Court of Common Pleas of Philadelphia County For Prothonotary Use Only (Docket Number)

Trial Division
Civil Cover Sheet E-Filing Number: 1901060509
PLAINTIFF'S NAME DEFENDANT'S NAME
HON. DAYLIN LEACH CARA TAYLOR

PLAINTIFF'S ADDRESS DE
601 SOUTH HENDERSON ROAD SUITE 208
KING OF PRUSSIA PA 19406

PLAINTIFF'S NAME DEFENDANT'S NAME

GWEN SNYDER

PLAINTIFF'S ADDRESS DE

PLAINTIFF'S NAME DEFENDANT'S NAME

COLLEEN KENNEDY

PLAINTIFF'S ADDRESS DE

TOTAL NUMBER OF PLAINTIFFS TOTAL NUMBER OF DEFENDANTS COMMENCEMENT OF ACTION

X Complaint Petition Action Notice of Appeal
1 3
Writ of Summons Transfer From Other Jurisdictions
AMOUNT IN CONTROVERSY COURT PROGRAMS

Arbitration Mass Tort Commerce Settlement

$50,000.00 or less Jury Savings Action Minor Court Appeal Minors
X More than $50,000.00 X Non-Jury Petition Statutory Appeals W/D/Survival
Other:
CASE TYPE AND CODE

2L - LIBEL, SLANDER, MISREPRESENT

STATUTORY BASIS FOR CAUSE OF ACTION

RELATED PENDING CASES (LIST BY CASE CAPTION AND DOCKET NUMBER) IS CASE SUBJECT TO
COORDINATION ORDER?
YES NO

JAN 28 2019
M. BRYANT

TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of Plaintiff/Petitioner/Appellant: HON. DAYLIN LEACH
Papers may be served at the address set forth below.

NAME OF PLAINTIFF'S/PETITIONER'S/APPELLANT'S ATTORNEY ADDRESS

JOSEPH R. PODRAZA WELLINGTON BLDG STE 400

135 S. 19TH ST
PHONE NUMBER FAX NUMBER PHILADELPHIA PA 19103
(215)561-7681 (215)561-0174

SUPREME COURT IDENTIFICATION NO. E-MAIL ADDRESS

53612 jpodraza@spragueandsprague.com

SIGNATURE OF FILING ATTORNEY OR PARTY DATE SUBMITTED

JOSEPH PODRAZA Monday, January 28, 2019, 10:03 am

FINAL COPY (Approved by the Prothonotary Clerk)

SPRAGUE & SPRAGUE Filed and Attested by the
Richard A. Sprague, Esquire, (I.D. # 04266) Office of Judicial Records
Joseph R. Podraza, Jr., Esquire (I.D. # 53612) 28 JAN 2019 10:03 am
M. BRYANT
William H. Trask, Esquire (I.D. # 318229)
The Wellington Building, Suite 400
135 South 19th Street
Philadelphia, PA 19103
(21s) s6r-7681 Attorneys þr Plaintiff
HONORABLE DAYLIN LEACH
601 South Henderson Road - Suite 208 IN THE COURT OF COMMON PLEAS
King of Prussia, PA19406 PHILADELPHIA COUNTY

Plaintiff, CIVIL ACTION

V Term:

CARA T OR No.

and

GWEN SNYDER

and

COLLEEN KENNEDY

Defendants.

NOTICE T O DEF'ENI)

NOTICE
You have been sued in court. If you wish to defend
against the claims set forth in the following pages'
you must take action within twenty (20) days after
this comptaint and notice are served, by entering a
written appearance personally or by attorney and
fiting in writing with the court your defenses or
objections to the claims set forth against you. You
are warned that if you fail to do so the case may
proceed without you and a judgment may be
entered against you by the court without further
AVISO
Le han demandado a usted en la corte. Si usted quiere
defenderse de estas demandas expuestas en las
paginas siguientes, usted tiene veinte (20) dias de
plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar una comparencia
escrita o en persona o con un abogado y entregar a la
corte en forma escrita sus defensas o sus objeciones a
las demandas en contra de su persona. Sea avisado
que si usted no se defiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin

Case ID: 190102559

notice for any money claimed in the complaint of
for any other claim or relief requested by the
plaintiff. You may lose rnoney or property or other
rights important to you.
You should tøke thís pøper to your løwyer øt once. If
you do not høve ø løwyer or cannot øfford one, go to
or telephone the office set forth below to find out
where you cøn get legal help.
Philadelphia Bar Association
Lawyer Referral
and Information Service
One Reading Center
Philadelphia, Pennsylvania 19107
(2ls) 238-ó333
TTY (21s) 4sr-6197
previo aviso o notificacion. Ademas, la corte puede
decider a favor del demandante y requiere que usted
cumpla con todas las provisiones de esta demanda.
Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.
Lleve ests demøndø ø un øbogødo immedíøtqmente. Si
no tíene øbogødo o sí no tíene el dínero suficíente de
pagar tøl semício. Vøyø en personø o lløme por teleþno
ø Iø oficína cuyø direccìon se encuentrø escrítø øbajo
pørø øveríguør donde se puede conseguír øsístencìø
legø1.
Asociacion De Licenciados
De Filadelfia
Servicio De Referencia E
Informacion Legal
One Reading Center
Filadelfiao Pennsylvani a 19107
(21s) 238-6333
TTY (21s) 4sL-6197
Case ID: 190102559
  

SPRAGUE & SPRAGUE

Richard A. Sprague, Esquire, (I.D. # 04266)
Joseph R. Podraza, Jr., Esquire (I.D. # 53612)
William H. Trask, Esquire (I.D. # 318229)
The Wellington Building, Suite 400
135 South 19th Street
Philadelphia, PA 19103
(215) 561-7681 Attorneys for Plaintiff

HONORABLE DAYLIN LEACH, :

601 South Henderson Road – Suite 208 : IN THE COURT OF COMMON PLEAS
King of Prussia, PA 19406, : PHILADELPHIA COUNTY
:
Plaintiff, : CIVIL ACTION
:
v. : Term:
:
CARA TAYLOR, : No.
:
:
:
and :
:
GWEN SNYDER, :
:
:
:
and :
:
COLLEEN KENNEDY, :
:
:
:
Defendants. :

COMPLAINT
I. INTRODUCTION

Defendants, jointly and severally, have combined to publish, republish, and widely

disseminate a salacious and despicable falsehood about plaintiff that they know to be false. One

fabricator of the lie against plaintiff is an admitted liar and notorious perjurer. The other two co-

conspirators have shown a reckless disregard for the truth in gleefully republishing and

Case ID: 190102559

embellishing upon the serial liar’s fabrication about plaintiff for the admitted purposes of

destroying plaintiff’s reputation, cutting short his career in public service, and harassing and

harming his family. The three defendants have sought to achieve their goals by seeking to exploit

for their own malicious purposes an important political movement in order to broaden the

audience of their false claim among a trusting, unknowing, and unsuspecting public, to

wrongfully mobilize and incite unwitting accomplices against plaintiff, and to inflict maximum

harm on plaintiff and his family based on accusations they know to be false. The defendants

have openly admitted the sole purpose of their endeavor is to see plaintiff’s “head” mounted as

“a trophy on their wall” regardless of truth and common decency. This action is brought to

champion the truth and redress the defendants’ malicious falsehood.

II. PARTIES

1. Plaintiff, the Honorable Daylin Leach (“Leach”) is an adult individual and citizen

of the Commonwealth of Pennsylvania who maintains a business address at 601 South

Henderson Road, Suite 208, King of Prussia Pennsylvania 19406. Leach has served in the

Pennsylvania Senate representing Pennsylvania’s 17th senatorial district since 2009, and

previously was a member of the Pennsylvania House of Representatives representing the 149th

district from 2003 to 2009. Prior to 2003, Leach practiced law for 16 years and was an adjunct

professor at two colleges in Pennsylvania. He is married and the father of two children.

2. Defendant Cara Taylor, f/k/a/ Cara Kuhns (“Taylor”) is an adult individual and

citizen of the Commonwealth of Pennsylvania residing, upon information and belief, at 2918 E.

Walker Road, Bath, Pennsylvania 18014.

  2
Case ID: 190102559
 3. Defendant Colleen Kennedy (“Kennedy”) is an adult individual and citizen of the

Commonwealth of Pennsylvania residing, upon information and belief, at 161 Shelbourne Road,

Havertown, Pennsylvania 19083, who is a self-proclaimed political and public policy expert.

4. Defendant Gwen Snyder (“Snyder”) is an adult individual and citizen of the

Commonwealth of Pennsylvania residing, upon information and belief, at 4235 Baltimore

Avenue 3d Fl., Philadelphia, Pennsylvania 19104, is a self-described grassroots movement

strategist, and previously accused an elderly man of sexual assault who later was acquitted of her

accusation following trial in a court of law.

III. JURISDICTION AND VENUE

5. The Court has jurisdiction over all parties pursuant to 42 Pa.C.S. § 5301.

6. Venue is proper in the Court of Common Pleas of Philadelphia County pursuant

to Pennsylvania Rule of Civil Procedure 1006(c)(1).

IV. FACTS

A. Taylor is an Admitted Perjurer Who has Fabricated Lies

About Leach

7. Defendant Taylor is an admitted and judicially determined perjurer and serial liar,

who has willingly conceded that she will lie without compunction to promote her personal

interest and agenda.

8. In sworn testimony in a court of law provided in 1992, Taylor has admitted that,

even as a young teenager, she was willing to repeatedly lie to obtain employment under false

pretenses, and would move from employer to employer to avoid detection. (N.T., Jun. 9, 1992 at

p. 11:15-21, attached hereto at Exhibit “A.”)

  3
Case ID: 190102559
 9. As an adult, Taylor lied under oath at her mother’s 1992 trial for the attempted

murder of Taylor’s step-father. At the trial, Taylor falsely swore that she, not her mother, was

responsible for the attempted murder of Taylor’s step-father. (Id. at p. 5:18-23.)

10. As a result, Taylor was charged by the Lehigh County District Attorney with

perjury and false swearing after the 1992 trial and later pleaded guilty to charges of felony

perjury and false swearing for which she was incarcerated. (See N.T., Apr. 15, 1999 at p. 7:17-

24, attached hereto at Exhibit “B.”)

11. Indeed, during the original 1992 attempted-murder trial, Taylor made clear her

willingness to lie for her own benefit and for that of her mother, which admissions may have

contributed to the jury’s disregard for her false testimony and unanimous guilty verdict. (See,

e.g., N.T. Jun. 10, 1992 at pp. 92:25 – 93:7, Exhibit A.)

12. Leach, criminal defense counsel in Taylor’s mother’s 1992 criminal trial, was an

early victim of Taylor’s stated willingness to lie in order to achieve her ends by any means.

13. In neither her mother’s sentencing for attempted homicide, nor in her own

sentencing for perjury did Taylor allege any unethical or inappropriate conduct on the part of

Leach, despite the fact that allegations of such misconduct, if believed, would have potentially

helped both her and her mother avoid or shorten incarceration.

14. At her sentencing for perjury, Taylor testified under oath that lying and

perpetrating a fraud on the court in her mother’s criminal trial was her idea alone.

15. After Taylor’s mother was sentenced for attempted homicide, Leach no longer

had any involvement in her case, and had no further contact with either Taylor or her mother

outside of testifying at Taylor’s mother’s 1999 post-conviction proceedings.

  4
Case ID: 190102559
 16. Taylor’s mother unsuccessfully pursued the full gamut of direct appeal options for

seven years.

17. Seven years after her trial, in 1999, during post-conviction proceedings to

challenge the conviction for the attempted murder of Taylor’s step-father, and in an effort to

secure her release from prison, Taylor’s mother filed a Post Conviction Relief Act (“PCRA”)

Petition which fabricated a story of an improper, one-time years-earlier sexual encounter

between Taylor and Leach as a ground for overturning her mother’s 1992 conviction.

18. Despite the allegations in the Petition, when afforded the opportunity in 1999 to

testify under oath in a court of law, Taylor declined, and her mother agreed to voluntarily

withdraw Taylor’s false and salacious allegation against Leach rather than see Taylor face the

prospect of a second perjury conviction with an accompanying longer prison sentence. (N.T.,

Apr. 15, 1999 at pp. 6:12 – 8:20, Exhibit B.)

19. Taylor and her mother withdrew the false and defamatory allegation, despite the

court making it clear that they would be forever waiving the opportunity to gain any benefit that

the false allegation might afford them.

20. Taylor’s mother even opined on the record at the April 15, 1999 court proceeding

that she was voluntarily withdrawing the false allegation of improper conduct against Leach by

Taylor because her daughter, Taylor, was a convicted perjurer whose fabrications could not be

believed. (Id. at p. 8:6-8.)

21. Despite the fact that the false and salacious allegation was withdrawn by Taylor

and her mother, Leach voluntarily testified at the hearing that he had no physical relationship

with Taylor at any time. He so testified under oath, something Taylor refused to do at that same

hearing. (Id. at p. 53:11-20.)

  5
Case ID: 190102559
 22. Moreover, Taylor’s false testimony and subsequent guilty pleas on the charge of

perjury and false swearing were widely reported in the contemporaneous media.

23. For example, the November issue of The Morning Call reported that Taylor

would “spend 30 days in jail for lying when she testified in her mother’s Lehigh County trial,”

and although “[n]ot everyone who fibs in court is charged with perjury, [Taylor’s] lie was one of

‘monstrous proportions.’” (Debbie Garliki, Woman gets jail term for lying at mom’s trial, THE

MORNING CALL, Nov. 13, 1993, p. 91, attached hereto as Exhibit “C.”)

B. The Defendants Weaponize and Embellish Taylor’s Knowingly

False Accusation

24. Kennedy volunteered a number of times on Leach’s Congressional campaign of

2014.

25. At the conclusion of the 2014 campaign, Leach and Kennedy parted on good

terms, with Kennedy posting friendly and positive messages on Leach’s social media accounts.

To Leach’s knowledge, he and Kennedy have never been in the same room together or

communicated in person again.

26. Leach has, to his knowledge, never personally met, or spoken to, Snyder.

27. Leach’s first became aware of the existence of Snyder when she began attacking

him on social media as “predatory,” an “abuser,” an “assaulter” and a “rapist.”

28. During the course of the preceding year, Kennedy and Snyder, upon information

and belief, have become increasingly close associates of Taylor. In fact, it is believed and

therefore averred that the three defendants are in constant contact through social media and

regularly meet in-person.

29. Kennedy and Snyder operate on the fringes of state and local politics and in

collaboration with Taylor, have recently taken to exploiting the energetic fervor of legitimate

  6
Case ID: 190102559
political activists to amplify their concerted attacks on Leach to advance their own private

ambitions and vindictive agendas.

30. Now Kennedy and Snyder, using the inconsistent and demonstrably false

accusation of a known and convicted perjurer (Taylor), have dogged Leach continually with

outrageous accusations of sexual misconduct.

31. At all times Kennedy and Snyder knew that Taylor was personally not credible

and that her claim of sexual misconduct by Leach was not credible. Nevertheless, Kennedy and

Snyder spread Taylor’s false allegation against Leach despite Taylor’s known long history of

lying and deceit, thereby acting in blatant and reckless disregard of the truth.

32. And all three Defendants knew and have known that Taylor’s allegation of rape

against Leach is false before and at the time they nevertheless decided to recklessly broadcast

Taylor’s false claim against Leach through the Internet and elsewhere.

33. At all times relevant hereto, Snyder and Kennedy knew of Taylor’s felony

conviction in 1993 and of the withdrawal of her heinous and false allegation of improper conduct

by Leach under the threat of new perjury charges if this allegation was actually pursued before

the Court at the 1999 hearing.

34. Nevertheless, despite having knowledge of the falsity of Taylor’s sexual-

misconduct claim against Leach, Snyder and Kennedy agreed to conspire with Taylor to extend

the public reach of Taylor’s false claims for the sole purpose of injuring Leach’s professional

and personal reputations and to shamefully subject him and his family to public ridicule and

scorn under false pretenses.

35. By way of illustration, Taylor, who upon information and belief enjoyed the

support and encouragement of Snyder and Kennedy, maliciously published on her publicly

  7
Case ID: 190102559
accessible Facebook page her fabricated account of prior contact with Leach, stating repeatedly

beginning in February 2018 that Leach “drove [Taylor] to his apartment and sexually assaulted

[Taylor].” (Exhibit “D” at p. 6 of 7.)

36. Thereafter, and throughout 2018, Taylor repeatedly published and republished her

false attacks on Leach as evidenced by a sampling thereof, a compilation of which is attached

hereto as Exhibit “E.”

37. During this time, upon information and belief, Snyder and Kennedy encouraged

Taylor’s increasing dissemination of her knowingly false allegation against Leach while assisting

Taylor in expanding the reach of Taylor’s false attacks by separately republishing them online,

by appearing at public events to harass Leach about Taylor’s false claim, and by encouraging

others in person and over social media to take action against Leach based on Taylor’s knowingly

false allegation against Leach.

38. Not only did Snyder and Kennedy republish Taylor’s false accusation against

Leach, they also incredibly embellished this false claim to better serve their own malicious

objectives.

39. For instance, Snyder took to every corner of the Internet proclaiming as a

“confirmed” fact that Leach is a “rapist and a predator,” (Exhibit “F”) criticizing Leach’s

activities during the “MLK Day of Service” with a non sequitur “reminder” that “Daylin is

credibly accused of raping a 17 year old….” (Exhibit “G.”) Snyder made these false claims

against Leach knowing them to be false at the time of their making or with reckless disregard as

to the truthfulness of these claims predicated on Taylor’s made-up accusation against Leach.

40. And at a recent protest march in Center City Philadelphia, Snyder lured a gaggle

of unsuspecting protestors off their route with her bullhorn, imploring her unwitting audience, on

  8
Case ID: 190102559
the basis of her knowingly false accusations, to contact Leach and demand that he resign (Exhibit

“H”) because “we’re done with rapists holding office.” (Exhibit “I.”) Snyder’s efforts, initially

directed at those physically present, were captured on video and rebroadcast over the Internet.

41. Similarly, Kennedy, in an unsolicited response to a post announcing a public open

house appearance to discuss public health issues, announced she would not be attending Leach’s

open house because “He statutory raped [Taylor],” a factual representation which she knew and

knows is false. (Exhibit “J.”)

42. Elsewhere and at other times Kennedy wrote with malice and/or reckless

indifference to the truth that “Daylin Leach sexually assaulted [Taylor] when she was 17 years

old” (Exhibit “K”), and accused Leach of “prey[ing] upon the most vulnerable.” (Exhibit “L.”)

43. Emboldened by Snyder’s and Kennedy’s malicious advocacy, Taylor, by the fall

of 2018, had adopted not only her co-conspirators’ tactics but their rhetoric as well, increasingly

referring to Leach as “my rapist,” a knowingly false claim. (Exhibit “M.”)

44. Not satisfied with confining these malicious attacks to the Internet and individuals

who could be physically reached at public gatherings, Taylor, with upon information and belief

the advice and encouragement of Snyder and Kennedy, fabricated a “private criminal complaint”

in November 2018 setting forth in salacious detail one version of the fictional 1991 encounter

with Leach that she previously refused to confirm under oath.

45. But just as she had been unwilling to share her fabricated story under oath at her

mother’s PCRA proceeding, Taylor conveniently declined to sign her purported “complaint” in

November 2018 thereby avoiding the admonition contained therein that by signing the

document, she verifies, subject to criminal penalty, the truth of the facts alleged. (Exhibit “N.”)

  9
Case ID: 190102559
 46. And rather than submit the November 2018 “complaint” to the appropriate

authorities, Taylor, with upon information and belief the assistance of her co-conspirators Snyder

and Kennedy, distributed the unsigned and unsworn document, albeit styled as a private criminal

complaint, to the offices of Leach’s colleagues at the state capital in Harrisburg, which has since

caused the senate leadership to initiate an independent investigation.

47. Although relieved Taylor’s fabrication will finally be subjected to scrutiny and

confident that any investigation will confirm what has been known to all three of the defendants

from the start—that Taylor’s malicious accusation against Leach is categorically false—Leach

and his family have nevertheless suffered and continue to suffer harassment, humiliation, and

embarrassment as a result of the defendants’ obscene misconduct.

48. Not only has the oft-repeated, demonstrably-false allegation by Taylor against

Leach besmirched the reputation of Leach and materially affected his ability to perform some

duties of his public office, but his family has been similarly affected.

49. Leach’s minor children have been subjected to public ridicule and harassment,

and his wife developed health issues, including loss of feeling in her extremities, necessitating a

diagnostic brain scan, as a result of the stress of the highly humiliating and public false attacks.

50. As a result of the actions of the defendant, the plaintiff has been subjected to

numerous other people posting on social media, calling him a “rapist” and a “creep” and an

“abuser” and demanding his resignation.

51. The public incitement based on the defendants’ malicious and wrongful conduct

delineated in this pleading has even compelled Leach to recently upgrade the security systems

installed at his private residence out of concern for his safety and that of his family.

  10
Case ID: 190102559
 52. And defendants, themselves, have even confirmed the sole sick objective of their

unconscionable defamatory assault on Leach through a recent Internet post by Snyder: “Y’all,

I’m a sexual misconduct accountability trophy hunter these days. I have Marcel Groen’s head on

my wall, a place next to it reserved for Daylin’s, and plenty of space left over for more[,]”

regardless of truth, basic common decency, or the Law. (Exhibit “O.”)

Count I – Defamation
(Leach v. All Defendants)

53. Plaintiff incorporates by reference the averments contained in the foregoing

paragraphs of plaintiff’s Complaint as though fully set forth at length herein.

54. Defendants published the above-mentioned statements, innuendos and

implications concerning Daylin Leach on repeated occasions as set forth above and in the

attached exhibits.

55. Each of the statements, innuendoes and implications concerning Leach were false

and defamatory.

56. These statements, innuendoes and implications accuse Leach of criminal conduct

and thus are defamatory per se.

57. The above-mentioned statements, innuendoes and implications concerning Leach

were published to individuals, including individuals in Philadelphia County, who understood

said statements, innuendos and implications to refer to, and defame, Leach.

58. Defendants knew that the statements, innuendoes and implications concerning

Leach were totally false. In the alternative, Defendants Snyder and Kennedy made the

statements, innuendos, and implications with a reckless disregard for their truth or falsity.

  11
Case ID: 190102559
 59. Defendants maliciously published, republished and distributed the aforementioned

defamatory statements, innuendoes and implications concerning Leach, knowing that they were

false, or with reckless disregard for their truth or falsity.

60. Defendants’ false and defamatory statements, innuendoes and implications have

severely injured Leach in that they have tended to: (a) blacken and besmirch Leach’s reputation;

(b) expose Leach to public contempt, ridicule or hatred; (c) convey the impression that Leach is a

rapist, a criminal, and a sexual predator; (d) detract from Leach’s respect as a state senator in

Pennsylvania, (e) subject Leach to embarrassment and humiliation within the Commonwealth

and local community; and (f) interfere with Leach’s ability to conduct some of his duties as an

elected official.

61. Each of the aforementioned defamatory statements, innuendoes and implications

was understood by third parties, including in the Philadelphia area, to pertain to, and defame,

Leach.

62. Defendants’ defamatory publications were so outrageous and malicious as to

warrant the imposition of punitive damages.

63. As a proximate result of defendants’ malicious, intentional and/or reckless

publication of these false and defamatory statements and innuendos, Leach’s good name and

reputation has been and will continue to be harmed, and Leach is entitled to such damages as will

compensate Leach for the injury to his reputation, as well as punitive damages to punish the

defendants for their conduct and deter them and others similarly situated from like acts in the

future.

WHEREFORE, plaintiff Daylin Leach demands judgment against defendants Cara

Taylor, Gwen Snyder and Colleen Kennedy, jointly and severally, in an amount of compensatory

  12
Case ID: 190102559
damages in excess of Fifty Thousand Dollars ($50,000.00), together with interest and costs, and

punitive damages in an amount which will punish the defendants for their conduct and deter

them and others similarly situated from like acts in the future.

SPRAGUE & SPRAGUE

By: /s/ Joseph R. Podraza, Jr.

Joseph R. Podraza, Jr., Esquire

  13
Case ID: 190102559
 vERrFrcaTIo¡{
[, Daylin Leach, am the plaintiff in the subject action and verify that the statements in the

foregoing document are true and correct to the best of my knowledge, information ¡nd belief, I

do further understand that these statements are made subject to the penalties of l8 Pa.C.S. $4904,

relating to unsworn falsification to authorities.

tg
Date Hon. Daylin

Case ID: 190102559

Exhibit A

Case ID: 190102559

 cçJu R.T û F: Cû itt3,rON pL EÂ$ O Þ. t Eir TG H Ct'ü !üT Ì*

cRrMIrüÀr, ÞIvI$rü!{
***
coMÞåür{þtEAr.,r:$ oF FH$i¡srtvÂNrà c

vg : I{o, 1XE6 ûË LSgL

KåT'gfIEgTü SPËTË{

*?t*

r e gr J. I{û Ji_g * g g *ç å.9 a *.K-r¡ fl $¡1

As heard befr¡re hhe Ftonore,bie l"aWfe¡iCe J.

Erenner on Tr.lesclay änd Wed¡lesdayr June I a nd une ."T
1t n 1g$? "
**"*

Ã.e.9.8.&8.&"N.C"86¿

I{TC¡'AEL P, IbICTIdTYRE, ESQÜTR,fi

FTR$T A$$J ISSAT{T ÞrSTRrCî ArTOg.T{EY
For the Conr¿ûr¡weaLtl:
ÐÂYL ïN tg¡tCItf E$ütI rRs
For tl¡* SeËendant

C{Cr*

,Sudith F4. I¡almerr RpR

Off ici.atr Cou¡:t Repori:er
Case ID: 190102559
 j.$Ðã *ELEË &"€.ü g -Ë
"a_sç¿

.Ð"9
"e
a$^Ë & * w J, 3 S "g "g s PÅ$"8
cJ\Rlr frul¡Ng
Ðirest Examf. nati on by totr . Le acb å,
Cross Hxarnination b3' IlEt, T4cInt,yre 3t
Redí rect Ðxam j. nation by lrlr , I-,eaclr J.S3
RecrCIss Exanrínat ios b]r B{r. ï{cI¡.rtyre rJ fl
tbvi! "!
I{er}irect Bxamånatiçn i:y Ftr. Leac}r rCI4

t_

Case ID: 190102559

 5

i. Iâ Y f{R. L Ëlí{ CII s

¿,
ll
Try t.o mahe i t, r ea çh ä€ ¡ Ca r a, when yÐu
t r¡pea k. l{ow olrl are yüu 110w¡ Cara?
4 Ì
Áx. 3.8"

5 '¡é Okay,, rîhere do ]¡öu Ë)rÐ&ently reside?

6 ãä.
I 3. ive at 2L5 Eaet Wai"nut gtreet in
7 Al-lentoï¡n.
t Q ti"iåV. llow long h*:ve you Ltved there?
n
fl 9rco yëars nûbr I vlould say.
1û ¡l
ûkay n Þo ysu lr*ow 5ta t,hy $pe t.h ?

1T fT Yeg r I do*
'l ')
Ç Anel who $.s Íiabhy $peth tû you?
L_ 13
l- .:þ ¡\ She is ¡11)¡ mOtï¡err
ld e 0kay' Anü do you know Ðelwyn $peLh?
"t Èï
h YêSr I tlÕ.
L6 Q 3ànd r'¡b¡at í s fåor¡ do you lrnow hln¡?
77 A &[e is $1y stepfa{:herr
18 {J Oltay, üarar do yor¡ lçncr+ of, your çwn
1$ knowledge whethen your nrother att,e¡upteu tq ki11
?û Ðelrvyn $X¡eth on Ë'ei:ruary 2Etl¡?
ä1 ¡{ I hnow $iy i¡rot,her dicln{t, do i.b.
4L ç¡ FIowdo yøLt hnow your mother did¡r I t, dc did?
a3 A r did ít"
ä4 Ë Nowr Cara¡ I am going to ga thrauEh t,hís in
25 detail with 1roür First,r I would like to aeh yoì¡ å
Case ID: 190102559
 ?r

3 :t
{å I v¡ns living åt. åI-5 Ëast VlaLn'"lt Street.
r Ë fà'nd whç rre r e yCIu T- iv inç w i" t.h ?
.J ã.
l"JúÍ boyfriencl¡ $cstt.
A
t¿ lüer e you guy$ ¡aar r å eel ä t t,l're tín¡e ?
$ ;r l.lcr wË were not,.
6 t¡ tkay, How did yr¡r sup¡tort y$Hrseif at ÈliaH
I tåme?
A I was dancing, f waË an ex*t,i.c ¿Tancer qb

the t, i.n¡e .

3{} çi ükay * I am B0rrf ¡ üarao but, irhat. ís *n

11 exot,íç cJanc*r? Canr if y$u yolJ car\ tel"l ì:he jury.
?r) A ir?er l,re çlance. !{e da nce exotiaa[1y irl bårs.
I
l'l TalEe ûur eLst.hes <¡ff in fronf:. of strðnqer ß f,çr a

14 1o t, Öf fr
rrtt ߀
^lä
ü 0kay, And w*re yo$ of âSe ât t,he tj.me?
å¿\ A i.Tsr I was not¡
l"i A firen ïrow did you rûanaqe to $et ånto bhe
å8 l¡ar s tç <ãü tl¡ Í s ?
¿v A l'{obocly reaL Ly ever asked ïRÊr you know. T¡
2û sthen they díd¡ r j ust woul"¿1nE t, rr¡ork at that grlace,
¿¿ Trd go dow¡r tbe st,reet.
¿¿ ü Okay" T{here .rrere yöu workinE or¡ the
f- ., evenirrg of February ?7Èhlã8th?
2& Â, v¡ðts *t the Grandview Inn in Gouldsboro
1¡ì off of Route 380,
Case ID: 190102559
 \ì'Å

L A Yeair.
.a Iiinç3 cf l"ilqe yûu 1åed ta
Pi
J /r fhat wä$r t,hat v¡,åË i¡r ¡ny iat,eIest,,
$ometltir¡g LÀke Lha'k,, T wes proteci:inS myself,
5 e ItiçhÈr
E
U fl Ttsr ntt, doíng Èha'L ir0w.
I \¿ F.å nei of I Í !se yçu Lied t0 yÐur st*pfet,her

Y aþout, i:eing n*rrierf to Scot,t KinEr ri.ght? gf ibr a

\{ in yçur inLereËt youi re gcing Ers 1íe¡ right?

Lü A IÌ m not gcing tor $0c $3å.¡t g have,
T} Q *knyn Leb¡s Look i¡:bo thí ri anrl see íf
tä A I am not så)ring Itm $aånt. I n€ver said
¿t

L_
t3 Lha t,
L8" t-J T dörr''b t,hi¡ilr årlybrdy ås uaying Ðhat,
Ï5 $1R., I¡BACIdc Sbjet;ticnr lour
16 !{onc¡ r r

77 fïr$ CûtJRtl¡ objech,åon

a¿t
¿(, suËtæined.
'i d¡
BY II,IR. I{C 51{TYR E ;

¿.v ü T"etç s laol+ in'eo whebher Ðr nÕt you lrave ån

1'¡ lnt,erest ån whetl¡er your $:sril gêås *onvicùed.
2,2 ;{ I al ready sa i d llÊsr f do+
¿J e Ðo you have an int,erest?
î"4 s
ft I dont t want t* Ëee her rJa tç Jail"r rlo¡
¡rH
¿, -, e Âncl y0u lrave tolqi us t,ha ù if it,¡s in y0ur
Case ID: 190102559
 93

1
ir¡'l;erest y*iå êre prCI¡:e i:û Iieo is ,chaL riEht?
+ Va <:
¿À Ét

2
J IJ $kay o yoir Ï¡ave varir$Ë i¡rtereËt s i¡l
idô',.r¡
ú. ttris cåsÊ¡ dønr t you? First of ð.1Lr åë 3r$u sai$
{t þefçre¡ yo love yÐur n¡othen ancå you lrate $e3.r,ayn
Tå

6 speths *cc{¡rdång tr: yûrJr ri,ght?

"t xx, ¡gÞr

al ct
Þ¡ ÄlL right. Ifated hå¡rr enouEh tç kåLl"niuln
Ci
right?
åli nit les.
t¡ rr fio I t,ake åL that, åf yüu !tated hÈ,m ÊhouËh
'¡ 15.Ì
-l to ki"l.i hånio y{rlí hat.e l"lisr enoirgir to Eei: osl thaL
I

13 wi.'Lirsös s'sand and lie it ie wouJ"d hurL !rim¡ is

¿ú¡ lhaL faår ståtement,?
a

1q fi f{or þecauge I I ¡n nöt 1yf.ng.

L6 LJ Ä1L r{ght, Lêtr sr let,¡ s analyze this $ËrÊr
'î '7
-t- I You habe â Ë)erËrn enougtr to kill themr tç talie
1iï their very lif e frrcm 'cheir lrodyr but yaü rlsn!t
'¡q hate hir¡t enouçh tö Lie on t,he wåtnâss stand abçut,
2,û t¡Ímr ås tþ¡at wt¡at youtre teIIinE us?
?1 f.\ ft would trurt me if I wês i¡p h¡ere lyingr I
2,r. dçrrr t $¡anL tq hurt, 'ßiðr ï dont t eäre abouL hi¡n at,
â3 àll.
Êê * ?ühat i f yûu t,houEht yêu coul d Eet âway wÍth
2b i*?
Case ID: 190102559
Exhibit B

Case ID: 190102559

 COURT OF COMMON PLEAS OF LEHICH COUNIY.
( PENNSYLVANTA

CRIMINAL DIVISION

COMMONWEALTH OF PENNSYLVANIA
)
)
vs. ) No. l99l/llß6
)
KATHLEEN SPETH )
)
Defendant )

NIOTES Or T[sTtMOily
PCRA FnTrlrpil FrA¡rp 4pBrL r& reqg

BEF'ORE THE HONONABLE LAÌT'RENCE J. BRENNER

E

t,

APPEARANCES;

CHARLES SIEGER, ESQUTRE c.

cl
Õ
... for tho Dcfcndant l-a C¡J

sË Tì
Ê:-.
=::. l\t
(.o
[flCllAEL McINTYRE, ESeUrRE t.:,a" .a
¿

... for the Commonwe¡lth =9.

Ét< .
.E rn
s([!-: t\) I,EJ
#ñ"' r::¡
t¡l

Court Monitor: Glorir Rocd Bobo

Irla

REtOaD F¡r.ã¡) ¡î{ supEn¡cn ocuh-f

OÍ)URÌ

APR ã ? UOOÍ' JUL t99g

7o

Case ID: 190102559

 ó
I A. Two and a quarrer years ago I did.
( 2 a. And it took about e year fo¡ the rranscript to be
3 prepared, did it no¡?
4 A. Fourtcen months.
5 a. Now, Kethleen. in your petition For post
6 conviction coilater¡r Relief you've rrtegod e nur¡bcr of
7 thingr. and I w¡nt ro go through those things with you.
I Okay?
I A. Alt right.
¡0 MR. STEGER: Wirb rhc
ll Court's indulgence for a moment.
I t2 A. Now. one of the things thrt you allogc in your
(, l3 Pclition cotrserns your Attorney, Daylin Lc¡ch, ¡nd his
l4 involvemcnt with your drughtcr, corrçct?
t5 A. Yss.
tó a. You ¡nd I h¡ve talkcd sbor¡t th¡t, H¿vc wc nor?
l7 A. Yes.
¡ l8 a- And we'vc talkcd ebout thË pros and cone of
Í
t9 following up with that ettegatio¡, h¡vc wc not?
i
a 20 A- Yos.

¡ 2l a. Whethcr it would be advis¡ble or --

!
! 22 THE COURT: ttoil. lct ms
23 ray th¡s. I rm ¡ot going to -- br¡icrlly wo rrc hcrc today.
( 24 this is your hcrring. Gctting ¿nothrr onc of thc¡c po¡t
23 Conviction Relicf Aot! onc wry or lnothcr, dcponding
on

Case ID: 190102559

 7
I tt'hat ¡ would do. will Ìot
f 2
coms Gesy undcr the prcsent
law. Today is thc time, Mrs. Spcth.
If thsrG is rnything
3 hore now is thc timc to prGsGnt
thG tostimo[y. B¡¡l
4 certainly you ¡rc frec to do rs you
deem eppropriatc.
5
MR. STEGER: And rft¡t.s
6 wh¡t I'm attcmpting to investigrtc hçrc.
? a' Miss spcth, your daughtcr subrcqucur
to your trìrr
I wtl chargcd with and convictod of perjury,
wrg shc not?
9 A. Ycs.
t0 IftR- McINTyRE: your
il Honor, rnry I posG rD objcctìon? r rnow that you ryrnt to
$ t2 grtnt somc lecwty. Evorything h¡s bccn
toading out of
( t3 Attorrêy Sieger. lVc should gct ¡r from _-
t4 THE COURT: The objection
l5 to thc form ie sust!¡nGd.
tó MR. SIEGER; Okry.
l7 a. Wee your daughter ohrrged witt r crime after your
I
ã
't8 trial ?
t
t9 A. Yes. ¡ho wrr cherged with pcrjury.
i
a 20 a. And wh¡t hrpponcd tr r reeult of rh¡t?
I 2t A. She w¡c givcn ¡ sGntencG ofthirty dayr to fivc
I
I 22 yctrr probrtion.
23 A, So rhc wr¡ co¡victcd?
( 24 A Conviclod fclon rt eightccn yerr¡ old. yc¡.
2S a And r¡ ¡ rcruft ofth¡t htvo you rnd
I t¡lkcd ¡bout

Case ID: 190102559

 E
t whether or not it
would bc a¡lvisrblc to continuG on
( 2 with rhe allegation thrt I h¡d mentioned eerlicr?
3 A. yês.

4 a. And what wrc your decision with regard to mtÌing

5 that allogation?
6 A. ltoll, in light of rhe flcr rhrt ny drughrcr i¡ r
7 convicted perjurer, whicb would prevcnt eny onc
from
8 bclieving hcr to¡timony, ir rcrlly mtke¡ no scnÊG.
9 a, Okry. So as a rcsutt of I convcrslt¡oû bctwocn
lo yoursctf and myrclf, is it your dccision to not
continuc on
ll w¡th thrt rllcgrtion lE r -- rr r ground¡ for iucffcctivc
CI
il l2
è a8sistrnce of soun¡cl by AüorDey Lcrch?
t. t3 A. lVcll, thcro wcrG two prrts __

l4 a. Just thrr ono ground.

l5 A. (No rosponoc)
t6 a. Did you -- d¡d you dccidc thrt thrt one ellegrtlon,
l7 concorning Mr. Le¡ch's incffccrive t¡sistrnce of countel,
t tE would not be followcd concorning hic rllcgcd involvoncnt
I
t9 with your daughtcr -- scxually?
i A.
a 20 YG¡, thrt porrion.
¡a 2a a. Now, thc -- rnd Attorncy Lo¡ch, w¡¡ ho privato
I
I 22 coun¡ol or trrr ho rppointcd to rcproscnt you?
23 Pri yttG.
^,
(,. 24 Q. Did you pry him?
25 A" A thou¡rnd doll¡r¡. And hc rgrcGd to wl¡t for rhc

Case ID: 190102559

 53
I her thc risks snd what she'd be giving up. Which I
t 2 believc Judge Brçnner exptained to her again the day of
3 eentenci ng.

4 At no t¡mc did I coerce hcr to withdraw her

5 appeal. Thcre is no advantsgc to ms of her withdrawing
ó her rppeal. And. you know. thc onty contribution I madc
7 to that rrlas to tell hcr a ûew trisl would h¡vc to be withour
8 her slibi witness.
9 I know thet docsn't rddrcss ell of ir, but thrt'¡ thc
l0 onc thing I rcally wanted to say.
tt Thc ¡econd thing -- one othor thing
I rcrlly
tð
at

t2 wantcd to sty for the record- Uthish is thrt I, you &nov,

'{
l3 C¡r¡ would com€ to my officc, I don't k¡ow. rclativcly
t4 froquently, I'd ray çvery other week on ¡ver¡gc to drop
r5 off ¡omcthing or tålk to me about hcr mon. Or shc would
Ió elwayr comc with hcr mom, too, whcn hcr mom c&mc. But
l7 th¡t's ¡s far es my rê¡¡tionship with hcr cvcr wGnt. A¡d.
I r8 you know. ¡he told me tt thc time ¡he would csy snyth¡ng
I to güt out of -- to gct her morher out of thi6. And I
t9
I 20 supposc .- I don't know if thet coDtitruê¡ or trot.
a
t 2l But, I just wantcd to rry thrr ¡¡ well. If tbcro i¡
I FomG othat issue you want olclred up, I'll bc hrppy to do
2Z
I
2! ¡t,
( 24 MR. MoINTYRE: I've no
2s furlhcr qüG¡t¡on¡. You mry crot¡ èx¡minG.

Case ID: 190102559

Exhibit C

Case ID: 190102559

 gsts iai I term
I

ãt mom'$

ourm*i

Clipped from The Morning CaIl, 13 Nov 1993,-SaL Main Edition, Page 91
Case ID: 190102559
Exhibit I)

Case ID: 190102559

 lq Èara Taylor
w Fnbru;lry 13 *t 13,?3;trl ' l¡t

http:fÅav,w.phllly.conr/.. "lcÕil'ÌmËn. .. rTltthtk-*pinion-?Û18t'l û7.hlml

Don't þe lit<e me; don't lte*p the secrcTs tf your abuËÈ¡'s. You deserve beTter'
Yoi¡ don't deserve lÕ bË ÈmbarrãsËed Or äshãmed for whaT wã$ dcnË T0
yffl. l\üas wlotìg lo dü thäL No mone-
The Artlcle lrelor,v is one thåt Ssnãtû'r Dãy|}n {-each had puhtished, (\¡vhlüft
dçes nùt ãllOW nümments} €nd lt iS titled: 'nWhåt t håve Leämed." You cnn
rËäd lt ilyou like, lrut everytTring tl'lall lrave in quotes ls what he said in the
a¡1icle. lt fs hiç response to lhe allegæTions of sextla! h*rassment lrom
numërÐus 01hËrwÕ¡üen. S¡ntü the Senatcr i$ ãllowed t0 pgbl¡5n Flls
"üplniön" wllhütlt ållÐwing comments, this fs rny respoffiË:
Cara Tnylor: WnåT lve learned b mät ü*ylin Leacft is a ltar. I lcnow because I

alx a llar, too"

"Tñe [ast lew weekr nävÈ glveft me time Tor lntroËpettlon'"
I believe yütt. lt's ålÌ äwft¡! thing to geT caugfrt in a web üf lies' I have had ä5
yeãrs ta devole to Introspection because ül nline" Do ycu remember thase
lles? They weI* The lles lhat yúl"r knew ãþttit, *nccruragecland thën finnlly
nsËd agaltlst me ta pr$leËT yottr*elY. I"ty Telnny record r*merflbsß them" Sa
Soes every ËmFlOyErWho eyer refilsed t* lrire rne *nd every landlord wfto
ürlngËd at the thouglit Of rent¡n$ to nne. My nÕlv grülvn chilclren rËffiemþËr
Thenr, too. Thcse lies a¡e the reas*r¡ I muldn't ättend ÌhËir 3chÕðlTleld trips
ür voluntËËr Tüx thËir ülàssroörn pãrtles"
"Frlnr to the rÈtent stÕry abÐut ffiË ifi the lnqt¡irer. I wss aware That reporters
werc calling dcrens tl fiy ËmpltljëËs" former Êmployees, acquaintances'
ancl oppcnents tc as¡( tf¡e¡'n !f ! had ever rnade tF¡em or ånyçne they lmew
unrümTürlãble. Thal s*rt tf sürutlny Ten$s tc ptlt one in Silnlvål mÕde,
triggertng sowrethlng akiu to a füghl-cr-figfrt respansË. When the sfolv t¡nälly
ËatnË ùut, {was angry a$d defensive" llashed uut, which I regret."
ThaT foresight nrust have þeen ntte. Whät did ycu do with all that prËp linË?
Wfrat yru did to me, what yctt frarl planned Íor nre, I never saw iT cürn¡ng.
Were you scåred ünçe yüu knevç? lwxs petrified. What were yol¡ ängry
aþr:ut? Yenh, gÊtTing caUght silcks, I lqno*¡- YÐu Tsld me I never ìrveu¡d; yÖtl
n¡ust have belinved the sarne thing for yourself. lt's r¡ot fun to have the
neu/spåpers 5äy lïÈän thüngs ãbüuï yôU, $5lt? T know. They said mËän thtngs
äbout me, tuü, but tlrey were nlltrruç. Are tfiey lying aþoilt you? Düe3
ËVerynnË iie exËÈpt Toryou? SLÌrV¡Val ffiüde you say? I've been ln survival
rfirr1Ë Tnr the last qr.larler uT a cen{ury, yaull gÈt usëd Ta it, I ditl. }*lenial wcrlt
fnr nrlnimal pay ts¡n't so lrad üftcç yÐr.A .ac[Ëpï the fact that thal's all you'll ever
you dnnT
flc.tälity Toç !f you'rc even luclty er,nugh to ge! thaT. Be grateful if
end up vrËh n¡ghtmarËs sr an uncontrpllalile Lwitch eithet becat¡se I still
haven't figured öut hCITtr Io avoid lhçse tFrings. YÕ$ have regrets? Welwme to

Case ID: 190102559

 Vüil glve Llp th¡nkhg you WllËver be ählå tÕ ådequâte:y prÕvidË Tor your
fätïlly. You glve ilp thlnhlns that anyone willevËr believe anyfhhg yoti hãve
. 'to say, evër äSain, You giVe up vründÊrlnü ¡f you'll eT/er be given forgivÈnes$'
ïbu reatize yoilr best yeärs are þEhtnd you betaltsË ThË würld knows your
shãmË ãnd sËf-Nüäthlng. tft, wä¡l. no, yot¡ shðuld be ok. Foryet evërything I
peÕple whs äre sorry for whãt thËy
Just sãid" ThoBË thlngs orTly häppgn I0
dfd, not mrry thãt theY gnt cåuüht.
"As I began trying to reckon wiTfr what happened, I reache.d out tt friends,
ct¡lËâgues, änd ëVen sürne people who dçnI lhink vÊry highly üf rne' I did a
l*t of lislenlng.'
I believe ttrls" too. lïs * goutf strãlÐgy. ltnowledge is pcwer. ËotTä knntry what
people wlll say so a þetlevable rleïense cän bË rTTãnulactilrËd, I rememÞer. lt
Jil$t üidnt würk üut 5ü wËll fÕr mË, dld it?
"l lenrned ttrat I have been largely rhlivitus to the näture of pewer dynanrlcs
ãnd prfullege, b6th hetween ffiÈn f,nd wtmën änd betryËÐn BnptÙyel's änd
ëff¡ployÉes. I nãVË nëver ËünBidËrËd rnyself very püwerful or inttmldatlng' I
have never bnen comTortable with ä hierarchical structure änd häve always
triecl ta trËatË working envirünmf,nts that wËre lnfürmal and rÉlãtivËly
egäl¡tärlän. Thus, I was under än lntün'ëct assumptlcn thaï anycne urhÜ hãd
än issue wlln me would lcelfree to sdüress me direcïþ. I nuw tlnderstanrl
thãT pëüple, especially ytung $rtrnen, rnight be reluctant to approach me
wllh ffincËrns ãb*ilt humorlâey ftrËfi't tomfûrtåble ïv¡th'"
I þelleve you lËårnËd allab*ul the nature oI pðwer dynannics nnd privilege
whgrT yÕt¡ tested them nHT *n mË 35 yenrs äüt" Am I wong? Was lhere a
cbfld or a yüung würTT*F beïore me? üö ytti tnhk I leltft'ne tç dlrÈctly
åddress ytu vvltn ãny tüntërfis I hed whÉn yüU drove me lc your apartment,
miles ffÕm my fìÈmË, ilnüËrlhÉ gtllse ül"helplng my mülher whn ha$ nc
rnüney ãnd nË*ded å läwyef'while you lald nxked on your bed sTrüKinS yotlr
eretrTinn, dlrentlnu r'ÌË help yolt Õilr"? wËrË ltüu he¡ng hunnorous?
to*ttffie
Was ¡t au just ã Jötre? Dld yüu Ìhlnh lriy teãrs, $näking inla the beny lubrlcanl
you pnured ün your$elf, wËrÊ ü,lnny? Fower and intlmldation wËre yçHr
T\teâfJonË of choire. T0 tjse lfrgse lscln now, incorporated intCI such a
lranrparent statemenT, UiVËs ilf1È ån ËvËF bigger, mnre horfific sense of
reËpon3ibillty towãrds äll Bf yûHr viËttms ùver the Nast 25 yÊars than I ãlrËady
had.
"l ÐlsÕ äskÈd PËûPle ît I trad ever dcne änl4hing ta tnahn tl¡em
ijnconÌfürTabte^ Frankly, lwas laolting fÛr reãËsurance, hoping ftr resp0nses
lllqe'Abpçlulely nnt, Daylin."'There ïryäË å gÐüd þit of thaï, wf¡ich I am grateful
for. ts$t sümÈ peüple wer€ [ãndid ¡il tÈllinü me that m]r hunnór tÇulcl be ðif*
color Ðr offenslve. Sorns lsld rne they häd been cffended by my httmtlr ln the
past, while solte told me etl¡e¡"s rnlght feelthat way'"
Frnnk[y, tf you ever tlrtugl* a '17 year cld girt w*s c*rnfortahle being
c*rnersd ar¡d *ssaulted by a 3ü year old man whs f¡eld thç lileral lile af
f:ersnlf, her" mplher and her Hffite slster in hîs hands wä5 ã cçmfortaþle
fËeling, tlren N t¡ave absolcJtely rrc abflily lo fnrgive yüu whaT:snevÈr. l'lr nüt
J¡flT¡

Case ID: 190102559

"¡ ä5Kecl people fi I hscl erer dtnË ãnythlng Tü maKe tnem
nlsr
uncomlÕrïÊble. Frankly, I was looking for reassurånte" hopinE lor responses Suggesterl
like'Absclulely not, Dëylin."'There wãs ñ gÕod bn oTthat. whith I am gratefgl
fcr. Ðut sotllË people were tãnd¡d ln telling me Tflat my humor cuuld be otr*
cotor sr offensive. Some told me they had been cffended by my humor in the
past, whilÊ some lotd rne cthers might Teelthat way."
Frankly, if you ever thüught a 17 year old girl was çtmftrtãble þeing
cürnered and assaulted by a 3t year old man who ileld the literal life of
herself" her mather ãnd f¡er ttttle sister in his hands Wãs ã cornftrtable
feeling, then I have absoluïely no äþility tn forglve yûu lrì¡ftäÌsoever. l'm nof
that big of a person. I dpn't even wanl to be.
t'3'
1,]"'lå rn*n
r

"My dlscussisns w¡th others dldn't end at humor- I have always heËn a
ssrnewnat touchy per$ün in conversalion wltlt both men a¡rd wçmen and,
thernfore, I always assumed ll was ÜK. Eut nct everyone *as the sãme
cornfofi levelwlth toaching" lt never occüffËd to me lc even think about this
before, which I am mortlfied tc admit."
I believe you did and dc believe that yottr touchlng is ClK. Did I tearh you
{,
that it was üK þecause I was toc afrald to say rro? Did you think you had a
rlgfrl to dÕ what you dt$ to me because I wæs.ittst a slrtpper and I needed Keystane (
yoilr help? Are you mortiïierf? lwås,lsCI. I stillãm" Every nnce in a while I * fii*nci* '

wçuld hear something abaut yüu ðn the news. Õr see son:ething about you
in the newspËpËr, anü I wauld get mortitied all cver agaìn. I got rid of unþle' I
stoFped reåding newspäpers. Then I \å18Ë only mcrlified whsn tht Te¡Õny yüu
trelped rrchestrale agxlnst me would PrÈvent me from livtng xnylh¡ng even Fe*pl* Y*u
remotelir rðselnþlln$ a Tull and complete life by being able to enjoy even the
simplest ol pleasures. MprÍified fs a gaad wçrd. I don't lhink you t<now whal it
ffieäns.
"All*lthis hæs IeË me shsken. lt has alpc talce*t a lotlon my faüT¡ly and staff-"
Yeah. Me, toa For 25 yËars" And there's no enEf ln stgltl Ttr rne or mine. I
tr Ri
1

tâke lt you ccnsider Xhe tast ä5 years *Íyuur llfe prnductive, prospersus...
nüt me. nüI my Nile. I donT feel sorry f*r you. ängiiriï: ttJ*
Fortuguås fl
"l spent my chilclhoarl in profoundly uncomlorlabte situalions. I hüd VÊry
Deutsclr
lirnited pËrentätcontäËt" nt siblings, and lived in ¿ series tf chãllenging
foster honrep" I learned eaÉy on tf¡al hurnor and perscnal contact lrrere ways p¡içs¡1¡ 1*
tp maÍ<e frierids ãnd Filt people at ease. This is not an €xtttsË, þut an CCI*kåes 1,,{

explanation. While mãny Feople have said pos?tive lhinss åbÐtrt my humcr Fac.e!:*,¡N. ã
over the yeärs, it i5 cleãr now That ffiY 'gense of whüI is and ¡s not $¡elcomÊ in
a given situation has, at tirnes, been flawed" lwas sumetinres impulsive and
thouglrtless, Ttrat needs lo ctrange. I should nËver put humor beTsrÊ
kindneg$."
Uncomfortabl* situations ä5 a chilcl, you say? Me, tso. Yotlweren't the first
pedophile to vislæle rne. hty s¡5tËf5 lather was ä disgLüsting pervert, too, I
f¡ad n hfbìë thuñìping hypccrite for a step fãther r¡¡he nnade ¡iÎe st ilnbeärable
that I left home Tvhen I was '15 and a mtTher who wanted nne lc talte lhe
bta¡ne fçr her aTtempTed n'lurder räp; yûu thinlç thaT was the lirst time she

Case ID: 190102559

UncomTortable sitt¡ations as ã child, you say? ltIe, tos, YoH weren't the ñrST
pedophìte ta uiolate rne. My siste/s father was a disgusting pervert, too. I $ugg*slec
l¡ad a hible thLrm¡:ing hypocrite for a step father whs niade lÈle so unþearable
that I left honre Wnen ¡ was 15 and n niother who wanted nne to take the
blame for her attenìpted rnurder rãp; you think thal was the first time she
snccessftlNly nranip$ated me? But you know what? I dld what t did. I rnade
choices. I was impulsive and thoughtless" lwas alss a child wiler¡ I was
irnpulsive *nd thoughTless" I didn't contin$e my lrehavior inlo aclulthood ancl I
dtdn't mäke extuses, or explanations, tc continue h$rfifl$ other people. You
need a new excuse-
'Ag I'ye ËOntËtnplãted wiere to go from here, üne thing is cerlain: I anr truly
t't',
'1.31ã xie

sorry lür ever saying tr doifig ænything thal has nn*de äfiyone uneasy-
unconîortable, ordistÍessed" lf there is any way io rnake things right, I want
to do that" lf ãnyone wants to conTact me to tallt ahnul this, I'm eãsy tÕ find
and eager to listen."
Ars yüu contenrplatlns where to gc from hËFe? l-et me ilelp yttl out; lT
$HüULDN'T BE THE IüNGRESS ÕF 01-,R UNITEÐ STATES" People like
ycu sfroutd nat be allowed tCI govern Over ãn enlire popufation of people.
And I lmow how you feel. I r¿¡as "tB years old wilh a brand nel baby and a 15
K*yst*ne
:1eär"tld tlttle sistet, w¡Th lrNy mcther in
jail *nd nc where TÛ gt' I
* fri¿nds
coãtemplãtËd, too, With your help, N Þeçame a þpr¡añde liaç a perjuret a
felçn, and I contemptated where T* go far 35 yeãrs- Every time I needed a
jab, l contemplated" Every tiff¡e lwas afraiel sometnË recognized me, I
ccntemplaled" Every tirne I wasn't altcwed To participate in a schoolfunctiCIn Itrer:pf* Yn

#
with my chlldren, lc*nlemplated- When I stayed in a loveless maniage
because I imew I cottld never mafce enpugh mcney to suppotl my children F

by mysell ap a felon, I contenrplated. Every tirne scrneçne had wronged me

1

and I had *n opportunity to rigl-rt it and decided äEãinstiuslice for myself or

my Tamily because I lffÌew nü üne wouTd believe a lying fehn" I
cantemplated. Every time I wanted tc volunteer in !ïy çümmilnity and was
told ¡'ro, I cnnlenrplaTed" Every tirfle I allowed rnyself tt believe thaT I was
more than what Twas being allowed to þe, I conternplated. Are you certain af Ingii-th iUl
Fnrtugt-rås
cne lhing? I am, laa" I am certain that you are not sçny fcr anitone but
Deutsch
yourself. lf you were, your deplorabte, abusive, iüst¡RÊd in your own mind
behavior wtuld not have cçnlinued for the tast 25 yeä15" And forthe record, I
Friv*:y Ti
will not be cantacting you to lalk about this. The Tact lhat you think anyone
l-.**kirs 1
would just goes tpward your blatant arrogance. Ðc not uantact me" I am Fsceb**Í' i

ãfr?¡d ûf you" I rlo not ulant you phys¡Ëälly neär mË ever again.
"The nçvelist Graig SttvË1t wrote that an apology 'dsesn"t talte things hack,
but it puslres lhi¡?gs forrruard." I th¡nk the þestway for rne to apnlogize is to
change rËy ctndu#. I promise tç dP thaï."
Do yOU lilre quctes? !-{etre's One: "l have learned silence frorn the tallutive,
loterance fram Tl-re intolerant and kindness Írorn the unl{nd; ye? strangely
enough" I am ungratefults these teaËhers." Khalil Gibrah" Thankx Íor all the
lessons. You çan stup anyTime nÐw. I'm not grateful-

Case ID: 190102559

 -'l
Do you like quotes? l-lere's sne: have learned silence from the talletive"
tolerance from tfe intolerant ancl lcindness from the unkind; yet strangely
'ehough, I äm unsrateful to these teachers." Khalil Gibrah. Thankx for all the
lesscns. Yûu can stû'F anytime novu. l'm not grateful.
"l arn trying tû learn. t lçnow this won't satisff everybody. Þut hopefully, over
tirne, any skeptic will be csnvinced of nny sincerity- I bel¡eve that there must
H room for growth and fotgiveness ün lh¡s ¡ssue and in all areas of life-"
Sorry" hutthis slteptic knnr¡vs better because I believe the wornen who spolte
rrJï ãgäÌnst you, after you did lvhät yüu tlitl lo me. And I lfiow you're wrtng
about growth and forgiveness, too" Felons don't ever get eitherof those. My
growth has been stunted for 25 yeãrs and there is no one to lorgive mefor
what I dld. My sin remains written and viewable for anyone with a cornputer
and $1ü. And äs petty as I'rÌ sure ttris tnakes me, I'm glad yours finally is,
toç. Mã1tþe this willfinally stop you frarn hurting others.
"We are liv[ng through a time in which humanity seems to be in desperalely
short supply. I hape rrve cÐn all loo?c at each olher as flawed human beings
whc are constanüytrying to irnprove. I promise that ts what I will be lrying to
do."
Nr ur_ë ãren'l and ¡¡ou are lying. With obvlous exception. people are generally
gcod, decent, caring human beings whn don't use their power and positions
antl influ*nce tc hurt oTher people. Tl¡ere is a marked diffierence between a
rne time rnomentary lapse in iudgement, and ccnsistent self serving,
deplorable behaviorthat greatly affects the lives ololhem, vievsed as
"hurncf. I have gr$Jvn up and I ne longer þelieve yaur lies" You should do
lhe sarne,
¡
lF I AM LYING I WA¡riT Y0U TO SUE ME- II
Cara Taylor; daughter, mother, wife, gnandmother, felon^

î.

r
t

f
(
f

Ðuylin l*ach: l$hat I\'e learned I tpinion - Phiþ

Case ID: 190102559

 Sign the petition: Senator Leach: Time s Up
liust signed a peliliun ts Sen. Baylin Leach. Pennsylvania State Senator: Despite
rnultiFle, crediùle accr¡sations oT sexilal harassmenÌ, Daylin l-Èåch cont¡nuÊs in his bid
lor Congress. This is unacc*pt*hle- \û,Je, til* undersigned. den:and that Daylin l-each...
FÊ?¡Ì'i *T'å5. $,4rlitËr]'.', ûrr"ü

'
ile* l.,Jl,J *lse is taii<ìnE si:*r-rl This peiitia* See Posts

gþ t-il** Ç C*mm*nt gþ share l-

Ora
4 Shares

View 1û more commenis

3 John $teilz Done! I will NEVER vote for a candidate lvho has clearly
engaged in sexualharassmenl. Nst in the Denrocralic prlmary. Not in
the generalelectian"..even if this meän* a Republican wins the
election. {And I know that F,4 Ðistrict 4 is s criticalseat for the
Dsmscrsts to take control of the U$ hlcuse uf Representatlves.) I live
in Mnntcc in tl'le proposed PA District 4.
Litre Repry 4d Q t

g Mich*e} Doyle Ðone

Lilqe RePt¡' 4<$

# Julie A. frams*y Please everyone who has signed, share the petitianl
Like Reply' .ld
ta"
Cara Teylor 25 years agc, urhen I rvas 17 years old and Daylln leach
Ëf was representing my nrother, he drove me to his ap*rtment and
sexr.l*lly assaulted me. l-le then nrade sure I l¿as convicied af perjury
so tl'rat nr Ðne would ever believe n:e if I told. Thank you for doing this"
Thank yau"
Lil.;e Repty l$

o ì1,.,;ii:A ¿ C,:fl"ln:*nt. ç)El@r¡

¡f;h Juli* A, Ramsey Lc!:¡ilãå€rl nÈi rl*ìiei ¡ri'l*lr:

Case ID: 190102559

 {lr Cara Taylcr
ry Feþr$ary ?5 a{ 8:3ïpm ' tû

l want to apologize tÐ wÐmen everywhere. for being sucf! a coward" I am sorry

that I feared for my own reputalion rnore thar-r I feared for the future victims cf
Dayl¡n Leach.
I am sorry that lceeping my skeletons hidder¡ ïvas more important than tellirç
someüne who mattered-
I am sorry that I was more worried aÞout what people wsuld say about fiïe or
how they would judge methan I was sf exposing a predator.
I am sorrythat I was too wrapped up in my pvdn sellpity to realize that I might
be able to save someone else ffom the same fate that I experienced, and that
when I diil realize it, I ignored it- I am sorry lhat I chose to ignore it- I ann sony I
made that choice tirne and time again because I clid. Because it was the easier
thing to do. I chose þnorance and hiding because it was easy- I ¿¡m st
increclibly sorry lt was wrûng. I was wrong. I t{täs wrong on so rnãny levels.
I hope that these wcrds dont feelas ernpty foryou as they do for me. f hope
that you don't hate me ts much as I hate rnysef. I seffishly hope you can
forgive me.
It will NEVER happen again.

fi t-i*e Ç Comment þ Share O -

Case ID: 190102559

Exhibit E

Case ID: 190102559

2t28t2}18 Cara Taylor on Twitter: "Ripping families apart? Remember when you ripped mine apart? Do you remember when you sexually violated me and ...

Cara Taylor Tw.ct¡ Following Follow¡r¡ Likc¡

a 4 29 l8 6
Follow
@AltonsOma
-

Daylin leech I @daylinleach ' Feb 10 v

You control all three branches of government NOW. You do know that, right you
tui human abacus? What have you done about #DACA other than ripping families
apart?

Donald J. Trump{l @realDonaldTrump

Republicans want to fix DACA far more than the Democrats do. The Dems
had allThree branches of government back in 2008-2011, and they decided
not to do anything about DACA. They only want to use it as a campaign
issue. Vote Republicanl

Çrs tf¿l 178 g

Cara Taylor
a @AltonsOma
Follow

-
Replying to @daylinleach

Ripping families apart? Remember when you

ripped mine apart? Do you remember when
you sexually violated me and then sentenced
me to a life of poverty when you consp¡red to
have me convicted of perjury so no one
would ever believe me? lf lm lying then SUE
ME.
11:304M - 10 Feb 2018

15 Retweets 2sukes ßO0 G g 3 g IrS

Çs tlts 26 g

lÞ i'*""tr"""0',

K¡ndall A. Brll @kashleybell ' Feb 10 v

G ü
Replying to @AltonsOma @daylinleach
Riiiiiiight. You're not a bot, or anything. Entirely credible. Yup. You're probably not
even a woman. How's the weather in Moscow?
*
4
¡
u
å
Çr t]" B Case ID: 190102559
https ://twitter.com/AltonsOma/status/962408563930030080 112
 Õr t*ra ]ãyiotr share# Jl.ltia ,4. Rat'nsËl-s pü$t ,l*r

-Ës February ä4 a1.{:Sfipm 11

ffi Julia A. Ram'sÊy

FsbrualT ?3 *t 1: {ð*nr ' tl
ãüÊrunt$ of miscanüurt, $enatcr Lsach is unfit für
W[ütit rîrulttpl€ credfrhte
rffiÊe" We rnu*t fnave a clean line of rËrü-tülËränü* fü,n $*xttaß ruisc*nduct
fsr uffic* lir,.,

Se* fu{sn*

,SIgn the petitinn: $enator Leath: TÍmels IJp

lir¡*t*ügnsd e Falilion to #en. ûsylin Ls*ch, F*nnsyËvania I'tat* S*nntcr: te$ite
muÍtiËls, ff*dibtç acn¡*a*nnn* nf gexuai hårg$srTrÉnt, Baïlün l-sash *antinues in ltis
þÍd for tollgress. Tfrüs üF [rrr*üfisptable. rÍfe, lhs undercignsfl,, fl*Ìnãnd lhat ü*ylin",,
F F: TliT l ü*'3S,f,'T ülrErl I'd, üñ.ü

Sss,¡¡hE¡ *{g# is tal*'rnil ah*r"¡t l}sas petitisrl Seq Fosts

6þ t-nc* Ë Comment # $hnre |l-

Case ID: 190102559
 ,Sign the petÍtion: $sna,tor Leach; Time's TJp
liust signed a petilion to $en, tlaylln Lsach, Fsnnsyhenie $tatt $sn¡tnr: ÐaspitE
ruultlFl*, cr¡dlbla eccuaatisn* çf rexu*f hEraEament, Oaïlin Leach contlnueE ln hl* þld
fbr *angråË*. Thls le unaccEptaþfÊ, l¡Ve, thç undaraþned, d'emsnd thet tnylin f.sach,..
ftËTt"$ i üi,i$ $d $vHfi ti.ünü

Stt*r'¡¡h* e$s* ¡s ü*tllij¡'try ãt¡#ilt trlåá* ¡¡t:titi*sù $aa Fosfr

6} Liks Ë Ëomment ñ sh*re fv

ürp
4 ,$hares

Vûgv¡ ît ntorE Ëân1rl1Ëil!6

o J*hn $te[te Songf I rvill FüEUER r¡ntn for a candldats u¡ha hac clerrlg
engägÊ{ in ssxual ham*snr*nt, [t]ot in thç Ðsmscratic primany, F'lct in
tha generst slscliürT",,Êv€rÌ if this m€ânË a Republican ïufn* the
eleclion, {And I know that FA Ðistdct 4 is,a crlticat sået for the
Fsmqcrat* ta tak* cnntral of the U$ Houer of R*pr*r*n:t;aËiv*n,] I liv*
ln i¡lontro in the pr$Fossd Få tfEtrict d,
L¡lqe Repry "ttl
Éi

g I'diehael 0nyïa

LIIEn HspH 4 t*
tona

# Julia A, Ha,ms,ey FlaarË Êufffûne who ha* rigned, shnr* thn petitinnl
Lihe Reptf ' 4{å

Irt
-.-qry Cara Trylur ã5 ynaru whan Xr¡¡as 1T yerre old andr Oaylin lsEch
ä$ü,,
rrrag rËprÊnanling rny mnthar* ha dr*ve me tu his ap*rtmsnt and
**xunl[y amaulted me. Ha th*n mad* Ëurs I wæ canuictad nf pariurl¡
sa that no onå wauld Ërår heliava nna if Í tofd" Thank you for dning thir,
Thank fril.
LilqE'REplf'3*å
Case ID: 190102559
l
Õ
Cara Taylor @Altnnstma ' Feb ?4

Senator Leach: Time's Up

I just signed a petition tn Sen- Daylin Leach,
W*enq.
eütiur- Fennsytvania Sta*te Senator: Despite rnultiple" credible
accusatians of sexual harassment, Daylin Leach contin---
petitions"m6vË0n-0rg

E} tf ü E

I Gara Thylor 6]Altsns0ma ' Feb J1

Reply,ing ts @anna arsn
a/

- 25 years ago, when I was 17. rvhîle he was representing my m*then this man
drcve me tn hîs apartrnent and sexually assaulted me" How is he allowed to
govern over an entire population of peaple?

Ç t-Ie q)3 El

Õ
I Cam Taylor @Altçns0ms 'Feb 1ü
Replying ta @daylinleach
Ripping f¡milies apart? Renrember u¡hen you ripped mine apart? Do you
rernernber lvhen yüu sexually violated me and then sentenced nre to a life of
poverty when yru rünspired to have me convicted of pÉ{ury st nÕ ane would
ever helieve me? lf lm lying then SUE ME.

Çs Îf rs tl¿6 El

ü
Case ID: 190102559
Ëeie ïnyfrur @Åltonstrna ' Zl m rr
Replying ts @GpçsncrTannllfslf
Hnw is it thst Senator Beyüïn lnsch wtrs drmre mÊ tü his epertment when I rres
1î snd sexualþ æ,ssuked me, end urhs lree hurt nthers- ls ellsrryed tn grendstend
from * podiufit, Õn thcse irsucr? Completing wad* for vietirns shauld indude nÕrt
having predatcrs invsived in these insues.

Ç ffi çr Ël

Case ID: 190102559

 *l¡Ë ¿ t-{Ê I ¡t \JË IU t-J

fiara Taylar
Follnw \1
@'Altnnstnra

Replying tÐ @pghÌr¡üRML @JnhnFetterrnsn and Z çthers

Your cause is grËät, but Senatur Daylin Leach

is not. When I was 17, he drove mË ts his
apãrtmËnt and sexuãlly assãulted rnË and he
has hurt others since thËn. I dün't knüw why
äny$ne $Iüuld suFpürt fi predat0r.
9:44 AM - Z6 Sep f$n I
I Retweet t
Ë t-f" I q? EI

Case ID: 190102559

E*m Tiiylnr @Åltonçûms - 6rR
\/
H*plyi*rg to ffi fiesseFirsF*{ @devllnleech
Wh*n I wEs I7, senetsr Srrylln Lr*ch droue mE to hir apertment end rexuelly
ersåÌJltÊd me, and hes hurt rnÊny othsrs *inrê, Now yüu knsr'u.
ficehnnhcnm/ca ra,taylü n I ff .,
,

q) ffi. trr EI

Case ID: 190102559

Earn Tie¡rbr @Altnnsürma ' Zl rn
Replying tü @GnvernnrTnmWslf
Hsw ls Tt thst Senator,Bayltln Lsach whn dn*r¡s me tÕ ïrie apartmÊnt when I wss
17 snd sexuelty sssåulted me and wlls ilss hurt ntfiera ls slltùr'red to grendstand
frnin a pndiufiT¡ üñ thesê îssues? Completing wark far victirns should indud'e nüt
having predatars inu$lved in tllese iËsuÊË.

Ç r3 üt EI

Case ID: 190102559

 af¿ t-{r I C. \*J 11' t*,!

Cara Taylor
Fotrtrqw nrr
@-Atttrnsünra

Replying tü @pghl',I$Rtb'll @Jçhr¡Fetterffr€m and 2 sthers

Your cause is grÊat, but Senatür Daylin Leach

is not. When I was 17, he drove me to his
äFãrtment and sËxually ässãulted me änd he
has hurt others since then" I dsn't knüw why
crnynne would support ä predatür"
9:44 Atrtl - ãõ Sep Aü1fi

1 Reürn¡e,et
t
q] T?I q3 EÏ

Case ID: 190102559

Exhibit F

Case ID: 190102559

l;¡ lJ,l l"lJ trlil r) (å ¡r lìl ìi. Érì rrl ,i(l ',, l J 4:11 / l'M

(- Co¡nrrrents

wâsted your tlme. You could

have as.., se¡r Mçrc
?nì Like Reply
Owrn 8nydrr
* Turêa, greppllng ând ãsklng
questlons ls totally pârt of thls
work,

And Colleen sald she *isnT*

saylng you should be klcked
out, I'm not elther.

But thls ls a group about

supportlng survlvors of sexual
essåult by powerful men and
havlng thelr backs.

Daylln ls a raplst and a

predator, a fact confirmed by
multlple women in thls group.

lf you donT belleve them, you

cêrtalnly have a rlght to that
oolnlon. however

fõì l¿Vrite a reolv..

trr @o

Case ID: 190102559

riìi l{l lll frr|j
. , q.!} (,} it. lll ù1. (') ,,r1,Ì()"1, l,l'ìt1l/ l'M

e Conrnrents '-{

Daylln is a rapist and a

predator, a fact confirmed by
multlple women in this group.

lf you dont believe them, you

certainly have a right to that
opinion, however
disappointing I find lt.

But lf you don't belleve them, I

don't understand why you
would want to be lnvolved ln a
movement about supportlng
and bellevlng survlvors and ln
partlcular survivors of
powerful politicians.

And I'll say for mysell we

started talklng after the Daylin
party, ând I was really exclted
to work wlth you and trled to
be really vulnerable and
honest, lt made me really sad
to frnd out that you had been
part of a host committee for

O þrite a reply... @e

Case ID: 190102559

Exhibit G

Case ID: 190102559

 Gwslr Snydcr lt ¡
' ' l.j:,ilì l,i, :ì: ,,: i ,¡ ' :;il 'j:j

F il 5 r'rt ilt* [,i *¡rl rrcr;tti¿: il i] Jr il tì iUnt lllegol ly

€i ì n$ Th,r ni I

deleted seuersl cornrnenls, including cne frorn black

as âct¡vlst &l*s:;r"lç {Jsåii},,r,rì3 calling ihem ñut fÐr
uslng a photc af taylln Leach FcËir¡g with a yûung
hlach g¡r[ ññ pårt rf their eute liitle 'þo hrnar MLK bv
¡:icklng up trash' faeebook Boat"
As ü rêfifildet Saylin ts +t*dtfrly ðt*usêd of raping n
lT y€ür dd and cümnr¡ttlng vâr¡olts ä*t$ üf seruål
nris*onduet egeínst å nl¡ffihÈr nf other yäutlg wårnÈn.
l#e¡rs already looking to go a{ter Faylir,r for il}egally
hlocking his çovernrn*nt reecurcçd ïwitler frsrn public
viewing, *nd ¡t nðulr it lusks like ifi* säuel.rs ls fixing te
get sueel, tna.
¡!{rl åt.r.¡ðT q¡It,

i*¡f ,"¡r.el¡ tr¡ lclr¡¡r.v ll¡. i{lrx¡ ç gr*frrpv: }y tr*ip'r:g athrv*

¡¡]ff þr., t¡irr{ fjür r OlÌrrrli¡f,,lh:.J

+¡tl¡¡ r $sn¡c üf !l!r thilr{r 0tlr Ssnst.Jrc $id u{l the

M¿ { {trl *t 5a!Yêr:e
- l{rlBot{ burlel vççlt þ,{a

I
- l.e¡f d ¡'rt¿rFi'"ídqúf üûr l]¡il¡1¡ôg;t..¡tt'tftLtt

[|--. t'.. 'i, i'ullu'olit

o ¡
I :É,
::t...¡¡!.r.r;b.il¡i¡
¡*-. , r.
r.?!r, '¡Ô.t irr-tr

r--.d¡L . rãlrar¿

Case ID: 190102559

Exhibit H

Case ID: 190102559

8i54 4 ..t utE cJ,

3,586 views

Çz u1e üos ,a

co99ie
@cassieowens

Gwen Snyder, a local activist,

addressed the crowd, instructing
demonstrators to tweet calls for
State Senator Daylin Leach's
res¡gnation: "lt's time for Daylin to be
gone," she sa¡d. "He put his twitter
on protected status, but that's not
going to stop us."

10:43 AM . 1119119 . Twitter for iPhone

7 Retweets 24 Likes

Ç t] O rlJ

coaaie @cassieowens . 1119119

- Tweet your reply

o
q o g
Case ID: 190102559
Exhibit I

Case ID: 190102559

 8:53 f .rtl LIE l¡ l:

Tweet

Gwen Snyder is uncivil

@gwensnyderPH L

THANK YOU to all the badass

#WomensMarch20l 9 #philly folks
who are taking out your phones
today and letting @daylinleach know
that #TimesUp and we're done with
rapists holding office.
Tcgether, we win.
r* I

12:33 PM . 1119119 . Twitter for Android

I Retweets 18 Likes

Tweet your reply

a
a, e g
Case ID: 190102559
Exhibit J

Case ID: 190102559

 i helieve her, Follow \.t
@baCKennedy

He statutüry räFed @Altons0ma s0 nü

thä n ks.

P*Senateltrem s Ü æ Pa SenateD*m s

Does sflmsûnË yÐu lnve have a substance ahuse addictisn?

Í-
th
É

Visit @daylinlsarh's tpen Houss sn Addictîon To¡.¡r stop in

Harherth an THURSDAY fram fr to $pm....

8:25 AM - 36 Sep 3üIfr

1 Retweet
t
Ç tfl {? E

Tlveet yruF r*ply Case ID: 190102559

Exhibit K

Case ID: 190102559

I tl €v¡1¡¡yto*R+twcta{
Collrrn lhnmdy @by-Cl{ennedy ' 17 Ott ¿018
Hi Orylln laach srxurþ a¡¡¡ulttd GlltorÉn* whèn the tn]ô3 l? yeôrs old,

fhe ltdd tmtrr 0fieldcsnter

Replying to 8d¡ytinle¡d¡ SSençr€€nleaf
thrnk pu @$rnG¡c¡nlr¡f rnd @drylinlerch Íor your hrderuhip, p*ûbtons€
8t rupport of trrñk*ing uictimt to m¡k¡ S¡Íc tl¡rbor ln Fennsydwnie e nalily.
Nou oa to llts S¿n¡tr ¡nd @frawmorTornllVolf to ryukr ll lupprn!
*Ch ldïr¡ffi dting f ChiltlWelfrr* ûGrxÏnficft ln¡

ç tlr t?¡ E!

tl Conl¡ylor8tt¡trtcd

o Mrü HfilÇl @hdåtrAõc¿? . l? 0ct ¿018

Flour* Mrjoriþ Le¡der Orw R€€d 3ðyl th¡y r.T{ll nôt ¡cÊEpt bill thåt dëê¡n't
lnclude civil window ih¡t ¡ltows viclim¡ to filc suit lgåirut instilution&

Ç Lls 1?¡ EI
{l fur¡ TrTlor ÊffÈ,Ërtcd

o üwrwomrnlü?

To
@Er¡err*or¡enl0?
&eplying lû lBdtylrrdoæh
'I tlgt ¿CIlÊ

rll tho¡r pfliring ôd¡ylint$gr tor hi¡ rltponlð to th¡¡ port pbås.e knolv thlt
he ir a rerial h¡rer¡¡r/¡bus,sr cf rtomcn snd shqutd resign immedietely. Kthltu.
v

q) Îf r 12s Ël

Case ID: 190102559

Exhibit L

Case ID: 190102559

t
I
û¡lLl0-tünEt
.tåãôry 1] ¡l ¡ !F
*r llTrh
Fti tl
tårû TrTior dilJ g olhs*¡

hrfË ùêGrì ð3kûft Ùy t coup¡c û{ nffilr È$¡{lôd lr0BÞl0r¡ ünd 'ltlGlf !üail ìlllül
lllc Þgulrtm wrnda ls tor ln6r 0{ os whq ¡ì'rnl sôïlln L€o{h fiËmorsd fonr
$ilìûc, I lhl'llr ml quÊltþn l¡ EompllcÉtrd lul h ollrÊr $€yi, ll'¡ 9{?tly NlfnplË
w! d{dt'l r'ûfrt û ¡,1ûlË ¡olrülùf rño bsr FrËyÊd won tlìe moül vulnâftbþ n
ollEü,
l/ïb rlofllr'wnt t üslË ¡¡ffrlor fi ¡ Þo¡iþn ls fsftGw Nfid vê crmrt.il þnttcr
lGgslillrf ltlrlb fiü rlûní3 acolrûêd ol rìûlÈüne ht body 01å l1 yúü ôlü sltl
wb mil ts Nrs {t{ËÎoo lËsþlstiûn, lrlìElr lhÈ lü3¡ rlðr$ 0l,egFlatof} låiled l0
dr
so ñrny gromrn tìroflçd lo gü ftrs nrw cle$ 0l lÊgisl¡lofs glect€d, ¡fld ¡
rotnpletuy unðrßtôfr{ lhff 0Ê31È þ pnoñt¡ö r }ûrtlttìa agûndå ü¡N¡ lt*lpt
rßryafi€ in utlr úHtilct ll nìr¡it fêÊlorenfiñðttríq, þYflg i0 nihe ülllhete
oeo¡¡onr
t,lu3l tilr tôu ¡ll lô nûufltùtr ¡ Êoosç aÎñlngi:
{1} llrt }Tûrt þ gsl l0 mß pornt hðÈ ul{Ëû }'Êãr3 YêûË. å1û manl $alìc ,Ûll ìnis
$!,rl( fgfçyôf btcruÍ{r lnçT luit çüul&r1 tüke þd¡lging ttËlr hêåd¡ rg*ñrt ttre
rìBfr | þtl lÒr s¡rtllè. ånd ln btdr I lllþn thål ümo[ûlr¡l F¡ltl
{3} tln vulgüfitT rf ¡ho giudy {lr*plr! m $ü vrüeo, lhe unnformt(l }rtrÏlêlt ôflo
3lülleH Fâlü þf by oErlh- &{iF00 ttlÈ erËñtnËec ol fnf frtçñd¡ nftt
coûÈrg¡rGr llt$uld nrs¡r rot¡ þ ¡pçslr oul I lropr ¡t lTlll Mûrs nìan tnÊL I hoÞr
lw aÍ ¡{nÈffu}tt ftclr 3ftrhHn0 âtlaKks a&t lhe tnå(tlon olo{neÊ trË it¡cilt t!
Btlñlut Nlrùy6l ArG äÊ 0l lha poiltl ¡n lhF 1I9r* $l'tËfc vse dôJn ùrfr ¡ F*¡¡nn
ûn Ìåpc?
TErg på3t mofih. as$Ê{¡rll$ nsË ùåao füûlly ddüiul ffi mÈ I $'Û{tl t0 tåtgôot
lrrt rngüf âñd uË çvÊ¡yürc'¡ fn6nc I trtnÌ b ltûl ü(Ë $e ürt åll fi lnÈ¡ ltsüF|ef .

bul lhtl rfn I trü,r I tufiçrlÜT fsgl ldayþê Ûlrfr r¡nfôlr, ånctr on!f' trn. ull lË¡ ln
lrMt fôgûil! I r* tfllÌ{ lû hÊlf td1¡t oll}€r3 38y, üm t rm lrying lo þËilnÈ Öut
rüË $ rllT påln ¡nü l¡¡lt lål(è l$l{r onc $lûp rt ! mê, Ðut ro{{tll$e* lhot
fæ$ rmpo$$lDlê

nc ¡oHlfly I i8? in 8ü! vrtùô: frnrn DårÍt v{cllmr sßd Eüs! vYllo härû
îûÈc{ dm[8r SGsrål rldè¡lÊt, li lrtlål ß þtrt lùout Ùl¡l üt'0grls¡r,.€ mwüiler}l
I hap,! gaqpÞ ¡ril þc msvüd lo rd
thðñt yau,
lmpv{rnl Þs sof$o çl l¡rsla lh¡r99. ltlü lh€ minonry chô¡!¡8in$üp, dol¡'l lìtBe
ån íirÍÊdl¡tta toå{lû¡ì, bul clÊf¡tÊ lsnt $t 8n$¡tr. L8ffn$ Ttr{ ToiÊt t0 lhÊ
tìduÊË ü(llf¡c$ioÍ d !nü $rong ìrrll Bûy rl rolumca n potltlîr! cðpnill, tnd I
lrti Fffi¡t tlvlì¡fi $Ê knsrÌ tborl yËi¡ s, &al !9$ än îltrt lsr whð{ l} fl0lÍ

Case ID: 190102559

Exhibit M

Case ID: 190102559

 efn Tfylcr'r-,,1¡ll{:,rJ1ìUinâ , i* Ltit /t11il
l i{oly ehit, Thatr rny repiut. Þeylin l*arh. Wh¡t krnd pf ¡ wsrld do ne liyç ¡fl when
pr*dlt*$ ts hidê iüÌ Êlåiû righr?I
'"r

- ûÊt

Fr8r*¡tr0rml O ü'Falens tç$çrnç

I ,Sdr¡{inl+ech'g 5¡f* lt*rbcr ball is nËrv nerting ihe
i
Çsvêrnûr'r åEnst$rÊ.

-Ïher* is no luch tÞrsrç åe r clritd pra*ti{rtç. Thtre ¡rc,..

{"}'r t3z *r B
Cfn lfyl6f 4¡ìp¡l!ç¡¡rí]nr4 , II (ì{t;'i'1¡l
^.
l¡ ,, ;¡ ¡tmä*r untre¡esblç te gås rny r¡¡?i$t 5en*ior *aylin [**ch, *ônrist€nt]y ånd
O slrÐlÊgrçðrfy prit.,ng nrms?r¡ pËnrf'ro rña pooiurn r*rn IFur an{r r*Êr*sÍ vì(¡rrns.
surøivo$ åfld ådvç{ätçg lt f*Ê[$ lrkë !*ng åÞlr€d åîd turnêd lnl* å cnrnin{l $l¡
(¡Y€f rgårn snci agarn cnd agarn,

FA l.lq¡r grmocrrg I
SF¡f iïr¡¡ri,ier?¡r
.@ñepÊsrr¡ x*yl he's nrt gêing ¡nywhqrê snd he øn I
rtop fightinq brcln rgatnrt ¡çx¡.r¡l ¡bura.

t3 t? ; *-ì

Case ID: 190102559

Exhibit N[

Case ID: 190102559

 COMMONWEALTH OF PENNSYLVANIA
COUNTY OF PRIVATE
Mâgislsriå¡ Disuid N¡¡trùôr; CRIMINAL COMPLAINT
Mùrl,¡rmr HOn.

Addr€$:
COMMONWEALTH OF PENNSYLVANIA
vs.

T€lephonsl
TDEFEN
DANT:
NAME and ADDRESS
-l
Daylin Leach
601 S Henderson Rd Suite 208
Date Filed: King of Prussia, PA 19406
OTN:

to çourt personnel)
L (Fill in defendanl's narne and address)
__J

Notice: Under Pa.R.Crim.P. 506, your complaint may require approval by the attorney for the Commonwealth before it can be
accapted by the maglsterlal dlslrlct courl. lf the attorney for the Commonwealth dlsapproves your complaint, you may pell¡on
the court of common pleas for revlew of the declslon of the attomey for the Gommonwealth.

Fill in as much information as you have.

Dcfondânf s Rrc€/Elhn¡city Defendent'$ Defendantis DO.E. Dofcndanl'E AK-Â. {âl¡o known as)
Ser
B whíre E Brack E Female
06123161 Ðave Leach, Dutch Laroo
E As¡an E NativâArnsricân E l,ta¡a
)êhndânt's veh¡cl€ ¡nformâtlon
E Hispanic EUnknown
tlate i¡umbor Slato Rsgisùat¡on St¡cksr (MM/YY)

unknown

I, Cara P. Taylor
(Ners ol Cor¡olsimt-Fþas Pr¡nt or TtD€)

do hereby slate: (check appropriate box)

1. El laocuselhe above named defendant who lives at the address set forih above
El I accuse the defendant whose name is unknown to me but who is described as

fl I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I
have therefore designated as John Doe.

with violating the penal laws of the Commonwealth of Pennsylvania at Trexler Park Apartments __ ..

(PlâGPoüUcd SuþdMston)

tn Lehiqh County on or about Summer of 1991

Participants were: (if there were participants, place their names here, repeating the name of the above defendant)

Daylin Leach

AOPC 4114 Paga I of 2

I
I gln* ! fç o*
r 5$ål,l$F.ffi[EJnlJn"r',u

Case ID: 190102559

 Defendant's ¡¡¡¡s;Daylin LeaCh
PRIVATE
CRIMINAL COMPLAINT
2. The acts committed by the accused were:
(Sot foñh a âummary ot the lacts Êutt¡claDt lo edvlse the dofondant ol lho natura ol.lho offsrs€ charged, A clta[on
lo ths statutð allogÊdly vbtBted, w¡thout ñorÊ,
18not sumdant' ln s summary câsè. you must c¡te lh€ Bpsc¡fic ô€ctlon snd sub¡sctlon of thè st¡tutðor od¡nance allegodly
vblatad.i

Sexual assault of a minor by forcible compulsion. During the Summer of 1991, during which
time the private swimm¡ng pool for Trexler Park Apartments was open and available for use
to the residents, Daylin Leach picked me up from my home located at 215 E Walnut Street
in Allentown, PA, telling me we had to talk about my mother's case, as he was her criminal
attorney, and drove me to his apartment located in the Trexler Park Apartment Complex
where he sexually assaulted me. I was 17 years old, having turned 17 on March 25th of this
same year. Upon enter¡ng the apartment, after getting himself a drink from the refrigerator,
Daylin disappeared into a room and then called my name. I got up and went to where I had
heard his voice coming from. lfound him naked, with only his socks on, lying on his bed
stroking his erection. Daylin then said, "Come help me out". ldid as lwas told, getting on
the bed, on my knees between his legs and put his penis in my mouth. When my tears had
visibly annoyed him, he took a bottle of red lubricant from his bedside table and poured it
onto his genitals. After he ejaculated, I went into the bathroom to clean his body fluid off of
myself and when I returned to his bedroom he was dressed holding his keys. I followed him
out the door and he drove me home.

All of whlch were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of
Assembly, or in vlolatlon of and
a¡g;¡_ ($Þi€cüm)

of the
(PAShrurâ)

3. I ask that process be issued and that the defendant be required to answe¡ the charges I have made.

4 I veriff that the facts set forth in this complaint are true and conect to lhe best of my knowledge or information
and
belief. This verification is made subject to the penalties of Section 4904 of the Crimes cooe
fta pa.C.S. S 4904)
relat¡ng lo unswom falsificatlon to authoritles,

5. I certiff that this filing complies with the provlsíons of the Case Records Puôlrc, ccess policy of the
LJnffted Judiciat
System of Pennsylvanla that require filing confidenlial information and documents differently than non-confidential
informalion and documents.

D¡te Slgnalure of Complalnent

office of the Atlomey for the commonwealth fl Approveo E Disapproved because

(l,låme ol Albrnoy f$ Commwsslth.Pl€aå€ Pfiût or Typo) (Sþnål$e of Anornsy lor Commnrôalthl (0at')

AND NOW, on this dale , I certifr that lhe complaint has been properly completed and verified.

SEAL
{Mrgisrefisl olltrict) (ls8u¡ng Authortty)

AOPC 41 1A Påore 2 of 2

ll'ffi =
ót,^,,,, 55åE,if IFffiãEIff i"h,.

Case ID: 190102559

 CRIMINAL COMPLAINT FOR USE IN FUTURE CRIMES
COMMITTED BY PA SENATOR DAYLIN LEACH
Written byl Cnrn Taylor
DOB 03/25n974
2918 E Walker Rd
Bsth, PA 18014
il0vescabbysirl@smail.co Ut
610-762-0043

My name is Cnra Taylor and I ¡m a sexual assault victim, My abuser's name is Daylin Lench and he is
currently a PA Senator. I was 17 years old when he assaulted me. He wss my mother's criminal defense
attorney. Daylin didn't just physically abuse me. He also convinced me, tbrough severe and repeated
mnnipulation tactics, to commit perjury by trking the bl¡me for whnt my mother had done, and because of
this' I hnve been r felon for my entire sdult life. Daylin ¡lso convinced me to hrve a child in an attempt to
have a medical reason for a requested continu&nce of my mother's trial. I wâs â utripper during this period
of my life' Currentl¡ I am a 44 year old wife, mothe¡ and grnndmother. I am not a carßer criminal.
This is my true story.

1990¡ My age - I first met Daylin at this time when my boyfriend and I needed a lawyer for a
16.
landlord/tenant issue. My father came down from New York to pay Dnylin for his help with my legnl issue. I
was living wifh my boyfriend in an apartment in PA. I h¡d left home when I was 15.

Feb 1991 - My mother{Kathleen Speth, DOB l2t?ltl945) was arrested and charged with attempted
homicide. She hnd tried to kill my stepfather (Detwyn Speth). When my motherwas ¡rrested, I took my little
sister to live with me. Once my mother was bailed out she came to live with us.

Spring f99l - Due to my mother's continued crying and pleading regarding her fears surrounding having a
public defender, I approached Daylin about helping my mother with her case. Daylin accepted. -

Spring and Summer l99l - My age - 16; I turned 1? on M¡rch 25 of this yenn Daylin hnd been talking to
me on the phone and in per.sonr rlthough it was mostly in person, forweeks. During this time, Daylin would
tnlk to me about how he did not know how to defend my mother unless someone else hsd done it He would
ask me questions about where I was that night, about my life, about why I hnd lcft home at such o yo,rng
age. He would ask me questions ¡bout what it was like to be ¡ stripper, irow much money I mrde,
wtrere I
worked. He explnined to me how I was onþ 16 when the crime w¡i committed, how thebAwould n.nu,.
swÍtch defendants and how even if they did, with me being a juvenile, minimal timewould be sewed
whereas my mother was looking tt decades behind bnrs. Daylin assured me that perjury wasnrt an option
for the DA either, th¡t no one ever got charged with perjury. Every time I would ashhim a question like,
'(What do you wnnt from me?" or rrl don't know wh¡t to sayn what nm I suppose to say?" Daylin would tell
me to go home ¡nd talk to my mothen After weeks and weeks of this, and weeks and weelis oi my mother
cryíng ¡bout how she didntt know how she was going to get ouú of this, after talking to my mother about
how Daylin wouldn't atrswer my questions a1d having her explain to me that there were certain things a
lawyer couldnrt be involved inr l knew what I had to do. I remember the day I walked into into Dnylin's
office to give both him and my mother what they wanted from me like it was yesterday, and for decades I
have taken more thrn my share of responsibility for this. It was my idea fo agree to this plan, but the plan
wûs never my idea.

My assault - During the Summçr of lg9l, during which time the private swimming pool for Trexler p¡rk

Case ID: 190102559

Apartments was open and avail¡ble for use to the residents, Daylin Leach picked me up from my home
located at 215 E Walnut Street in Allentown, PA, telling me we had to talk nbout my mofher'c case, and
drove me to his apartment located in the Trexler Park Aprrtment Complex where he sexually assaulted me
using forcible compulsion. I w¡s 17 yerrs old, having turned 17 on March 25th of this ssme yeån Upon
entering the apartment, after getting himself ¡ drink from the refrigerator, Daylín disappeared intó a room
and then called my name. I got up and went to where I hrd heard his voice coming from. I found him naked,
with only his socks on,lying on hís bed stroking his erection. Dnylin said, "Come help me outrt.I did as I wns
told' getting on the bed on my knees between hts legs and put his penis in my mouth. When my tears had
vlsibly annoyed him, he took r bottle of red lubricant from his bedside table and poured lt onio hÍs genitals.
After he ejaculated, I went into the bathroom to clean his hody fluicl off of myself and when I returned to his
bedroom he was dressed holding his keys. I followed him out the door md he drove me home,

Late Summer l99l - My age - 17. Daylin told me that he was out of reasons for continuing mom's trial d¡te.
He told me thnt f was a key witness and that if I were to break a leg, get sicþ or get pregnant, that he would
have a v¡lid reason for asking for a postponement He said he needed one, that he wasnrt prepared at all to
defend hen I completely believed this because we nevor spoke about anything important the way I thought
we should have. He told me that if I were to have a bab¡ that they delinitely wouldn't go to hard on me if
they decided to come after me for the actusl crime. I didn't want to break a bone or get sick, so I got
pregnnnt l did that I did that horrible act to two eompletely innocent lives and have hated myself ever
sinçe. My son was born on March 20tho 1992, and five days later I turned lt. Daylin got the continuance he
w¡nted and I was an adult when I committed my crime of perjury.

June 9 and 10, 1992- My age - 18. I turned l8 on March 25'h of this yenn I spent 2 days testifying that I had
done what my mother rv&s accused of. I wns the only defensc witness.

June 1992 - My motherwa$ found guitty. On the day of this verdict, I wrs out in the courthouse hall when
Daylin told me I hed to meet him at his oflice right awny. I did as I was told ¡nd walked oven He came ouf of
his oflÏce and told me that there w¡s trouble. He said they were coming ¡fter me for conspiracy and that he
never s¡w that coming ¡nd fhat Ít was a bad thing. He told me that I was smartn that I was a gôod girl, that
he was going to call me into his office in a few minutes and that I had to follow his lead and answer his
questions, that he knew I would know how to do that. He told me we had to record it. He told me I had to
ety. He left me rnd went back into his office, When he came back to get me, he took me in his offlce and held
his finger up to his mouth (shhh) and pointed to the tape recorder sitting on his desk. He held his hands on
his he¡d nnd sat in his chair while he said ttC&râ, please tell me I did not just send an inuocent rvoman to
iail.il I w¡s ìnstnntly petrified. I knew something bad was happening, but I didntt know what, and I was so
scared, I instantly started crying. I answered all of his questions the way I knew I was suppose to. I knew I
was protecting hlm and me, but I also knew I wås no longer protecting mom and that made me feel sick.It
didn't last long, and when it was over, he literally pushed me out the door, telling me to go homen that he
would call me.

Sepfember 2,1992 - I was charged with perjury and false swearing.

November 12, 1993 - I entered a guilty plea,

November 15, 1993 @9am- I turned myself in, as ordered, to sen¡e my sentence.

December 17 r20l7 - An srticle in the Phitly Inquirer came out rbout Daylin sexually harassing female staff.
This snme day' I contacted one of the reporters, Angela Couloumbis. She met with me and *p.ot months
vetting me, only to have her editors pull the story days before publication due to Daylin,s larvyers
threatening to sue' I was told, ironically enough, thnt because of Daylin denying rny kind of a,.relationship"
with me in a PCRA hearing, that the paper would basicrlly be accusing him of perjury and that was a pretty
bnd thing to do, so thcy would nof be printing my story.

Case ID: 190102559

Daylin did what he did to me, but there âre mâny other people who failed me during this time, other than
my own crazy mothen None of the rdult profession¡ls involved in any of this stepped up to help me or to
even try to do the right thing. Corporal Stnte TFooperArsenio Rosn went to the ADA, about his wÍtnessing
Daylin feeding me answers while I was on the stnnd, yet Corporal Ross was the one to fill out and file the
Criminnl Complaint for perjury agrinst me. Rosa never filed anything against Daylin. My public dcfender,
Karen Schuler, she was made twâre of what Daylin did to me and not only dÍd she choose to ignore the
inform¡tion but she then didntt even bother to show up on the day I plead guilty; r man was there to help
me and he asked me if I could resd. The Disciplinary Board was notified and dismissed the claim. Charles
Seiger, a new attorney for my mother, was told also and not only did this man not report the crime that was
reported to him, he also talked my mother out of talking about what Daylin did to me during that snme
PCRA hearing in 1999' while she was on the stand, because I was a felon for periury. And last but certainly
not least, there is formerADA Michael Mclntyre, who has admitted, pubticly and privatel¡ to knowing what
Daylin wrs "up toD yet refused to notify the prnper ¡uthorities and instead called for charges against me.

My intent is neither to absolve myself of blame nor justify my crime, but rather to share responsibility with
those who desene to share it with me in nn effort to bring attention to the wittful ignorance of mandated
repoÉers in the hopes that this type of self-preserving behavior can be prevented from happenlng to
someone else. Blnme can be a harmful, ugly thing. Unless it Ís deserved,

But now, this is no longer about me. It is all too late for me. Tlventy-seven yerrs have passed nnd I am ae
broken oras whole as I will ever bG, nothÍng can change th¡t for me and I am partþ to bl¡me for all of it.
What can change is the ability of all of us fo help thc next person. Whoever it is who h¡s come fo you with a
claim against Drylin, please listen to them and please know that they nre not nlone. Please know that there is
mueh proof' and many other people, who have been immeasurably harmed by this man; this man who is
allowed to make and vote on laws that govern over the rest of us. This man who pretends to be a champion
of women's rights' lÍterally surrounding himself with a potential victim pool. Please know that you, as a
person in a position of power, hold not only the ability to possibly right a wrong to the extent that the lnw
allows, but to also play a large role in saving nnother victim from all of the crippling effects that come along
wifh feeling powerless against a powerful man and an even more powerful system, Justice can be a harmful,
ugly thing foo, and I have rarely been comforted by the meaning of it lVhatts done is done. Time can't be
taken bacþ hurts can't be undone, lives can't be relived. You can apologize all you want to a broken plate on
the lloor, but it doesntt chnnge the fact that the plate will never be the same. \ilhat ean happen, thoughn what
we should strive to have happen, where there mþht be some small amount of justice, that hopeful reality lies
in our ability to prevent the repeated behrvior of known predators and real criminals, no matter how
powerful they have become.

Ple¡se help, however you can, whoever it is who has come to you. Please tell them that they are not alone.
Please tell them that I will hate myself forever for what my own inaction has contributed to, in what has
happened to them, and while I rtalize that the utter emptiness of my regret witl do nothing to contribute to
their wholcne$s, please tell them that I promise it will never happen again, It will NEVER happen again.

Case ID: 190102559

Exhibit O

Case ID: 190102559

OüÌ* ìi.ìrl"!ìr¡!i lllr.jr¡.,

¡f--r f lko i, J {Ìçrnl:¡rt¡ fj.l Shnrr,

ü*rä srrTdär
û 1 '' .i,j. Ì ì{ì ¡r ;
l' trl
Y'¡rIì. fíl
{r{tiñ¡ rnìãd{rñdue! {rÊoFåtsbitity
¡t
t¡ðË|ry ¡{¡tliff lhtì[d d{l,fï I hðf.r rÞ¡t¡ìrf.{il ôrðéri'S
Rêûd ç{-}rrlr sr.¡$¡, ð FfugB nox( lð i! rf !çrv{'{t l'ût
Ëåíqri'*,.ü!d Ëtrñltï 0! Ëp¡Ë* lolÈ *f*r Íor n6r6.

Ot rr .i i:niittlìr1ìl:,

#J li¡t {--^í *onrmrnr i,1 $håfrtr

t õvÊngfiydriú
Tt .r

'?l
rrir. /: ¡., ,.

;':j r'4
'. , ' trl

:,

Case ID: 190102559