Você está na página 1de 218

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 1 of 105

9:51 A.M.

Appeal Docket Sheet

Superior Court of Pennsylvania

Docket Number: 1164 EDA 2016


Page 1 of 3
May 17, 2016
CAPTION

Commonwealth of Pennsylvania
v.
Kathleen Granahan Kane
Appellant
CASE INFORMATION

Initiating Document:

Notice of Appeal

Case Status:

Active

Case Processing Status:

April 21, 2016

Awaiting Original Record

Journal Number:
Case Category:

Criminal

Case Type(s):

Criminal Conspiracy
Other
Perjury

CONSOLIDATED CASES

RELATED CASES

Docket No / Reason

Type

1166 EDA 2016


Same Issue(s)

Related

SCHEDULED EVENT

Next Event Type: Receive Docketing Statement


Next Event Type: Original Record Received

Next Event Due Date: May 5, 2016


Next Event Due Date: June 20, 2016
COUNSEL INFORMATION

Appellant
Kane, Kathleen Granahan
Pro Se:
No
IFP Status:
No
Attorney:
Minora, Amil Michael
Minora, Minora, Colbassani, Krowiak, Mattioli & Munley
Law Firm:
Address:
700 Vine St.
Scranton, PA 18510
Phone No:
(570) 961-1616
Fax No: (570) 963-1691

Attorney:
Address:

Phone No:
Attorney:
Address:

Shargel, Gerald L.
Winston & Strawn, LLP
200 Park Avenue
New York, NY 10166
(212) 294-2637

Fax No: (212) 294-4700

Kramer, Ross Mitchell


WINSTON & STRAWN LLP
200 Park Avenue
New York, NY 10166

Neither the Appellate Courts nor the Administrative Office of Pennsylvania Courts assumes any liability
for inaccurate or delayed data, errors or omissions on the docket sheets.

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 2 of 105

9:51 A.M.

Appeal Docket Sheet

Superior Court of Pennsylvania

Docket Number: 1164 EDA 2016


Page 2 of 3
May 17, 2016
COUNSEL INFORMATION
Appellant
Kane, Kathleen Granahan
Pro Se:
No
IFP Status:
No
Attorney:
Farber, Seth C.
Winston & Strawn, L.L.P.
Law Firm:
Address:
200 Park Avenue
New York, NY 10166
Phone No:
(212) 294-6700

Fax No:

Amicus
Caterbone, Stan J.
Pro Se:
Yes
IFP Status:
Pro Se:
Stan J. Caterbone
Address:
1250 Street
Lancaster, PA 17603
Phone No:
(717) 669-2163

Fax No:

Appellee
Commonwealth of Pennsylvania
Pro Se:
No
IFP Status:
Attorney:
Steele, Kevin R.
Address:
Montgomery County District Attorney's Office
PO Box 311
Norristown, PA 19404-0311
Phone No:
(610) 278-3098
Fax No:

Attorney:
Law Firm:
Address:
Phone No:

Falin, Robert Martin


Montgomery County District Attorney's Office
P.O. Box 311
Norristown, PA 19404
(610) 278-3102
Fax No: (610) 278-3841
FEE INFORMATION

Fee Dt

Fee Name

04/21/2016

Notice of Appeal

Fee Amt Receipt Dt


85.50 04/21/2016

Receipt No

Receipt Amt

2016-SPR-E-000686

AGENCY/TRIAL COURT INFORMATION

Court Below:
County:
Order Appealed From:
Documents Received:
Order Type:
OTN(s):

Montgomery County Court of Common Pleas


Montgomery
Division:
March 28, 2016
Judicial District:
April 21, 2016
Notice of Appeal Filed:
Order Entered
T6863802

Lower Ct Docket No(s):

CP-46-CR-0006239-2015

Lower Ct Judge(s):

Demchick-Alloy, Wendy
Judge

Montgomery County Criminal Division


38
April 20, 2016

Neither the Appellate Courts nor the Administrative Office of Pennsylvania Courts assumes any liability
for inaccurate or delayed data, errors or omissions on the docket sheets.

85.50

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 3 of 105

9:51 A.M.

Appeal Docket Sheet

Superior Court of Pennsylvania

Docket Number: 1164 EDA 2016


Page 3 of 3
May 17, 2016
ORIGINAL RECORD CONTENT

Original Record Item

Filed Date

Content Description

Date of Remand of Record:


BRIEFING SCHEDULE

None

None
DOCKET ENTRY

Filed Date

Docket Entry / Representing

April 21, 2016

Notice of Appeal Docketed

April 21, 2016

Participant Type

Filed By

Appellant

Kane, Kathleen Granahan

Docketing Statement Exited (Criminal)


Superior Court of Pennsylvania

May 2, 2016

May 5, 2016

Application to Quash Appeal


Appellee

Commonwealth of Pennsylvania

Amicus

Caterbone, Stan J.

Amicus

Caterbone, Stan J.

Other

Document Name: EOA pro se amicus


May 5, 2016

Answer to Application to Quash Appeal

Document Name: pro se answer to quash

Neither the Appellate Courts nor the Administrative Office of Pennsylvania Courts assumes any liability
for inaccurate or delayed data, errors or omissions on the docket sheets.

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 4 of 105


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 Court Case No.


Docket No. 8423-15

:
COMMONWEALTH OF PENNSYLVANIA :
v.

KATHLEEN KANE

REQUEST THE COURTESY OF THE COURT TO APPEAR PRO SE AND TO FILE


AN AMICUS CURAIE BRIEF IN SUPPORT OF THE FOLLOWING
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, request for Appearance to file an Amicus in the above captioned case to support the
following:
1.

Quashing the charges in case Montgomery Court Case No. 8423-15

2. In support of any other relief this Court deems just and proper.
The following Amicus should provide this Court with the proper jurisdiction for legal standing
to consider this Amicus according to Rule 531 of the Pennsylvania Rules of Procedure.

Rule 531. Participation by Amicus Curiae.


(a) Briefs.Anyone interested in the questions involved in any matter pending in an appellate court,
excluding Petitions for Allowance of Appeal, although not a party, may, without applying for leave to
do so, file a brief amicus curiae in regard to those questions.
(1) Unless otherwise ordered by the court, any amicus curiae shall file and serve its brief in the
manner and number required and within the time allowed by these rules with respect to the party
whose position as to affirmance or reversal the amicus brief will support, or with respect to the
appellant, if the amicus brief does not support the position of any party.

Superior Court 1164 EDA 2016

Page 1 of 2

Tuesday, May 3, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 5 of 105


(2) In an appeal proceeding under Rules 2154(b), 2185(c) and 2187(b), any amicus curiae shall file
and serve its brief within the time allowed by these rules for service of the advance text of the brief
by the party whose position as to affirmance or reversal the amicus brief will support or, if the amicus
brief does not support the position of any party, within the time allowed by these rules for service of
the advance text by the appellant. Alternatively, the amicus curiae may, but is not required to, serve
an advance text and then file and serve a definitive copy of its brief. If the amicus curiae chooses to
serve an advance copy and then file and serve a definitive copy, its deadlines for each are the same
as for the party whose position as to affirmance or reversal the amicus brief supports or, if the
amicus brief does not support the position of any party, as for the appellant.
(b) Oral argument.Oral argument may be presented by amicus curiae only as the appellate court
may direct. Requests for leave to present oral argument shall be by application and will be granted
only for extraordinary reasons.
Official Note
Where the amicus cannot comply with the requirements of this rule because of ignorance of the
pendency of the question, relief may be sought under Rule 105(b). The last eight words of the rule
are new. In Piccirilli Bros. v. Lewis, 282 Pa. 328, 336, 127 Atl. 832, 835 (1925) the court noted the
applicability of this rule to public officers who are represented by official counsel with an adverse
position.
The 2011 amendment to the rule clarified when those filing amicus curiae briefs should serve and file
their briefs when the appellant has chosen or the parties have been directed to proceed under the
rules related to large records (Rule 2154(b)), advance text (Rule 2187(b)) and definitive copies (Rule
2185(c)). Under those rules, the appellant may defer preparation of the reproduced record until after
the briefs have been served. The parties serve on one another (but do not file) advance texts of their
briefs within the times required by Rule 2187. At the time they file their advance texts, each party
includes certified record designations for inclusion in the reproduced record. The appellant must then
prepare and file the reproduced record within 21 days of service of the appellees advance text (Rule
2186(a)(2)). Within 14 days of the filing of the reproduced record, each party that served a brief in
advance text may file and serve definitive copies of their briefs. The definitive copy must include
references to the pages of the reproduced record, but it may not otherwise include changes from the
advance text other than correction of typographical errors. Those filing amicus curiae briefs may
choose to serve an advance text and then file and serve definitive copies according to the procedure
required of the parties or they may choose to file a definitive brief without citations to the reproduced
record.
Date: May 3, 2016

Superior Court 1164 EDA 2016

_____
Stanley J. Caterbone, Pro Se
Freedom From Covert Harassment and Surveillance
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com
scaterbone@live.com
(717) 669-2163

Page 2 of 2

Tuesday, May 3, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 6 of 105


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 Court Case No.


Docket No. 8423-15:

COMMONWEALTH OF PENNSYLVANIA :
v.

KATHLEEN KANE

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


MOTION TO QUASH BASED ON SELECTIVE AND VINDICTIVE PROSECUTION
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 County
District Attorney's Office dating back to the myriad of prosecutions by the Commonwealth of
Pennsylvania in 1987, 2005, and 2006 while a resident of the County of Lancaster, Pennsylvania.
Most of which have been dismissed without any convictions, most without any trials, which according
to law are false arrests and false imprisonments. The MOVANT was a Federal Whistleblower in the
United States v. International Signal and Control, Plc., case of 1991.
This amicus provides a voice for the Movant as well as providing another perspective and
opinion that should benefit the courts; the parties; and the public-at-large. The matters presented in
this amicus have a direct relevancy in the disposition of this case as it does in the Attorney General's
(Kathleen Kane) fight to restore integrity and equity to the Judicial System of Pennsylvania, which
affects all of the residents of the COMMONWEALTH. The

Attorney General has been quoted as

saying she is in a battle with the 'old boys' network' of Pennsylvania and the MOVANT has written
extensively about this same select group over the years beginning in 1998. In an interview with
Brian Taff of WPVI on February 16, 2016 the Attorney General is quoted as saying Everybody

Superior Court 1164 Amicus re Kathleen Kane

Page 1 of 48

Thursday, April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 7 of 105


makes mistakes. I knew there was a good old boy network, everyone does. I had no idea
how deep and how powerful that network actually ran. The fact that I took it on and I
wasn't silent about it and that I am determined to tear that down, I think that's what my
legacy will show.
In a 1998 narrative the MOVANT wrote the following This story was perpetuated
through a gross miscarriage of justice: a tenure of malicious wrongdoing by both the law
enforcement community of Lancaster County and the Commonwealth of Pennsylvania, as
well as community leaders. A process that continues to obstruct Stan Caterbone's rights
for justice. It's mannerisms reach into the inner soul of political and judicial corruption. All
in the name of greed, and all in the honor of continuing the status quo of the "Good Ole
Boy's" club of Lancaster County. A process obsessed with keeping it's disclosure from
escaping beyond the confines of "Pandora's Box". It's a tenure of power that evolved from
the days of this country's earliest settlers, but an evolution that has somewhere strayed
away from the intent of our constitution; with total disregard for the law, in total
disrespect for the Constitution, and void of many of our civil liberties. This atrocity,
like the Lambert case, would have made our founding forefathers revel in disgust and
bellow in despair. In fact, their spirits and energies probably are!
In 2009 Opednews.com printed the narrative in full and the MOVANT wishes this said
court to consider it's content in it's final deliberations in support of dismissing all prosecutions
against the Attorney General of Pennsylvania. In addition attached are supporting documents
to advanced the credibility and integrity of the MOVANT.

These documents are attached as

EXHIBITS.
Diary: Lancaster County, The CIA, and U.S. Sponsored Mind Control,
http://www.opednews.com/populum/diarypagem.php?f=Lancaster-County-TheCIA-by-Stan-Caterbone-091125-169.html
In addition the MOVANT wrote to the ATTORNEY GENERAL on November 12, 2015 and
stated the following Back in 1998 I had a meeting with an NSA (National Security
Agency, Ft. Meade, Md) operative in a parking lot of a former car dealer in York, PA. I
had just attended a job fair and he approached me as I was about to get into my car.
He introduced himself as being from the NSA and I questioned him about why they
would not leave me alone. His response was "It is not US (NSA) it's the Good Ole
Boys". I also have a huge problem with modified, stolen, and planted documents. We
parted ways in an amicable fashion.

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 2 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 8 of 105

The ATTORNEY GENERAL returned a letter the following day that stated Dear Mr.
Caterbone, Thank You for your correspondence to the Office of Attorney General, we
will keep your information in our files. These are attached as EXHIBITS.

Date: April 28, 2016

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

/S/
Stanley J. Caterbone, Pro Se
Freedom From Covert Harassment and Surveillance
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com
scaterbone@live.com
(717) 669-2163

Page 3 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 9 of 105


___________________________________________________
HAD LANCASTER COUNTY (Pennsylvania) LOST IT'S SOVEREIGNTY BEFORE IT LOST
IT'S SOUL?1
Authored in May of 1998
"Each time a man stands up for an ideal, or acts to improve the lot of others, or
strikes out against injustice, he sends forth a tiny ripple of hope. And crossing each
other from a million different centers of energy and daring, those ripples build a
current which can sweep down the mightiest walls of oppression.".
by Robert F Kennedy
In 1987 This Plaintiff (Stan J. Caterbone) Had Unjustly Lost His Freedoms, His Rights, And His
Pursuit Of Life, Liberty And Justice.
The following report (most identities purposely omitted from this version) is an amazingly true
and factual account of an extraordinarily bizarre tragedy that has turned one man's life into an
eleven (11)2 year free fall into "Dante's Hell".
On the surface, this is a story of a victim (Stan J. Caterbone) struggling to seek the truth, but
in reality, the evidence will conclude that this is a victim, literally, held hostage by virtue of his
truth. Later, the preponderance of evidence that Stan Caterbone has amassed and his
obsession for meticulously documenting his ordeal might seem eccentric, yet his demonstrated
ability to react to events before they unfold appears mystical. And this was his manner in which
he tactfully defended and protected his life. It is these actions that have painted the landscape
with a dire vengeance for his ruin. His actions will ultimately serve to protect, preserve, and
foster the truth of his story, incriminating the culpability of his many perpetrators, while at the
same time being twisted and tainted in a relentless manner to attack his credibility.
This is a story of a human being endearing for his rights, living in fear of his life, and the
remedial actions required for the truth to set him free. A victim (Stan J. Caterbone) forever
believing in his accomplishments and his visions, yet forced to adhere to a life of their
diversions. Fatefully, ten years after being taken as a "political hostage", with the aid of
numerous arrests and false imprisonment's conveniently falling short convictions, a Federal
Judge, Judge Stuart Dalzall, of the Eastern District Court of Pennsylvania, opened a "Pandora's
Box" into the true colors of the inner workings and politics of ultra conservative Lancaster
County, Pennsylvania, a supposedly "God's" country. His findings reeled a dramatic and
emotional response from the Lancaster County community that was akin to the assassination of
1
2

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 4 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 10 of 105


JFK. A community where "obstructions of justice" strikes a startling and stark contrast to the
image it so desperately embraces. A community proud of it's "tough on crime" judges, a
community of "plain folks" and Amish, and a community settled in a beautiful landscape
abundant in an agricultural bounty. This is not a community of compromising integrity. Or so it
has been perceived.
Judge Dalzall's extremely controversial findings were responsible for Pennsylvania's own
crafting of the "Laurie Bill", the retaliation by the Commonwealth of Pennsylvania intended to
curb the Federal Courts interference within the respective state's own jurisdictions and
proceedings. Or was it a political maneuver to close the lid on "Pandora's Box"? The
Pennsylvania Attorney General and the Lancaster County District Attorney have both thrown all
their might and all their muscle at turning the tides of Judge Dalzall's findings. This story and
Stan Caterbone's rights have been violated and abused by some of the very same principals
that were responsible for Judge Dalzall's unsettling revelations. Lancaster County prosecutors
were found to have engaged in one of the grossest acts of prosecutorial misconduct "found in
the English speaking language", which allegedly occurred in this now famous Lisa Michelle
Lambert case, a murder trial which began in the summer of 1992. Subsequently, it is now in
the midst of a treacherous appeal process convened by Judge Dalzall. And if so, by fate, in
Philadelphia, Pennsylvania; the home of the "Freedom Fighters".
It is this public disclosure, that casts a new light and sudden hope for freedom into Stan
Caterbone's unbelievable and horrid story, that begun just four years prior to the murder of
Laurie Show. It is the decisive similarities of how both victims were subjected to a very
calculated and politically motivated attempts to "frame" and "fabricate circumstances" to obtain
the results that justified the means for illicit self-serving interests. This very same conduct,
committed by public servants, elected and enlisted to enforce the law, to which Judge Dalzell
found so appalling. Conduct, which violated the very same rights their respective offices are
commissioned to protect. Conduct, which strikes the meaning of "We The People" from our
nation's very own Constitution.
Fortunately, Stan Caterbone's story is laced with a thread of faith, a faith in God. And because
of his faith, Stan Caterbone will forever regard Lisa Michelle Lambert 3 and Laurie Show as his
little "Angels of Justice", a Godsend. An answer to his many prayers, that for the first time in
ten years provided a small glimmer of hope, and a few moments of solitude that have
materially justified his own tragic experience. The realization that the truth is that much more
believable because of the trials and tribulations of Lisa Michelle Lambert. Unfortunately, this
revelation came at the unfortunate and untimely death of Laurie. However, it just may be God's
intentions of a Higher Purpose.
3

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 5 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 11 of 105


This story was perpetuated through a gross miscarriage of justice: a tenure of malicious
wrongdoing

by

both

the

law

enforcement

community

of Lancaster

County

and

the

Commonwealth of Pennsylvania, as well as community leaders. A process that continues to


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

AT ISSUE
The central issue in this story is a cover up, a cover up of mass proportions, and of perplexing
design, with national consequences. The fact of the matter is that this cover up has had
ramifications throughout this world; specifically the Middle East The cover up would be
emphatically unbelievable without the wealth of evidence, especially the recorded conversations
with Pennsylvania officials. A cover up that permeates from what will later emerge as the 4th
largest financial fraud (Billion Dollars) in the history of the United States coupled with the
covert sales of arms to Iraq. And five years after this cover up began, these same munitions
were used against our own troops in the Persian Gulf War. And of course, there are admitted
ties to the Central Intelligence Agency (CIA) and the National Security Agency (NSA).. And this
cover up and story, which began in June of 1987, in Lancaster County, preceded criminal
indictments by the United States Attorney General, the Federal Bureau of Investigation (FBI),
the Internal Revenue Service (IRS), the Department of Justice and Commerce, and more. A
vast array of criminal activities conspired from the ultra conservative Lancaster County, where
God is supposedly supreme, and it's hard line approach to crime is said to be preeminent. In
June of 1987, Lancaster County was immersed in a dynamic twist of fate, with a host of players
which may never be fully identified.
The irony of this story is how Lancaster County manages the disclosure of the very same
criminal activities that this story proves that it condoned, prior to the intervention of federal
authorities. It most dramatically will prove the nature of it's integrity, or lack thereof.
International Signal & Control, (ISC) is the controversial player in this web of conspiracy. In
1987, ISC was the third largest employer in Lancaster County, a non-discrete defense
contractor. In all due respect to our beloved country, this report is in no way challenging the
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 6 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 12 of 105


policies or the activities of the Department of Defense, or the vast agencies of the "Intelligence
Community", especially the CIA or the NSA (National Security Advisory). with regards to ISC's
foreign dealings. Trying to protect the world of malicious and evil empires is a process which
never ends, and whose players are constantly changing. And our respective intelligence
agencies are continually challenged with the task of trying to make a difference, in accordance
with protecting our national security. Unfortunately, given the nature of their discrete activities,
and given the CIA's history of avoiding congressional approval in certain situations, our current
laws are void of effectively dealing with the peripheral catastrophes of such activities that
inherently

transpire.

The

CIA

remains

immune,

while

everyone

outside

suffers

the

consequences.
The fact that the CIA, or anyone of the other intelligence community, may have been involved,
does not grant a blanket of immunity over activities which were not material to protecting our
national security. If a company provides a service to anyone in the intelligence community, our
constitution, our laws, and it's respective commercial regulatory authorities, must still have the
full sense of their jurisdiction. The intelligence community may not have the right of
intervention into the commercial enterprise, or organization, circumventing the rights of its
employees, shareholders, creditors, and customers. No United States law or statute suggests
that there is any involuntary mandate that requires any of the preceding to compromise his or
her interests in the respective enterprise for the sake of national security, or the respective
intelligence agency. There must be considerations paid to all involved for those rights and
interests that compromise such a relationship. Otherwise, the CIA could effectively gain control
of any domestic corporation it so desires, without ever owning one share of its outstanding
stock, simply by enlisting its product or services for the sake of national security. The CIA
requires a formal vehicle to enlist the aid of our domestic commercial enterprises. ISC is a
proven and unfortunate example of that.
Stan Caterbone was a shareholder of record of International Signal & Control (ISC) for the
previous four years prior to when this tragic ordeal began. Stan Caterbone was to purchase the
stock from now Republican Pennsylvania Senator Gib Armstrong, who was in the brokerage
business at the time and selling ISC stock. The stock was sold over the London Securities
Exchange, supposedly for reasons to suppress information. Stan Caterbone was interested in
the stock because of his appetite for technology, and was more curious about the business of
ISC, than anything. In fact, Stan Caterbone had never made any inference to any of the illicit
dealings with Iraq. However, the perpetrators of this story, attempt to hide behind a vale of
"national security," in an effort to find legal immunity from all wrongdoing. In accordance, the
record will prove that this is merely a smoke screen used to intimidate and obstruct Stan
Caterbone's access for due process of the law.

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 7 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 13 of 105


The trials and tribulations of Stan Caterbone are unprecedented in terms of emotional and
psychological duress, fortunately his indestructible faith in God, and his enduring belief in
himself and the truth, endures his life. There was one attempt on the his life, days within the
public disclosure of the CIA's involvement with the local Lancaster County defense contractor
(ISC), which Ted Kopel reported on ABC News Nightline, on May 23, 1991, 4 years after the
initial cover up began. This story will depict a series of systematic and strategic offensive
attacks upon Stan Caterbone and his businesses that will result failed business enterprises, and
a Hollywood motion picture, deserted. An impeccable professional reputation and a flawless
credit rating purposely sabotaged. Financial opportunities, that in 1987, were almost impossible
to extrapolate, Vast financial opportunities and aspirations forever a part of history. This
horrendous Crime was perpetrated for the interest of a cover up, further protecting the corrupt
enterprises of Lancaster County's International Signal & Control (ISC). A quest for justice that
polarized every relationship Stan Caterbone maintained, in Lancaster County and beyond,
including friends and family. This story demonstrates a methodology of his perpetrators for
keeping Stan Caterbone "quarantined" from justice and public disclosure, through a malicious
means of "credibility" proponents, and horrendously deceptive tactics. Financial motives
prominently displayed in the hands of all of the perpetrators, which absolves the burden for a
traditional conspiracy.
The emotional response to the truth of this story is compelling, to say the least. Subsequently,
the startling keen sense of perception that Stan Caterbone had demonstrated is even more
intriguing. It is this extraordinary quality that is responsible for saving his life, while yet at the
same time providing his perpetrators with an alibi and a vehicle for discrediting his startling
allegations and his story. This story embellishes a dichotomy of perception that had Hollywood
producers from his film project call his work genius, while his perpetrators from the Lancaster
County Community conveniently and maliciously labeling him as "insane" and "emotionally
disturbed."
THE LANDSCAPE
The perplexing question of Stan Caterbone's intelligence, or lack thereof, is best analyzed as a
question of perception. However it terms of the legal consequences of the activities contained
herein, they are of little if any relevancy. The fact of the matter is that the "mental deficiencies"
have very little relevancy to this story, other than serving as a means to discredit Stan
Caterbone, a vehicle to facilitate the cover up, and a blanket of immunity for all of the
perpetrators.
The heart of Stan Caterbone's legal dogma is best described as follows: If a person, is
perceived to have a "mental deficiency"; yet whose actions and decisions are always proven to
be instinctually and amazingly prudent, always abiding within the law, and in the best interest
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 8 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 14 of 105


of his affairs, what rights and protection do the laws afford him from persons abusing that
perception, in order to yield political and financial rewards, as a direct consequence of his
demise? Furthermore, how does the law protect his rights, if any and all malicious acts against
Stan Caterbone, are constantly and immediately disregarded because he is perceived to not to
be "credible"? As this story unfolds, these questions will become even more troubling and
appalling. Although Stan Caterbone could never describe the pain of his trauma, he would often
say that the closest situation that may compare is that of a woman being continuously raped,
night after night, helplessly praying for relief, struggling to free herself from her captor, all with
no avail. He would call it as being "brain f------".
Stan Caterbone, coming from the lower middle class of Lancaster City, was only 29 years old
when this tragedy began. Coming from a broken home, he was the third of six boys. While at a
very young age, he would help his mother run a dry cleaning business, in an amazing similarity
like Lisa Michelle Lambert, he had also nursed his mother during bouts of depression. While in
high school, he was nursing his mother's depression, while at same time tending to his older
brothers bouts of schizophrenia. Stan Caterbone had learned to listen to the obscenities of
mental illness since he was a child. He learned to fill the shoes of his absent father in helping
his mother raise his three younger brothers.. Stan Caterbone was often called the "little old
man" because of his extraordinary maturity as a child. Stan Caterbone was determined to
break the "barrier" of the "Good Ole Boy's" club or the power elite, and had always felt a sense
of compassion for those less fortunate, and those neglected by those of material means, the
oppressed and impoverished. He had an undivided aspiration to someday make a difference to
those that could not help themselves, especially his older brother. Through his ingenious,
resourceful, and honest business approach, he was relentlessly growing his business and their
respective missions, in constant reminder of his oppression. His in depth understanding of
computer technology and his vision were his most powerful allies. Always pushing the envelope
for advanced technologies and seeking solutions for the most efficient means of his operations..
He knew that every break was going to be few and far between, he dedication himself to his
work, and married his business affairs, always embracing his projects with a passion.
In 1986, after serving on the Board of Directors for the Central Pennsylvania Chapter of
International Association of Financial Planners (IAFP), Stan Caterbone had made a large
contribution to increasing its membership and it's awareness among local professionals, as it's
vice president. In an effort to promote the organization, Stan Caterbone solicited a nationally
recognized and prominent financial planner from Washington, D.C., to be a headline speaker at
a dinner meeting. Ms. Alexandra Armstrong, one of the most nationally recognized financial
planners, often headlined in Money Magazine, attracted 100 industry professionals to the
Treadway Resort Inn. The attendance was unprecedented for the local IAFP chapter. The IAFP
is the authoring organization for certification as a financial planner. It was through the direct

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 9 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 15 of 105


conversations with Ms. Armstrong regarding his ideas and her experience, that inspired Stan
Caterbone to pursue his ambitions of growing his own financial firm, which he began in the
following months.
Disgruntled with the conflicts of interest and the lack of incentive for various professionals to
work together in managing one's wealth, a process which lacked efficiency, this entrepreneur
founded the firm Financial Management Group, Ltd., or FMG as it was often called. The firm
was to incorporate a "one-stop-shopping" strategy and incorporate financial services, legal,
accounting, tax preparation, real estate, insurance, mortgage banking, and estate services all
in one firm, all residing in one location, all taking advantage of the synergistic approach toward
managing wealth. And to provide the professionals long term security and equity participation,
all participants were encouraged to purchase stock in the company. This was a new and
innovative approach that attracted a lot of attention from investors and clients, but also came a
lot of nervous twitches from competitors, especially in conservative Lancaster County.
Stan Caterbone began recruiting professionals from all of the other firms, with great success.
He had enlisted two partners whom he had worked with at IDS/American Express, to carry out
his mission, which he began after extensive market studies and his early version of the
company, Pro Financial Group, Ltd., His two partners had followed Stan Caterbone to an
independent broker dealer in Atlanta, named Financial Services Corporation, where Ms.
Alexandra Armstrong was associated, and encouraged Stan Caterbone to visit, during their
discussion after dinner. Within one year, by June of 1987, the firm had invested over $40
million for respective clients.
The company had developed satellite offices throughout Pennsylvania and in several other
states, through his unique design. This firm was causing the other financial services companies
and the local banks in Lancaster County a run for their money. The firm had built a new 20,000
square foot office building just a few miles north of the city. The firm was attracting clients,
associates, and nervous attention from, well just about everybody. Considering the capabilities,
legal, real estate, insurance, financial services, accounting, FMG was making as many enemies
as it was making friends. And Stan Caterbone always believed in the premise that it's always
better to have people talking about you, regardless of the matter, than to have no one notice
you. And they were talking. Stan Caterbone was only in his late twenties when he started this
organization,. He held several positions; he was Executive Vice President and Secretary of
Financial Management Group Ltd, and President of FMG, Advisory, Inc., which was one of the
many subsidiaries parent company owned. Stan Caterbone acted as the architect and legal
administrator of the organization, in addition to building his own financial planning clients. He
filed all of the articles of incorporation in the Commonwealth of Pennsylvania and submitted all
of the tedious and rigorous filings necessary for the Pennsylvania Securities Commission, which

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 10 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 16 of 105


were very demanding considering Stan Caterbone, was selling stock of his company to his
associates and investors. Stan Caterbone and his associates had also attracted some very
prominent Lancastrians's to invest in his venture, coming from various professional circles, all
infatuated with this extraordinary and intriguing concept of this young victim (Stan J.
Caterbone). All had seen it's potential for success and financial reward.
Many of his friends were involved, and in Lancaster, everyone knows everybody, so it seams..
And everyone talks, gossip is as common as jogging. This exaggerated trait of Lancaster
County, will later to come back to haunt Stan Caterbone, in a way that is most sickening. In a
way that will parallel the attitudes and sentiments in the Lisa Michelle Lambert story.
In 1987, his business affairs were reaching a point of incredible success. In fact, most of his
family and friends, have always questioned the merits of their legitimacy. He always conducted
his affairs with the presumption that time could not afford the opportunity to complete his
agenda, while at the same time disclosing his business affairs to persons that were not directly
involved.. Accomplishing his mission was first and foremost. But in Lancaster County, that was
difficult. Lancastrians's have a notion to fear what they don't know, and will always believe
what they think they know, regardless of its merits. In Lancaster County new ideas are
shunned unless coming from their own, and their own ideas are often kept close at bay,
inhibiting progress and stymieing learning. By June of 1987, a majority of his business affairs
were conducted out of the grasp of Lancaster County, his unknown activities made others
curious, especially in Lancaster County, where the blessing of the power elite was essential for
success. But, deep down inside, he knew he could never be accepted, because he did not
descend from a family of "social grace". This fueled his aspirations for success even further,
committed to prove that intelligence was innate and learned, not a direct correlation to material
wealth or social grace.
An elder attorney, Mr. Kenellm Shirk, a very respected and prominent older Lancaster attorney,
who was part of the status quo, provided one of his most cherished testimonials to his concept,
his reputation, and his mission. Mr. Shirk had petitioned the Pennsylvania Bar Association, after
meeting with Stan Caterbone, to obtain their blessing and their knowledge of any laws which
would forbid his firm to provide a satellite office in the headquarters of Financial Management
Group, Ltd., (FMG) Mr. Shirks firm was to provide a partner, and estate services to the clients
of FMG. The Pennsylvania Bar provided a lengthy recommendation that did not prohibit a
relationship, although cautioned it to proceed with careful review. The fact that the very young
and unknown Stan Caterbone could attract an elder, conservative Lancaster County attorney to
associate with his firm was an encouraging sign of respect. Ironically, Mr. Shirk is the father of
Roy Shirk Jr., Lisa Michelle Lambert's first attorney who represented her during trial of 1992,
the proceeding which was the center of Judge Dalzall's controversial and appalling findings.

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 11 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 17 of 105


Stan Caterbone prided himself on his entrepreneurship, and after building the foundation for
FMG, he set out to take advantage of its resources and it's synergism.
By June of 1987, Stan Caterbone had developed a fairly substantial mortgage banking
relationship with a Houston, Texas banker. That operation was capable of providing lending to
potential developers and businesses in the range of $ 3 million to $100 million. And the lending
packages were as competitive if not more competitive than the local lending institutions of
Lancaster County, capable with even higher lending limits. In a matter of months of securing
this relationship, Stan Caterbone and his partner were evaluating deals from Pennsylvania, New
Jersey, New York, Florida, and as far away as California.
There was a uniqueness to his capabilities that was very appealing to potential borrowers.
Because of the vast array of services of FMG, potential developers had the opportunity to
obtain both debt and equity financing through his companies. In plain terms, most shopping
centers raised capital by raising funds through investors coupled with a mortgage. This gave
potential developers one place to "take down the deal" rather than dealing with many other
professionals at the same time. It was a much more efficient process for all. Stan Caterbone
was capable of providing a mortgage, while at the same time selling shares in a shopping
center through it's vast client base of investors at FMG. This also gave Stan Caterbone a
formidable presence into the venture capital markets, by way of his strong ability to raise
capital through his vast portfolio of clients of FMG. And this was a rarity that developers and
investors loved. Investors were attracted because they could invest in equity type real estate
projects with real sense of knowing the developer, or "kicking the bricks" of the project. This
was far different than investing in a nationally syndicated project, with properties scattered all
over the country, and with developers that they did not know. The synergistic approach to his
organization began paying dividends by developing other peripheral markets and businesses.
Given the complex nature of Stan Caterbone's design of FMG, internal struggles within the
organization readily became the challenge. Orchestrating the relationships among all of the
different professionals, and trying to adhere to the interests of the clients, the professionals
and of the firm, FMG, managing the daily activities required immense thought and prudence on
the part of the principals. Of, course, Stan Caterbone assumed honesty and integrity to be a
given. And for most it was. However there were times when the senior partner engaged in
tactical rights of power.
In the later part of 1986, after Stan Caterbone had developed FMG to the point where it's
future was on stable grounds, his two partners conveniently attempted to circumvent his
position and regain control of his stock and the firm. In fact, after Stan Caterbone refused to
collaborate on a scheme to "set up" his other partner, the remaining two partners began to
attempt to regain Stan Caterbone's control. Through intimidating techniques, the partners
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 12 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 18 of 105


began to attack his presence. Stan Caterbone became agitated, especially because he played
the lead role and was responsible for the formation of the company, methodically designing and
developing its foundation, with great success. And now after the company was beyond it's point
of greatest risk, due to in large part Stan Caterbone's efforts, the other two partners wanted to
take advantage of his work, and "take the cream of the pie" for their own financial gain. It was
a difficult task to carry out because Stan Caterbone was the most respected of all three
partners, consistently keeping their respective policies in the best interest of the firm and of the
other associates and stockholders. In fact, most feared that the loss of control of Stan
Caterbone would ultimately lead to adverse consequences. However the two partners trued
unsuccessfully to weaken his position, and when that didn't work, they focused on weakening
Stan Caterbone, via intimidation and humiliation The coup and hostile environment caused a
state of depression for Stan Caterbone, although he kept to his daily duties and responsibilities,
accordingly, he called a client and friend who was a psychiatrist, whom he trusted and
respected. It was easy access to a professional, yet on a very informal basis. Because Stan
Caterbone had a family history of "mental deficiencies", he wanted to seek the proper help.
The psychiatrist had diagnosed Stan Caterbone as having Bi Polar Mood disorder. The
psychiatrist had quickly discounted any correlation between the current state of affairs, and his
partner's abuse. The psychiatrist rationale was that "because the startup of the company was
so successful in such a short period of time" , and his demonstrated intelligence and creativity,
Stan Caterbone must have been in a state of mania, and of course now, was subsiding in a
state of depression, the typical cycle for manic depressants. Stan Caterbone complied with the
psychiatrist. And after refusing to sell out to his partners, vowed to regain his business and
rescind any efforts to give up his claim to his accomplishments. The depression soon faded.
Stan Caterbone never disclosed the fact that he had sought help to anyone other than family
members. This coup lead to Stan Caterbone's aggressive approach to grow the business, and to
posture himself in projects that would ultimately remain in his control, out of the influence of
his partners. Particularly of most interest was saving the mortgage banking activities and the
digital movie, which he did successfully, but apparently too successfully.
THE "DIGITAL MOVIE"
Through an act of fate, in February of 1987, Stan Caterbone found himself in a meeting with
Tony Bongiovi at Power Station studios. Through one of his partners, he reluctantly traveled to
New York to consider financing a motion picture. Stan Caterbone's own lack tolerance for the
risk associated with film investments was overshadowed by the opportunity to visit a recording
studio. Although his associate was a friend of Tony's, he was not familiar with his
accomplishments, or his work, so he thought. If nothing else, it was a weekend away from
Lancaster, and a chance to visit the Big Apple. Intriguingly, he found more than he had ever

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 13 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 19 of 105


imagined on that weekend excursion. Tony Bongiovi, a musical genius, who's credits include
one of the most recognized recording studios in the country, Power Station Studios. Tony
Bongiov produced the sound track for "Star Wars", and is responsible for the format of one of
the most successful recording artist of the 80's, Jon "Bon Jovi", his cousin. Power Station has
recorded the albums for some of the most influential artists of all time, including Diana Ross,
Madonna, The Rolling Stones, Steve Winwood, Bruce Springsteen, etc., Tony, an eccentric
genius, of Italian decent, had many talents, from music to aerospace engineering. Stan
Caterbone's associate's sister met Tony while he flew his plane into Lancaster's airport for
repairs. They dated for some time and Stan Caterbone's associate and Tony became friends,
which led Stan Caterbone to Tony's Power Station Studios.
Tony was looking to finance his new project, which was to be the first digital movie. And, given
Stan Caterbone's extreme appetite for technologies, coupled with his amazing sense of
perception, he dramatically recognized the future evolution for the technical merits of delivering
digital video and digital audio entertainment to the mass markets. By June of 1987, Stan
Caterbone was positioned as the Executive Producer, collaborating with Flatbush Films of
Hollywood California, the movie producers, entrusted with the mission of finding investors to
provide funding for the "first digital movie", and to manage the ensuing business elements it
required.
The movie was to be shot "on-location" at the Jersey shore points, mostly in Wildwood. Tony
strategically envisioned making a movie in the horror genre. There were several specific
reasons that supported this strategy. First, he determined that it was the least expensive
format to produce, we all estimated a budget of $4 million for the production and post
production. Secondly, the horror genre would compliment a very intense sound track. The
sound track was important to enhance the new digital format, and also provide the means to
introduce a new band that he had been grooming in his studio for the past several years,
"French Lick", his predecessor to "Bon Jovi". There had been bad blood between Tony and his
cousin "Bon Jovi", which resulted in legal disputes pertaining to Tony's financial interests in
Jon's success. It was an unfortunate situation considering Tony's father and Jon's father were
brothers living in the same area. It was a subject that Tony never wanted to discuss, except for
his contributions toward Jon's career.
If by another act of fate, Stan Caterbone had the privilege of meeting one of the many
superstars while working at Power Station studios. While growing up, at an early age, Stan
Caterbone would sneak up into the bedroom of his oldest brother, and start up his old General
Electric stereo phonograph and listen to his favorite album - Diana Ross and the Supremes. It
was a passion and a ritual that provided an early infatuation to music, and to Diana Ross. Stan
Caterbone was only 10 or 11 years old. And at this early age, he noticed and listened to the

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 14 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 20 of 105


annoying hiss, that conventional hiss that always seemed to overshadow the music, whether
played on an album, on the radio, 8-track tape, or cassette.
And in a mystical twist of fate, while engrossed in a project dedicated to delivering music
without that hiss (digital) - Stan Caterbone opened the door to the recording suite to pack his
bags for the journey back to Lancaster; - and there she sat, with a glowing array of beauty,
more beautiful than any picture could ever tell, Ms. Diana Ross. She was pregnant and in the
middle of a recording session, for a new album. Her assistant quickly demanded, in a stern and
protective voice, that we leave, and Stan Caterbone and his associate replied "this is our
makeshift bedroom, we are just gathering our belongings". Stan Caterbone walked toward
Diana Ross, who was seated near his bag, and she asked "and who are you?", Stan Caterbone
calmly replied his name and absorbed as much of her beauty as his eyes could behold before
walking out the door. The room that was his bedroom the nigh before, and suddenly transfixed
into the recording suite of Diana Ross, thinking back some twenty years earlier, one of the
many gifts that God would bestow upon him. A living memorial and reminder to his older
brother, who died on Christmas day of 1985, his best friend who taught him two of his greater
pleasures in life, Diana Ross, and listening to music. He prayed that his brother was watching
from above.
And so, the digital movie project that Stan Caterbone had embraced in 1987 had personal
significance, and he never ever doubted his instincts regarding the technical merits of the
project. Stan Caterbone's perception that the entertainment industry would deliver full length
motion pictures in a truly digital medium will later become a truly remarkable vision.
The technical merits of this project and at this particular time with respect to Stan Caterbone's
extreme sense of perception require analysis. To truly understand this time perception, some of
the attributes of digital technologies need to be fully understood. In 1987, Compact DISC (CD)
technology was only now being introduced to the commercial markets. Stan Caterbone's own
crafting of his joint venture proposals, dominated by the term "digital movie", is in itself some
4 or 5 years away. In 1987, there was very little use of the term "digital", with the exception of
research and development engineers. Stan Caterbone will, throughout the documentation of
this story, will have preceded a terminology that has literally become the root of most
technological advancements in the computer and telecommunications industries of our present
day, 10 years after Stan Caterbone's vision. Today, "digital" is found to be part of or referred to
in just about every product available in the commercial markets.
During May of 1987, Stan Caterbone had created a joint venture proposal for SONY
Entertainment, Inc., for the digital movie. After weeks of researching the current state-ofaffairs within SONY, and after his proposal was completed, SONY publicly announced their
desire to open the markets for new and emerging technologies on the cover of TIME magazine,
Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 15 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 21 of 105


another demonstrated sense of perception. It was this proposal, when delivered to one of the
Hollywood producers in Santa Monica, California, after reading a draft of the proposal she said
"you are a genius". The proposal was introduced to Tony Bongiovi at the Wildwood Boardwalk,
where many of scenes were to be shot, and he approved of the proposal and thought that it
had great merits. Tony, who wanted very to do with the business elements of his project, gave
Stan Caterbone complete authority to secure the financing of the project, with a salary as
Executive Producer, and a percentage of the profits on the back end.
After review of Stan Caterbone's research and proposal's, his vision and his passion,
unfortunately without his efforts, has come to be known as Direct Satellite System, or DSS,
which is Sony's satellite entertainment system (TV), delivering digital audio and digital video
entertainment. That technology is fast eroding at the cable industry. Stan Caterbone had his
patent research center around the PSDMS system, the Power Station Digital Movie System. And
that was in 1987, some seven years before SONY delivered his dreams. Later Stan Caterbone
would also accurately predict that the 90's would become the "Information Age" because of the
direct contributions and advancements of "digital technologies", which is directly responsible for
the development of the "INTERNET".
Stan Caterbone's obsession with his "digital movie" has proven to be one of his most
remarkable demonstrations of his keen sense of perception.
The author admitted in an affidavit in 1998 that he did not know the criminal culpability of Lisa
Michelle Lambert, and further argues that it was because of the prosecutorial misconduct and
the erroneous handling of the crime scene that the truth evaded both the prosecution and the
defense as to who actually killed Laurie Show.
_________________________________________________

Date: April 28, 2016

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

/S/
Stanley J. Caterbone, Pro Se
Freedom From Covert Harassment and Surveillance
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com
scaterbone@live.com
(717) 669-2163

Page 16 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 22 of 105

EXHIBIT

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 17 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 23 of 105

Stan J. Caterbone
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163

November 12, 2015


Ms. Kathleen Kane
Pennsylvania Attorney General
16th Floor Strawberry Square
Harrisburg, Pennsylvania
Re: Old Boys Network filed in GENERAL OAG QUESTIONS November 11, 2015
November 11, 2015 7:42am
"Kane, the first woman and Democrat elected to the position of Pennsylvania's top
prosecutor, has dismissed the case as a backlash over her challenge to what she
calls the old-boys' network in Pennsylvania law enforcement." LNP, Attorney
General Kane faces trial on more charges, by the Associated Press on November 11,
2015.
Back in 1998 I had a meeting with an NSA (National Security Agency, Ft. Meade, Md)
operative in a parking lot of a former car dealer in York, PA. I had just attended a job
fair and he approached me as I was about to get into my car. He introduced himself
as being from the NSA and I questioned him about why they would not leave me
alone. His response was "It is not US (NSA) it's the Good Ole Boys". I also have
a huge problem with modified, stolen, and planted documents. We parted ways in an
amicable fashion.
Stan J. Caterbone Advanced Media Group
717-669-2163
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-TargetedIndividual-of-U-S-Sponsored-Mind-Control-Executive-Summary-Updated-October12-2015

Stan J. Caterbone

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 18 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 24 of 105

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 19 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 25 of 105

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 20 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 26 of 105

EXHIBIT

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 21 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 27 of 105

Stan J. Caterbone
ADVANCED MEDIA GROUP

Freedom From Covert Harassment & Surveillance,


Registered in Pennsylvania

1250 Fremont Street


Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
scaterbone@live.com
717-669-2163

April 20, 2016

Stan J. Caterbone/Advanced Media Group Biography


Present - Advanced Media Group, President, Owner, and Founder.
In 1987 I became a federal whistleblower for the case of local defense contractor International Signal
and Control, or ISC. ISC was a black ops program for the NSA and CIA that was convicted in 1992 for
an elaborate scheme to arm Iraq and other Middle Eastern countries with a broad array of weapons,
most notably cluster bombs. It was the third larges fraud in U.S. History at that time. I have been a
victim of organized stalking since 1987 and a victim of electronic and direct energy weapons since 2005.
I had also been telepathic since 2005. In 2005 the U.S. Sponsored Mind Control turned into an all-out
assault of mental telepathy; synthetic telepathy; hacking of all electronic devices; vandilism and thefts
of personal property, extortions, intellectual property violations, obstruction of justice; violations of due
process; thefts and modifications of court documents; and pain and torture through the use of directed
energy devices and weapons that usually fire a low frequency electromagnetic energy at the targeted
victim. This assault was no coincidence in that it began simultaneously with the filing of the federal
action in U.S. District Court, or CATERBONE v. Lancaster County Prison, et. al., or 05-cv-2288. This
assault began after the handlers remotely trained/sychronized Stan J. Caterbone with mental telepathy.
The main difference opposed to most other victims of this technology is that I am connected 24/7 with
the same person who declares telepathically she is a known celebrity. Over the course of 10 years I
have been telepathic with at least 20 known persons and have spent 10 years trying to validate and
confirm their identities without success. Most U.S. intelligence agencies refuse to cooperate, and the
Federal Bureau of Investigation and the U.S. Attorney's Office refuse to comment and act on the
numerous formal complaints that are filed in their respective offices. Most complaints are focused on
the routine victimization's of a targeted individual including but not limited to stalking, harassment,
threats, vandalism, thefts, extortion, burglaries, false imprisonments, fabricated mental health warrants
or involuntary commitments, pain and torture to the body, and most often the cause of obstruction of
justice is the computer hacking.
I have a very sophisticated and authentic library of evidence of the use of U.S. Sponsored Mind Control
technologies on my father and brother that dates back to the 1940's while my father was in the U.S.
Navy after he graduated with honors from Air Gunners School in Florida, including an affidavit motorized
and authenticated by my father in 1996. My brother served in the U.S. Air force and was victim to LSD
experiments of the infamous MKULTRA program in the late 1960's.
In 2015 I filed an amicus curie on behalf of Lisa Michelle Lambert who was convicted in 1992 of the
murder of Laurie Show, both of Lancaster, Pennsylvania. I currently am in litigation in the U.S. Third
Circuit Court of Appeals and in February of 2016 Lisa Michelle Lambert published her book titled
Corruption in Lancaster County My Story, which is available in bookstores and on Amazon.com. I
am in frequent contact with her co-author, Dave Brown of Philadelphia, Pennsylvania.

Stan J. Caterbone/Advanced
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page22
1 of 48
6

Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 28 of 105

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

Stan J. Caterbone/Advanced
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page23
2 of 48
6

Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 29 of 105

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

Stan J. Caterbone/Advanced
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page24
3 of 48
6

Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 30 of 105

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

Stan J. Caterbone/Advanced
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page25
4 of 48
6

Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 31 of 105

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

Stan J. Caterbone/Advanced
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page26
5 of 48
6

Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 32 of 105

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

1250 Fremont Street


Lancaster, PA 17603
www.amgglobalentetainmentgroup.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

Stan J. Caterbone/Advanced
Superior
Superior
Court
CourtNo.
1164
8423-15
Amicus
Amicus
Media
re Kathleen
Group Biography
Kane
Page
Page27
6 of 48
6

Wednesday,
Thursday,
Thursday,April
April 28,
20, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 33 of 105

EXHIBIT

Superior Court
Superior
CourtNo.
1164
8423-15
Amicus
Amicus
re Kathleen Kane

Page 28 of 48

Thursday,
Thursday,April
April 28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 34 of 105

Stan J. Caterbone
ADVANCED MEDIA GROUP

Freedom From Covert Harassment & Surveillance,


Registered in Pennsylvania

1250 Fremont Street


Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
scaterbone@live.com
717-669-2163

April 16, 2016

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


In 1987 I became a federal whistleblower for the case of local defense contractor International
Signal and Control, or ISC. ISC was a black ops program for the NSA and CIA that was convicted in
1992 for an elaborate scheme to arm Iraq and other Middle Eastern countries with a broad array of
weapons, most notably cluster bombs. It was the third larges fraud in U.S. History at that time. I have
been a victim of organized stalking since 1987 and a victim of electronic and direct energy weapons
since 2005. I had also been telepathic since 2005. In 2005 the U.S. Sponsored Mind Control turned
into an all-out assault of mental telepathy; synthetic telepathy; hacking of all electronic devices;
vandilism and thefts of personal property, extortions, intellectual property violations, obstruction of
justice; violations of due process; thefts and modifications of court documents; and pain and torture
through the use of directed energy devices and weapons that usually fire a low frequency
electromagnetic energy at the targeted victim. This assault was no coincidence in that it began
simultaneously with the filing of the federal action in U.S. District Court, or CATERBONE v. Lancaster
County Prison, et. al., or 05-cv-2288.
This assault began after the handlers remotely
trained/sychronized Stan J. Caterbone with mental telepathy. The main difference opposed to most
other victims of this technology is that I am connected 24/7 with the same person who declares
telepathically she is a known celebrity. Over the course of 10 years I have been telepathic with at least
20 known persons and have spent 10 years trying to validate and confirm their identities without
success. Most U.S. intelligence agencies refuse to cooperate, and the Federal Bureau of Investigation
and the U.S. Attorney's Office refuse to comment and act on the numerous formal complaints that are
filed in their respective offices. Most complaints are focused on the routine victimization's of a targeted
individual including but not limited to stalking, harassment, threats, vandalism, thefts, extortion,
burglaries, false imprisonments, fabricated mental health warrants or involuntary commitments, pain
and torture to the body, and most often the cause of obstruction of justice is the computer hacking.
I have a very sophisticated and authentic library of evidence of the use of U.S. Sponsored Mind
Control technologies on my father and brother that dates back to the 1940's while my father was in the
U.S. Navy after he graduated with honors from Air Gunners School in Florida, including an affidavit
motorized and authenticated by my father in 1996. My brother served in the U.S. Air force and was
victim to LSD experiments of the infamous MKULTRA program in the late 1960's.

Stan J. Caterbone
Superior
Superior
Court
CourtNo.
1164
8423-15
Story
Amicus
and
Amicus
Evidence
re Kathleen
of Kane
a TI
Targeted
Page
Page
Individual
291of
of48
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 35 of 105

In 2015 I filed an amicus curie on behalf of Lisa Michelle Lambert who was convicted in 1992 of
the murder of Laurie Show, both of Lancaster, Pennsylvania. I currently am in litigation in the U.S. Third
Circuit Court of Appeals and in February of 2016 Lisa Michelle Lambert published her book titled
Corruption in Lancaster County My Story, which is available in bookstores and on Amazon.com. I
am in frequent contact with her co-author, Dave Brown of Philadelphia, Pennsylvania.
In 2009 I Proposed an ORGANIZED STALKING AND DIRECTED ENERGY WEAPONS HARASSMENT
BILL to Pennsylvania House of Representative Mike Sturla (Lancaster, Pennsylvania) and City of
Lancaster Mayor Richard Gray in 2009. The draft legislation is the work of Missouri House of
Representative Jim Guest, who has been working on helping victims of these horrendous crimes for
years. The bill will provide protections to individuals who are being harassed, stalked, harmed by
surveillance, and assaulted; as well as protections to keep individuals from becoming human research
subjects, tortured, and killed by electronic frequency devices, directed energy devices, implants, and
directed energy weapons. I again reintroduced the bill to the Pennsylvania General Assembly in 2015
and frequented the Pennsylvania Capitol trying to find support and a sponsor; which I still do to this
day.
In 2005 I, as a Pro Se Litigant filed several civil actions as Plaintiffs in the United
States District Court for the Eastern District of Pennsylvania, the United States Third District
Court of Appeals, the Pennsylvania Supreme Court, The Pennsylvania Superior Court, the
Commonwealth Court of Pennsylvania, The Court of Common Pleas of Lancaster County,
Pennsylvania. These litigations included violations of intellectual property rights, anti-trust
violations, and interference of contracts relating to several business interests, harassment,
extortion, fraud, etc.,. . Central to this litigation is the Digital Movie, Digital Technologies,
Financial Management Group, Ltd,/FMG Advisory, Ltd., and its affiliated businesses along
with a Federal False Claims Act or Federal Whistleblowers Act regarding the firm of
International Signal and Control, Plc., (ISC) the $1Billion Dollar Fraud and the Export
violations of selling arms to South Africa and Iraq. This litigation dates back to 1987. In
1987 I microfiched some 10,000 pages of documents that prove this story without any doubt.
I also have recorded conversations of persons and government officials.
Stan J. Caterbone, Pro Se Litigant
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania

1250 Fremont Street


Lancaster, PA 17603
www.amgglobalentetainmentgroup.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

Stan J. Caterbone
Superior
Superior
Court
CourtNo.
1164
8423-15
Story
Amicus
and
Amicus
Evidence
re Kathleen
of Kane
a TI
Targeted
Page
Page
Individual
302of
of48
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 36 of 105


Stan J. Caterbone Affidavit

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3113of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 37 of 105


Stan J. Caterbone Affidavit

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3224of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 38 of 105


Stan J. Caterbone Affidavit

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3335of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 39 of 105


Stan J. Caterbone Affidavit

! "

"

$% &
!

" #

%
"&#
(

'
!

(
,

"

"

")

"

""
-

)
!
! "
!

'
%

" !
"

!
)

+
!

" *
"

"
,

,
,

*
%

*
(

%
!
/"0

1
1 ,
"
"

4
!

"

"
!

!
#
.

.
&,,0
%

1 ,

2"3

!
)

** ! "
&,,..$/

&,,

%
&,,
%

&

, "

"

00

"

!,

"

6
7

7 , !
&,,-

8,
:
(

$;$

"2

! " ,

, ,

** !

;
5

$
!

&,,@

,
.

&<;=

>
1

9
,

&,,=
$

,
>
A

1 B3

.+

&,,=
1 B3

2
>
%

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3446of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 40 of 105


Stan J. Caterbone Affidavit

<

1
1

* "
!

"
C#

"$

"

<
*

&, ,

24

#9

; "
&,,@(&,,= A
3
24
5
!
%

&,,0 4
! %3

"

"

!
&,,
%

!
4

'
5

4
D

%
%

"

""

,! "
0 =

0 =9

9
00&9 00

:
9

&,,-

&, , $
!

%
!
D

%
%

=
F
!

))
+

/4

),

"

0 =

/
$

G
3

%
00

3
3

"

%#
$

$
&, ,

&,,4

!- "

.
&,,@

,
*

&,,<
E

&,,

-) !
/ 4

24
/

$
D

&, ,
D

$
&,,-

&,,0

%
D

!
D
D %
7F !
>
!
D

$
A
8F
$

%
;

D
.

%
&,,3
E
$

*
00=; 00

$
5

! 7

0 =
00

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3557of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 41 of 105


Stan J. Caterbone Affidavit

)
A

24
$;$

00
(F

&

%
B

5
00 9

" * <
00=( 00 9

:#

> ) "" ""


$

;3

#, " !
&,,-

"

"

"

0 =
&, ,

/
.
$

B
3

3
=

0 =

) "

.
&,,1

0 =

24

" "
3

"
&,,@

" E

""

B
$

<

&,,1

.
&,,-

,-(&&
2

=
@,

"

&,
3

&,,!

&,,@

&,,@

0 =
@, 1

&,,@
9
!
@,

#" !,
0 =

" "1 ,

"

"*

":

" E
F

&,,-

!
B

/
!

"

00=( 00 9
B
:
9

$
'

.
&,,1
9

0 =
&, ,

/
.

00 9

/
&,,9

&,

( "

!
.

00

$
!

&, ,
F

3
7

8
!

&,,

&, ,

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3668of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 42 of 105


Stan J. Caterbone Affidavit

&

, * "

&&

*#
"

&:

;!

&<

:
%

$
&, ,

$
&,,-

!-

,
5
%

"

>

$
$

< !-

24

? "
;

>

&,,0
B

&,,%
(

$
&, ,

&-

A
.+ $

&@

! :

&,,$

: , *

&, ,

* @

&,,@

"
E

3
&,,

"

&,,0

7 "!

7 "
0 =
*

&=

) "

":

)"

&,,@
"

&

&0

!
< ")
+
9 &,,@
:
9
&, ,
&,,

00

:,

!6

"

"

" .
9 &,,0

0 = "&#

, *

&,,@
/

" F
0 =

;A

0 =
F

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
3779of
of
of48
27
29

0 =

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 43 of 105


Stan J. Caterbone Affidavit
3
"
+

$
1

$
.

0 =

I $
!

0 =

.
$

"2

'

+$;F
D
"$

&,;&,
3
A

00

'
$ 24

"1E1# $

K
E
A

00&

>

L
F

F
B

F
+

0=,K
A

$
$

1
+

>

1
$
>

B
!

3
F

1
00
) % 3
&,,-

!
>

! A !

00,K
1 B3
>

F
F
& 1

F
8

! 4

'
A

! 4

A
0=,K

F
00,K

0 ,K

0<,K

3
/

>

%
&,,

) %$

0@,K
0@,K
$

2!
A

D 1

"
$

0 <9 F

4
A? D!B
#
*

$
7

+
00

D 18

.
E

$
M 1
00= E

0 =
%

0 ,K
$

0 =

M
00
!

&,,9

(
9

!
1

,-(

$ !2B+EF2

(&&

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
38
10
8 of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 44 of 105


Stan J. Caterbone Affidavit

") !

"

7!

N
.
!
5
F

(
(

5
G
*

A'
, ?
*
? 1
!,
A
(
> "
!, '!

,
B

A
" " * #" !, " "

$C

* #" !, D

73

8
* 7

,
"

"

&

"
#

.
"

#(

5
7
9

'
5

%
7A

8 !

8 !

'

!
7D .2

O
% 8

'
7

'

(
(

%
%

4
K
K

M %

%
K
'

7E

(
8

"

%
'

%(

(
(

4
;

(
7
7

87

(
(

8
8

- 7 > !,

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
39
11
9 of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 45 of 105


Stan J. Caterbone Affidavit
!
!
@
E
!
DD
@
E
!
DD
B &. @
DD
B@
. DD
")
!
"
B@
& DD
)
B@
. DD
)
*
B@
& DD
)
!
B@
$ DD
")
!
B@
DD 7
B@
E
DD
"! "
*
. @
EB& DD
!
*
. @
EB DD
")
!
& @
& B DD 6, "
1
B@
DD 5
B@
& DD
B@
DD
)
1
B@
& DD >
B@
DD ' "
!
B@
)
B@

E DD

)
*

"E

* , "
,
!

1
3
1

))

1"

"

, "

*"

"
, "

!
*

"

")

"

7
*
)

*
, "
1 ,!
, "
)
!
"
"
!
!
1
"": !
, 1
"": !
"
1
"": !
!
"
! * !
*

!"

, "

"

"

"

1 ,"

DD

*)

PPPPPPP "

>7

%#

'?

Stan J. Caterbone
# PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP

"

Stan J. Caterbone
# PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP

"

June 19, 2015


PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP

Pennsylvania
PPPPPPPPPPPPPPPPPPPPPPPPPP
$
Lancaster
PPPPPPPPPPPPPPPPPPPPPPPPPPPPP
19
PPPPPPP

15
June
PPPPPPPPPPPPPPPPPPPPPPP
&,PP

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


PPPPPPPPPPPPPPPPPPPPPPPPPPPPPPPP
F
PPPPPPPPPPPPPPPPPPPPPP
SJC
I
.

I
&, ,

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
40
10
12of
of
of48
27
29

Don't Know When

24

$
$

Q &, , "!
I

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 46 of 105


Stan J. Caterbone
Samuel
P. Caterbone
Affidavit
Jr., (Father) Affidavit

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
41
11
13of
of
of48
27
29
THE ADVANCED MEDIA GROUP

Page 35 of 41

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
06/10/2007

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 47 of 105


Samuel P. Caterbone Jr., (Father) Affidavit

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
42
12
14of
of
of48
27
29
THE ADVANCED MEDIA GROUP

Page 36 of 41

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
06/10/2007

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 48 of 105


Sammy Caterbone (Brother) Affidavit

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
43
13
15of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 49 of 105


Sammy Caterbone (Brother) Affidavit

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
44
14
16of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 50 of 105


Sammy Caterbone (Brother) Affidavit

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
45
15
17of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 51 of 105

September 25, 2009

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
46
16
18of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 52 of 105

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
47
17
19of
of
of48
27
29

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016

What is CCHR?

1 of 2

http://www.cchr.org/about-us/what-is-cchr.html

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 53 of 105

ABOUT US

VIDEOS

TRUTH ABOUT PSYCHIATRY

ALTERNATIVES

TAKE ACTION

ORDER

The Citizens Commission on


Human Rights was originally
formed in 1969 as a global
watchdog committed to
investigating and exposing human
rights violations in the field of
mental health. From its
headquarters in Los Angeles,
CCHR coordinates activities
amongst its chapters around the
world.

HOME ABOUT US WHAT IS CCHR?


SUBSCRIBE
TO CCHR NEWS

< ;

WHAT IS THE CITIZENS COMMISSION ON HUMAN


RIGHTS?
! !"
#'

FREE INFORMATION KIT


AND DVD

$$!##!

($

))

* #
!

(
Restoring Human Rights and
Dignity to the Field of Mental
Health

'#/

, #!

About Us
Accomplishments
Message from the President
Board of Advisors

)#+

'

'#/

) . )! ! / (

'!

# % ##

#!
(

//

))

! (

$ !

$( )
!

! ! #!

'

!#

)!

!
(

#!# (

))
#+

'
.

,! #

')

!
$ !

#
! (

&

! (

))

#+

0 '#/

* !

, #

.! !

)+

!. #

'
#

' )! !

#+

!#)

)
.

))/ '

.!#

.
$

# /
')

#+ )

!# # *

!#

!
(

/$

!#

!# #+ ) */
!

! ))/ ! (

( 1#/
#

#!

6# 7

#+

( ##

!#9 2 '

#!

# ))

!#0# (
$

* /

'! !

!#

# 5

'! !

3'

#!

0!

) ( 4 !#

+ % & ))

( #

# ( * '#/

!# #+ '#/

!# (

.! *+ %7&

# !,

'

$
#

# ) )/

!.!)

!#

))

)8
0

*
$ , #!.

+*

# / #

!# #

)/ #0 !(

% &

)!

)
)# (

,)

, !

#+ # !

!# * ,#!

# #

)3

# $

( ##!

!.!

#*

!# #+

!" !

$ ) !,!))!
0

$
(!

#+ !

## '

') (

,! )

' !

#+ ,

What is CCHR?

'

)!
$

( #

' !

, #! !

)
#+ # !

(! $

!#0# ( '#/

'

+ ( )) ! (

)+ !.!)

! 3'

#+

#!#+

!$ *
!

! #

$$!##!

,/

# # ) )/ #

)# !

)! !

)!$!

!. #

#!

,/

Order a Free
Citizens Commission on
Human Rights Information Kit

" #"

( ))

+,

!
$ #

& !#

) )

( ##!

/ ( '#/

#2

# !''

'

+!

#%

- ) *# '

#)
)

! !$

)) . !) ,) $

)'!

!. '
(! )
$

#!,) (

$ !

()!
, !

%2&

$( )

Leadership
#*

CCHR Financials

Mental Health Declaration

! (

$ !

$!

#(

( )) ! (
!

# *!

'#/
. #

#
!

!
!

(! )

($

# #

# ! 0

'!

)
+

' ,)! !

0
!# !
! (

CCHR
CHAPTERS WORLDWIDE

(
!

: #

Psychiatry: An Industry of
Death Museum
CCHR Global Locator

!# #'! !

$ !
'

* '

#!
(!

$/
!" !

*!

*!

+ ! !#

Stan J. Caterbone
Superior
Superior
Caterbone,
Court
CourtNo.
1164
8423-15
Story
Targeted
Amicus
and
Amicus
Individual
Evidence
re Kathleen
of
Evidence
Kane
a TI
Targeted
Page
Page
Page
Individual
48
18
20of
of
of48
27
29

.!

#+ ,)

#+

*#+ $

) ;'

#
' ,)!

,)

Thursday,
Saturday,
Thursday,April
April 16,
28, 2016
11/6/2015 12:42 AM

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 54 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 55 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 56 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 57 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 58 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 59 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 60 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 61 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 62 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 63 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 64 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 65 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 66 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 67 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 68 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 69 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 70 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 71 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 72 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 73 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 74 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 75 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 76 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 77 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 78 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 79 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 80 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 81 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 82 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 83 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 84 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 85 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 86 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 87 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 88 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 89 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 90 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 91 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 92 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 93 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 94 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 95 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 96 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 97 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 98 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 99 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 100 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 101 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 102 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 103 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 104 of 105

Case 5:15-cv-03984-JCJ Document 52 Filed 05/17/16 Page 105 of 105

www.amgglobalentertainmentgroup.com
mailto:amgroup01@msn.com
717.427-1621 Fax

Stanley J. Caterbone
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603

UNITED STATES DISTRICT COURT


EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

__________________________________________________________________________

American Civil Liberties Union, American


Civil Liberties Union Foundation;
American Civil Liberties Union of
Michigan; Council on American-Islamic
Relations; Counsel on American-Islamic
Relations Michigan; Greenpeace, Inc.;
National Association of Criminal Defense
Lawyers; James Bamford; Larry Diamond;
Christopher Hitchens; Tara McKelvey; and
Barnett R. Rubin,
Plaintiffs
v.
National Security Agency/
Central Security Service, and Lieutenant
General Keith B. Alexander, in his
official capacity as Director of the National
Security Agency and Chief of the Central
Security Service,
Defendants

:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:

Case No. 2006-cv-2095


Case No. 2006-cv-2140
Honorable Anna Diggs Taylor

__________________________________________________________________________________

BRIEF ON BEHALF OF AMICI CURIAE STANLEY J. CATERBONE


and ADVANCED MEDIA GROUP
IN SUPPORT OF PLAINTIFFS MOTION FOR PARTIAL SUMMARY JUDGMENT

_________/s/_______________
Date: February 20, 2007

Advanced Media Group

Stanley J. Caterbone, Pro Se Litigant


220 Stone Hill Road
Conestoga, PA 174516
717-427-1821 facsimile
amgroup01@msn.com
Page 1 of 20

02/21/2007

__________________________________________________________________

TABLE OF CONTENTS
_____________________________________________________________

I.

STATEMENT OF INTEREST OF AMICUS CURIAE ......................3

II.

BRIEF IN SUPPORT OF AMICI CURIAE STANLEY J. CATERBONE AND


ADVANCED MEDIA ..5

III.

ARGUMENT 21

Advanced Media Group

Page 2 of 20

02/21/2007

__________________________________________________________________
STATEMENT OF INTEREST OF AMICUS CURIAE
__________________________________________________________________
Stanley J. Caterbone is a private citizen and the majority shareholder of the United States
incorporated business Advanced Media Group.

Stanley J. Caterbone was a whistle-blower and

shareholder in 1987 involving the United States Defense Contractor International Signal & Control,
Plc., known as ISC. In 1992, International Signal & Control was indicted and found guilty of among
other things a Billion Dollar Fraud and export violations concerning illegally shipping cluster bomb
technologies, missile defense systems, and other defense systems to foreign interests including South
Africa, Iraq and Saddam Hussein. Cluster bombs and related technologies are known to have been
exported to Iraq by the Chilean Arms Dealer Carlos Cardoen, a joint venture partner of International
Signal & Control.

The Central Intelligence Agency is confirmed to have been involved in a covert

program to arm Iraq during the 1980s with close ties to International Signal & Control, which
allegedly included the help of the National Security Agency, a former end user of International Signal &
Control technologies under the early 1980s program Project X. A Presidential Finding in 1984 by the
Bush Administration was executed to implement the program of arming Saddam Hussein and Iraq with
the cluster bomb technologies. Serious allegations of these programs were the focus of investigations
that included the knowledge and supervision of then appointed nominee for the Director of Central
Intelligence Agency, Robert M. Gates.
Since 1987, Stanley J. Caterbone has been the victim of vast civil conspiracy that started in
1987 to cover-up allegations of fraud within International Signal & Control during the negotiations and
merger of International Signal & Control and Ferranti International of England. Stanley J. Caterbone
alleges that warrantless surveillance was used to obstruct justice and moot his constitutional rights in
an effort to divert attention away from his allegations of fraud within International Signal & Control
back in 1987, and afterwards to the present as a means to deny his access to the courts for remedy
and relief, and Federal False Claims Act violations. The business of Advanced Media Group has been
greatly compromised and intellectual property stolen during the late 1980s and early 1990s that
included information technology contracts with the United States Government.
In January of 2006, Stanley J. Caterbone was detained at every airport security check point,
which was during a policy of random checks, and taken out of line during travel from Philadelphia,
Pennsylvania, to Houston, Texas, and on to Puerto Vallarta, Mexico. At the Houston Airport, Stanley J.
Caterbone was falsely accused of carrying plastics explosives and taken to an interview room by
Homeland Security officials. Stanley J. Caterbone was also detained for three days in Mexico, and was
not provided with an opportunity to gain access to a flight out of the country by Mexican Officials.

Advanced Media Group

Page 3 of 20

02/21/2007

The interest of amicus in this case is ensuring that constitutional rights of private citizens are
not compromised and justice subverted through information obtained from warrantless surveillance
upon which there is no just cause for any allegations or association with terrorism. Whistle-Blowers
are inherently supportive of a system of checks and balances within our government that go beyond
our constitutional doctrines regarding the same.

Whistle-Blowers ensure that the rule of law is

universally applied to all government officials in all branches of government. The Federal False Claims
Act and its provisions protect individuals from abuse of power, while providing relief and remedies for
those that were wronged and those that had the courage to cite a wrong.
It is too easy for present and future administrations to abuse their power and utilize
warrantless surveillance as a means of subverting and obstructing justice for those that are engaged in
Whistle-Blowing cases that concern National Security.

Without the proper oversight and judicial

review, a Whistle Blower can be place on terrorist lists for malicious reasons without the knowledge or
just cause. This is in direct conflict with keeping our democracy free of corruption while adhering to
the spirit of the constitution in the manner our founding fathers envisioned.

Advanced Media Group

Page 4 of 20

02/21/2007

__________________________________________________________________________

BRIEF IN SUPPORT OF AMICUS CURIAE

__________________________________________________________________
Background Information: The following transcripts from National Broadcast Television, ABC News
Nightline and ABC News 20/20; provide material information as to the activities of International Signal
& Control and the importance of these matters with regard to National Security.
ABC NEWS 20/20 FEBRUARY 1, 1991
[Lynn Sherr ABC News 20/20 Correspondent] This is the story of how this deadly weapon,
designed for the U.S. military made its way form this country to Iraq. And how American Soldiers may
face the devastation of a cluster bomb if a ground war breaks out in the Persian Gulf. Federal Officials
believe Saddam Hussein got his arsenal thru a lethal combination bureaucratic foul ups in the U.S.
Government and simple greed.
Here is how the cluster bomb works. An artillery shell, an airplane, or a rocket launcher sends the
bombs toward their targets.

Each bomb carries hundreds of smaller bomlets, something like hand

grenades. Cluster bombs can be used against ground troops or tanks, and can even scatter mines to
lie dormant for days. The bombs can spray thousands of pounds of sharp objects pins or even razor
blades. The shrapnel can rip through anyone or anything in its way, causing massive casualty among
civilians or ground troops.

You can see the destruction in these buildings in Lebanon after a cluster

bomb attack.
How did Iraq obtain the cluster bombs and the ability to make their own? It was incredibly simple.
Investigators believe it started with International Signal & Control, A government contractor with
5,000 employees based in Pennsylvania, which build key components of cluster bombs in a subsidiary
in California. 20/20 has learned Federal Investigators believe ISC provided the technology, that is the
plans, to this man, Carlos Cardoen, Chilean arms dealer.

Authorities believe he used the plans to

build the cluster bombs in Chile, then he shipped them to Iraq.


Whats wrong with all this?

If the cluster bomb technology actually left the county, that is illegal

without U.S. Government permission, investigators say ISC never got. It is also illegal for a foreigner,
like Cardoen, to take the plans out of the United States without a license, which sources tell us, he
never obtained. The man who opened the door to Iraq for Cardoen, was this man Nasser Bedouin. He
is a Lebanese born middleman for Cardoen who is based in the United States. Bedouin traveled often
to Bagdad, and arranged for sale cluster bombs and other military hardware to Saddam Husseins
army. In his first television interview, he told us about the business of dealing in deadly weapons.

Advanced Media Group

Page 5 of 20

02/21/2007

[Nasser Bedouin, Arms Dealer] I can sell you a knife to peel an apple, if you cut someones
throat, thats your business. Weapons do not kill, who behind them kill.
[Lynn Sherr ABC News 20/20 Correspondent] With slick promotional videos, Cardoen marketed
his arms throughout the world. Arab countries were favorite customers.
[Cardoen Marketing Video] Each one of the bomblets of the cluster bomb is multi purpose and
contains an incendiary, anti personnel and anti armor detection.
[Lynn Sherr ABC News 20/20 Correspondent] This letter from Cardoen authorizes Bedouin to
sell cluster bombs to Saddam Hussein during his war with Iran.

This letter says Cardoens company is

willing to take its share in helping Iraq in its time of need. We can provide you with our cluster bombs
at the lowest possible price. According to these contracts the sale of cluster bombs to Iraq was an
extremely lucrative business. February 24, 2984 3,000 cluster bombs sent to Saddam Husseins army
worth $21 million dollars.
dollars.

A few months later, another 3,000 cluster bombs, another $21 million

The supply of cluster bombs eventually totaled more than $400 million dollars.

In fact,

Bedouin is suing his former boss for commission payments.


According to Bedouin, Cardoen not only sold the bombs produce in Chile to Saddam Hussein, he
actually set up a factory near Bagdad.
bombs.

So the Iraq President could mass-produce his own cluster

That was one of the first attacks by the military when the attack began.

Its unknown

whether that plant is totally out of commission.


[Nasser Bedouin, Arms Dealer] He set up a factory to manufacture the cluster bomb. Um, ah
later stage for the fuses. And this is a complete project. I mean its completer from raw material to
finished product. Because the purpose in Iraq is to have control over the weaponry they have put in
their strategy.
[Lynn Sherr ABC News 20/20 Correspondent] Federal Investigators are now trying to bring
Carlos Cardoen to justice.

But why didnt they find out about him sooner? He has been selling cluster

bombs to Iraq for nearly a decade. The U.S. Patent Office knew about Cardoen back in 1986. But
they didnt tell anyone else in the Federal Government about them. In a move that went apparently
unchecked in the highest levels of the government, Cardoen applied for his own patent for cluster
bombs in 1986. Based on some changes on previous designs, he received the patent two years later.
Getting the Patent is not illegal. But at a time when U.S. shipments of arms to Chile were banned, as
to all sales to Iraq, Why didnt the Patent Office raise any questions why was this foreigner dealing in
U.S. arms?

Advanced Media Group

Page 6 of 20

02/21/2007

Experts say bureaucratic infighting regularly causes such lapses.

The Departments of Commerce,

State, and Defense, are supposed to control arms sales, and communicate with one another.
[Anthony Cordazman, Correspondent] - Even today, the same squabbling goes on, every day
within the Commerce, State, and Defense. The Administration can never agree on what

kinds of laws

can be passed to correct this.


[Lynn Sherr ABC News 20/20 Correspondent] Carlos Cardoen denied our requests to speak on
camera. In an interview last year, he denied he did anything wrong.
[Carlos Cardoen, Chilean Arms Dealer] - And as long as a human being is an animal that needs to
defend himself, weapons are going to exist. I think that is wrong.

As a human being I believe that

weapons are wrong. But they are a fact. And we have to live with facts.

The former head of ISC, James Guerin, who dealt with Chilean, said he did not provide anything to Cardoen to build
weapons. But Nasser Bedouin tells a different story.
[Nasser Bedouin, Arms Dealer] I believe that Dr. Carlos Cardoen got the plans to build the
cluster bombs from the United States.
[Lynn Sherr ABC News 20/20 Correspondent] Questions about the cluster bombs come at a
time when questions are being focused on how so many American designed weapons got into the
hands of Saddam Hussein. Senator John McCain.
[Senator John McCain] Theres not just one Saddam Hussein on this globe. Theres lots and lots
of them who at this time as we speak are acquiring technologies to give them the capabilities of
weapons of mass destruction because its a way of gaining victory on the cheap.
[Lynn Sherr ABC News 20/20 Correspondent] McCain has introduced legislation that would
severely penalize and company or countries that would sell weapons illegally or harbor arms dealers.
[Senator John McCain] To provide many of the kinds of weapons that we have today to many
nations, which are clearly offensive in nature, and are clearly far exceed their requirements to defend
themselves, is frankly unconscionable and must be brought to a stop.
[Lynn Sherr, ABC News 20/20 Correspondent] Basically what you are saying is hit them in the
pocketbook.

Advanced Media Group

Page 7 of 20

02/21/2007

[Senator John McCain] Hit them in the pocketbook and public exposure. No corporation or nation
likes to be branded as a nation that is involved in this illicit trafficking.
[Lynn Sherr ABC News 20/20 Correspondent] But public exposure and pressure will not shield
American Soldiers. If Saddam Hussein uses the cluster bombs he already has.
[Senator John McCain] And if there is one good thing that has come out of this Persian Gulf war
its to dramatically heighten the awareness of the people of the world to the American people of how
dangerous this proliferation of weapons of mass destruction can be.
[Hugh Downs, ABC News 20/20 Correspondent] God those things are vicious. Have there been
any indictments yet Lynn?
[Lynn Sherr ABC News 20/20 Correspondent] Ah, no Hugh, no indictments yet.

Carlos

Cardoen has not been indicted, even though Federal Agents raided his headquarters office in Miami.
And U.S. Customs people took a number of documents, but no indictments yet, but there are
investigations going on.
[Hugh Downs, ABC News 20/20 Correspondent] If these things are dropped from airplanes,
and we have air supremacy, as it now has been said by our leaders, is there that much to worry about
for our troops?
[Lynn Sherr ABC News 20/20 Correspondent] Were told yes, because you dont need to an
airplane to a cluster bomb, they can also be used on rocket launchers and on unguided missiles, both
of which Iraq has. And incidentally, we talked about that bomb factory, even if it was badly damaged,
the cluster bomb factory he already has, were told in three to six months it can be operational again,
and anyway he likely has a big stockpile.
[Hugh Downs, ABC News 20/20 Correspondent] We of course, have these weapons also, and I
understand they are called something different?
[Lynn Sherr ABC News 20/20 Correspondent] Yes, if youre listening to a Pentagon Briefing,
dont listen for the term cluster bomb, there calling them Aerial Denial Weapons.
[Hugh Downs, ABC News 20/20 Correspondent] Thank you Lynn.
END

Advanced Media Group

Page 8 of 20

02/21/2007

ABC News Nightline - September 12, 1991


[Ted Koppel] incidentally the function of the senior review panel is to advise one man, the director
of central intelligence. And at least part of the period in question there was an acting director of the
CIA Robert Gates. Well attempt to pull some of these threads together when we come back.
Commercial Break
[Ted Koppel] When all is said and done, why should your or your representatives in Congress care,
eventually after all President Bush spoke and acted against Sadaam Hussein more forcefully than
anyone could have expected.
[Former President George H. Bush Speech] Were dealing with Hitler revisited, a totalitarianism,
a brutality, that is neglect and unprecedented in modern times.
[Vidoe-Gary Milhollin, Director, The Wisconsin Project] The more we gave Sadaam, the more
dangerous he got. And ultimately we had to go to war to destroy what we sold him.
[Ted Koppel] But its not a question of holding the Bush or Reagan Administrations to account for
having made mistakes with regards to their policies toward Iraq The issue is how those policies were
implemented.
As we reported over the past few months, The Atlanta Branch of an Italian Bank, BNL, was able to
funnel $Billions, some of it in U.S. Credits to Iraqs Military Procurement

Network.

The U.S.

Government knew, and turned a blind eye. Sophisticated Military Technology was illegally transferred
from a major U.S. company in Lancaster, Pennsylvania (International Signal & Control),

to South

Africa, and Chile, and from there onto Iraq. The Iraqi borne designer of a chemicals weapons plant in
Lybia, set up shop in Florida, producing and shipping to Iraq chemical weapon components. The CIA,
FBI, and other U.S. agencies were made aware of the operation and did nothing to prevent it.
During the 1980s and into the 90s senior officials of both the Bush and Reagan Administration
encouraged the privatization of foreign policy, certainly towards Iran and Iraq. The policy may have
had merit - but there werent willing or in some instances werent successful in fighting it out in Capital
Hill so they found other ways. They made a mockery of the Export Control System, and they found
ways of encouraging foreign governments to do what our laws prohibited. They even knew or if not
were guilty of the grossest incompetence that U. S. companies were collaborating with foreign Arms
merchants in the illegal transfer of American Technology that helped Sadaam Hussein build is
formidable arsenal.

Advanced Media Group

Page 9 of 20

02/21/2007

This week, the CIA again told ABC News Nightline that our allegations over the past few months
regarding covert operations to supply Iraq with U.S. Arms and weapons technologies simply were not
true.
The CIAs Inspector General said a statement from the Agency [On Screen] - Has found to factual
support whatsoever for such an operation or for the involvement of Mr. Gates.
[Ted Koppel] At least one member of the Senate Intelligence Committee, Bill Bradley of New
Jersey, feels that there may be reason to doubt both those claims, and hell raise the issues next week
during the Gates Confirmation Hearings, next week.
The CIA also told us that its Inspector General has found no evidence of any off-the-books illegal
activity.

But the CIA concedes, off-the-books activities, are not documented.

Precisely so that

deniability can be preserved.


One thing is undeniable, this gun sight video of a stealth fighter bomber from the 32nd Tactical Fighter
Wing, last February attacking a bomb factory, on the outskirts of Bagdad U.S. Technology in the air,
destroying U.S. Technology on the Ground. The factory was built by Carlos Cardoen.
For all of us here at ABC News, Good night.
END

Advanced Media Group

Page 10 of 20

02/21/2007

ABC News Nightline - July 1991


[Ted Koppel] Carlos Cardoens role in shipping arms to Iraq has been known for years.

His

connection with Robert Gates has not. By the mid 1980s Cardoen was the largest private supplier of
weapons to Iraq.

In all he has believed to ship a half billion dollars worth of arms and advanced

technologies to Bagdad.

At a factory 500 miles north of Santiago, Cardoen produced tens of

thousands of bombs and other equipment, absolutely essentially to Iraq during its eight year war with
Iran.
The material would be loaded aboard regular Iraqi airway flights flown from Santiago to Bagdad.
Cardoen did not simply ship weapons, he set up entire factories capable of producing bombs and other
explosives the components would be shipped from all over the world and then assembled in Iraq. One
of those factories turned out Cluster Bombs.
As we first reported on the 24th of May, much of the sophisticated military technology that Cardoen
was shipping to Iraq came from the United States. This company in sleepy Lancaster, Pennsylvania, is
believed to be the source for some of the Cluster Bomb technology. But there was more.

Nasser

Bedouin is also an arms dealer. He acted as a middleman between Carlos Cardoen and Iraq.
[Nasser Bedouin on Video] I am aware of Carlos Cardoen getting some type of technology from
the air fuel bomb from the United States. I believe Iraq has a viable fuel air explosive.
[Ted Koppel] These explosives are designed to explode just above ground level like miniature
atomic bombs, literally sucking all available oxygen out of the air. It is clear that Carlos Cardoens
special relationship with the United States was not known by all Departments. When the Commerce
Department inquired about that relationship in early 1987, it received a cable from the U.S.
Ambassador to Chile saying although Cardoen is involved with the sale of armaments, and he has
made his fortune from it, he is considered to be a responsible recipient of U.S. products. In fact by
1987, the covert relationship between the CIA and Cardoen was already well established.
In 1983 the Reagan Administration had become alarmed at how poorly the Iraqi military was doing
against Iran. A decision was made at the highest level of Government to begin helping Iraq.
Indeed ABC News has learned only today, that around that time, in 1983 Ronald Reagan issued a
highly classified Presidential Finding stating that it was important to the National Interests that arms
and technical assistance be covertly funneled to Iraq

and with the help of the CIA.

More on the

significance of that Presidential Finding in a moment.

Advanced Media Group

Page 11 of 20

02/21/2007

What it unleashed was a flood of US help to Iraq. A former CIA operative who was involved in the
program has told us of a series of covert operations, in which loads of 727s were flown into Iraq. On
one such mission in 1987 our source tells us he accompanied a planeload of Soviet built one hundred
twenty-two missiles.

The Soviet equipment was shipped because it would be compatible with what

the Iraqis already had. By 1987, there was at least one such flight a week into Bagdad.
Our former CIA source recalls bringing in $100 dollar bills in a bowling bag, they would also carry
whiskey, cartons of cigarettes and copies of Penthouse magazines to speed up the unloading process,
which usually took place at night.

Once the White House has authorized the Covert Assistance

Program to Iraq, the CIA took over. In effect the former CIA operative told us the covert operation
amounted to here is what we want you to do, and we really dont want to know too much about how
you do it.
Our source tells us that he has at least one meeting in 1986 in Florida between Robert Gates and
Carlos Cardoen, the Chilean Arms Dealer. Other sources have told us of other such meetings. Here in
the United States and in Europe. Which brings us to an unsolicited statement that was telephoned in
to Nightline from the Central Intelligence Agency almost a month ago on June 17th. Allegations, the
statement read that Robert Gates facilitated illegal shipments to Iraq during the 1980s are totally
without basis. Since we had never requested a statement of Mr. Gates, we didnt know quite what to
make of it at the time. But then today we learned of that Presidential Finding, authorizing the Covert
shipment of arms to Iraq.
It would be true then that Robert Gates did not facilitate illegal shipments to Iraq, under the
Presidential Finding, the shipments would have been quite legal.

But during this last set of

confirmation hearings, back in 1987, Robert Gates assured the Senate Confirmation Committee that he
would always keep the Committee current on ongoing covert operations. Indeed the CIA is supposed
to provide the Intelligence Committee with quarterly reports. According to well-informed sources on
the Committee it has had no briefings on the Covert arms pipeline to Iraq.

That, said one Senator on

the Committee would be a total breach of trust. What would it do to the Gates Nomination? I asked.
It would probably be enough said the Senator, to derail the Nomination.
Again, an excerpt from Mr. Gates Testimony before the Senate Intelligence Committee in 1987:
[Robert Gates 1987 on video] If you cannot have a system in which you can have some
confidence between A the branches of government, and confidence between the senior officials of the
Government, A that they abide by the rules, and B that they will deal with one another honestly, then
I think the system begins to collapse.

Advanced Media Group

Page 12 of 20

02/21/2007

[Ted Koppel] Late this evening, the Whitehouse communicated its response to the charges
contained in this report, the Whole story is unfounded. There were never any sales; covert or overt
to Iraq or Iran through a third country. And Mr. Gates never met with Carlos Cardoen.
Well be back with more, in a moment.
[Ted Koppel] For the viewers, this is Alan Freidman, New York Correspondent for the Financial
Times of London, and a member of the team investigating Robert Gates. Alan Id like to begin by
repeating a statement, and let me put my specs on for a moment, the White House. This story is
unfounded and there were never any sales covert or overt to Iraq or Iran through a third country. And
Mr. Gates never met with Carlos Cardoen.
Ah, ah a fairly carefully drafted statement one would think.
[Alan Friedman, New York Correspondent for the Financial Times of London] Yes Ted, I
think that is right, I would agree with the statement that there were never any sales Iraq through a
third party.

Indeed what we found was that some of the cluster bomb technology and fuel air

technology was given smuggled down to Chile, for use that were used and made and shipped on
through to Iraq.

In terms of the um statement by the White House that there were never any

meetings between Mr. Gates and Mr. Cardoen, we have a number of sources, some of them personally
involved in these operations, one of them who was personally and physically an eye witness present at
a meeting, in Florida, with Mr. Gates and Mr. Cardoen in 1986. And who was told my Mr. Gates, about
other meetings that he had with Mr. Cardoen.
[Ted Koppel] Now Congressman Gejdenson, I realized that we sort of unleashed an awful lot of
material on you today, but to what degree does this fit in with those thousands of documents that you
subpoenaed with the information that you have?
[House Representative Sam Gejdenson of the House Foreign Affairs Committee] Well we
just got the documents after a several month battle with the Administration to pry them loose and it
took the vote of a subpoena by the subcommittee to start the flow of those documents, but its
certainly consistent with the information that we got with Committee staffs with some of those people
that said they were at those meetings, ah as well. I think that the important thing to remember here
is that the United States in 1982 under the Reagan Administration took Iraq off the terrorist list at a
time when some of the worst terrorist of the world were being harbored by Saddam Hussein, and we
suddenly changed our policy and continued to keep Iraq off the terrorist list, enabling the export of
dual use, ah items that can be used for dual use from the United States to Iraq, as well as these sales
that went indirectly to Iraq.

Advanced Media Group

Page 13 of 20

02/21/2007

So, all through a time when they were harboring terrorists, and they killed 5,000 Kurds in 1988, and
as recent as six days before the invasion of Kuwait, when I and several members of Congress, tried to
stop the subsidy of grain sales to Iraq, the Bush Administration continued to impose any sanctions
against Iraq.
[Ted Koppel] Well of course theres a huge difference between grain sales and the shipment of
entire plants for the building of a cluster bomb factory.
[House Representative Sam Gejdenson of the House Foreign Affairs Committee] Except for
what I think you find is that a pattern by both the Bush and Reagan Administrations to trying to assist
Saddam Hussein. What we found at one Hearing was a document from the State Department, ah that
said that the United States was ready to sell weapons to Iraq as long as they were for the personal
protection of Saddam Hussein. A policy that ignored all the outrages, a policy that ignored I think the
intent of the Congress and the American People. And that the allegations that weve gotten from a
number of sources seem to be consistent with that. The United States did everything it could under
the Reagan and Bush Administrations to assist Saddam Hussein.
[Ted Koppel] Alan, I know that one of the things that we discovered in our investigations was and
Id like you to elaborate on it a little bit was that frequently there was Federal Agencies, Law
Enforcement Agencies that was trying to uncover what was going on we found that they were stymied
at every turn. Can you talk about a that a little bit?.
[Alan Friedman, New York Correspondent for the Financial Times of London] Yes I think
that if we look back at other discoveries that we made, you can say that when we found ISC, the
company in Lancaster, Pennsylvania, that was, that had cluster bomb technology, shipped down to
Chile that was part of this covert operation for Iraq, we found that the CIA had detailed knowledge
over a period of 4 years of all sorts of shipments from ISC to South Africa, some of which were later
trans shipped to Iraq, we found that Federal Law Enforcement Officers and Agencies were unable to do
anything about it because they just werent told. Likewise, we were just told of the case that the man
that built the Rapta Chemical Weapons plant in Libya, who ah, even though the CIA were tracking him
very carefully here in the United States, was allowed to build a chemical weapons plant here in Florida,
and shipped dangerous cyanide with the help of CIA Contract Shippers to Iraq.

All of these things

were going on and the investigators seem unable to do anything about any of these things. We seem
to have part of the Government trying to investigate, and part of the Government trying to ship.
[Ted Koppel] Congressman Gejdenson Id like to get your reaction to that and see if your
experiences have been similar in some of the findings that ah or some of the conclusions that you
have reached, but well take a break first and be back in just a moment.

Advanced Media Group

Page 14 of 20

02/21/2007

[House Representative Sam Gejdenson of the House Foreign Affairs Committee] Well we
saw it ah from across all of the agencies. We had Dennis Kloskey who was then in charge of export
licensing at Commerce testify before our committee in April that he suggested to Mr. Gates and others
that ah meetings at White House to stop the export of dangerous technologies to Iraq. The following
day ah Mr. Kloskey resigned from the Government.

We were told by Mr. Kloskey that the White

House, the people in that room representing the President argued for a policy that assisted Saddam
Hussein in getting dual use technologies. We had Congressman Rose who I know has been on your
show testifying about the grain sales being tied up with funding weapons to Iraq as well. So across
the government, this thing went on. Its hard to believe that somebody like Mr. Gates in his position
didnt know about it.
[Ted Koppel] We are suggesting a lot more that he knew about it. Were suggesting that he was
actively involved in it let me just pass on a little information that we have gathered today, having to
do with the Confirmation Hearings and was told earlier this afternoon. Alan Fryers, Senior Officer with
the CIA and Clair George are not likely to be testifying voluntarily, indeed Alan Fryers said he will not
be testifying before the Senate Intelligence Committee.

The White House, as we have all heard

throughout the day is putting on some pressure to get those Hearings underway before the August
recess, August 2nd, of course, the Senate goes into recess. Ah, and there are indications now that a
week from Monday, indeed the Hearings will begin, Mr. Gates will be asked to testify at that time, but
Ive been also told that there is no way that the Hearing will no way be completed before the August
recess.

And that Mr. Gates will be told that he will be recalled again

after other witnesses have

testified, after the August recess. So these Hearing now, are destined to go into September.
[House Representative Sam Gejdenson of the House Foreign Affairs Committee] I think that
is terribly important, because we have to what we have to remember here, unlike other appointees of
the President, what the head of the CIA does is not transparent. If youre the Secretary of Housing,
like Jack Kemp is, and I disagree with one of his programs, not only do I know about it, but the
average citizen knows about what Jack Kemps doing. Sometimes you agree with it and sometimes
you disagree with him. In the case of the Director of the CIA, as is clear from repeated experiences,
often times even the people in Congress were suppose to know about these activities are not
informed. This has to do with National Security the standard ought not be somebody that can get by
the Hearing process with White House pressure. The White House ought to be with us on this one, we
ought to make sure that we have someone fully discloses what is going on to the appropriate
committees and to Congress. Not someone involved in Iran Contra and not someone who hasnt told
the entire truth. And not someone who is in question about these activities. This has to be a definitive
decision by the Congress, that this individual will come clean with the Congress and fulfill not just the
letter of the law, but the spirit of the law.

Advanced Media Group

Page 15 of 20

02/21/2007

[Ted Koppel] Alright, let me just interrupt here for a moment, because were down to our last
minute and a half or so, Alan, it is inevitable in this kind of investigation that you run into a lot of
sleazy characters and I just want to get from you for our audience some sense of how much of the
information that we have compiled here comes from the sleazy characters and how much comes from
the few that we can really rely upon?
[Alan Friedman, New York Correspondent for the Financial Times of London] I think, ah Ted
the important thing to remember here is that we have had all kinds of allegations for the last three
months when our team has interviewed dozens of people, weve been acidulously cross checking and
weve waited to go ahead with this story until weve had very credible witnesses. Those who were
documented CIA operatives and those who were physically with Mr. Gates during those meetings, and
we asked some of them why would Mr. Gates take the risk and go out and meet with Mr. Cardoen and
get directly involved and get his hands dirty in these operations, especially as he was deputy director
of the CIA at the time himself.

We were told that he went out because he wanted to give his

improvtoire in order to make sure the job got done. Weve talked to a number of top people and cross
checked.
[Ted Koppel] Alright, Alan Friedman thank you very much, Congressman Gejdenson, thank you
very much, Ill be back in a moment.
END

Advanced Media Group

Page 16 of 20

02/21/2007

Whistle-Blowing Activities Starting in June of 1987, local, state, and federal authorities were
called by Stanley J. Caterbone, including the Federal Bureau of Investigation, the Federal Securities
and Exchange Commission, Congressman Robert Walker, the Pennsylvania Attorney General, the
Lancaster District Attorney, Manheim Township Police, and a host of others.
The following is a memo of a meeting with ISC executive Mr. Lawrence Resch and Mr. Stanley J.
Caterbone at his office at Financial Management Group, Ltd., which took place on June 23, 1987. Mr.
Lawrence Resch, of San Clamente, California, was a long time associate of Mr. James Guerin who
worked as a marketing consultant, and was an ISC executive prior to the company going public in
1982. He served as Director of Marketing and head of Lancaster operations for then defunct United
Chem Con, an affiliate of ISC. He was sued by Ferranti International in 1990 for $189 million dollars
and indicted and found guilty by prosecutors for his role with ISC and served a jail term.
Upon the arrival of Mr. Larry Resch, Stan Caterbone met him in the lobby of Financial Management
Group, Ltd, at which time Larry Resch said "Carl Jacobson could not attend, we had to suddenly fly him
out of the country early this morning (flew to Chile) The meeting was started with the subject of the
financial difficulties of United Chem Con and possible alternatives. Larry Resch specifically addressed
the possibility of moving the operations of United Chem Con to another facility, with specific regards to
the Renovo Plant. Larry Resch specifically addressed the financing capabilities of Stan Caterbone,
along with possible management opportunities. Larry Resch also gave financial statements and
documents to Stan Caterbone for the latest fiscal year for United Chem Con. Stan Caterbone went on
to allege that United Chem Con had embezzled some $15,000,000 from the United States
Government for contracts that contained improprieties. Stan Caterbone also alleged improprieties of
International Signal & Control and James Guerin, with specific regards to its role in the United Chem
Con, and its business activities as related to government contracts. Stan Caterbone noted that he, as a
legal shareholder of International Signal & Control was concerned about improper business activities.
Larry Resch was taken by surprise by all of the above. Stan Caterbone became quite upset by the
evasiveness and the lack of specifics with regards to Larry Resch's conversation. In efforts to thwart
any further communication from James Guerin, United Chem Con, or International Signal & Control,
Stan Caterbone demanded a retainer fee of $10,000 before anyone contacted him again.
The following is a transcript of a meeting with Agent Howard Eisler, of the Pennsylvania Securities
Commission on September 29, 1987. The meeting was solicited at the bequest of Agent Howard Eisler
supposedly for an investigation into securities violations at Financial Management Group, Ltd.,
However, that also turned out to be untrue, or Agent Eisler also ignored all of the violations that
occurred at the company headquarters.

The meeting lasted approximately 4 hours at the residence of

Stanley J. Caterbone. Also present were attorney Mr. Robert Byers, and client of Stanley J. Caterbone,
Mr. Millard Johnson. Agent Howard Eisler, in November of 1987, requested that Stanley J. Caterbone

Advanced Media Group

Page 17 of 20

02/21/2007

put any complaints or grievances in writing and never did anything with information or testimony from
the meeting.
[Stanley J.

Caterbone, ISC Shareholder; Founder Executive Vice President of Financial

Management Group, Ltd., and President of FMG Advisory, Ltd.,] - Chem Con is the big local
minority-held corporation that was doing a lot of Defense contracts-it was associated with ISC. They
went under last spring, beginning of the summer, and there was a lot of criminal allegations made,
none of them substantiated. And I was connected with that. They sent a board member in to see me a
week before this happened. Why. I don't know. Jim Christian owned it - now I hear rumors that I was
tied to ISC and I am close to several people in that organization. Why they sent someone in to
California to see me, I don't know. They wouldnt answer me. They wanted me to talk to a guy from
D.C., New York, a guy from the Caribbean. I don't know what the hell is going on.
[Mr. Robert Byer, Criminal Attorney for Stanley J. Caterbone] the supposition was - I don't
know how true it was a front for ISC.
[Stanley J.

Caterbone, ISC Shareholder; Founder Executive Vice President of Financial

Management Group, Ltd., and President of FMG Advisory, Ltd.,] - It was, I'll tell you why.
Because when Chem Con was started, back to their inception, you look at ISC's books. They didn't
have any money. Well, the fist thing Chem Con did was they went and got all that free money from
the government and you look where that money went. I bet I know where it went. This guy named
Guerin, James Guerin. And I know that they were selling contracts back. He runs ISC and he also has
his fingers pretty deeply into Chem Con. He's the one who started Chem Con, Guerin is the one who
started it.
[Mr. Millard (Bill) Johnson, Client of Mr. Stanley J. Caterbone] - Wasn't there some allegations
about a tie to Wedtech? (Defense Contractor of New York)
[Stanley J.

Caterbone, ISC Shareholder; Founder Executive Vice President of Financial

Management Group, Ltd., and President of FMG Advisory, Ltd.,] - You bet. They were tied, you'd
better believe they were tied with Wedtech. The same guys in Wedtech were invoked with ISC and
Chem Con.

ISC is sold over the London Exchange. (I bought my shares from Pennsylvania State

Senator Gibson Armstrong) I owned a thousand shares. I sold it when things started to hit the fanthey just did a multimillion dollar merger with a company in London. They probably think this is going
to cover their tracks. What they did was, they fronted all that money and started the contracts, went
bankrupt, and now the government is stuck for $18,000,000.

I know right now in this town's

viewpoint, I stole money, I am insane, and I am a lunatic I tell you I will not condemn Jim Christian
until he tells to my face what happened. "I was framed and set up. I dont know maybe Jim Christian
doesn't have the money. Maybe Guerin has it or somebody else has it.
Advanced Media Group

Page 18 of 20

02/21/2007

__________________________________________________________________
ARGUMENT
__________________________________________________________________
Keith, 407 U.S. at 313-14. There, the Court explained that
[n]ational security cases . . . often reflect a convergence of First and Fourth Amendment values . . . .
Fourth Amendment protections become the more necessary when the targets of official surveillance
may be those suspected of unorthodoxy in their political beliefs. The danger to political dissent is acute
where the Government attempts to act under so vague a concept as the power to protect domestic
security.
Id. The Court thus concluded that Fourth Amendment freedoms cannot properly be guaranteed if
domestic security surveillances may be conducted solely within the discretion of the Executive Branch.
The Fourth Amendment does not contemplate the executive officers of Government as neutral and
disinterested magistrates. . . . The historical judgment, which the Fourth Amendment accepts, is that
unreviewed executive discretion may yield too readily to pressures to obtain incriminating evidence
and overlook potential invasions of privacy and protected speech. . . . [T]his Court has never sustained
a search upon the sole ground that officers reasonably expected to find evidence . . . and voluntarily
confined their activities to the least intrusive means . . . . The Fourth Amendment contemplates a prior
judicial judgment, not the risk that executive discretion may be reasonably exercised.

Advanced Media Group

Page 19 of 20

02/21/2007

CERTIFICATE OF SERVICE
I hereby certify that on February 21, 2007, I have mailed by U.S. Postal Service, by electronic means, or by
facsimile the foregoing paper to the following (funds permitted) :
ANN BEESON
Attorney of Record
JAMEEL JAFFER
MELISSA GOODMAN (admission pending)
CATHERINE CRUMP (admission pending)
National Legal Department
American Civil Liberties Union Foundation
125 Broad Street, 18th Floor
New York, NY 10004-2400
(212) 549-2500
MICHAEL J. STEINBERG
KARY L. MOSS
American Civil Liberties Union Fund of Michigan
60 West Hancock Street
Detroit, MI 48201-1343
(313) 578-6814
Kate Martin
CENTER FOR NATIONAL SECURITY STUDIES
60 1 Thirteenth Street, N. W.
1120 19th Street, N.W.,
Washington, DC 20036
(202) 72 1-5650
Joseph Onek Erin N. Linder
Sharon Bradford Franklin
THE CONSTITUTION PROJECT
1025 Vermont Avenue,
Washington, DC 20005
(202) 580-6920
Donald B. Verrilli, Jr.
JENNER & BLOCK LLP
S. 800 Suite 1200 South
Washington, DC 20005
(202) 639-6095
JENNER & BLOCK LLP
330 N. Wabash Avenue
N. W. Chicago, IL 60611
(312) 222-9350
Randy Gainer
Davis Wright Tremaine LLP
1501 Fourth Avenue, Suite 2600
Seattle, WA 98101 - 1688

Lucy A. Dalglish, Esq.


Counsel of Record
Gregg P. Leslie, Esq.
Elizabeth J. Soja, Esq.
1101 Wilson Blvd., Suite 1100
Arlington, VA 22209-2211
(703) 807-2100
Attorneys for Amicus Curiae The Reporters
Committee for Freedom of the Press
Kathleen M. Sullivan
Derek L. Shaffer
Constitutional Law Center
Stanford Law School
559 Nathan Abbott Way
Stanford, California 94305-8610
ANN BEESON
Attorney of Record
JAMEEL JAFFER
MELISSA GOODMAN (admission pending)
SCOTT MICHELMAN (admission pending)
CATHERINE CRUMP (admission pending)
National Legal Department
American Civil Liberties Union Foundation
125 Broad Street, 18th Floor
New York, NY 10004-2400
(212) 549-2500
annb@aclu.org
David W. DeBruin
Theresa A. Chmara
Julie M. Carpenter
Michael B. DeSanctis
Wade B. Gentz
JENNER & BLOCK LLP
601 Thirteenth St., N.W., 12th Floor
Washington, D.C. 20005
tel. (202) 639-6000
fax (202) 639-6066
Margaret A. Costello
DYKEMA GOSSETT PLLC
400 Renaissance Center
Detroit, MI 48243
tel. (313) 568-5306
fax (313) 568-6893

Douglas N. Letter
Thomas N. Bondy
Anthony A. Yang
Attorneys, Appellate Staff
Washington, DC 20530
Civil Division, Room 7513
U.S. Department of Justice
950 Pennsylvania Avenue, NW
Washington, DC 20530

Date: February 20, 2007

Advanced Media Group

____________/s/________________
Stanley J. Caterbone, Pro Se Litigant
1250 Fremont Street
Lancaster, PA 17603
717-427-1821 facsimile

Page 20 of 20

02/21/2007

BAUSMAN MPO

Product
Descri p t i on

THANK YOU FOR SHOPPN


IG
WEIS MARKETS #41
CLUB CUSTOMER

Ite.

MC

r*rr

LANCASTER,p~

40041389011
Rice
1.49 F
1.49 F
1.OD-F
1.00-F
.OO BAL
.98

H8 VIENNA 60
HB VIENNA 80
COUPON 11009
MANUFACTURERCPN

TAX

Cash

CwGE
1.00
cowon savines. . .. . .. ... .. ..... .oZ
2.00
YOU- Total Savings are 6 7 . 1 1 ~ 2.00
2/20/07

.*r.

I,~>?~.?C;E

LaTIOh

TAX
Cash

E%S
06 B ~ L

Final
Price

LANCASTER PA 17604
First-Cless
1.50 oz.

PA

It$

Sales Receipt
Sale Unit
Qty Price

D
, .r i.ce
1.2, F
1.00 T

Issue PVI :
PHILADELPHIA PA 19101
First-Cl ass
1.30 oz.

2.27
2.27

.00

. Issue PVI:

2/18

DETROIT M I 48201
Fi rst-Cl ass
4.90 oz.

4:14 PM 0041201 0129 225

x
X

St

Issue PVI :
Total :
Paid by:
Cash
Change Due:
Bi l I # : 1000200788239
Clerk: 03

A l l sales f i n a l on stamps and postage.


Refunds for guaranteed services on1 y.
Thank you f o r your business.

www.amgglobalentertainmentgroup.com
mailto:amgroup01@msn.com
717.427-1621 Fax

Stanley J. Caterbone
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603

March 19, 2007

United States District Court


Eastern District Of Michigan Southern Division
The Clerk of The Court
Detroit, MI
Re:
Brief On Behalf Of Amici Curiae Stanley J. Caterbone And Advanced Media Group
In Support Of Plaintiffs Motion For Partial Summary Judgment
Dear Clerk of the Court:
Please see the attached for filing. On February 22, 2007, I did not have your address so I
forwarded the filing to the ACLU Office in Detroit with a note to please forward it to you for filing. I
have no way of confirming, so I am submitting another copy for you to file.
I thank you for your service in advance. If you require any additional information, please
contact me by email at the above address.

Respectfully,

Stan J. Caterbone
Pro Se Lititgant

Lancaster New Era: Dems' inaction on FISA harmful

http://eedition.lancasteronline.com/pages/news/edition/NEPM/2008...

Lancaster New Era


Dems' inaction on FISA harmful
It's things like this that make us wonder how serious some
Democrats are about confronting the terrorist threat on America.
The Democratic-led House let a crucial government-eavesdropping
law expire over the weekend before Congress began a 12-day
recess.
The eavesdropping won't end; it just makes the task that much
harder for our intelligence officials.
The House failed to adopt the bipartisan Senate version of the
Foreign Intelligence Surveillance Act, which would have renewed an
update of the law approved in August that makes it easier for the
government to spy on foreign phone calls and e-mails that pass
through the United States.
FISA, first adopted by Congress during the Cold War, would let the
government initiate wiretaps for up to one year. It also would
compel telecommunications to comply with wiretap orders while
shielding them from civil lawsuits that may be filed against them as
a result.
The provisions in the law have one purpose and one purpose only:
to protect the American people from further terrorist attacks.
"American citizens must understand, clearly understand that there's
still a threat on the homeland...," says President Bush. "We've got to
give our professionals the tools they need to be able to figure out
what the enemy is up to so we can stop it."
Some Democrats apparently don't see it that way. They downplay
FISA's expiration and accuse the president of fear-mongering and
misrepresenting the facts.
"This is not about protecting Americans. The president just wants to
protect American telephone companies," argues Rep. Rahm Emanuel
(D-Illinois), referring to the liability-protection provision that
insulates telecoms from lawsuits.
While the eavesdropping can continue, the compliance requirement
and liability protection for telecoms no longer apply. That means
telecoms' cooperation must be voluntary. And without the liability
protection, they're less likely to be so.
As a result, the government has to go back to the old way of getting
orders approved by the Foreign Intelligence Surveillance Court -- a
cumbersome process that ties intelligence agents up in red tape and
causes needless delay.
To get a court order, the government has to prove "probable cause"
before being allowed to tap a line inside the U.S. -- even if the
communication originates and ends in a foreign country. This is
difficult to do, and it takes time.
Indeed, by the time the government complies with the law, the
phone numbers or e-mails that it wanted to track could be obsolete.
"More than likely we would miss the very information we need to
prevent some horrendous act from taking place in the United States,"
says Mike McConnell, director of national intelligence.

1 of 2

2/19/2008 4:21 PM

Lancaster New Era: Dems' inaction on FISA harmful

http://eedition.lancasteronline.com/pages/news/edition/NEPM/2008...

The law does makes provisions for emergencies, but the paperwork
still must be completed within a few days.
Democrats who let the FISA law expire insist America is no less safe
from another terrorist attack. But can they be so sure?
The only thing certain is that Americans are not now getting the full
benefit of FISA protection. This is unacceptable.
We should be protecting the American people, not the terrorists.
The eavesdropping won't end; it just makes the task that much
harder for our intelligence officials.
2004-2007 Lancaster Newspapers

PO Box 1328, Lancaster PA 17608, (717) 291-8811


Terms of Service Privacy Policy

2 of 2

2/19/2008 4:21 PM

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 1 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 2 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 3 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 4 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 5 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 6 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 7 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 8 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 9 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 10 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 11 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 12 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 13 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 14 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 15 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 16 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 17 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 18 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 19 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 20 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 21 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 22 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 23 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 24 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 25 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 26 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 27 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 28 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 29 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 30 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 31 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 32 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 33 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 34 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 35 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 36 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 37 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 38 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 39 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 40 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 41 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 42 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 43 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 44 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 45 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 46 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 47 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 48 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 49 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 50 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 51 of 52

Case 5:14-cv-02559-PD Document 4 Filed 06/23/15 Page 52 of 52

Stan J Caterbone
Project Hope Foundation
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603

IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY,


PENNSYLVANIA
CIVIL DIVISION
IN RE:
MEGHAN . LIAPPATT V

:
:

Docket No. CI-08-04781

CD 6 208A

AMICUS CURIAE IN SUPPORT OF A CLOSED HEARING


TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
AND NOW comes before the said court Stanley J. Caterbone, appearing Pro Se,
Project Hope Foundation, and Advanced Media Group, as Movant, to file an Amicus in the above
captioned case.
The Movant has an interest in this case as Project Hope being an advocate and a 501
(3) ( c ) non-profit foundation focusing in mental health issues and mental health awareness;
Stanley J. Caterbone and Advanced Media Group having similar mental health issues before the
courts with a history and experience of how misaligned community attitudes towards persons labeled
with mental health problems can carry an unnecessary and costly burden and stigma.
This amicus provides a voice for the movants as well as providing another perspective
and opinion that should benefit the courts; the parties; and the public-at-large. The matters
presented in this amicus have a direct relevancy in the disposition of this case as it does in the
opinion and ORDER of James P. Cullen of July 11, 2008 which ruled against a closed hearing.
Stanley J. Caterbone appeared pro se before a 7303 Section 303 Of The Pennsylvania
Mental Health Procedures Act P.S. 7303 hearing in the Lancaster General Hospital on April 7,
2006 and had a successful conclusion in arguing against commitment and treatment. Stanley
J. Caterbone was released after a 5-day evaluation, which is also being challenged in the
courts.
July 21, 2008 _________

Respectfully Submitted:

__________________
__________________

SSS
Stanley J. Caterbone, Pro Se
Project Hope Foundation
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com
Page 1 of 35

TABLE OF CONTENTS

1. BACKGROUND OF MOVANTS

Page 3

a. Stanley J. Caterbone
b. Project Hope
c. Advanced Media Group
2. PREFACE TO ISSUES BEFORE THE COURT

Page 7

3. ISSUES BEFORE THE COURT

Page 8

a. I) Should The Hearing On The Commonwealths Amended Petition Under


Section 304 Of The Pennsylvania Mental Health Procedures Act P.S. 7304 Is
Open To The Public?
b. II) Did The Court Give Due Consideration To The Claims By Meghan Lippiatt
Regarding Retaliation By The Public During And After A Public Hearing On
The Issues?
4. CONCLUSION _

Page 11

5. CERTIFICATE OF SERVICE

Page 12

6. EXHIBITS ___

Page 13

a. Jonathon Turley Post of December 13, 2007

Page 13

b. Biography of Jonathan Turley

Page 16

c. Conditional Release and Mandated Outpatient Treatment


By George F. Parker, M.D.

Page 29

d. Griffin PA, Steadman HJ, Heilbrun K


e.

A Look Behind the Scenes of HIPAA and the


Privacy Rule

f.

Page 22
Page 24

Federal Oversight of Psychiatric Records:


The Health Insurance Portability and Accountability Act

Page 28

g. More protections for patients and psychologists


under HIPAA

Page 33

Page 2 of 35

BACKGROUND OF MOVANTS
Stanley J. Caterbone (CATERBONE)
CATERBONE has been following very closely the case of Meghan Lippiatt and was a witness
to the trial on one of the few last days before the Honorable Judge James P. Cullen in the
Lancaster County Court of Common Pleas to hear the testimony of Psychiatrist Dr. Gotlieb of the
Lancaster General Hospital.

CATERBONE had also written a response on the blog of nationally

known law expert and constitutional scholar Jonathan Turnley on December 19, 2007 days after
the conclusion of the trial. Jonathan Turley, like other national experts, had posted an opinion on
the Lippiatt case after the verdict and conclusion of the trial. The response is EXHIBIT A.
CATERBONE has been involved with Project Hope Foundation for more than 10 years and
has conducted extensive research in the field of mental illness and has been an advocate for
mental illness for almost 3 decades.

Mental illness has been an issue in his family since the

1960s and has been an extremely challenging dilemma resulting in the untimely and suspicious
deaths of two brothers in their 30s.

His oldest brother died in Santa Barbara, California on

Christmas day of 1984 with the death being ruled a suicide, but now known to have been a
murder. In 1996 his youngest brother, Tom had committed suicide and the circums tances are
currently being litigated in the federal courts as a wrongful death complaint.

CATERBONE has

researched and investigated the causes of both deaths as it relates to the issue of mental illness
and has conducted research and instigations into his own malicious diagnosis of his own mental
health record. His father, Samuel, has a history of mental health records however; he too has a
history of psychic phenomena and a history of suspicious activities with the United States
Government and the Lancaster community. His mental health record is also in dispute. He was a
very successful businessman and had served in the U.S. Navy as a radioman and graduated from
gunner school with honors. He also developed new technologies for the Dry Cleaning industry. He
has also conducted extensive research into areas concerning U.S. Government activities.
CATERBONE has developed relationships with mental health professionals for his work with
Project Hope and has been the main person responsible for coordinating and administrating the
mission of creating awareness and education to the community-at-large with the distribution of
Project Hopes video Numbers Dont Lie; including to the Mental Health and Retardation
Department of the County of Lancaster this past year. CATERBONE has worked extensively with
Contact Lancaster, the Mental Health Alliance of Lancaster County, and other mental health
organizations as well faith based organizations.

CATERBONE had dealings with national

professionals and organizations in the field; especially since C. EvreTt Koop, the former U.S.
Surgeon General and Tipor Gore made mental health awareness a top priority in 1998. Tipor Gore
also received the Project Hope video for distribution as a resource for other non-profit
organizations. CATERBONES research includes national and local trends of suicides; symptomatic
Page 3 of 35

behavior in bi-polar and manic depression; and the issues and stigma confronting those affected
with mental illnesses.

CATERBONE brings a unique perspective to the courts that may help to shed light into how
people with mental illnesses are treated unfairly by family, friends, and the community-at-large.
It should be noted that CATERBONE is also telepathic with a history of psychic traits in his family
dating back 2 generations. CATERBONE is currently engaged in extensive litigation challenging his
own mental health record, treatment, and diagnosis in federal and state courts. His own mental
health record includes 2 fabricated suicide stories that are part of the record in hospitals and with
police departments; this is in addition to the 30 false arrests. Mental health and criminal records
can be very damaging in destroying a persons credibility and reputation and ultimately his
professional and personal life if not respected by all.

CATERBONE is presently the founder of Advanced Media Group and conducts his business
from Lancaster County, Pennsylvania. For the past several years, in addition to appearing before
the courts as a pro se litigator, Advanced Media Group has been developing several business
interests in the revitalization of downtown Lancaster,

Those projects include a downtown UPS

Copy and Shipping Store; the Theater at Hotel Brunswick; and the Excelsior Place Business Plan,

In 2006 CATERBONE began his role as an Activist Shareholder for Fulton Financial, which
is listed as "FULT" on the NASDAQ stock exchange. As a founder of Financial Management Group,
Ltd., a full service financial firm, CATERBONE has drawn upon the success in developing the
strategic vision for his company and the experience gained in directing the legal affairs and public
offering efforts in dealing with Fulton Financial.
In 2005 CATERBONE, as a Pro Se Litigant filed several civil actions as Plaintiffs that are in
current litigation in the United States District Court for the Eastern District of Pennsylvania, the
United States Third District Court of Appeals, the Pennsylvania Supreme Court, The Pennsylvania
Superior Court, the Commonwealth Court of Pennsylvania, The Court of Common Pleas of
Lancaster County, Pennsylvania. These litigations include violations of intellectual property rights,
anti-trust violations, and interference of contracts relating to several business interests. Central to
this litigation is the Digital Movie, Digital Technologies, Financial Management Group, Ltd,/FMG
Advisory, Ltd., and its affiliated businesses along with a Federal False Claims Act or Federal
Whistleblowers Act regarding the firm of International Signal and Control, Plc., (ISC) the $1Billion
Dollar Fraud and the Export violations of selling arms to South Africa and Iraq. This litigation dates
back to 1987. CATERBONE was a shareholder of ISC, and was solicited by ISC executives for
professional services. The Federal False Claims Act is currently part of RICO Civil Complaint in the
United States District Court for the Eastern District of Pennsylvania and the Third Circuit Court of
Appeals, as docket no. 05-2288.
Page 4 of 35

A complete biography and history is located on the website of Advanced Media Group at:
www.amgglobalentertainmentgroup.com
PROJECT HOPE
Project Hope Foundation was founded in 1996 after the untimely suicide of Thomas P. Caterbone,
brother of Stanley J. Caterbone.

Project Hope was initially formed by another brother, Dr. Phillip

W. Caterbone of Austin Texas, and other friends and relatives that wanted to continue the legacy
of Tom Caterbone and make a contribution to the community-at-large in dealing with mental
health issues and mental health awareness.
In 1996 Project Hope Foundation produced the extremely successful instructional video Numbers
Dont Lie for helping teenagers deal with suicide and help them to identify kids which may be at
risk. The video was produced and directed by Dr. Phil Caterbone & Psychologist Craig Crabtree,
both of Austin, Texas. The video is a approximately 20 minutes and is accompanied by an
instructional workbook for the monitors and a workbook for the students. "Numbers Don't Lie"
has been sold to the Texas School Board of Education to pay for its development and production.
The video has been provided to other Faith Based non-profit organizations, school districts, church
groups, and municipalities by CATERBONE and Advanced Media Group over the past 10 years.
The video can be viewed online at: www.advancedmediagroup.youtube.com and clic king on the
Numbers Dont Lie video.

Project Hope provided funding for the Mental Health Alliance of Lancaster County, Contact/Lifeline
of Lancaster (The 24/7 Suicide Hotline), The Schreiber Pediatric Center, and other charitable
organizations and faith based charities. In 1999 Project Hope donated and constructed a soccer
field on the new Headquarters of the Schreiber Pediatric Center on Goods Road, in Lancaster.
Tom's Project Hope is funded by an annual golf tournament on the 1st Saturday in August, called
the Tommy Caterbone Memorial Golf Tournament.
The Lancaster County Mental Health/Mental Retardation department is currently using the video
as a resource Mental Health/Mental Retardation Department.
ADVANCED MEDIA GROUP

In 1989 CATERBONE founded Advanced Media Group, Ltd., which was one of only 4 or 65
U.S. domestic companies that had the capability to manufacture CD-ROM's.

Advanced Media

Group also developed tools, applic ations, and provided consulting to information technologies.
Page 5 of 35

Advanced Media did business with commercial companies, government agencies, educational
institutions, and foreign companies including the Department of Defense; NASA, National
Institution of Standards & Technology (NIST); Department of Defense, The Defense Advanced
Research Projects Agency (DARPA); and the Defense Mapping Agency, Central Intelligence
Agency; (CIA), IBM; Microsoft, AMP; Commodore Computers, American Bankers Bond Buyers;
and a host of others. I also was working with R.R, Donnelly's Geo Systems; which was developing
various interactive mapping technologies, which is now a major asset of Map Quest. Map Quest is
the premier provider of mapping software and applications for the Internet and is often used in
delivering maps and directions for Fortune 500 companies.

Advanced Media Group now has interests in various business and fields including the film and
entertainment industries; information technologies; revitalizations of downtown Lancaster;
Research and Study in Mind Control and ESP; and the fulfillment and distribution of past
intellectual property assets.
PREFACE TO ISSUES BEFORE THE COURT1
Upon the verdict of the lower court trial of not guilty by reason of insanity, CATERBONE
posed the question of why a condition for release of a psychiatric evaluation was not issued by
presiding Judge James P. Cullen. This is evident in the Jonathan Turley Post of December 19,
2007 which states the following:

Here is a brief synopsis; In the VERDICT ORDER there did not seam
to be any condition for Ms. Liappatt to be held in custody until a
further psychiatric evaluation could be performed. This set in motion
a number of court filings by the District Attorney, the Defense
Counsel, and others trying to recommit her to a treatment facility.

There has been much research done on the subject of conditional releases in not guilty by
reason of insanity cases throughout this country and most all have concluded that conditional
releases are a very acceptable and successful legal alternative to quell the public fear and
animosity of persons getting away with murder.

In most cases the person is subject to a

variety of post verdict mental health treatment plans that may include community participation

The legal opinion of Stan J. Caterbone was formulated on or before December 19, 2007 prior
to conducting any research on the topic or using any internet search engine to define the words
conditional release or any similar terminology. Stan J. Caterbone again is suspicious of the
dates of the post on the Jonathan Turley blog of December 19, 2007. The post may have been
posted prior to that date.
Page 6 of 35

until it can be proven by a certified psychiatrist that the person no longer poses any threat to
society before being released into the community.2 3

ISSUES BEFORE THE COURT

1. WETHER THE HEARING ON THE COMMONWEALTHS AMENDED PETITION UNDER

SECTION 304 OF THE PENNSYLVANIA MENTAL HEALTH PROCEDURES ACT P.S. 7304 IS
OPEN TO THE PUBLIC.
2. DID THE COURT GIVE DUE CONSIDERATION TO THE CLAIMS BY MEGHAN LIPPIATT
REGARDING RETALIATION BY THE PUBLIC DURING AND AFTER A PUBLIC HEARING ON
THE ISSUES.

I) SHOULD THE HEARING ON THE COMMONWEALTHS AMENDED PETITION UNDER


SECTION 304 OF THE PENNSYLVANIA MENTAL HEALTH PROCEDURES ACT P.S. 7304
IS OPEN TO THE PUBLIC?
Section 304 of the Pennsylvania Mental Health Procedures Act P.S. 7304

7304. Court-Ordered Involuntary Treatment Not To Exceed Ninety Days.


(a) Persons for Whom Application May be Made.-1. A person who is severely mentally disabled and in need of treatment, as
defined in section 301(a), may be made subject to court-ordered
involuntary treatment upon a determination of clear and present danger
under section 301(b)(1) (serious bodily harm to others), or section
301(b)(2)(i) (inability to care for himself, creating a danger of death or
serious harm to himself), or 301(b)(2)(ii) (attempted suicide), or
301(b)(2)(iii) (self- mutilation).
2. Where a petition is filed for a person already subject to involuntary
treatment, it shall be sufficient to represent, and upon hearing to
reestablish, that the conduct originally required by section 301 in fact
occurred, and that his condition continues to evidence a clear and present
danger to himself or others. In such event, it shall not be necessary to
show the reoccurrence of dangerous conduct, either harmful or
debilitating within the past 30 days.
2

Geoge M. Parker, MD Under conditional release, such acquittees are released into the
community with various conditions imposed; for example, they are often required to live in
specified housing and not to use illegal drugs. They remain under the jurisdiction of a criminal
judge or a central monitoring agency, such as a psychiatric security review board. Adherence to
mental health treatment in the community is almost always a condition of release. As leverage,
this type of mandated community treatment uses both avoidance of jail and avoidance of
hospitalizationboth a brief jail stay and rehospitalization are possible consequences of
violation of the conditions of release, depending on the state. See Exhibit B.
3
See Exhibits A thru D.
Page 7 of 35

(c) Procedures for Initiating Court-ordered Involuntary Treatment for


Persons Not in Involuntary Treatment.-1. Any responsible party may file a petition in the court of common pleas
requesting court-ordered involuntary treatment for any person not
already in involuntary treatment for whom application could be made
under subsection (a).
2. The petition shall be in writing upon a form adopted by the department
and shall set forth facts constituting reasonable grounds to believe that
the person is within the criteria for court-ordered treatment set forth in
subsection (a). The petition shall state the name of any examining
physician and the substance of his opinion regarding the mental condition
of the person.
3. Upon a determination that the petition sets forth such reasonable cause,
the court shall appoint an attorney to represent the person and set a date
for the hearing as soon as practicable. The attorney shall represent the
person unless it shall appear that he can afford, and desires to have,
private representation.
4. The court, by summons, shall direct the person to appear for a hearing.
The court may issue a warrant directing a person authorized by the
county administrator or a peace officer to bring such person before the
court at the time of the hearing if there are reasonable grounds to believe
that the person will not appear voluntarily. A copy of the petition shall be
served on such person at least three days before the hearing together
with a notice advising him that an attorney has been appointed who shall
represent him unless he obtains an attorney himself, that he has a right
to be assisted in the proceedings by an expert in the field of mental
health, and that he may request or be made subject to psychiatric
examination under subsection (c)(5).
5. Upon motion of either the petitioner or the person, or upon its own
motion, the court may order the person to be examined by a psychiatrist
appointed by the court. Such examination shall be conducted on an
outpatient basis, and the person shall have the right to have counsel
present. A report of the examination shall be given to the court and
counsel at least 48 hours prior to the hearing.
6. Involuntary treatment shall not be authorized during the pendency of a
petition except in accordance with section 302 or section 303.
(e) Hearings of Petition for Court-order Involuntary Treatment.--A
hearing on a petition for court-ordered involuntary treatment shall be conducted
according to the following:
1. The person shall have the right to counsel and to the assistance of an
expert in mental health.
2. The person shall not be called as a witness without his consent.
3. The person shall have the right to confront and cross-examine all
witnesses and to present evidence in his own behalf.

4. The hearing shall be public unless it is requested to be


private by the person or his counsel.
5. A stenographic or other sufficient record shall be made, which shall be
impounded by the court and may be obtained or examined only upon the
Page 8 of 35

request of the person or his counsel or by order of the court on good


cause shown.
6. The hearing shall be conducted by a judge or by a mental health review
officer and may be held at a location other than a courthouse when doing
so appears to be in the best interest of the person.
A decision shall be rendered within 48 hours after the close of evidence.

Under Section (e) 4. of the Section 304 of the Pennsylvania Mental Health Procedures
Act P.S. 7304 it clearly states the following:
The hearing shall be public unless it is requested to be
private by the person or his counsel.
In Judge James P. Cullen ORDER and OPINION of July 11, 2008 Judge Cullen appears to
be abusing his discretion by mandating a higher burden and threshold for showing good cause
why Ms. Lippiatt is entitled to her request of a closed hearing. It also appears that Judge Cullen
is trying to pacify the public interest and outcry when Meghan Liappitts was released at the
conclusion of her trial, which should have been addressed with a condition for release, which
Judge James P. Cullen failed to address in his VERDICT ORDER of December 13, 2008.
HIPAA CONSIDERATIONS
The privacy laws of health records addressed with the passage if the Health Information
Portability and Accountability Act (HIPAA) in 1996 may have some controlling interest in these
matters. A summary of HIPAA is as follows:
A major upshot of the Health Insurance Portability and Accountability Act
(HIPAA) of 1996 is a series of federal rules that have a considerable impact on
providers and patients their interactions, their rights, and their responsibilities.
In sorting through the details and compliance requirements of the privacy rule in
particular, it helps for practitioners to know something of the historical and
political context in which HIPAA and the rules that resulted from this law took
shape.
Under HIPAA, Congress tasked the Department of Health Human Services (HHS)
with developing federal rules that govern how patient records are handled,
shared, and protected in the health care system. The transactions rule, the
first rule promulgated by HHS, provides for standard formatting of electronic
patient records for health care claims and other purposes. This rule benefits
health professionals by making it easier for them to work with uniform rather
than multiple claims forms. While more rules will follow, the 800-pound gorilla
of the series, the privacy rule, was finalized last April. The privacy rule
provides some important protections for psychology records, with provisions that
will impact the confidentiality of the psychologist-patient relationship. 4

See Exhibit F: A Look Behind the Scenes of HIPAA and the Privacy Rule by Doug Walter, J.D.
Page 9 of 35

An Open Hearing would be placing mental health records in the public domain
and may be a violation of the rights of Ms. Lippiatt as defined in the HIPAA code.

The general public really has no interest in the process or the Section 304 of the
Pennsylvania Mental Health Procedures Act P.S. 7304 hearing, but rather has an interest in the
conclusion of the hearing in protecting itself from someone whom may pose a danger or threat
to others. That danger and or threat to the community-at-large is not compromised nor is it
supported by an open hearing. That danger and or threat is only of importance and relevant if
Ms. Lippiatt is found to have a mental health illness and is not committed for treatment. The
question of an open or closed hearing is not relevant, only the conclusion of the matters that
will be presented to the courts.

II) DID THE COURT GIVE DUE CONSIDERATION TO THE CLAIMS BY MEGHAN LIPPIATT
REGARDING RETALIATION BY THE PUBLIC DURING AND AFTER A PUBLIC HEARING ON
THE ISSUES?
Stanley J. Caterbone has been subject to an unprecedented history of retaliation and
intimidation that has been the result of a stigma due to his mental health record. Although this
mental health records validity and authenticity is being challenged in several courts, the stigma
and treatment by the community-at-large is real and can be used to substantiate Ms. Lippiatts
claim of retaliation in her opposition to an open hearing. Subjecting Ms. Lippiatt to unnecessary
intimidation and retaliation for information that would be made public during an open hearing is of
concern to all who may face similar circumstances.

Stanley J. Caterbone has a criminal record of some 30 false arrests in Lancaster County
that would have never been possible without his mental health record. Law enforcement relied
upon the fact that Stanley J. Caterbone had a history and mental health record to discredit him
before the courts, in his arrests, although he was successful in having those arrests and
convictions dismissed and overturned.
Stanley J. Caterbone also must endure a systematic and problematic attack of harassment
in public that is also due to the same mental health record and his fabricated and diminished
reputation caused by the same.

The fact that Ms. Lippiatt was found not guilty by reason of insanity of murdering her small
children should compel the court to consider her claims of retaliation more seriously. If the courts
do no recognize the risks involved to Ms. Lippiatt and others that may come before the courts in
similar circumstances, the courts should be compelled to provide the burden of proof that would
Page 10 of 35

be considered in closing the hearing for the same said reasons.

CONCLUSION

The Lippiatt case is apparently precedent in the County of Lancaster of a person being found
not guilty by reason of insanity. That being the case, the court should take extra precaution in
protecting all parties in all related matters and should be careful when reaching opinions and
conclusion that will be precedent to future and similar parties that will come before the courts.

Judge Cullens ORDER and OPINION of July 11, 2008 fails to protect the rights of Ms. Lippiatt
and others that may come before the courts, but does so unnecessarily. Closing the hearing to
the general public would not diminish the public interest, nor would it make the general public
safer. Only a conclusion of an involuntary commitment of Ms. Lippiatt IF she does now possess a
mental health illness that does pose a threat or danger to others.

July 21, 2008 _________

__________________
__________________

Respectfully Submitted:

Stanley J. Caterbone, Pro Se


Project Hope Foundation
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com

Page 11 of 35

CERTIFICATE OF SERVICE

Service was made on this 21s t day of July 2008 upon the following by way of electronic
mails; first class U.S. mails; or personal delivery at the addresses set forth below:

Kelley M. Sekula, Esq, ADA


Lancaster County District Attorney Office
Lancaster County Courthouse
50 N. Duke Street
Lancaster, PA 17602
Julie M. Cooper, Esq.,
Street: 222 South Market Street
Elizabethtown, pa 17022-2439
Phone: (717) 367-1370
George C. Werner, Esq.,
Barley Snyder, LLC
126 East King Street
Lancaster, PA 17602
Alspach & Ryder (Ryder, Bruce P)
232 N Duke St
Lancaster, PA 17602-5205
Phone: (717) 393-3939

July 21, 2008 _________

__________________
__________________

Respectfully Submitted:

Stanley J Caterbone, Pro Se


Project Hope Foundation
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentertainmentgroup.com

Page 12 of 35

EXHIBIT A

Page 13 of 35

The following can be viewed online at: http://jonathanturley.org


And search on LIPPIATT

Pa. Woman Who Killed Her Two Children Found Not Guilty by
Reason of Insanity
Published 1, December 11, 2007 Criminal law , Justice by Jonathan Turley
Meghan Lippiatt has been found not guilty by reason of insanity in a Lancaster court. Lippiatt
admitted suffocating her infant son and drowning her 2-year-old son in 2004.
The killing two-year-old Silas and his four- month-old brother Miles occurred weeks after a
break-up with her husband.
Lippiatt called 911 and told the operator: I did something really bad, I just killed my kids.
She later tried to kill herself and left a note which read: I am sorry, I didnt want to hurt
anyone. I am sorry, goodbye, please help me from the grave.
There is growing interest in allowing greater use of the insanity defense after it was heavily
curtailed after the shooting of President Ronald Reagan.
For a prior column on the insanity defense, click here
For the full story, click here

Response to Pa. Woman Who Killed Her Two Children Found


Not Guilty by Reason of Insanity
CATERBONE of Advanced Media Group wrote:
December 19, 2007
Dear Mr. Turley,
First of all I always look for your opinion when issues are looking for expert constitutional
scholars. I have been an avid learner of your opinion for many, many years.
Regarding this case, I dont know if you are aware, but there was a problem and fiasco after
the trial and wondered what your opinion was. She was freed immediately after her bench trial
upon a Habeas corpus filed by her defense counsel. See the following news account:
http://local.lancasteronline.com/4/213886
Here is a brief synopsis; In the VERDICT ORDER there did not seam to be any condition for Ms.
Liappatt to be held in custody until a further psychiatric evaluation could be performed. This set
in motion a number of court filings by the District Attorney, the Defense Counsel, and others
trying to recommit her to a treatment facility.
The following was my ema il to someone regarding my suspicion, I have later found that
temporary insanity, if in his verdict would free her immediately after trial:
December 18, 2007
To Ron Harper of http://www.5thestate.com
Are you following this case at all? This is truly a first class Lancaster County
smoke and mirrors game?
Page 14 of 35

This is my analysis. And for the record, I did attend the trial and sat to hear
Gottlieb, the psychiatrist testify and be cross-examined. I have also studied
mental health issues for Project Hope, for my own case, and for my familys
different cases, especially my father and brothers Sam and Tom; for over 20
years. So I am not uneducated with the issues.
Being that this is the first such verdict of not guilty by reason of insanity in
Lancaster County, as reported, I think this whole case was purposely
mismanaged so that the next time such a verdict is before a Lancaster County
jury, they can say see, if you find the defendant not guilty by insanity, that
person may be released and freed without any treatment or conditions.
I think Judge Cullen should have to explain why he did not issue a
condition in his verdict to have Ms. Lippiatt held in Lancaster County
Prison or transferred to a mental health facility until the outcome of a
psychiatric evaluation. I dont understand why he did not do this, unless
the law prevented him from doing that. I will have to research this.
I would love to hear your opinion, if you find the time. Hope to meet you in the
future.

STAN J. CATERBONE
Advanced Media Group

Page 15 of 35

EXHIBIT B

Page 16 of 35

Bio of JONATHAN TURLEY


Professor Jonathan Turley is a nationally recognized legal scholar who has written extensively
in areas ranging from constitutional law to legal theory to tort law. He has written over three
dozen academic articles that have appeared in a variety of leading law journals at Cornell,
Duke, Georgetown, Harvard, Northwestern, and other schools.
After a stint at Tulane Law School, Professor Turley joined the George Washington faculty in
1990 and, in 1998, was given the prestigious Shapiro Chair for Public Interest Law, the
youngest chaired professor in the schools history. In addition to his extensive publications,
Professor Turley has served as counsel in some of the most notable cases in the last two
decades ranging, representing whistleblowers, military personnel, and a wide range of other
clients. These include his representation of the Area 51 workers at a secret air base in Nevada;
the nuclear couriers at Oak Ridge, Tennessee; the Rocky Flats grand jury in Colorado; Dr. Eric
Foretich, the husband in the famous Elizabeth Morgan custody controversy; and four former
United States Attorneys General during the Clinton impeachment litigation. In the Foretich
case, Turley succeeded recently in reversing a trial court and striking down a federal statute
through a rare bill of attainder challenge. Professor Turley has also served as counsel in a
variety of national security cases, including espionage cases like that of Jim Nicholson, the
highest ranking CIA officer ever accused of espionage. Turley also served as lead defense
counsel in the successful defense of Petty Officer Daniel King, who faced the death penalty for
alleged spying for Russia. Turley also served as defense counsel in the case of Dr. Tom Butler,
who is facing criminal charges dealing with the importation and handling of thirty vials of
plague in Texas. He also served as counsel to Larry Hanauer, the House Intelligence Committee
staffer accused of leaking a classified Presidential National Intelligence Estimate to the New
York Times. (Hanauer was cleared of all allegations).
Among his current cases, Professor Turley represents Dr. Ali Al-Timimi, who was convicted in
Virginia in 2005 of violent speech against the United States. He also represents Dr. Sami AlArian, accused of being the American leader of a terrorist organization while he was a
university professor in Florida. He also currently represents pilots approaching or over the age
of 60 in their challenge to the mandatory retirement age of the FAA. Turley has
served as a consultant on homeland security and constitutional issues, including the Florida
House of Representatives.
Professor Turley is a frequent witness before the House and Senate on constitutional and
statutory issues as well as tort reform legislation. Professor Turley is also a nationally
recognized legal commentator. Professor Turley was ranked as 38th in the top 100 most cited
public intellectuals in the recent study by Judge Richard Posner. Turley was also found to be
the second most cited law professor in the country. In 2008, he was ranked in a study of the
nations top 500 lawyers - one of only a handful of academics. In prior years, he was ranked as
one of the nations top ten lawyers in military law cases as well as one of the top 40 lawyers
under 40.
Professor Turleys articles on legal and policy issues appear regularly in national publications
with over 500 articles in such newspapers as the New York Times, Washington Post, USA
Today, Los Angeles Times and Wall Street Journal. He is on the Board of Contributors of USA
Today. In 2005, Turley was given the Columnist of the Year award for Single-Issue Advocacy
for his columns on civil liberties by the Aspen Institute and the Week Magazine.
Professor Turley also appears regularly as a legal expert on all of the major television
networks. Since the 1990s, he has worked under contract as the on-air Legal Analyst for NBC
News and CBS News to cover stories that ranged from the Clinton impeachment to the
presidential elections. Professor Turley is often a guest on Sunday talk shows with over twodozen appearances on Meet the Press, ABC This Week, Face the Nation, and Fox
Sunday.Professor Turley teaches courses on constitutional law, constitutional criminal law,
environmental law, litigation, and torts. He is the founder and exectuve director of the Project
for Older Prisoners (POPS).
Page 17 of 35

Professor Turley received his B.A. at the University of Chicago and his J.D. at Northwestern. (In
2008, he was given an honorary Doctorate of Law from John Marshall Law School for his
contributions to civil liberties and the public interest).
For further information: Ms. Kristen Hilderbrand 202-994-0537

Page 18 of 35

EXHIBIT C

Page 19 of 35

Letters
Conditional Release and Mandated Outpatient Treatment
George F. Parker, M.D.
To the Editor: In the thoughtful and stimulating article on mandated outpatient treatment by
Monahan and colleagues in the September 2001 issue (1), little mention was made of the fairly
substantial literature on mandated treatment of forensic populations in the community.
Conditional release has been used for decades as a technique for managing the risks inherent in
returning a person found not guilty by reason of insanity to the community.
Under conditional release, such acquittees are released into the community with various
conditions imposed; for example, they are often required to live in specified housing and not to
use illegal drugs. They remain under the jurisdiction of a criminal judge or a central monitoring
agency, such as a psychiatric security review board. Adherence to mental health treatment in
the community is almost always a condition of release. As leverage, this type of mandated
community treatment uses both avoidance of jail and avoidance of hospitalizationboth a brief
jail stay and rehospitalization are possible consequences of violation of the conditions of
release, depending on the state.
I recently conducted a thorough literature search, using PubMed and manual strategies, on the
topic of conditional release for persons found not guilty by reason of insanity. I found more than
60 articles, including more than 30 published in the past ten years. Many of the earlier studies
on conditional release focused on the demographic characteristics of persons found not guilty by
reason of insanity. However, most of the articles on this subject for the past 30 years have
reported arrest rates and hospitalization rates of persons on conditional release. A recent metaanalysis on this issue, based on statewide results from New York, California, and Oregon, found
estimated annual arrest rates to range from 3.4 to 7.9 percent, while the estimated annual
hospitalizatio n rates ranged from 14.5 to 25.8 percent (2,3). I recently presented a poster at
the annual meeting of the American Academy of Psychiatry and the Law showing that among
persons receiving assertive community treatment the annual arrest rate was 1.2 percent and
the annual hospitalization rate was 14.5 percent (4). In addition, some of the published reports
have included statistical models for factors that are predictive of the granting or revocation of
conditional release (5).
The literature on conditional release of persons found not guilty by reason of insanity thus may
hold some of the answers to the many questions about mandated community treatment posed
by Monahan and colleagues. In particular, the issues of the process of mandating treatment,
the outcomes of programs both for the individual and for the systemthat do mandate
treatment, and the legal, ethical, and political questions that result from mandating treatment
in the community have all been discussed, to greater or lesser degrees, in the conditional
release literature over the past 30 years.
Footnotes
Dr. Parker is associate professor of clinical psychiatry at Indiana University School of Medicine
in Indianapolis.
References
1. Monahan J, Bonnie RJ, Appelbaum PS, et al: Mandated community treatment: beyond
outpatient
commitment.
Psychiatric
Services
52:1198-1205,
2001[Abstract/Free Full Text]
2. Wiederanders MR, Bromley DL, Choate PA: Forensic conditional release programs and
outcomes in three states. International Journal of Law and Psychiatry 20:249-257,
1997[CrossRef][Medline]
Page 20 of 35

3. Harris VL: Insanity acquittees and rearrest: the past 24 years. Journal of the American
Academy of Psychiatry and the Law 28:225-231, 2000[Medline]
4. Parker GF: Low reoffense rate in a conditional release program. Poster presented at the
annual meeting of the American Academy of Psychiatry and the Law, Boston, Oct 25-28,
2001
5. Callahan LA, Silver E: Factors associated with the conditional release of persons
acquitted by reason of insanity: a decision tree approach. Law and Human Behavior
22:147-163, 1998[CrossRef][Medline]

Page 21 of 35

EXHIBIT D

Page 22 of 35

Griffin PA, Steadman HJ, Heilbrun K.


Virginia Department of Mental Health, Mental Retardation, and Substance Abuse Services,
Richmond 23214.

Monitored treatment in the community, also known as conditional release, has been described
a s the most important advance in the treatment of insanity acquittees in the last decade.
Despite the importance of the development of conditional release, however, there has been
relatively little written about relevant issues and planning principles important in designing and
implementing conditional release systems. The present paper discusses important
considerations relevant to conditional release that are associated with key decision points
within systems for persons found not guilty by reason of insanity (NGRI). Four planning
principles, generalizable to all NGRI systems, are then presented in a way that integrates the
previous discussion. It is concluded that conditional release plays a crucial role in the treatment
of insanity acquittees and that mental health administrators may either proactively modify their
systems, in a way that balances public safety with individual rights and treatment needs, or
wait for the modification mandate to be forced upon them in the wake of a highly publicized,
heinous offense.

Page 23 of 35

EXHIBIT E

Page 24 of 35

A Look Behind the Scenes of HIPAA and the Privacy Rule


by Doug Walter, J.D.
A major upshot of the Health Insurance Portability and Accountability Act (HIPAA) of 1996 is a
series of federal rules that have a considerable impact on providers and patients their
interactions, their rights, and their responsibilities. In sorting through the details and
compliance requirements of the privacy rule in particular, it helps for practitioners to know
something of the historical and political context in which HIPAA and the rules that resulted
from this law took shape.
Under HIPAA, Congress tasked the Department of Health Human Services (HHS) with
developing federal rules that govern how patient records are handled, shared, and protected
in the health care system. The transactions rule, the first rule promulgated by HHS, provides
for standard formatting of electronic patient records for health care claims and other
purposes. This rule benefits health professionals by making it easier for them to work with
uniform rather than multiple claims forms. While more rules will follow, the 800-pound
gorilla of the series, the privacy rule, was finalized last April. The privacy rule provides
some important protections for psychology records, with provisions that will impact the
confidentiality of the psychologist-patient relationship.
The privacy rule may be divided into three parts. The provisions of the first part address when
and how patient records may be used and disclosed among treating providers and to third
parties. The second part provides patients with certain rights regarding their records, such as
the right to access and amend records. The third part outlines administrative requirements
that psychologists and other health care professionals and entities must follow in using and
disclosing patient records.
In essence, the privacy rule affords psychologists new protections regarding the records of
their patients, but it also requires psychologists to proactively ensure the protection of records
through certain administrative requirements. These include, for example, providing patients
with information about their privacy rights, implementing procedures to ensure records
privacy, and securing records in offices.
While the privacy rule includes some requirements already contained in various state laws,
some of the federal rules mandates are new. The rule may be understood, however, as
providing a national floor of patient records protections upon which states may build further
protections, since Congress has specifically provided that state laws providing for greater
records protection will not be preempted by the federal rule.
Some may question why a federal privacy rule was promulgated in the first place, since many
state laws already protect the privacy of patient records. The short answer is that state laws
vary in the extent to which they protect patient records privacy, particularly mental health
records. A federal floor of protection provides a baseline uniformity of records protection. The
long answer is rooted in the history leading to promulgation of the privacy rule.
The Stage for Conflict Is Set
HIPAA legislation and rulemaking, including development of the privacy rule, have much to do
with the emergence of managed care organizations (MCOs) in the early 1990s as the primary
payers for health care. Unlike insurers in the fee-for-service system, MCOs began demanding
broad access to patient records for payment and administrative purposes. Patients and
providers balked and fought to keep sensitive personal information outside of the claims management process.
Page 25 of 35

management process.
By the mid 1990s, the insurance and business lobbies began pitching to Congress that a
uniform, electronic patient records system to standardize health insurance claims processing,
dubbed administrative simplification, would save the health care system billions of dollars
and relieve the inefficiency and fragmentation in health care claims management. Insurers
were also looking for a federal law that legitimized their demands for broad access to patient
records. While organized psychology supported administrative simplification, it could not come
at a cost to records privacy.
APA was at the forefront of groups concerned that the onerous MCO demands for patient
records disclosures often for administrative purposes not directly related to patient care
had eroded confidentiality. Provider and patient organizations advocated for privacy and
security safeguards that would be needed if Congress were to mandate uniform electronic
claims processing.
The stage for political conflict therefore was set by the time President Clinton included both
patient records privacy and administrative simplification provisions in his Health Security Act
of 1993, which failed to win passage. The inclusion of these provisions shed light on the
bitter fight brewing between patients/providers and MCOs over control of records and
foreshadowed the rancorous congressional debate to come. The underlying conflict, which
continues to this day, was the force that shaped HIPAA law in general and the privacy rule
specifically.
Battle Pits Provider Groups Against Insurers
The advocacy battle began in earnest when Senator Robert Bennett (R-Utah) introduced the
Medical Records Confidentiality Act in late October 1995. The Practice Directorate was
concerned by the Bennett bills bipartisan co-sponsorship by powerful members of Congress
and by the strong support of insurers and other influential organizations. The concern arose
from APAs taking a careful look at the bills details. The directorates analysis revealed
substantial weaknesses in protecting the rights of patients and providers with respect to the
privacy of records. APA and allied groups mobilized to prevent the Bennett bill from being
included in broader health care legislation that Congress also was seriously considering that
fall. That broader legislation eventually was enacted as HIPAA.
A "Final" Rule Is Subject to Change
The political battle between insurance and patient and provider organizations continues to
this day. President George W. Bushs Administration put the HIPAA privacy rule into effect

Page 26 of 35

the rules privacy protections, and even expanding them. For example, the MHLG
continues to urge that the special privacy protection given to psychotherapy notes as
defined in the rule (see article on page 5) should be broadened to apply to other sensitive
information such as psychological testing data.
For several months, the directorates government relations staff worked to educate Congress
and the public about the need for a strong federal privacy bill, or at least a bill that would not
undermine existing state privacy laws that protected patients rights. APAs lobbying push
successfully countered the insurance industrys efforts to win inclusion of the Bennett bill in
HIPAA. In place of the Bennett bill, Congress incorporated a few sentences into HIPAA to
provide a timeline for action. Legislators gave themselves three years, until August 1999, to
enact a federal law governing records privacy and further directed that HHS would establish a
privacy rule within six months of Congress failure to meet its deadline.
Shortly after HIPAAs passage, it became increasingly clear that the patient and provider
lobbies and the insurance lobby were entrenched in polar positions. APA assessed that
Congress would not likely pass legislation. While the association continued to advocate for
appropriate privacy legislation in Congress, APA began focusing efforts on the Administration
in anticipation of a rule from HHS. Organized psychology sought a rule that would recognize
the particular privacy requirements of records associated with mental health treatment,
including the need for heightened protection for psychotherapy notes and other mental health
records.
Too Hot for Congress to Handle
Indeed, the privacy issue ultimately became too controversial for members of Congress to
handle, and HHS ended up proposing a federal privacy rule in November 1999. It looked like a
compromise for both sides of the debate. Insurers saw their broad access to records
recognized in the proposed rule. At the same time, consumers and providers had won strong
protections for records each time they were disclosed to insurers.
Throughout 2000, APA worked to ensure that the proposed rules strong patient protections
were preserved in a final rule. Meanwhile, the insurance lobby pushed to void the rule or at
least substantially weaken its protections. HHS released the final privacy rule in the last days
of the Clinton Administration in much the same form as the proposed rule. The Practice
Directorate considered the final rule a success, with qualification. For example, APA reiterated
in written comments to HHS that the privacy rule allowed insurers too much access to records
for administrative purposes not directly related to treatment. It appeared the conflict and
compromise characteristic of the legislative and rulemaking processes was reflected in the
final rule once it ultimately took effect last April.
The following chronology illustrates from 1993 through 2001 the major events and players
related to the HIPAA law and the final privacy rule from HHS.

Page 27 of 35

EXHIBIT F

Page 28 of 35

Federal Oversight of Psychiatric Records: The Health Insurance Portability and


Accountability Act
by Karen Welch
More than two years ago, I published an article on psychiatric records in Mental Health
World. This same article was included on one of the Internet editions of MHW found on our
website at www.mentalhealthworld.org. Since publishing that article, each month, I receive at
least one email asking questions about confidentiality and access to psychiatric records. The
previous MHW article on psychiatric records specifically addressed access to records and
confidentiality under New York State law. Since that article was written, the federal
government has created regulations under the Health Insurance Portability and Accountability
Act (HIPAA) which deal explicitly with access and confidentiality of all health care records. The
present article will summarize some of the main provisions of these regulations as they relate
to the confidentiality and access of psychiatric records.
It will also note how the HIPAA
regulations differ from New York Law.
The Health Insurance Portability and Accountability Act was passed by Congress in
1996. Final regulations regarding the privacy provisions of this law were issued by the Bush
administration in August 2002 and will become effective in April 14, 2003. These regulations
provide a comprehensive set of rules for the confidentiality and access to all health records.
Since this is a federal law, it affects everyone in the United States. The HIPAA privacy
regulations supersede any state law, to the extent that they provide greater protections than
state law. However if a states law provides greater privacy protections than HIPAA, then the
states rules apply.
General Provisions of HIPAA
HIPAA greatly expands the entities which must keep psychiatric records confidential.
Entities which are covered by the requirements of HIPAA include health care providers, health
plans and health care clearinghouses that transmit or maintain any health information via
electronic media. The definition of health plans includes group health plans, health insurance
issuers, HMOs, Medicaid programs, Medicare programs and long-term care policies.
Additionally, the law requires that business associates of covered entities which perform
services involving the use or disclosure of protected health information must enter into an
agreement to safeguard the privacy of the protected health information.
HIPAA also greatly expands the types of information that are protected. With a few
narrow exceptions, HIPAA applies to all individually identifiable health information in any form
held or transmitted by a covered entity. Individually identifiable means that it is information
from which a person can identify the person to whom it relates. The information is covered
whether it is oral or recorded. It also does not matter if it was created by a health care
provider, health plan, public health authority, employer, life insurer, school or university or
health care clearinghouse. The information may relate to past, present or future physical or
mental health or condition of an individual, the provision of health care to an individual or the
past, present or future payment of health care to an individual.
In contrast, under the New York Mental Hygiene Law, a clinical record means any
information covering or relating to the examination or treatment of a patient or client
maintained by the facility which has treated or is treating such patient or client.
Under the
New York Mental Hygiene Law, privacy protections apply to facilities that are operated or
licenced by the New York State Office of Mental Health. Additionally, the law requires that
disclosure of these records to third parties places the third party under an obligation to
maintain confidentiality.
For consumers of mental health services, the expansion of privacy protections found in
HIPAA is welcome. Often, individuals would successfully seal their clinical records under New
York law only to be thwarted by the fact that insurers or health information clearinghouses had
Page 29 of 35

created their own records which were not subject to the confidentiality provisions of New York
law. Under HIPAA, the likelihood of this problem is substantially decreased since these entities
must now maintain strict confidentiality or face the penalties under the law.
Access By Individuals to Their Own Records
HIPAA creates a general right for an individual to access his or her own health records
subject to a number of exceptions. Additionally, the comments to the regulations state that
individuals have a right of access to information used to make health care decisions or
determine whether an insurance claim will be paid. The four exceptions to the general right of
access to records are:
1) psychotherapy notes;
2) information compiled in reasonable anticipation of, or use in, a civil, criminal or
administrative action and proceeding;
3) where access is prohibited by the Clincial Laboratory Improvements Amendments of
1988: or
4) records that are exempt under the regulations of the Clinical Laboratory
Improvements Amendment. The Clinical Laboratory Improvements Amendments of 1988 is an
act which forbids laboratories doing tests on human specimens to disclose the results to anyone
except the individual or entity who requested the test.
The definition of psychotherapy notes is notes recorded in any medium by a health
care provider who is a mental health professional documenting or analyzing the contents of a
conversation during a private counseling session or a group, joint, or family counseling
session.
Psychotherapy notes are intended to refer to a mental health professionals own
personal notes of a therapy session. Notes do not count as psychotherapy notes unless they
are kept separately from the patients medical chart.
Reviewable Denial of Access to Records
Under HIPAA, other than the unreviewable reasons discussed below, the right of a
patient to see his own chart can be restricted in only three circumstances. Each of these
circ umstances is reviewable by an appeal process.
First, a licensed health care professional may deny access if in the exercise of his
professional judgement it is determined that such access is reasonably likely to endanger the
life or physical safety of the individual or other person. Under this reason for denial, covered
entities may not deny the access on the basis of the sensitivity of the health information or the
potential for causing psychological or emotional harm. A health care professional must find
that the individual has exhibited suicidal or homicidal tendencies and that access to the records
would reasonably result in murder, suicide or other physical violence.
Second, there is a reviewable exception when the requested information relates to
another person (other than the health care provider) and in the professional judgement of the
licensed health care professional, the access would likely cause substantial harm to such
person.
Third, if the personal representative of an individual makes the request rather than the
individual himself, the request may be denied if the provision of access to records to the
personal representative is reasonably likely to cause substantial harm to the individual or other
person.
This scheme is somewhat different from that found in the New York Mental Hygiene
Law. Under New York law, the treating practitioner may review the information requested. If
after consideration of all factors, the practitioner determines that the requested review could
reasonably be expected to cause substantial and identifiable harm to the patient, client or
Page 30 of 35

others, the facility may deny access to all or a part of the record and may grant access to a
prepared summary of the record.
Unreviewable Denial of Access to Records.
Under HIPAA, there are five areas where an entity may deny access to records without
an opportunity for review of this denial. The areas are:
1) the exceptions to the right of access described above
2) the request of a prison inmate to see his records if obtaining such copy would
jeopardize the health, safety, security, custody or rehabilitation of the prisoner or other
inmates or the safety of the correctional staff.
3) if the protected health information is
contained in records subject to the Privacy Act;
4) the information was obtained from someone other than a health care provider under
a promise of confidentiality and the access would be reasonably likely to reveal the source of
the information.
5) a research subjects request to see his records during research, if the consent form
for the research advised that access to records would be suspended during research and the
patient signed the consent form.
Process of Review of Denial of Access
The review of a denial of the access is to be conducted by a health care professional
designated by the covered entity. This professional may not have been directly involved in
the original denial of the request for access. The review must be conducted in a
reasonable time period but the regulations do not impose deadlines on any entity. There is
no provision for judicial review of this denial.
New Yorks review procedure for a denial of access appears to be more helpful to
consumers. Under the New York Mental Hygiene Law, if access to a psychiatric record is
denied, a patient has the right to appeal for review by the Clinical Records Access Review
Committee. A client must be notified by the facility of his right to a review of the denial by
the appropriate clinical record access review committee. If the client requests this review,
the facility must within ten days of the request, transmit the record to the chairman of the
appropriate committee with a statement setting forth the specific reasons access was
denied. If access is denied by the records access review committee, a patient has a right
to seek judicial review of this denial. Court review must be commenced within 30 days of
receiving notification of the committee decision.
Procedure for Correcting Records
Under HIPAA, an individual has the right to have a covered entity amend protected
health information or records about the individual in a designated record set. An
individuals request for amendment may be denied if the health information or record:
1) was not created by the covered entity;
2) is not part of the designated record set;
3) would not otherwise be available for inspection by the individual;
4) is accurate and complete.
An individual should make a request for the amendment in writing. The entity may
require [that omit DN] the individual to provide reasons to support a requested
amendment to a record. An entity must act on the request within 60 days of the request
for an amendment although this time may be extended once for 30 days if it notifies the
Page 31 of 35

individual in writing of the reasons for the delay.


If the entity agrees to make the amendment to the consumers record it must do so
and make a reasonable effort to inform others about the amendment including persons
identified by the consumer as having the information and any persons that are known by
the entity to have the records. If the entity denies the consumers request to amend the
record, the entity must provide a timely written denial. The consumer can then submit a
written statement disagreeing with the denial. This information must be appended to the
record and included in any future disclosure.
Under the New York Mental Hygiene Law, an individual may challenge the accuracy
of the information maintained in his clinical record and may require that a brief written
statement prepared by him concerning the challenged information be inserted into the
clinical record. This statement shall become part of the permanent part of the record and
shall be released whenever the clinical record at issue is released. The information to be
challenged shall be only factual statements and shall not include a providers observations,
inferences or conclusions.
For information concerning access to records, confidentiality or sealing of records, or for
other questions concerning the mental health laws, please contact the PAIMI (Protection and
Advocacy for the Mentally Ill) program at Neighborhood Legal Services, 716/847-0650.
Sources
Stefan, Susan, Q&A, What effect do the recently promulgated HIPAA regulations on
privacy of records have for the rights of my clients to access their own records?, Center for
Public Representation, August 2002
Clemens, Jane F., New Federal Regulations Expand Protections For Privacy of Health
Records,
New York State Bar Journal, June 2002.
Flannery, John, Paley, Eric, and Roland, M.K. Gaedecke, With HIPPA deadlines on
horizon, whats required?, Buffalo Law Journal, September 26, 2002

Page 32 of 35

EXHIBIT G

Page 33 of 35

More protections for patients and psychologists under HIPAA


HIPAA's psychotherapy notes provision safeguards sensitive patient information.
BY JENNIFER DAW HOLLOWAY
Monitor staff
Print version: page 22

Though the mention of the Health Information Portability and Accountability Act (HIPAA)
privacy rule compliance date--April 14--can make some psychologists anxious, most applaud
the new law for increasing privacy protections.
Especially interesting to practitioners is the psychotherapy notes provision, says Russ Newman,
PhD, JD, APA's executive director for practice. The provision recognizes that certain kinds of
mental health information need to be protected more than other types of information. Under
HIPAA, psychotherapy notes are defined as "notes recorded in any medium by a mental health
professional documenting or analyzing the contents of conversation during a private counseling
session." These notes, which capture the psychologist's impressions about the patient and can
contain information that is inappropriate for a medical record, are similar to what psychologists
have historically referred to as "process notes."
HIPAA affords psychotherapy notes more protection--most notably from third-party payers-than they'd been given in the past. Under HIPAA, disclosure of psychotherapy notes requires
more than just generalized consent; it requires patient authorization--or specific permission--to
release this sensitive information. And, whereas in the past insurance companies have
requested entire patient records--including psychotherapy notes--in making coverage
decisions, now health plans cannot refuse to provide reimbursement if a patient does not agree
to release information covered under the psychotherapy notes provision.
"In the past, patients could refuse to have this type of information released, but then the
company might refuse to cover services," notes Newman. "The HIPAA privacy rule protection
stops that kind of practice from taking place."
Psychologists take note
The privacy rule gives rights to health professionals, as well as to their patients. Under the new
law, psychologists can decide whether to release their psychotherapy notes to patients, unless
patients would have access to their psychotherapy notes under state law (see the article about
HIPAA and state laws in last month's Monitor). Though the privacy rule does afford patients the
right to access and inspect their health records, psychotherapy notes are treated differently:
Patients do not have the right to obtain a copy of these under HIPAA. And when a psychologist
denies a patient access to these notes, the denial isn't subject to a review process, as it is with
other records.
There is a catch in the psychotherapy notes provision. HIPAA's definition of psychotherapy
notes explicitly states that these notes are kept separate from the rest of an individual's record.
So, if a psychologist keeps this type of information in a patient's general chart, or if it's not
distinguishable as separate from the rest of the record, access to the information doesn't
require specific patient authorization. According to the Department of Health and Human
Services (HHS), it makes good sense to keep the notes separate since this type of information
should not be available automatically.
This may, says Newman, be a practical difference from the way some psychologists have
previously stored patient information. But, "if psychologists want higher protections for
psychotherapy notes, then they should keep the information separate," he urges.
Daniel Abrahamson, PhD, professional affairs coordinator for the Connecticut Psychological
Association, adds that psychologists "shouldn't jump the gun." Keeping records separate is an
option and "each practitioner will need to determine whether the benefits of maintaining extra
protection outweigh keeping the records distinctly separate from medical records," he says. In
Page 34 of 35

other words, some psychologists may decide that, for some patients, the information doesn't
particularly need the extra level of protection. If a particular treatment evolves and the
psychologist wants to keep the psychotherapy notes separate, he or she can choose to do that.
"It's part of good clinical judgment," says Abrahamson. "In the past, clinicians didn't include
some information in a record and therefore wouldn't be able to later document that
information. Now they have the option to include detailed content in separate notes."
In addition to keeping these notes separate from other patient information, psychologists
should be aware, says Newman, that there are certain parts of a record that are expressly not
considered psychotherapy notes--and that don't require patient authorization for disclosure-under the HIPAA privacy rule. This information includes medication prescription and monitoring,
counseling session start and stop times, modalities and fre quencies of treatment, results of
clinical tests, and any summary of diagnosis, functional status, treatment plans, symptoms,
prognosis or progress.
This portion of the rule is likely to leave some "potential for interpretation," says Newman.
"What if a managed-care company says it needs a summary of the themes from psychotherapy
sessions? They may say that's outside the psychotherapy notes provision. We'd argue that
divulging themes of the conversations in psychotherapy is tantamount to giving away the whole
conversation," he says.
In the same vein, testing information, like summary information, isn't included under
psychotherapy notes. APA submitted comments to HHS on both the proposed and final rules
asking that psychological test data be included in the provision. Disclosing this type of
information, says Newman, could divulge intimate details about a patient much like the
information from psychotherapy sessions. Unfortunately, he says, HHS declined to expand the
definition.
Despite the exclusion of certain information, however, the psychotherapy notes provision
should be heralded "as a significant victory for privacy advocates," says Nanci Klein, PhD,
professional affairs coordinator for the Utah Psychological Association. "Practitioners have long
found it onerous to have to release psychotherapy notes for additional treatment authorization
by managed-care companies." Now, she says, managed-care companies are only entitled to
certain types of information, not including psychotherapy notes.
"I think this defines the psychologist as the treating expert whose professional analysis and
opinion represent the core information necessary for making judgments about the necessity for
continued treatment," she adds.
This article is the second in a three-part series on HIPAA topics. The next piece, on HIPAA's
minimum necessary requirement, will appear in March.

Page 35 of 35

Você também pode gostar