lancaster County, where
God is supposedly supreme, and it's hard line approach to crime is said to be preeiLninent. Ini
June of 1987, Lancaster County was immersed in a dynamic twist of fate, with a host of players)
which may never be fully identified.

The irony of this story is how Lancaster County manages the disclosure of the very same I

criminal activities that this story proves that it condoned, prior to the intervention of federal,
authorities. It most dramatically will prove the nature of its integrity, or lack thereof.
International Signal & Control, (ISC) is the controversial player in this web of conspiracy. In
1987, ISC was the third largest employer in Lancaster County, a non -discrete defense;
contractor. In all due respect to our beloved country, this report is in no way challenging the

Superior Court 1164 Amicus re Kathleen Kane Page 6 of 48 Thursday, April 28, 2016
 policies or the activities of the Department of Defense, or the vast agencies of the "Intelligence
Community ", especially the CIA or the NSA (National Security Advisory). with regards to ISC'is
foreign dealings. Trying to protect the world of malicious and evil empires is a prolcess whicli
never ends, and whose players are constantly changing. And our respective intelligence
agencies are continually challenged with the task of trying to make a difference, in jccordance
with protecting our national security. Unfortunately, given the nature of their discrete activities,
and given the CIA's history of avoiding congressional approval in certain situations, our current
laws are void of effectively dealing with the peripheral catastrophes of such activities that
inherently transpire. The CIA remains immune, while everyone outside staffers the
consequences.

The fact that the CIA, or anyone of the other intelligence community, may have been involved,
does not grant a blanket of immunity over activities which were not material to protecting our
national security. If a company provides a service to anyone in the intelligence comnliunity, our
constitution, our laws, and its respective commercial regulatory authorities, must still have the
full sense of their jurisdiction. The intelligence community may not have the right of
intervention into the commercial enterprise, or organization, circumventing the rights of its
employees, shareholders, creditors, and customers. No United States law or statut6 suggests,
that there is any involuntary mandate that requires any of the preceding to compromise his or
her interests in the respective enterprise for the sake of national security, or the respective
intelligence agency. There must be considerations paid to all involved for those ights and,
interests that compromise such a relationship. Otherwise, the CIA could effectively gain control
of any domestic corporation it so desires, without ever owning one share of its outstanding
stock, simply by enlisting its product or services for the sake of national security¡. The CIA
requires a formal vehicle to enlist the aid of our domestic commercial enterprises, ISC is a

proven and unfortunate example of that.

Stan Caterbone was a shareholder of record of International Signal & Control (ISC) for the
previous four years prior to when this tragic ordeal began. Stan Caterbone was to purchase the
stock from now Republican Pennsylvania Senator Gib Armstrong, who was in the brokerage
business at the time and selling ISC stock. The stock was sold over the London Securities
Exchange, supposedly for reasons to suppress information. Stan Caterbone was interested in
the stock because of his appetite for technology, and was more curious about the business of
ISC, than anything. In fact, Stan Caterbone had never made any inference to any of the illicit
dealings with Iraq. However, the perpetrators of this story, attempt to hide behind a vale of
I

"national security," in an effort to find legal immunity from all wrongdoing. In accordance, the
record will prove that this is merely a smoke screen used to intimidate and obstruct Stan
Caterbone's access for due process of the law.

Superior Court 1164 Amicus re Kathleen Kane Page 7 of 48 Thursday, April 28, 2016
 The trials and tribulations of Stan Caterbone are unprecedented in terms of emotional an l
psychological duress, fortunately his indestructible faith in God, and his enduring belief ii
himself and the truth, endures his life. There was one attempt on the his life, days within the
public disclosure of the CIA's involvement with the local Lancaster County defense contractor
(ISC), which Ted Kopel reported on ABC News Nightline, on May 23, 1991, 4 years after the
initial cover up began. This story will depict a series of systematic and strategic offensive
attacks upon Stan Caterbone and his businesses that will result failed business enterprises, and
a Hollywood motion picture, deserted. An impeccable professional reputation and a flawless
credit rating purposely sabotaged. Financial opportunities, that in 1987, were almost impossible
to extrapolate, Vast financial opportunities and aspirations forever a part of h story. Th's
horrendous Crime was perpetrated for the interest of a cover up, further protecting the corrupt
enterprises of Lancaster County's International Signal & Control (ISC). A quest for justice that
polarized every relationship Stan Caterbone maintained, in Lancaster County and beyond,
including friends and family. This story demonstrates a methodology of his perpetrators for
keeping Stan Caterbone "quarantined" from justice and public disclosure, through a malicious
means of "credibility" proponents, and horrendously deceptive tactics. Financial motives
prominently displayed in the hands of all of the perpetrators, which absolves the burden for a

traditional conspiracy.

The emotional response to the truth of this story is compelling, to say the least. Subsequent) /,
the startling keen sense of perception that Stan Caterbone had demonstrated is even more
intriguing. It is this extraordinary quality that is responsible for saving his life, while yet at the
same time providing his perpetrators with an alibi and a vehicle for discrediting uis startling
allegations and his story. This story embellishes a dichotomy of perception that ha i Hollywood
producers from his film project call his work genius, while his perpetrators from the Lancaster
County Community conveniently and maliciously labeling him as "insane" and '¡emotionally
disturbed."

THE LANDSCAPE

The perplexing question of Stan Caterbone's intelligence, or lack thereof, is best analyzed as a

question of perception. However it terms of the legal consequences of the activities contained
herein, they are of little if any relevancy. The fact of the matter is that the "mental deficiencies"
have very little relevancy to this story, other than serving as a means to discredit Stan
Caterbone, a vehicle to facilitate the cover up, and a blanket of immunity for all of tie
perpetrators.

The heart of Stan Caterbone's legal dogma is best described as follows: If a person, is
perceived to have a "mental deficiency "; yet whose actions and decisions are always proven to
be instinctually and amazingly prudent, always abiding within the law, and in the best interest

Superior Court 1164 Amicus re Kathleen Kane Page 8 of 48 Thursday, April 28, 2016
 of his affairs, what rights and protection do the laws afford him from persons atI)using that
perception, in order to yield political and financial rewards, as a direct consequEmce of his
demise? Furthermore, how does the law protect his rights, if any and all malicious acts against
Stan Caterbone, are constantly and immediately disregarded because he is perceived to not to
be "credible "? As this story unfolds, these questions will become even more trciubling and
appalling. Although Stan Caterbone could never describe the pain of his trauma, he Would often
say that the closest situation that may compare is that of a woman being continuoiusly rapec,
night after night, helplessly praying for relief, struggling to free herself from her captor, all with
no avail. He would call it as being "brain f ".

Stan Caterbone, coming from the lower middle class of Lancaster City, was only 29 years old
when this tragedy began. Coming from a broken home, he was the third of six boys( While at a

very young age, he would help his mother run a dry cleaning business, in an amazing similarity
like Lisa Michelle Lambert, he had also nursed his mother during bouts of depression. While in
high school, he was nursing his mother's depression, while at same time tending to his older
brothers bouts of schizophrenia. Stan Caterbone had learned to listen to the obscenities of
mental illness since he was a child. He learned to fill the shoes of his absent father in helping
his mother raise his three younger brothers.. Stan Caterbone was often called thle "little old
man" because of his extraordinary maturity as a child. Stan Caterbone was determined :o

break the "barrier" of the "Good Ole Boy's" club or the power elite, and had always felt a sense
of compassion for those less fortunate, and those neglected by those of material means, the
oppressed and impoverished. He had an undivided aspiration to someday make a difference to
those that could not help themselves, especially his older brother. Through his ingenious,
resourceful, and honest business approach, he was relentlessly growing his business and their
respective missions, in constant reminder of his oppression. His in depth understanding of
computer technology and his vision were his most powerful allies. Always pushing the envelope
for advanced technologies and seeking solutions for the most efficient means of his (operations..
He knew that every break was going to be few and far between, he dedication himself to his
work, and married his business affairs, always embracing his projects with a passion.

In 1986, after serving on the Board of Directors for the Central Pennsylvania Chapter of
International Association of Financial Planners (IAFP), Stan Caterbone had made a large
contribution to increasing its membership and it's awareness among local professionals, as it's
vice president. In an effort to promote the organization, Stan Caterbone solicited a nationa ly
recognized and prominent financial planner from Washington, D.C., to be a headlin 2 speaker at
a dinner meeting. Ms. Alexandra Armstrong, one of the most nationally recognized financial
planners, often headlined in Money Magazine, attracted 100 industry professionals to tie
Treadway Resort Inn. The attendance was unprecedented for the local IAFP chapter. The IAÌ =P
is the authoring organization for certification as a financial planner. It was through the direct

Superior Court 1164 Amicus re Kathleen Kane Page 9 of 48 Thursday, April 28, 2016
 conversations with Ms. Armstrong regarding his ideas and her experience, that inspired Stan
Caterbone to pursue his ambitions of growing his own financial firm, which he began in th
following months.

Disgruntled with the conflicts of interest and the lack of incentive for various professionals to
work together in managing one's wealth, a process which lacked efficiency, this entrepreneur
founded the firm Financial Management Group, Ltd., or FMG as it was often called. The firm
was to incorporate a "one -stop- shopping" strategy and incorporate financial services, legal,
accounting, tax preparation, real estate, insurance, mortgage banking, and estate services all
in one firm, all residing in one location, all taking advantage of the synergistic approach toward

managing wealth. And to provide the professionals long term security and equity participation,
all participants were encouraged to purchase stock in the company. This was a new and
innovative approach that attracted a lot of attention from investors and clients, but ailso came a

lot of nervous twitches from competitors, especially in conservative Lancaster County.

Stan Caterbone began recruiting professionals from all of the other firms, with great success.
He had enlisted two partners whom he had worked with at IDS/American Express, to carry out
his mission, which he began after extensive market studies and his early version of the
company, Pro Financial Group, Ltd., His two partners had followed Stan Caterbone to an
independent broker dealer in Atlanta, named Financial Services Corporation, where Ms.
Alexandra Armstrong was associated, and encouraged Stan Caterbone to visit, during their
discussion after dinner. Within one year, by June of 1987, the firm had invested over $4)
million for respective clients.

The company had developed satellite offices throughout Pennsylvania and in several other
states, through his unique design. This firm was causing the other financial services companies
and the local banks in Lancaster County a run for their money. The firm had built a new 20,00)
square foot office building just a few miles north of the city. The firm was attracting clients,
associates, and nervous attention from, well just about everybody. Considering the :apabilities,
legal, real estate, insurance, financial services, accounting, FMG was making as many enemies
as it was making friends. And Stan Caterbone always believed in the premise that it's always
better to have people talking about you, regardless of the matter, than to have no one noti Ie
you. And they were talking. Stan Caterbone was only in his late twenties when he started this
organization,. He held several positions; he was Executive Vice President and Secretary of
Financial Management Group Ltd, and President of FMG, Advisory, Inc., which was one of the
many subsidiaries parent company owned. Stan Caterbone acted as the architect and legal
administrator of the organization, in addition to building his own financial planning clients. He
filed all of the articles of incorporation in the Commonwealth of Pennsylvania and submitted all
of the tedious and rigorous filings necessary for the Pennsylvania Securities Commission, which

Superior Court 1164 Amicus re Kathleen Kane Page 10 of 48 Thursday, April 28 2016
 e
were very demanding considering Stan Caterbone, was selling stock of his company to his
associates and investors. Stan Caterbone and his associates had also attracted some very
prominent Lancastrians's to invest in his venture, coming from various professional circles, all
infatuated with this extraordinary and intriguing concept of this young victim (Stan J.

Caterbone). All had seen it's potential for success and financial reward.

Many of his friends were involved, and in Lancaster, everyone knows everybody, so it seams .

And everyone talks, gossip is as common as jogging. This exaggerated trait of Lancaster
County, will later to come back to haunt Stan Caterbone, in a way that is most sickening. In a

way that will parallel the attitudes and sentiments in the Lisa Michelle Lambert story.

In 1987, his business affairs were reaching a point of incredible success. In fact, most of his
family and friends, have always questioned the merits of their legitimacy. He always conducted
his affairs with the presumption that time could not afford the opportunity to complete h's
agenda, while at the same time disclosing his business affairs to persons that were not directly
involved.. Accomplishing his mission was first and foremost. But in Lancaster County, that was
difficult. Lancastrians's have a notion to fear what they don't know, and will always believe
what they think they know, regardless of its merits. In Lancaster County new ideas are
shunned unless coming from their own, and their own ideas are often kept close at bay,
Is
inhibiting progress and stymieing learning. By June of 1987, a majority of his business affair(
were conducted out of the grasp of Lancaster County, his unknown activities made others
curious, especially in Lancaster County, where the blessing of the power elite was essential for
success. But, deep down inside, he knew he could never be accepted, because he did not
descend from a family of "social grace ". This fueled his aspirations for success even further,
committed to prove that intelligence was innate and learned, not a direct correlation to material
wealth or social grace.

An elder attorney, Mr. Kenellm Shirk, a very respected and prominent older Lancaster attorney,
who was part of the status quo, provided one of his most cherished testimonials to his concept,
his reputation, and his mission. Mr. Shirk had petitioned the Pennsylvania Bar Assocl.iation, after
meeting with Stan Caterbone, to obtain their blessing and their knowledge of any laws which
would forbid his firm to provide a satellite office in the headquarters of Financial Management
Group, Ltd., (FMG) Mr. Shirks firm was to provide a partner, and estate services to the clients
of FMG. The Pennsylvania Bar provided a lengthy recommendation that did not prohibit a

relationship, although cautioned it to proceed with careful review. The fact that the very young
and unknown Stan Caterbone could attract an elder, conservative Lancaster County attorney to
associate with his firm was an encouraging sign of respect. Ironically, Mr. Shirk is the father of
Roy Shirk Jr., Lisa Michelle Lambert's first attorney who represented her during trial of 1992,
the proceeding which was the center of Judge Dalzall's controversial and appalling findings.

Superior Court 1164 Amicus re Kathleen Kane Page 11 of 48 Thursday, April 28, 2016
 Stan Caterbone prided himself on his entrepreneurship, and after building the foundation for
FMG, he set out to take advantage of its resources and it's synergism.
II

By June of 1987, Stan Caterbone had developed a fairly substantial mortgage banking
relationship with a Houston, Texas banker. That operation was capable of providing) lending to
potential developers and businesses in the range of $ 3 million to $100 million. And Ithe lending
packages were as competitive if not more competitive than the local lending institutions of
Lancaster County, capable with even higher lending limits. In a matter of months iof securing
this relationship, Stan Caterbone and his partner were evaluating deals from Pennsylvania, New
Jersey, New York, Florida, and as far away as California.

There was a uniqueness to his capabilities that was very appealing to potential borrowers.
Because of the vast array of services of FMG, potential developers had the opportunity to
obtain both debt and equity financing through his companies. In plain terms, most shopping
centers raised capital by raising funds through investors coupled with a mortgage. This gave
potential developers one place to "take down the deal" rather than dealing with rinany other
professionals at the same time. It was a much more efficient process for all. Stan Caterbone
was capable of providing a mortgage, while at the same time selling shares in a shopping
center through it's vast client base of investors at FMG. This also gave Stan Caterbone a
formidable presence into the venture capital markets, by way of his strong ability to raise
capital through his vast portfolio of clients of FMG. And this was a rarity that developers and
investors loved. Investors were attracted because they could invest in equity type real estat:e
projects with real sense of knowing the developer, or "kicking the bricks" of the project. This
was far different than investing in a nationally syndicated project, with properties scattered all
over the country, and with developers that they did not know. The synergistic app-oach to his
organization began paying dividends by developing other peripheral markets and businesses.

Given the complex nature of Stan Caterbone's design of FMG, internal struggles within the
organization readily became the challenge. Orchestrating the relationships among all of the
different professionals, and trying to adhere to the interests of the clients, the professionals
and of the firm, FMG, managing the daily activities required immense thought and prudence on
the part of the principals. Of, course, Stan Caterbone assumed honesty and inteçrity to be a
given. And for most it was. However there were times when the senior partner engaged in
tactical rights of power.

In the later part of 1986, after Stan Caterbone had developed FMG to the point where it's
future was on stable grounds, his two partners conveniently attempted to circumvent I-is
position and regain control of his stock and the firm. In fact, after Stan Caterbone refused to
collaborate on a scheme to "set up" his other partner, the remaining two partners began to
attempt to regain Stan Caterbone's control. Through intimidating techniques, the partners

Superior Court 1164 Amicus re Kathleen Kane Page 12 of 48 Thursday, April 28, 2016
 began to attack his presence. Stan Caterbone became agitated, especially because he played
the lead role and was responsible for the formation of the company, methodically designing and
developing its foundation, with great success. And now after the company was beyond it's point
of greatest risk, due to in large part Stan Caterbone's efforts, the other two partners¡ wanted t(i)

take advantage of his work, and "take the cream of the pie" for their own financial gain. It was
a difficult task to carry out because Stan Caterbone was the most respected of all three
partners, consistently keeping their respective policies in the best interest of the firm and of the
other associates and stockholders. In fact, most feared that the loss of control of Stan
Caterbone would ultimately lead to adverse consequences. However the two partners trued
unsuccessfully to weaken his position, and when that didn't work, they focused on weakening
Stan Caterbone, via intimidation and humiliation The coup and hostile environment caused áI

state of depression for Stan Caterbone, although he kept to his daily duties and responsibilities!,
accordingly, he called a client and friend who was a psychiatrist, whom he trusted and
respected. It was easy access to a professional, yet on a very informal basis. Because Stan
Caterbone had a family history of "mental deficiencies ", he wanted to seek the proper help.

The psychiatrist had diagnosed Stan Caterbone as having Bi Polar Mood disc)rder. The
psychiatrist had quickly discounted any correlation between the current state of affairs, and his
partner's abuse. The psychiatrist rationale was that "because the startup of the company was
so successful in such a short period of time" , and his demonstrated intelligence and creativity,.
Stan Caterbone must have been in a state of mania, and of course now, was subsiding in a

state of depression, the typical cycle for manic depressants. Stan Caterbone complied with the
psychiatrist. And after refusing to sell out to his partners, vowed to regain his business and
rescind any efforts to give up his claim to his accomplishments. The depression soon faded,
Stan Caterbone never disclosed the fact that he had sought help to anyone other than family
members. This coup lead to Stan Caterbone's aggressive approach to grow the businss, and t5
posture himself in projects that would ultimately remain in his control, out of the influence of
his partners. Particularly of most interest was saving the mortgage banking actìviti's and they

digital movie, which he did successfully, but apparently too successfully.

THE "DIGITAL MOVIE"

Through an act of fate, in February of 1987, Stan Caterbone found himself in a meeting witl-
Tony Bongiovi at Power Station studios. Through one of his partners, he reluctantly traveled to
New York to consider financing a motion picture. Stan Caterbone's own lack tolerance for the
risk associated with film investments was overshadowed by the opportunity to visit a recording
studio. Although his associate was a friend of Tony's, he was not familiar with his
accomplishments, or his work, so he thought. If nothing else, it was a weekend away from
Lancaster, and a chance to visit the Big Apple. Intriguingly, he found more than he had eve'

Superior Court 1164 Amicus re Kathleen Kane Page 13 of 48 Thursday', April 28, 2016
 imagined on that weekend excursion. Tony Bongiovi, a musical genius, who's credits include
one of the most recognized recording studios in the country, Power Station Stuidios. Tony
Bongiov produced the sound track for "Star Wars ", and is responsible for the formait of one of
the most successful recording artist of the 80's, Jon "Bon Jovi ", his cousin. Power Station has
recorded the albums for some of the most influential artists of all time, including Diana Ross,
Madonna, The Rolling Stones, Steve Winwood, Bruce Springsteen, etc., Tony, aril eccentric
genius, of Italian decent, had many talents, from music to aerospace engineering. Stan
Caterbone's associate's sister met Tony while he flew his plane into Lancaster's airport for
repairs. They dated for some time and Stan Caterbone's associate and Tony beca ne friends!,
which led Stan Caterbone to Tony's Power Station Studios.

Tony was looking to finance his new project, which was to be the first digital movie. And, given
Stan Caterbone's extreme appetite for technologies, coupled with his amazing sense of
perception, he dramatically recognized the future evolution for the technical merits of delivering
digital video and digital audio entertainment to the mass markets. By June of 1987, Stai
Caterbone was positioned as the Executive Producer, collaborating with Flatbush Films of
Hollywood California, the movie producers, entrusted with the mission of finding investors to
provide funding for the "first digital movie ", and to manage the ensuing business (elements it
required.

The movie was to be shot "on- location" at the Jersey shore points, mostly in Wildwood. Tony
strategically envisioned making a movie in the horror genre. There were several specific
reasons that supported this strategy. First, he determined that it was the least: expensive
format to produce, we all estimated a budget of $4 million for the production and post
production. Secondly, the horror genre would compliment a very intense sound track. The
sound track was important to enhance the new digital format, and also provide the means to
introduce a new band that he had been grooming in his studio for the past several years,
"French Lick ", his predecessor to "Bon Jovi ". There had been bad blood between Tony and his
cousin "Bon Jovi ", which resulted in legal disputes pertaining to Tony's financial interests in
Jon's success. It was an unfortunate situation considering Tony's father and Jon's father were
brothers living in the same area. It was a subject that Tony never wanted to discuss except for
his contributions toward Jon's career.

If by another act of fate, Stan Caterbone had the privilege of meeting one of the many

superstars while working at Power Station studios. While growing up, at an early age, Stan
Caterbone would sneak up into the bedroom of his oldest brother, and start up his old General
Electric stereo phonograph and listen to his favorite album - Diana Ross and the Supremes. It
was a ritual that provided an early infatuation to music, and to Diana Ross. Stan
passion and a

Caterbone was only 10 or 11 years old. And at this early age, he noticed and listened to the

Superior Court 1164 Amicus re Kathleen Kane Page 14 of 48 Thursday, April 28, 2016
 annoying hiss, that conventional hiss that always seemed to overshadow the music, whether
played on an album, on the radio, 8 -track tape, or cassette.

And in a mystical twist of fate, while engrossed in a project dedicated to delivering music
without that hiss (digital) - Stan Caterbone opened the door to the recording suite to pack his
bags for the journey back to Lancaster; - and there she sat, with a glowing array of beauty,
more beautiful than any picture could ever tell, Ms. Diana Ross. She was pregnant and in the
middle of a recording session, for a new album. Her assistant quickly demanded, in a stern and
protective voice, that we leave, and Stan Caterbone and his associate replied "this is our
makeshift bedroom, we are just gathering our belongings ". Stan Caterbone walked towarcii
Diana Ross, who was seated near his bag, and she asked "and who are you ? ", Stan Caterbone
calmly replied his name and absorbed as much of her beauty as his eyes could behold before)
walking out the door. The room that was his bedroom the nigh before, and suddenly transfixed
into the recording suite of Diana Ross, thinking back some twenty years earlier, one of the
many gifts that God would bestow upon him. A living memorial and reminder to his older
brother, who died on Christmas day of 1985, his best friend who taught him two of uis greaterlr
pleasures in life, Diana Ross, and listening to music. He prayed that his brother was watching
from above.

And so, the digital movie project that Stan Caterbone had embraced in 1987 had persona
significance, and he never ever doubted his instincts regarding the technical merits of the
project. Stan Caterbone's perception that the entertainment industry would deliver full length
motion pictures in a truly digital medium will later become a truly remarkable vision.

The technical merits of this project and at this particular time with respect to Stan Caterbone's
extreme sense of perception require analysis. To truly understand this time perception, some of
the attributes of digital technologies need to be fully understood. In 1987, Compact DISC (CD)
technology was only now being introduced to the commercial markets. Stan Catertone's own
crafting of his joint venture proposals, dominated by the term "digital movie ", is in itself some
4 or 5 years away. In 1987, there was very little use of the term "digital ", with the exception of
research and development engineers. Stan Caterbone will, throughout the documentation of
this story, will have preceded a terminology that has literally become the root of most)
technological advancements in the computer and telecommunications industries of our present:
day, 10 years after Stan Caterbone's vision. Today, "digital" is found to be part of or -eferred tc
in just about every product available in the commercial markets.

During May of 1987, Stan Caterbone had created a joint venture proposal for SONY
Entertainment, Inc., for the digital movie. After weeks of researching the current state -of-
affairs within SONY, and after his proposal was completed, SONY publicly announced their
desire to open the markets for new and emerging technologies on the cover of TIME magazine1

Superior Court 1164 Amicus re Kathleen Kane Page 15 of 48 Thursday, April 28, 2016
 another demonstrated sense of perception. It was this proposal, when delivered to one of the
Hollywood producers in Santa Monica, California, after reading a draft of the proposal she saic
"you are a genius ". The proposal was introduced to Tony Bongiovi at the Wildwood I3oardwalk,
where many of scenes were to be shot, and he approved of the proposal and thought that il:
had great merits. Tony, who wanted very to do with the business elements of his pròject, gave
Stan Caterbone complete authority to secure the financing of the project, with a salary as
Executive Producer, and a percentage of the profits on the back end.

After review of Stan Caterbone's research and proposal's, his vision and his passion,
unfortunately without his efforts, has come to be known as Direct Satellite Systern, or DSS,
which is Sony's satellite entertainment system (TV), delivering digital audio and digital vide
entertainment. That technology is fast eroding at the cable industry. Stan Caterbone had his
patent research center around the PSDMS system, the Power Station Digital Movie S (stem. An
that was in 1987, some seven years before SONY delivered his dreams. Later Stan Caterbon

would also accurately predict that the 90's would become the "Information Age" because of the
direct contributions and advancements of "digital technologies ", which is directly responsible for
the development of the "INTERNET ".

Stan Caterbone's obsession with his "digital movie" has proven to be one of his most
remarkable demonstrations of his keen sense of perception.

The author admitted in an affidavit in 1998 that he did not know the criminal culpability of Lisa
Michelle Lambert, and further argues that it was because of the prosecutorial misconduct and
the erroneous handling of the crime scene that the truth evaded both the prosecution and the
defense as to who actually killed Laurie Show.

Date: April 28, 2016 Stanl J. Caterbon Pro Se

Free.om From Co Harassment and Surveillance
Advanced Media up
1250 Fremont Street
Lancaster, PA 17603
www. amgglobalentertainmentgroup.com
scaterbone(live corn
(717)669 -2163

Superior Court 1164 Amicus re Kathleen Kane Page 16 of 48 Thursday, April 28, 2016
 EXHIBIT

Superior Court 1164 Amicus re Kathleen Kane Page 17 of 48 Thursday, April 28, 2016
 Stan J. Caterbone
ADVANCED MEDIA GR0111P
1250 Fremont Street
A Lancaster, PA 17603
(I{1 scaterbone @live.com
717 -669 -2163

November 12, 2015

Ms. Kathleen Kane

Pennsylvania Attorney General
16th Floor Strawberry Square
Harrisburg, Pennsylvania

Re: "Old Boys Network" filed in GENERAL OAG QUESTIONS November 11, 2015 .

November 11, 2015 7:42am

"Kane, the first woman and Democrat elected to the position of Pennsylvania's top
prosecutor, has dismissed the case as a backlash over her challenge to what she
calls the old -boys' network in Pennsylvania law enforcement." LNP, Attorney
General Kane faces trial on more charges, by the Associated Press on November 11,
2015."

Back in 1998 I had a meeting with an NSA (National Security Agency, Ft. Meade, 'Id)
operative in a parking lot of a former car dealer in York, PA. I had just attended a job
fair and he approached me as I was about to get into my car. He introduced himself
as being from the NSA and I questioned him about why they would not leave me
alone. His response was "It is not US (NSA) it's the Good Ole Boys ". I also have
a huge problem with modified, stolen, and planted documents. We parted ways in an
amicable fashion.

Stan J. Caterbone Advanced Media Group

717 -669 -2163
www .amgglobalentertainmentgroup.com

See the enclosed as well as U.S.C.A. 15 -3400 LISA MICHELLE LAMBERT APPEAL,
APPELLANT, Stanley J. Caterbone, Pro Se

https://www.scribd.com/doc/ 284639091 /Federal -Whistleblower- and -Targeted-

Individual-of-U -S- Sponsored- Mind -Control- Executive -Summary- Updated -October_
12 -2015

a&L_

Stan J. Caterbone

Superior Court 1164 Amicus re Kathleen Kane Page 18 of 48 Thursday, April 28, 2016
 COMMONWEALTH OF PENNSYLVANIA

KATHLEEN G. KANE CONSTITUENT SER DICES

ATTORNEY GENERAL
Floor Strawberry Square
16th

Harrisburg, PA. 17120

717- 787 -3391

November 13, 2015

Stan Caterbone
1250 Fremont Street
Lancaster, PA 17603

Dear Mr. Caterbone,

Thank you for your correspondence to the Pennsylvania Office of Attorney General.
We will add your information to our files.

Sincerely,

Renee Martin
Director of Education and Outreach

RGM/emk

Superior Court 1164 Amicus re Kathleen Kane Page 19 of 48 Thursday, April 28, 2016
 G, TN
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 EXHIBIT

Superior Court 1164 Amicus re Kathleen Kane Page 21 of 48 Thursday., April 28, 2016
 Stan iJ. Caterb9ne
ADVANCED MEDIA GROUP
vedorn
From Covert
Freedom From Covert Harassment &I. Surveillam e,®
Registered in Pennsylvania
1250 Fi emont Street
1.1arnment & sarveila, ct Lancaster, PA 17603
www .amgglobalentetainmientgroup.(
scaterbbne @live.çom
717- 669 -2ií63

April 20, 2016

Stan 7. Caterbone /Advanced Media Group Biography

Present - Advanced Media Group, President, Owner, and Founder.

In 1987 I became a federal whistleblower for the case of local defense contractor Internkional Signal
and Control, or ISC. ISC was a black ops program for the NSA and CIA that was convicted in 1992 for
an elaborate scheme to arm Iraq and other Middle Eastern countries with a broad array of weapons,
most notably cluster bombs. It was the third larges fraud in U.S. History at that time. I have been a
victim of organized stalking since 1987 and a victim of electronic and direct energy weapons since 20)5.
I had also been telepathic since 2005. In 2005 the U.S. Sponsored Mind Control turned into an all -out
assault of mental telepathy; synthetic telepathy; hacking of all electronic devices; vandilism and thefts
of personal property, extortions, intellectual property violations, obstruction of justice; violations of clue
process; thefts and modifications of court documents; and pain and torture through the use of directed
energy devices and weapons that usually fire a low frequency electromagnetic energy at the targeted
victim. This assault was no coincidence in that it began simultaneously with the filing of the federal
action in U.S. District Court, or CATERBONE v. Lancaster County Prison, et. al., or 05 -cv 112288. This
assault began after the handlers remotely trained /sychronized Stan J. Caterbone with mental telepathy.
The main difference opposed to most other victims of this technology is that I am connected 24/7 with
the same person who declares telepathically she is a known celebrity. Over the course of 10 years I
have been telepathic with at least 20 known persons and have spent 10 years trying to validate and
confirm their identities without success. Most U.S. intelligence agencies refuse to cooperiate, and the
Federal Bureau of Investigation and the U.S. Attorney's Office refuse to comment and act on the
numerous formal complaints that are filed in their respective offices. Most complaints are focused on
the routine victimization's of a targeted individual including but not limited to stalking, harassment,
threats, vandalism, thefts, extortion, burglaries, false imprisonments, fabricated mental health warrants
or involuntary commitments, pain and torture to the body, and most often the cause of obstruction of
justice is the computer hacking.

I have a very sophisticated and authentic library of evidence of the use of U.S. Sponsored Mind Cont -ol
technologies on my father and brother that dates back to the 1940's while my father was in the U S.
Navy after he graduated with honors from Air Gunners School in Florida, including an affidaé,it motorized
and authenticated by my father in 1996. My brother served in the U.S. Air force and was victim to LSD
experiments of the infamous MKULTRA program in the late 1960's.

In 2015 I filed an amicus curie on behalf of Lisa Michelle Lambert who was convicted in 1992 of the
murder of Laurie Show, both of Lancaster, Pennsylvania. I currently am in litigation in the U.S. Third
Circuit Court of Appeals and in February of 2016 Lisa Michelle Lambert published her book titlid
"Corruption in Lancaster County - My Story ", which is available in bookstores and on Amazon.com. I '

am in frequent contact with her co- author, Dave Brown of Philadelphia, Pennsylvania.

Superior Court 1164 Amicus re Kathleen Kane Page 22 of 48 VThursday, April 28, 2016
In 2009 I Proposed an ORGANIZED STALKING AND DIRECTED ENERGY WEAPONS HARASSMENT BILL
to Pennsylvania House of Representative Mike Sturla (Lancaster, Pennsylvania) and City of Lanca ;ter
Mayor Richard Gray in 2009. The draft legislation is the work of Missouri House of Representative Jim
Guest, who has been working on helping victims of these horrendous crimes for years'. The bill (will
provide protections to individuals who are being harassed, stalked, harmed by surveillance, and
assaulted; as well as protections to keep individuals from becoming human research subjects, tortured,
and killed by electronic frequency devices, directed energy devices, implants, and directed energy
weapons. I again reintroduced the bill to the Pennsylvania General Assembly in 2015 arid frequented
the Pennsylvania Capitol trying to find support and a sponsor; which I still do to this day.

In 2006 I began his role as an Activist Shareholder for Fulton Financial, which is listed as FULT" on the
NASDAQ stock exchange. As a founder of Financial Management Group, Ltd., a full service financial fi -m,
Stan J. Caterbone has drawn upon the success in developing the strategic vision for his i-ompany and
the experience gained in directing the legal affairs and public offering efforts in dealing with Fulton
Financial. I have been in recent discussions with the Fulton Financial Board of Directors with regards to
various complaints dealing with such issues as the Resource Bank acquisition and the subpirime failures.
I believe that Fulton Financial needs management to become more aggressive in it's strategic planning
and the performance it expects from it's management team in order to increase shareholder value.
Expanding the footprint of the regional bank has not yielded an increase to the bottonlil line that: is
consistent with the expectations of shareholders. Lancaster County has seen several local banking
institutions acquired by larger regional banks, thus increasing the competition Fulton Financial will see in
it's local marketplace as well as in it's regional footprint.
In 2005 I, that are in current litigation in the
as a Pro Se Litigant filed several civil actions as Plaintiffs
United States District Court for the Eastern District of Pennsylvania, the United States Third District
Court of Appeals, the Pennsylvania Supreme Court, The Pennsylvania Superior Court, the
Commonwealth Court of Pennsylvania, The Court of Common Pleas of Lancaster County, Pennsylvania.
These litigations include violations of intellectual property rights, anti -trust violations, and interfererlice
of contracts relating to several business interests. Central to this litigation is the Digital Movie, Digital
Technologies, Financial Management Group, Ltd, /FMG Advisory, Ltd., and it's affiliated businesses aláng
with a Federal False Claims Act or Federal Whistleblowers Act regarding the firm of International Sigiasi.
and Control, Plc., (ISC) the $1Billion Dollar Fraud and the Export violations of selling arms to Soiii
Africa and Iraq. This litigation dates back to 1987. Stan J. Caterbone was a shareholder of IiSC, and vias
solicited by ISC executives for professional services. The Federal False Claims Act is currently part) of
RICO Civil Complaint in the United States District Court for the Eastern District of Pennsylvania and the
Third Circuit Court of Appeals, as docket no. 05 -2288.

In 2005 Advanced Media Group /Project Hope filed a Civil Action in the Court of Comriion Pleas of
Lancaster County against Drew Anthon and the Eden Resort Inn for their attempts to withhold the
Tourism Tax and Hotel Tax that supports the Downtown Lancaster Convention Center & Marriot. We also
proposed an alternative plan to move the Convention Center to the Hotel Brunswick añd Lancaster
Square to all of the major stakeholders. The Lancaster County Convention Center is finally uncer
construction with a March 2009 Opening date.
In 2005 I was selected to attend the Clinton Global Initiative in New York City after submission of
an essay with and application. I received the invitation from Bruce R. Lindsey, Chief Executive Officer of
the William J. Clinton Foundation

In 2005 I began our philanthropic endeavors by spending our energies and working with such
organizations as; ONE.org, Livestrong.org, WoundedWarriors.org, The Clinton Global Initiative,
Lancaster Convention Center Authority, Lancaster Chamber of Commerce, Tom's Project Hope, People to
People International, GlobalWarming.org, Contact Lancaster /24 Hour Suicide Hotline, Schreiber Pediatric
Center, and numerous others.

Superior Court 1164 Amicus re Kathleen Kane Page 23 of 48 VThursday, April 28, 2016
In 2004 I embarked on our past endeavors in the music and entertainment industries with an emphasis
on assisting for the fair and equitable distribution of artists rights and royalties in the fight against
electronic piracy. We have attempted to assist in developing new business models to address the
convergence of physical and electronic mediums; as it displaces royalties and revenues for those
creating, promoting, and delivering a range of entertainment content via wireless networks'.

In 2000 to 2002 I developed an array of marketing and communication tools for wholesalers of the
AIM Investment Group and managed several communication programs for several of the company
wholesalers throughout the United States and Costa Rica. We also began a Day Trading project that
lasted until 2004 with success.

In 1999 I developed a comprehensive business plan to develop the former Sprecher Brewery, known as
the Excelsior Building on E. King Street, in Lancaster, Pennsylvania. This plan was 'developed in
conjunction with the Comprehensive Economic Development Plan for the Revitalization pf Downtown
Lancaster and the Downtown Lancaster Convention Center for the former Watt & Shand building.

In 1999 I contributed to the debate, research, and implementation of strategies to counter the effects
of the global Y2K threat to the worlds computer technologies. I attended the U.S. Sponsored Y2K
symposium and Conference in Washington, D.C. hosted by the Senate Y2K Subcommittee and Senator
William Bennett.

In 1998 I had began to administer the charity giving of Tom's Project Hope, a non -profit) organizat'on
promoting education and awareness for mental illness and suicide prevention. We had provided fund ng
for the Mental Health Alliance of Lancaster County, Contact Lancaster (The 24/7 Suicide Prevent on
Hotline), The Schreiber Pediatric Center, and other charitable organizations and faith based charities.
The video "Numbers Don't Lie" have been distributed to schools, non profit organizations!, faith ba Eed
initiatives, and municipalities to provide educational support for the prevention of suicide and to bring
awareness to mental illness problems.

In 1996 I had done consulting for companies under KAL, Inc., during the time that I was controller of
Pflumm Contractors, Inc., I was retained by Gallo Rosso Restaurant and Bar to computerized their
accounting and records management from top to bottom. I had also provided consulting for the
computerization of accounting and payroll for Lancaster Container, Inc., of Washington IBoro. I as
retained to evaluate and develop an action plan to migrate the Informations Technologies of the ]ily
Group, formally of Ronks, PA, now relocated to a new $26 Million Dollar headquarters located in WE1,?.st
Hempfield Township of Lancaster County. The Jay Group had been using IBM mainframe technologies
hosted by the AS 400 computer and server. I was consulting on the merits of migrating to a PC based
real time networking system throughout the entire organization. Currently the Jay Group employees
some 500 employees with revenues in excess of $50 Million Dollars per year.

In 1993 I was retained by Pflumm Contractors, Inc., as controller, and was responsible fár saving the
company from a potential bankruptcy. At that time, due to several unpaid contracts, the company was
facing extreme pressure from lenders and the bonding insurance company. We were responsible for
implementing computerized accounting, accounting and contract policies and procedúres, human
resource policies and procedures, marketing strategies, performance measurement reporting, aid
negotiate for the payment of unpaid contracts. The bonding company was especially problmatic, since
it was the lifeline to continue work and bidding for public contracts. The Bank of Lancaster County
demanded a complete accounting of the operations in order to stave off a default on the not=_s and loans
it was holding. We essentially revamped the entire operation. Within 3 years, the company) realized an
increase in profits of 3 to 4 times its previous years, and record revenues.

Superior Court 1164 Amicus re Kathleen Kane Page 24 of 48 VThursday, April 28, 2016
In 1991 I was elected to People to People International and the Citizen Ambassador Prbgram, which
was founded by President Dwight D. Eisenhower in 1956. The program was founded to "To give
specialists from throughout the world greater opportunities to work together an'd effectively
communicate with peers, The Citizen Ambassador program administers face -to -face scientific, technical,
and professional exchanges throughout the world. In 1961, under President John F. Kennedy, the State
Department established a non -profit private foundation to administer the program. We wÉ're scheduled
to tour the Soviet Union and Eastern Europe to discuss printing and publishing technologies with
scientists and technicians around the world.

In 1990 I had worked on developing voice recognition systems for the government's tecynology think
tank - NIST (National Institute for Standards & Technology). I co- authored the article "Escaping the Unix
Tar Pit" with a scientist from NIST that was published in the magazine "DISC ", then one cif the leading
publications for the CD -ROM industry. Today, most all call centers deploy that technology whenever you
call an 800 number, and voice recognition is prevalent in all types of applicatidns involv ng
telecommunications.
In 1989 I had founded Advanced Media Group, Ltd., and was one of only 5 or 6 U.S. domestic
companies that had the capability to manufacture CD- ROM's. We did business with commercial
companies, government agencies, educational institutions, and foreign companies. I performed services
and contracts for the Department of Defense, NASA, National Institution of Standards f;< Technológy
(NIST), Department of Defense, The Defense Advanced Research Projects Agency (DARPA), and the
Defense Mapping Agency, Central Intelligence Agency, (CIA), IBM, Microsoft, AMP, Commodore
Computers, American Bankers Bond Buyers, and a host of others. I also was workiriig with RI.R,
Donnelly's Geo Systems, which was developing various interactive mapping technologies, which is novv a
major asset of Map Quest. Map Quest is the premier provider of mapping software and applications for
the internet and is often used in delivering maps and directions for Fortune 500 companies. We had
arranged for High Industries to sell American Helix, the manufacturer of compact discs, to R!.R. Donnelly.
We had brokered a deal and the executives from Donnelly's Chicago headquarters flew to'Lancasterlto
discuss the deal and perform due diligence of the manufacturing facility located in the Greenfield
Industrial Park.
In 1987 Power Station Studios of New York and Tony Bongiovi retained me as executive producer
of a motion picture project. The theatrical and video release was to be delivered in a digital format; the
first of it's kind. We had originated the marketing for the technology, and created the corrcept for the
Power Station Digital Movie System (PSDMS), which would follow the copyright and marketing formula
of the DOLBY technology trademark.

We had also created and developed marketing and patent research for the development and
commercialization of equipment that we intended to manufacture and market to the recording industry
featuring the digital technology. Sidel, Gonda, Goldhammer, and Abbot, P.C. of Philadelphia 'vas the lead
patent law firm that We had retained for the project. Power Station Studios was the brainchild of Tony
Bongiovi, a leading engineering genius discovered by Motown when he was 15. Tony and Power Station
Studios was one of the leading recording studios in the country, and were responsible for developing Bon
Jovi, a cousin. Power Station Studios clients included; Bruce Springsteen, Diana Ross, Clyndi Lauper,
Talking Heads, Madonna, The Ramones, Steve Winwood, and many others. Tony and Power Station
Studios had produced the original Sound Track for the original "Star Wars" motion picture. It was
released for distribution and was the number one Sound Track recording of its time.

Tony Bongiovi was also active in working and researching different aerospace technologies. * We had
developed and authored a Joint Venture Proposal for SONY to partner with us in delivering the Digii:al
Movie and it's related technologies to the marketplace. The venture was to include the comrriercializati )n
of technologies, which Tony Bongiovi had developed for the recording industry simultaneously with tie
release of the Digital Movie.

Superior Court 1164 Amicus re Kathleen Kane Page 25 of 48 1/Thursday,, April 28, 2016
 I also created the concept for the PSDMS trademark, which was to be the Trademark logo for the
technology, similar to the DOLBY sound system's trademark. The acronym's stand for the Power Station
Digital Movie System. Today, DVD is the mainstay for delivering digital movies on a portable medium, a
compact disc.

In 1987 I had a created and developed FMG Mortgage Banking, a company that was funded by a mejor
banking firm in Houston Texas. We had the capability to finance projects from $3 to $100 rriillion dollars.
Our terms and rates were so attractive that we had quickly received solicitations from developers acrDss
the country. We were also very attractive to companies that wanted to raise capital that include bath
debt and equity. Through my company, FMG, we could raise equity funding through private placements,
and debt funding through FMG Mortgage Banking. We were retained by Gamillion Studios cif HollywoDd,
California to secure financing of their postproduction Film Studio that was looking to relocate to North
Carolina. We had secured refinancing packages for Norris Boyd of and the Olde Hickory aniJ were in :he
midst of replacing the current loan that was with Commonwealth National Bank. We had rilneetings and
discussions with Drew Anton of the Eden Resort, for refinancing a portion of his debt portfolio. We w are
quickly seeking commitments for real estate deals from New York to California. We also had a number of
other prominent local developers seeking our competitive funding, including Owen Kugal, H gh
Industries, and the Marty Sponougle a partner of The Fisher Group (owner of the Rt. 30 Outlets). Ne
were constantly told that our financing packages were more competitive than local institutions.

In 1986 I had founded Financial Management Group, Ltd (FMG); a large financial services organizat on
comprised of a variety of professionals operating in one location. We had developed a stock purchase
program for where everyone had the opportunity for equity ownership in the new firm. FMG had
financial planners, investment managers, accountants, attorneys, realtors, liability insurance services,
tax preparers, and estate planners operating out of our corporate headquarters in Lancaster. In dne
year, we had 24 people on staff, had approximately 12 offices in Pennsylvania, and

several satellite offices in other states. We had in excess of $50 million under management, and our
advisors were generating almost $4 million of commissions, which did not include the fees from the
other professionals. We had acquired our own Broker Dealer firm and were valued at about $3 to $4
million.

In 1985 I developed the Easter Regional Free Agent Camp, the first Free Agent C<jmp for the
Professional Football industry; which was videotaped for distribution to the teams scouting clepartmens.
(See Washington Post 3/4 page article of March 24, 1985) Current camps were dependant ion the team
scouts to travel from state to state looking for recruits. We had developed a strategy of video taping the
camp and the distributing a copy, free of charge to the teams, to all of the scouting departments for
teams in all three leagues FL, CFL and WFL. My brother was signed at that camp by the Otta
Roughriders of the CFL, and went on to be a leading receiver while J.C. Watts was one of the leagues lva
most prominent quarterbacks. My brother also played 2 years with the Miami Dolphins while Dan Mario
was starting quarterback. We were a Certified Agent for the National Football League Players
Association. Gene Upshaw, the President of the NFLPA had given me some helpful hints for my camp,
while we were at a Conference for agents of the NFL. The Washington Post wrote a full -page article
about our camp and associated it with other camps that were questionable about their practices.
Actually, that was the very reason for our camp. We had attended many other camps) around the
country that were not very well organized and attracted few if any scouts. We had about 60 participants,
with one player coming from as far away as Hawaii. We held the camp at Lancaster Catholic, with a
professional production company filming the entire camp, while I did the editing and produced the video.
The well respected and widely acclaimed professional football scout, Gil Brandt, of the Dallis Cowboys,
had given me support for my camp during some conversations We had with him and said he looked
forward to reviewing the tapes for any hopeful recruits.

Superior Court 1164 Amicus re Kathleen Kane Page 26 of 48 VThursday, April 28, 2016
In 1985 I was elected Vice President of the Central Pennsylvania Chapter of the International
Association of Financial Planners, and helped build that chapter by increasing membership 3to 4 times.
We had personally retained the nationally acclaimed and nationally syndicated Financial Planner, Ms.
Alexandria Armstrong of Washington D.C.; to host a major fundraiser. More than 150 professionals
attended the dinner event that was held at the Eden Resort & Conference Center. Ms. Armstrong
discussed financial planning and how all of the professions needed to work together in order to be most
effective for their clients. We attracted a wide variety of professionals including; brokers, lawyers,
accountants, realtors, tax specialists, estate planners, bankers, and investment advisors.IToday, it ias
become evident that financial planning was the way of the future. In 1986 executives approached us
from Blue Ball National Bank to help them develop a Financial Planning department within bank.

In 1984 I had helped to develop strategic planning for Sandy Weill, former President of Citi Group ( :he
largest banking entity in the U.S). We were one of several associates asked to help advise on the future
of Financial Planning and how it would impact the brokerage and the investment industry at large. Mr.
Weil was performing due diligence for the merger of American Express and IDS (Investors Diversified
Services). We were at that time a national leader in the company in delivering Fee Based Financial
Planning Services, which was a new concept in the investment community and mainstreSm investors.
That concept is now widely held by most investment advisers.
Se Litigant
Stan). Caterbone, Pro
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
1250 Fremont Street
Lancaster, PA 17603
www .amaglobalentetainmentgroup.com
scaterbone @live.corn
717- 669 -2163

ACTIVE COURT CASES

J.C. No. 03 -16 -90005 Office of the Circuit Executive, United States Third Circuit Court of
Appeals - COMPLAINT OF JUDICIALMISCONDUCT OR DISABILITY re 15 -3400 and 16 -1149
U.S.C.A. Third Circuit Court of Appeals Case No. 16- 1149;15 -3400; 16 -1001; 07 -4474
U.S. District Court Eastern District of PA Case No. 15- 03984; 14- 02559; 05 -2288; 06 -4650
Superior Court of Pennsylvania Case No. 1561 MDA 2015; 1519 MDA 2015
Lancaster County Court of Common Pleas Case No. 08- 13373; 15- 10167; 06- 03349, CI -06 -03401
U.S. Bankruptcy Court for The Eastern District of Pennsylvania Case No. 16 -10157

Superior Court 1164 Amicus re Kathleen Kane Page 27 of 48 UThursday, April 28, 2016
 EXHIBIT

Superior Court 1164 Amicus re Kathleen Kane Page 28 of 48 Thursday, April 28, 2016
 Stan 7. Caterbone
ADVANCED MEDIA GROUP
p roó_
% FromOCovert
Freedom From Covert Harassment Si Surveillance,®
Registered in Pennsylvania
1 1250 Fremont Street
'Kf i'asuceit & siirve{llame
Lancaster, PA 17603
www .amgglobalentetainmerltgroup.c )m
scaterbire @live.com
717- 669 -2163

April 16, 2016

My Story of Victimization for Derrick Robinson's Document to the FBI

In 1987 I became a federal whistleblower for the case of local defense contractor International
Signal and Control, or ISC. ISC was a black ops program for the NSA and CIA that was convicted in
1992 for an elaborate scheme to arm Iraq and other Middle Eastern countries with a broad array of
weapons, most notably cluster bombs. It was the third larges fraud in U.S. History at thatItime. I have
been a victim of organized stalking since 1987 and a victim of electronic and direct energy weapons
since 2005. I had also been telepathic since 2005. In 2005 the U.S. Sponsored Mind Control turned
into an all -out assault of mental telepathy; synthetic telepathy; hacking of all electrónic devices;
vandilism and thefts of personal property, extortions, intellectual property violations, obstruction of
justice; violations of due process; thefts and modifications of court documents; and pain and torture
through the use of directed energy devices and weapons that usually fire a lore frequency
electromagnetic energy at the targeted victim. This assault was no coincidence in ttiat it began
simultaneously with the filing of the federal action in U.S. District Court, or CATERBONE w. Lancas:er
County Prison, et. al., or 05 -cv -2288. This assault began after the handlers remotely
trained /sychronized Stan J. Caterbone with mental telepathy. The main difference opposed to most
other victims of this technology is that I am connected 24/7 with the same person v'ho declares
telepathically she is a known celebrity. Over the course of 10 years I have been telepathic with at least
20 known persons and have spent 10 years trying to validate and confirm their identities without
success. Most U.S. intelligence agencies refuse to cooperate, and the Federal Bureau of investigation
and the U.S. Attorney's Office refuse to comment and act on the numerous formal complaints that are
filed in their respective offices. Most complaints are focused on the routine victimization's óf a targeted
individual including but not limited to stalking, harassment, threats, vandalism, thefts, extortion,
burglaries, false imprisonments, fabricated mental health warrants or involuntary commitments, pain
and torture to the body, and most often the cause of obstruction of justice is the computer hacking.

I have a very sophisticated and authentic library of evidence of the use of U.S. Spoñsored Mind
Control technologies on my father and brother that dates back to the 1940's while my father was in tiie
U.S. Navy after he graduated with honors from Air Gunners School in Florida, including an affidait
motorized and authenticated by my father in 1996. My brother served in the U.S. Air force and was
victim to LSD experiments of the infamous MKULTRA program in the late 1960's.

Superior Court 1164 Amicus re Kathleen Kane 1 Page 29 of 48 Thursday, April 28, 2016
 In 2015 I filed an amicus curie on behalf of Lisa Michelle Lambert who was convicti d in 1992 of
the murder of Laurie Show, both of Lancaster, Pennsylvania. I currently am in litigation in t!.he U.S. Third
Circuit Court of Appeals and in February of 2016 Lisa Michelle Lambert published her book titled
"Corruption in Lancaster County - My Story ", which is available in bookstores and on Amazon.com, I
am in frequent contact with her co- author, Dave Brown of Philadelphia, Pennsylvania.

In 2009 I Proposed an ORGANIZED STALKING AND DIRECTED ENERGY WEAPONS HARASSMENT

BILL to Pennsylvania House of Representative Mike Sturla (Lancaster, Pennsylvania) and City of
Lancaster Mayor Richard Gray in 2009. The draft legislation is the work of Missouri House of
Representative Jim Guest, who has been working on helping victims of these horrendous crimes for
years. The bill will provide protections to individuals who are being harassed, stalked, harmed by
surveillance, and assaulted; as well as protections to keep individuals from becoming hurhan resea -ch
subjects, tortured, and killed by electronic frequency devices, directed energy devices, replants, and
i

directed energy weapons. I again reintroduced the bill to the Pennsylvania General Assembly in 2015
and frequented the Pennsylvania Capitol trying to find support and a sponsor; which I still do to tuffs
day.

In 2005 I, as a Pro Se Litigant filed several civil actions as Plaintiffs in the United i

States District Court for the Eastern District of Pennsylvania, the United States Third District
Court of Appeals, the Pennsylvania Supreme Court, The Pennsylvania Superiori Court, the
Commonwealth Court of Pennsylvania, The Court of Common Pleas of Lancaster Couni:y,
Pennsylvania. These litigations included violations of intellectual property rights, anti -trust
violations, and interference of contracts relating to several business interests, harassment,
extortion, fraud, etc.,. . Central to this litigation is the Digital Movie, Digital Technologies,
Financial Management Group, Ltd, /FMG Advisory, Ltd., and it's affiliated businesses along
with a Federal False Claims Act or Federal Whistleblowers Act regarding the firm of
International Signal and Control, Plc., (ISC) the $1Billion Dollar Fraud and the Expcit
violations of selling arms to South Africa and Iraq. This litigation dates back to 1987. In
1987 I microfiched some 10,000 pages of documents that prove this story without any doubt.
I also have recorded conversations of persons and government officials.

Stan J. Caterbone, Pro Se Litigant

ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
1250 Fremont Street
Lancaster, PA 17603
www. amciglobalentetainmentgroup.com
scaterbone @live.com
717- 669 -2163

ACTIVE COURT CASES

J.C. No. 03 -16 -90005 Office of the Circuit Executive, United States Third Circuit Court of
Appeals - COMPLAINT OF JUDICIALMISCONDUCT OR DISABILITY re 15 -3400 and 16 -1149
U.S.C.A. Third Circuit Court of Appeals Case No. 16- 1149;15 -3400; 16 -1001; 07 -4474
U.S. District Court Eastern District of PA Case No. 15- 03984; 14- 02559; 05 -2288; 06 -4650
Superior Court of Pennsylvania Case No. 1561 MDA 2015; 1519 MDA 2015
Lancaster County Court of Common Pleas Case No. 08- 13373; 15- 10167; 06- 03349, CI -06 -03401
U.S. Bankruptcy Court for The Eastern District of Pennsylvania Case No. 16 -10157

Superior Court 1164 Amicus re Kathleen Kane Page 30 of 48 Thursday, April 28, 2C 16
 Caterbone Affidavit

AFFIDAVIT

l, .ept.; 4 t7 aibree.a644-le a residing at:

Address: _fa-74 14444$(1.4-

City, Stato, Zip Coda; ...etz ref_ "7 14.4

do hereby state that am at least 1$ years of age, that lama citizen or a legal resident of the
I

United States Of America, that I am of sound mind, and that am the person whose signature
J

follows on this Affidavit, The purpose of this document Is (1) to advise Congress as well as sta :e
and local officials of organized stalking and electronic and mind manipulation trxrtu a being
committed against me and (2) to request a state, local, or Congressional investigation and
hearing on the use of remotely- operated directed energy attacks and mind control technologies
on Americans in this country.

Our Government Is responsible for protecting its citizens from elements that covertly harass,
torment, murder, andcause victims to commit suicide through organized stalking and remote
electronic torture. Yet, unbiased research indicates that certain elements of Government either
engage in these act vities or protect those who perform theM. i seek the complete dismantling
of a ny officially-sanctioned covert Government torture programs, the passage of legislation
specifically outlawing that high -tech torture, and the full prosecution of any person, regardless
of his rank or position, who has violated my civil rights an cl my molt basic human rights.

The assaults on my mind and body have been occurring fort V year(s) or month(s) a ld
include, but are not limited to the following (checked below);

blanketing my dwelling and surroundings with electromagnetic energy,

/invading my thoughts viaremote sensing technologies.

,)TTA
f making me mentallyc M.MDr1lcAllt
laa+r others' tiwtts through the .microwave healing effect.

/depriving me of sleep due to neurological intervention.

introducing poisonous as and radiation toxins into my home. Ct4 r. a a "ply C.M E', 4:2n+60 4,4`/

Li/having me stalked me en masse on foot and In vehicles, Ak 8.c -4CT2 .)

vandalizing my borne and /or car.

(appFrig my phones and hacking my computer,' ,6 c/a drstfzr-Æ`°C-6 /A.) .++y dams. 1 6.04"rB above

Superior Court 1164 Amicus re Kathleen Kane Page 31 of 48 Thursday,April 28, 2016
Stan J Caterbone Affidavit

blacklisting-riiin the labor market

"workplace mobbing'.

bombarding my body with debilitztiing electronic and mind manipulation effects.

The acts described above violate many laws aimed at protecting Americans. Some of these Taws
-are:

IC USC 921', Article 121 - Laroen_y antYwrorigf lrl-appro rIation:

10 USC 920A, Arti cle 1,20a = SIkirg

18 2340 USC - Torture

18 USC 241 - Conspiracy against rights, of sovereign free; 606- reared, spilt 4nd soul beiflgs

18 USC 213 - illegal Surreptitivifs.entry

18 USC 242 - Deprivation-of.rights ;In der.color of law

18 USC 35 - Imparting or conveyingfalse information
18 USC 1117 - Conspiracy to Murder
18 USC 1111- Murder

18 USC: - Dlsclosure of Information generally

1905

42 USC 19$3 - action for deprítwatóon of rights

CPwll

42 USC 1985 - Conspiracy tp interfere with civil rights

31 USC 532,8- Whistlebbwier protections

18 USC 151.2 - Engaging in miu-ieading conduct

18 USC 1503 -- intimidating a witness }victim

18 USC 1512 - Tampering with a Mine-Wyk-tun

18 USC 1513 - Retaliation against a witness/victim

Superior Court 1164 Amicus re Kathleen Kane 3 Page 32 of 48 Thursday, April 28, 2016
Stan J. Caterbone Affidavit

18 USC 1510 - Obstructing a criminal investigation, conflict of interest roles in governmen

18 USC 1509 -
Impeding due exercise of rights by attempting to prevent, obstruct, Impede and
Interfere with same

18 USC 1622 - Subordination of perjury by procuring another to commit perjury

AFFIRMATION

Iaffirm that the statements in this Affidavit concerning my torture and the results of that
torture are true and correct. fúrther affirm that those statements are based on my own direct
I

knowledge, personal experience, research,, and known and published historical fact_

Affi ant (signature)

Name (print):

Date: -

Stamp & Sèal:

NOTARIAL SEAL
GLORIA COLON
Notary Publro
LANCASTER GIN. LANCASTER COUNTY
My CorfttrllsslGn Expires Dao 12. 2DT T'

Superior Court 1164 Amicus re Kathleen Kane Page 33 of 48 Thursday, April 28, 2016
Stan J. Caterbone Affidavit
AFFIDAVIT

I, Stanley J. Caterbone, Targeted Individual or TI, residing at: 1250 Fremont Street,
Lancaster, Pennsylvania, 17603, do hereby state that I am at least 18 years of age, that I am
a citizen or a legal resident of the United States of America, that I am of sound mind, ¿)nd that I
am the person whose signature follows on this Affidavit. The purpose of this document: is (1) to
advise Congress as well as state and local officials of organized stalking and electronic and mind
manipulation torture being committed against me and (2) to request a state, local, or
Congressional investigation and hearing on the use of remotely- operated directed energy attacks
and mind control technologies on Americans in this country.

Our Government is responsible for protecting its citizens from elements that
covertly harass, torment, murder, and cause victims to commit suicide through
organized stalking and remote electronic torture. Yet, unbiased research indicates that
1

certain elements of Government either engage in these activities or protect those whi) perform
them. I seek the complete dismantling of any officially- sanctioned covert Governmeript torture
programs, the passage of legislation specifically outlawing that high -tech torture, and the full
prosecution of any person, regardless of his rank or position, who has violated my civil rights and
my most basic human rights. The assaults on my mind and body have been occurring for 24
year(s) and include, but are not limited to the following victimization's:

1. Blanketing my dwelling and surroundings with electromagnetic energy.

Bombarding my body with debilitating electronic and mind manipulation effects.
Directed Energy Weapons Causing Severe Pain to Body and Brain. Began in at cast 2005 I

and still continuing, with complaints to Freedom From Covert Harassment and Surveillance, FFCHS
in 2009, and in cited in various state and federal court cases over the past several years.
Attacks causing severe artificial pain most likely from Directed Energy Devices synchronized with
telepathic harassment and organized stalking and harassment have been logged and reported to
law enforcement and medical professionals since 2008. Prior to 2008 the attacks were
experienced and reported to medical professionals but the sources were not known. AlsCI reported
attacks of pain to a family physician, emergency room personnel and psychiatrists.

2. Invading my thoughts via remote sensing technologies. Was sent an autonomous

email in 1998 introducing the term remote viewing. Various technologies and tactics are being
used to create "emotional signatures" that induce various emotional states; a systematic complete
hacking of my mind.

3. Making me mentally "hear" others' voices through the microwave hearing effect.
Synthetic and /or Mental Telepathy. First started to experience telepathy/synthetic telepathy
in 2005 with full -time 24/7 connection during the same time to present. When full -time telepathy
started a male conducted interrogations lasting several hours at a time concerning a wealth of
subjects including ISC /CIA Knowledge. Cannot disconnect from continuous conversati ins at all
times with one female person. The handlers know everything I know and experience in real time.
During 2006 and 2007 have been telepathic with some 10 or more persons, both male and female
for short durations. Can recall most conversations and subject matter with identities of who they
said they were. Interrogation type harassment is still being used telepathically to harass and for
some sleep deprivation. Made first complaints to DARPA, the FBI, and U.S. Senator Arlen Specter
in 2007. Some conversations by the persons that are telepathic with me elude to some program
similar to the DARPA datalog program where they record your entire life. Everything that you try
to do on a daily basis is subject matter for conversation and harassment. Interference with
thought, harassment, and interrogation is used often times with electromagnetic weapon attacks
to the brain or body.

Superior Court 1164 Amicus re Kathleen Kane Page 34 of 48 Thursday; April 28, 2016
Stan J. Caterbone Affidavit
e
4. Depriving me of sleep due to neurological intervention. Mostly Experiençed Sleep
Deprivation Techniques during periods of time in 2008 to 2010. Mostly with attacks of 'pain from
Directed Energy Weapons to back, neck, head (brain); and heart on a few occasions;( and with
harassment from telepathy.

5. Introducing poisonous gas and radiation toxins into my home. First experienced
toxic gases (Chloroform ?) in heavy doses in 2006 -2007. Made complaints to the Lancaster City
Police Department and the Southern Regional Police. Experienced attacks that would cause
dizziness at home, in automobile and in public. Was informed it was being released through a
distribution system the size of fishing line. To counter attacks used cotton in nostrils, and gas
mask. In 2009 experienced attacks of what is said to be sleeping gas, when attacked could not
open eyes. Took Pictures during some attacks.

6. Having me stalked en masse on foot and in vehicles. vandalizing my horn! and /or
car. Gang Stalking or Organized Stalking began in 1987 and continues today. It includes
strangers using gestures such as finger under eye; various forms of harassment; and public
mobbing. Complaints have been filed in 1987; 1992;1998 and 2005 to 2010. Complaints were
made to various public officials and local, state, and federal agencies as mental duress. The terms
organized stalking, gang stalking, targeted individual, etc., was not learned until a few years ago.
The organized stalking and harassment followed in several states, some while traveling from
Lancaster, Pennsylvania to California. Tracking technologies may have been used and most likely
are still being used. Police were involved in most places.

7. Tapping (Bugging) my phones. Complaints of phone tapping /tampering were made to

New Jersey Bell in 1987 with a service call to Stone Harbor, New Jersey to check lines anil phones.
The same was done by a Bell Atlantic repairman in Conestoga, Pennsylvania in 1998. in 2004 a
complaint with a report number was filed with the Pennsylvania Attorney General Office in (

Pittsburgh, Pennsylvania (Agent Amy Zelnick) regarding interference with phone calls and
impersonations by perps intercepting and rerouting calls. Computer Hacking complaints Iiiivere filed
to local authorities in the County of Lancaster and the Cyber Crime unit of the Federal l3ureau of
Investigation in 2005 to 2010.

8. Blacklisting me in the labor market. Filed complains of employment discrimination with

the Pennsylvania Attorney General in 2006 and the Lancaster County Human Relations
Commission in 2008.

9. Workplace mobbing. Experienced in 1987 at Financial Management Group, Ltd.,

American Helix of High Industries in 1991 and Pflumm Contractors, Inc., in 1997/1998. Filed
complaints and logs as mental duress and harassment. Was forced out of all 3 organizations as a
result of the mobbing and harassment.

10. Public Mobbing. Public type mobbing and organized stalking and harassnlient was
perpetrated heavily in the years 2005 to 2010 in the following places: The Lancastel;r County
Courthouse, The Lancaster County Public Library, the Pennsylvania Career Link, and the hilillersville
University Library and University Offices. I was given suspicious and illegal "No Trespass" Notices
in some 18 public places in Lancaster County in the years 2005 to 2009 without just cause. I was
complaining of stalking and harassing in most all of those public places. The Lancaster County
Public Library and the Millersville University took away my access to a computer after my' personal
computers were vandalized and /or hacked inoperable. Fulton Bank took away my safe deposit
box. Others included my church of worship, various bars and restaurants and one attornieys office
Complaints have been filed regarding the same in courts and with various authorities.

Superior Court 1164 Amicus re Kathleen Kane Page 35 of 48 Thursday, April 28, 2016
Stan J. Caterbone Affidavit

11. Attempted Murder. Experienced with an attempt of vehicular homicide in 111991 after
National News Media reported ISC /CIA -NSA connection of "Arms to Irag ". The incident involved a
vehicle changing lanes and direction and heading directly toward me in the wrong direction
running me off the road, narrowly missing a tree. I Filed the incident in federal courts and used
as a motion to seal federal case no. 05 -2288 in 2005 in the United States District Court for the
Eastern District of Pennsylvania.

12. Pet Killing. Cat was killed in 2005 with complaints to the Lancaster County Humane
Shelter and the Southern Regional Police Department.

13. Illegal Entries of Home /Properties. First in 1987 in Stone Harbor, New Jersey, then
again in 1991; 1997 -1998; and most serious in 2005 to 2010. Filed Police Reports and insurance
claims, most with the Southern Regional Police Department of Conestoga, Pennsylvania , State
Farm and Harleysville Insurance Companies.

14. Illegal Repossessions. Airplane in 1987 containing legal and business files.
Home /Property and Contents in 2006 also containing legal and business files and documents.

15. Physical Assaults. One attack and filed complaint with police report in Los Osos alifornia
in 2005 and one in the City of Lancaster. Police reports were filed and obtained for both.

16. False Arrests. Experienced 7 in 1987 and more than 20 in 2005 and 2006 in the
Commonwealth of Pennsylvania Lancaster County Court of Common Pleas. The false arrests were
charges that were all dismissed prior to court hearings.

17. False Imprisonments. Spent 7 to 10 days in Lancaster County Prison in 1987 with all
charges dismissed and again for some 60 days in 2006 with all charges dismissed. The 60 Days of
imprisonment of 2006 was triggered with a false report of missing a bail supervision meeting,
which was confirmed to be false in court; however bail was maliciously and purposefully reinstated
as secured instead of unsecured. The appropriate appeal was filed which secured my release after
some 60 days of false imprisonment. There were no charges that resulted in any convictions.

18. Psychiatric Abuses with False Suicide Allegations from Perpetrators /Stalkers. One
in 1987 resulting in a forced hospitalization for several hours by police in Stone Harbor, New
Jersey. And one again in February of 2005 resulting in police restraining me in my home and
abusing me. This one was a fraudulent and phony email sent to police by a perp. The Southern
Regional Police had to vacate after the email was proven to be a fraud.

19. Vandalism to Property. First in 1987 in Stone Harbor, New Jersey, then again in 1991;
1997 -1998; and most serious in 2005 to 2010. Filed Police Reports and insurance claims, most
with the Southern Regional Police Department of Conestoga, Pennsylvania and Harleysville
Insurance Company. 3 computers have been rendered inoperable since 2005 along with various
electronics equipment; dvd recorders; printers; household items; appliances; etc., Most nsurance
claims have been paid. In the past years a wave of purchased items, online and in stores, were
received broken or the wrong item and all had to be returned. Some included items to secure my
property, and others included computer related items, others were household and clothing items.

20. Gas Lighting. The illegal entering of home and causing psychological duress by moving
items and or hiding items. First reported in 1998 to the Conestoga Police and continued to
present. Clothing was also manipulated and altered. The term "gas lighting" was only Learned in
2010, although it was reported to police as harassment by neighbors of friends. The daily draining
of my hot tub was also used as a psychological warfare tactic and used to run up utility bills.
Numerous complaints were made to police in 2008 to 2010.

Superior Court 1164 Amicus re Kathleen Kane Page 36 of 48 Thursday, April 28, 2016
Stan J. Caterbone Affidavit

21. Thefts of Property. Not Yet Completed.

22. Vandalism to Car /Truck. Since 2005 have experienced years of gas siphoning, battery
outages, letting air out of tires, and wetting of inside of floor mats as psychological warfare tactics
by perps and stalkers. Made numerous complaints the Lancaster City Police Department.

23. Toxic Chemical Causing Running Nose. Experienced on regular basis in 2009 when in
public places. Was not in conjunction with cold /flu symptoms. Research states it is a tactic used
in organized stalking.

24. Computer Hacking. Computer Hacking complaints were filed to local authoritiies in the
County of Lancaster and the Cyber Crime unit of the Federal Bureau of Investigation iri 2005 to
2010. Numerous complaint numbers have been secured. Complaints of cell phone hacking was
also reported in 2010. Websites and blogs were regularly hacked and sometimes takers off -line.
Electronic calenders, court documents, and financial records were often hacked causing many
problems of the years, including having to withdraw civil complaints.

25. Cyber Stalking. Most in 2005 to 2010. Complaints to Microsoft legal counsel, Yahoo
Message Board, and the FBI Cyber Crime Unit.

26. Interference /Delay /Theft of U.S. Mails. First reported to U.S. Postmaster- of mail
tampering and illegal changing of address in 1987. In 2008 to 2009 have made several more
complaints to the U.S. Postmaster Inspector General who claim to have begun investigations.
Some caused missed court hearings and other missed appointments and or meetings.

27. Electromagnetic Weapons Causing Severe Muscle Spasms /Cramps First

experienced in 2006 to present. One experience in 2006 was while I was in my hot tub and the
pain and cramp was so severe in my left calf muscle (you automatically bend over to r.ib it out,
which placed my head underwater) I had to crawl out of the hot tub before almost drowning.

28. Electromagnetic Weapons Causing Sexual Stimulation. First experienced in 2005.

29. Forced Hospitalizations. Forced Hospitalizations in 1987 (2) one for 6 hours and one for
5 days; 2006 one for 3 days; 2009 one for several hours while in intensive care for emergency
surgery; and 2010 one for 8 days. Filed complaints to Citizens Commission for Human Rights in
1991 and 2008.

30. Manipulation and Theft of Documents. Numerous thefts and manipulation ot all legal
and business documents both in paper and in electronic format have occurred since 1987.
Microfiche /Microfilming began in 1987 and other measures to secure documents have been
ongoing to present. Numerous complaints have been filed with law enforcement since 1937.

Superior Court 1164 Amicus re Kathleen Kane Page 37 of 48 Thursday, April 28, 2016
Stan J. Caterbone Affidavit
Statement: I have been a Targeted Individual, TI, and Victim since 1987. In 1987 I blew the
whistle (public Allegations and Complaints to State and Federal Authorities of Fraud during merger
negotiations with British Defense Contractor Ferranti International) on an international defense
contractor named International Signal & Control, or ISC, who was selling arms (Everything from
Telemetry Systems to Cluster Bombs) to Iraq via South Africa and was convicted of a $1 Billion
dollar Fraud in 1992 by the United States Attorney and several other federal agencies. See
ABC /News 20/20 and Nightline in 1991. They were founded and headquartered in my hometown
of Lancaster, Pennsylvania. I was a shareholder and was solicited by a top ISC Executives
(Convicted as a Mastermind of the Billion Dollar Fraud) to help finance some of their operations
through an affiliate called United Chem Con. ISC was a Department of Defense (DOD) Contractor
and a partner with United States Intelligence Agencies since it's beginnings in the early 1970's.
One of it's first contracts was Project X with the National Security Agency or NSA of Ft. Meade,
Maryland. Former Secretary of the Navy, Bobby Ray Inman was on the Board of Directors of ISC
and was also on the Board of Directors of Science Applications International Corporation) or SAIC.
SAIC was a huge defense contractor that was the recipient of the Defense Intelligence Agency, or
DIA, program on Remote Viewing, which SAIC named Project Stargate. It was reported that
Bobby Ray Inman declined the nomination for Secretary of Defense under the first Clinton
Administration because of the ISC and Trecor scandals. In the early 1990's I was a subcontractor
on a project for the Defense Advanced Research Project Agency, or DARPA, with the National
Institute of Standards and Technology, or NIST called TIMIT. The project developed speech
corpora for the development of computer based speech recognition systems. I was also involved
in the bidding of other Department of Defense contracts dealing with information technologies. In
1998 I was stalked and approached by an employee of the National Security Agency, or NSA in
York, Pennsylvania who said my problems were not with the NSA, but the "good ole boys ". In
2005 I was detained by 2 Defense Intelligence Agency, or DIA officers in a museum on 3 military
base in Austin, Texas and was questioned and interviewed regarding my civil actions filed in
federal court for several hours. I was released and told to stay off of all military bases. My
brother, a Family Physician in Austin Texas had to verify my travel plans and the fact that I was
staying with him prior to my release.

My father alleged he was part of U.S. Navy experiments in the 1940's and experienced
synthetic telepathy in the 1970's, 1980's and 1990's as outlined in memos and documents he had
authored; and from my personal conversations with him prior to his death. Ms. Amy Fuchs of the
Disclosure Project confirmed that he was most likely given an ET experience via (synthetic
telepathy. He died in 2001 in New York City of cancer. My brother was in the U.S. Air Force in the
late 1960's and I allege was a victim of the LSD experiments relating to MKULTRA in' the late
1960's and a victim of murder (Suspicious Suicide with tainted medical reports) in Santa Barbara
California in 1984; Notarized Complaints were filed to the California Attorney General in 1991. He
made a declaration type statement prior to his death that he got "bad LSD" while in the U.S. Air
Force.

Organized stalking and harassment began in 1987 following the public allegations of fraud
within ISC. As far back as the late 1980's I thought that my mind was being read, or "remotely
viewed ". During the times that legal Counsel and attorneys were solicited in 1987, 1991, and
1997 Organized Stalking and Harassment and other forms of attacks experienced by Targeted
Individuals were severely increased. In 2005 the U.S. sponsored mind control turned into an all -
out assault of mental telepathy; synthetic telepathy; and pain and torture through the use of
directed energy devices and /or electromagnetic weapons. This assault was no coincidenc;.e in that
it began simultaneously with the filing of the federal action in U.S. District Court, of CATERBONE v.
Lancaster County Prison, et. al., or 05 -cv -2288.

This targeting has ruined every aspect of my life.

Superior Court 1164 Amicus re Kathleen Kane Page 38 of 48 Thursday,lApril 28, 2016
Stan J. Caterbone Affidavit

Some Perspectives
"The calculated and technological entry into another person's mind is an act of monumental bar-
barism which obliterates- perhaps with the twiddling of a dial - the history and civilization of
man's mental development. It is more than an abuse of human rights, it is the destruction of
meaning. For anyone who is forced into the hell of living with an unseen mental rapist, the effort
to stay sane is beyond the scope of tolerable endurance. The imaginative capacity of the ordinary
mind cannot encompass the horror of it. We have attempted to come to terms with tke experi-
ments of the Nazis in concentration camps. We now have the prospect of systematic control au-
thorized by men who issue instructions through satellite communications for the destruction of
societies while they are driving new Jaguars and Mercedes, and going to the opera."
"On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mind Invasive
Technology "by Carole Smith
Global Research, October 18, 2007; Journal of Psycho -Social Studies, 2003.

"People have no comprehension of how lethal only one aspect (aside from the obvious Df driving
the victim completely insane) of telepathy technology can be in disrupting and ruining an individ-
ual's life through the sabotaging of his /her daily activities. Everything an individual does begins
with a momentary thought. From the split second that thought is learned by the person on the
other end (telepathically) - the individual's right to privacy is not the real threat or loss. The real
lethal weapon is the advantage in disrupting or preventing the individual from accomplishing
whatever he/she is going to do before they actually do it. With a simple cell phone call or instant
message, the "Advanced Team" is in place to subvert; sabotage; manipulate; propagandize;
smear; disrupt; or even prevent the task or activity from being accomplished in any successful
manner. The perps are skilled at creating scenarios that are covertly arranged to simulate every-
day occurrences to make the victim at fault for the loss or failure. Imagine the consequences
when these activities have legal and financial implications. With telepathy technology the need for
tracking and surveillance technology is greatly diminished and may even become obsolete. This is
not merely "Mind Invasive" Technology, as Carole Smith so eloquently wrote - this is "LIFE Inva-
sive" Technology ". Say Goodbye to any true sense of capitalism and free enterprise in the not to
distant future - unless of course someone stops these illegal and disastrous technology transfers
and leaks ".
Stan J. Caterbone

Organized or Gang Stalking

"A system of organized psychological terror tactics used against a person who has beconilie an en-
emy of an individual or a government. Subtle but effective techniques of stalking by multiple indi-
viduals and psychological intimidation and manipulation are used to slowly but surely drive the
target to make complaints to authorities who will see the complaints as bogus because of the
methods used against the target. As a result, the target gets labeled as mentally ill.

There are as many stalking tactics as there are targets as the multistalkers will tailor th4 stalking
to the individuals habits and individual personality. Some common examples or organized stalking
are: following the target on foot, by car and public transportation, crowding the target's space in a
public place, murmuring insults under the breath so only the target can hear, sitting iii the car
outside the target's residence, starting "fights" in public with the target, doing "skits" on the
street which involves information only the target should know but has been found out vi a surveil-
lance of the target, stealing and vandalism of the target's possessions."
Organized Stalking Website

"Organized Stalking is a form of terrorism used against an individual in a malicious attempt to

reduce the quality of a person's life so they will: have a nervous break -down, become (incarcer-
ated, institutionalized, experience constant mental, emotional, or physical pain, become home-
less, and /or commit suicide. This is done using well- orchestrated accusations, lies, rumors, bogus
investigations, setups, framings, intimidation, overt or covert threats, vandalism, thefts, sabo-
tage, torture, humiliation, emotional terror and general harassment. It is a "ganging up" by mem-
bers of the community who follow an organizer and participate in a systematic "terrorizing" of an
individual." Mark M. Rich

Superior Court 1164 Amicus re Kathleen Kane 3 Page 39 of 48 Thursday, April 28, 2016
Stan J. Caterbone Affidavit
The acts described above violate many laws aimed at protecting Americans. Someof thE:se laws
include but are not limited to the following:
10 USC 921, Article 121 -- Larceny and wrongful appropriation
10 USC 920A, Article 120a -- Stalking
18 2340 USC -- Torture
18 USC 241 -- Conspiracy against rights of sovereign, free, God created, spirit and soul
beings
18 USC 213 -- Illegal Surreptitious entry
18 USC 242 -- Deprivation of rights under color of law
18 USC 35 -- Imparting or conveying false information
18 USC 1117 -- Conspiracy to Murder
18USC1111 -- Murder
18 USC 1905 -- Disclosure of information generally
42 USC 1983 -- Civil action for deprivation of rights
42 USC 1985 -- Conspiracy to interfere with civil rights
31 USC 5328 -- Whistleblower protections
18 USC 1512 -- Engaging in misleading conduct
18 USC 1503 -- Intimidating a witness /victim
18 USC 1512 -- Tampering with a witness /victim
18 USC 1513 -- Retaliation against a witness /victim
18 USC 1510 -- Obstructing a criminal investigation, conflict of interest roles in
government
18 USC 1509 -- Impeding due exercise of rights by attempting to prevent, obstruct,
impede and Interfere with same
18 USC 1622 -- Subordination of perjury by procuring another to commit perjury

(Optional) I have attached a personal message (check).

AFFIRMATION
I affirm that the statements in this Affidavit concerning my torture and the results of
that torture are true and correct. I further affirm that those statements are based on
my own direct knowledge, personal experience, research, and known and published
historical fact.

Affiant (signature) ea&26e)14.

Name (print): Stan J. Caterbone

Date: June 19, 2015

State of Pennsylvania County of

Lancaster

Sworn before me this 19 day of June 20 15

Stan J. Caterbone - was a notary from '94 -'98

I
, Notary Public Exp.: Don't Know When

Freedom From Covert Harassment & Surveillance. All rights reserved. Copyright © 2010 (This is an amended
form of the original Affidavit of September 2010 from Freedom From Covert Harassment & Surveillance.)

Superior Court 1164 Amicus re Kathleen Kane Page 40 of 48 Thursday, April 28, 2016
Samuel P. Caterbone Jr., (Father) Affidavit

FIELD OF DREAMS 11

THIS STORY FIRST STARTED IN 1957 Ì

Video came in 1973 and Audio in 1984 and before that it was
sort of psychic with felt impressions and today a Human Radio.

The same following information was given to the Doctor for

searching the internet and continues to be worth $1000.00.

Sam Caterbone
VIDEO
How can the eye project the same image on any surface and it
be a independent intellegent entity.
This eye projection exists every conscious moment with or
without my awareness.
I cannot accept the brain or mind to be responsible.

EYE PROJECTION IMAGE

Its own mobility of movement within the space of sight
independent of my eye control.
Two female facial images larger then a silver dollar on any wall
who simulate a computer orgin model with each having their 1

own personality.
A eye projection in vivid color that is lively and simulates1
being of a computer control orgin.
For communication the eye projection uses a coded system of
colors and numbers.

EYE PROJECTION COMMUNICATION

The total eye projection is constanly flashing with dots in
color at a speed only a computer mind can interpert. 1

When directed to myself the dots appear so I can interpert.

The facial parts are used thru dots and facial expressions.
The clock posistions sometimes with hands are used for numbers
and time.
The two facial images are side by side and one is smaller and
can direct themselves to look up, down, to the side and
facing each other.

AUDIO
Male and female people talking in a audio pipeline at 3 locations
Each location has its own voice ID.
They use my eyes, my ears and talk about everything I know and
whereever I go and do it all better then I.
Audio sees Video and Video hears Audio.
Apartment 309, the mailing list and the envirement other then
309 is their conversation with TV and the local paper.

Superior Court 1164 Amicus re Kathleen Kane Page 41 of 48 Thursday, April 28, 2016
THE ADVANCED MEDIA GROUP Page 35 of 41 06/10%2007
 e
Samuel P. Caterbone Jr., (Father) Affidavit

INTEGRITY.

This writing with the dateline September 1996

intends to focus on integrity, my integrity and aliso your
integrity. Your lack of interest is obvious and I would say
this is the nineties and this type of story does not jell
regardless of value. Then again the investigative value
associated to the Extraterrestrial phenominon is a fact the
Media does concur with. Looking back at when this hi- profile,
mailing list started in July 1994 and expanded to a final count
of fifty does suggest something. Whatever those conclusions
I can only imagine. However for the value contained in this
story this mailing list is most proper. Aliso adding that I
think I am the most advanced in the phenomena of Extraterrestrial
information. Saying this because I am a legitimate and
scientific valid Human Radio. A Human Radio that operates in
the micro -range of biological radio frequency communication
that is both audio and video. A technology situation that is
not known to this World. My confidence of this value allows
this mailing situation to be taken one step further. Therefore
to encourage incentive to challenge this break -thru story a
special account of one thousand dollars has been opened with
the Core States Meridian Bank (717)569 -8731. Showing I am
dead serious in being equal to the contemporary rational of
Aatronomers using radio telescopes to investigate the
Exraterrestrial. Finally a name and number will allow a phone
call at my expense to continue this writing on Integrity.

Remember the challenge $1000.00 to debunk my direct communication

with the Extraterrestrial that is both audio and video. These]
Extraterrestrials are people who are at a specific place
with technology.

Sam Caterbone

Dr.Taylor:

If you and your colleagues can find a comparable Case Historyl

of my Audio and Video situation anywhere on the Internet that
is recorded and not hear -say and would prove the above hi -lite
wrong I promise to pay one -thousand dollars.

S C.rt ip ed a+- A114 r»^etJ b e:3o re-

t V,. clay Or De.#,lv,
NOTARIAL SEAL
f)-Nr%110.44
Joanne B. May. Notary Public
Superior Court 1164 Amicus re Kathleen Kane Page 42 of 48
: Thursday, April 28, 2016
I My Commission ExpiwsoJtTet8,11997 06/10/2007
THE ADVANCED MEDIA GROUP .
Sammy Caterbone (Brother) Affidavit

Advanced Media Group, Ltd.

An Information Technologies Company

October 23, 1991

California State Attorney General's Office

Sacramento, California

Re: Caterbone, Samuel A. 11733 089 (Military ID), Deceased

Dear Sirs:

As per the enclosed death certificate of December 25, 1984, which

states in item #35A "Under Investigation ", I am hereby formallk'
and officially requesting information as to the findings of that
investigation.

Please understand, that in the spring of 1985, I had personally

visited the County of Santa Barbara's Public Guardian Office for
the above information, however they would did not provide any
additional information.

For the record, on December 27th, 1984, I had received a phone call
from Charles Snyder Jr., the mortician, upon receiving and
examining the body of the deceased, which arrived from Santa,
Barbara, California.

Mr. Snyder raised some concerns into an apparent discrepancy with

the cause of death, as stated by the Coroner, John Carpenter. Mr.
Carpenter certified that the cause of death was "Asphyxiation;
ligature strangulation; Suicide -hung self with belt: Under
Investigation".

Mr. Snyder stated to, in similar words, "Stan, I have a problem,

the report says that your brother hung himself, yet there) are no
markings on your brothers neck, there should be some kind of marks
from the bruises, there is always some kind of markings in flanging,
I can't find any marks ".

I had intimate discussions with attorney Joseph Roda, of Lanlcaster,

pertaining to these matters.

Most importantly, while visiting with my brother in Santa Barbara,

California, he had informed me that he was given "Bad LSD" while
in the service, and that was the reason for his mental condition.
I have always known that he had often times experienced
"flashbacks ", and in that conversation my brother confirmed, and
admitted that he often times .experienced "flashbacks And ",I,

"flashbacks" are medically proven to be a characteristic' of LSD'

users.

Superior Court'1164 Amicus re Kathleen Kane Page 43 of 48 Thursday, April i87201'810

Lancàster. P4 17601 FAX 717 392 7897;

i I
Sammy Caterbone (Brother) Affidavit

California State Attorney General, October 23, 1991, Page 2

In light of the recent information concerning alleged "experimental

drug programs administered by certain branches of the United States
Military", 'and the use of LSD in the respective programs, ind my
intimate conversations concerning LSD with my brother, I¡ have
serious questions regarding my brother's death.

Especially in regards to the alleged suicide, which as I have been

told by medical professionals, is impossible without any marking
on the victim's neck, if indeed asphyxiation by strangulation is
the cause of death.

So that I may bring a conclusion to these issues, I would expect

information regarding the "Investigation ", apparently conducted by
Coroner Kenneth Carpenter, be submitted to me in a timely fashion.

I would think that I, as administering all matters regarding my

brother's death, be privilege to this information.

Incidently, I have had numerous fabricated allegations of suicide,

which have always been supported by the fact that my brother
allegedly committed suicide, and I would like this issue either
denied or confirmed. It has caused me a great deal of emotional
duress, especially when the allegations of my suicide were proven
to be fabricated.

I may be reached at: Stan J. Caterbone

615 Wyncroft Lane #2
Lancaster, PA 17603
(717) 392 -3682 Phone
(717) 392 -5032 Fax

I appreciate your immediate cooperation into these sensitive

matters.

Sincerely,

Stan J. C:' erbone

Enclosures
cc: County of Santa Barbara, Public Guardian Office
Senator Bill Bradley, New Jersey
Charles Snyder, Jr., Snyder Funeral Home
Congressman Robert Walker, Pennsylvania

Notary:
SUBSCRIBED AND SWORN TO BEFORE ME
THIS
DAY
CT 2 1991

--r
SEAL
NOLE M. MAURER. Notary PubIle
WHOLE
Superior Court 1164 Amicus re Kathleen Kane Page 44 of 48 tcaster, Lancaster County. Pa. Thursday, April 28, 2616
My Commission Expires Aug. 2. 1993
Sammy Caterbone (Brother) Affidavit

PLAsE 3Eet4".--*
.
or »tat? of CaIifurnìii
grt
4,4E11, ..;^- rriitg of aanta ?Barbara 11

, 19
In the Matter of the Conservator-
HOWARD C. MGN'Zk.L, dimity Clerkl.
shä.2_ of the Person .,,and Estate Of
By ....................................................................... ...
Dcputy Cterk
SAMUEL ANTHONY CATERBONE, 137839
No
Conservatee. CITATION

THE PEOPLE OF THE STATE OF CALIFORNIA,

To SAMUEL ANTHONY CATERBOtaE

Greeting:

YOU ARE HEREBY CITED to be and appear in the Superior Court of the State of California in and

for the County of Santa Barbara, at the Courtroom thereof, at. the Court House in the City of___._. ..... .

Santa Barbar
.-.....r.,w.. a ::--, C.-aunty of Santa Barbara, State of California, on_..11les._day,

day of.. idoyember ß-82., at, -E 5 o'clock.n,k_M., of that day then and there to show
cause, if any you have whythe:4 a..Pöilàtffi ? .4.:ß...A ..D s r..Q. Q£...Y..4i,F..Person ..
áDd..g.. atg. s.
. ces,

etoze Maier_ S.u.i le.. pereIIm1. Sholl.l.ci nat,. ,e. zeappaixLtec ..._rzn SrS v .tor. of

HOWARD C. MENZEL, County Clerk

(
It M. MLIKE1

Deputy Clerk.

CL_I $7 Mr. 3/76

Superior Court 1164 Amicus re Kathleen Kane 3 Page 45 of 48 Thursday, April 28, 2016
 Case No. C1 -08 -13373 Lancaster County Court of Common Pleas

CITIZENS COMMISSION ON HUMANRIGnTS' INTERNATIONAL

Stanley J Caterbone
1250 Fremont St
Lancaster, PA 17603
September 25, 2009

Dear Mr. Caterbone,

We would like to thank you for sending your psychiatric abuse report to the Citizens
Commission on Human Rights International (CCHR). After reviewing your information, it is
evident that you experienced many psychiatric abuses. However, it has been determined that
CCHR is unable to take any action on the information.

Unless you request otherwise, your confidential information will remain on file with CCHR and
could potentially be used in the future. For instance, because we receive hundreds of abuse
reports each year, it is possible that other people might fife reports on the same practitioner or
facility. CCHR can use such data to show a pattern of abuse.

Please understand that CCHR is not a law enforcement or legal agency in any way. We are
not an attorney referral service, cannot bring lawsuits against individuals and do not have law
enforcement powers.

CCHR Int'l, 6616 Sunset Blvd., Hollywood, CA 90028,

humanrights ©cchr.org

Sincere

Lura Schmiedeke,

Abuse Case Documenter

6616 SUNSET BOULEVARD LOS ANGELES, CALIFORNIA 90026 (323) 467-4242 FAX (371.3í447.312O
intentes Address: http://www.cchr.urg E-Mall Address: humanrightsQcchr.org

Advanced Media Group Page 5 of 9 October 6, 2099

Creatod with

Lit1POF pro$esslonai
.

Superior Court 1164 Amicus re Kathleen Kane 3 Page 46 of 48 d CAM nk dthe Thursday, April 28, 2016ev,;nnr,i
 Case No. j}3'i13 Lancaster County Court of Common Pleas

Created with

Advanced Media Grouo Pane 6 of 9 Octnher 6. 2009

nitroPDrprofessi ona (

Superior Court 1164 Amicus re Kathleen Kane : Page 47 of 48 download the Thursday, April 28, 2016eçUel
What is CCI-IR?

1- 800 -869 -2247 Order CCHRInt.org Language Contact

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I of 2 11/6/2015 12:42 AM
 ORIGINAL
IN THE COURT OF COMMON PLEAS
MONTGOMERY COUNTY, PENNSYLVANIA - CRIMINAL DIVISION

COMMONWEALTH OF PENNSYLVANIA

v.

KATHLEEN G. KANE
`D;

MOTION OF ATTORNEY GENERAL KATHLEEN G. KANE

TO QUASH BASED ON SELECTIVE AND VINDICTIVE PROSECUTION

Attorney General Kathleen G. Kane, by and through her counsel, Gerald L. Shargel, Esq.,

hereby moves the Court before the Honorable Wendy Demchick -Alloy, Justice of the Coui-t of

Common Pleas, Montgomery County, 2 East Airy Street, Norristown, Pennsylvania for an 'Order:

1. Quashing the charges in this case because Attorney General Kane is the victim Of

selective and vindictive prosecution;

2. And for any other relief the Court deems just and proper.

Dated: New York, New York

April 27, 2016
Winston &/f tAawn LL P

Geralf Shargel, Esq.

Seth C. Farber, Esq.
Attorneys Pro Huc Vice for Attorney General
Kathleen G. Kane

Minora, Minora, Colbassani,

Krowiak, Mattioli & Munley
Amil M. Minora, Esq.
Attorney for Attorney General Kathleen G. Kane
Attorney ID: 22703

1
 i

OR{9INAL
IN THE COURT OF COMMON PLEAS
MONTGOMERY COUNTY, PENNSYLVANIA - CRIMINAL DIVISION

COMMONWEALTH OF PENNSYLVANIA
: No. 6239-15
v. : No. 8423-15

KATHLEEN G. KANE

MEMORANDUM OF LAW IN SUPPORT OF ATTORNEY GENERAL

s KATHLEEN G. KANE'S MOTION TO QUASH BASED ON
SELECTIVE AND VINDICTIVE PROSECUTION

s WINSTON & STRAWN LLP

Gerald L. Shargel
Seth C. Farber
200 Park Avenue
New York, NY 10166
Attorneys Pro ¡lac Vice for Attorney
General Kathleen G. Kane

MINORA, MINORA,
COLBASSANI, KROWIAK,
MATTIOLI & MUNLEY
Amil M. Minora, Esq.
Attorney for Attorney General
Kathleen G. Kane
Attorney ID: 22703
s

s
 TABLE OF CONTENTS
INTRODUCTION 3

LEGAL STANDARD 3

STATEMENT OF FACTS I 4
ANALYSIS 11

I. Others Similarly Situated Are Not Prosecuted 11

II. Attorney General Kane Has Been Intentionally and Purposefully Singled Out for
Prosecution for an Invidious Reason i. 13

CONCLUSION 17
 TABLE OF AUTHORITIES

Page(s)

Cases

Corn. v. Butler,
533 A.2d 105 (Pa. Super. Ct. 1987) passim

Corn. v. Butler,
601 A.2d 268 (1 991) 3, 4

Corn. v. Rocco,
544 A.2d 496 (Pa. Super. Ct. 1988), appeal denied Corn. v. Rocco, 559 A.2d
36 (1989) 3, 4

Snyder v. Bender,
No. 1:09 -CV-0927 (YPK), 2010 WL 2103640 (M.D. Pa. May 25, 2010) 14

Statutes

Pennsylvania's Criminal History Record Information Act 12

 INTRODUCTION

Leaks of grand jury information are not uncommon; neither are disclosures óf other

confidential information about criminal investigations. However, prosecutions for these leaks or

disclosures are extraordinary. Attorney General Kane was singled out for investigation and

subsequent prosecution in this case as a result of the initiative of prosecutors with personal

antagonism towards Attorney General Kane resulting from her exercise of her First Amendment

rights and her lawful duties as Attorney General of the State of Pennsylvania. Because the

Federal and Pennsylvania Constitutions prohibit such selective and vindictive prosecutions, the

charges in this case must be dismissed.

LEGAL STANDARD

The defense of selective and vindictive prosecution is a question of law that is properly

brought in a motion to dismiss, and is a complete defense to a criminal charge. Corn. v. Butler

601 A.2d 268, 270 -71 (Pa. 1991) ( "Butler II "). At the heart of the defense of selective or

vindictive prosecution is the proposition that "[u]nder the equal protection clause (i)f the

Fourteenth Amendment of the United States Constitution, the government must afford similarly

situated persons similar treatment." See Corn. v. Butler, 533 A.2d 105, 108 (Pa. Super. Ct. 1987)

( "Butler ").
1 In order to establish a case of prosecutorial selectiveness or vindictiveness, a

defendant must show that: "(I) others who are similarly situated to the defendant are not

generally prosecuted for similar conduct; and (2) the defendant has been intentionallÿ and

purposefully singled out for prosecution for an invidious reason." Id. at 109.

An "invidious reason" for prosecution can be demonstrated in one of two ways; either

situation warrants "inquiry and judicial intervention." Corn. v. Rocco, 544 A.2d 496, 498 (Pa.

Super. Ct. 1988), appeal denied Corn. v. Rocco, 559 A.2d 36 (1989). The first is "where a

3
prosecutive decision is based on discriminatory grounds of race, religion, national origin Or other

impermissible classification." Id. The second is where "the accused is treated more harshly

because he has successfully exercised a lawful right." 1d.; see also Butler ll, 601 A.2dl at 270

(stating that defense may be "based upon the theory that due process prohibits a prosecutin- from

punishing a criminal defendant in retaliation for that defendant's decision to exercise a

constitutional right"). It is the second situation that exists in this case.

STATEMENT OF FACTS

As a candidate for Attorney General, Attorney General Kane publicly and openly

questioned and criticized the apparent mishandling of the Jerry Sandusky prosecution. In

particular, she pledged that, if elected, she would commence a review of the Sandusky

prosecution.' Shortly after taking office she began that review, even retaining a former federal

prosecutor, H. Geoffrey Moulton, Jr., to lead the review and produce a report on his findings.2

Attorney General Kane's review received considerable public attention, and press reports

suggested that the review might result in a public finding critical of the prosecution) team,

including a finding that the investigation suffered from inexcusable delays.3 A lead prosecutor

Jan Murphy, "State attorney general candidates want to review Sandusky case," Pcnnlive.com,
Aug. 30, 2012,
http: // www. pennlive.com /midstate /index.ssf/2012/08 /state_attomey general candid a.html.
2
Charles Thompson, "Attorney General Kane's Sandusky deputy seen as fair, balanced,"
Pennlive.com, Feb. 4, 2013,
http: //www.pennIive.com /midstate/index.ssf/2013 /02 /attorney _general kanes sandusk.htm I.
3 Charles Thompson, "Attorney General Kathleen Kane nears launch of Sandusky probe,"

Pennlive.com, Feb. 2, 2013,

httn:// www. pennlive.com/midstate /index.ssf/2013 /02 /attorney general kathleen kane 2.htiml
("The new inquiry, [Kane] has said, would look at, among other things: Whether enough
agents and investigators were dedicated to the investigation at the start? Why Sandusky
wasn't arrested after the first credible case was built? Why Corbett's staff took the case before
a grand. jury? Did campaign contributions from hoard members of The Second Mile,
Sandusky's youth charity, influence matters ? "); Thompson, "Attorney General Kane's
Sandusky deputy seen as fair, balanced." ( "The pledge, in essence, is to conduct a thorough
4
in the Sandusky investigation had been Frank G. Fina, and L. Marc Costanzo assisted in the

prosecution, as wel1.4 The investigation and subsequent prosecution of Mr_ Sandusky

received enormous publicity at the time,5 and, undoubtedly, was the capstone of Fina' I; career

in the Office of the Attorney General ( "OAG ").

Fina and Costanzo had left the OAG shortly after Attorney General Kane took office,6

and, according to published reports, were incensed by the Attorney General's review of their

work. For example, a March 5, 2013 article in the Legal Intelligenter stated:

Attorneys and agents from the Pennsylvania Attorney General's Office who were
involved in the investigation and prosecution of Jerry Sandusky are `outraged' I

that Attorney General Kathleen Kane is keeping her promise to investigate the
office's handling of the case, and some are prepared to go public if the review's
findings are overly critical of their work or inaccurate, sources close to the
Sandusky investigation said.

`If they come after us, we're coming out publicly,' said one source who held a
leadership post in the office and was involved in the investigation.

Ben Present, "Prosecutors Angered Over Kane's Sandusky Investigation," The Legal

Intelligencer, Mar. 5, 2013.

review of the 33 -month Sandusky probe to answer lingering questions about why Sandusky
wasn't arrested after the first credible witness came forward; why the case was turned over to
a grand jury; and whether external factors like then -Attorney General Tom Corbett's
gubernatorial aspirations influenced its pacing. ").
Sara Ganim, "Jerry Sandusky trial: Prosecutor is used to the spotlight," PennLive.com,1June
10, 2012,
http://www.pennlive.com/midstate/index.ssf/2012/06/jerty sand usky,prosecutor is u.htlml
(Fina); Mark Shade and Dave Warner, "Jerry Sandusky waives preliminary hearing on cliild
sex abuse charges," The Christian Science Monitor, Dec. 13, 2011, I

http: //www_csmonitor.com /USA/Latest- News -Wires /20I / 1213 /Jerry -Sandusky- waives -
I

preliminary- hearing -on- child- sex -abuse- charges (Costanzo).

See, e.g., Joe Drape, "Sandusky Guilty of Sexual Abuse of I O Young Boys," The New York
Times, June 22, 2012, http://www.nytimes.com/ 2012/06/23/ sports /ncaafootball/jerry- sandusky-
convicted -of sexually- abusing-boys_html? r=0
6 Craig R. McCoy, "Phila. DA assembles team to investigate corruption," Philly.com, Apr. 29,

2013, http://articles.philly.com/2013-04-29/news/38880260 _veteran-prosec utors-polit ical-

I

corruption-attorney-general.
5
 Approximately a year later, Attorney General Kane publicly criticized a second high-

profile investigation conducted by Fina during his tenure at the OAG: the "Tyro;n Ali"

investigation. In that investigation, Fina supervised a three -year undercover sting operation into

allegations of public corruption. Attorney General Kane halted the investigation (without

bringing charges and publicly stated that Fina's investigation was poorly conceived; badly

managed, and tainted by racism because it had targeted African Americans.7

Shortly after Attorney General Kane made her public statements, Fina (who by then had

become a prosecutor in the Philadelphia District Attorney's Office) took the extraordinary step

of writing an op -ed article publicly attacking Attorney General Kane's decision to close the

Tyron Ali investigation. In that article, Fina wrote:

Attorney General Kathleen Kane ended that corruption investigation without

charging any of the public officials involved, and she has in the past week
made critical and negative assertions about my colleagues and I and the work I

that we performed in the investigation.

* * *

Surely, an elected official should be able to and required to speak to the citizens
of this Commonwealth and explain how and why she made a decision to not
pursue possible official corruption, and instead chose to criticize those who
sought to bring possible crimes to light, and then remain silent when called to
answer.

I await AG Kane's response to my invitation to speak to the citizens of this

state - unless of course she remains silent at her lawyer's direction.

7
Angela Couloumbis and Craig R. McCoy, "Kane: Targets committed crimes but sting still,
flawed," Philly.com, Mar. 19, 2014, http://articles.philly.com/2014-03-
19/news/48334899_1 sting-operation-kane -sting-case ( "While saying public corruption made
her `sick,' Kane said the sting was flawed and tainted by racism, and could not have led to
successful prosecutions. `There is nothing we can do to salvage this case,' she said. ").
6
Frank G_ Fina, "I challenge AG Kane to face me on the facts of corruption probe: Frank G.

Fina," PennLive Op -Ed, Mar. 24, 2014,

http: //www.pennlive.com/ opinion/ 2014 /03 /i_challenge_ag_kane_to_face me.html.

Only six weeks later, on May 7, 2014, Fina and Costanzo were contacted by a reporter,

Christopher Brennan, who indicated that he was working on a story that would be critical 0f their

conduct of yet another significant investigation, in this case, their failure to pursue corruption

charges against J. Whyatt Mondesire, the former head of the Philadelphia chapter lof the

NAACP. (Exhibit A, Transcript of Conference Held in Chambers, May 12, 2014, at 2 -5.) This

time, Fina and Costanzo took even more extraordinary measures in response to the specter of

further bad publicity. First, even though Brennan himself was under no obligation of grazed jury

secrecy and had a First Amendment right to publish his story, Fina and Costanzo attempted to

dissuade Brennan from doing so by intimating that grand jury secrecy obligations applied to him

and that publication of the article would be a "problem." (Id. at 16.) Second, and even more

unusually, and even though the Mondesire investigation had ended five years earlier, inl 2009,

Fina and Costanzo decided to instigate a criminal investigation.

Accordingly, the next day, on May 8, 2014, Fina and Costanzo sent a letter to Judge

William R. Carpenter "to report the release of Grand Jury information." (Exhibit B, Letter from

Chief Assistant District Attorney E. Marc Costanzo and Assistant District Attorney Fralnk G.

Fina to Honorable William J. Carpenter, dated May 8, 2014, at I.) They wrote that they had

been contacted by a reporter who claimed to have documents containing "extensive eviden:e and

information that clearly fall within the ambit of Grand Jury secrecy." (Id. at 1.) They offered to

provide further details and answer questions and expressed a preference to do so at an in cizmera

conference with Judge Carpenter. (Id. at 2.)

7
 On May 12, 2014, Fina and Costanzo appeared before Judge Carpenter in an in c:arriera,

sealed proceeding. (Exhibit A at 1.)8 During their appearance, Fina and Costanzo again stated

that they had been contacted by a reporter who claimed to have information related to la prior

grand jury proceeding. (Id. at 2 -3.) Fina said that he believed it was his "duty" to report the leak

and offered his legal conclusion that "the individual who had provided [the reporter} with) this e-

mail in all likelihood had committed a crime, possibly even a felony." (Id. at 4.)

Judge Carpenter asked Fina and Costanzo what action they were requesting that the Court

take. (Id. at 10.) In response, Fina noted that Judge Carpenter could investigate the allegEil,d leak

as a potential criminal violation. (Id. at 11 -12.) Fina also suggested the appointment of a especial

prosecutor to pursue criminal charges. (Id. at 12) ("Judge Garb on one occasion appointed an

independent prosecutor, answerable only to him, somebody from outside the A.G.'s Officée, and

that person looked into an alleged secrecy breach. "). Fina even insinuated that he himself would

be particularly qualified to run a leak investigation. (Id. at 12) ("1 have conducted some or these

reviews when I was in the Attorney General's Office on behalf of different supervising judges. I

did it for Judge Garb. I also did it for Judge Feudale and a judge in Pittsburgh once. ").

Fina also suggested that the target of such a special prosecutor's investigation should be

the Office of Attorney General:

This document, as far as I'm aware, only existed on a historical database

somewhere in the Attorney General's Office. Who is looking through those
historical e-mails am not aware specifically, but it has now apparently been
1

handed out to the media.

R
Fina and Costanzo acted in their official capacity in their correspondence with, and appearance
before, the supervising judge of the investigating grand jury_ First, they wrote Judge Carpenter
on the stationery of the Philadelphia County District Attorney and signed their letter as Assistant
District Attorneys. (Exhibit B at 1). Second, they gave their appearances at the start of the
conference as Assistant District Attorneys in Philadelphia County. (Exhibit A at 1.) Third,
before reporting the leak to Judge Carpenter, Fina had informed the Philadelphia County District
Attorney that he would be doing so. (Id. at 6.)
8
(Id. at 12 -13.) Fina continued:

The Court: What you are saying is, it would appear, without any firm basis fort
knowledge, that it probably was leaked from within the Attorney General's1
Office. That is what you would suspect.

Mr. Fina: Your Honor, again I don't see any other reasonable explanation at this
time.

(Id. at 14 -15.)

Significantly, during the conference, Fina admitted to Judge Carpenter that he and

Costanzo had a personal basis for antagonism against Attorney General Kane. In particular, Fina

stated:

Iknow we are certainly feeling like a couple of ten -point bucks in the first week
of deer season lately. I have reason to understand that the Office of the Attorney
General has been looking through historical emails, particularly my emails.

(Id. at 13.)

Although Judge Carpenter likely took Fina's comments to refer to a concern about being

the target of public criticism over his performance in the OAG, in fact Fina and Costanzd had a

far more serious basis for their concern. The OAG email review eventually led to the discovery

and public disclosure of pornographic, racist, misogynistic and homophobic emails from the

government email files of numerous members of the OAG and other Pennsylvania 'public

officials. That public disclosure has forced many of those officials from public office" and,

when it was finally revealed that Fina and Costanzo had themselves received (and, in -Finn's

9
See, e.g., Associated Press, "2nd top Pa. judge resigns over porn email scandal,"
CBSNews.com, Mar. 15, 2016, http: //www.cbsnews.coni/ news/pcnnsylvania judge- michael-
eakin- resjgns- porn -email -scandal: Wallace McKelvey, "Porn email scandal forces resignation of
Pa. fraud investigator," PennLive.com, Aug. 28, 2015,
http:// www. pennlive.com/midstate /index.ssf/2015 /08/kane porn email resignations.html.
9 -
case, also sent) such pornography,1Ò both faced public demands for their removal from the

District Attorney's Office.11 Articles reporting on those public demands for removal included

graphic descriptions of some of the emails, including: "a 32 -image pictorial circulated by Fina

entitled `Blonde Banana Split' [that] shows two women inserting bananas into their vaginas and
12
anuses' a 2009 email that Fina sent to his colleagues entitled "FW: New Office Motlivation

Policy Posters" "containing images with a theme of women sexually pleasing their bosses; "13

and, an email where "Fina indicated his favorite image was of a woman in a rainbow thong, with

a caption underneath stating: `Rainbows: Not as Gay as You Might Think. "'14

Judge Carpenter would have known none of this as he listened to Tina's and Costanzo's

presentation, but these two Philadelphia County Assistant District Attorneys surely knew what

their own email correspondence contained and surely recognized the threat to their careers and

their reputations that Attorney General Kane's investigation of that correspondence posed.

to
Mary Wilson, "Court Releases Pornographic Emails Kane Wanted Public," WKSGnewsl.com,
Aug. 26, 2015, http:/ /wskgnews.org/post/court- re]eases- pornographic-emails -kane- wanted
public #stream /0 ( "The court also unsealed a selection of the pornographic a -mails Kane's oiffice
uncovered, revealing Fina and Costanzo among the messages senders and recipients. ").
11
See, e.g., Joel Mathis, "Why Doesn't Frank Fina Quit?" PhillyMag.com, Dec. 9, 2015, at
http:/ /www.phillymag.com/news /2015 / 2/09/frank -fina- quit -resign]; Tricia Nadolny,
1

"Philadelphia DA reassigns prosecutors caught up in Porngate," The Morning Call, Dec. 4, 2015,
http: / /www.mc al l.com/news/nationworld/pennsylvani a/m e -pa -porn Bate-ph i l l y- prosecutors -;
reassigned- 20151204 -story.html (referencing "repeated calls" for Fina and Costanzo's
resignation due to the porngate scandal); Ernest Owens, "Councilwomen call for resignation of
city prosecutors tied to Porngate," Metro, Nov. 12, 2015, at
http: / /www. metro. us /philadelphia/councilwomen-call- for -resignation -ofcity-prosecutors -tied -to-
porngate/zsJokl--- YKb61aFaNclmY/ (referencing petition launched by group of Philadelphia
Councilwomen calling for resignation of Fina and Costanzo).
12
Tim Cwiek, "NOW Urges Firing of D.A. Staffers in Porn Ring," EPGN_com, Sept. 24, 2015,
http:/ /www.epgn.com/news/local /9403 -now-u ges- firing- of-d -a- staffers -in- porn -ring.
13 David Gambacorta and William Bender, "Fina plays central role in scandals," The Morning

Call, Oct. 1, 2015, http://www.mcall..com/ news/ nationwor ld /pennsylvania/mc -pa- kane -porn-
em ai l- frank -fi na -2 0 l 51001 -story. htm l
14
Cwiek, "NOW Urges Firing of D.A. Staffers in Porn Ring."
l0
 Unaware of this personal reason for animosity by Fina and Costanzo towards Attorney

General Kane, Judge Carpenter followed Fina's suggestion to launch a criminal investigation.

Thus, on May 29, 2014, Judge Carpenter appointed Thomas Carlucci() as Special Prosecutor and

authorized his investigation into an alleged grand jury leak. (Exhibit C, Order Appointing

Special Prosecutor, May 29, 2014, at 2.) That investigation resulted in the grand jury report, a

subsequent referral to the Montgomery County District Attorney, and, eventually, the criminal

charges lodged against Attorney General Kane in this case.

ANALYSIS

The charges in this case must be quashed because Attorney General Kane was the victim

of selective and vindictive prosecution; First, others who are similarly situated are not generally

prosecuted for similar alleged conduct. As detailed below, leaks of grand jury information have

occurred repeatedly in recent high -profile Pennsylvania cases - including two of Frank.'; Fina's
own cases; none of these other leaks appear to have resulted even in a grand jury investigation,

and certainly none have led to a criminal prosecution, as here. Second, Attorney General Kane

was targeted for investigation and prosecution for an invidious reason. Specifically, the timing

and circumstances of Fina's and Costanzo's actions, and Finas statements, all support the

inference that ADA Fina and ADA Costanzo instituted the Special Prosecutor's criminal
O
investigation in an effort to retaliate against Attorney General Kane for exercising her First

Amendment rights and for actions she took while carrying out the lawful duties of her lelected

office.

I. Others Similarly Situated Are Not Prosecuted

The first prong of the selective or vindictive prosecution standard is easily satisfied in this

case, as "others who are similarly situated to the defendant are not generally prosecuted for

11
similar [alleged] conduct." See Butler I, 533 A.2d at 109. Indeed, a Westlaw search reveals no

reported decisions at all of Pennsylvania state court prosecutions for either leaks of grand jury

information or violations of Pennsylvania's Criminal History Record Information Act (CURIA)

for the past 25 years.t5 But while such prosecutions are virtually unheard of, leaks of grand jury

information are not. Indeed, and as discussed below, there have been numerous recent leaks of

grand jury information in Pennsylvania and, as far as the public record reveals, none of these

other leaks has led to a grand jury investigation, much less to a criminal prosecution.

For example, during the grand jury investigation into Jerry Sandusky, the very charges

against the defendant were posted to the state court website while they were still supposed to be

secret.16 As mentioned earlier, the lead prosecutor on the Sandusky case was Frank Fina.

However, there is no indication in the public record that Fina or any other prosecutor cohvened

an investigating grand jury to examine that leak, and no one has been criminally prosecuted for

it. Similarly, during the "Bonusgate" scandal, a partial transcript of grand jury testimony was

leaked to the Pittsburgh Post -Gazette.' Once again, there is no public indication that any

investigation of this incident ever occurred and, once again, no one has been prosecuted for the

leak.

Even the March 17, 2014 Philadelphia Inquirer article that, according to the Complaint in

this case (August 6, 2015 Complaint, Affidavit of Probable Cause, at 2), served as the alleged

15 For instance, a search across the Westlaw database for all Pennsylvania criminal cases with
"violat!" in the same sentence as "Criminal History Record Information Act" yields no lhits for
actual prosecutions under CI-IRIA.
16 Sarah Ganim, "Attorney General to investigate early release of Sandusky charges as grand jury

probe continues," The Patriot News, Nov. 5, 2011,

hap://www. pennlive.com/midstatc/index.ssf/2011/11 /agio investigate early releas-htm'I.
17
Tracie Mauriello and Dennis B. Roddy, " Stetler aide links firmer lawmaker to Bonusgate,"
Pittsburgh Post -Gazette, June 19, 2009, http://www.post-
gazette.com /news / state /2009/06/ 19 / Stetler- aide -I inks-former-lawmaker-to-
Bonusgate/stories/2009061 901 80.
12
"motive" for Attorney General Kane to release grand jury information contained multiple leaked

facts from the Tyron Ali grand jury investigation. For example, that article reports such

potentially disparaging facts as: "[flour state lawmakers took money. ... State Rep. Ronald G.

Waters accepted multiple payments totaling $7,650; State Rep. Vanessa Brown took $4,000;

State Rep. Michelle Brownlee received $3,500; and State Rep. Louise Bishop took $1,5001, said

people with knowledge of the investigation. "18 Fina supervised the Ali investigation, but there is

no evidence that he brought these leaks to the attention of a supervising judge in an effort to start

an investigation and prosecution, as he did here. And, again in contrast to the treatment of

Attorney General Kane in this case, no one has been prosecuted for the Ali leaks.
i

In short, although there have been leaks of grand jury information in other recent, high-

profile cases, only Attorney General Kane has been prosecuted. Even when there were grand

jury leaks in two of Fina's own cases, there is no evidence that he ever referred those leaks to a

supervising judge or recommended a criminal investigation. Among similarly sil,uated

individuals, Attorney General Kane stands alone.

H. Attorney General Kane Has Been Intentionally and Purposefully Singled Out
for Prosecution for an Invidious Reason

The second prong of the selective or vindictive prosecution standard is also satisfied in

this case, as the evidence strongly supports the inference that Attorney General Kane was

intentionally and purposefully singled out for investigation and prosecution for an invidious

reason. In particular, the timing and circumstances of Fina's and Costanzo's actions, and Fina's

statements, all suggest that these Assistant District Attorneys targeted Attorney General Kane

because she had openly and publicly criticized their work on the Sandusky and Tyron Ali cases,

'Angela Couloumbis and Craig R. McCoy, "Kane shut down sting that snared Phila. Officials,"
Philadelphia Inquirer, Mar. 17, 2014, http:I /ìrticles.philly.com /2014 -03-
17/news/48269239 l investigation- kanc -ali.
13
and because she had made public statements and taken actions reflecting poorly on their

professional accomplishments and reputation. In effect, she was targeted because sh'e had

exercised her lawful duties as Attorney General and her First Amendment rights to make public

statements about Fina's performance.

An individual has a constitutionally protected right to hold elected office and to carlry out

the lawful duties of that office. See, e.g., Snyder v. Bender, No. 1.09 -CV -0927 (YPK), 2010 WL
1

2103640, at *4 (M.D. Pa. May 25, 2010) (discussing First Amendment right to run for elected

office and citing Flinn v. Gordon, 775 F.2d 1551, 1554 (11th Cir. 1985), for proposition that an

individual has "a constitutional right to run for office and to hold office once elected" )I The

lawful duties of Attorney General Kane's office include the review of past OAG prosecutions to

determine if misconduct occurred (Sandusky), the decision to discontinue an investigation (Ali)

and the communication to the public of the reasons for her decisions. Because the evidence

points to the conclusion that ADA Fina initiated the criminal investigation of Attorney General

Kane because of his antagonism against her due to her exercise of these lawful rightts, the

charges against her must be dismissed.

The Superior Court's decision in Butler I, 533 A.2d at 108 -110, is instructive. In Butler,

the defendant had been tried for prostitution three years prior. Id. at 105. At trial, she testified in

her own defense. Id. When asked if she had ever been convicted of a crime, she answered that

she had not. Id. She was acquitted. Id. Following her acquittal, she filed a civil action against a

police detective and other government officials based on an allegedly coercive searc1. Id.

Shortly after her civil suit was filed, county officials "discovered" that the defendant did in fact

have a prior conviction, and she was arrested and tried for perjury based on her allegedly false

testimony at her prior trial. Id. at 106.

14
 During the perjury trial, the detective who was the subject of the defendant's civil suit

testified that he was in fact the person who had learned of her prior conviction and had reported

it to the District Attorney's Office. Id. Out of the jury's presence, "he claimed that it was

merely coincidence that this information came to his attention after the civil suit was filed" Id.

The court did not allow the defendant to develop this evidence at trial. Id.

On appeal, the Superior Court held that the trial court had erred in precluding evidence

that was relevant to the issue of prosecutorial vindictiveness. Id. at 108. The Court noted that "it

is unconstitutional for the government to prosecute an individual because the prosecutor hasa

personal animus against the defendant." Id. at 108 -09 (citing United States v. DeMichael, 692

F.2d 1059, 1061 (7th Cir. 1982)). "Because it is constitutionally repugnant, selective prosecution

constitutes a valid defense to a criminal charge_" Id. The Court added:

Though the vast majority of prosecutors are dedicated and able public servants
who would never misuse their tremendous power, our legal system strives to
prevent even the occasional injustice. Thus, the defense of selective prosecution I

provides a check upon the arbitrary exercise of governmental power. When all
else has failed, an individual victimized by governmental wrath is still protected
by judicial vigilance.

Id. at 110.

The Court held that the prosecution of the defendant for perjury had at least "a suspicious

air." Id. at 109. The Court wrote:

In this case, Butler claims that Delaware County prosecuted her for perjury
because of her civil suit which is based upon an allegedly unconstitutional search.
Certainly, the proximity in time between the filing of the civil suit and Detective
O'Leary's re- awakening of interest in Butler's case has a suspicious air. It is also
suspicious that O'Leary mysteriously found a Justice Department report in
Butler's file soon after she filed her civil suit.

Id. The Court further wrote:

It is arguably logical that the County re- investigated Butler and dredged up
previously ignored information in retaliation for her lawsuit. The effect was then
15
 to single out Butler. The purpose was to retaliate for her exercise of protected
constitutional rights.

Id.

The Court concluded that the defendant's allegations "made out a prima facie cáise of

selective prosecution" because she had "asserted both discriminatory effect and discrimiñiatory

purpose." Id. The Superior Court held that because the defendant's claim of selective and

vindictive prosecution had "arguable merit," the trial court "should have held an evideiiitiary

hearing and given Butler an opportunity to present her defense." Id. at I 10.

As in Butler I, "the proximity in time" between, on the one hand, (a) Attorney General

Kane's public criticism of Fina's and Costanzo's work; (b) the "outrage" expressed bly the

Sandusky prosecutors and their threat that `If they come after us, we're coming out publicly;' (c)

Fina's op-ed piece (demonstrating his personal indignation about Kane's statements and actions

in relation to the Tyron Ali case); and, on the other hand, Fina's and Costanzo's report to Judge

Carpenter of allegedly leaked grand jury documents, and Fina's supposition that it must have

involved Attorney General Kane and OAG, "has a suspicious air," to say the least. See id.

Also "suspicious" is Fina's statement that he believed it was his "duty" to report a leak in

this five- year -old closed case. (See Exhibit A at 4.) When sensitive grand jury information was

leaked in the highly -publicized Sandusky case (on which Fina was the lead prosecutor), and

again in the Tyron Ali case (on which Fina was also the lead prosecutor), he apparently felt no

similar "duty," as there is no evidence that he ever referred those leaks to the supervising judge

and, indeed, no one has been criminally charged for those disclosures.

In sum, the evidence indicates that, in response to harsh and ongoing criticism oil their

accomplishments, and concerned about the potential consequences of an email professional

review that would eventually disclose their pornographic emails and lead to calls for their
16
 resignation, ADA Fina and ADA Costanzo singled out Attorney General Kane for investigation

and prosecution. Such selective and vindictive prosecution is unconstitutional, and, as a result,

the charges in this case should be quashed in their entirety. See Butler I, 533 A.2d at 109 -10

( "Because it is constitutionally repugnant," selective and vindictive prosecution constitutes valid

and complete defense to criminal charge).

CONCLUSION

For the foregoing reasons, the charges against Attorney General Kane must be dismissed

with prejudice. In the alternative, should the Commonwealth contest the factual bases of this

motion, an evidentiary hearing is required. See Butler I, 533 A.2d at 110.

Dated: New York, New York

April 27, 2016
Winston & S awn LLP

Ger. d . Shargel, Esq.

Seth C. Farber, Esq.
Attorneys Pro Hoc Vice for Attorney General
Kathleen G. Kane

Minora, Minora, Colbassani,

Krowiak, Mattioli & Munley

Amil M. Minora, Esq.

Attorney for Attorney General Kathleen G. Kane
Attorney ID: 22703

17

Ir
i
CONFERENCE HELD IN CHAMBER

NCNDAY, MAY 12, 2014

9:30 A.M.

000915
 2 (The following conference was

3 held in the judicial chambers with the Court, Marc

4 Costanzo, Esquire, and Frank Fina, Esquire, beì1ig

5 present:)

7 MR. COSTANZO: T am Marc

8 Costanzo. I'm currently an Assistant District

9 Attorney in Philadelphia County, formally a Deplty

10 Attorney General for the Commonwealth of Pennsylvania.

11 MR. FINA: Frank Fina, al;3o

12 currently an Assistant District Attorney in

13 Philadelphia County and formally Chief Deputy At.torney

14 General with the Office of Attorney General.

15 Your Honor, we are present;:,

16 unfortunately I don't remember the notice number or

17 even the grand jury, but it is regarding a matter that

18 was under investigation in 2009 before the grand jury

19 that was then sitting in Norristown, Pennsylvania.

20 What has brought us here today

21 is phone calls that both Mr. Costanzo and ï received

22 last Wednesday from a reporter named Christopher

23 Brennan with the Philadelphia Daily News. He gilled

24 us separately. We later determined, in talking to a

25 . for mr co- worker of ours, William Davis, who had been

000916
 2 a Deputy Attorney General also in 2009 with thE: Offic e

3 of Attorney General, that he had also been called by

4 Christopher Brennan.

5 I'll speak about the call,_ I had

6 with Mr. Brennan and let Mr. Costanzo talk about his

7 phone call.

8 I had been in court Wednesday.

9 When I returned from court sometime after 4:00 I

` 10 checked my messages in my office in the Philad(!plphia

11 District Attorney's Office and there was a message on

12 there from a reporter who I have never spoken 1_0

I

el"1
13 before and have no familiarity with. He says }iris name

14 is Christopher Brennan with the Philadelphia Dj.3ily

15 News, and he left on the message that he was calling

16 about a specific document that he had in his

17 possession regarding Jerome Mondesire, who had been

18 for many, many years the head of the NAACP in

19 Philadelphia, Your Honor. He left his number and sai d

20 that he needed to talk to me about this matter.

21 It's not my standard habit to

22 call reporters back, but in this case, having some

23 recollection of the investigation in which

24 Mr. Mondesire's name had appeared, and knowing that

25 nothing regarding Mr. Mondesire in that investigation

000917
0
("""'N
2 had ever been made public or been released from the

3 ambit of grand jury secrecy, I did call Mr. Brennan

4 back at approximately 5:00, 5:15 on Wednesday.

5 He relayed to me that helhad a

6 2009 e -mail which contained, either as an attachment

7 or as part of the text -- that wasn't clear to me,

8 Your Honor -- a four to five page memorandum detailing

9 extensively the grand jury investigation that had been

10 conducted up to that point by Mr. Davis, and

11 Mr. Costanza had also been a part of that

12 investigation. He actually read to me portions of the

/41-1.
13 document. It detailed extensively an investigation

14 that had been conducted into a nonprofit in

15 Philadelphia County that had been run by a woman named

16 Harriet Garrett. Miss Garrett had subsequently been

17 charged, Your Honor, as a result of that grandljury

18 investigation.

19 As part of that investigation,

20 in reviewing the financial records of the nonprofit

21 and some other evidence, Jerome Mondesire's name had

22 appeared as a result of some monies he had received

23 from that nonprofit. And there was, again, detailed

24 information in that memorandum about Mr. Mondesire,

25 his relationship with the nonprofit, and questions

000918
 2 that had been raised regarding the legality of his

3 conduct in taking money from the nonprofit.

4 I asked Mr. Brennan specifically

5 if he had this document in his possession. He said he

6 did. I asked him what was the form? He said it was

7 an e -mail. I asked him who was on the e -mail in terms

8 of recipients and senders. He said it was an e -mail

9 only between myself it was an e -mail received by me

10 from Mr. Davis, and Mr. Costanzo was c.c.'d, and that

11 nobody else appeared on this e -mail.

12 I then instructed Mr. Brennan

13 that there was a significant problem with his

14 possession of the e -mail. I said to him that I was

15 not going to give him an opinion as to the legality of

16 his situation possessing the e -mail, but that I could

17 assure him that the individual who had provided him

18 with this e -mail in all likelihood had committed a

19 crime, possibly even a felony. That this was grand

20 jury information. It is subject to the strictures of

21 secrecy under the Grand Jury Act and the Rules of

22 Criminal Procedure and rather extensive case law.

23 I told him that I believed it

24 was my duty to report this, that he was in possession

25 of this. He said he understood. He seemed to become

000919
 2 a little bit nervous. He mentioned to me something

3 about the case agent on the case, who was an

4 individual named Michael Miletto. He said, Well,

5 Mr. Miletto has already been questioned about this by

6 the Office of Attorney General. I said, Questioned

7 about what? He said questioned about this case and

8 what happened with Mondesire, and everybody wan s to

9 know why Mondesire wasn't charged, he said some hing

10 to that effect. And I said, This again I'm not going

11 to confirm or deny anything in regards to this.Í It's

12 grand jury information and I will need to report it.

13 Subsequent to that I spoke to

14 Mr. Costanzo and Mr. Davis about this, who had also

15 ended up talking to Mr. Brennan.

16 1 have no hesitation, Your

17 Honor, going under oath or expressing in any manner

18 that I did not disclose this document. I do not have

19 possession of this document. I have not seen this

20 document since 2009. I will also just state, Your

21 Honor, that in my personal opinion it's not possible

22 that Mr. Costanzo or Mr. Davis would disclose this

23 document, either.

24 THE COURT: Did you report= it

25 anywhere other than here?

000920
 2 MR. FINA: I have not, Your

3 Honor; other than I did tell the District Attorney of

4 Philadelphia County that I would be reporting it here

5 because I felt that was the prudent thing to doL

6 MR. COSTANZO: Your Honor, I had

7 a brief conversation with Mr. Brennan. I actually

picked up the phone, it was earlier in the afternoon

9 on the same day, probably closer to 3:00 or 3:30. He

10 identified himself as Chris Brennan, and I think

11 that's the name he uses when he does a column. I've

12 heard of him. I may have spoken to him over th;e many

/4-°1
13 years of my career. I can't remember specifically

14 ever doing so.

15 He identified himself. told

16 me that he wanted to speak to me about a case that I

17 may have been involved with and he had some questions

18 about an e -mail that he possessed, and specifically he

19 wanted to know why Jerome Mondesire was not charged in

20 a particular case and what happened with a particular

21 case.

22 I quickly was alerted to iny

23' recollection of the case. Frankly, Your Honor,

24. hetiause there have been recent allegations about

25 Mr. Mondesire in the newspapers, where there has been

000921
 2 a very open civil war in the NAACP in the Philadelphie

3 branch, where several older board members have }made

4 accusations against Mr. Mondesire to the point where

5 they, I think, filed suit. They are represented by ar

6 attorney whose last name is Egan; I can't remember hip

7 first name. I know that Mr. Egan sent letters both tc

8 the District Attorney of Philadelphia County and to

9 the Attorney General, probably in the last couple

10 months, alerting both law enforcement entities Of

11 possible misuse of funds at the NAACP by Mr. Mondesire

12 and requesting some sort of inquiry. I was aware that

13 that request was in our office in Philadelphia (':ounty.

14 So I quickly was very familiar with my recollection of

15 the case.

16. I was not the assigned attorney.

17 I was the senior attorney in the Norristown office.

18 Mr. Davis worked with me. Mr. Davis was assign0 that
19 investigation. It did lead to charges against Harriet

20 Garrett and her daughter for perjury.

21 THE COURT: Is anything pending?

22 Is that case now closed?

23 MR. COSTANZO: That underlying

24 prosecution is closed and the actual case file in the

25 office was closed before my departure. I departed in

000922
,. 2 January of 2013. I've had no contact with the (case.

3 Frankly, I was c.c.'d on the

4 e -mail. The three of us were aware of the e- mail,

5 because basically the three of us spoke on the

6 telephone about the current status of the case and

7 various information that was coming out in grand jury

8 And it was Mr. Fina's suggestion to me and Mr. Davis

9 that he put a status summary together and send it to

10 him in Harrisburg so he could do whatever he felt was

11 appropriate with that information. I was c.c.'dd

12 because technically I was between the two in the chair.

e""t.
13 of the command. So this was not an e -mail basiCally

14. alerting Mr. Fina to something he didn't know. It was

15 something we had all already spoken about, and ¡this

16 was at the request of Mr. Fina to put it in the form

17 of a written document so that he would have it in hand

18 in Harrisburg.

19 So I had a recollection that

20 some sort of notice went up to Harrisburg. I didn't

21 remember if was an e-mail or a memo. I didn't

22 necessarily remember the contents of it, but I know

23 that it was a status memo.

24 According to Mr. Brennan, he

25 said it was four or so pages long. The first half had

000923
 2 to do with information about Miss Garrett. The second

3 half had to do with information with regard to

4 Mr. Mondesire. I told him very quickly, I said,

5 That's grand jury information. It's not something I

6 can talk to or anybody else can speak to. He said,

7 Well, I understand it's a closed case. Can't ybu talk

8 about it now? And I said, No; the grand jury se=crecy

9 provisions provide for secrecy in perpetuity. 3o it

10 doesn't matter if the case is open or closed, it's not

11 something we can ever comment on, and frankly, :it's

12 not something you should probably be possessing, I

13 said, I don't know how you got it, but you shoudn't
14 have it and it may be illegal for you to have received

15 it from somebody. So I left it at that.

16 I later heard in the afternoon

17 from Mr. Davis that he had received a similar dill.

18 He gave a similar response that it was not something

19 he could speak about, that it was grand jury, arid left

20 it at that.

21 I spoke later Friday night with

22 Mr. Davis, of last week, after we sent the letter to

23 Your Honor and Your Honor set up a meeting with ';me for

24 today, and I asked Mr. Davis if he was available to

25 come today so that he could go on the record as well.

000924
 2 He was interested in doing so. Unfortunately, he
3 wanted me to report to the Court that he is duelin

4 Media in Common Pleas Court. He is there. He'd be

5 happy to address the Court in any way, shape orHform

6 in the future. He has told me that he's never had

possession of that e -mail and, of course, would never

8 have released it to anybody; doesn't know this

9 reporter and never spoke to him before.

10 Mr. Davis also indicated, if

11 need be, he would be available by telephone tod y if

12 Your Honor had any interest in hearing from him. And

13 that's my last contact with it, Your Honor.

14 THE COURT: All right then.

15 What are you requesting the Court do, if anythirlg?

16 MR. FINA: Your Honor, our

17 concern, our immediate concern, and it certainly

18 hasn't changed since last Wednesday, this is a

19. document that would not have been provided in

20 discovery in the prosecution of Miss Garrett or 'her

21 daughter. This is an internal document that, at least

22 to our minds, clearly contains grand jury information.

23 As in a great many

24 investigations we have conducted over the years,, we

25. encounter lots of information, some of it

000925
 2 unfortunately unsavory about individuals who end up

3 not being charged. As this Court well knows, one of

4 the fundamental tenets of grand jury secrecy,

5 especially in an investigating grand jury as opposed

6 to an indicting grand jury, is that those matters if

7 not otherwise disclosed in furtherance of an

8 appropriate prosecution or grand jury report are to

9 remain sealed in perpetuity. Again, as this Court

10 well knows, the Rust Proof case is probably the

11 penultimate example of that.

12 This information about

13 Mr. Mondesire is information that would certainly

14 adversely affect his reputation if disclosed publicly,

15 and maybe worse, so we just felt it was important to

16 disclose it to the Court.

17 In the past -- and I'm not

18 trying to be presumptuous here, I'm just reciting

19 history -- in the past, when there have been potential

20 grand jury leaks, grand jury judges have conducted

21 under their authority as supervising judges, aslis

22 explained with some clarity, I think, in the court

23 order from the Chief Justice appointing the

24 supervising judge, the supervising judge has reàlly

25 absolute jurisdiction to look into any potential

000926..
 2 breaches in secrecy and determine what, if anything,

3 happened and whether it is a criminal violationjof the

4 Grand Jury Act.

5 I have conducted some of these

6 reviews when I was in the Attorney General's Office on

7 behalf of different supervising judges. I did it for

8 Judge Garb. I also did it for Judge Feudale and a

9 judge in Pittsburgh once. Courts have handled it

10 differently, Your Honor. Judge Garb on one occasion

11 appointed an independent prosecutor, answerable only

12 to him, somebody from outside the A.G.'s Office, and

13 that person looked into an alleged secrecy breah.

14 That ended up resulting in an agent with the Office of

15 the Attorney General being identified as the brach

16 some years later, and that person was actually

17 prosecuted for it and went to jail.

18 I'm not suggesting -- I dOn't

19 know what happened here, Your Honor, but I do ktiiow

20 from everything that I'm aware of is this docum nt

21 contained grand jury information. This document, as

22 far as I'm aware, only existed on a historical

23 database somewhere in the Attorney General's Office.

24 Who is looking through those historical a -mails I am

25 not aware specifically, but it has now apparently been

000927
 2 handed out to the media.

3 THE COURT: And you have, not

4 contacted the Attorney General about this, I t.'rust?

5 MR. FINA: I have not, Y7ur

6 Honor.

7 THE COURT: What is the

8 reasoning, if you don't mind?

9 MR. FINA: Because I'm ni)t sure

a 10 who may be involved in this disclosure, Your H Dnor. .

11 I'm anxious not to mix aiDples

12 and oranges. I know we are certainly feeling :Like a

13 couple of ten -point bucks in the first week of deer

14 season lately. I have reason to understand that the

15 Office of Attorney General has been looking through

r So I
16 historical e- mails, particularly my e- mails.

17 don't know where this document was released from, Your

18 Honor.

Z9 THE COURT: Anything further?

20 MR. COSTANZO: I have nothing,

21 Your Honor. ..

22 THE COURT: I'm wonderinc¡ if I

. 'I

23 should have this transcribed under seal and reviewed

24 by Mr. Jim Baker of the Attorney General's Office. Do

25 you have any thoughts there? He's in charge of the

000928.
 2 grand jury, as I understand it.
3 MR. FINA: Yes, Your Honor. Mr

4 Barker was actually put in that position while I was

5 with the office.

6 THE COURT: Or do you think thi s

7 is the Garb situation?

MR. FINA; Your Honor, I don't

9 know. I think that it would be a safe assumption tha t

10 if you were to disclose this to Mr. Barker, he would

11 have an obligation to disclose it to his command. I

12 think that is just a situation you would have to bear

e"" 13 in mind,

14 I'm not in any way questioning

15 Mr. Barker's integrity.

16 THE COURT: Right. I understand

17 that.

18 MR. FINA: I would be shocked

19 beyond question --

20 THE COURT: What you are saying

21 is, it would appear, without any firm basis for

22 knowledge, that it probably was leaked from wit hin th

23 Attorney General's Office. That is what you wo uld

24 suspect.

25 MR. FINA: Your Honor, again I

p492s
f1
2 don't see any other reasonable explanation at 1l:his

3 time.

4 THE COURT: Because it wásn't in

5 discovery. It wasn't otherwise disclosed in tile

6 prosecution. And your shaking your head yes? i

7 MR. FINA: Yes, Your Honor.

8 This was an entirely internal

9 memo that I don't know at the end of the day whether

10 there were even a sum total of five people who,may

11 have laid eyes on it. I would have showed -- and I

12 don't have a specific recollection of this --- ¡out in

/\ 13 normal practices, when I would ask for a memo like
1

14 this, it would be because I would show it to mr

15 supervisor, who was Richard Sheetz. Again, Yoúzr

16 Honor, Richard Sheetz does not have copies of these.

17 THE COURT: And the timing of

18 where we are with all of this is, I don't even.

19 remember the name of the controversy that the Inquire r

20 has been exploring between Attorney General Karde and

21 the uncharged people in Philadelphia.

22 what would you call that,

23 investigation? You were in charge of it.

24 MR. FINA: It was called'The

25 Undercover Lobbyist Investigation, was the formal

000930
 2 title in the Attorney General's Office.

3 THE COURT: That still

4 churning, so to speak. Isn't it in the news t8 some

5 extent?

6 MR. FINA: It is, Your Honor.

7 And that's what I was referring to earlier when I said

8 apples and oranges.

9 THE COURT: And Sandusky is

10 still churning to some extent.

11 MR. FINA: Unfortunately.!

12 THE COURT: Do you think that

13 some aspect of what we are talking about is goiJng to

14 end up in the newspapers in the near future? Iis that

15 your sense from talking with that reporter?

16 MR. COSTANZO: That's an

17 interesting question, Your Honor. I know Mr. Fina,

18 more than I, but we both got the impression that

i

19 Brennan was about to go with the story. And I ithink

20 he specifically said that to Mr. Fina, but I.thlink

21 during the conversation with Mr. Fina he seemed to ge:

22 a little nervous and said that he needed to bring this

23 to the attention of his editors. Now it's been

24 several days and there's been no --

25 THE COURT: Because you both

000931
 2 cautioned him that it was grand jury material alnd

3 possibly a problem.

4 MR. FINA: We are hoping,I Your

5 Honor, that has caused them considerable pause and

6 will prevent them from running a story on this;¡

7 although, investing -in the good will of the media is a

8 rather risky venture. But to date there has been no

9 story.

10 And again, Your Honor, to be

11 totally candid, it is profoundly my deepest hope, and

12 I know Mr. Costanzo's as well, that there is some

13 rational explanation for this and that this is not

14 part of an act of vengeance or an act of criminality

15 by anybody in the Office of the Attorney General.

16 I'm really not just saying this

17 We have the deepest fondness for that office as an

18 entity and have not sought conflict at any point with

19 that office or its members. Now, when the sword gets

20 drawn, we fight back. But this is not part of that it

21 any way, shape or form. And I hope, indeed, it's not

22 part of it from the other side as well, but the facts

23 as they currently appear to us don't add up

24 particularly well in terms of where this information

25 must have come from. It seems to me that it had to

ODD932
(4'41
2 come from the Office of the Attorney General, based on

3 what I know at this time. Now who and why, I don't

4 know, Your Honor.

5 THE COURT: All right. Anything

further?

7 MR. COSTANZO: No, sir.

8 MR. FINA: No, sir.

9 THE COURT: Thank you very much

10 MR. COSTANZO: Thank you,1 Your

11 Honor. We appreciate your time.

12 THE COURT: This matter is

13 sealed.

14

15 (At 10:00 a.m., the conférence

16 is concluded.)

17

18

19

20

21

22

23

24

25

000933
 C E R T I F I C A T I O N

I hereby certify that the

proceedings and evidence are contained fully and

accurately in the notes taken by me in the above cause

and that this is a correct transcript of the saine.

MEGAN McCARTIN, R.P.R.

Official Court Reporter;

000934
 flECEVrvg
1 A
pt
DISTRICT ATTORNEY'S OFFICE 9^l j
v ,1

THREE SOUTH PENN SQUARE

PHILADELPHIA, PENNSYLVANIA 19107 -3499 BY:---
(215) 686 -8000

R. SETH WILLIAMS
DISTRICT ATTORNEY

May 8, 2014

Honorable William Carpenter

R.

Supervising Judge Statewide Grand Jury

Montgomery County Courthouse
2 East Airy Street
Norristown, PA 19404

Via fax (610) -278 -5192 and U.S. Mail

RE: Grand Jury Information

DearJudge.Carpenter:

We are providing this correspondence to report the release of Grand Jury.informatíon.

Yesterday, the undersigned were separately contacted by an individual who represented himself as
Chris Brennan, "a reporter with the Philadelphia Daily News". He stated that he was in possession of a

2009 email between Frank Fina, Marc Còstanzo and Wiiliarn Davis. At the time, Frank Fina was Chief
Deputy Attorney General for the Criminal Prosecutions section of the Attorney General's Ofñce:and
Marc Costanzo and William Davis were prosecutors in that section. The email contained a lengthy
review of the evidence and testimony froma Statewide Grand Jury investigation being conducted at the
time. As part of that investigation, .information derived from the Grand Jury- about a certain prominent
-
individual who was never charged was detailed in this internal email. We are hesitant tò detail.thi!;
information in a corresporidèrice but will.gladly do so in person. We can represent to the Court that the
email contained extensive evidence and information that clearly fall within the ambit of Grand Jury
secrecy. The reporter stated that he had a copy of the email and he.even recited from it when
questioned:about the contents. The reporter also stated that the email was only between Fina, Davis
and Cóstanzo. We can assure the Court that none of us disclosed this email.

We were subsequently called by William Davis, now in private practice in Delaware County, ivho
Id
relayed that he too had been called by Brennan about this email. Àll three of us, separately, informer
Brennan that he possessed secret -Grand Jury information and that whoever gave.it to him had likely,
committed a serious crime_ We are also certain that, as individuals who continue to be sworn to secrecy
before the Grand. Jury in question, we have an obligation to disclose this apparent breach of secrecy to
the current Supervising Judge.

000912
 We are available, at the Court's discretion, to provide further details and answer any questicIms
regarding this matter. We would prefer to do so on the record in camera, but obviously defer to the
Court in this regard.

Thank you for your attention to this matter.

Sincerely,

1444.r_crzt;---
E.Marc Costanzo
Chief Assistant District Attome

Frank G. Fina
Assistant District Attorney

Ca Edward McCann
First Assistant District Attorney, Philadelphia District Attorney's Office

William Davis, Esquire

000913
 nncl, SIO
DISTRICT ATTORNEY'S OFFICE
'
THREE SOUTH PENN SQUARE 4
z %
PH1LADELPHiA, PENNSYLVANIA 19107-3499 ray inal.,a;r5
C2 1 $ 00,480
`2111*-A
MAILED FROM 'ZIP CODE 21 0.1 E
o
Honorable William R. Carpenter
Supervising judge Statewide Grand Jury
2 East Airy Street R6 BoL311
Norristown, PA 19404
 IN THE COURT OF COMMON PLEAS
MONTGOMERY COUNTY, PENNSYLVANIA

IN RE; /A13 I '42.-I - .Z of .

TI-IE.STATEWIDE
4 : MONTGOMERY COUNTY COMMON PI.IEAS
INVESTIGATING GRAND JURIES

: In Re: Powers.and Responsibilities of

: Special Prosecutor Exercising
Extraordinary Jurisdiction; on Allegations that
Secret Grand Jury or Related Information vas
Unlawfully and /or Negligently
: Accessed/Released/Compromised

SEALING ORDER.

AND NOW, this 29th day of May, 2014; it is hereby ORDERED, that the áittached

Order of May 29, 2014 be filed under seal. with the Clerk of Courts of Montgomery

County until further Order of this Court.

BY THE COURT:

OAR
WILLIAM R. CARP TER, J.
Supervising Judge

True and correct Copy

Certified from the record
This Day of !`1i AL). 20

Cl ï óf Cc arts
P
 IN THE COURT OF COMMON PLEAS
MONTGOMERY COUNTY, PENNSYLVANIA

IN RE:

THE STATEWIDE
: MONTGOMERY COUNTY COMMON PLEAS
INVESTIGATING GRAND JURIES .

: In Re: Powers and Responsibilities of

: Special Prosecutor Exercising
: Extraordinary Jurisdiction; on Allegations that
: Secret Grand Jury or Related Information was
: Unlawfully and /or Negligently
Accessed/Released /Compromised

ORDER
i

AND NOW, this 29th day of May, 2014, after "preliminary investigation "; this

court in its capacity as Supervising Judge of the 35'h Statewide Investigating Grand Jury,

finds there are reasonable grounds to believe a further more substantive investigation is

warranted into allegations that statewide Grand Jury secrecy may have been compromised:

It is therefore ORDERED and DIRECTED by this Court in accordance with the authority

vested in it by the 1078 Pennsylvania Investigating Grand Jury Act of 1978, 42 Pa. C.S. §

4541, et seq. and the procedural rules that followed (Pa.R.Crim.P 220, et seq.) as well as

relevant case law; that THOMAS E. CARLUCCIO, ESQUIRE, be and is hereby

appointed Special Prosecutor with full power, independent authority and jurisdicition to

investigate and prosecute to the maximum extent authorized by law any offenses related to

any alleged illegal disclosure of information protected by the law and /or intentional 'and /or
 negligent violations and rules of Grand Jury secrecy as to a former Statewide Investigating

Grand Jury, such as; .

1. 42 Pa. C.S. § 4549(b) Disclosure of proceedings by participants other than

`'°witnesses... "all such persons shall be sworn t«secrecy, and shall be in contempt

of court if they disclose/reveal any information which they are sworn to keep

secret."

2. 18 Pa. C.S. § 5101 Obstructing administration of law or other governmental

function - "a person commits a misdemeanor of the second degree if he

intentionally obstructs, impairs or perverts the administration of law or other

Í

governmental function by force, violence, physical interference or obstacle,

breach of official duty.

3. Any other applicable offense.

It is FURTHER ORDERED by the Court that the Special Prosecutor:

1. Shall use any appropriate currently empaneled Grand Jury to investigeite any

alleged or suspected violations of secrecy or concomitant crimes related toIsuch.

2. Shall have the right to request an application for an immunity order from the

Attorney General.

3.. Shall have the right to employ all appropriate resources including a minirritum of

one investigator and if necessary, one support staff.

 o
4. Shall have day-to -day independence and will be free to structure the

investigation as he wishes and to exercise independent prosecutorial discretion

whether, which and when any potential witness should be brought before the

Grand Jùíÿ. and/or whether,: which and when chargers should be brought,
_

including contempt of court.

5. Shall be permitted, while serving as Special Prosecutor, to consult with ¡past and

present members of the Office of Attorney General and take such action as is

necessary to ensure that matters he is investigating and/or prosecuting in his role

as Special Prosecutor are brought to a successful conclusion, so long as such

consultation/action does not present a conflict of interest with his duties as

Special Prosecutor and/or violate the secrecy oath.

6. Shall be empowered to respond to interference with his investigation by also

having authority to investigate and prosecute crimes committed in the coi.rrse of,

and with the intent to interfere with the Special Prosecution's investigation such

as Perjury, Intimidation of witnesses and other Applicable and relevant violations

of the law.

7. Shall comply with all relevant statutory and case Iaw as well as all applicable

canons of ethics.

8. Shall be_ removed from the-position of Special Prosecutor only by the poi;rsonal

action of the Grand Jury Judge and /or the Pa Supreme Court.
9. Shall be appointed for a period not to exceed six months from today, utl.11ess the

Special Prosecutor makes a written request to the Court for an extension setting

forth the reasons for the extension.

10.The Special Prosecútrsr shall be compensated at the rate of $6S_00` nhour to be

paid by the Commonwealth of Pennsylvania. The investigator/support staff

chosen by the Special Prosecutor shall be compensated at the rate of $2;0.00 an

hour. All those seeking compensation shall keep detailed records of time and

services rendered. All shall provide the Supervising Grand Jury Judgé with a

monthly accounting of time/services rendered.

11.Shall provide the Supervising Grand Jury Judge with periodic summaries, of any

progress.

12.Submit a report addressed to the Pennsylvania Supreme Court, and the

Supervising Grand Jury Judge, setting forth any findings and recommendations

on any proposed statutory, rulemaking or recommended practices than would

preserve the critical requirement of secrecy in Grand Jury proceedings as iwell as

insuring the rights of defendants to a fair trial and maintaining the integrity of

our Grand Juries.

 BY THE COURT:

144g
WILLIAM R. CARPEN 'R, J.
Supët-vising Judge
....

Copies sent. on May 29, 2014

By First Class Mail to:
Chief Justice Ronald D. Castille
Pennsylvania Attorney General Kathleen G. Kane
Thomas E. Carluccio; Esquire
 CERTIFICATE OF SERVICE

I hereby certify that I am this day serving Attorney General Kathleen G. Kane's Moition
to Quash Based on Selective and Vindictive Prosecution upon the persons and in the manner
indicated below. The manner of service satisfies the requirements of Pa.R.Crim.P. 575.

Service by hand:
Thomas McGoldrick (610) 278 -3126
Chief, Trials Division
Montgomery County District Attorney's Office
P.O. Box 311
Norristown, PA 19404
TMc Go ldr@montcopa. org 7 rn.:
(Attorney for the Commonwealth)
I

'
.
v+
Dated; New York, New York .c-
April 27, 2016
.

Jean Gilbert Leonidas

Docket Clerk
Winston & Strawn LLP
200 Park Ave.
New York, NY 0166
1

(212) 294 -5349