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CATERBONE v. The United States, et.al.

, - A CIVIL RIGHTS COMPLAINT

Stan J. Caterbone
ADVANCED MEDIA GROUP

Freedom From Covert Harassment &

Surveillance,
Registered in Pennsylvania

1250 Fremont Street


Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
stancaterbone@gmail.com
717-528-2200

UNITED STATES DISTRICT COURT


FOR THE EASTERN DISTRICT OF PENNSYLVANIA

STANLEY J. CATERBONE AND ADVANCED MEDIA GROUP


PLAINTIFF
:
:
v.
:
:
The United States of America, et al.
:
DEFENDANTS
:
:
:

CASE NO. ________

______________________________________________________________________________
COMPLAINT CIVIL ACTION
42 U.S. Code 1983 - Civil action for deprivation of rights.

The complaint will be filed under 42 U.S. Code 1983 - Civil action for deprivation of rights.
In summary the statute reads: Every person who, under color of any statute, ordinance,
regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or
causes to be subjected, any citizen of the United States or other person within the jurisdiction
thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and
laws, shall be liable to the party injured in an action at law, suit in equity, or other proper
proceeding for redress, except that in any action brought against a judicial officer for an act

or omission taken in such officers judicial capacity, injunctive relief shall not be
granted unless a declaratory decree was violated or declaratory relief was unavailable.
For the purposes of this section, any Act of Congress applicable exclusively to the
District of Columbia shall be considered to be a statute of the District of Columbia.

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CATERBONE v. The United States, et.al., - A CIVIL RIGHTS COMPLAINT


DATED:

December 10, 2016

___________/S/____________
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
stancaterbone@gmail.com
717-528-2200

Notice and Disclaimer: Stan J. Caterbone and the Advanced Media Group have been slandered, defamed, and
publicly discredited since 1987 due to going public (Whistle Blower) with allegations of misconduct and fraud
within International Signal & Control, Plc. of Lancaster, Pa. (ISC pleaded guilty to selling arms to Iraq via
South Africa and a $1 Billion Fraud in 1992). Unfortunately we are forced to defend our reputation and the
truth without the aid of law enforcement and the media, which would normally prosecute and expose public
corruption. We utilize our communications to thwart further libelous and malicious attacks on our person, our
property, and our business. We continue our fight for justice through the Courts, and some communications
are a means of protecting our rights to continue our pursuit of justice. Advanced Media Group is also a
member of the media. Reply if you wish to be removed from our Contact List. How long can Lancaster County
and Lancaster City hide me and Continue to Cover-Up my Whistle Blowing of the ISC Scandel (And the Torture
from U.S. Sponsored Mind Control)?

ACTIVE COURT CASES


1. J.C. No. 03-16-90005 Office of the Circuit Executive, United States Third Circuit
Court of Appeals - COMPLAINT OF JUDICIALMISCONDUCT OR DISABILITY re 153400 and 16-1149; 03-16-900046 re ALL FEDERAL LITIGATION TO DATE
2. U.S. Supreme Court Case No. 16-6822 PETITION FOR WRIT OF CERTIORARI re
Case No. 16-1149 MOVANT for Lisa Michelle Lambert
3. U.S.C.A. Third Circuit Court of Appeals Case No. 16-1149 MOVANT for Lisa Michelle
Lambert;15-3400 MOVANT for Lisa Michelle Lambert;; 16-1001; 07-4474
4. U.S. District Court Eastern District of PA Case No. 16-4014 CATERBONE v. United
States, et.al.; Case No. 16-cv-49; 15-03984; 14-02559 MOVANT for Lisa Michelle
Lambert; 05-2288; 06-4650, 08-02982;
5. U.S. District Court Middle District of PA Case No. 16-cv-1751 PETITION FOR
HABEUS CORPUS
6. Commonwealth of Pennsylvania Judicial Conduct Board Case No. 2016-462
Complaint against Lancaster County Court of Common Pleas Judge Leonard Brown III
7. Pennsylvania Supreme Court Case No. 353 MT 2016; 354 MT 2016; 108 MM 2016
Amicus for Kathleen Kane
8. Superior Court of Pennsylvania Summary Appeal Case No. CP-36-SA-0000219-2016,
AMICUS for Kathleen Kane Case No. 1164 EDA 2016; Case No. 1561 MDA 2015;
1519 MDA 2015; 16-1219 Preliminary Injunction Case of 2016
9. Lancaster County Court of Common Pleas Case No. 08-13373; 15-10167; 06-03349,
CI-06-03401
10. U.S. Bankruptcy Court for The Eastern District of Pennsylvania Case No. 16-10157

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CATERBONE
v. The United
et.al.,Media
A CIVIL
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COMPLAINT
Stan J. Caterbone
andStates,
Advanced
Stan
J.- Caterbone,
Group,
Pro Se
Billing File

Stan
LOCAL,
Caterbone
STATE,
FEDERAL
& FEDERAL
COURT
COURT
DOCKETS
DOCKDETS Page
DOCKETS
171
499
811
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December 10,

CATERBONE
v. The United
et.al.,Media
A CIVIL
RIGHTS
COMPLAINT
Stan J. Caterbone
andStates,
Advanced
Stan
J.- Caterbone,
Group,
Pro Se
Billing File

Stan
LOCAL,
Caterbone
STATE,
FEDERAL
& FEDERAL
COURT
COURT
DOCKETS
DOCKDETS Page
DOCKETS
171
499
811
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CATERBONE v. The United States, et.al., - A CIVIL RIGHTS COMPLAINT


Case law involving the following will be cited:
1. Federal Sovereign Immunity
2. The Pennsylvania Castle Doctrine
3. U.S. Intellectual Property Law
4. RICO - Racketeer Influenced and Corrupt Organizations Act
5. United States Bill of Rights
6. American Disabilities Act, or ADA
7. Pennsylavnia Mental Health Procedures Act
8. 18 U.S. Code 249 - Hate crime acts
9. COINTELPRO - Case Law The Assassination of Fred Hampton, by Flint Taylor
Attorney, 7th Circuit Decision, December 5, 2016
10. The Legal Prohibition Against Torture -

The prohibition against torture is firmly

embedded in customary international law, international treaties signed by the United


States, and in U.S. law. As the U.S. Department of State has noted, the "United
States has long been a vigorous supporter of the international fight against torture
Every unit of government at every level within the United States is committed, by law
as well as by policy, to the protection of the individual's life, liberty and physical
integrity" [U.S. Department of State, "Initial Report of the United States of America to
the UN Committee Against Torture." Oct 15, 1999. (15 Nov. 2001)]. That commitment
should not be abandoned. Indeed, it must be deepened as the world watches how the
U.S. responds to the challenges before it. If the U.S. were to condone torture by
government officials or foreign governments in its fight against terrorism, it would
betray its own principles, laws, and international treaty obligations. It would irreparably
weaken its standing to oppose torture elsewhere in the world. And it would provide a
handy excuse to other governments to use torture to pursue their own national
security objectives (The Legal Prohibition Against Torture
https://www.hrw.org/news/2003/03/11/legal-prohibition-against-torture ).

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SUMMARY OF COMPLAINT
On May 11, 2016 the article Court rejects man's claim that Lancaster County's
residents are torturing him with mind controlBy Matt Miller of Pennlive.com, reported the
following:
Rest easy, residents of Lancaster County. The state Superior Court says Stanley
Caterbone can't sue you for stalking him and messing with his mind (They did not
dispute the allegation). A panel of that court deep-sixed Carterbone's case in an opinion Judge
Paula Francisco Ott issued Tuesday. Quite frankly, Ott wrote, Caterbone gave the state judges no
firm explanation of what he was claiming or what sort of remedy he was after. Her court's ruling
upholds an August 2015 decision by county Judge Jeffery D. Wright to dismiss Caterbone's
lawsuit as frivolous. According to Ott, Caterbone, acting as his own lawyer, filed the case in
county court against the "residents of the county of Lancaster, Pennsylvania," seeking an order to
halt abuse he claims he was suffering at their hands. The Lancaster man accused countians of
participating in "organized stalking and/or electronic and mind manipulation torture being
committed against him," Ott noted. Also, she wrote, Caterbone asked the county judge to enlist
the local news media in a campaign to inform countians (Lancaster) to stop mistreating him.
Since that article the "organized stalking and/or electronic and mind manipulation torture
being committed against him (Stan J. Caterbone)," has escalated in a fevered pitch that can
only elicit one outcome if left without countermeasures murder, suicide, and or a prolonged
deep psychosis.
After the collection of authentic transcripts from other Targeted Individuals, including NSA
Whistleblower Karen Stewart, U.S. Army Intelligence Officer Julianne McKinney, and expert,
advocate, and world renowned lecturer Dr. Nick Begich, Stan J. Caterbone is now prepared to file
the complaint. In 2009 President Barach Obama, Robert Gates (former Secretary of Defense and
former Director of the CIA and the National Security Agency or NSA), and countless others, were
all named in a similar complaint in the Lancaster County Court of Common Pleas, case no. CI-0813373, CATERBONE v. the Duke Street Business Center, et.al.,. That case is still listed as
OPEN in the Lancaster County Prothonotary Office.

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HISTORY AND BACKGROUND


INTRODUCTION
The following is from the Stan J. Caterbone and Advanced Media Group Executive
Summary of 2009 ______________________________________________
[Ya know what, I am beginning to analyze this War on Terror and am having difficulty
understanding it all. To me the most effective fundamental fight against Extreme Terrorism is to
reduce the motive; or the Hatred Against America. No one seems to talk about that subject. How
do we reduce that Hatred Towards America and the West?
See, from my perspective, my situation is very disturbing. I mean we have the United
States Torturing Me, a U.S. Citizen for no good or valid reason. I have warned EVERYONE about
using my situation to feed this HATRED towards America.
Low and behold a week or so ago I have had several Muslims sign up as Followers to my
www.scribd.com/amgroup01 online webspace, which I use to post documents. The following
being the most prominent IKWAN Scope, "The Largest Muslim Brotherhood's Scope on the Web":
http://ikhwanscope.net/main/
There have also been several Muslim individuals who signed up as followers around the
same time, a week or so ago. They have also signed up as followers on my
www.twitter.com/StanCaterbone webspace.
You must understand, I am a VERY Patriotic Person and live a very patriotic life - I
believe in the U.S. Constitution and Our Founding Father's vision for America; I support
Our Military and our Troops; I believe in the Rule of Law; I am a Practicing Catholic,
and have been my whole life; I Believe in the TRUTH; I believe in Right v. Wrong; Good
v. Evil; and finally I believe in God. What do you believe in? ]
__________________________________

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HISTORY OF COMPLAINT
In 1987 Stan J. Caterbone went public with allegations of fraud within International Signal
and Control, or ISC as they were commonly referred.

After discussions with ISC and United

Chem Con officials (an ISC/James Guerin straw company), and as a shareholder of record since
1983 of ISC, Stan J. Caterbone had a meeting with an ISC executive on June 23, 1987, which
resulted in a 22 year legal odyssey. The discussions involved a joint venture with his company,
Financial Management Group, Ltd., or FMG, Ltd., but ended in disclosure of his recent public
allegations of fraud. Four years later, ISC founder and chairman James Guerin, and other officials
and companies pleaded guilty to a $1 Billion Dollar Fraud and export violations including the
selling of arms through South Africa to Iraq and Sadaam Hussein.

However, money, power,

influence and public corruption had been used to cover-up the activities and Federal False Claims
Act violations of Stan J. Caterbone for the next eighteen years. There ensued a total blockade of
all United States Courts for all redress and remedy available in accordance with federal, state,
and local laws. This included recovery of his business interests; intellectual property; real estate;
personal and business real property; his unblemished and impressive reputation; and his most
valuable asset - the ability to produce income. This might be legally referred to as the Right-ToWork under federal statutes.

Notwithstanding, Stan J. Caterbone has never made a bad

investment or developed a business that did not make a profit over the next 22 years.

This

includes two real estate properties that were illegally seized through foreclosure proceedings.
Since 1987 Stan J. Caterbone has been a prisoner and enemy of the state.

ISC was a

Department of Defense (DOD) Contractor and a partner with United States Intelligence Agencies
since it's beginings in the early 1970's. One of it's first contracts was Project X with the National
Security Agency or NSA of Ft. Meade, Maryland.
In summary, the following are facts and part of the public record regarding
INTERNATIONAL SIGNAL & CONTROL OR ISC:

Once the third (3rd) largest employer in the County of Lancaster,


Pennsylvania, with over 5,000 employees.
James Guerin, founder and CEO was once the largest philanthropist to
charitable organizations in the County of Lancaster, Pennsylvania.
The ISC/Ferranti Scandal was the third (3) largest white-collar fraud within the
United States as of 1992.
The following are some of the public officials and politicians associated with ISC:
George H.W. Bush, former U.S. President, and Director of the Central
Intelligence Agency (CIA).
Robert Gates, former Director of the Central Intelligence Agency (CIA) and
current Secretary of Defense.
Bobby Ray Inman, former Board of Directors if ISC, former Director of the NSA,
and currently associated and directly involved with Mind Control Research
organizations.
Alexander Haig, former U.S. Secretary of State, and ISC lobbyist and Board of
Directors?

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Joseph McDade, former Pennsylvania House of Representative and Chair of the


Appropriations Committee who was later investigated for the United Chem Con
scandal.
Carlos Cardoen/Cardoen Industries, a joint venture partner with ISC and arms
merchant for the cluster bomb who eventually sold to Iraq and other Middle Eastern
Countries under U.S. sanctions.
ISC was credited with the design of the cluster bomb, and has patents filed in the
U.S. Patent Office.
In 1987 ISC completed the merger with the 3rd largest defense contractor of
Great Britain, Ferranti International; who paid $1 billion dollars for ISC and all of
it's subsidiaries.
ABC News/Financial Times aired 3 episodes on ABC Nightline with Ted Koppel
regarding the ISC/CIA defense weapons; technologies; and cluster bombs to Iraq
story and lead into the allegations that then nominee for the Director of CIA Robert
Gates was involved with ISC and the selling of arms to Iraq.
ABC News 20/20 aired a story on the ISC/CIA efforts to sell cluster bombs to
Saadam Hussein and Iraq on February 1, 1991 days after the start of the Persian
Gulf War I, with the initial bombing raid destroying a cluster bomb factory built in
Iraq by Carlos Cardoen.
On July 1st and 2nd of 1987 Stan J. Caterbone solicited the legal counsel of
Lancaster Attorney Joseph Roda for counsel regarding, FMG, Ltd., International
Signal & Control (ISC); Commonwealth Bank, etc., and was billed for his services.
Joseph Roda did absolutely nothing but refute Stan J. Caterbone's claims and would
not believe him.
In Clark v. Guerin (CI-1990-0074 Lancaster County Court of Common Pleas),
Lancaster Attorney Joseph Roda represented William Clark, ISC's in-house legal
counsel, and never mentioned any conflict to Stan J. Caterbone in 1987.
In Clark v. Guerin (CI-1990-0074 Lancaster County Court of Common Pleas),
James Guerin deposited $1.75 million dollars into an escrow account at Fulton
Bank, Lancaster, County.

In Clark v. Guerin (CI-1990-0074 Lancaster County Court of Common Pleas),


Christopher Underhill of Harman, Underhill & Brubaker, represented James
Guerin. In 2005 Christopher Underhill represented the Manheim Township Police
Department (05-cv-2288 U.S. District Court for the Eastern District of
Pennsylvania) CATERBONE v. Lancaster County Prison, et. al.,.
In Clark v. Guerin (CI-1990-0074 Lancaster County Court of Common Pleas),
Philadelphia Attorney Joseph Tate represented James Guerin and ISC, and in 2007
Joseph Tate represented Scooter Libby during his federal prosecution by U.S.
Special Prosecutor Fitzpatrick.
In 2015 Stan J. Caterbone and Advanced Media Group had to again return to local,
state, and federal courts. Again the obstruction of due process, the local gang stalking, torture,
trespass, thefts, and the like began in earnest.

From the fabricated Petition for Involuntary

Psychiatric Commitment of April 2010 by Detective Clark Bearinger, until January of 2015, Stan J.
Caterbone and Advanced Media Group had been in seclusion and in a state of rehabilitation and
rest due to the forced medication by Fairmount Behavioral Hospital and Dr. Silvia Gratz.

The

psychotropic drugs reduce your motor skills and put you in an extreme state of confusion.

By

the

the

end

of

the

summer

of

2010

every

social

media

site,

including

www.amgglobalentertainmentgroup.com website was taken off-line due to the intimidation and


coercion by Detective Clark Bearinger.
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In May Stan J. Caterbone had again endured the Attacks and Torture from the
employees of the Lancaster County Courthouse, and the Lancaster County Government Building.
Then soon after the Residents of Lancaster County engaged in a massive Organized Stalking
Campaign. In addition an extreme Computer Hacking Campaign was initiated and executed in
an effort to again SILENCE Stan J. Caterbone and Advanced Media Group.

And Again, the

Lancaster City Police Department took the lead role. As usual Stan J. Caterbone summoned state
and federal authorities for help and assistance, including direct communications with the White
House, the Federal Bureau of Investigation, the Pennsylvania Attorney General's Office and
Kathleen Kane, The Pennsylvania State Police, the Pennsylvania General Assembly, several U.S.
Congressmen, and of course the Lancaster County District Attorney's Office.

Since August 1,

2015 the Geek Squad had performed diagnostics and repairs six (6) times due to computer
hacking. On at least 2 occasions the entire hard drive had to be wiped clean and restored.
On June 23, 2015 Stan J. Caterbone was named MOVANT in the 2014 Habeus
Corpus Petition by Lisa Michelle Lambert, Case No. 14:02559 in the U.S. District Court
for the Eastern District of Pennsylvania after filing an Amicus on the case. Judge Paul
Diamond was presiding since it's filing in 2014. However, the Petition was not able to
be granted and the case was stalled on jurisdictional law based on new and compelling
evidence, or lack there of.

The Amicus was filed to cure that deficiency with direct

witness corroboration to the Prosecutorial Misconduct and Innocence of Lisa Michelle


Lambert.

In fact a working theory was filed that suggested that the East Lampeter

Police Department engaged in a strategy of Entrapment that lead to the unfortunate


murder in 1991. This, would of course, allow a wrongful death claim to be filed by the
Show family. The case is now before the Third Circuit Court of Appeals, Case No. 153400. There are three (3) questions that the Third Circuit may rule on; whether to free
Lisa Michelle Lambert, or grant her her Habeus Corpus, and whether to grant Summary
Judgment to Stan J. Caterbone in all civil actions in both state and federal courts.
Two weeks later, on July 9, 2015, Detective Clark Bearinger filed another fabricated
Petition for Involuntary Psychiatric Commitment. And again Stan J. Caterbone endured 7 days in
the Fairmount Behavioral Hospital in Philadelphia.

However, this time there was

no

MANDATORY Treatment Program Ordered by the Lancaster County Court of Common Pleas.
So Stan J. Caterbone continued filing in the courts for assistance and resolution. In August, in a
desperate attempt to stop the local torture campaign, another Emergency Injunction was filed in
the Lancaster County Court of Common Pleas. On August 6, 2015 Stan J. Caterbone went so far
as to undertake a Professional Polygraph Test administered by Bonnie Lee of Polygraph Solutions
of West Chester, Pennsylvania. The test ended up being 4 grueling hours of torture and a scam
of $600.00.
On July 9th , 2015 a Private Criminal Complaint was filed against Detective Clark Bearinger,
Officer Williams, Officer Binderup, and 2 unidentified patrolman.

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The Complaint contained

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allegations of torture and abuse at every moment of contact.

The Lancaster City Police

Department were so desperate for retaliation from the Amicus filing in the Lisa Michelle Lambert
case, that they actually broke the door in of 1250 Fremont Street in order to execute the
fabricated 302 petition. The Complaint was denied by the Lancaster County District Attorney on
August 8th . The Complaint is now under a Petition for Review by the Lancaster County Court of
Common Pleas.
On August 17, 2015 another Emergency Injunction for Relief was filed in the Lancaster
County Court of Common Pleas, Case No. 15-06985. The Injunction was heard by Judge Jeffrey
Wright, who dismissed it as frivolous. An appeal, MD 1561, is pending in the Superior Court of
Pennsylvania.
In addition, by September 26, 2015 Stan J. Caterbone had been granted Electronic Filing
Privileges in the local, state, and federal courts. This should alleviate the fraud and abuses of the
U.S. Postal Service and the computer hackers.
In 2015 Stan J. Caterbone identifies a trend that suggests that the Lancaster County
community-at-large was subject to either community targeting or community hypnosis.

The

community targeting theory is supported by experts Jullianne McKinney, Cheryl Welsh, and Dr.
John Hall. The community hypnosis theory is supported by direct personal relationships with the
Amazing Kreskin, Samuel P. Caterbone and Stan J. Caterbone.
In September of 2015 Stan J. Caterbone begins to digitize a library of approximately 45
audio cassette tapes from his father, Samuel P. Caterbone. The tapes range in date from 1971 to
1996. The tapes prove an identical targeting campaign against both Samuel P. Caterbone and
Stan J. Caterbone. In addition the tapes confirm that Steven P. Caterbone, brother of Stan J.
Caterbone, was most likely a target dating back to the early 1960's. In addition, the death of
Samuel P. Caterbone on July 20, 2001 was confirmed to be that of murder, not natural causes.
In the early 1990's Dr. Phillip Caterbone, brother, had been solicited by the National
Institute of Health, or NIH in Washington, D.C., for a fellowship to research and catalog a study to
find a genetic marker for depression in the CATERBONE family.

Phil interviewed all living

descendants and relatives of my father, Samuel P. Caterbone, Jr., and took blood samples. I am
alleging that this was a deliberate act to continue the cover story of mental illness to distract and
provide plausible deniability for any linkage to U.S. Sponsored Mind Control.
THE MANIFEST OF A COVER-UP
Not only did the allegations of fraud within ISC have to be silenced at a time when merger
negotiations were ongoing with Ferranti, but all of the fraud; extortion; public corruption;
burglaries; civil rights violations; anti-trust and intellectual property right violations; lender
liability torts; false arrests; false imprisonments; as well as other civil and criminal activities had
to be covered up and buried in bureaucratic red tape.
uncovered and discovered to this day.

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Information and findings are still being

Contrary to popular belief, up until 1996 a grand jury

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investigation into ISC was still ongoing. It is not known whether it has closed or not. All of these
activates constitute a RICO crime due to the pattern and organization of the perpetrators. The
pattern and source of the activities can be traced back to 1987, with subgroups changing over
time, but still engaging in the same practices. The following plan of action was followed in order
to perpetrate the cover-up:

Totally discredit Stanley J. Caterbone and any and all allegations in every way
possible.

Fabricate a history of mental illness.


Fabricate a criminal record.
Attach his character and honesty with rumors and propaganda.
Extort and maintain his net worth to $ zero or load him with debts.
Keep him out of any profession and or occupation when and where possible.
Totally isolate him and disenfranchise him from his friends, colleagues, and family.
Somehow persuade the community of Lancaster County to buy into this plan
Use bribery with sex, drugs, influence, career promotion, favors, etc.,
Always prohibit attorneys and anyone remotely involved with the legal community.
When attempts to enter the U.S. legal system arise, isolate, harass, and extort
any monies and/or possessions of value.
Change the history of events and the truth.
THE COURTS AND THE UNITED STATES LEGAL SYSTEM
For 18 years, (from 1987 until 2005) it has always been fairly easy to keep these issues
from court dockets and judges.

During these years Stan J. Caterbone had solicited at least

twenty attorneys, some from large firms with national recognition in their respective fields of
specialties. Attorneys from New York City to Santa Barbara and San Diego California were visited
and consulted as well as a group of ex FBI agents who specialized in white collar crime that are
now globally recognized. However, the money and influence of persons and entities that wanted
these issues silence always prevailed. The issues were so complex and convoluted, and involved
such high profile politicians and U.S. agencies, it was far easier to state that there was no case, or
their were no claims that would result in remedy or redress. Between the Republican Party and
the Department of Defense, the CIA and the NSA, there was not an attorney that could not be
influenced. The obstruction of justice and due process in this case is most likely unprecedented in
nature and in malice.

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However in 2005 that all changed when Stan J. Caterbone appeared as a pro se litigant
representing himself, without any counsel, in the United States District Court for the Eastern
District of Pennsylvania in CATERBONE v. The Lancaster County Prison, et. al., or case no. 05-cv2288.

This case is still not settled and has been withdrawn by plaintiff Stan J.

Caterbone in October of 2008 after a successful ruling in the U.S. Third Circuit Court of
Appeals (07-4474) in September of 2008. The case will be continued upon the security
of evidence and the cease and desist of obstruction of justice and due process. On May
16, 2005 at the Federal Courthouse in Philadelphia, Stan J. Caterbone filed the case under seal.
One week later in the United States Bankruptcy Court for Eastern Pennsylvania in Reading,
Pennsylvania, again appearing as pro se, Stan J. Caterbone filed a petition for protection under
the Chapter 11 Bankruptcy Code, in case no. 05-23059.
These acts of entering the United States legal system with these issues triggered yet
another round of attempts to keep these cases from the courts and judges - Organized Stalking
with Directed Energy Devices and Weapons, built on a foundation of mental telepathy or total
Mind Control.
REMOTE VIEWING; ORGANIZED STALKING; DIRECTED ENERGY DEVICES AND
WEAPONS.
Organized stalking and harassment began in 1987 following the public allegations of fraud
within ISC. This organized stalking and harassment was enough to drive an ordinary person to
suicide. As far back as the late 1980's Stan J. Caterbone knew that his mind was being read, or
"remotely viewed". This was verified and confirmed when information only known to him, and
never written, spoken, or typed, was repeated by others. In 1998, while soliciting the counsel of
Philadelphia attorney Christina Rainville, (Rainville represented Lisa Michelle Lambert in the Laurie
Show murder case), someone introduced the term remote viewing through an email. That was
the last time it was an issue until 2005. The term was researched, but that was the extent of the
topic.

Remote Viewers may have attempted to connect in a more direct and continuous way

without success.
In 2005 the U.S. sponsored mind control turned into an all-out assault of mental
telepathy; synthetic telepathy; and pain and torture through the use of directed energy devices
and weapons that usually fire a low frequency electromagnetic energy at the targeted victim.
This assault was no coincidence in that it began simultaneously with the filing of the federal action
in U.S. District Court, or CATERBONE v. Lancaster County Prison, et. al., or 05-cv-2288.

This

assault began after the handlers remotely trained Stan J. Caterbone with mental telepathy. The
main difference opposed to most other victims of this technology is that Stan J. Caterbone is
connected 24/7 with a person who declares that she is Interscope recording artist Sheryl Crow of
Kennett Missouri. Stan J. Caterbone has spent 3 years trying to validate and confirm this person

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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.

See attached documents for

more information.
In 2006 or the beginning of 2007 Stan J. Caterbone began his extensive research into
mental telepathy; mind control technologies; remote viewing; and the CIA mind control program
labeled MK ULTRA and it's subprograms.
FAMILY HISTORY
If you listen to the propaganda machine and the community of Lancaster County,
Pennsylvania, including professionals, the family history of Stan J. Caterbone goes something like
the following:
Father, Samuel Caterbone, Jr., Schizophrenic who ran out on his family
because of nervous breakdowns while trying to run a small dry cleaning business.
He traveled the world looking for the Blessed Mother Mary and Space Aliens. He
ended up living in government subsidized housing broke and with a severe mental
illness.
Brother, Samuel A. Caterbone, suffered from the very same illness has his
father, Schizophrenia, who finally killed himself trying to live in California.
Brother, Thomas W. Caterbone, suffered from the very same mental illness as
his brother, Stan J., Bipolar Mood Disorder, who ran a lawn business and finally
committed suicide at an early age.
Stan J. Caterbone, suffered from Bipolar Mood Disorder, or Manic Depression and
had a nervous breakdown in 1987 trying to compete in the financial services
industry.

When he has his nervous breakdowns, he always threatens to sue

everyone in court and is deeply paranoid in thinking the whole world is against him.
He always spends all of his money during his fits of mania and has delusions about
his success as a businessman.
The Family History was formulated back in the 1960's when Samuel Caterbone, Jr.,
father of Stan J. Caterbone, became engaged in a black budget mind control program that began
during his service in the United States Navy as a radioman and air gunner.

Samuel Caterbone,

Jr., was most likely a direct product of MK ULTRA or one of it's subprograms. His brother, Samuel
A. Caterbone, was most likely part of the LSD experiments of MK ULTRA. Stan J. Caterbone is
most likely part of a program sponsored by the Department of Defense Agencies, such as DARPA
or the Defense Intelligence Agency (DIA). The facts of Stan J. Caterbone's intimate discussions
with both his father and brother over the years before they died, the totality of documents that
were preserved in their estate, including service records; letters; official court papers; high school
documents; and the like - all will prove that they were in fact part of MK ULTRA or one of it's
subprograms. The following are the facts and the real record of the family history:

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Samuel P. Caterbone, Jr., (Father) served in the Navy from 1943 to 1946 and
graduated with honors from Air Gunners School in Jacksonville, Florida. He was an exceptional
student/athlete while attending Lancaster Catholic High School, participating in the band as well
as sports. He was also his senior class secretary/treasurer. After the Navy, he went on to build a
successful dry cleaning business, which he is credited with inventing a filtration system for the
solvents.

He also developed a very good investment in real estate along the Manheim Pike,

owning several properties. By his own writings and from his personal accounts to me, he was
definitely a remote viewer or data miner for some U.S. Agency with telepathic abilities.

His

viewing is documented to have begun back in the early 1970's. He also suffered from organized
stalking, and was considered an enemy and prisoner of the state. Back in the 1960's, he was a
world traveler, this is documented by his passports. Samuel P. Caterbone, Jr., may have been a
covert carrier for someone in intelligence.

Samuel P. Caterbone, Jr., had his mental health

history laced with electro shock therapy.

Electro Shock Therapy Experiments is another

subprogram of MK ULTRA. In addition, and especially disturbing is his criminal record with the
Lancaster City Police Department and the Lancaster County Court of Common Pleas.

In 1973

Samuel P. Caterbone, Jr. was convicted of forging a 2 checks from the Caterbone Cleaners, Inc.,
checking account. The one check to Joe the Motorists Store at the Manor Shopping Center was
never entered into evidence, it was for a total of $70.00.

The other check was made out to

Lancaster Attorney James Coho for $200.00 with "divorce proceedings" written in the memo. This
was his only criminal record. Samuel P. Caterbone, Jr., was sentenced to one year probation by
President Judge William Johnstone.

However, on August 29, 1973 after nine months, Judge

Johnstone wrote an ORDER releasing him from probation and ordering him to "leave the vicinity
of the County of Lancaster, Pennsylvania".

The President Judge of Lancaster County Court of

Common Pleas literally threw my father out of Lancaster County for forging 2 checks from his own
corporation.
In 1987 I was arrested for stealing my own files from my own company, Financial
Management Group, Ltd., You can research the life of Candy Jones and Kate O'Brien to learn
more on this topic. Samuel Caterbone, Jr., has left enough writings and documentation to know
that his life fits the model for targeted individuals, complete with economic ruin, isolation,
disenfranchised from family and friends, and of course a fabricated mental illness history. You
can view most of his record online. On or about May 18, 2001 Samuel P. Caterbone Jr., finally
received an inheritance from his mother's (Mary Caterbone) estate.

The check was for some

$70,000.00. The estate was probated in November of 2000. Some two weeks later, on Memorial
Day Weekend of 2001, he had called me to come to New York City to help care for him. He was
in perfect health until this time. In a matter of six (6) weeks he had succumbed to lung cancer.
As per Julianne McKinney, former intelligence officer for the U.S. Army and victim activist of U.S.
Sponsored Mind Control, the weapons are lethal enough to kill and the one thing that I worry

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about is that of dying of cancer (paraphrase). There is no doubt now that my father's death was
a murder, not natural.
Samuel A. Caterbone, (Brother) served in the United States Air Force in 1968 to 1970.
In 1991, Stan J. Caterbone accused the United States Government of using his brother, Samuel
A. Caterbone for part of the LSD experiments on mind control, or MK ULTRA. A notarized letter of
October 23, 1991 was sent certified mail to the California Attorney General on the subject matter,
with a return letter from the California Attorney General on January 14, 1992.

By his own

admission before his death, Samuel A. Caterbone disclosed to Stan J. Caterbone of the "bad LSD"
trips while in the Air Force. Since his death of December 25, 1984, Stan J. Caterbone and others
questioned the classification of suicide, and made allegations of foul play that was ultimately
responsible for his death. Finally in a meeting in Santa Barbara, California with the Santa Barbara
Public Guardian's Office, an office admitted that the death was more likely due to foul plan than
suicide.

Samuel A. Caterbone was also an exceptional student and athlete while attending

Lancaster Catholic High School.

After playing varsity football as a sophomore, he had an

unfortunate accident while deer hunting the following November.

While in the woods in

Bellefonte, Pennsylvania, his hunting pants caught fire trying to stay warm.

It left him in the

Lancaster General Hospital for months, going through painful skin grafts and isolation.
hunting accident interrupted his athletic career and scared his legs for life.

The

The Schizophrenia

diagnosis was a combination of LSD flashbacks and organized stalking and harassment.
Thomas P. Caterbone, (Brother) had an unfortunate transaction at Fulton Bank that set
a course of action that resulted in a suicide. Although diagnosed with Bipolar Disease and Manic
Depression -- embezzled and extorted monies were most likely the reason for his suicide in 1996.
Fulton Bank was involved in a fraud that took $72,000 from a real estate settlement closing and
lead to his total financial ruin and collapse in June of 1995. The funds were never recovered and
Fulton Bank is a defendant for a wrongful death claim in the United States District Court for the
Eastern District of Pennsylvania in CATERBONE v. Lancaster County Prison, et. al., 05-cv-2288.
FULTON BANK triggered a severe and lethal death blow to Thomas P. Caterbone, and as of this
day has refused to acknowledge any wrongdoing or remorse. Thomas P. Caterbone was also an
exceptional athlete. Playing for Lancaster Catholic High School, Franklin and Marshall College, the
Harrisburg Patriots, and even the Philadelphia Eagles.

Tom also coached football at J.P.

McCaskey and Franklin and Marshall College. Thomas P. Caterbone had a very successful lawn
and landscaping business before joining forces with John DePatto of United Financial Services and
selling residential mortgages.

John DePatto was the former head of Parent Bank, owned by

James Guerin and ISC. Parent Bank, owned by ISC also foreclosed on 2323 New Danville Pike,
Conestoga, Pennsylvania in 1988, which was owned by Stan J. Caterbone. Thousands of dollars
of equity was extorted in the process, despite still being short sold for a profit to Mr. Keith
Kirchner, an executive of Lancaster Newspapers and former graduate of Lancaster Catholic High
School.

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Stan J. Caterbone is a remote viewer (at least one way in), is telepathic, and a
federal whistleblower with an exceptional entrepreneurial record in spite of all of his adversaries
and their assaults. In spite of the U.S. Sponsored mind control and torture, he has endured and
will prevail. Legally, Stan J. Caterbone has been able to preserve his claims, and progress his
legal challenges and claims through both the federal and state court system appearing pro se,
without the aid or expense of additional legal counsel. Some of his claims and briefs will most
likely be landmark decisions in years to come. Stan J. Caterbone was a 2-Sport MVP at Lancaster
Catholic High School, in both football and track. Stan J. Caterbone never received less than a B
grade in his four years of high school and had an 87+ average. Stan J. Caterbone excelled in
computer technologies, taking his first full term course in 1975, while in high school and
continuing into college at Millersville University, graduating with a degree in business
administration in 1980.

Stan J. Caterbone excelled profoundly at building his companies, first

beginning with Financial Management Group, Ltd., then working with Tony Bongiovi of Power
Station Studios and the "Digital Movie"; then building Advanced Media Group, Ltd..

Over the

years, despite the illegal seizures and foreclosures, Stan J. Caterbone has amassed a portfolio of
impressive real estate deals that have always paid off in profits, no matter how or when they
were sold.

The same was true of his businesses.

Financial Management Group, Ltd., was a

$20,000 dollar investment in 1986 and was still sold for approximately $100,000 two years later,
despite the false arrests and the extortion of most of it's real value and equity.
The mental health history and the criminal records were completely fabricated, and a
close review and investigation into the actual court records and hospital records can prove that in
very short fashion.

There are TWO (2) ways to quickly dispute the Mental Health History and

Record:
One - Review the word "Delusional; delusions; etc.,;

every instance of the word

used by mental health professionals, and the false reports by friends and family were associated
with facts, and matters of the official record, the complete opposite of the meaning of the word
"delusional". And they still exist to this very day.
Two - Review the 3 Fabricated Suicide Allegations of the following dates: August
10(?), 1987 at Burdette Tomlin Hospital (Cape May County New Jersey); February 18th(?), 2005
by Kerry Egan and the Southern Regional Police Department; and July 19, 2009 for the 302
Commitment by the Lancaster City Police Department at Lancaster General Hospital.
The Criminal Record is very similar, since 1987 Stanley J. Caterbone has had 31 false
arrests; formal charges and convictions dismissed prior to court proceedings or won on summary
appeals in the County of Lancaster, Pennsylvania; most of which Stan J. Caterbone appearing as
pro se (representing himself). These have resulted in civil complaints filed in 2008 in CATERBONE
v. The County of Lancaster, Pennsylvania in U.S. District Court for the Eastern District of
Pennsylvania.

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THE PUBLIC RECORD


The Public Record is comprised of court filings and exhibits in U.S. Federal Courts;
Pennsylvania State Courts; and the Lancaster County Court of Common Pleas.

In all some

40,000 pages of documents are now filed and electronically scanned or microfilmed in
prothonotary offices. In addition in both the U.S. Federal Courts and the Lancaster County Court
of Common Pleas there are more than 11 hours of audio recordings; some 3,000 scanned
images; and several video broadcasts of the ISC News broadcasts all stored on a CD-ROM and
filed as an exhibit to some of the law suits filed by Stan J. Caterbone and Advanced Media Group,
as plaintiffs. Stan J. Caterbone has over 100 court docket sheet numbers in federal, state, and
local courts.
There are also Pennsylvania Unemployment Compensation records; Department of Welfare
and Lancaster County Assistance Office records; Local Real Estate Tax records; Lancaster County
Tax Assessment records; Social Security Administration Benefits records; Lancaster Catholic High
School transcripts; Millersville University transcripts; all for Stan J. Caterbone, in addition to his
court filings.
For Samuel A. Caterbone, my brother, there are United States Air Force service
records; Lancaster Catholic High School transcripts; Millersville University transcripts; Social
Security Administration records; Santa Barbara County Guardian and Public Defender records;
and papers and documents persevered from his estate.
For Samuel P. Caterbone, my father, there are United States Naval records,
Lancaster Catholic High School transcripts; Social Security Administration records; Lancaster
County Assistance Office records; Local Real Estate Tax records; Lancaster County Tax
Assessment records; Samuel Caterbone Cleaners, Inc., corporate records; Real Estate Deeds and
Mortgages; Lancaster County Court of Common Pleas civil and criminal records; and of course
papers and documents persevered from his estate
** It is important to note that as of this writing, Remote Viewing has recently
been commercialized by corporate America, and certain Fortune 500 companies are
using Remote Viewers as consultants for trend analysis and market forecasts. This is
often the evolution of most technologies born out of the U.S. Department of Defense.
Top Secret experiments and the resulting technological advancements can stay
secretive for so long.

This has recently been used in a NBC story of the Television

drama "Medium" this last season.

On July 9, 2008 I had recorded an AM radio live

broadcast on WHAN Coast to Coast with a guest that was one of the leading Physicist
turned Remote Viewer and expert that testified to this same notion.

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Is County of Lancaster, Pennsylvania Ground Zero for Organized Stalking and Covert
Surveillance?
I believe that they try new models for harassment; organized stalking and surveillance on
me here in Lancaster. Remember, Lancaster is now one of the most "Watched Communities" in
the country. "With those cameras, the Safety Coalition will operate and monitor 165 cameras
across Lancaster City making Lancaster the most watched city of its size in the nation." See
article attached, Watching you: City to add 105 more cameras.
I believe that Lancaster may be ground zero for some of the models of organized stalking
and harassment that we TI's experience and wanted to get some reaction from Lancaster. Some
history on the Lancaster Convention Center. Dale High of High Industries is the lead partner in
our new convention center/hotel. It is first class all the way. Now in the late 1980's I was a joint
venture partner with Dale High in American Helix Technology Company/Advanced Media Group.
American Helix was a cd manufacturer and I and my company Advanced Media Group was the
CD-ROM division of American Helix. I was one of a handful of CD-ROM manufacturers in the
domestic United States back then. Also in 2005 I filed a civil action against the lead hotel, the
Eden Resort Inn, for trying to block the development and building of the Hotel/Convention Center,
see

attached.
Now, some history about Lancaster and the intelligence community. Back in the 1980's

there were several defense contractors located in Lancaster, the main being International Signal
& Control, which I, of course, blew the whistle on a billion dollar fraud and arms to Iraq.
Click here for an overview of ISC.
Click here to see the Lancaster Newspapers Archives regarding International Signal & Control, or
ISC.
Click here to view the live video of the WGAL-TV News Broadcast of October 31, 1991 the evening
of the ISC indictments. The U.S. Department of Justice and other U.S. Agencies held a Press
Conference in the Philadelphia Federal Courthouse to announce the indictments and $ Billion
Dollar Fraud.
Click here for Part 2 of the WGAL-TV 8 Broadcast.
Now politically, Lancaster is and has always been predominately Republican. Lancaster is one of
the oldest cities in the country and our courthouse was one of the first in this country. Lancaster
has one of the oldest fraternities of the Masons. Lancaster and the George W.Bush administration
has a close and very "interesting relationship". George H. Bush had a very close relationship with
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ISC, and of course the NSA and CIA all had a very "close" relationship with International Signal &
Control, or ISC. The following are some transcripts for Ted Koppel and ABC News Nightline
regarding ISC and Arms to Iraq and the intelligence community. The transcripts are contained in
my Amicus for Case No. 2006-cv-2160 filed in the Eastern District of Michigan, Southern Division.
Now, Robert Gates, presently the Secretary of the United States Defense Department, and
his relationship to Lancaster. First of all, the attached video is the authentic transcript of Robert
Gates' confirmation hearing in September of 1991 for the Director of the Central Intelligence
Agency (CIA). If you fast forward to approximately 9:00:00 you will see the back and forth
questions from Senator Murkowski to Robert Gates regarding the allegations by several members
of the U.S. Senate Select Committee on Intelligence regarding his alleged involvement with ISC
and the Arms deals with Carlos Cardoen and the shipping of cluster bombs through South Africa
and on to Iraq. Of course, he denied all of the allegations.
Robert Gates also has relatives that live in Lancaster County, if fact he attended a wedding here a
few months ago, on May 3, 2009 at St. John Neuman Catholic Church in Manhiem Township,
Lancaster County. His wife has a niece that lives in Manheim Township.
Now, I'll give you the ABC News Nightline May 23, 1991 excerpt regarding ISC and the
NSA, National Security Agency:
"It all started legally, if covertly, back in 1974. That's when the National Security Agency,
a super-secret U.S. Intelligence unit asked ISC to help complete project X, a chain of electronic
listening posts based at South Africa's Simonstown Naval Station. South Africa was using these
posts to follow Soviet submarine traffic off of the Cape of Good Hope. To ensure secrecy, ISC and
the NSA made sure shipments could not be tracked back to them. They created a company called
Gamma Systems Associates. In fact, this company was nothing more than a post office box at
John F. Kennedy Airport. Gamma was a cut-out. ... But this sanctioned covert operation was
stopped in 1977 when President Carter, a strong opponent of South Africa's apartheid regime,
told U.S. firms to stop any military-related business with Pretoria. But ISC continue shipping
electronics, some civilian, some military, to South Africa. The in the early 1980's, South Africa
began to intensify its efforts at ballistic missile development. For ISC, that was a golden
opportunity because on of its top executives was a man named Clyde Ivey, an American
electronics expert who has been the father of South Africa's missile program. Ivey had
extraordinary contacts in the nations defense structure. Begining in 1984, federal investigators
say, senior ISC exeutives, including Ivey, began regular contacts with CIA officials." You can read
the rest. The entire transcript of the May 23, 1991 ABC News/Nightline broadcast.

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Now remember, George H. Bush was director of CIA. "He served in this role for 357 days,
from January 30, 1976 to January 20, 1977.[22] The CIA had been rocked by a series of
revelations, including those based on investigations by Senator Frank Church's Committee
regarding illegal and unauthorized activities by the CIA, and Bush was credited with helping to
restore the agency's morale.[23] In his capacity as DCI, Bush gave national security briefings to
Jimmy Carter both as a Presidential candidate and as President-elect, and discussed the
possibility of remaining in that position in a Carter administration[24] but it was not to be,"
according

to

Wikipedia.

Now, lets get to Bobby Ray Inman, former Navy, Director of the National Security Agency
(NSA), former Director of International Signal & Control (ISC), and currently part of the Mind
Control industry. The following appears on the Welcome page of my website:
"S.A.I.C. involvement in 1993 American Para psychological Association meeting arrangements,
via their 'Cognitive Sciences Laboratory'. Science Applications International Corporation is a big
time defense contractor, has held the largest number of research contracts of any defense
contractor. Bobby Ray Inman (ISC Board of Directors) is on its board of directors, among others."
by John Porter, CIA Program on Mind Control copyright 1996. In 1994, after Bobby Ray Inman
requested to be withdrawn from consideration as Bill Clinton's first Defense Secretary, his critics
speculated that the decision was motivated by a desire to conceal his links to ISC. Inman was a
member of the so-called "shadow board" of the company which was allegedly either negligent or
approved the exports." by Wikipedia on International Signal and Control, (ISC).
Now, lets list the former Navy personnel:
George H. Bush, former President of the United States, former Director of CIA.
James Guerin, President and Founder of International Signal & Control.
Bobby Ray Inman, former Director of the National Security Agency (NSA) and Director of
International Signal & Control, (ISC).
My father, Samuel P. Cateronne, Jr.
His father, Samuel J. Caterbone, Sr.
George Noory, of Coast to Coast Radio (just anecdotal, nothing assumed or alleged).
George W. Bush flew with the Navy.
James Cross
TO BE COMPLETED IN AN AMENDED COMPLAINT

Next we get to Jim Guerin's attorney back in 1989 through at least 1992. His name was
Joseph Tate, of Philadelpha. This link will take you to a document regarding Joseph Tate, James

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Guerin and Joseph Roda, Esq., of Lancaster, my former attorney who said I fabricated everything
back in 1987. The document contains a letter of September 12, 2005 from Special Prosecutor
Patrick Fitzgerald regarding Scooter Libby, Former Vice President Dick Cheney's Chief of Staff.
the letter involves Scooter Libby's Grand Jury Indictment for leaking Covert CIA Operative Valerie
Plame and eventually outing her.
Now in Austin Texas in July of 2005 I was detained by 2 Agents from The Defense
Intelligence Agency.

I was merely visiting a Military Museum, that had old and vintage

helicopters and airplanes. near where my brother, Dr. Phillip Caterbone lived. I was visiting on
my way to California.

While inside the museum 2 Agents from the Department of Defense

Defense Intelligence Agency escorted me outside to my Honda Oddesey and interrogated me


making me confirm that I was visiting and staying with my brother. They caused a problem for
my brother's Medical Practice by shaking up one of his secretaries.

The reviewed my court

documents for CATERBONE v. Lancaster County Prison, et. al., Case No. 2005-cv-0288 filed in the
U.S. District Court for the Eastern District of Pennsylvania. The demanded that I stay off all
military bases before releasing me.
In 2006 I was telepathic with an older NSA executive on many occasions who wanted to
meet me at the Clipper Stadium who told me he wanted to rent a facility in Lancaster for a
training exercise. I told him to to and see Dale High and the High Group for space at the
Greenfield Industrial Park. He said he was retiring and that our discussions were keeping him a
few weeks longer than expected. We had intimate discussions of my history and the Chesapeake
Bay Area. We also discussed Sheryl Crow, and he told me his wife was a fan. I turned him on to
her new album, Wildflower, and he said she liked it. We had to disengage because he was being
harassed by other telepathic assailants.
My former secretary (Susan Bare) at Pflumm Contractors, Inc., where I was controller and
was hired to rescue the company from near bankruptcy in 1993, told me that her husband, Ross
Bare, who grew up just some 10 or so doors from me, worked for the NSA. She disclosed this
soon after I hired her in 1994 or 1995.

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II)

JURISDICTION:
1. Count I - 18 U.S.C. 1961 through 18 U.S.C.
2. Count II - 1968, RICO; 31 USCS
3. Count III - 3729-33 Federal False Claims Act;
4. Count IV - extortion,
5. Count V - defamation of character,
6. Count VI - slander,
7. Count VII - wrongful interference with business relations,
8. Count VIII - wrongful interference with contracts,
9. Count VIIII - breach of contract
10. Count X - a plea for an accounting;
11. Count XI - deceptive and fraudulent practices
12. Count XII - breach of fiduciary duty
13. Count XIII - unfair competition
14. Count XIIII - tortuous interference with business relationships
15. Count XV - unjust enrichment
16. Count XVI - a pattern of racketeering in violation of the Racketeering Influenced and
Corrupt Organizations Act (RICO), 18 U.S.C. 1961 et seq.
17. Count XVII - illegal retaliation
18. Count XVIII - unlawful discrimination
19. Count XVIIII - intentional infliction of emotional distress
20. Count XX - wrongful repossession
21. Count XXI trespass to person
22. Count XXII civil conspiracy
23. Count XXIII violation of due process
24. Count XXIIII conspiracy to commit fraud
25. Count XV loss of liberty
26. Count XVI false imprisonment
27. Count XVII false arrest
28. Count XVIII collusion
29. Count XVIIII false statements
30. Count XXX trespass to property
31. Count XXXI conversion
32. Count XXXII replevin
33. Count XXXIII - breach of contract arising out of the alleged repossession
34. Count XXIV assault
35. Count XXXV battery
36. Count XXXVI - malicious prosecution
37. Count XXXVII - malicious abuse of process claims arising out of the charges and arrest
38. Count XXXVIII mail fraud

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STATUTE OF LIMITATIONS
Legal Arguments and issues of the Statute of Limitations and Time Barred Causes of Actions that
support that justice has been denied and due process subverted thus granting relief to the
PLAINTIFFS:

a. (RICO), 18 U.S.C. 1961 et seq.; A claim may be barred by the statute of


limitations if you discovered or reasonably should have discovered your injury four
or more years ago.
b. Civil RICO claims are not subject to a statute of limitations. Congress failed to
include a statute of limitations when it passed the RICO Act, but the United States
Supreme Court has remedied that oversight and imposed a four-year statute of
limitations on all civil RICO claims.
c. Civil Rico's statute of limitations begins to run when the victim discovers or
reasonably should have discovered its injury. Once a victim is aware or should be
aware of its injury, the victim has four years to discover the remaining elements of
its claim and bring suit. A victim cannot sit on its rights and refrain from filing suit
in the face of known injuries.
d. There are several equitable doctrines that may toll or suspend the running
of the statute of limitations. If a defendant fraudulently conceals facts that
are essential to the victim's ability to purse its rights, the running of the
statute of limitations may be tolled.
e. Acts of duress, such as "if you sue me, I'll kill you," may toll the running of
the statute of limitations.
f.

All tolling doctrines are based upon whether it is fair, under the
circumstances, to bar the victim's claims on the basis of the running of the
statute of limitations.

g. If a defendant engages in a new pattern of racketing, that causes new and


independent injuries, a new limitations period may apply to those new and
independent injuries.

2. The Racketeer Influenced and Corrupt Organizations Act (commonly referred to


as RICO), 18 U.S.C. 1961 et seq.;: RICO is a United States federal law which provides for
extended penalties for criminal acts performed as part of an ongoing criminal organization.
RICO was enacted by section 901(a) of the Organized Crime Control Act of 1970, Pub. L.
No. 91-452, 84 Stat. 922 (Oct. 15, 1970). RICO is codified as Chapter 96 of Title 18 of the
United States Code, 18 U.S.C. 1961 through 18 U.S.C. 1968. RICO addresses longterm, not one-shot, criminal activity. Not only must a RICO claim be based upon criminal
activity, but the criminal acts must constitute a "pattern" of criminal activity.
a. A single criminal act, short-term criminal conduct, or criminal actions that bear no

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relationship to each other will not give rise to a RICO claim. The United States
Supreme Court has ruled that criminal actions constitute a "pattern" only if they are
related and continuous.
b. In order to be "related," the criminal acts must involve the same victims, have the
same methods of commission, involve the same participants, or be related in some
other fashion. A pattern may be sufficiently continuous if the criminal actions
occurred over a substantial period of time or posed a threat of indefinite duration.
c. The former patterns are referred to as closed-ended patterns; the latter patterns
are referred to as open-ended patterns.

d. Accordingly, even if you have been injured by a criminal act, you will not have a
RICO claim unless that criminal act is part of a larger pattern of criminal activity.

COINTELPRO CASE LAW - The Assassination of Fred Hampton: 47 Years Later, Sunday,
04 December 2016 00:00 By Flint Taylor, Truthout | News Analysis
On this very day, as the Army Corps of Engineers and police forces from Morton County
North Dakota and nine surrounding states gather their collective forces and fearsome weaponry in
an effort to evict the proud and peaceful Indigenous Water Protectors from their sacred land at
Standing Rock, and thousands of veterans gather to protect them from concussion grenades,
water hoses, rubber bullets and God knows what else, it is profoundly appropriate to reflect on
the courage and leadership of Chicago Black Panther leader Fred Hampton and revisit the sordid
history of his assassination at the hand of a conspiracy between local law enforcement and the
FBI 47 years ago.

On December 4, 1969, 47 years ago today, a select unit of Chicago police officers
executed a predawn raid that left Illinois Black Panther Party (BPP) leaders Fred Hampton and
Mark Clark dead and several other young Panthers wounded. The seven survivors of the raid were
arrested on fraudulent attempted murder charges. The officers who committed the execution
were specially assigned to Cook County State's Attorney Edward Hanrahan. The claims of a
"shootout" that were made by Hanrahan and his men were soon exposed as bald-faced lies: the
physical evidence definitively established that the raiders fired nearly 100 shots at the sleeping
Panthers, while only one shot could be linked to a Panther weapon.
However, as was painstakingly proved over the next eight years, the false official claim of a
violent confrontation was only one layer of a massive conspiracy that was also designed to cover
up the central role of the Federal Bureau of Investigation and its COINTELPRO program in the
murderous raid.
The headstone of slain Black Panther leader Fred Hampton in Haynesville, Louisiana, has
been riddled by a barrage of bullets from unidentified night riders. Flint Taylor -- one of the
lawyers for Hampton's family -- recently journeyed to Haynesville to eulogize Fred Hampton's
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mother, Iberia, a devoted mother and courageous activist who passed away in October 2016. He
discovered this desecration of Hampton's grave at that time. (Credit: Flint Taylor)
Just after the raid that killed Fred Hampton and Mark Clark, the Minister of Defense for the
Illinois Chapter of the Black Panther Party, Bobby Rush, declared that J. Edgar Hoover and the
FBI were responsible for the raid. However, at that time there was no hard proof. The first
documentation that supported Rush's claim came in 1971 when activists broke into an FBI office
in Media, Pennsylvania, and liberated a trove of FBI documents. These documents outlined the
FBI's super-secret and highly illegal COINTELPRO program and its focus in the 1960s on the Black
liberation movement and its leaders. Using Malcolm X as an example, Hoover directed all of the
Bureau's offices to "disrupt, misdirect, and otherwise neutralize" African American organizations
and leaders including the Southern Christian Leadership Conference, the Student Nonviolent
Coordinating Committee, the Nation of Islam, Dr. Martin Luther King Jr., Stokely Carmichael and
H. Rap Brown.
In Chicago, a major breakthrough came in 1973 when it was revealed that Chicago BPP
Chief of Security William O'Neal was a paid informant for the FBI. Lawyers at the People's Law
Office (full disclosure: I was one of those lawyers) had filed a civil rights lawsuit on behalf of the
Hampton and Clark families and the raid survivors shortly after the raid, and they subpoenaed the
Chicago FBI's files on O'Neal. While the FBI only produced a tiny fraction of the relevant files, an
honest Assistant US Attorney produced an FBI memorandum that included a detailed floor plan of
the interior of Fred Hampton's apartment that specifically identified the bed on which Hampton
slept. The memo, on its face, showed that the floor plan, together with other important
information designed to be utilized in a police raid, was based on information communicated by
O'Neal to his FBI control agent, and that the agent supplied this information to State's Attorney
Hanrahan's office before the raid.
The lawyers then focused on discovering more details about the FBI's involvement in the
conspiracy. We sought the Chicago office's COINTELPRO file in order to establish a direct link
between the FBI's illegal program and the raid on December 4. At the same time, Idaho Senator
Frank Church's Select Committee to Study Governmental Operations (Church Committee), which
was created in the wake of the Watergate scandal, was investigating rampant abuses by all US
intelligence agencies, including the FBI. In late 1975 a Church Committee attorney informed the
People's Law Office lawyers that the Committee had obtained several Chicago documents that
definitively established the link. Armed with the content of the still secret documents, the lawyers
were able to convince the judge, who had previously refused to compel the FBI to produce the
Chicago COINELPRO file, to order the FBI to do so. In the file that was subsequently produced
were several documents that revealed the FBI's efforts to foment gang violence against Hampton
and the Chicago Panthers, and one dated December 3, 1969, that claimed the impending raid as
part of the COINTEPRO program.

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In January 1976 the trial of the Fred Hampton civil case began in Federal Court.
Two months into what would turn out to be the longest trial in federal court history,
O'Neal's FBI control agent inadvertently revealed that the FBI had not produced all of
its files on Hampton, O'Neal, the raid survivors and the Chicago BPP. The judge
reluctantly ordered that they do so, and the next day a government lawyer wheeled in
on shopping carts nearly 200 volumes of FBI files that had been suppressed since they
were first requested three years before. The government produced several redacted
volumes of these files each day over the next month. The files contained directives to
destroy the Panther's Breakfast for Children Program and disrupt the distribution of the
BPP newspaper; reports showing that the dynamic and charismatic 21-year-old Fred
Hampton was a targeted BPP leader; materials demonstrating that O'Neal was an agent
provocateur; and massive wiretap "overhears" (logs that included conversations
between BPP members and their attorneys).
Among the government's documentation was O'Neal's control file. In it was yet
another smoking gun: memos to and from FBI headquarters and the Chicago office
requesting and approving payment of a $300 bonus -- 30 pieces of silver -- to reward
O'Neal for his role in the raid. According to the memos, O'Neal's information was of
"tremendous value" and, in the words of O'Neal's COINTELRO supervisor, made the raid
a "success."
That same month, on April 23, 1976, the Church Committee released its final
staff report, which devoted an entire chapter to the "FBI's Covert Action Plan to
Destroy the Black Panther Party." The chapter concluded by highlighting the Hampton
raid as a COINTELPRO operation and quoting from the recently uncovered "bonus"
documents.
The judge, an unabashed supporter of the FBI, exonerated the FBI and its DOJ
lawyers of any wrongdoing in suppressing the documents. A year later, he dismissed
O'Neal and the other FBI defendants from the case. On April 23, 1979, the Seventh
Circuit Court of Appeals, in a landmark 2-1 decision, overturned the trial judge, finding
that the FBI and their government lawyers "obstructed justice" by suppressing
documents. The Court of Appeals also concluded that there was "serious evidence" to
support the conclusion that the FBI, Hanrahan and his police unit had participated in a
"conspiracy designed to subvert and eliminate the Black Panther Party and its
members" in planning and executing the raid, thereby suppressing a "vital radical Black
political organization." The Court of Appeals further found that the evidence

additionally supported the conclusion that these same defendants also participated
in a post-raid conspiracy to "cover up evidence" regarding the raid, "to conceal the
true character of their pre-raid and raid activities," to "harass the survivors of the
raid" and to "frustrate any legal redress the survivors might seek." This decision
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survived a challenge in the US Supreme Court, and stands to this day as a unique
judicial recognition of outrageous federal and local conspiratorial criminality and
cover-up.
As we enter the uncharted waters of a volatile Trump presidency, with an
unrepentant Ku Klux Klan sympathizer slated to head up the Justice Department, it is
important not to relegate the Hampton assassination and COINTELPRO to the annals of
history. Particularly in an era of officially sanctioned drone assassinations, government
provocateurs running wild, and a presidential election in which the "winner" appears to
have benefited from international and FBI COINTELPRO-like actions, while the "loser"
used similar tactics against her opponent in the primaries, it is well to remember a
quote from a 1964 COINTELPRO directive:
Over the years, our approach to investigative problems in the intelligence
field has given rise to a number of new programs, some of which have been
most revolutionary, and it can be presumed that with a continued aggressive
approach to these programs, new and productive ideas will be forthcoming.
These ideas will not be increased in number or improved upon from the
standpoint of accomplishments merely through the institution of a program
such as COINTELPRO which is given another name and in fact, only
encompasses everything that has been done in the past or will be done in the
future.
For Black Lives Matter, the Water Protectors at Standing Rock, undocumented
workers, Muslims, environmental activists, and a multitude of other people and
organizations, the future, as contemplated in the 1964 COINTELRO memo and
implemented in its most violent and racist form on December 4, 1969, may well be
upon us again. The only answer now, as it was then, is to organize, educate and resist.
And, as Fred Hampton would say, "All Power to the People."
Note: For more information on the Hampton/Clark case, the history of the Black Panther Party
and the FBI's program to destroy it, visit peopleslawoffice.com.
Copyright, Truthout. May not be reprinted without permission.
Flint Taylor
Flint Taylor is one of the lawyers for the families of slain Black Panther leaders Fred
Hampton and Mark Clark. Together with his law partner Jeffrey Haas, Taylor was trial
counsel in the marathon 1976 civil trial. For more information on the Hampton/Clark
case, the history of the Black Panther Party and the FBI's Program to destroy it, visit
peopleslawoffice.com.

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CAUSES OF ACTIONS
1. Lancaster Aviation arrange for the selected aircraft to be flown in from the Midwest to be
inspected by PLAINTIFF. Pete Wolfson of Lancaster Aviation conducts the meeting, as an
official agent of Lancaster Aviation. Commonwealth Bank has approved the financing of
$97,000 for the purchase.

The additional $25,000 required is not yet available.

Pete

Wolfson insists that the plane must be purchased before being flown back to the Midwest.
Pete Wolfson requests a post-dated check from PLAINTIFF for the remaining balance.
PLAINTIFF refuses, citing that the remaining funds must be liquidated from the Keystone
Mutual Fund, and the exact receipt of the moneys is not guaranteed, and could take up to
10 days. Pete Wolfson agrees not to deposit the check until PLAINTIFF confirms that the
funds have been received and deposited in order to cover the check for the remaining
$25,000. PLAINTIFF makes sure that Pete Wolfson has the authority to make the
arrangement, and Pete Wolfson agrees. The purchase of the airplane was also subject to a
pre-purchase inspection by Lancaster Aviation. Lancaster Aviation also advises PLAINTIFF
to have his airplane included in their Fleet Insurance plan. PLAINTIFF also advises
Lancaster Aviation that he would like to offer the airplane to his business associates for
use in order to subsidize the costs and maintenance.
2. Chuck Smith, president of Lancaster Aviation, later discloses to PLAINTIFF that he had
deposited PLAINTIFFs pre dated check for $25.000, without the confirmation by PLAINTIFF
that the funds had been transferred from accounts.

PLAINTIFF had argued with Pete

Wolfson, the salesman for Lancaster Aviation, that he did not want to give them a post
dated check, however Chuck Wolfson insisted. Now, Chuck Smith had told PLAINTIFF that
Pete Wolfson did not have the authority to complete the transaction. However PLAINTIFF
reminded Chuck Smith that he was acting as an agent for Lancaster Aviation, and that was
not material to this dispute.
3. Lancaster Aviation and Commonwealth Bank engaged in Count IV - extortion, defamation
of character, slander, wrongful interference with business relations, wrongful interference
with contracts, obstruction of justice, trespass to person, unfair competition, fraud,
conspiracy, embezzlement, breech of contract and several violations in lender liability; in
later repossessing the aircraft on July 1, 1987 with no advanced notice and no reason or
cause. Commonwealth Bank was the mortgagor on the property of Olde Hickory, which
the PLAINTIFF had a loan commitment of $5 million to refinance that property. Lancaster
Aviation will deny the PLAINTIFFs airplane to provide service to a scheduled charter by
Jim Bly of Source Management of Virginia on June 27, 1987.

The PLAINTIFF had an

agreement for $300.00 per hour and an estimated 6-hour charter planned.
4. On June 23, 1987 Larry Resch, an executive of both International Signal & Control, Plc,.
(ISC) And United Chem Con visits PLAINTIFF at Financial Management Group, Ltd.,
headquarters in Lancaster, as scheduled to discuss business opportunities.

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explains "we had to fly Carl Jacobson out of the country early this morning" as the reason
for his not being able to attend the meeting as planned. Larry Resch discusses possible
strategies to rescue Chem Cons Minority 8A Set-aside contracts, and solicits financing for
new facility. PLAINTIFF becomes annoyed the context of the conversation, especially the
lack Of disclosure, and discusses allegations of wrongdoing by Guerin and International
Signal & Control, Plc, and the relationship to United Chem Con. After evaluating the
financial statements, PLAINTIFF also suggests there is approximately $15 to $18 million in
missing funds.
5. Mr. Larry Resch failed to inform the PLAINTIFF of his association and position with
International Signal & Control, Plc., while the PLAINTIFF formally began his whistle blowing
activities on International Signal & Control, Plc..
6. On June 23, 1987, at 2:00 pm immediately following the meeting with International Signal
& Control Executive, Mr. Larry Resch, the PLAINTIFF has his locks changed to his office by
Russell Locksmith of Lititz, in order to secure confidential personal and business files in
light of the current internal power struggle between himself, Michael Hartlett and Robert
Kauffman, and given the conversation with Mr. Larry Resch of International Signal &
Control, Plc., a few hours earlier.
7. The Plaintiff was a personal guarantor of a 5 year lease agreement with the Developer,
Fishcer Spounagle, Ltd., for the offices of Financial Management Group, Ltd., at 1755
Oregon Pike, Lancaster, Pennsylvania, that began in 1986 and did renew until 1991.
8. Robert Kaufman, President of FINANCIAL MANAGEMENT GROUP, Ltd., and other
FINANCIAL MANAGEMENT GROUP, Ltd., executives burglarize PLAINTIFF's office removing
confidential personal and business tiles.

Some of the mortgage banking and other

business files have yet to be found. Kauffman and Robert Long illegally issue FINANCIAL
MANAGEMENT GROUP, Ltd., stock certificates to Peter Peneros and Scott Robertson.
Robert Long signs the stock certificates as Secretary of FINANCIAL MANAGEMENT GROUP,
Ltd., when PLAINTIFF was acting Secretary, and was the only person duly authorized to
issue FINANCIAL MANAGEMENT GROUP, Ltd., stock certificates. PLAINTIFF learned of the
burglary by Robert Kauffman, President, in a telephone conversation while at Stone
Harbor, NJ; Kauffman inadvertently mentioned that the stock certificates were issued,
however, with all documents at risk of being stolen, PLAINTIFF did not mention the
incident, in hopes to first recover any potentially stolen business and personal files.
9. Financial Management Group, Ltd., executives engaged in obstruction of justice, in unfair
competition, wrongful interference with contracts, trespass to person, criminal trespass,
forgery, undo influence, conspiracy, embezzlement, Count IV - extortion, mental duress,
slander, defamation of character, wrongful interference with business relations, and
violated several bylaws of Financial Management Group, Ltd.,
10. On May 20, 1987, the PLAINTIFF and Attorney Ric Fox, of Harrisburg, Pennsylvania, draft

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the legal Letter of Intent for investors of Power Productions I, which the PLAINTIFF was
general partner.

The PLAINTIFF had several interested parties some which have made

verbal commitments, including Norris Boyd and Dave Cook, an executive of Turkey Hill
Minit Markets.
11. On June 29, 1987, the PLAINTIFF received patent research materials from patent attorney
Joel S. Goldhammer, of the prominent Philadelphia law firm Siedel, Gonda, Goldhammer &
Abbot regarding the "Digital" Movie, and the national franchising of Financial Management
Group, Ltd.,.
Abbot

in

PLAINTIFF had retained the services of Siedel, Gonda, Goldhammer, and

order

to

investigate

all

relevant

matters

concerning

the

technology,

merchandising, and marketing of the "Mutant Mania" project, and the use of the "Power
Station" label.

Research was required for the merchandising of consumer electronics,

professional audio/visual digital mixing consoles, and the "Power Station Digital Movie
System (PSDMS), as created by PLAINTIFF in the proposal for SONY Corporation of
Japan.
12. On May 11, 1987, the PLAINTIFF invested and paid Scott Robertson, executive vice
president of Financial Management Group, Ltd., $2,000 dollars from a personal account for
an advance for work on mortgage banking projects and the Digital Movie. On the same
day the PLAINTIFF paid film producer Marcia Silen, of Flatbush Films, Hollywood,
California, an advance of $750.00 for a cash advanced for work with the Digital Movie
project.
13. The PLAINTIFF was executor producer of the project, general partner of Power Productions
I, the investment group, and named in the Mutant Mania budget to receive a salary of
$100,000. In addition the PLAINTIFF had agreements to receive royalties on all revenues
associated with both the distribution of the film and video release and all branding of the
merchandise from the project.
14. Financial Management Group, Ltd., its officers and employees, along with other
Defendants including but not limited to Commonwealth National Bank (Mellon Bank)
(Mellon), Fulton Bank, the Manheim Township Police Department engaged in unfair
competition, wrongful interference with contracts, trespass to person, criminal trespass,
forgery, undo influence, conspiracy, embezzlement, Count IV - extortion, mental duress,
slander, defamation of character, obstruction of justice, wrongful interference with
business relations, and other anti trust violations pertaining to the Digital Movie project.
15. The PLAINTIFF, on behalf of Financial Management Group, Ltd., began research and
discussions with corporate attorney, Jeff Jamanou of the law firm McNesse, Wallace and
Nurick regarding franchising the concept of Financial Management Group, Ltd, on a
national scale and considerations for a stock split.

The PLAINTIFF handled all legal

endeavors of Financial Management Group, Ltd.,


16. Beginning in April of 1987, Financial Management Group, Ltd, officers and executives

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engaged in a pattern of unfair competition, wrongful interference with contracts, trespass
to person, obstruction of justice, criminal trespass, forgery, undo influence, conspiracy,
embezzlement, Count IV - extortion, mental duress, slander, defamation of character,
wrongful interference with business relations, and other anti trust violations.
17. On June 18, 1987, the PLAINTIFF and Randy Grespin, corporate attorney for The Life
Underwriters Group, fly to Atlanta, Georgia, to visit with executives of Planners Securities
Group, a nationally known Broker Dealer, and joint venture partner that was in the midst
of a deal in which Financial Management Group, Ltd., had negotiated an equity interest.
The PLAINTIFF had initially consulted with both Kauffman and Hartlett concerning the trip,
however when both disagreed, The PLAINTIFF questioned why the PLAINTIFF was the only
principal to personally visit the operations of Hibbard Brown & Company, which lead the
PLAINTIFF his decision to terminate the ill fated merger.
18. Planners Securities Group, was regarded as the most successful Broker Dealers in the
financial planning community, and included several former presidents of the national board
of the International Association of Financial Planners. The company had previously been
recruiting Financial Management Group, Ltd.,., and offering an attractive equity interest.
Randy Grespin agreed to reimburse $600 to The PLAINTIFF for the expense and use of his
aircraft.
19. The PLAINTIFF had the following agenda for the trip and meeting:
A. Visit and discuss the joint venture and merger with Financial Management Group, Ltd.,
and evaluate the various departments necessary to administer Financial Management
Group, Ltd.,'s., stock transactions and private real estate offerings.
B. Discuss and evaluate the opportunities of utilizing insurance products from Randy
Grespin's firm, and all matters related to the structuring of business.
C. Familiarize Greg Burie, a personal friend and recruitment of The PLAINTIFFs who was
also visiting from Florida to consider opening a Florida office for Financial Management
Group, Ltd..
D. Conduct an extensive and thorough due diligence investigation of the stability,
efficiency, and security of the operations, in order to prevent a similar situation that
facilitated the previous termination of the recent Hibbard Brown & Company deal. The
PLAINTIFF left the meetings with very optimistic and impressive findings, that only left
more questions as to the decision of Kauffman and Bartlett to affiliate with Hibbard
Brown & Company, knowing that the Atlanta group had been aggressively pursuing
talks of a merger since the inception of Financial Management Group, Ltd.,., On the
return flight home, The PLAINTIFF confided to Randy Grespin, requesting legal advise,
regarding the recent problems and his allegations of misconduct by Financial
Management Group, Ltd.,., President Robert Kauffman.

Randy Grespin advised The

PLAINTIFF to take some time and seek legal counsel.

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On June 18, 2007, after arriving at the corporate offices of Upon entering the offices of
Financial Management Group, Ltd., Robert Kauffman pulls The PLAINTIFF into his office
and abruptly shouts "Who is running this corporation, me or you?".

The PLAINTIFF

quickly answers "I don't give a damn who runs this company. as long as it's run right,
and for the right reasons!" The PLAINTIFF immediately left the office.
20. On June 18, 1987, later in the evening, Robert Kauffman, President visits the home of the
PLAINTIFF and engaged in a contractual dispute when the PLAINTIFF refused to agree to
approve the new contract and salary increase of Robert Kauffman, President,.

Robert

Kauffman, President, engaged in retaliatory and activities, including fraud, Count IV extortion, libel, defamation of character, obstruction of justice, and conspiracy.
21. June 22, 1987, The PLAINTIFF hires Todd Dellinqer, a planner in Financial Management
Group, Ltd.,., to help administrate the daily activities of his personal clientele and to
perform administrative duties necessary due to the amount of time The PLAINTIFF is
conducting business out at the office, allowing The PLAINTIFF to focus attention on the
Strategic Planning, and allowing him to better manage his time. The PLAINTIFF sends a
memo to client and shareholder Dr. William Umiker that introduces his new assistant, in
addition to information regarding his pension accounts.
22. FINANCIAL MANAGEMENT GROUP, Ltd, Board of Directors meet to vote on PLAINTIFF's
request and demand to ratify the recent joint venture agreement/contract with Hibbard
Brown & Company, after PLAINTIFF learned of dire inefficiencies within Hibbard Brown &
company, and the "Born Again" relationships of Kauffman, that placed an unprecedented
amount of risk to FINANCIAL MANAGEMENT GROUP, Ltd.,. PLAINTIFF voted by telephone
from the Chicago Airport, in the midst of his travel to Palm Springs and Hollywood
California. The Board also voted to negotiate and approve a deal with the Planners
Securities Group, of Atlanta, GA. PLAINTIFF had won the votes of Alan Loss and Robert
Long, overturning the decision of Robert Kauffman, President, and Michael Bartlett and
officially terminating the agreement. This vote, in and above itself, took control of the
Board of Directors from Kauffman and Bartlett, and put the power of the Board in the
direction of PLAINTIFF. This will eventually lead to the Coup conspired by Kauffman and
Hartlett to find a way to get PLAINTIFF out of the corporation.
23. On January 20, 1987, the PLAINTIFF and Al Dannatt, a principal and managing partner
with the commercial mortgage banking company Institutional Investors of Houston, Texas,
consummate a joint venture agreement where the PLAINTIFF will market and solicit clients
on the eastern part of the regional for commercial mortgages with a lending authority of
$3 to $100 million dollars. The agreement also calls for the PLAINTIFF to develop other
joint venture proposals and business transactions with a bank the Institutional Investors
was in the process of purchasing. The PLAINTIFF in turn would began to offer the joint
venture to members of Financial Management Group, Ltd., to offer finder fees to both

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Financial Management Group, Ltd., and any members of Financial Management Group,
Ltd., which referred clients and projects.
24. The PLAINTIFF alleges that the following revenue sources:
A. Financial Planning Fees and Commissions
B. Financial Management Group, Ltd., Management Salary
C. Mortgage Banking Business
D. Real Estate Limited Partnerships (Dave Schaad, Jim Bly, Dave Cook)
E. Pension Fund Portfolio Management (Harsco, Inc., of Harrisburg)
F. Life Insurance Joint Venture Agreements
G. Personal Real Estate Investments
H. Air Charter Services
I.

Reorganize Gamillion Film Studios

J. Equity Interests in Financial Management Group, Ltd.,


25. PLAINTIFF has the following violations Count IV - extortion, defamation of character,
slander,

wrongful

interference with

business relations,

wrongful

interference

with

contracts, trespass to person, unfair competition, fraud, conspiracy, embezzlement, breech


of contract
26. On June 25, 1987, Financial Group Executives burglarized the PLAINTIFFs office and
began to extort the PLAINTIFF business interests in the Institutional Investors joint
partnership. Up to that point in time, the PLAINTIFF had developed a pipeline in excess of
$100 million in projects, a firm commitment for a satellite office in Hollywood, California,
and a commitment for a $5 million second mortgage on the Olde Hickory Properties, of
Lancaster, County.

The PLAINTIFF was able to offer more attractive financing

arrangements than that of the local commercial lending institutions, including Fulton Bank
and Commonwealth Bank. Both banks would eventually engage in anti-trust violations.

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27. On June 29, 1987, The PLAINTIFF visits with Dave Schaad, President of the York based
real estate firm of Bennett Williams, Inc., The PLAINTIFF was finalizing plans to secure
financing of a $2.5 million office complex for the new headquarters of Bennett Williams, as
well as 3 or 4 additional anchor tenants.

The PLAINTIFF had been working with Dave

Schaad for the past 3 months, along with Scott Robertson. The PLAINTIFF had previously
discussed the deal with Dave Cook, and executive and former owner of the Turkey Hill
Convenience Stores. Dave Cook indicated a serious interest in providing the entire $2.5
million investment.

The above deal would have provided over $150,000 of fees upon

settlement to The PLAINTIFF upon settlement. Prior to the meeting, Dave Schaad had
indicated by telephone, that Robert Kauffman had invited himself to the meeting, without
prior consent or notice to The PLAINTIFF, During the meeting, The PLAINTIFF disclosed the
current criminal activities within the principals of Financial Management Group, Ltd., being
facilitated by Robert Kauffman himself.
28. In June of 1987, Jill Carson, a Fulton Bank Branch Manager libeled and slandered the
PLAINTIFF in notifying Mr. Chuck Smith, owner operator of Lancaster Aviation, the Plaintiff
was bankrupt and had no liquid funds, which was totally fabricated. At the time of this
infringement and at least until August 8, 1987, the PLAINTIFFs credit rating as reported
by the Lancaster Credit Bureau was perfect, with all creditors paid in full within 30 days,
as agreed.

The credit report included 22 creditors.

Being that the PLAINTIFF was a

customer, borrower, and a client in good standing with Fulton Bank, this amounts to
defamation of character, slander, wrongful interference with business relations, wrongful
interference with contracts, trespass to person, unfair competition, fraud, conspiracy,
embezzlement, breech of contract.
29. On July 1, 1987, the PLAINTIFF retained the counsel of Mr. Joseph F. Roda, Esq., of
Lancaster, to arrange for a meeting to discuss the recent events and Coup attempt by
Kauffman and Hartlett that included several criminal and security violations. The
PLAINTIFF visits with Mr. Joseph F. Roda, Esq. and describes the incidents in detail,
including the "Digital Movie", ISC, and all related activities.

Mr. Joseph F. Roda, Esq.

instructs The PLAINTIFF to have all of the files copied and arranges for the return of all
Financial Management Group, Ltd., corporate files. The PLAINTIFF had questioned Mr.
Joseph F. Roda, Esq. for a legal opinion as to his right of any moneys in Financial
Management Group, Ltd., checking accounts that he was authorized to sign for.

Mr.

Joseph F. Roda, Esq. advised that The PLAINTIFF had no right to any funds. All checks
were returned to Financial Management Group, Ltd., along with all other documents.
30. The PLAINTIFF advises Mr. Joseph F. Roda, Esq. that he is in fear that someone is
deliberately orchestrating all of the recent incidents, which were quite extraordinary and
extremely criminal and have been coming from all directions. The PLAINTIFF advised Mr.
Joseph F. Roda, Esq. that he would like to take all of his files to Stone Harbor, New Jersey

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for safekeeping while he pursued his legal recourse. The PLAINTIFF also explained that he
would feel safer leaving Lancaster until these circumstances were brought under control.
31. Mr. Joseph F. Roda, Esq., failed to provide any advocacy representation; colluded with
Financial Management Group, Ltd.,; failed to inform the PLAINTIFF of any conflicts of
interests with current clients (Mr. William Clark, in house legal counsel for International
Signal & Control, Plc.,); was negligent in not reviewing the hundreds of documents the
PLAINTIFF delivered and for not identifying causes of actions, which United States District
Judge Mary McLaughlin identified from similar documents in June of 2006; was negligent
in not believing the PLAINTIFF detailed account of the Commonwealth National Bank
(Mellon Bank) wrongful repossession, may have conspired to cover-up the PLAINTIFFs
Federal False Claims Act against International Signal & Control, Plc,.
32. Mr. Joseph F. Roda committed fraud in invoicing the PLAINTIFF for services rendered,
without any actual benefit afforded to the PLAINTIFF.
33. The Defendants conspired to discredit the PLAINTIFF with a massive campaign of libel,
slander and deceit when immediately following the meeting with International Signal &
Control, Plc., meeting of June 23, 1987 the following contracts were terminated without
cause:
K. Planners Securities Group, Ltd., NASD Series 22 Securities License
L. Planners Securities Registered Representative Agreements
M. William O. Umiker Executor of Estate
N. Michael T. Caterbone Power of Attorney
34. On July 3, 1987, at approximately 12:00 am, Victor Miasnikowcs, owner operator of Romar
Aviation (Currently Venture Jets, Inc.) calls The PLAINTIFF to notify him that his aircraft
was reposed some hour earlier, and locked in the hanger of Lancaster Aviation, with all of
his personal and business files on board. Victor only would say that Commonwealth Bank
had taken part in the repossession, with no reasons given. The first payment of the loan
agreement with Commonwealth National Bank (Mellon Bank) was not due until July 25,
1987 and the $25,000 cash deposit for the airplane was now officially extorted from the
PLAINTIFF. There was no money due to Commonwealth National Bank (Mellon Bank). The
PLAINTIFF also becomes quite suspicious, after learning a few weeks earlier that his efforts
to provide a refinance of some $6 million to Boyd Wilson Properties, was more favorable
than the existing or proposed financing arrangements now place with Commonwealth
National Bank (Mellon Bank), which not only has a lender relationship with The PLAINTIFF,
but is also a competitor for his mortgage banking activities. It was also known that The
PLAINTIFF's lending authority was larger and more competitive than most of the local
banking community. The PLAINTIFF now becomes in fear for his life due to this incident,
and all other unexplained incidents in the preceding days and weeks.
35. Commonwealth Bank engaged in an illegal repossession, conversion, replevin, trespass,

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fraud, breach of fiduciary duty, and/or breach of contract arising out of the alleged
repossession, Count IV - extortion, lender liability, interference with business contracts
and relations, civil conspiracy, fraud, and violated anti-trust and lender liability laws.
36. On July 4, 1987 at approximately 9:00 am in the morning, The PLAINTIFF calls his
attorney Mr. Joseph F. Roda, Esq., under emotional duress from the previous conversation
with Victor and the repossession of his aircraft with all documents on board; Mr. Joseph F.
Roda, Esq. responds "Stan, you have to quit fabricating these allegations, it is July 4th,
what do you want me to do.

This conversation reaffirms a conspiracy theory within

Lancaster to ruin him, and supports his efforts to leave Lancaster with his files to solicit aid
and support from legal and law enforcement authorities to suppress the conspiracy. The
PLAINTIFF realizes that the documents were authentic proof and evidence of all of his
allegations, and most importantly all of his business activities for the past 5 or more years.
The loss of the files would have devastating consequences for his life.
37. Mr. Joseph F. Roda committed fraud in invoicing the PLAINTIFF for services rendered,
without any actual benefit afforded to the PLAINTIFF.
38. On July 4, 1987, at approximately 9:30 am, after the disturbing phone, The PLAINTIFF
drives to the Cape May County Airport to solicit the services of a pilot to fly to Lancaster to
retrieve his files.

Brad Donahue accepts the job, and agrees to a $200 tee, and an

additional $200 it there are any difficulties in obtaining the files. The PLAINTIFF provides
Brad Donahue with all documentation showing legal title to the aircraft in the event
authorities are notified. The PLAINTIFF gives explicit instructions to notify the police in the
event personnel will not return all of the files. Brad Donahue arrives a few hours later, with
boxes of files.

Brad Donahue briefly describes an encounter at Lancaster Aviation, and

demands payment of $400 as agreed.

An invoice is signed by all parties as proof of

payment and the activity, and $400 in cash is paid to Brad Donahue. Pilot Dave Austin, of
the Cape May County Airport witnesses the transactions and the event.
39. In

the following weeks, Dave Austin, would later disclose to The PLAINTIFF that Brad

Donahue was killed in a mysterious "Air-Accident", while over water, with an unexplained and
questionable flight chart.
40. The PLAINTIFF solicits the legal services of Ric Fox, a Harrisburg attorney that has
prepared legal documents for the "Digital" Movie. Rio Fox flies his aircraft to the Cape May
County Airport, and arrives at The PLAINTIFF's house accompanied with another attorney
Robert Chercicoff.

All of the recent activities were detailed and described concerning

Financial Management Group, Ltd.,; the "Digital Movie"; and the illegal repossession of the
aircraft.

The PLAINTIFF questioned Mr. Fox and his associate of any relationship with

Commonwealth Bank, which headquarters were also in Harrisburg, and both gave a very
ambiguous answer. The meeting ended with both attorneys failing to recognize or admit to
any wrongdoing by any and all related parties, and further demanding a $2,000 retainer
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fee to look further into the matters. The PLAINTIFF suspects the conspiracy theory again,
especially in light of the acknowledged relationship with Commonwealth Bank, and an
indirect relationship with Robert Kauffman, through Life Underwriters of Harrisburg, a joint
venture arranged by The PLAINTIFF some months earlier. By July 5, The PLAINTIFF had
already made two legitimate attempts to solicit legal aid for the unexplained events and
circumstances, both of which were maliciously sabotaged.
41. Ric Fox and Robert Chercicoff engaged in conspiracy, collusion, interference with business
contracts, interference with business relations, and had attempted to thwart and cover-up
the PLAINTIFFS Federal False Claims Act complaint.
42. On July 6, 1987, In an effort to document the conspiracy theory, PLAINTIFF requests Tom
Caterbone to call Robert Kauffman, President, to inquire about the status of his affairs, and
to tape the conversation.

Tom Caterbone identifies himself as John Green, a client of

PLAINTIFF's and Robert Kauffman, President, states the following: "PLAINTIFF has moved
his office to Stone Harbor, NJ.. he is not taking care of business, and I need to see to it
that his clients are taken care of for the time being.. he has been spending a lot of money,
an airplane, a place at the shore, and he seems to think that he is too important for his
traditional clientele.. There is some history of mental disorders in his family history.. I
can't come right out and say that that is what's going on,.... I wish Stan would get some
professional help.. However for the time being, Stan is not taking care of business, and I
need to be concerned for his clients.
43. On July 6, 1987, PLAINTIFF telephones Dr. Al Schulz, psychiatrist at St. Joseph Hospital,
and client of PLAINTIFF's in order to thwart the allegations of insanity. Dr. Al Shulz had
disclosed that several persons, including Mary Lynn Dipaolo and Jere Sullivan had called
him concerning PLAINTIFF's behavior and activities.
44. From the allegations, Dr. Shulz advised that PLAINTIFF was suffering from illusions of
grandeur, and prescribed Lithium treatment, and to return to Lancaster for consultation.
PLAINTIFF insisted that the allegations were purely fabricated, and that no one had any
legal right to interfere with his business and or legal affairs, let alone his confidential
medical records.
45. On July 6, 1987, PLAINTIFF contacts David Drubner, of Boston, Ma, a friend of PLAINTIFF's
brothers Mike, and an attorney.

During the conversation, David Drubner questions

PLAINTIFF about "taking some medication", and supports the allegations of insanity.
46. On July 17, 1987 PLAINTIFF travels to Hollywood, California to meet and visit with Ted
Gamillion and Gamillion Studios (Film Studio), and Marcia Silen of Flatbush Films. Ted
Gamillion had previously solicited the consulting of PLAINTIFF in order to help reorganize
the financing of the film studio, after earlier arrangements in North Carolina had gone
sour.

PLAINTIFF had spent several days visiting and touring the studio. Ted Gamillion

agreed to allow PLAINTIFF to represent the studio in order to secure the required

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financing.

Ted Gamillion provided PLAINTIFF with substantial amounts of confidential

financial, legal, and tax documents for the project.


47. During the visit, Marcia Silen had disclosed to PLAINTIFF that Scott Robertson had made
allegations of insanity about him (PLAINTIFF) to persons at Power Station Studios and and
Flatbush Films.
48. In the following days, PLAINTIFF had made numerous telephone calls to local, state, and
federal authorities, for intervention and help regarding all of the preceding events and
circumstances.

The following is a brief description of each: Manheim Township Police

Department, responded "what bank branch repossessed your aircraft"; Pennsylvania State
Senator Gib Armstrong, responded, "I will call the Pa Attorney General's Office and have
them call you; the Federal Bureau of Investigation (FBI), the Philadelphia-based field
office; U.S. Representative Robert Walker (R-Pa), a detailed and explicit conversation with
Mrs. Robert Walker, who would only advise PLAINTIFF to put his situation in writing and
submit it to the Congressman in his Washington, D. C. office. In addition: David Wouls
(Executive Vice President of the Lancaster chamber of Commerce & Industry), PLAINTIFF
talked at length, and in detail, making allegations of misconduct with members of the
same; National Association of securities Dealers (NASD), in Washington, D.C., PLAINTIFF
discussed the securities related violations. And also: the Securities & Exchange
Commission (SEC), also in Washington, D.C., and discussed securities laws violations; the
Pennsylvania Securities Commission, of Harrisburg, Pa, discussed the implications of
PLAINTIFF's illegal lock-out, and his legal and formal positions, including incorporating
officer of Financial Management Group, Ltd., PLAINTIFF received no support or follow-up
communications concerning all of the above requests, despite his apparent emotional
duress, and extreme situation.
49. On July 2, 1987, The PLAINTIFF negotiates with Romar Aviation to provide pilot; storage;
and insurance with his aircraft after many very questionable occurrences at Lancaster
Aviation, just a few hundred feet away.

The PLAINTIFF secures insurance and pays

$1,000 to Romar Aviation for the flight to Stone Harbor and insurance, which was
conducted by Victor M. of Romar Aviation.

In addition, at the referral of Victor, The

PLAINTIFF calls Sam Goode, of Sam Goode Assoc., to bind insurance for the aircraft. Sam
Goode Binds the insurance and instruct The PLAINTIFF to mail a payment of $750. The
conversation took place in Romar Aviation, at the time the $1,000 was paid to Victor. The
PLAINTIFF loads his aircraft with all of his personal and business files to be transported to
the Cape May County Airport, just a few miles outside of Stone Harbor, in the morning of
July 4.
50. In July and August of 1987 Mr. Robert Kauffman, President, had several meetings with
Millard Johnson, client of PLAINTIFF since 1982, in efforts to coerce Millard Johnson to
provide false statements to a bonding company that a legitimate loan from Millard Johnson

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to the PLAINTIFF was instead an act of embezzlement of $25,000 of funds that were
transferred to the PLAINTIFF for an investment. Mr. Millard Johnson testified in person on
September 29, 1987 before Mr. Howard Eisler of the Pennsylvania Securities Commission
in a recorded interview and attested to the preceding. Mr. Millard Johnson refused and
notified Mr. Robert Kauffman that his attempt was a serious crime.
51. Mr. Kauffman and Mr. Michael Hartlett, a principal and partner of Financial Management
Group, Ltd., contracted with an insurance company on June 29, 1987 an errors and
omissions insurance policy for corporate officers of Financial Management Group, Ltd., in
an effort to collude, conspire, and defraud that insurance company of a claim, while at the
same time committing slander, libel, and conspiracy to extort the PLAINTIFFs stock
holdings, and all other business interests.
52. On July 24, 1987, Michael M. Hartlett sends a letter to all creditors of Financial
Management Group, Ltd., informing them that stated the following: The PLAINTIFF is no
longer an officer of the corporation; he was removed from office on July 1, 1987; he had
been purchasing items under Financial Management Group, Ltd., and obtaining corporate
discount and rates; and formally notifying them that The PLAINTIFF had never had the
right to purchase items through Financial Management Group, Ltd., or make corporate
commitments on behalf of Financial Management Group, Ltd., or contract or in any way
obligate Financial Management Group, Ltd.,.
53. Mr. Michael M. Hartlett engaged in slander, libel, defamation of character, conspiracy to
commit fraud, conspiracy to commit Count IV - extortion, interference with business
relations, and interference with business contracts.
54. On July 7th, 1987, the PLAINTIFF contacts the law firm of Capello & Foley, of Santa
Barbara, California.

The PLAINTIFF had conducted research (American Bar Association

Journal) in "Lender Liability", which had became a very popular legal issue, where banks
participate in illegal activities resulting in the financial ruin of it's borrowers.

The

PLAINTIFF intended to file suit against Commonwealth National Bank (Mellon Bank) for the
illegal and unjustified repossession of his aircraft. The PLAINTIFF discussed the case briefly
with Diane Campell that day, and The PLAINTIFF made arrangements to deliver supporting
documents to the office in Santa Barbara the following week, while visiting with Gamillion
Studios, in Hollywood.
55. On July 8, 1987, A formal notification of the termination of The PLAINTIFF's Registered
Representative Securities license with the Planners Securities Group Inc., of Atlanta, GA is
received, with a "cc: Robert Kauffman".
56. Planners Securities Group, Inc., engaged in conspiracy to commit Count IV - extortion,
conspiracy, fraud, libel, defamation of character, slander, Count IV - extortion,
interference with business relations, interference with business contracts, and had violated
several anti-trust violations.

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57. No explanation was provided, or any reasons for the termination. The PLAINTIFFs reprisal
for disclosing criminal activities to the proper authorities is that he will illegally loose his
privilege to sell securities without any merit.
58. On July 8, 1987, The PLAINTIFF's brothers, Steve, Phil, Mike, and Tom, arrive
unexpectedly and uninvited at the residence of The PLAINTIFF's in Stone Harbor, NJ, and
refuse to leave until The PLAINTIFF agrees to take Lithium and return

to Lancaster to

undergo treatment by Dr. Al Schulz, for mental illness.


59. Steve Caterbone, Phil Caterbone, Mike Caterbone, and Tom Caterbone had engaged in
conspiracy, libel, slander, defamation of character, conspiracy to commit Count IV extortion, interference with business relations, interference with business contracts,
invasion of privacy, and civil trespass.
60. On July 9th, 1987, The PLAINTIFF receives a notice by regular

1st class mail from

Commonwealth National Bank (Mellon Bank) regarding the repossession of 9 days prior.
The following reasons are given for the repossession: Failure to provide adequate
insurance; Removal of aircraft from Lancaster Aviation; Intended plan to fly aircraft to
Florida without prior written notice.
61. Commonwealth National Bank (Mellon Bank) engaged in violations of lender liability by not
providing advanced notice of the repossession with any opportunity for the PLAINTIFF to
cure any legitimate deficiencies in the lending agreements.
62. On July 10, 1987, the PLAINTIFF receives a formal notarized notification from Dr. and Mrs.
William Umiker of Financial Management Group, Ltd., removing The PLAINTIFF as the
former Trustee for their Estates.
63. On July 10, 1987, Mr. Robert Kauffman also sends a personal letter to all of The
PLAINTIFFs clients informing each and every one that he has moved to Stone Harbor,
NJ; that he may not handle investments at all; and that people close to The PLAINTIFF had
requested that he, Robert Kauffman, personally service his clientele.
64. Robert Kauffman engaged in Count IV - extortion, fraud, libel, slander, defamation of
character, conspiracy to commit Count IV - extortion, interference with business relations,
interference with business contracts, invasion of privacy, and civil trespass, and violated
several anti-trust statutes.
65. On July 15, 1987 the PLAINTIFF travels to Boston, Massachusetts to research lender
liability and other legal matters in a law library of Suffolk Community College.
66. On July 16, 1987, the PLAINTIFF travels to New York, from Boston, MA, to visit with Bob
Walters of Power Station Studios, to discuss the allegations of Blackmail, and to find out
who is involved, including Scott Robertson and Power Station Studios.
67. On July 17, 1987, the PLAINTIFF travels to Hollywood, California to meet and visit with Ted
Gamillion and Gamillion Studios (Film Studio), and Marcia Silen of Flatbush Films. Ted
Gamillion had previously solicited the consulting of The PLAINTIFF in order to help

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reorganize the financing of the film studio, after earlier arrangements in North Carolina
had gone sour. The PLAINTIFF had spent several days visiting and touring the studio. Ted
Gamillion agreed to allow The PLAINTIFF to represent the studio in order to secure the
required financing.

Ted Gamillion provided The PLAINTIFF with substantial amounts of

confidential financial, legal, and tax documents for the project. During the visit, Marcia
Silen had disclosed to The PLAINTIFF that Scott Robertson had made allegations of
insanity about him (The PLAINTIFF) to persons at Power Station Studios and at Flatbush
Films.
68. The PLAINTIFF discusses the illegal repossession and other related matters, however
during the conversation, becomes suspicious when Bob Walters and Tony Bongiovi disclose
that the "Digital" Movie project is suddenly suspended until a later time.
69. On July 21, 1987, At 2:30 pm The PLAINTIFF visits the law firm of Capello & Foley, in
Santa Barbara, California, and delivers 3 large blue binders for Diane Cambell and attorney
Barry Capello to review, concerning his allegations of dire violations of lender liability with
specific regards to the illegal repossession of his aircraft by Commonwealth National Bank
(Mellon Bank). The PLAINTIFF research the law firm of Capello & Foley at the Suffolk law
library and learned that it was the leading law firm in the nation leading the way in
violations of lender liability litigation.
70. The law firm of Capello & Foley and the PLAINTIFF had numerous communications,
although there was never any commitment for representation by Capello & Foley, it is
alleged that the law firm engaged in conspiracy, collusion, interference with business
contracts, interference with business relations, and had attempted to thwart and cover-up
the PLAINTIFFS Federal False Claims Act complaint by not acting in good faith with the
solicitation of the PLAINTIFF.
71. On July 24, 1987 The PLAINTIFF conducts a three (3) hour meeting at his residence in
Stone Harbor, NJ, with attorney Lew Schweller regarding legal action concerning all events
and activities of the prior days and months.

The PLAINTIFF also gives Lew Schweller a

$500.00 retainers fee, for his representation.


72. Lew Schweller engaged in conspiracy, collusion, interference with business contracts,
interference with business relations, and had attempted to thwart and cover-up the
PLAINTIFFS Federal False Claims Act complaint.
73. On July 24, 1987, Attorney Joseph Roda invoices The PLAINTIFF $527.00 for the time and
services of July 1 & 2, 1987.
74. On July 30, 1987, The PLAINTIFF had paid $600 to Dr. Levine, a Psychiatrist from North
field, New Jersey, for an objective evaluation of his mental state of mind, in order to prove
the fabricated allegations of 'insanity". Dr. Levine had conducted a 2-hour meeting in his
residence in Stone Harbor, NJ, and required The PLAINTIFF to complete the Minneapolis
Multiphase Personality Inventory (MMPI).

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The PLAINTIFF completed the test, and

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immediately returned it to Dr. Levine. After several weeks without any communications
from Dr. Levine, The PLAINTIFF had called for the results. Dr. Levine had explained that
he had conducted telephone interviews with members of The PLAINTIFF's family, without
notice or consent, in addition to the original request of The PLAINTIFF to conduct an
objective and confidential examination. In addition, Dr. Levine prescribed Lithium drug
therapy, and disclosed a diagnosis of Bi-Polar Mood Disorder.
75. Dr. Levine engaged in Count IV - extortion, conspiracy to commit fraud, defamation of
character, slander, libel, and obstruction of justice.
76. On August 6, 1987, the law firm of Appel, Yost & Sorentino, of Lancaster, Pa., sends a
formal notice to The PLAINTIFF, demanding the return of a facsimile machine leased from
the ACM Company of Lancaster, Pa. Attorney Appel advises The PLAINTIFF that it is the
property of Financial Management Group, Ltd., and should be returned at once or legal
action will follow.
77. Appel Yost & Sorentino and Attorney Appel engaged in fraud, collusion, libel, slander,
defamation of character, conspiracy to commit Count IV - extortion, interference with
business relations, interference with business contracts.
78. On August 7, 2007 the PLAINTIFF receives a Credit Report from the Credit Bureau of
Lancaster County as requested. The credit report up to the date of August 1, 1987 verifies
and confirms that his credit report was excellent, without any blemishes. The history of all
accounts was "paid within 30 days, or as agreed".
79. On August 8, 1987, John M. Wolf, Executive Vice President of Commonwealth National
Bank (Mellon Bank) sends The PLAINTIFF a formal letter advising that the repossession of
July 2, 1987 was both lawful and appropriate, and declines to accept a settlement of $5
million for lender liability violations.
80. On August 10, 1987, the PLAINTIFF receives a facsimile from the Board of Directors of
Financial Management Group, Ltd., signed by Robert Long as The FMG Board of Directors
threatening to file criminal charges for "embezzlement (we have checks to prove it),
burglary, employee theft, corporate opportunity and slander against our firm".
81. Financial Management Group, Ltd., engaged in obstruction of justice, in unfair competition,
wrongful interference with contracts, trespass to person, criminal trespass, forgery, undo
influence, conspiracy, embezzlement, Count IV - extortion, mental duress, slander,
defamation of character, wrongful interference with business relations, and violated
several bylaws of Financial Management Group, Ltd.,
82. On August 12, 1987, Yolanda Caterbone, mother of The PLAINTIFF, Steve, Phil, Mike, and
Tom Caterbone, all brothers, arrive unexpectedly and uninvited to the residence of The
PLAINTIFF in Stone Harbor. After several requests for the visitors to leave the premises
are denied, several brothers refuse to let The PLAINTIFF leave the premises.

The

PLAINTIFF flees, and the brothers chase after him. The PLAINTIFF runs into a neighbors

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house to ask to use the telephone to phone the police. However, after realizing that he is
scaring the occupants, he flees to the Stone Harbor Police Department, a few blocks away,
in an effort to obtain a restraining order and to lawfully have the unwanted persons vacate
his residence and personal property. Officer Steve Conners and Officer Henry Stanford
refuse the request, and hold The PLAINTIFF in custody.

After some 30 minutes, the

officers, accompanied by Steve and Tom Caterbone, place The PLAINTIFF into a Police
Cruiser and proceed to the Burdette Tomlin Hospital, in Stone Harbor. Upon arriving, The
PLAINTIFF is interrogated and questioned extensively about a "gun".

A hospital staffer

then accuses The PLAINTIFF of an attempted suicide and keep him in custody for 4 or
more hours.

An extensive mental health evaluation is performed by another hospital

staffer. The PLAINTIFF is given an ultimatum of signing a contract in order to be released


form the hospital, the contract stated: "I Stanley J. Caterbone will not take my life tonight
or at anytime".
83. Yolanda Caterbone, Steve Caterbone, Phil Caterbone, Mike Caterbone, Tom Caterbone
engaged in invasion of privacy, civil trespass, obstruction of justice, wrongful interference
with contracts, trespass to person, criminal trespass, forgery, undo influence, conspiracy,
embezzlement, Count IV - extortion, mental duress, slander, defamation of character,
wrongful interference with business relations; and engaged in psychiatric abuse.
84. The Stone Harbor Police, James Warner (Current Executive Director of the Lancaster
County Solid Waste Management Authority) and Burdette Tomlin Hospital engaged in
obstruction of justice, wrongful interference with contracts, trespass to person, criminal
trespass, forgery, undo influence, conspiracy, embezzlement, Count IV - extortion, mental
duress, slander, defamation of character, wrongful interference with business relations and
engaged in psychiatric abuse.
85. On August 13, 1987, the PLAINTIFF At approximately 9:30 am, The PLAINTIFF returns to
the Burdette Tomlin Hospital to obtain a formal copy of the incident the preceding night.
After some arguments1 hospital officials provide explicit records of the event, including the
following summary: "Stan was brought to the ER (emergency room) by two brothers and
police.

Police received a phone call from Jim Warner, (872-9081, friend staying at the

Conestoga residence of the PLAINTIFF), who told them he believed Stan planned to take a
gun, go to the beach & kill himself. Client denied any such statement, thoughts or plans.
He has legal and difficult times, financial deals which have fallen through; license to do
financial planning (his business) revoked; repossessed material goods (airplane); being
blackmailed; and several major financial deals (in which he had invested personal funds)
fall through-but NO PROBLEMS! Denied any Depression.
86. On August 14, 1987, the same family members again arrive unwanted at the residence of
The PLAINTIFF in Stone Harbor, NJ. After another confrontation, similar to the incident of
two evenings before, The PLAINTIFF fleas to the Avalon Police Department for another

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attempt to get a restraining order. However, en route, just a few blocks from the Avalon
Police Station, an Avalon Police cruiser pulls The PLAINTIFF over and arrests him for the
following violations:
87. Driving Beyond the speed limit.
88. Driving an unregistered vehicle (all required registration materials were in Lancaster, PA)
89. Containing an empty beer can in his vehicle (which was at .1 east three days old)
90. In addition, the Avalon Police Department repossessed his car and locked it in the Avalon
Police

Department compound,

which was his only means of transportation and

communication by car phone.


91. Again, Yolanda Caterbone, Steve Caterbone, Phil Caterbone, Mike Caterbone, Tom
Caterbone engaged in invasion of privacy, civil trespass, obstruction of justice, wrongful
interference with contracts, trespass to person, criminal trespass, forgery, undo influence,
conspiracy, embezzlement, Count IV - extortion, mental duress, slander, defamation of
character, wrongful interference with business relations; and engaged in psychiatric abuse.
92. The Avalon Police Department engaged in false arrest, false imprisonment, false
statements, civil conspiracy, malicious prosecution and/or malicious abuse of process
claims arising out of the charges and arrest; and (2) civil rights claims under 42 U.S.C.
1983, arising out of the Department's actions or inactions during court scheduled hearings
in 1987.
93. On August 24, 1987, Robert Kauffman sends a letter to Millard Johnson, The PLAINTIFF's
client, regarding his previous intentions of paying the $25,000 demand note of The
PLAINTIFF to Millard Johnson. Robert Kauffman had previously promised to pay the debt
to Millard Johnson during a meeting. Robert Kauffman, told Millard Johnson to contact the
Financial Management Group, Ltd., attorney, Craig Russell in order to file legal claim, and
formally disclosed that he would: no longer handle any discussions concerning Stanley J.
Caterbone. In the last paragraph, Robert Kauffman discloses "attorney Mr. Patterson, no
longer represents the Caterbone family regarding his pending bankruptcy or guardianship".
The PLAINTIFF never gave any legal jurisdiction or rights to any family member, has never
filed for bankruptcy, was not bankrupt, or even knew of an attorney named Mr. Patterson.
94. Robert Kauffman and Craig Russell engage in conspiracy to commit fraud, libel, slander,
defamation of character, conspiracy to commit Count IV - extortion, and false statements.
95. On September 1, 1987, in an attempt to resolve issues, The PLAINTIFF calls Financial
Management Group, Ltd., board member P. Alan Loss and requests a meeting with Robert.
long and Scott Robertson to explain allegations of misconduct of Robert Kauffman and
Michael Hartlett and the illegal lockout of The PLAINTIFF.

P. Alan Loss agrees and a

meeting is set for September 4, 1987 at 10:00 am in the aide Hickory Inn, a mile away
from Financial Management Group, Ltd., The PLAINTIFF requests that the meeting be in
the strictest of confidence.

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96. On September 3, 1987, Attorney Joseph Roda sends The PLAINTIFF a letter requesting
payment of $525.48 in outstanding legal tees for the meetings of July 1 & 2 and copying
charges.
97. The PLAINTIFF calls Victor of Romar Aviation (no charge) to schedule a charter flight from
Cape May County Airport to the Lancaster Airport for September 3rd at approximately
2:00 pm, the day before the meeting with Financial Management Group, Ltd., executives.
98. On September 3, 1987, Robert Kauffman calls detective Larry Sigler of the Manheim
Township Police Department to report an alleged Terroristic threat made two days prior,
on September 1, 1987, by The PLAINTIFF between the hours of 9:00 and 1 pm noontime.
Detective Larry Sigler issues a warrant for the arrest of The PLAINTIFF with District Justice
Murray Horton that was issued at about the same time as the arrival of The PLAINTIFF at
Romar Aviation.
99. On

September 3, 1987, Larry Sigler and the Manheim Township Police Department engage in

false imprisonment, false arrest, malicious prosecution and/or malicious abuse of process
claims arising out of the charges and arrest in September 1987; and (2) civil rights claims under
42 U.S.C. 1983, arising out of the Department's actions or inactions in July and September
1987, and January 1991.
100.

On September 3, 1987, At approximately 3:00 pm Mary Lynn Dipaolo picks The

PLAINTIFF up at Romar Aviation for a scheduled visit and dinner.

After The PLAINTIFF

becomes annoyed at Mary Lynn Dipaolo's unjustified allegations, The PLAINTIFF borrows
her car to go home to his residence in Conestoga and to go play basketball.
101.

On September 3, 1987, at approximately 7:00 pm, upon leaving the playground, he

is approached by Nancy Arment, Financial Management Group, Ltd., secretary, who is


elaborated and crying, asking "why are you doing this?".
102.

Nancy Arment of Financial Management Group, Ltd., engaged in harassment and

conspiracy to commit Count IV - extortion.


103.

On September 3, 1987, At approximately 9:00 pm, in an attempt to recover

additional stolen personal and business tiles, The PLAINTIFF proceeds to the offices of
Financial Management Group, Ltd., where he is greeted by employee Stacy Waters and
allowed to enter the building. The PLAINTIFF insists that Stacy Walters accompany him
throughout the building as he recovers files in the offices of Robert Kauffman, Michael
Bartlett, and Robert Long. In addition retrieving a Back-Up (Financial Management Group,
Ltd., records and communications) copy of the computer system which he integrated.
Upon leaving, The PLAINTIFF temporarily disconnect the systems which he had integrated
and developed for Financial Management Group, Ltd., which fall under intellectual property
rights. Stacy Walters assists The PLAINTIFF in loading the tiles in his automobile, and The
PLAINTIFF kisses Stacy Walters goodbye, and awaits for her safe return to the building
until leaving.
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104.

Stacy Walters engaged in criminal trespass, conspiracy to commit Count IV -

extortion, undo influence, mental duress, slander, defamation of character, and wrongful
interference with business relations.
105.

On September 4, 1987, after midnight, upon entering his residence, the PLAINTIFF

is taken into custody by the Conestoga Police, and requests that the files that he had
taken out of the offices of Financial Management Group, Ltd., be taken along to prove his
rights to the property, and his position within the company.

The PLAINTIFF was then

taken to the jurisdiction of Manheim Township Police, at Where the New Danville Pike
meets South Prince Street, where he is arrested and taken into custody.
106.

On September 4, 1987, at approximately 2:00 am, The PLAINTIFF is arraigned

before District Justice Richard R. Reeser for the following charges: Terroristic threats;
burglary; unlawful restraint; unlawful use of computers; theft by unlawful taking; robbery;
and criminal mischief.
107.

Bail is set at $20,000 and The PLAINTIFF is placed in the Lancaster County Prison.

He was not permitted to post real estate for bail.


108.

The Manheim Township Police Department, Detective Larry Mathias and the

Lancaster County Prison engage in (1) assault, battery, false imprisonment, false arrest,
malicious prosecution and/or malicious abuse of process claims arising out of the charges
and arrest in September 1987; and (2) civil rights claims under 42 U.S.C. 1983, arising
out of the Department's actions or inactions in July and September 1987, and January
1991.
109.

September 5, 1987 - The Lancaster New Era and the Lancaster Intelligencer Journal

report the alleged crimes, reporting that The PLAINTIFF is an ax-employee; that Financial
Management Group, Ltd., sustained $60,000 because of his actions; and that he
threatened 2 female employees.
110.

The Lancaster Newspapers, Inc., engaged in libel, slander, defamation of character,

conspiracy to commit fraud, conspiracy to commit Count IV - extortion, conspiracy to


commit obstruction of justice.
111.

The entire arrests and reports fail to acknowledge that The PLAINTIFF is an

individual lessee of the property, and in accordance with law, still holds all of his offices of
PING, Ltd., and is the founder of the company. The above incident further facilitates the
ongoing conspiracy, and publicly discredits The PLAINTIFF in every way, financially,
professionally, and most importantly conveniently supports the continued allegations of
insanity.
112.

On September 6, 1987, all attempts to post bail are denied. Robert Beyer appears

for visitation at the Lancaster county prison, completely unexpectedly and unsolicited.
Robert Beyer offers his services and representation with regards to only defending the
criminal charges.

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113.

On September 9, 1987, The PLAINTIFF is given an ultimatum by the Lancaster

county prison authorities, Robert Bayer, Yolanda Caterbone, and Mary Lynn Dipaolo of
posting the required bail only if The PLAINTIFF voluntarily admits himself into the
Psychiatric Unit of St. Joseph Hospital, or remains in the Lancaster County prison.
114.

The PLAINTIFF is released from Lancaster County prison, and immediately escorted

to St. Joseph Hospital and admitted into the Psychiatric Unit.


115.

On September 9, 1987, Yolanda Caterbone, Robert Beyer, and Mary Lynn Dipaolo

engage in conspiracy to commit fraud, false statements, and conspiracy to commit Count
IV - extortion, obstruction of justice, and false imprisonment.
116.

On September 15, 1987, The PLAINTIFF questions the legality of the ultimatum for

posting bail, and upon learning that it is unlawful, arranges for his discharge - Upon his
discharge, the St. Joseph Hospital administrators learn that Financial Management Group,
Ltd., had terminated his health insurance, and demand payment of $3, 064.60 for the six
days of hospitalization. The PLAINTIFF is not able to pay, and leaves the hospital and
returns to his residence of Conestoga, PA.
117.

St. Joseph Hospital engaged in collusion to commit fraud, Count IV - extortion,

libel, slander, and defamation of character, false imprisonment, obstruction of justice, and
false statements.
118.

On September 15, 1987, The PLAINTIFF receives an invoice from St. Joseph

Hospital for $3,064.00.


119.

On September 16, 1987, The PLAINTIFF receives a call from Howard Eisler, an

Investigator for the Pennsylvania Securities Commission who requests a meeting with The
PLAINTIFF.

A meeting is scheduled for September 29, and The PLAINTIFF arranges for

Robert Beyer and Millard Johnson to attend.


120.

On September 21, 1987, ISC and the British Ferranti firm agree in principal to

merge, creating what appeared to be a $1.5 billion defense/electronics conglomerate, after


six months of negotiations.
121.

On September 22, 1987,The PLAINTIFF and James Warner settle on the real estate

deal, of 433 w. Marion Street, which The PLAINTIFF had sold to James Warner, at a
distressed price, which still yielded a profit.

The profits of the transaction were paid

directly to Millard Johnson, with The PLAINTIFF getting none of the proceeds.

Millard

Johnsons funds were extorted by Commonwealth National Bank and Lancaster Aviation.
122.

The parties engaged in Count IV - extortion of funds, collusion to commit fraud, and

civil conspiracy.

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123.

On September 25, 1987, Art Kerst visits The PLAINTIFF at his residence and

accuses him and his cousin of being connected with the Mafia, and conspiring together, in
order to provide the financing of the $50 million shopping center in Florida, that was
originally owned by the Fisher/Sponougle Group, and diverting the profits of the deal away
from him (Art Kerst) and the Fisher Sponougle Group.
124.

The PLAINTIFF becomes infuriated, not only at the absurd allegation, but the

timing, when in fact The PLAINTIFF had bean fighting for his life for the past 4 months,
and to even consider such activities would be insane.
125.

On September 29, 1987, Howard Eisler conducts a meeting at the Residence of The

PLAINTIFF, with all parties consenting to have the meeting recorded by The PLAINTIFF.
126.

Howard Eisler was not able to provide a believable explanation of what he was

investigating or why he had contacted The PLAINTIFF. The PLAINTIFF explains all of the
circumstances regarding his prior meeting with ISC/Chem Con executive Larry Resch, and
details his allegations of wrongdoing of James Guerin/ISC/Chem Con6 and the discussions
of that meeting on June 23, 1987, with ISC executive Larry Resch. The PLAINTIFF also
discloses his ISC stock holdings, and his relationships with ISC and Chem Con associates.
127.

Howard Eisler, the Pennsylvania Securities Commission, and the Commonwealth of

Pennsylvania engaged in a cover-up, obstruction of justice, public corruption, collusion and


conspiracy to commit Count IV - extortion.
128.

Millard Johnson testifies to Howard Eisler during the meeting regarding a previous

meeting in August with Robert Kauffman, where Robert Kauffman tried to persuade Millard
Johnson to fabricate a story that a legitimate personal loan of $25,000 to The PLAINTIFF
in June of 1987, was instead intended for investment and embezzled by The PLAINTIFF.
Robert Kauffman wanted Millard Johnson to support this story to authorities.

The

PLAINTIFF spent more than 4 hours explaining and detailing all of his allegations and
business activities including how he founded and built Financial Management Group, Ltd.,;
his mortgage banking activities; the illegal repossession of his aircraft; all of the fabricated
arrests; and the chronology of events after the June 23 meeting with ISC executive Larry
Resch.

Howard Eisler ended the meeting and requested copies of documents from The

PLAINTIFF.
129.

On September 1987, Scott Robertson, begins work with American Helix founder,

David Dering, to secure financing for the venture and manufacturing facility to
manufacture CD Audio & CD-ROM Compact Discs, an extension of the "Digital"
technologies activities of The PLAINTIFF.
130.

David Dering solicited Financial Management Group, Ltd., to provide help in

securing the necessary $5 million of capital required .for the venture. David Dering was
referred to Financial Management Group, Ltd., by Norris Boyd (Financial Management
Group, Ltd., shareholder) and Bob Fogarty, who had previously been working with The

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PLAINTIFF on various financing arrangements. It was The PLAINTIFF that elected to allow
both Scott Robertson and Rob Long to participate in the venture capital markets. Scott
Robertson would later conduct negotiations with High Industries, Inc., to provide the entire
$5 million financial package. Scott Robertson also was named executive Vice President of
American Helix Technology Corporation, and would resign from Financial Management
Group, Ltd., in order pursue the venture on a full time basis.
131.

David Deering, Scott Robertson, and Financial Management Group, Ltd., engaged in

collusion and conspiracy to commit Count IV - extortion, and violated several anti-trust
violations.
132.

James Boyer, formerly the lead recording engineer for Billy Joel, was also recruited

to form the principals of American Helix, consisting of Dave Dering, Scott Robertson, and
James Boyer In mid December of 1990, David Dering will confirm the above formation of
American Helix to The PLAINTIFF, after The PLAINTIFF alleges violations at the 1934
Sherman Antitrust Act, concerning his activities in the digital technologies industries, and
the undo influence by Scott Robertson, Robert Long, and High Industries, as well as
criminal conspiracy, of all parties concerned in the destruction of his business affairs that
began in June at 1987.
133.

On October 2, 1987, District Justice Murray Horton conducts a preliminary hearing

for all criminal charges against The PLAINTIFF. Attorney Robert Beyer refuses to discuss
any issues regarding his individual lease of the Financial Management Group, Ltd., offices,
or any issues resulting in the illegal activities of anyone other than The PLAINTIFF District
Justice Murray Horton orders The PLAINTIFF to defend all of the criminal charges in the
next term of criminal court in Lancaster County. The PLAINTIFF ordered to be bound over
for the next term of criminal court of Lancaster County and remain free on bail.
134.

District Justice Murray Horton engaged in obstruction of justice, collusion and

conspiracy to commit Count IV - extortion, public corruption, and violated several antitrust violations
135.

On October 4, 1987, The PLAINTIFF meets with high school classmate and attorney

Mike McDonald at The PLAINTIFF's residence, to discuss legal action and recourse against
all involved. Mike McDonald accepts the case, and The PLAINTIFF provides all of the
relevant information and documentation.
136.

Mike McDonald will engage in negligence, and collusion to commit Count IV -

extortion.
137.

On October 12, 1987, The PLAINTIFF travels to New York city to the offices of

Intercon Special Services (white collar crime detective agency) in order to attempt to
obtain assistance in all of the circumstances. Intercon Special Services, which is staffed
with ax FBI agents, estimates that the services would cost at least $25,000.
138.

On October 16, 1987, The PLAINTIFF survives a near death collision on the New

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Danville Pike, when a driver ran through a stop sign at the intersection of Long Lane, while
traveling at a speed of 45 mph. The driver hit The PLAINTIFF's Jeep Cherokee directly in
the passengers door, sending The PLAINTIFF in a free tall, spinning a full 180 degrees and
landing upside down in a field, facing the opposite direction. The PLAINTIFF was trapped in
the car, while a passerby attempted to brake the windshield to get him out.

The

PLAINTIFF's car was completely demolished, and he sustained a whiplash. The PLAINTIFF
was now without any means of transportation, in addition to all of his other mitigating
circumstances.
139.

On October 18, 1987, The Unemployment Compensation Review Board formally

and officially decides against a claim for benefits by The PLAINTIFF and cites misconduct
and wrongdoing as the reasons; states that the PLAINTIFF managed the day to day
operations, and used the false arrests as the reason to deny benefits.
140.

The Pennsylvania Unemployment Office of the Department of Public Welfare

committed fraud, and were negligence in providing benefits.


141.

On October 27, 1987, Lancaster Aviation files a civil suit with District Justice Murray

Horton for alleged unpaid bills of some $5,000.


142.

In late October or early November, The PLAINTIFF was driving in the Southern end

of the County, in Conestoga, when he noticed a vehicle following closely.

It was about

9:00 pm in the evening, and the roads were deserted in this rural area. The PLAINTIFF
began turning, not going in any particular direction. The ensuing vehicle kept following,
and The PLAINTIFF quickly found himself in a high-speed car chase, that lasted at least 30
minutes. Finally, The PLAINTIFF arrived near Millersville, and was able to loose the vehicle.
143.

On November 9, 1987, The PLAINTIFF visits with Parent Federal Savings and Loan's

president, John Depatto, to discuss him problems in meeting his current mortgage
payments. John Depatto immediately disclosed to The PLAINTIFF that foreclosure
proceedings have officially begun, and that the full loan of approximately $110,000 is
immediately due. The PLAINTIFF stands up from the conference table and declares, "You
tell Mr. James Guerin he is in trouble", and abruptly walks out of the offices.
144.

John Depatto engaged in collusion to commit Count IV - extortion, and conspiracy

to commit fraud.
145.

On November 11, 1987, The PLAINTIFF meets with representatives of Tabor

Community Services, of Lancaster, Pa, in order to formally apply for assistance to the
Pennsylvania Homeowners Emergency Mortgage Fund, in order to subsidize his monthly
mortgage payments, in an effort to avoid becoming homeless. The PLAINTIFF supplies
Tabor community services with financial data and supportive documents relating to his
circumstances, which must be found to be out of the applicants control in order for
financial assistance.
146.

On November 18, 1987, ISC-Ferranti settlement takes place with Guerin becoming

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the deputy chairman of Ferranti and exchanges his is million shares of ISC stock for over
32.2 million shares of Ferranti stock.
147.

On November 19, 1987, The PLAINTIFF contacts attorney Jeff Jamounou of

McNeese, Wallice, and Nurick, who The PLAINTIFF retained as legal counsel for the
security law, and demanded a legal opinion as to the offices that The PLAINTIFF formerly
held, including his Financial Management Group, Ltd., Board of Directors seat. Jeff
Jamounou disclosed that he no longer represented Financial Management Group, Ltd., in
that capacity, and that Craig Russell was the attorney now handling issues such as that.
148.

On November 23, 1987, A Referees Decision by the unemployment Compensation

Review Board upholds a recent decision to deny The PLAINTIFF from collecting any
benefits, again citing misconduct and wrongdoing. The PLAINTIFF calls Howard Eisler, of
the Pennsylvania Securities Commission and demands an explanation for not returning to
obtain any documents as promised in the meeting of September 29th. The phone call was
recorded.
149.

On November 25, 1987, The PLAINTIFF receives a letter from the Pennsylvania

Securities

Commission,

Howard

Eisler,

citing

misunderstanding

and

lack

of

communication, and now requests that The PLAINTIFF submit a written complaint of all
allegations discussed in the meeting of September 29, 1987.
150.

On November 30, 1987, The PLAINTIFF fears that the conspiracy now involves local

and state authorities, and delivers 9,079 documents to the Good Sheppard Industrial
Services, of Allentown, PA to be transferred to microfiche in order to preserve the
authenticity of the documents.
151.

The PLAINTIFF feared that an attempt would be made to destroy all incriminating

evidence, and given the number of documents, and the lack of money, their safekeeping
was becoming at great risk.
152.

For security reasons, and to remain anonymous, The PLAINTIFF uses the Global

Entertainment Group, Ltd., company for the transaction with the Good Sheppard Industrial
Services company.
153.

On November

26, 1987 , The PLAINTIFF visits the Pennsylvania State Police

barracks in Lancaster, to file a formal complaint to the White Collar Crime Division. The
PLAINTIFF was treated as if he was making the entire story up, and received no help.
154.

On December 1, 1987, In continuing the efforts of the intervention of authorities,

The PLAINTIFF visits the PA State Capitol building and personally delivers documents to
the offices of: Pennsylvania Governor Casey; the Pennsylvania Securities Commission; and
Financial Management Group, Ltd., attorney Jeffrey Jamounou of McNeese, Wallice, &
Nurick, all of Harrisburg, PA. During the same day, at a press conference being held by
Mark Singleton, The PLAINTIFF approaches State Senator Sib Armstrong and Sen.
Armstrong refused to talk and literally ran away in the middle of the State Capitol.

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155.

On December 4, 1987, Financial Management Group, Ltd., holds its first annual

shareholders meeting, for the year ended June 30, 1987, at the Treadway Resort Inn
(Eden Resort Inn owned by Drew Anthon). In an effort to promote propaganda against
The

PLAINTIFF,

and

to

support

the

fabricated

allegations

of

insanity,

Financial

Management Group, Ltd., president hired armed security personnel to guard the doorways
of the meeting, insinuating that the meeting was under a threat of violence, and to
collaborate his recent allegations of Terroristic threats, which The PLAINTIFF was
previously arrested and awaiting trial.
156.

Financial Management Group, Ltd., engaged in libel, slander, and defamation of

character.
157.

On December 17, 1987, The United States Postal Inspector acknowledges receipt of

formal complaint from The PLAINTIFF regarding executives from Financial Management
Group, Ltd., illegally changing or address; opening of confidential personal and business
mail; and withholding and possibly destroying confidential personal and business mail at
The PLAINTIFF's leased property of 1755 Oregon Pike, Lancaster, PA, also the
headquarters of Financial Management Group, Ltd.,.
158.

On January 15, 1988, the PLAINTIFF drives to San Diego, California, and meets

with attorney Sandra Gray, and International Signal & Control, Plc., uses his dire
illegalities and to find access to due process of the law.

In an effort to avoid the political

consequences of obtaining legal counsel, The PLAINTIFF thought that it would be easier to
find adequate and effective counsel from out of state. In addition, The PLAINTIFF needed
some time away from his persecutors.
159.

On January 26, 1988, the Pennsylvania Homeowners Emergency Mortgage

Assistance Program formally and officially denies The PLAINTIFF of benefits citing the
following: " Applicant was terminated from job Financial Management Group, Ltd.,),
therefore was not suffering from circumstances beyond his control".
160.

On March 14, 1988, The PLAINTIFF is served notice by Lancaster Constables

regarding Parent Federal .Guerin' Bank) v. The PLAINTIFF Mortgage Foreclosure of his
residence at 2323 New Danville Pike, Conestoga, PA.
161.

On May 1988, The PLAINTIFF is forced to sell his residence, and subdues to the

undo influence that he was responsible for all circumstances, and moves to Florida with
his brother.
162.

On October 23, 1988 the PLAINTIFF, destitute, without a personal residence,

automobile, or any income, and with accumulated debts of more than $65,000 from all
related incidents in the 1987 "Blackmail", sells his Financial Management Group, Ltd.,
holdings to Robert Kauffman and is given $72,000 in proceeds at settlement. This by and
of itself will be proven to be Count IV - extortion. Robert Kauffman was in fear of The
PLAINTIFF exercising his large voting rights in the upcoming Financial Management Group,

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Ltd., annual shareholders meeting, which included the election off Financial Management
Group, Ltd., Board of Directors. The PLAINTIFF had approximately 19% of the outstanding
shares of Financial Management Group, Ltd., and had the potential to vote someone of his
selection to a Board seat. Scott Robertson had solicited the deal for both parties, and
acted as negotiator for both.
163.

On November 23, 1988 the PLAINTIFF completes a management-consulting

proposal for Scott Robertson, Tony Bongiovi, and American Helix for Power Station Studios
of New York.

Scott Robertson had solicited the PLAINTIFF to New York to review the

current management and to author a proposal to help Tony Bongiovi manage the
recording studio and all special projects.

The PLAINTIFF spent time in New York and

interviewed the Power Station management team and personnel.

The Digital Movie,

Mutant Mania project had already been terminated in 1987.


164.

On March 13, 1989, Scott Robertson, cofounder and executive vice president of

American Helix Technology Corporation, a wholly owned subsidiary of High Industries,


Inc., of Lancaster, Pa, recruits The PLAINTIFF for marketing help. The PLAINTIFF accepts
a weekly consulting contract, with no long-term commitment, in light of his efforts with
Radio Science Laboratories, Inc., Scott Robertson wanted The PLAINTIFF to help develop
the new and emerging CD-ROM business, which was essentially "Digital" technologies.
American Helix was one of 10 domestic manufacturing facilities located in the continental
U.S., for the production of CD-Audio International Signal & Control, Plc., (CD's or Compact
International Signal & Control, Plc.,), and one of only a few CD-ROM manufacturers.
165.

On April 17, 1989, the PLAINTIFF incorporates Radio Science Laboratories, Inc., to

further his interest in microwave technologies, and the telecommunications industry. The
company is a venture with James & Lynn Cross, both capable design engineers with over
30 years experience. The company was trying to secure financing for the development of a
manufacturing enterprise for Low Noise Amplifiers, or LNA's as they are commonly
referred.
166.

On July 8, 1989, William A. Clark, Guerin's former top INTERNATIONAL SIGNAL &

CONTROL, PLC., attorney, sues Guerin for $2 million, the balance Clark claims is owed him
in a $2.75 million settlement (over an employment dispute) accepted by Guerin in March.
Joe Roda is legal counsel for William Clark. Joe Roda was the first attorney that The
PLAINTIFF had gone to for help, who told The PLAINTIFF to quit fabricating things.
167.

On July 19, 1989, The PLAINTIFF, Scott Robertson, and American Helix agree on a

one year employment contract, which American Helix will never fulfill in its entirety, and
will be terminated in the following April.
168.

On October 10, 1989, British Labor unions urge Ferranti to drop all INTERNATIONAL

SIGNAL & CONTROL, PLC., related companies, claiming job loss in Scotland alone could
exceed 8,000 workers.

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169.

On October

16, 1989 , A 1987 report commissioned by Sebastian de Ferranti

surfaces showing that the company bearing his family's name was cautioned not to merge
with INTERNATIONAL SIGNAL & CONTROL, PLC., by Lazard Brothers. Ferranti chairman,
Sir Derek,Alun Jones comes under tire by stockholders who demand his resignation during
the company's annual meeting in London.
170.

On October 24, 1989 , Scotland Yard joins the U.S. in the Guerin probe. Federal

agents will travel to London in January to coordinate the investigation.


171.

On November 1989, Ferranti begins firing INTERNATIONAL SIGNAL & CONTROL,

PLC., executives still within the company.


172.

On December 1, 1989, Ferranti sues Guerin and three former INTERNATIONAL

SIGNAL & CONTROL, PLC., executives, including Larry Resch, for $198 million each,
claiming all of INTERNATIONAL SIGNAL & CONTROL, PLC., worth was a sham built on
bogus contracts.
173.

On April 1990, The American Helix Board of Directors, lead by S. Dale High/High

Industries, vote to terminate Scott Robertson of American Helix, continue the financing of
the CD-ROM business which The PLAINTIFF was directly managing.

The joint venture

agreement with Network Technologies, or Washington, D.C., had lost an estimated


$450,000 in the past 9 months, and the technologies, which were to be delivered, had
proven to be worthless.

Scott Robertson had solicited, negotiated, and administer the

deal, The PLAINTIFF had raised serious concerns at to the capabilities of the technologies,
the business, and Network Technologies, early in the project. High Industries then
conducted several meetings with The PLAINTIFF to purchase the business, however, The
PLAINTIFF had told the executive in a meeting on Good Friday, that he was solely
responsible for any business that was left, and any there was no real value. High
Industries agreed to pay The PLAINTIFF his weekly consulting tee only until June 30, in
hopes of negotiating an agreement to keep American Helix in the CD-ROM business, which
was only feasible with The PLAINTIFF, because of his knowledge and expertise in "Digital"
technologies.
174.

On May 5, 1990, the PLAINTIFF is awarded his first government contract for CD-

ROM technologies with the National Institute of Standards and Technologies (NIST), of
Gaithersburg, Maryland. NIST is the technology arm of the federal government, similar to
the National Institute of Health (NIH), of Bethesda, Maryland. Because of the technological
complexities of the project surrounding the UNIX system environment, Phillips DuPont
(PSO) was the only other competitor in the U.S.. Computer Scientist, John Garofolo, will
coordinate the project, which is responsible for the research and development of speech
recognition systems for the Defense Advanced Research Projects Agency Information
Science and Technology Office (DARPA-ISTO) The Automated Speech Recognition Group,
will supervise the project for MIST. The group will develop CD-ROM'S containing speech

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corpora for the scientific I community, including: Massachusetts institute of Technology
(MIT); Texas instruments (TI); SRI International; and other academic institutions.
175.

On May 21, 1990 the PLAINTIFF and American Helix Technology Corporation,

represented by David D. Dering, sign an agreement authorizing the PLAINTIFF and


Advanced Media Group to continue all CD-ROM activities and to market the services to the
markets-at-large.
176.

On October 1, 1990 the PLAINTIFF and American Helix Technology Corporation,

represented by David D. Dering, sign another agreement authorizing the PLAINTIFF and
Advanced Media Group to continue all CD-ROM activities with an agreement for payments
from all activities.

The PLAINTIFF was afforded office space, secretarial, office supplies,

marketing materials, and the continuation of all support personnel of American Helix
without expense to the PLAINTIFF. The PLAINTIFF was entitled to represent all CD-ROM
services to the markets-at-large.

The PLAINTIFF was to be paid on all replication,

premastering, and mastering charges to the clients. All other services were billed directly
by the PLAINTIFF.

The contract and agreement will continue until the negotiation of

another agreement is reached and agreed upon. Both David D. Dering and the PLAINTIFF
have signed and executed the agreement.

The agreement was dated and signed on

November 2, 1990. All previous invoices and work by the PLAINTIFF was grandfathered
into this agreement.
177.

On October 11, 1990, Department of Justice claims proceeds from the sale of his

Naples home after paying the $600,000 outlined in his guilty plea agreement to the Justice
Department. Ferranti has asked the court to assist in collecting over $189 million from
Guerin, an amount awarded the firm by a British court when it said Guerin failed to
convince the court he had nothing to do with the 31 billion fraud. The PLAINTIFF begins to
organize. all relevant documents, stored in some 30 boxes, regarding all circumstances
involving the "1987" blackmail and criminal conspiracy, in hopes of finally resolving all
outstanding issues, by taking action tar legal recourse. In response from the effects of
Post Traumatic Stress Syndrome, The PLAINTIFF had rescinded efforts for due process
immediately after loosing his home and businesses. In similar matter of being
brainwashed, The PLAINTIFF was fearful of pursuing due process of the law in fear of
continuing reprisals, intimidation, and retaliation. However, upon the public disclosure of
the Federal courts indictments into illegal ISC activities, the PLAINTIFF began to review his
case, and find distinct and substantiated activities associated directly to his disclosure of
fraud within ISC.
178.

On January

9, 1991 Lt. Madenspacher of the Manhiem Township Police

Department call The PLAINTIFF at his lab/office in him home at approximately 2:00 pm.
Lt. Madenspacher explains that he had received a copy of the letter to the Department of
Defense, that Detective Larry Mathias had forwarded to him. Lt. Madenspacher questioned

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his motives of the letter and stated: "What are you going to do.. We (Manhiem Township
Police Department) just don't want to see a multi-million do00000000023llar law suit come
down our way.." The PLAINTIFF responded, "You know that I was an individual leassee of
that property, and in addition I had never resigned any offices or my Board of Director's
seat of Financial Management Group, Ltd., .. You also know that I had met with Larry
Resch of ISC on June 2S, 1987, and that I made allegations of misconduct.." Lt.
Madenspacher responded, "We were forced into that (the arrests of The PLAINTIFF on
Sept.

, 1987), we were caught between a rock and a hard place, we were forced into

that". Lt. Madenspacher then changed the subject to "Digital" technologies, and described
the activities of the police department of using the same in the telephone surveillance of
criminal suspects. Lt. Madenspacher then requested to meet with The PLAINTIFF.

The

PLAINTIFF agreed, however due to his current busy schedule, confirmed he would contact
him later to schedule a meeting.
179.

On January 10, 1991 The PLAINTIFF sends a letter to Lt. Madenspacher of the

Manheim Township Police Department, to schedule a meeting for Thursday, Jan. 17th at
3:00 pm, at his office at American Helix Technology Corporation, at the Green field
Corporate Park. The PLAINTIFF requested a response only if the time was in conflict of his
schedule.
180.

ON January 17, 1991 Lt. Madenspacher fails to show up for the scheduled meeting

with The PLAINTIFF at Amen can Helix, and never contacted him before that date to
change the meeting, or called to apologize for not being able to keep the prior
commitment.
181.

On January 18, 1991 The PLAINTIFF sends documents concerning the Blackmail" of

1987 to several reporters of the Lancaster Newspapers,: Tim MeKeele; Earnest Schriber;
and Thomas Planner.

Tim MeKeele also received a tape with some excerpts of the

September 29, 1987 meeting with the PA Securities Commission, where The PLAINTIFF
discusses allegations of misconduct against J. Guerin and ISC.
182.

On January 19, 1991 the PLAINTIFF, Al Thornburg, with Dave Dering. On Saturday

morning, THE PLAINTIFF went to the American Helix facility to pick up some computer
hardware.

Upon attempting to unlock the side door entrance with his 24-hour access

security card, the door would not unlock. Assuming something may have been wrong with
the security system, THE PLAINTIFF drove to the residence of Al Thornburg (former SONY
DADC engineer from Terre Huette, Indiana), the engineer for American Helix.

THE

PLAINTIFF asked Al to drive over to see if his access card was operable. The PLAINTIFF
and Al Thornburg entered the building with Al Thornburg's access card and found that his
access card was inoperable throughout the building. Al then said, "Stan, your locked out".
THE PLAINTIFF said, "I was in here until 5: 00pm last evening and my access card worked
fine. THE PLAINTIFF proceeded to pick up the tape back-up and said "Let's go. I don't

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want to be arrested for burglary, like I was 3 years ago. I don't know what the Hell is
going on".
183.

As the PLAINTIFF and Al Thornburg left the computer room, Dave Dering appeared.

This was quite unusual, since Al Thornburg and the PLAINTIFF often work on Saturdays,
and Dave Dering had not been in the plant on a Saturday for the past few months. THE
PLAINTIFF said to Dave "Dave, why am I locked out?" He said "talk to Jim Boyer". The
PLAINTIFF, quite emphatically said, "why am I locked out?". "Stan, you'll have to talk to
Jim". THE PLAINTIFF said, "Dave, you are the president, my contract is with you, not Jim
Boyer".

Dave said "Now, Stan, just calm down.

This isn't a conspiracy against The

PLAINTIFF." THE PLAINTIFF told Al I'm getting out of here. The PLAINTIFF and Al
Thornburg left the building, and Al was especially suspicious of the events and especially
why suddenly Dave Dering showed up at the building on that particular Saturday, only
moments after we arrived at the building.
184.

On January 21, 1991 The PLAINTIFF Faxed a letter to David D. Dering, afraid of the

"LOCKOUT" and the lack of any events or activities that would explain such a drastic and
damaging action of American Helix citing Dave Dering in breach of the PLAINTIFFS
business agreement and in conspiracy to eliminate or sabotage the PLAINTIFFS business
and reputation. The fax also contained a cc: to High executives, that was never sent.
185.

On January 22, 1991 the PLAINTIFF and Dave Dering Dave Dering had a telephone

conversation; "Stan, how did you get in here last night?". Stan "Dave, what are you
talking about?, I won't go near that building, the last time I went back into my own
building after being illegally locked out, I ended up in jail". Dave Dering " How did you get
in here and steal your fax?". The PLAINTIFF replied, Dave, why would I want to steal the
fax that I wrote?" Dave Dering "You have caused a big problem. You put me in a difficult
position I don't know if I can rectify things with the 'High's' and especially Allon Lefevre.
I always went to bat for you how do I trust you?" A meeting was set up for 6:00 pm
later that day.
186.

January 22, 1991 the PLAINTIFF met with Dave Dering and he gave three (3)

reasons for the "LOCKOUT", although never willing to engage in any real conversations
relating to those issues:
187.

The computer system went down, causing a problem in the security system.

188.

Jim Boyer did not reinstall the PLAINTIFFS access identification number for the

security system.
189.

Jim Boyer was to talk to the PLAINTIFF on Friday, the day before the Lockout,

concerning eliminating your access to the facility.


190.

Dave Dering said "Jim Boyer said that he can take over the CD-ROM business no

problem". Dave Dering talked about trust and who to trust.

Dave Dering reluctantly

agreed to continue the business relationship and adhere to the agreements, however' only

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on an arms length basis.

THE PLAINTIFF was no longer allowed in the building except

during normal business hours. THE PLAINTIFF was no longer to have a private office.
191.

Dave Dering never addressed the issues or the circumstances that preceded the

"LOCKOUT", and never addressed the reasons as to why there was any reason to modify
the agreement concerning my business American Helix that was established back in June
of 1990.

There were no disputes, activities, or conversations that gave any indication

that American Helix, Dave Dering, or Jim Boyer intended to change or modify our
relationship.
192.

On January 24, 1991: The PLAINTIFF met with Allon Lefevre (Executive Vice

President of High Industries responsible for overseeing all subsidiaries). The PLAINTIFF
called a meeting Allon Lefevre to discuss the following:
193.

The R.R. Donnelly merger and acquisition of American Helix.

194.

The "LOCKOUT".

195.

Allon Lefevre asked questions regarding the PLAINTIFFS contact with R.R. Donnelly

and Barry Click (President of R.R. Donnelly GeoSystems, former MAPQUEST).

THE

PLAINTIFF quickly made it clear that Barry Click contacted the PLAINTIFF in December
after seeing the PLAINTIFFS advertisement in the CD-ROM Enduser magazine, published
by Linda Helgerson.

Barry Glick was elated to see someone in the local area that was

involved with CD-ROM technologies and asked to visit with the PLAINTIFF.

Allon asked

many questions about Donnelly and Barry Click. THE PLAINTIFF made it clear that during
the visit, and from the discussions regarding the strategic plan of Donnelly, THE PLAINTIFF
suggested that there might be an opportunity for a merger or acquisition with American
Helix. THE PLAINTIFF also discussed the capabilities for the facility to be a dedicated CDROM manufacturing facility.

THE PLAINTIFF notified Allon Lefevre that Barry Glick was

awaiting a call from the PLAINTIFF the next day concerning the appropriate contact to
discuss the subject of an acquisition. Allon assured the PLAINTIFF that the High's would
not contact Donnelly directly and would await a call from Barry Click.
196.

Regarding the "LOCKOUT" THE PLAINTIFF gave the three reasons that Dave Dering

had provided during our meeting a few days before to Allon Lefevre. THE PLAINTIFF told
Allon that after "THE PLAINTIFF had built a strong foundation for the CD-ROM business
everybody suddenly wants it back, six months ago, nobody wanted anything to do with it,
not to mention the capital that THE PLAINTIFF had invested in it".
197.

Allon Lefevre was only concerned with why THE PLAINTIFF had sent the Fax. "Why

did you send the Fax?

I just don't understand why you sent the Fax".

Allon was not

concerned with or wanted to discuss the issue of why THE PLAINTIFF was "LOCKED OUT".
Allon asked the PLAINTIFF the problems surrounding American Helix and what solutions
THE PLAINTIFF thought could help restore the company to stability. THE PLAINTIFF
discussed the lack of systems, the lack of a strong business foundation, and most

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Importantly the lack of management.

He asked the PLAINTIFF about Dave Dering and

THE PLAINTIFF responded, "Dave Dering is an engineer, not a manager, he has no real
management skills". Allon then asked me how to approach the meeting with Donnelly.
THE PLAINTIFF suggested that they just sit and listen to their ideas. THE PLAINTIFF asked
Allon to assure me that this meeting would be kept confidential between the two of us. He
said "THE PLAINTIFF will have to tell Dave sooner or later, and that he was not gong to get
in the middle of the two of us".
198.

February 15, 1991 the PLAINTIFF met with Jim Tritch & Allon Lefevre. Allon Lefevre

had requested a meeting to be certain that THE PLAINTIFF was not representing the High's
or American Helix. THE PLAINTIFF had told Allon that THE PLAINTIFF was not concerned
with the merger issue, that the Advanced Media Group was continuing discussions with
Barry Click on various information technologies, which were strictly my business.

THE

PLAINTIFF also informed him that Barry Click had told me "Stan, we are quite honestly
more interested in you rather than the facility or American Helix".

THE PLAINTIFF also

informed Allon that Barry asked if THE PLAINTIFF would make a trip the Chicago, the
corporate headquarters to discuss the technologies and specifically the manufacturing
technologies of CD-ROM.
199.

THE PLAINTIFF made it perfectly clear that the two (2) contacts for a merger or

acquisition that THE PLAINTIFF had provided to the High's were contacts that approached
the PLAINTIFF.

THE PLAINTIFF also notified Lefevre and Tritch that Dave Dering had

requested the PLAINTIFF to look for a joint venture partner as far back as November. THE
PLAINTIFF also made it perfectly clear that THE PLAINTIFF would not solicit any leads:
unless THE PLAINTIFF was to be compensated. Alien Lefevre suggested that it may help
the PLAINTIFF to look for contacts, and THE PLAINTIFF quite emphatically restated my
contentions that THE PLAINTIFF would not do any work without compensation.
200.

Jim Tritch acknowledged that THE PLAINTIFF was the only person responsible for

the development of the CD-ROM business, and the only person with any real technical
expertise in information technologies and CD-ROM, and that neither American Helix nor
High Industries had the capabilities to manufacture CD-ROMs without the PLAINTIFF. Jim
Tritch also admitted that the Advanced Media Group, Ltd., would have to be a purchased
separately in the case of any merger or acquisition of American Helix. Jim Tritch also
stated that in his initial meeting with Donnelly that they like me and wanted to continue to
work toward a business relationship. Both Allon and Jim stated that they would like to
continue to work with me in the CD-ROM business.
201.

On February 15, 1991 American Helix conducted a Staff Meeting. Through an

employee that was present during the meeting, THE PLAINTIFF had learned that Dave
Dering "spent 20 minutes "slimming", or slandering and defaming the character of the
PLAINTIFF, and called the PLAINTIFF a RUNAWAY EX-CONVICT THAT WOULD END UP IN

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JAIL SOON". Dave Dering also told the group that THE PLAINTIFF had almost ruined the
company, and THE PLAINTIFF should not be trusted. THE PLAINTIFF was also informed the
previous day that David Dering was telling persons that the reason that THE PLAINTIFF
was out of town in December was because "THE PLAINTIFF was on the run from
authorities".
202.

The PLAINTIFF was in Captiva, Florida, scanning documents and indexing the CD-

ROM AMG Legal Prototype Disc concerning the ISC Cover-UP.


203.

On January 19, 1991 High Industries American Helix illegally and without notice

locks The PLAINTIFF out of his office and the facility of American Helix, who was
currently under a joint venture agreement with The PLAINTIFF and his Advanced
Media Group, Ltd., for his digital technologies business.

This "Lock-Out" was similar to

that of Financial Management Group, Ltd., on July 1, 1987. Again conveniently when The
PLAINTIFF had raised issues and allegations involving Guerin and ISC.
204.

On January 21, 1991 In fear and confused about his involvement, and in respect to

the massive fraud of the ISC/Ferranti merger, The PLAINTIFF sends a package to Ferrantis
legal counsel in England by way of United Postal Service' Overnight International Delivery
Service (Tracking Number 1773 0619 670).The PLAINTIFF was in fear that a potential
"Cover-Up" by U.S. authorities, and specifically the Lancaster community, would place his
life in danger, and wanted to insure that the information concerning his knowledge of ISC
misconduct before the lSC/Ferranti merger, and his disclosure to local, state, and federal
authorities in the summer of 1987, at least would be received by Ferranti, reducing the
possibility of someone terminating his life in order so that these circumstances would not
be used as an asset in the present Ferranti Legal efforts.
205.

On Jan 22, 1991In an effort to support his allegations of misconduct and the

allegedly threatening activities of The PLAINTIFF, American Helix president Dave Dering
has all of the locks in the building changed by a professional locksmith, which is nothing
more than an act of propaganda. Later that day, The PLAINTIFF and David Dering meet.
David Dering resolves to only allow The PLAINTIFF in the building during normal business
hours, and does not allow him to occupy his own office. The PLAINTIFF has never been
given any reason why he was locked out in the first place.
206.

On February 1, 1991 ABC News 20/20 features the story "Weapons Sales to Iraq"

about the ISC/Cardoen cluster bomb technology and how it got to Saddam Husain.
207.

On Feb 17, 1991 The PLAINTIFF receives a letter from Sandra K. Paul, of the

Citizens Ambassador Program, a division of People to People International, notifying him


that he has been selected to participate in the upcoming Printing and Publishing Delegation
to the Soviet Union and Eastern Europe in the coming August. People to People
International is a nonprofit organization started by the late Dwight D. Eisenhower to
facilitate the communications of experts from various professions throughout the world.

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The objective of the delegation was to exchange ideas, information, and technologies of
the printing and publishing industries with American counterparts in the Soviet Union, and
various Eastern European countries.
208.

On February 22, 1991 Federal prosecutors seize $800,000 from Clark, claiming he

was privy to information about ongoing criminal acts within ISC that generated the tainted
cash.
209.

On February 1991 In an American Helix staff meeting, with all employees present,

but The PLAINTIFF, president David Dering had spent approximately 20 minutes alleging
that The PLAINTIFF almost ruined his company, and that he "is a runaway ex-convict, that
will end up in jail very soon". Engineer Al Thornburg, immediately following the meeting,
disclosed the above discussion.
210.

On May 23, 1991 At approximately 2:00 pm, Jay Curtis, (appearing as a

Department of Defense contractor, who had recently solicited the services of The
PLAINTIFF and his Advanced Media Group, Ltd., to provide engineering in the development
of "Digital" simulation and training applications for various U.S. Military Logistics bases)
had called The PLAINTIFF. The following is synopsis of the conversation: "Because of your
recent discussions concerning your knowledge and information about the ISC Scandal, and
an alleged "Cover-Up", I had to do a background check on you, to insure against any
problems when including you in by proposal to the U.S. Department of Defense...
Everyone backs up your story, and is looking over your documents now, including the CIA,
IRS, SEC, FBI, Scotland Yard, Attorney General, the British M-4, and others. They are all
verifying and confirming your "cover-up" allegations.. They don't know what to tell the
Press and Media "I also know that you submitted documents to Mr. Thomas Flannery of
the Lancaster Intelligencer Journal". "How did you know about the CIA and its involvement
with ISC, how did you know that, and what do you know?" Jay Curtis kept pushing The
PLAINTIFF on the CIA issue, and what he had known and how he knew, The PLAINTIFF
kept telling him that the whole situation was to emotional, and that he was afraid for his
life.

The PLAINTIFF had to eventually tell Mr. Curtis that he could not discuss this

anymore.

He abruptly changed the subject and hung up on Mr. Curtis. The PLAINTIFF

immediately went to a friends house, and disclosed that fact that he was in fear for his
life. He quietly sat on the steps with his friend, Abby (2 years old). Later that night, his
friend Dave Pflumm would take him to the corner bar for a few drinks, while unknowing to
The PLAINTIFF, Ted Koppel was disclosing the story of the CIAs involvement with ISC.
Several hours later, Ted Koppel broke the story about the CIA and ISC's covert operations
to sell arms to Iraq.
211.

Immediately following the conversation with Mr. Jay Curtis regarding the CIA and

ISC, The PLAINTIFF packed a suitcase and confidential information assets, in preparation
to leave Lancaster, in total and legitimate fear for his life.

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212.

On May 23, 1991 ABC News/Nightline and Ted Koppel feature the first in a series of

stories, relating to CIA knowledge of a covert operation to supply munitions to south Africa
implemented by ISC and Carlos Cardoen. The story featured Lancaster and ISC.

The

report ties Guerin to the National Security Agency project in the 1970s. ABC News, the
Financial Times of London, and the Lancaster Intelligencer News investigated the report.
Tom Flannery of the Lancaster Intelligencer Journal appeared on the program and was
given credits on the show.
213.

On May 24, 1991 The Lancaster Intelligencer Journal reports on the above story. At

approximately 1:30 pm, The PLAINTIFF drives out of Lancaster, en route to a safe haven,
and stops at a convenience store and reads the early edition of the Lancaster New Era,
learning for the first time of ABC News/Nightline story about ISC and the CIA the evening
before, just hours after his conversation regarding the same to Jay Curtis.
214.

On June 7, 1991 The PLAINTIFF is again arrested by the Stone Harbor Police. After

passing several sobriety tests, and two Breathalyzer tests, The PLAINTIFF is placed in a jail
cell, and refused to be released. Several hours later, The PLAINTIFF is cited for
outstanding arrests warrants of Avalon, NJ, dated back to August 14, 1987, by an officer
of the Avalon Police department who suddenly appeared. Both arresting officers demanded
$340.00 for the posting of bail.

The PLAINTIFF requested that the required cash be

retrieved from his car, located just a few blocks away. The Avalon police officer responded
by saying, "we can't let you go to your car, you may have a gun in there". The PLAINTIFF
was immediately escorted to the cape May county Prison, fingerprinted and processed.
215.

On June 8, 1987 The PLAINTIFF calls Mike Orstein, Lt. of the Stone Harbor police

patrol, and requests that he retrieve the required cash from his car, and post the required
bail. At approximately 2:30 pm, The PLAINTIFF is released on bail. On June 11, 1991 The
PLAINTIFF left the Stone Harbor Marina at approximately 12:30 am en route to Lancaster,
Pa, to retrieve some files concerning the ISC cover-up. Upon driving north on Route 47
(the normal route to Lancaster), approximately 10 miles outside the Cape May county
Courthouse, The PLAINTIFF noticed a car following him closely. Suspicious, The PLAINTIFF
decreased his speed from 55 mph to 35 mph, in order for the car to pass him. However,
the car remained directly behind, adjusting the speed accordingly. In an effort to elude the
car, without raising suspicion, The PLAINTIFF gradually increased his speed, while also
increasing the distance between the cars, resulting in the loss of his taillights to the
ensuing vehicle - Because of the winding road, The PLAINTIFF looked for an abrupt turnoff, in hopes of dashing the eluding vehicle, by loosing sight of his taillights. There was
little or no traffic on the route during the early morning hours, and The PLAINTIFF stopped
at an intersection, and noticed that the headlights of the ensuing vehicle were not visible
in his rear view mirror, meaning that his taillights were also not visible to the ensuing
vehicle. Immediately upon pulling from the intersection, The PLAINTIFF noticed a narrow

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dirt road that lead into a field of small trees, the perfect place to sit for the ensuing auto to
pass him, unnoticed. The ensuing vehicle pulled to the intersection, and continued north
on route 47, in the direction of Lancaster. The PLAINTIFF sat in his vehicle a few minutes,
until continuing on his travel, north on Route 47. Approximately five (5) minutes later, a
car traveling in excess of SS mph, approached The PLAINTIFF, traveling south on the same
road (2 lanes).As the two cars approached each other, and approximately 30 yards from
reaching each other, the approaching vehicle drove directly into the lane of The PLAINTIFF,
with its high beams on, and continued straight for his vehicle, or what appeared to be a
head-on-collision. The PLAINTIFF drove off of the berm of the road, missing a line of trees
by less than 12 inches (eluding a life threatening disaster), and passed the vehicle that
was still in the north bound lane, heading south. The PLAINTIFF, shaking and sweating
furiously, noticed the cars brake lights go on, and the car apparently turned around, and
began pursuing The PLAINTIFF again. The PLAINTIFF drove as fast as he could to Route
55, hoping to find traffic in order to hide and loose the pursuing car. The PLAINTIFF
arrived in Lancaster, at approximately 3:00 am, and again noticed a car sitting in the
parking lot of the vacant "Sportsman's Den", at the intersection of the New Danville Pike
and Prince Streets. Upon driving west on Hershey Avenue, The PLAINTIFF noticed the car
following him. In an effort to identify the license plate, The PLAINTIFF made a few turns in
the area of Hamilton Watch, and followed the car heading north on S. West End Avenue.
The car was a late model, gold or tan, Cougar or possibly a Buick Park Avenue. The
PLAINTIFF watched the car increase his speed, and finally changed directions and
proceeded to his residence, and parked a few blocks away, and walked through the woods,
to his apartment in the Hershey Heritage complex. The PLAINTIFF then used a flashlight,
in order not to reveal his presence, and returned to his vehicle, sometime in the early
morning, during daylight.
216.

On June 10, 1991 two independent U.S. courts uphold a $189 million award by

Britian's High Court against ISC executives Shireman and Larry Reach for their role in the
fraud. Ferranti makes its first open statement against Guerin saying a similar decision is
expected to uphold the High Court's decision against him.
217.

On June 19, 1991 -

The PLAINTIFF leaves Stone Harbor, in constant fear for his

life, and remains in seclusion, in various parts of the Eastern Seacoast, spanning from
Captiva Island, Florida, to Boston, MA, in order to prepare an official request for a
Congressional Investigation of all related matters.
218.

On Jul 11, 1991 The PLAINTIFF files an official request C300 pages) for a

Congressional Investigation into all of the ISC and preceding issues with U. S.
Representative Robert Walker CR-Pennsylvania), and Speaker of the House, U. S.
Representative Thomas Foley. Overnight Mail Service of the United States Post Office,
outside of Baltimore, Maryland, sent both requests.

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219.

On July 12, 1991 The PLAINTIFF returns to his home, in Lancaster, PA, at

approximately 1200 pm, after remaining in seclusion immediately following the phone
conversation of May 23, 1991 with Jay Curtis, regarding the CIA and ISC. ABC
News/NightLine features it's second story about Lancaster's ISC and Arms to South Africa
and Iraq.
220.

On July 18, 1991 U.S. Representative Robert Walker sends a letter to The

PLAINTIFF relating to his request for a Congressional Investigation into all of his
allegations of misconduct and criminal wrongdoing regarding his alleged ISC/Fraud "coverup". The letter said : "Thank you for your recent letter and information on International
Signal & Control corporation. I appreciate your thinking of me; however, since this case is
before the courts, it is unethical for me to interfere with the judicial process. If you think I
may be of assistance with other matters, please feel free to contact me".
221.

On July 25, 1991 Christian is released from prison after serving two years and a

day for his role in the Chem Con fraud and toxic waste dumping.
222.

On August 1, 1991 The PLAINTIFF receives a notice of a warrant for his arrest by

the Stone Harbor (NJ) Municipal Court, regarding summons #081370. The PLAINTIFF
called the Court Clerk, Pam Davidson, to explain the circumstances. The Court Clerk
refused to identify herself, and did not have time to listen to his explanation. She then
questioned why he (The PLAINTIFF) wanted to write to the Judge to explain. The
PLAINTIFF writes a formal letter to Judge Peter M. Tourison, of the Stone Harbor Municipal
Court explaining his allegations of misconduct, and the issues surrounding his recent arrest
of June 7th, and all of the arrests dating back to August of 1987. The PLAINTIFF had
described in detail his assertions and evidence that the arrests were conveniently
orchestrated while he was seeking legal recourse for the alleged ISC

"Cover-Up'. The

PLAINTIFF also explained his fear for not returning to the Stone Harbor Municipality, in
light of the fabricated arrests, and other questionable incidents. The PLAINTIFF requested
another means of settling all outstanding frivolous traffic violations, other than appearing
in Stone Harbor Municipal Court.
223.

On August 8, 1991 Stone Harbor Municipal Court Judge, Peter M. Tourison, sends

The PLAINTIFF an official letter acknowledging receipt of his previous letter and
explanations. Judge Tourison concluded his notice by demanding that The PLAINTIFF
appear in Court, as scheduled, "to have this matter taken care of in the proper manner
224.

On August 13, 1991 Ferranti announces it has recovered $650,000 hidden by

Guerin in a number of Swiss Hank accounts. Ferranti also announces a fiscal 1991 loss of
$282 million. The PLAINTIFF responds to Judge Tourison letter of August 8, and discloses
the recent attempt on his life, the past June, just outside or Stone Harbor, and states that
because of the apparent criminal conspiracy within the same municipality, The PLAINTIFF
formally notifies the Judge that he refuses to return to Court, as requested.

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225.

On August 15, 1991 Guerin and Cardoen are shown to have been deeply involved in

a failed $100 million arms procurement plot linked to the infamous Iran-Contra scandal.
226.

On August 16, 1991 The PLAINTIFF receives a formal notice and demand from

American Helix President David D. Dering, for the return or equipment, currently in the
possession of The PLAINTIFF, and notice of the termination of the business agreement,
dated October 1, 1990 between Stan J. Caterbone and American Helix Technology
Corporation. The PLAINTIFF receives a facsimile from Mike Hess (former ISC engineer who
frequented S. Africa and who solicited The PLAINTIFF in late 1989 for work), and refuses
to sign a non-disclosure agreement with The PLAINTIFF and the Advanced Media Group,
Ltd., as requested to continue a further relationship considering the recent activities from
the May 23rd phone call and the national media publicity regarding the ISC Scandal.
227.

On August 19, 1991 The PLAINTIFF sends a letter to attorney Timothy Lanza via

the Lancaster Bar Association, and asks for an explanation as to his misrepresenting to
The PLAINTIFF for the past month that his order for Advanced Media Group, Ltd., stock
certificates were ordered, when in fact The PLAINTIFF verified with authorized personnel of
the H. Burr Kein company that the order was never placed. Timothy Lanza had personally
disclosed to The PLAINTIFF on several occasions that he was awaiting the delivery of the
certificate kit via UPS. The PLAINTIFF responds to the previous letter of David D. Dering,
and his request for the return of American Helix equipment, currently in the possession of
The PLAINTIFF. The PLAINTIFF formally notifies David Dering that the equipment will be
held as collateral, according to statutes of the Pa. Uniform Commercial Credit code, that
the equipment will not he returned until the past due invoice {# 1018), of the Advanced
Media Group, Ltd., of July 12, 1991 for $4,914.00, which was due upon receipt according
to their business agreement, was paid in full.
228.

On August 29, 1991 A federal judge dismisses Christian's $93 million suit against

Guerin, but Christian vows to re file the suit.


229.

On September 13, 1991 ABC News/Nightline features another story about ISC, the

CIA, and Arms Deals, in preparation for the beginning of the-Confirmation Hearings of
George Bush's nomination or the Director of the Central Intelligence Agency, Robert Gates,
which begins just three days away, by the Senate Intelligence Committee.
230.

On September 16, 1991 The first day of the Robert Gates' Confirmation Hearings

brings questioning by Senator Murkowski, of the Senate Intelligence Committee, about


knowledge of the ISC operations by Robert Gates. Gates, whose candor about Iran-Contra
resulted in his 1987 withdraw when nominated for the same slot by then President
Reagan. In a less-than sincere line of questioning, Robert Gates denies any knowledge of
ISC, Guerin, or Carlos Cardoen, including any operations to sell munitions to Iraq or south
Africa. In addition, he denies any knowledge of any CIA involvement in the same.
231.

On September 19, 1991 The PLAINTIFF visits the office of Senator Bill Bradley (D-

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New Jersey), in the Hart Office Building, Washington, D.C., and delivers documents, tapes,
and a video, all relating to his allegations of an alleged "Cover-Up" regarding the ISC
Scandal. The materials were taken by assistant Jackie Widrow, who signed a receipt.
232.

On September 21, 1991 The PLAINTIFF delivers a contract for the consulting

services he has agreed to provide to J. Oman Landis, in order to insure against any
wrongdoing, and especially in light of Mr. Landis' assertion the previous Friday that "you
(The PLAINTIFF) are taking a break (from business) to rest your mind". This assertion
conveniently supports the alibi of mental insanity, that has been made by numerous
persons, including Mr. Landis' friends, the High's, who wholly own American Helix
Technology corporation. Several hours after delivering the contract to Mr. Landis, and after
beginning to work, as outlined in the contract, Mr. Landis called The PLAINTIFF into his
office and said "there were some developments over the weekend, why don't you continue
on your normal duties of driving (limousines), this has nothing to do with the contract that
you asked me to sign".
233.

On September 25, 1991 The PLAINTIFF mails a cover letter and accompanying

materials to attorney Howard Corny, of New York city, as previously discussed, via UPS
regular way service.
234.

On October 1, 1991 The PLAINTIFF receives a facsimile from David Dering,

President of American Helix, formally charging The PLAINTIFF with charges of 16,730.00.
David Dering also demands that the equipment be returned, and upon receipt, American
Helix would forgive $11,816.00 ($16,730 - $4914)(Caterbone's invoice) of unpaid charges
to The PLAINTIFF and or the Advanced Media Group, Ltd.,
235.

On October 1, 1991 The PLAINTIFF sends by certified mail, a copy of a recent

complaint (filed Sep. 6, 1991) to the New Jersey Department of Motor Vehicles, and a
demand for the title to his boat, and again allegations of criminal wrongdoing by the Stone
Harbor Marina, for not delivering title, given the bill of sale was satisfied on June 10, 1991,
and a fee for the title was paid as well.

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236.

On October 1, 1990 The PLAINTIFF personally meets with Ted Koppel, of ABC

News/Nightline, at the Washington National Airport, at approximately 5:30 pm. The


PLAINTIFF questioned Ted Koppel if he knew a Mr. Jay Curtis, and why he was questioned
about the CIA's involvement with the ISC affairs, just hours before the broadcast. Ted
Koppel denied any knowledge of Mr. Jay Curtis, and stated that Thomas Flannery was
involved in the broadcast by the Financial Times of London. The letter of August 28, 1987
to Diane sawyer was also mentioned. Ted Koppel requested the phone number of The
PLAINTIFF, and said that he would contact him later, due to his present time constraints,
and asked, "what do you want, and what is the story line?" The PLAINTIFF responded,
"Justice and protection, someone is trying to cover me up, and someone already made
attempts on my life... someone keeps getting information from me, while I'm left sitting in
Lancaster like a sitting duck".
237.

On October 2, 1991 The PLAINTIFF responds by facsimile, to the Oct. 1,

correspondence, to David D. Dering. The PLAINTIFF requested supportive documentation


regarding the suspicious charges of $16,730.00 as declared, in order to consider the
request for the return of the equipment. David C. Dering responds by facsimile,
demanding for The PLAINTIFF to meet him at the Holiday Inn, in Lancaster on Friday, Oct
4th, with the equipment in his possession, and states that he will deliver the required
supportive documentation of the charges as requested.
238.

On October 2, 1991 The PLAINTIFF responds by facsimile to Ted Koppel, as to his

question concerning the "story line".


239.

On October 27, 1991 The PLAINTIFF writes a letter to Sandra Woods, Associate

Managing Editor, of the Philadelphia Inquirer, regarding the recent feature story, "What
went wrong in America" The PLAINTIFF describes his experience and present situation
regarding the ISC scandal, and cites corruption as the cause of the present dire and
destitute circumstances controlling his life.
240.

On October 31, 1991 Guerin and 19 others, including Larry Reach, are indicted on

75 criminal counts by the Philadelphia based grand jury.


241.

On October 31, 1991 Laura McQueen, administrator for the New Jersey Department

of Motor Vehicles, called The PLAINTIFF at approximately 3:30 pm, to notify him that she
was trying to sort out the problem with his complaint regarding title to his boat. Ms.
McQueen acknowledged that the Stone Harbor Marina had submitted an application for a
title, apparently dated on or about June 10, however the identity of the boat did not match
that of The PLAINTIFFs. Ms. McQueen also admitted that there seemed to be evidence of
wrongdoing, but denied to state whether the matter was presently being investigated. Ms.
McQueen also stated that the title in question was being microfiche, and that within a few
days, they should be able to trace the title, and resolve the problem.
242.

On October 31, 1991 Robert Clyde Ivy, Terrance Faulds, Wayne Radcliffe, Gerald

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Schuler, and Thomas Jaslin enter a not guilty pleas to all charges handed down by the
Philadelphia grand jury.
243.

On November 24, 1987 Robert Shireman, ISC financial executive pleads his guilt in

the ISC $billion fraud and scandal. Anthony Stagq, ISC executive in charge of Singapore
operations, pleads guilty in the Arms Export violations.
244.

On November 27, 1987 ISC Executive Larry Resch pleads guilty to his role in the

massive contract fraud in the Ferranti/ISC merger of November, 1987.


245.

On December 3, 1991 Philadelphia grand jury hands down a "superseding

indictment", clarifying the money-laundering portion of the charges. The indictment states
that between November of 1986 and June of 1989, Guerin looped $450 million through
phony bank, vendor, -and customer accounts to give the appearance several of the bogus
ISC contracts were real.

The preceding information also allows for the possibility of an

indictment of William Clark, and possibly his attorney Joseph Roda. The largest of the fake
contracts was the Pakistan Missile deal, in which Larry Resch was charged and indicted by
the grand jury for managing.
246.

On December 3, 1991 Mike Hess, a former ISC engineer that also has done work

for The PLAINTIFF, visits The PLAINTIFF to deliver all materials in his possession which is
the property of the Advanced Media Group, Ltd., The PLAINTIFF and Mike Hess engage in
an argument when Mike Hess becomes annoyed at The PLAINTIFFs continued caution and
suspicion of Mike Hess's real motives and agenda for the relationship. The PLAINTIFF had
witnessed several incidents of inconsistencies with the attitude of Mike Hess, with specific
respect regarding The PLAINTIFF's efforts for justice and legal recourse concerning the
affairs of 1987. The PLAINTIFF admitted in several occasions that he will never trust
anyone, especially given his former association with ISC, and most importantly his
activities and travel to South Africa.
247.

On December 4, 1991 The PLAINTIFF calls the Citizens Commission of Human

Rights, after seeing the organization featured on the Murray Povich Show, and talks to Roy
Griffen. The organization's mission is to investigate abuses within the mental illness
profession. Roy Griffen requests information, and agrees to investigate his allegations. The
PLAINTIFF states that he will Federal Express a copy of this chronology.
248.

On December 5, 1991 At approximately 10:00 am, The PLAINTIFF sent a package

of information via Federal Express (tracking number 9734766S93) to: Roy Griffen, Citizens
Commission for Human Rights, 6362 Hollywood Blvd., Los Angeles, CA 90028, (800) 8692247. The package was received at 9:56 am (PST) by L. Mezkerlsl, at the front desk.
249.

On December 5, 1991 At approximately 4:52 pm, James Guerin pleads guilty to

eight (B) grand jury indictments of October 31. The indictments are as follows: Criminal
Conspiracy, Violation, Arms Export Control Act Violation, Comprehensive Anti-Apartheid
act. Money Laundering, Securities Fraud, Filing False Income Tax Return, Aiding and

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Abetting the Commission of crime. Sentencing is scheduled for February 25, 1992, with a
minimum of 14 years, and a maximum of Life in prison.
250.

On December 4, 1991The PLAINTIFF receives uninvited visitors at his residence,

cousin Sam Miller family, who in September left him stranded in Florida.

They

conveniently need a place to stay, while visiting in Lancaster, and purposely cause
distractions to his efforts for legal recourse.
251.

On December 11, 1991 The PLAINTIFF finally requests that Michelle and Jason

Miller vacate his residence.


252.

On December 20, 1991 The PLAINTIFF receivers a notice from the Internal Revenue

Service regarding a discrepancy in income reported on his 1989 Federal Income Tax
Return. The items in question were his "disability income" from Monarch life insurance and
American Helix "non-employee income".
253.

On December 23, 1991 The PLAINTIFF responds to the IRS letter and submits a

copy of the chronology of this conspiracy, along with the entire audio transcript (2 - 90
minute cassettes) of his meeting of September 29, 198? with the Pennsylvania Securities
Commission and requests assistance in his ordeal.

The correspondence was sent via

'Return Receipt Requested" in order to insure proof of delivery. The PLAINTIFF sends an
updated chronology to Roy Griffen of the Citizen's Commission for Human Rights.
254.

On December 28, 1991 The PLAINTIFF sends a formal notice to attorney Howard

Cerny, 245 Park Avenue, New York, informing him to return the previously submitted
information and tapes regarding this case, and also informing him that he no longer wishes
to discuss these issues with him or any member of his firm.
255.

On December 30, 1991 The PLAINTIFF travels to the U.S. 9:50 am courthouse in

Philadelphia, PA, and personally delivers the chronology and a copy of the "1987"
Pennsylvania Securities Commission meeting to Chief Judge Bechtle, who is presiding over
the ISC court preceding.

At 10:00 am The PLAINTIFF visits the U.S. Attorney Generals

office in the same building and files a formal complaint, "Criminal Conspiracy to "cover-up"
the International Signal a Control scandal.

The proper form is filed with the clerk.

Assistant U. S. Attorney General Gray asks The PLAINTIFF to briefly describe his
complaint. The PLAINTIFF gives Gray the chronology along with the tapes. The PLAINTIFF
briefly describes the meeting of June 23, 1987 with Larry Resch, the nay 23, 1991 phone
call from Jay Curtis, the arrests by Manheim Township, and the attempts on his life. Agent
Gray took notes, and said he is not familiar with the case, but would personally see that
the information is passed to the proper authorities involved in the case. During the
conversation, Mr. Gray asked the exact same question that was asked by both Joe Roda
and Investigator Eisler of the Pennsylvania Securities Commission) "But you did not work
for them (ISC), you were not involved with them?" The PLAINTIFF gave this response to all
questions by Mr. Gray: It's all in there (the chronology), all of the information and events".

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256.

On January 6, 1992 The PLAINTIFF sends a copy of the criminal conspiracy

chronology and a complete audio transcript of the PA SEC meeting of 1987 to the legal
counsel of the Pennsylvania Securities Commission via Certified Mail Return Receipt
Requested: P825 695 935.
257.

On January 8, 1992 At a "Town Meeting" in Columbia, Pennsylvania held by U. S.

Senator Arlen Specter, The PLAINTIFF personally delivers a copy of the criminal conspiracy
chronology to Anon Specter after the meeting and asks Arlen Specter to read the letter,
Mr. Specter replied, " I will do that".
258.

On January 9, 1992 The PLAINTIFF receives the Return Receipt from the

Pennsylvania SEC, signed by Sharon F. Heinspach on January 8, 1992.


259.

On November 8, 1997 the PLAINTIFF solicits Attorney Matt Samley, of the law firm

of Xelkallis, Reese and Pugh (Pflumm Contractors Corporate Attorney and David Pflumms
Attorney), to provide a legal opinion as to the circumstances involved in the cover up. Mr.
Samley quickly asks if anyone had called Stan Caterbone about the issues. Mr. Samley
agrees to review the documents and will provide a legal opinion of any criminal and
prosecutorial misconduct.
260.

On November 23, 1997 - the PLAINTIFF delivers materials to Mr. Samley and also

sends via Federal Express the same materials to Christina Rainville, of Shnader, Harris,
Lewis, and . With a letter requesting a legal opinion from Ms. Rainville. Stan Caterbone
had read the biography of Ms. Christina Rainville parts of which were published as part of a
story for the Lisa Michelle Lambert murder trial and was impressed with her experience in
the litigation of securities violations, software and computer cases, entertainment, and of
course the wide array of allegations of prosecutorial misconduct in the Lancaster County
District Attorneys Office and the East Lampeter Police Department. The PLAINTIFF knew
he needed someone that was not afraid to challenge and take on the Lancaster
Establishment.
261.

On December, 8, 1997 - Ms. Pam Pflumm call Dr. Albert Shultz regarding the

behavior of the PLAINTIFF.


262.

On December 15, 1997 - the PLAINTIFF telephones Jim Christian to again confirm

that he did not have knowledge of his meeting with Mr. Larry Resch. Jim Christian began
threatening the PLAINTIFF from public disclosure of these issues, he said

you have to

forget about it. Your life will be worse off than it is now, you better just forget it
263.

In December of 1997 The PLAINTIFF had made a journal of all of the mental and

psychological duress that the employees of the firm of Pflumm Contractors, Inc., had
engaged. The PLAINTIFF started to log incidents of mental duress in December of 1997
after the incidents became consistent and demonstrated not be random acts of mere
occurrences. This behavior and malicious treatment was an extreme divergence from the
previous 45 months of my tenure and a polarization of the PLAINTIFFS relationships with

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all employees involved, including Mr. David Pflumm.

Prior to these incidents the

PLAINTIFF was credited with saving the company from near bankruptcy (1993) and
leading the company to the highest level of profitability, marketability, financial stability,
and respect in the 20 year history of the company.

Pflumm Contractors, Inc. was

generating over $4 million dollars per year in revenues.


264.

On January 14, 1998 The PLAINTIFF visits with Fr. Edward Lavelle for advice and

guidance concerning his situation. the PLAINTIFF only asked that Fr. Lavelle call Mr. David
Pflumm, and ask he and is key employees refrain from inflicting any additional mental
duress upon his person Fr. Lavelle refuses unless he is told to do so by Dr. Al Shulz. He
offers no further assistance. 1:00 pm

A few hour later, the PLAINTIFF visits Dr. Al

Shulz for his quarterly appointment.

Immediately upon entering the appointment, and

before the plaintiff will speak any words, Dr. Al Shulz will contemporaneously accuse the
plaintiff and declare: Stan, you are very sick.

You are not well!

You need to take

additional medications. The recorded transcript will prove the horrid implications of these
conversations.
265.
266.

On February 20, 1998 the PLAINTIFF is forced to vacate his position of Controller of

Pflumm Contractors, Inc., due to the purposeful and intentional infliction of mental duress,
perpetrated as a direct reprisal against the PLAINTIFFS rightful pursuit of due process of
the law concerning all issues contained herein.
267.

On April 21, 1998 The Pennsylvania Department of Labor and Industry will again

illegally deny the Plaintiff of his legitimate claim for Unemployment Compensation Benefits,
which again is an act of reprisal against his rightful pursuit of fair access to the law, and
his disclosures of the incidents contained herein. The Pennsylvania Department of Labor
and Industrys 1987 rulings against the Plaintiff have been also proven to be in err, which
conveniently and intentionally subjects the Plaintiff to financial hardship and mental
duress, all purposefully hindering the Plaintiffs right to access the law. The record of the
plaintiffs claim for Unemployment Compensation Benefits is corrupted.
268.

On November 25, 2004, Thanksgiving day, the PLAINTIFF was inside his residence

with the doors locked.

At approximately 11:30 am Dave Pflumm, Lizzy Pflumm, and

Keagan Pflumm began knocking on the back patio door. The PLAINTIFF did not want to
accept the visitors and would not answer the door.

The visitors had not been at the

residence for at least 4 or 5 months and the PLAINTIFF had not been to the residence of
the Pflumms since July of 2002.

After the unwanted visitors would not leave, the

PLAINTIFF went downstairs to the back bedroom hoping they would leave. Lizzy Pflumm
and Keagan Pflumm then began banging on the lower daylight door and the front door.
The PLAINTIFF then began lifting weights.

After approximately 20 minutes Keagan and

Lizzy Pflumm appeared inside the back bedroom. The PLAINTIFF quickly questioned them

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how they got into the residence of the PLAINTIFF. Keagan Pflumm said he used a credit
card to open the back patio door. They both said that their father, Dave Pflumm was
upstairs sitting at the PLAINTIFFS kitchen bar. They walked upstairs and the PLAINTIFF
immediately questioned Dave Pflumm as to how they broke into the PLAINTIFFs
residence. Dave Pflumm responded that I have keys, everyone has keys to your house.
The visitors stayed for about an hour before leaving. This incident has been reported to
the Southern Regional Police Department and the PLAINTIFF had questioned the Southern
Regional Police Department if the incident was ever investigated.

The PLAINTIFF never

received a response.
269.

On December 15, 2004 Plaintiff sends a complaint to Agent Sarsfield of the

Pennsylvania Attorney Generals Office in Pittsburg regarding illicit telephone activities.


The PLAINTIFF made complaints and amended the formal Verizon Customer Relations
Complaint number C-006142-2004, which was made pursuant to the Pennsylvania Do Not
Call statute. The complaint alleged that his telephone calls were often being intercepted,
misdirected, or impersonated.

The PLAINTIFF also made complaints of harassing calls

from Out of the Area caller identification that were occurring several times a day with no
response after answering. The PLAINTIFF has had endured these activities for years.
270.

On February 12th, 2005, Pamela Pflumm invited the Plaintiff for dinner after the

Plaintiffs return from a trip to Florida on the same day.

Pamela Pflumm was attending to

the Plaintiffs cats and mail during his trip to Florida at his residence at 220 Stone Hill
Road, Conestoga, Pennsylvania.
271.

On February 12th, after dinner, Pamela Pflumms asked the Plaintiff to drive her

and a boyfriend of Abby Pflumm to Kegels Restaurant to pick up Abby Pflumm from work.
The boyfriend of Abby Pflumm and Keagan Pflumm entered the rear seats of the Plaintiffs
car and the boyfriend held a green tennis ball in his hand and aggressively put in the
Plaintiffs face and said I found a tennis ball in your back seat. The Plaintiff drove down
the driveway and Keagan Pflumm and Abby Pflumms boyfriend made a comment about
the Plaintiffs car audio system that was previously vandalized. The Plaintiff became upset,
turned around and told Pamela Pflumm to drive herself to pickup up Abby Pflumm from
work. When the Plaintiff arrived back home at his residence, the green tennis ball that
hangs from the Plaintiffs garage to align his parking, was suspiciously missing and was
reported stolen that night to the Southern Regional Police Department.
272.

On February 17th, 2006, as the Plaintiff drove down Main Street, in Conestoga,

while the Plaintiff noticed a four-wheeler driving in the horse pasture of the Plfumm
Property.

The Plaintiff stopped and questioned the unknown persons because it was a

school night and Pamela Pflumm was residing at the residence alone without her husband.
No member of Pflumm family was on the scene at that time. The Plaintiff did immediately
vacate the property as soon as a member of the Pflumm household walked out of the

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house indicated that the persons on their property did have permission.

A few months

previous to these incidents, Mr. David Pflumm separated from his wife and was not living
at the residence. The Plaintiff was called upon by Pamela Pflumm on several occasions to
help her around the house and property.
273.

On February 17, 2005, at approximately 2:20am Officer Fedor of the Southern

Regional Police Department abruptly entered the Plaintiffs home, awakening the Plaintiff,
and falsely accused the Plaintiff of harassment for driving on the residence of David and
Pamela Pflumm. Pamela Pflumm calls the Plaintiff during the altercation with Officer Fedor
on the Plaintiffs cell phone.
274.

Immateriality after the altercation with Officer Fedor, the Plaintiff wrote a letter and

sent it the Chief Fiorill (formerly of the Lancaster City Police Bureau) of the Southern
Regional Police Department.
275.

At 1:00 pm on February 17, 2005 the Plaintiff did visit the Lancaster County District

Attorneys Office and requested to meet with District Attorney Donald Totaro. The Chief of
Detectives, Mr. Michael Landis (Former Chief of the Lancaster City Police Bureau)
conducted a meeting in a conference room where the Plaintiff complained about the
conduct of the Southern Regional Police Department and the harassment of the Officer and
clearly stated that the Plaintiff was preparing a Federal Civil Action (05-2288) and was
concerned about obstruction of justice, anit-slapp, and civil rights violations concerning
Federal Civil Action 05-2288 which was filed a few months later on May 16, 2005 in the
United States District Court for the Eastern Court of Pennsylvania.
276.

On February 18,2005 the Plaintiff did meet with the Chief of the Southern Regional

Police Department, Chief Fiorill, at the precinct located at 3284 Main Street, in Conestoga.
The meeting was initiated by request of Chief Fiorill. Officer Robert Busser (formerly of
the Pennsylvania State Police) was outside Chief Fiorills office listening to the meeting.
277.

At the meeting of February 18th, 2005, Chief Fiorill did libel and slander the Plaintiff

by stating that I dont believe anything that you say, regarding the incidents of the week
of February 17th and the allegations contained in Federal Civil Action 05-2288.
278.

At the meeting of February 18th, both Chief Fiorill and Officer Robert Busser did

libel and slander the Plaintiff by stating that the Plaintiff was nuts and questioned the
Plaintiffs mental health. This assault on the Plaintiffs mental health was done to discredit
the Plaintiffs allegations in the Federal Civil Action 05-2288.
279.

At the meeting of February 18th, Officer Fiorill disclosed that he had called the

Plaintiffs brother, Mike in Plantation Florida (who has been residing in Florida for the past
18 years), to discuss the incidents without permission, thus violating the Plaintiffs civil
rights and privacy rights.
280.

At the meeting of February 19th Officer Robert Busser threatened and assaulted

the Plaintiff by taking his nightstick and raising it up in a position to strike the Plaintiff on

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the head. Chief Fiorill grabbed Officer Robert Bussers forearm just in time to stop him
from hitting the Plaintiff.
281.

Both Officer Busser and Chief Fiorill demanded the Plaintiff out of the office, thus

violating his civil rights, and placing the Plaintiff in harms way of future threats,
harassment, and numerous criminal activities.
282.

On February 18th, 2005, the Plaintiff visited the establishment of the Alley Kat Bar

and Restaurant, located on Lemon Street, Lancaster, Pennsylvania from approximately


10:00pm until 11:30pm.

The Plaintiff had a brief conversation with Ms. Kerry Egan

immediately before leaving to proceed directly home.


283.

On February 19th, 2005, at approximately 5:00am, Officer Fedor pounded on the

Plaintiffs front door to awaken him.

The Plaintiff refused to open the door and let the

Officer in due to the preceding incidents and went into his bathroom and called the
Pennsylvania State Police. The Pennsylvania State Police refused to answer the plea for
help to intervene in the altercations with the Southern Regional Police Department.
284.

Approximately 20 minutes later, Officer Fedor and Pamela Pflumm illegally entered

into the residence of the Plaintiff by breaking and entering.


285.

Officer Fedor stated he was responding to a 911 call about an attempted suicide.

The Plaintiff tried to tell Officer Fedor that he did not know what he was talking about.
Officer Fedor handcuffed the Plaintiff and was physically abusive by pushing and shoving
the Plaintiff directly in front of the Plaintiffs loveseat and handcuffing the Plaintiff. Officer
Fedor asked him why he sent an email to Kerry Egan threatening to commit suicide.
Pamela Pflumm was standing in front of the Plaintiffs back door. The Plaintiff kept trying
to tell Officer Fedor that he came home and was sleeping all night.

The Plaintiff and

Officer Fedor kept arguing about an incident that never occurred. Officer Fedor violated
several civil rights of the Plaintiff.
286.

Officer Fedor stated the Kerry Egan made a call to 911 at approximately 4:00 am

and stated that she received an email from the Plaintiff early that morning with a threat to
commit suicide. The Plaintiff called Comcast cable during the altercation to try to get an
activity list of the Plaintiffs online activities to prove that the Plaintiff did not send any
email to Kerry Egan. Officer Fedor slandered and libeled the Plaintiff by not believing his
account.

The Plaintiff kept asking why Pamela Pflumm was summoned to the Plaintiffs

home and received no explanation. The Plaintiff did not see Pamela Pflumm before that
she entered the residence with Officer Fedor.
287.

It was later determined that there never was an email, and the Southern Regional

Police Department never withdrew their allegations of mental health issues.


288.

On April 5, 2006 Officer Buzzer did knowingly and willing falsely imprison Plaintiff

and maliciously attack plaintiff and accompanied several police officers in theft of a white
envelope containing approximately $743.00 in cash in a police chase from the Conestoga

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Wagon Wheel Restaurant in Conestoga to Duke Street in Millersville, Pennsylvania, via
Kendig Road.
289.

On April 5th, 2006, Officer Fedor did make false statements to authorities in the

302 petitions to Lancaster General Hospital and to Crisis Intervention of Lancaster,


Pennsylvania with regards to the incarceration of the Plaintiff in the Psychiatric ward from
the period of April 5th to April 10th, 2006.
290.

On April 5th, 2006, Officer Busser did harass, threaten, and physically abuse the

Plaintiff in the apprehension that took place on South Duke Street, Millersville,
Pennsylvania and did knowingly draw his weapon upon the Plaintiff without any threat,
merely to incite public attention to the Plaintiff that defamed his character, and slandered
his name.
291.

All of the preceding acts of retaliation by the Southern Regional Police Department

were a direct result of undo influence upon the Plaintiff and his attempts to remedy causes
of action that have been disclosed in the Federal Civil Action 05-2288, and the Federal
False Claims Act filed in the United States District Court for the Eastern Court of
Pennsylvania.
292.

On April 5th, 2006, Defendants did falsely imprison Defendant at Approximately

3:15 EST at the emergency intake unit of the Lancaster General Hospital, Duke Street,
Lancaster County, Pennsylvania.
293.

On April 5th, 2006, upon request, staff of the Lancaster General Hospital failed to

produce any official documentation to support the apprehension of the Plaintiff or the
holding of the Plaintiff in said facility.
294.

The Defendants did open locking cell and plaintiff again asked for documentation,

plaintiff walked out of the holding cell, and not documentation was produced, agent for
defendant picked plaintiff up and literally threw plaintiff back into holding cell.
295.

Between 3:30pm and 7:15pm Dr. Riley examined plaintiff by asking the following

questions:
296.

Do you drink alcohol?

297.

Do you take drugs?

298.

May I listen to your heart and drugs?

299.

The preceding examination took under 2 minutes and was not near sufficient for

the requirements as outlined in the 302 petition, whether legal or not.


300.

Mental Duress: Agents, employees, and staff of the Lancaster General Hospital did

engage in planned and occasional events to inflict, cause, and provoke extreme mental
duress.
301.

Agents, employees, and staff did obstruct justice and cause plaintiff to suspend,

neglect, and or cease all activities relating to CA 05-0288 and TMT 05-23059 in an overt
attempt to interfere with Plaintiffs constitutional right to due process.

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302.

Agents, employees, and or staff did subject Plaintiff to a life threatening

environment when patient William X was intentionally given a ball point pen immediately
after Angela X administered a drug, and William X stood 1 foot away from Plaintiff and
held ball point pen as a knife. Plaintiff had to immediately remove himself from the
immediate area.
303.

Agents, employees, and or staff subjected Plaintiff to further harm by condoning

and further provoking situation. As of April l0th, 2006, Plaintiff is still falsely imprisoned.
304.

Agents, employees, and or staff did take from Plaintiffs possession a white bank

envelope containing Seven Hundred and Forty-Three dollars ($730.00), which was not
included in Plaintiffs Possession Form.
305.

On July 23rd, 2006 PLAINTIFF speaks with Governor Ed Rendell at a Campaign

Speech at Binns Park, in Downtown Lancaster, and requests his assistance in his Civil
Rights Obstruction of Justice Complaint filed a few weeks earlier in the Office of Attorney
General.
306.

On October 14th, 2006 PLAINTIFF files a RICO complaint in the United States

District Court against Shawn Long, attorney for Fulton Bank, MDJ Leo Eckert, Commins,
Simms, Case No. 4650.
307.

On October 17th, 2006 PLAINTIFF attends a Bail Supervision (of the Lancaster

County Sheriffs Department) Intake meeting at the Bail Administrators Office in the
Lancaster

County

Courthouse.

PLAINTIFF

serves

the

Lancaster

County

Sheriffs

Department, the Lancaster County District Attorneys Office, and the Lancaster County
Public Defenders Office Civil Actions. The Lancaster County Public Defenders Office literally
took the Certificate of Service signing sheet from PLAINTIFF and PLAINTIFF immediately
told Judge Joseph Madenspacher about the incident while he walked to the Bus Terminal to
go the Office of MDJ Commins.

The document was never returned even after several

emails to the contrary by the Public Defender, Mr. Karl.


308.

On October 20th, 2006 PLAINTIFF files a Federal False Claims Act for Whistle-

Blowing against ISC in the United States District Court For The Eastern District of
Pennsylvania, Case No. 06-4734.
309.

On October 26th, 2006

The Pennsylvania Superior Court received a Brief for the

Appeal Challenging the Fulton Bank Judgment of June 29, 2006.


310.

October 30th, 2006 The Pennsylvania Superior Court sends a letter to PLAINTIFF

requesting (7) more copies of the brief, which PLAINTIFF will not receive until January 4 th,
2007. An amended complaint to PLAINTIFFs Southern Regional Police Department Civil
Action, Case No. 06-3401, is due in the Court of Common Pleas of Lancaster County on
exactly this date. An Unsecured Bail Bond was revoked by Officer Adam Cramer of the
Southern Regional Police Department and (2) Bench Warrants were issued for the Arrest
of PLAINTIFF by Adam Cramer of the Southern Regional Police Department and MDJ Leo

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Eckert, Jr.. PLAINTIFF filed the Amended Complaint and mailed it from the Bausman Post
Office Substation, and did not go to the Lancaster County Courthouse in fear it would not
get filed. At 2:20pm (2) PA Constable arrest and apprehend the PLAINTIFF at 1250
Fremont Street, Lancaster, PA, and take him to Magisterial District Justice Eckerts Office
on the (5) Bench warrants for summary citations and then COMMITT The PLAINTIFF to the
Lancaster County Prison, stating that an Indigent Hearing will be held within 10 days, and
challenges the PLAINTIFFS Indigent status and his Superior Court Cases.

Magisterial

District Justice Eckert complains to the PLAINTIFF about being named a Defendant in
Federal Case No. 06-4650, and remarks that the PLAINTIFF may have to be taken to
Dauphin County Prison for suing all of the District Justices in Lancaster County. He also
said You are not even close to getting to the Superior Court.
311.

On November 1st, 2006

PLAINTIFF appears before Judge Paul K. Allison who

reinstates his Bail Bond as Secured, which required PLAINTIFF to post $5,000 to get out of
the Lancaster County Prison instead of just signing an Unsecured Bail Bond, which should
have happened, and is not released from the Lancaster County Prison, as expected.
312.

On November 6th, 2006 PLAINTIFF files his first Appeal for Reconsideration to the

ORDER of Judge Paul K. Allison to Reinstate the Bail Bond as Unsecured, and Release him
from Lancaster County Prison.
313.

November 20th, 2006 The United States District Court for the Eastern District of

Pennsylvania records 28 U. S. C. 2241 Habeas Corpus Petition Case No. 06-5138


(Challenging the Detainer and Imprisonment) filed from the Lancaster County Prison on
November 14th, 2006. This case is still
314.

On November 30th, 2006 Judge Paul K. Allison Denies PLAINTIFFs Appeal to

Reinstate Bail as Unsecured.


315.

On November 8th, 2006 PLAINTIFF is transported to Magisterial District Justice Leo

H. Eckert, Jr., and signs a document that was missed on October 30th, 2006, and is not
given an Indigent Hearing as promised.
316.

On December 2nd, 2006 PLAINTIFF files an Appeal to Judge Paul K. Allison ORDER

of November 30th, 2006.


317.

On December 4th, 2006 the Lancaster County Sheriffs Department is ORDERED to

transport PLAINTIFF to both residences, 1250 Fremont Street, and 220 Stone Hill Road to
obtain files and evidence for a Trial, as a Pro Se Litigant and representing himself on the
East Lampeter Township summary citations.

There were no Sheriff Sale Posting on 220

Stone Hill Road, and both residences look fine.


318.

On December 5th, 2006 The Lancaster Intelligencer Journal publishes the Story The

Next Sound You Hear regarding former business partner Tony Bongiovi, which is central
to all of the litigation in the United States District Courts. The worlds of pro audio and
consumer electronics were bridged at New York City's Avatar Studios in December, where

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Bongiovi Acoustics unveiled the Digital Power Station car radio. Demonstrated by audio
icon Tony Bongiovi (pictured) in Avatars Studio A (former Power Station Studios), the
patent-pending technology being manufactured by JVC made a very impressive debut.
319.

On December 6th, 2006 Honda Financial repossess a Honda Odyssey stored at the

St. Dennis Towing Companys facility from August 31, 2006; the Honda was take because
of the illegal repossession of the drivers license and there were no funds available for the
tow that was just a few blocks away. The Honda was protected under the pending Chapter
11 Bankruptcy Petition and was conveniently taken while incarcerated. The PLAINTIFF had
talked to Honda Financial in August and there was no problem with the lease, even though
the PLAINTIFF had not made a payment since May of 2005.

The St. Dennis Towing

Company was charging $25.00 per day, and has never filed or sent the PLAINTIFF an
invoice for the storage, which is very suspect.
320.

On December 8th, 2006 PLAINTIFF files a Writ of Mandamus against

Magisterial

District Justice Leo H. Eckert, Jr, and Mary Commins for the fraudulent activities leading to
the false imprisonment of October 30th, 2006, and Bench Warrants.
321.

On December 12th, 2006 PLAINTIFF files for Continuances in all of the following Civil

Complaints in the Commonwealth Court of Common Pleas of Lancaster County,


Pennsylvania: CI-06-07330; CI-06-08742; CI-06-08490; CI-06-07376; CI-06-07188; CI06-06658; CI-06-04939; CI-06-03403; CI-06-03401; CI-06-03349.
322.

On December 13th, 2006 The Lancaster County Sheriffs Department (Maluskus)

and Chief John Fiorill tried to get PLAINTIFF to change his address to the Lancaster County
Prison and Judge Perezous refused to get ORDER PLAINTIFF to comply with the demand
and Judge Perezous CONTINUED the Appeal Hearing because PLAINTIFF did not have any
files to conduct a Trial.
323.

On December 20th, 2006 The Lancaster County Sheriffs Department (Hiem & N/A-

names given by Sheriff Simone) refused PLAINTIFF to wear his suit into the courtroom, or
take his files into the Pre-Trial Conference before Judge Farina, which caused PLAINTIFF to
forget to discuss material motions for the Trial, and caused the PLAINTIFF to be defamed
by appearing in a Lancaster County Prison uniform before the Court and in front of 20 or
so other people in the Courtroom.
324.

On December 20th, 2006, while in the Lancaster County Prison, the Lancaster

County Sheriffs Department and Fulton Bank conduct a Sheriff Sale for 220 Stone Hill
Road, Foreclosure CI-06-02271, with NO notification before or after the SALE to
PLAINTIFF; and sold the property to Central Penn Settlement Company of Akron,
Pennsylvania.
325.

On December 28th, 2006 Judge Paul K. Allison overturned his previous ORDER and

Granted PLAINTIFF his Appeal ORDER and signed the Unsecured Bail ORDER and the
RELEASE from Lancaster County Prison.

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326.

On December 29th, 2006 PLAINTIFF is RELEASED from Lancaster County Prison,

and walks to the Lancaster County Courthouse to report to Court Administration and the
Prothonotary Office to get a print out of all of the Civil Dockets for all cases in Civil Court,
including the Fulton Bank Foreclosure and finds out for the first time that the Sheriff Sale
on December 20th took place. PLAINTIFF retrieves a check for $19.34 from Attillio Grossi,
which is all the funds has available for food, and all other necessities.
327.

On January 2, 2007 PLAINTIFF files and records (4:09pm) a Petition To Set Aside

Sale for 220 Stone Hill Road, Conestoga in the Pennsylvania Court of Common Pleas of
Lancaster County and personally serves Fulton Bank and the Lancaster County Sheriffs
Department.
328.

January 4th, 2007 At 1:15pm PLAINTIFF visits 220 Stone Hill Road and finds 2

unidentified individuals on his property loading the entire contents of 220 Stone Hill Road
onto 2 Penske moving trucks, to an unidentified location, and is ordered off the Property
for Trespassing. The 2 individuals said they were from Noble Real Estate Company. Mr.
Joseph Caterbone accompanied him as a witness and driver. PLAINTIFF takes several
pictures of the individuals and the Penske Trucks. At 1:35pm PLAINTIFF retrieves his mail
from the Conestoga Post Office from dating back to October 25th, 2006 up to the present
and temporarily forwards mail to 1250 Fremont Street, Lancaster, PA. PLAINTIFF visits the
Lancaster County Sheriffs Office and speaks to Lt. Lancaster and Mr. Bergman about the
incident at 220 Stone Hill Road and is told that Southern Regional Police have already
responded, and would not give any information about the incident. At 3:00pm PLAINTIFF
attends the Trial for Criminal Case No. CP-36-CR-0003179-2006 (Fleeing & Eluding filed by
Sgt. Busser of Southern Regional Police Department on April 5 th, 2006) in Courtroom 1 of
the Lancaster County Courthouse and moves for a Motion for a Continuance due to the
incident at the property at 220 Stone Hill Road an hour before.

The Honorable Judge

James P. Cullen Denies his Motion.


329.

On January 5th, 2007 At 8:30am PLAINTIFF files and records an Addendum to the

Petition To Set Aside Sale for 220 Stone Hill Road, Conestoga in the Pennsylvania Court of
Common Pleas of Lancaster County and personally serves Fulton Bank and the Lancaster
County Sheriffs Department regarding the theft of all of his personal possessions,
including business files of Advanced Media Group, and all Legal files and evidentiary assets
for all pending litigation. At 9:00 am the Lancaster County District Attorney Deborah
Muzereus moves for A Continuance in the Trial for Criminal Case No. CP-36-CR-00031792006 and the Honorable James P. Cullen Grants a Continuance until the February Trial
Schedule.
330.

On January 7th , 2007 PLAINTIFF files a claim with Harleysville Insurance

Homeowners Policy HOAI 93468 for the theft of his personal possessions and the property
at Stone Hill Road. PLAINTIFF files for a Change of Venue for the Hearing scheduled for

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January 18th, 2007 in Intercourse before Magisterial District Justice Leo H. Eckert, Jr..
PLAINTIFF does not have all of his evidentiary files and no transportation because of the
illegal revocation of his Red Rose Transit Authority Monthly Bus Pass.
331.

On January 8th, 2007 PLAINTIFF files an Emergency Petition for Food Stamps and

other in the Pennsylvania Court of Common Pleas of Lancaster after his Food Stamps and
Red Rose Transit Authority Monthly Pass was illegally terminated, thus leaving him without
food and transportation for all court preceding. PLAINTIFF files for a Continuance for
Summary charges by District Justice Leo H. Eckert Jr., a Defendant in U.S. District Civil
Action 06-4650, scheduled for January 18th, 2007., again for not having access to all of his
evidentiary files and without transportation. PLAINTIFF files and sends his Brief to the
Superior Court of Pennsylvania Case No. 1463 MDA 2006 for the challenge to Fulton
Banks 220 Stone Hill Road Foreclosure, via U.S. Postal Priority Mail Return Receipt No.
0306 2400 003 1072 4451; the request stated: Other - We need 7 copies of this brief,
also all copies need to be bound on the left like a book and if you use staples they must be
covered with tape. PLAINTIFF borrows $50.00 from Joseph Caterbone for food, paper,
and postage for the Superior Court Brief.
332.

On January 9th, 2007 PLAINTIFF files for Continuance in all of his pending Civil

Actions before the United States District Courts for the Eastern District of Pennsylvania;
05-2288; 06-4650; 06-5138; 06-4734; 06-CV-4154; 06-5117; 06-2236; 05-23059BKY.
PLAINTIFF files for a Change of Venue and Continuance for Summary Citations (TR0008735-2006; TR-0008578-2006; TR-0008721-2006; TR-0008503-2006; TR-00075282006) Scheduled for a Hearing on January 23, 2007 before District Magistrate Richard H.
Simms, a Defendant in U.S. District Civil Action 06-4650. PLAINTIFF receives a Notice to
Change the Hearing Scheduled for January 18th, 2007 from Magisterial District Justice Leo
H. Eckert, Jr. to Isaac Stoltzfus of Intercourse. PLAINTIFF Petitions the Pennsylvania Court
of Common Pleas of Lancaster County to vacate the Bail Supervision Ordered by
Magisterial District Justice Mary Commins on October 10 th, 2006. The Bail Supervision was
without merit or cause.
333.

January 10th, 2007 PLAINTIFF reports a theft of the Digital Recorder used

containing an authentic and original audio recording of the incident for the Case No. CP36-CR-0003179-2006 (Fleeing & Eluding filed by Sgt. Busser of Southern Regional Police
Department on April 5th, 2006) to Officer Cole of the Lancaster City Police Department who
responded at approximately 10:25pm to 1250 Fremont Street and filed the incident as
Case No. 0701-014878.
334.

January 11th, 2007 The Honorable Judge James P. Cullen Orders PLAINTIFFs

Petition to vacate the Bail Supervision as Denied Case No. 4771-2006. PLAINTIFF writes
the following in an email to the Red Rose Transit Authority: I am having a problem with
my monthly passes.

16-cv-4014 UPDATED COMPLAINT

I have not received my January Monthly Pass, and my forwarded

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mail has not been received from 220 Stone Hill Road, Conestoga. Today, your driver Dave
on the 3 8th Ward/Park City 8:35 bus made me pay him for the fare. Some drivers let me
on with my December Pass and my Letter of Acceptance from September of 2006. I never
received a termination letter, and on January 5th, filed an Emergency Petition against the
Lancaster County Assistance Office to have all benefits that have been terminated,
reinstated. What is the status of my Monthly Pass? Below is an excerpt from the Civil
Action, Case No. CI-07-00150 in the Court of Common Pleas of Lancaster County,
Pennsylvania. The Petitioner has not received his January Red Rose Transit Authority
January Monthly Bus Pass, sponsored by the RRTA and the Lancaster County Assistance
Office. The Petitioner did receive his December Monthly Bus Pass, and complained to the
Red Rose Transit Authority Terminal Station on Queen Street, Lancaster, Pennsylvania, on
January 5th,2007. The staff worker told the Petitioner that his Monthly Pass was deleted
because he was incarcerated. The Petitioner explained that the Red Rose Transit Authority
Monthly Bus Pass was issued for a (2) year period. The incarceration was not valid and I
was released upon the Success of my Appeal, which was signed by the Honorable Judge
Paul K. Allison on December 28th, 2007. The PLAINTIFF, in the Pre-Trial Conference
moves for a Continuance for 0004771-2006 before Judge Ashworth and it is GRANTED.
335.

January 12th, 2007 PLAINTIFF receives the following email from Ms. Gail Parenteau,

of Bongiovi Acoustics: What is Advanced Media Group? It is our policy not to open
unsolicited attachments. What's your tel. no. I've been with Tony since 1986 and neither
of us remembers what this is. I've highlighted your type-os in red below. PLAINTIFF
responds with the following email to Ms. Gail Parenteau: I (Financial Management Group,
Ltd.,) was at Power Station from February until July in 1987 working extensively with
Tony, Ellen, and all of the Producers from Flatbush Films in Hollywood. Tony named me
Executive Producer of the project, and that is in the budgets. Now, are you really
associated with Tony, or are you covering for someone? I have still photos, audio recorded
meetings with Bob Walters (Co-Owner of Power Station Studios), business plans for
"Mutant

Mania",

Tony's

Digital

Movie,

with

budgets,

screenplays,

joint

venture

agreements, Patent and Copyright materials for Power Station Studios and Tony. I also
have documents for the Pier in Wildwood, which Tony owned. I personally authored many
of these materials with Tony, at his request. I spent many days and nights working at
Power Station on this project. I had a Navajo Chieftain twin turbo prop that I flew to Power
Station for some of my meetings, the other times me and Scott Robertson drove. I even
have another management consulting proposal that I developed for Tony in 1989, when he
wanted me to restructure Power Station from top to bottom. If, you were not privy to
these projects, then maybe you should at least talk to Tony.

I was just providing a

professional courtesy to Tony, especially, since I have admitted many documents


pertaining to my claims in the United States District Court for the Eastern District of

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Pennsylvania. Tony is not a Defendant in my claims. I have authored a Joint Venture
Proposal for Sony, which details the Power Station Digital Music System, and I have
noticed what Tony is doing. I will not call, for security reasons, I cannot tell who is on the
other end. You can have a legal representative or Tony forward correspondence to:
PLAINTIFF, 1250 Fremont Street, Lancaster, PA 17603.
336.

January 13th, 2007 PLAINTIFF visits the Red Rose Transit Authority Terminal at

Queen Street again attempting to get his January Monthly Bus Pass, which he thinks is
missing in the mail. PLAINTIFF borrows $20.00 from Richard Hobday, for food, postage,
and paper; and ride home from the Lancaster County Courthouse. PLAINTIFF receives a
letter and a Distribution Schedule from the Lancaster County Sheriffs Office that states:
On December 20,2007 your property located at 220 Stone Hill Rd. was sold at Sheriff
Sale to a third party buyer, Central Penn Property Services, Inc. for $156,000.00.
Attached, you will find a Schedule of Distribution, which we are required to do. On this
schedule you will see that there is a balance of proceeds to be paid to you, Stanley J.
Caterbone. You, the defendant, will receive this balance of $17,306.80, however, you have
served Sheriff Bergman with a petition to set aside the sale (PARCP 3132). Please note
that we, the Sheriffs Office, do not have a dated and signed copy by the court of your
petition. At the advice of our solicitor, the distribution of any payouts regarding this
property will not be made until the matter is resolved. Fulton Bank and the Lancaster
County Sheriffs Department embezzle over $50,000 in Fees, Costs, and the Distribution of
Sale associated with the Sale Proceeds of 220 Stone Hill Road, Conestoga, PA.

The

Praecipe-Writ of Execution filed on July 31sth, 2006 by Fulton Bank for Foreclosure Case
No. CI-06-02271 stated: FILED. WRIT ISSUED. AFFIDAVIT OF NON-MILITARY SERVICE.
PRINCIPAL: $88,568.53; INTEREST TO 03/02/2006 AT A RATE OF $14.56 PER DIEM:
$4,442.96;

NEGATIVE

ESCROW

BALANCE:

$1,096.38;

LATE

CHARGES:

$317.20;

ATTORNEYS' FEES: $3,000.00; TOTAL: $97,425.07. FILED BY SHAWN M. LONG, ESQ.


PLAINTIFF receives a letter from the Superior Court of Pennsylvania regarding the Fulton
Bank Foreclosure Challenge, notifying him that AND NOW, this fourth day of January,
2007 the appeal in this matter is DISMISSED for failure to file a brief. This DISMISSAL is
highly suspect considering that the Superior Court placed no time conditions on receiving
the additional (7) Copies and it was received several days AFTER PLAINTIFF had already
mailed the required (7) Copies and fulfilled the obligations to the Superior Court, thus
furthering the fact that Fulton Bank and the Sheriffs Office of Lancaster County held an
illegal sale on December 20th, 2006. PLAINTIFF receives DENIED on an ORDER
Change of

from

Venue and Continuance for the Hearings for January 18th, 2007, signed by

Judge Dennis Reinaker of the Pennsylvania Court of Common Pleas of Lancaster County,
Pennsylvania.
337.

The PLAINTIFF, Stanley J. Caterbone (CATERBONE), alleges that the City of

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Lancaster and the Lancaster City Bureau of Police and others colluded to deliberately
ignore CATERBONES complaints, an abuse of process, in an effort to interrupt and
sabotage current and ongoing litigation and civil complaints against several major
businesses and government agencies with headquarters in the City of Lancaster and the
Commonwealth of Pennsylvania.

Those would include the Lancaster General Hospital;

High Industries (Penn Square Partners and the Lancaster County Convention Center);
Fulton Bank and Fulton Financial Corporation; Wachovia Bank branches; Lancaster
Newspapers; the County of Lancaster; the Lancaster County Prison; the Hotel Brunswick;
James Street Investment District; Aurora Films; Haverstick Films; and the Lancaster City
Bureau of Police.
338.

CATERBONE also alleges that the Lancaster City Bureau of Police were used to

retaliate

and

sabotage

other

litigation

and

civil

complaints

against

other

police

departments, namely the Southern Regional Police Department, Manheim Township Police
Department, East Lampeter Police Department, Millersville Boro Police, Avalon Police
Department and the Stone Harbor Police Department.
339.

CATERBONE alleges that by ignoring his complaints the Lancaster City Police

Department gave the green light for others to continue a long and successful period of
harassment, thievery, property damage, computer and electronic hacking, deletion and
manipulation of court related documents, records and evidence, mail fraud, and the like.
These activities are so intense that they have taken on the characteristics of hate crimes.
340.

CATERBONE alleges that the gross abuse and negligence defamed his name and

that of his company, ADVANCED MEDIA GROUP, which discredited his reputation in an
effort to diminish credibility in the courts and to disrupt and thwart any possible business
relations and operations of ADVANCED MEDIA GROUP resulting in direct and immediate
financial losses and loss of income.
341.

Chief Keith Sadler and the Lancaster City Police Bureau rejected and refused to

resolve these disputes through mediation when CATERBONE opened a case with the
Lancaster Center for Mediation in May of 2008 and Keith Sadler communicated on May 8,
2008 that he would not cooperate and mediate with CATERBONE.
342.

On several occasions in 2007 several police officers of the Lancaster City Bureau of

Police instructed CATERBONE, in person upon responding to complaints, not to call 911 or
the Lancaster City Police Department and that the Lancaster City Bureau of Police would
not respond or take complaints.
343.

The Lancaster City Bureau of Police only took one (1) incident of gas siphoned and

stolen from CATERBONEs 1991 Dodge pickup truck, and refused to take the over 50 (from
December 20, 2007 to present), or so other incidents as a complaint, regardless of the
efforts to have Lancaster City Mayor Rick Grey and the Lancaster City Solicitor to look into
the allegations and complaints. CATERBONE had meticulously documented the incidents in

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a journal and a log of gas receipts, photographs, and odometer miles for all of the
incidents.
344.

The Lancaster City Bureau of Police had responded to approximately 10 or so 911

calls in the last eighteen (18) months to 1250 Fremont Street, residence of CATERBONE,
for complaints of property damage; stolen property, legal and business files and evidence
for litigation; computer and electronic hacking with deleted electronic files; harassment;
terrorist threats, stalking, stolen mail, etc.,.
345.

CATERBONE had complained of abuse of process to state and federal law

enforcement of the situation, including U.S. Senator Arlen Specters office. CATERBONE
had also visited the Federal Bureau of Investigation (FBI) in both Harrisburg and
Philadelphia for help and intervention.
346.

CATERBONE also had personal meeting with Lancaster City Mayor Rick Gray in

Lancaster City Hall on at least 4 occasions to find a solution to the problems and for help
to mediate the problems and resolve the conflicts and the pain and suffering, as well as
loss and destruction of property and that CATERBONE was undergoing.
347.

In November of 2007, CATERBONE and the Advanced Media Group went public with

their Downtown Lancaster investments and business plans that were culminated over the
past 9 years.

The Advanced Media Group also formerly and publicly introduced their

Downtown Lancaster Action Plan via handouts, websites, and blogs; and began meetings
and negotiations with major stakeholders, City of Lancaster Public Officials, Developers,
and investors.
348.

In 1997 CATERBONE had solicited Attorney Christina Rainville of Philadelphia and

pro bono attorney for Lisa Michelle Lambert in the Laurie Show murder case. The murder
trials and appeals of the Lambert case demonized Ms. Christina Rainville and U.S. District
Court Judge Stewart Dalzell.

After CATERBONE submitted documents and audio

recordings, Ms. Christina Rainville had communicated with CATERBONE that she was not
able to take his case due to the fact that her Philadelphia law firm had banned her from
taking on any more Lancaster County residents, despite the fact that many more sought
her legal counsel. On December 31, 1997, CATERBONE had also personally delivered a
CD-ROM to the chambers of U.S. District Court Judge Stewart Dalzell in an effort to bring
attention to his case. In May of 1998 CATERBONE submitted an AFFADAVIT to the law
firm of Schneider and Harrison outlining the prosecutorial misconduct or Finding of Facts of
the 1987 cover-up for Ms. Christina Rainville. CATERBONE alleges that these facts were
part of the attitude and the motives for the law enforcement-at-large of Lancaster County
and the Commonwealth of Pennsylvania to ignore the rule of law and procedure in order to
bring these false arrests and malicious prosecutions. The Lancaster County community-atlarge had the same attitude toward CATERBONE.

The Lambert case received national

notoriety when U.S. District Judge Stuart Dalzell freed Lambert on a Habeus Corpus appeal

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hearing citing she was actually innocent beyond a reasonable doubt. Judge Dalzell was
quoted in chambers as saying, "I can tell you, Mr. Madenspacher, that I've thought about
nothing else but this case for over three weeks, and in my experience, sir, and I invite you
to disabuse me of this at oral argument, I want you and I want the Schnader firm to look
for any case in any jurisdiction in the English-speaking world where there has been as
much prosecutorial misconduct, because I haven't found it. The case was covered by a 3
part series in the Los Angeles Times by writer Barry Seigel on November 10, 1997 and a
television episode on the A&E Network American Justice Series. The Lancaster community
gathered over 10,000 signatures on a petition to impeach U.S. District Judge Stewart
Dalzell for his rulings. In the end, the Commonwealth of Pennsylvania took control of the
case and appealed the ruling that freed Lambert sending her back to prison.

The case

went all the way to the U.S. Supreme Court in 2005, after being denied any review. The
case accentuated the rights of Federal Law vs. State Law and the Commonwealth of
Pennsylvania solicited a team of attorney generals from across the nation to help their
cause. CATERBONE attended a hearing before Judge Larry Stengel in the Lancaster County
Court of Common Pleas and to this day, due to his knowledge and experience with the
Lancaster County Judicial System and Law Enforcement believes the case should have
never been conducted without a jury trial, and that the over zealous prosecution proves
that prosecutorial misconduct was never thoroughly investigated or prosecuted in the
Lambert case. CATERBONE will not let that happen in his cases.
349.

TO BE CONTINUED IN AN AMENDED COMPLAINT

350.

On or about April 14, 2008 1999 HP Notebook n5150 laptop was rendered useless

by intruder shorting the power cord. This was the third computer rendered useless since
November of 2007, and the last computer available for use in the home and office. The
only computer available for use was the public computer at the Lancaster County Library
on North Duke Street in downtown Lancaster.
351.

On March 18, 2008 CATERBONE went to the Hotel Brunswick in Downtown

Lancaster to continue his take measurements of the Movie Theater for his continued
efforts of a business and development plan to open the Brunswick Movie Theater, which
had been closed since 1995. CATERBONE and Advanced Media Group had an agreement
with the Owner of the Brunswick, Hamid Zahedi, to make a formal proposal and offer for
leasing the site. CATERBONE noticed that the United States Department of Justice Office
of Trustee was conducting hearings for Chapter 11 petitioners in the Presidential Room of
the Hotel Brunswick. CATERBONE had not received ORDERS from his United States Third
Circuit Court of Appeals Case No. 08-3054 for his appeal of an issue in his Chapter 11
Case No. 05-23059. CATERBONE alleged that the ORDERS were stolen or never mailed
from the clerk of courts.

CATERBONE thought maybe Dave Adams, the trustee for the

United States Department of Justice Office of Trustee might be conducting the hearings.

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The following day CATERBONE received a disturbing email from Mr. Barry A. Solodky,
Esquire, of

Blakinger, Byler & Thomas, P.C., 28 Penn Square, Lancaster, PA 17603.

CATERBONE had known Mr. Solodky since the 1980s and had even solicited him to review
his bankruptcy matters before the Appllent filed his Chapter 11 case on May 23, 2005. The
following email exchanges detail the incident and the false reports and allegations from a
member of Blakinger, Byler & Thomas, P.C.
352.

Sometime in February of 2008 by way of hacking or the staff of the Clerk of Court

of the Third Circuit Court of Appeals, CATERBONE was erroneously and maliciously placed
on electronic email distribution with no paper copies for all of his ORDERS for all of his
cases, which at that time numbered four (4), without the knowledge of CATERBONE. After
receiving one of the email alerts and ORDERS CATERBONE personally visited the Clerk of
Court for the Third Circuit and was told by staff that it was just a new courtesy copy. The
staff did not notify CATERBONE that his cases would not be eligible for paper copies of
ORDERS. CATERBONE was alleging since February that his ORDERS were being stolen in
the U.S. mails, and only received information in April on the bottom of a copy of a letter
attached to an ORDER for Case No. 3054 that he was switched to electronic email
distribution with no paper copies. This makes no sense since, filing as pro se, CATERBONE
is not eligible to file any electronic documents in any U.S. or Pennsylvania Courts.
353.

On several occasions since February, CATERBONE was not able to open the Third

Circuit electronic ORDERS on the first attempt, which denied CATERBONE access or
knowledge of the Third Circuit ORDERS with no way of retrieving them again. CATERBONE
was not even able to respond or know how the United States Third Circuit Court of Appeals
had ruled or what ORDERS were handed down, which also denied CATERBONE any chance
to follow court mandated responses in a timely fashion.
354.

On April 17, 2008 CATERBONE went to respond to the U.S. Third Circuit Court of

Appeals for case no. 3054-07 and CATERBONEs paper copies of his briefs and filings were
stolen and were not in his home and office.
355.

From April 14, 2008 to April 19, 2008 CATERBONE was electronically hacked by

professional computer hackers at the Lancaster County Library in a more hostile manner
than usual.

At one time CATERBONE had lost three or more hours of work for the

Downtown Theater at Hotel Brunswick business and development plan, and the hackers
had also deleted sensitive research and data files for the project.
356.

On April 15, 2008 CATERBONE had his brakes rigged on his bicycle while riding in

downtown Lancaster, which almost caused CATERBONE to loose control and again
rendered his bicycle unfit to ride. CATERBONE reported the incident to Lancaster County
Sheriff Terry Bergman and deputy Bourne at the Lancaster County Courthouse.

The

Lancaster County Sheriff provided tools to CATERBONE to fix the brakes at the Lancaster
County Courthouse.

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357.

From April 14th to May 6th, 2008, CATERBONE had his gas siphoned out of his 1991

Dodge Dakota Pickup truck on at least 7 different occasions.

On April 29 th, 2008,

CATERBONE was scheduled for oral arguments before the Superior Court of Pennsylvania
at 9:30 am and had his gas siphoned the evening or day before and had missed the
7:39am Amtrak train to Harrisburg and missed the Superior Court Appeal Hearing for Case
No. 855 MDA 2007.
358.

On April 7th, 2008, CATERBONE had $200 of fraudulent fees charged to his

Wachovia Bank checking account via a clever guise of posting transactions and erroneous
statements of the account.
359.

During the month of April and up until the Pennsylvania Primary CATERBONE has

documented several incidents of harassment at the Lancaster Campaign Headquarters for


Senator Hillary Clinton at Queen and Chestnut Streets.
volunteered for the campaign.

CATERBONE had formally

CATERBONE had alleged misconduct by several key

Lancaster Officials and politicians that have influence in Lancaster City. Most were Obama
Supporters and two were Obama elected delegates. It was ironic that Lancaster County
was one of only 7 of 67 counties in Pennsylvania to vote for Obama.
360.

On April 18, 2008, CATERBONE received a fraudulent invoice and collections letter

from the Lancaster County Credit Bureau for $96.00 from the Lancaster County Prison.
CATERBONE immediately went to the Lancaster County Prison and met with Vincent
Guirnir, the Warden, who made certain he would take care of the matter and have the
Lancaster Credit Bureau delete the invoice and the charge from CATERBONEs record.
361.

On several days in April his U.S. Postal Carrier, Mr. Mitchell, in delivering his mail

had harassed CATERBONE. For the past year or so, CATERBONE had a sign on his front
door that instructed the U.S. Postal Carrier to ring the bell if the screen door was locked,
which they had done. Then suddenly the U.S. Postal Carrier refused to ring the door or
deliver the mail if the screen door was locked and lied and said he never did it that way
before.
362.

For the past 2 years CATERBONE had problems and numerous complaints (drug

trafficking, prostitution, thefts, harassment, destruction of Appellants property, thefts of


stolen files, siphoning of gas, stalking) with local law enforcement and the City of
Lancaster officials regarding the next-door occupants of 1252 Fremont Street, and its
owner, Mr. William Lefty Plank, a convicted felon (vehicular homicide with DUI, Robbery,
Assault, False Identification, Driving Under Suspension, Probation Violations, etc., and
career criminal.
363.

CATERBONE had made formal complaints to Lancaster City Mayor Rick Gray

regarding the incidents and allegations of 1252 Fremont Street during personal meetings
during February, March, and April Open Door public one on one meetings for the public
with the Mayor. During February, March, and April, CATERBONE pleaded with Lancaster

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City Mayor Rick Gray to intervene with the Lancaster City Police to try to resolve the
disputes and to take CATERBONEs complaints and incident reports.

After the Mayor failed

to bring any change to the situation, CATERBONE notified Mayor Rick Gray that
CATERBONE would file for mediation with the Lancaster Center for Mediation after the
newly appointed Chief of Lancaster City Police, Keith Sadler was sworn into office on or
about April 23, 2008.
364.

After almost 2 months of complaints regarding an unregistered and un-inspected

old junk pickup truck (Owned by William Lefty Plank, parked in the alley behind 1252
Fremont Street, on April 15, 2008 the Lancaster City Bureau of Housing and Inspections
placed a Red Public Nuisance and/or Hazardous Vehicle sticker on the truck. The sticker
requires the owner to remove the vehicle within 48 hours or face a $1,000 per day fine
and have the vehicle towed at the owners expense. CATERBONE again complained to both
the Lancaster City Bureau of Housing and Inspections and the Lancaster City Police after it
was not removed. Finally, on April 21, 2008 CATERBONE visited the Lancaster City Bureau
of Housing and Inspections and again complained.

Within hours the vehicle was finally

towed. In April of 2007, CATERBONE had his mint condition 1991 Dodge Dakota Pickup
delivered to his home and office at 1250 Fremont Street after being stolen by Parula
Properties, LLC on December 20, 2006.

The Lancaster City Bureau of Housing and

Inspections placed the Red Public Nuisance and/or Hazardous Vehicle on the truck
because CATERBONEs could not afford insurance or registration.

CATERBONE removed

his 1991 Dodge Dakota pickup truck within 24 hours after being threatened with the
$1,000 per day fine and having the truck towed away at a location with a per diem charge.
365.

On April 22, 2008 while CATERBONE was polling for the Lancaster Campaign Office

to elect Hillary Clinton, at the Helena Greek Orthodox church on Hershey Avenue. First on
the way to the voting precinct, which was only 5 blocks from CATERBONEs home and
office,

CATERBONE ran out of gas because some one again siphoned his gas tank.

Lancaster City Councilman Nelson Polite, who showed up to poll for Barrack Obama,
harassed CATERBONE. CATERBONE did not want to take any more harassment and went
back to the Lancaster Office to elect Hillary Clinton and filed a formal complaint.
366.

On April 22, 2008 the 1252 Fremont Street property, and its owner, Mr. William

Lefty Plank had the house CONDEMNED by the Lancaster City Bureau of Housing and
Inspections. The notice read as follows: NOTICE THIS PROPERTY HAS BEEN CONDEMNED
As Being Unfit For Human Habitation and May Not Be Occupied Until Repaired. The penalty
for violation of this notice can be a fine of $1,000 per day or a term of imprisonment up to
90 days per offense. Do not obstruct or remove this notice under penalty of law. CITY OF
LANCASTER DEPARTMENT OF HOUSING AND NEIGHBORHOOD IMPROVEMENT (717)2914705. The property of 1252 Fremont Street was never evacuated, and persons continued
to Habitat the property no matter how many times CATERBONE complained to officials of

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the Lancaster City Bureau of Housing and Inspections, the Lancaster City Police
Department, or the Mayor of Lancaster, Mayor Rick Gray. The Lancaster City Housing and
Inspections Bureau advised CATERBONE during personal visits to the office that 1252
Fremont Street was CONDEMNED for water shut-off, and that no one was permitted in
the property. They advised CATERBONE to notify the Lancaster City Police if anyone was
seen in the house. CATERBONE has constantly heard voices and persons inside the 1252
Fremont Street during the entire period of Condemnation.
367.

On or about April 24, 2008 a female and a Hispanic male approached 1252 Fremont

Street from the back alley. CATERBONE instructed the two individuals that no one was
allowed in the property, under the condemnation laws.

They argued and entered the

property with a key. CATERBONE called 911 for the Lancaster City Police. Two Lancaster
City Police officers arrived within 10 minutes and William Lefty Plank and Lee Schopf
appeared. They argued that they were permitted in the house to retrieve things. The two
individuals were not seen. The Lancaster City Police ORDERED everyone out of the house
and advised them to vacate the property. The Lancaster City Police instructed me to keep
calling if anyone is seen in the house.
368.

On April 26, 2008 a white mail approached 1252 Fremont Street from the front

while CATERBONE was outside working on his property next door. CATERBONE advised
the person not to go inside and the person threatened CATERBONE with physical violence
and walked into the house at 1252 Fremont Street. CATERBONE called 911 to report the
threat to his person and that a person had just went inside 1252 Fremont Street.

One

Lancaster City Police officer arrived on foot within approximately 10 minutes and waited
for backup before pounding on the door of 1252 Fremont Street. Another Lancaster City
Police Officer arrived on foot walking up Fremont Street from the Euclid Avenue vicinity.
CATERBONE then went inside his home and office next door at 1250 Fremont Street. After
several minutes of pounding on the door, William Lefty Plank opened the door and Lee
Schopf walked out of the door.

CATERBONE watched through his screen door and was

waiting for the tall white male that threatened him to appear.

CATERBONE opened his

screen door and told the Lancaster City Police that they were not seen when the tall white
male entered 1252 Fremont Street.

Both Plank and Schopf said there was no one else

inside of 1252 Fremont Street. Later more Lancaster City Police officers arrived and they
handcuffed Lee Schopf and escorted him to a Lancaster City Police cruiser waiting in front
of 1250 Fremont Street. The tall white mail apparently left out the back door before the
Lancaster City Police arrived, or before they inspected the house.

The Lancaster City

Police vacated the premises and rang on the door of CATERBONE.

The Lancaster City

Police Officer explained that they would call on the Lancaster City Bureau of Housing and
Inspections on Monday morning to confirm the story by Plank that he was allowed in the
house to retrieve items. Plank said he needed his cell phone charger. If the Lancaster

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City Bureau of Housing and Inspections confirmed that they were not allowed in the house,
then the Lancaster City Police officer said they would charge the two with trespass. The
Lancaster City Police officer said that Lee Schopf had outstanding warrants on him. After
the Lancaster City Police had left the scene William Lefty Plank knocked on CATERBONEs
door to argue that they were allowed inside and that he was going back inside the house.
CATERBONE slammed the door and told William Lefty Plank to stay away from him.

On

Monday, April 28, 2008 CATERBONE went to the office of the Lancaster City Bureau of
Housing and Inspections and talked to a male who said he was the supervisor, he
confirmed to CATERBONE that no one was allowed inside 1252 Fremont Street and told
CATERBONE to keep calling the Lancaster City Police, but said it in a sarcastic manner to
irritate CATERBONE because no one would enforce the Condemnation Notice.
369.

On the early morning of April 24, 2008 at the Brickyard Bar and Restaurant on

North Prince Street CATERBONE was assaulted by a tall black male. CATERBONE went up
to the bar to pay for his tab, one drink, and the assailant started to harass CATERBONE
about what was inside his backpack. CATERBONE left and went downstairs to the lobby
where his bicycle was locked.

The assailant followed and kept harassing CATERBONE.

CATERBONE warned the assailant to stay away from CATERBONE or he would call the
police. The assailant pulled out his cell phone and kept saying he has the police in his
back pocket, or something to that extent. CATERBONE walked his bicycle out the door as
other patrons arrived and rode down the Brickyard pavement toward North Prince Street.
The assailant chased CATERBONE and grabbed his backpack tearing it in half and stopping
CATERBONE. CATERBONE quickly reached back so that all of the legal files would not spill
and kept yelling at the assailant to get away. The assailant kept asking CATERBONE if he
was a Federali or Federal Agent. CATERBONE saw a Lancaster City Police cruiser on the
west side of Lemon street at a stop light and quickly rode to flag the police down. The
Lancaster City Police drove across the intersection and stopped in the middle of the street.
CATERBONE told the officer what happened and he said he would drive around to Prince
Street to the front of the Brickyard. CATERBONE went back to Prince Street for his bicycle
and saw the assailant approaching him again. CATERBONE sped away following the police
cruiser to the corner of the alley at Market Street and Lemon Street to hide from the
assailant.

The Lancaster City Police cruise was out of sight.

After the assailant

disappeared CATERBONE went back to the Brickyards via Lemon Street to look for the
Lancaster City Police. After a few minutes the Lancaster City Police cruiser appeared from
James Street and turned down Prince Street. The Lancaster City Police took a statement
from CATERBONE and CATERBONE asked the Lancaster City Police for a ride home
because CATERBONE could not ride and hold the backpack together at the same time.
CATERBONE explained that there were Federal case files in the backpack, but they refused
and told CATERBONE to call a taxi. CATERBONE wrapped his backpack up with a bungi

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cord and went home. A few days later CATERBONE went back to the Lancaster City Police
Bureau and requested a report of the incident.

Officer Cosmore printed CATERBONE a

summary of the call from County-Wide Communications with a log of the time of the call, a
description, and the responding officers names, and instructed CATERBONE to check back
later for a complete report. CATERBONE did and was instructed to go to the records office
of the Lancaster City Police Bureau where they demanded $15.00 for a verification letter.
CATERBONE waited for about ten minutes after the clerk said she would print one out, but
left after no one came back to the window.
370.

On May 2, 2008 CATERBONE opened a case for mediation with the Lancaster City

Police Bureau and Chief Keith Saddler at the Lancaster Center for Mediation.
371.

On

May

8,

2008

Lancaster

City

Police

Bureau

and

Chief

Keith

Saddler

communicated with the Lancaster Mediation Center that they refuse to mediate with
CATERBONE.
372.

On

May

1,

2008

the

Advanced

Media

Group

Website

at

www.amgglobalentertainmentgroup.com was hacked and only 1 hit showed up on the


statistics report.
373.

On May 6, 2008 the scanner and printer was again rendered inoperable.

374.

On

May

6,

2008

the

Advanced

Media

Group

Website

at

www.amgglobalentertainmentgroup.com was hacked and shut down with only 44 hits


showed up on the statistics report.
375.

On May 7, 2008 Wachovia Bank illegally charged CATERBONE a $10.00 fee for a

cahiers check in an effort to incite and harass. The Wachovia Bank has processed at least
10 cashier checks prior to this date without ever charging a fee. Joe Caterbone, uncle of
CATERBONE was present in line and walked out after CATERBONE ignored him.
376.

May 7, 2008 was one of most painful days of electromagnetic radiation for

CATERBONE.
377.

On May 8, 2008 the Lancaster City Water Department turned on the water at 1252

Fremont Street and the CONDEMNED NOTICE was removed.


378.

ON May 8, 2008 the electronic version of a brief filed by CATERBONE for Superior

Court Case No. MDA 2053-07 was hacked and changed.


379.

On May 9, 2008 the link to the Downtown Lancaster Action Plan of the Advanced

Media Group website was hacked and turned off.


380.

On May 10, 2008 after noise all night at 1252 Fremont Street, the home of William

Lefty Plank and Lee Schopf, the hot tub jet switch was turned on twice during the day in
an effort to run up the electric bill. At about 8:30 am a long grey haired male started an
altercation and screamed and threatened CATERBONE from the backyard of 1252 Fremont
Street, the home of William Lefty Plank and Lee Schopf.
381.

On May 12, 2008, as with most mornings CATERBONE tried to get a free breakfast

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at the St. James Episcopal Church Food Kitchen.

The church had a policy of placing all

backpacks outside the facility and hanging them on the wooden fence in the rear. On
several occasions when CATERBONE had very sensitive court related materials inside, he
had left the backpack at Lancaster City Hall, and even at the Lancaster Public Library. On
one occasion a few weeks ago an alternate Schadd Detective Agency Security Officer
locked up the backpack in an office inside St. James Episcopal Church. On this day, May
12, 2008, CATERBONE decided to request some sort of exception from the administrators
of St. James Episcopal Church.

The woman administrator in the office of St. James

Episcopal Church allowed CATERBONE to place the backpack with court documents and
filings insider the church administrators office. She said she would inform George Dunn,
the Schadd Detective Agency Security Officer that he had her permission.

CATERBONE

proceeded to the line for breakfast and Mr. George Dunn immediately made him leave the
line and told him it was not her decision. CATERBONE was instructed to take the backpack
with court related documents and filings out of the building.

He told George Dunn, the

Schadd Detective Agency Security Officer that the matter would be taken up with his
Superiors. The James Street District Security employee stood close by trying to insinuate
that CATERBONE was in the wrong and causing problems.

Immediately following the

incident, CATERBONE went to the Lancaster County Library, which was located right next
door, and Googled Schaad Detective Agency to find an email address to file a complaint
and found the following article: Schadd Detective agency owner to stand trial on
prostitution charge by MATTHEW KEMENY, The Patriot- News Friday February 01, 2008,
3:28 PM Provided PhotoRussell L. Wantz Jr.

The owner of one of the largest private

detective and security agencies in central Pennsylvania will stand trial on a charge of
criminal attempt to solicit a prostitute, a Dauphin County district judge ruled today.
Russell Leroy Wantz Jr., 57, who owns the York-based Schaad Detective Agency, Inc., was
arrested Dec. 10 in Swatara Twp., after police said he arraigned to meet a woman for sex
at the Red Roof Inn.
382.

On May 13, 2008 CATERBONE went to the office of Spiziri Insurance to use a

computer offered by owner John Spiziri. CATERBONE was hacked and windows explorer
would not work while trying to make a CD-ROM backup of files from a thumb drive.
383.

Again on May 13, 2008 the statistics report for Advanced Media Group was hacked

and not displayed.


384.

On May 15, 2008 CATERBONE was hacked at the Lancaster County Library while

trying to display the electronic ORDER of the U.S. Third Circuit Court of Appeals, thus
denying him access to the document. There is only 1 (one) view allowed per electronic
email.

The Library staffer that was in the Duke Street Business Center of the Library

during that time made a remark before the incident as if she was involved.
385.

On May 18, 2008 immediately following the Sunday mass at St. Marys Catholic

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Church, which CATERBONE attends on a regular basis and is a member, had made
arrangements with Charles Chip Snyder, owner operator of Snyder Funeral Home, to pick
up the remaining estate files of his brother, Sammy Caterbone (December 25, 1984
death). The Snyder Funeral Home and Chip Snyder was the mortician and the first to raise
concern and doubt that the suicide on the death certificate did not make sense since there
were no marks of any kind on the neck of the Sammy Caterbone when the remains were
retrieved from Santa Barbara, California. That observation and notification to CATERBONE
started the formal process and investigation into Sammy Caterbones cause of death back
in 1984.

They agreed to that the files would be available at the King Street Office of

Snyder Funeral Home. At that Mass, Fr. Leo Goodman had announced to the congregation
that St. Marys was going to start a video broadcast of the Sunday morning mass on
network television and a web cast for those that are homebound; and requested feedback
from the congregation. CATERBONE waited to offer his services to Fr. Leo Goodman and
talked to him outside after mass.

Father Leo Goodman tried to humiliate and harass

CATERBONE, as he has done on so many occasions.


386.

On May 19, 2008, CATERBONE observed the owner of 1242 Fremont Street, Wally

(last name unknown), leaving a note for the occupants at the front door. CATERBONE has
also been making formal complaints regard the activities of that residence and had an
illegally parked car removed from the back alley a few weeks before.

CATERBONE

informed Wally of suspicious activity that looked like drug trafficking with people going in
and out during the day and night, similar to 1252 Fremont Street.
were selling drugs also.
evicting the tenants.

Wally thought they

Wally confirmed that they were not paying rent and he was

CATERBONE went back to his residence and heard yelling and

screaming from 1242 Fremont Street, and heard the tenants threaten Wally with physical
threats and Sylvia Boas, 1244 Fremont Street also yelling at Wally. Wally was walking to
his car and threatening to call the police.
387.

On May 20, 2008, CATERBONE left his residence in his 1991 Dodge truck and within

a half of block was stalked by Mr. Joseph Caterbone and Ms. Dee Stover Butz.

Blocks

away CATERBONE got out of his car at a red light and asked Mr. Joseph Caterbone (Uncle)
if he was following him, and went back to his car, where Dee Stover Butz was directly
behind CATERBONE. CATERBONE asked her while she was waiving to him in a sarcastic
manner, if she was 12 years old. CATERBONE went immediately to the Headquarters of
WGAL-TV where there was supposed to be a protest of the TV Station for the bias of the
media coverage of the Clinton-Obama presidential race.

CATERBONE received an email

the day before soliciting protestors from Rebecca Lytle, a Clinton campaign person for
Lancaster County.

In the parking lane of WGAL-TV CATERBONE ran out of gas due to

another incident of someone stealing his gas. He found only one (1) person protesting and
suggested that the email was a fraud to the person protesting.

TO BE COMPLETED
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Dated:

December 10, 2016

___________/S/____________
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
stancaterbone@gmail.com
717-669-2163

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CATERBONE v. The United States, et.al., - A CIVIL RIGHTS COMPLAINT

CERTIFICATE OF SERVICE

Dated:

July 20, 2016

___________/S/____________
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
stancaterbone@gmail.com
717-669-2163

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EXHIBIT

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