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infor@amgglobalentertainmentgroup.com
717.731.8184 Phone
717.427-1621 Fax
Stan Caterbone
Advanced Media Group
220 Stone Hill Road
Conestoga, PA 17516
July 9, 2006
put this concept is: no crime - no RICO violation. This rule applies even in the context of
civil RICO claims. Every RICO claim must be based upon a violation of one of the crimes
listed in 18 U.S.C. 1961(1). The RICO Act refers to such criminal activity as
racketeering activity. RICO claims cannot be based upon breach of contract, broken
promises, negligence, defective product design, failed business transactions, or any
number of other factual scenarios that may give rise to other claims under the common
law. This being said, a RICO claim can be based upon violations of the criminal mail and
wire fraud statutes. The mail and wire fraud statutes are very broad. Some creative
lawyers have succeeded in arguing that the mail and wire fraud statutes have been
violated by fact patterns that superficially appear to give rise only to claims of negligence,
breach of contract, and other actions giving rise to common law rights. If a RICO claim is
based only upon violations of the mail or wire fraud statutes, however, courts are likely to
subject the claims to stricter scrutiny. Courts look more favorably upon RICO claims
based upon true criminal behavior, such as bribery, kickbacks, extortion, obstruction of
justice, and clearly criminal schemes that are advanced by the use of the mails and
wires.
?? RICO addresses long-term, 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 single criminal act, short-term criminal conduct, or criminal actions that
bear no 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. 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.
The former patterns are referred to as closed-ended patterns; the latter patterns are
1
reasonably should have discovered your injury four or more years ago. Many
people are mistaken that civil RICO claims are not subject to a statute of limitations. True,
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. Civil Rico's statute of limitations begins to
run when the victim discovers or reasonably should have discovered its injury. Many
people also believe that the statute of limitations is reset every time a new criminal act is
committed - this is not true. 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. That
being said, however, 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. In addition, acts of duress, such as "if you sue me, I'll kill you," may toll the
running of the statute of limitations. 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. Also, if a defendant engages in a new pattern of rackeeting, that
causes new and independent injuries, a new limitations period may apply to those new
and independent injuries.
Of course, these are merely general considerations. Consult with an attorney to determine whether the
facts of your particular case give rise to a RICO claim.
STANLEY J. CATERBONE,
Plaintiff
v.
No. 05-CV-2288
JURY TRIAL
Defendant, Fulton Bank, by and through its attorneys, Barley Snyder, LLC, hereby files the
following Response in opposition to Plaintiffs Motion for Ex Parte Meeting with the Honorable
Mary A. McLaughlin: On or about June 2,2006, Plaintiff filed a Motion requesting an ex parte
meeting with the Honorable Mary A. McLaughlin "to discuss the problems of preceding, this
action without obstruction of justice; and to amend the original complaint as discussed
previously." See Plaintiffs Motion. However, Plaintiff provides no justification whatsoever for
his request for an ex parte meeting with the Court. Rather, Plaintiff apparently labors under
the false assumption that by proceeding pro se he is absolved of all responsibility to comply
with the rules. Such is not the case. The fact that Plaintiff decided to be his own lawyer does
not excuse him from following the rules of civil procedure or entitle him to any particular
advantage for lack of legal training. "The right of self-representation is not a license to abuse
the dignity of the courtroom. Neither is it a license not to comply with relevant rules of
procedural and substantive law." Faretta v. California, 422 U.S. 806,834 n. 46,95 S.Ct.
2525,2541 n. 46,45 L.Ed.2d 562 (1975).
In the instant case, Plaintiff has no greater right to be heard than he would have if he were
represented by counsel. As a pro se litigant, Plaintiff, in essence, stands in the place of an
attorney. Plaintiffs request for an ex parte meeting with the Court in this case violates Rule
3.5(a) of the Rules of Professional Conduct because it is clear that Plaintiff seeks to influence
the Court with his version of events, without providing defense counsel any opportunity to
respond.' Since an ex parte meeting with the Court would violate the Rules of Professional
Conduct and provide Plaintiff an unfair advantage over Defendants, Plaintiffs request for
such a meeting should be refused.
HISTORICAL BACKGROUND
The following is copy of an Affidavit that was filed on January 31, 1998 in the chambers of
Honorable Stewart Dalzell in a desperate attempt for due process of the issues contained
herein. In November of 1997 the PLAINTIFF sought the counsel of Ms. Christina Rainville
while employed by the firm of Schnader, Harrison, Segal and Lewis. This was the last
attempt by the PLAINTIFF of seeking competent legal counsel. Ms. Rainville acknowledged
and communicated to the PLAINTIFF that the firm had barred her from representing any
additional clients from Lancaster County shortly after the PLAINTIFFs solicitation; which she
had plenty of solicitations from other potential Lancaster County clients. In the document
titled Plaintiff Finding of Facts it is clearly documented that the PLAINTIFF did attempt to
solicit and retain several competent lawyers since 1987, all of who displayed conflicts of
interests, and some went so far as to violate rules of ethics concerning client/attorney
privilege. PLAINTIFFs filing as Pro Se Litigant was the only alternative available that would
protect and preserve the PLAINTIFFs legal standing and right to due process. The following
excerpt from the Affidavit will demonstrate to the court a factual account of the events that
precluded and provided the Plaintiff the legal standing to file the original complaint on May
16, 2005.
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I, Stanley J. Caterbone being duly sworn according to law, make the following affidavit
concerning the years during which I was maliciously and purposefully mentally abused,
subjected to a massive array of prosecutorial misconduct, while enduring an exhaustive
fight for the sovereignty of my constitutional rights, shareholder rights, civil liberties, and
right of due access to the law. I will detail a deliberate attempt on my life, in 1991, exhibiting
the dire consequences of this complaint. These allegations are substantiated through a
preponderance of evidence including but not limited to over 10,000 documents, over 50
hours of recorded conversations, transcripts, and archived on several digital mediums. A
Findings of Facts is attached herewith providing merits and the facts pertaining to this
affidavit.
disclosures of International Signal & Control, Plc. However, the merits of the violations
contained in this affidavit will be proven incidental to the existence of any conspiracy.
The plaintiff protests the courts for all remedial actions mandated by law.
Financial
These violations began on June 23, 1987 while I was a resident and business owner in
Lancaster County, Pennsylvania, and have continued to the present. These issues are a
direct consequence of my public disclosure of fraud within International Signal & Control,
Plc., of County of Lancaster, Pennsylvania, which were in compliance with federal and state
statutes governing my shareholder rights granted in 1983, when I purchased my interests in
International Signal & Control., Plc.. I will also prove intentional undo influence against
family and friends towards compromising the credibility of myself, with malicious and selfserving accusations of insanity. I conclude that the courts must provide me with fair
access to the law, and most certainly, the process must void any technical
deficiencies found in this filing as being material to the conclusions. Such arrogance
by the Courts would only challenge the judicial integrity of our Constitution.
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1. The activities contained herein may raise the argument of fair disclosure regarding the
scope of law pertaining to issues and activities compromising the National Security of the
United States. The Plaintiff will successfully argue that due to the criminal record of
International Signal & Control, including the illegal transfer of arms and technologies to an
end user Iraq, the laws of disclosure must be forfeited by virtue that said activities posed
a direct compromise to the National Security of the United States.; the plaintiff will argue
that his public allegations of misconduct within the operations of International Signal &
Control, Plc., as early as June of 1987 ;demonstrated actions were proven to protect the
National Security of the United States..
Pls., placed American troops in harms way. The plaintiffs actions should have taken the
American troops out of harms way causing the activities of the International Signal &
Control, Plc., to cease and desist. .
All activities contained herein have greatly compromised the National Security of the
United States, and the laws of jurist prudence must apply towards the Plaintiffs intent and
motive of protecting the rights of his fellow citizens. Had the plaintiff been protected
under the law, and subsequently had the law enforcement community of the
Commonwealth of Pennsylvania, and the County of Lancaster administer justice, United
States troops may have been taken out of harms way, as a direct result of ceasing the
operations of International Signal & Control, Plc., in as early as 1987.
2. The plaintiff will successfully prove that the following activities and the prosecutorial
misconduct were directed at intimidating the plaintiff from continuing his public
disclosures regarding illegal activities within International Signal & Control, Plc,. On June
23, 1998, International Signal & Control, Plc was negotiating for the $1.14 billion merger
with Ferranti International, of England.
International Signal & Controls organization, and Mr. James Guerin himself, ,
consequently resulting in adverse financial considerations to all parties if such disclosures
provided any reason to question the integrity of the transaction, which later became the
central criminal activity in the in The United States District Court For The Eastern District
Of Pennsylvania.
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3. The plaintiff will prove that undo influence was also responsible for the adverse
consequences and fabricated demise of his business enterprises and personal holdings.
The dire consequences of the plaintiffs failed business dealings will demonstrate and
substantiate financial incentive and motive.
undo influence and interference in the plaintiffs business and commercial enterprises had
financial interests. The Commonwealth of Pennsylvania as a taxing authority, Lancaster
County had a great investment whos demise would facilitate grave consequences to its
economic development. .
competition in the mortgage banking business and other financial services, violating the
lender liability laws. The Steinman Enterprises, Inc., would loose a pioneer in the
information technologies industries, and would protect the public domain from truthful
disclosure. The plaintiff will also provide significant evidence of said perpetrators violating
common laws governing intellectual property rights.
4. Given the plaintiffs continued and obstructed right to due process of the law, beginning in
June of 1987 and continuing to the present, the plaintiff must be given fair access to the
law with the opportunity for any and all remedial actions required under the federal and
state statutes. The plaintiff will successfully argue his rights to the courts to rightfully
claim civil actions with regards to the totality of these activities, so described in the
following Findings of Facts, regardless of any statute of limitations. Given the plaintiffs
genuine efforts for due process has been inherently and maliciously obstructed, the
courts must provide the opportunity for any and all remedial actions deserving to the
plaintiff.
5. Under current laws, the plaintiffs intellectual capacity has been exploited as means of
discrediting the plaintiffs disclosures and obstructing the plaintiffs right to due process of
the law.
The plaintiff has always had the proper rights under federal and state laws to
enter into contract. The logic and reason towards the plaintiffs activities and actions are
a matter of record, demonstrated in the Findings of Facts, contained herein..
The plaintiff will argue and successfully prove that the inherent emotional consequences
to all of the activities contained herein have resulted in Post Traumatic Stress Syndrome.
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The evidence of the stress subjected to the plaintiff, will prove to be the direct result of the
activities contained herein, rather than the exhibited behavior of any mental deficiency the
plaintiff may or may not have. The courts must provide for the proper interpretations of all
laws, irrespective of the plaintiffs alleged intellectual capacity. The plaintiff successfully
argue that his mental capacity is of very little legal consequence, if any; other than in its
malicious representations used to diminish the credibility of the plaintiff.
6. The plaintiff will demonstrate that the following incidents of illegal prosecutions were
purposefully directed at intimidating the plaintiff from further public disclosure into the
activities of International Signal & Control, Plc., consequently obstructing the plaintiffs
access to due process of the law. Due to the fact that these activities to which the
plaintiffs perpetrators were protecting were illegal activities, the RICO statutes would
apply.
To this day, the plaintiff has never been convicted of any crime with the exception of 2
speeding tickets. The following report identifies 34 instances of prosecutorial misconduct
during the prosecutions and activities beginning on June 23, 1987 and continuing to
today.
7) Given the preponderance of evidence associated with this affidavit, the courts must
conclude that In The United States District Court For The Eastern District of
Pennsylvania, Federal Judge Stuart Dalzalls findings of April 14, 1997, in the Lisa
Lambert case identifying acts of Prosecutorial Misconduct, now, by virtue of this affidavit,
now discloses evidence of a bona fide pattern of prosecutorial misconduct, in the
Commonwealth of Pennsylvania and in the County of Lancaster. Criminal law must now
determine if these disclosures would warrant investigations of a possible criminal
enterprise. This affidavit is of material interest to the Lambert case, for the very fact that
this affidavit compromises the very same integrity of the court, which would tip the scales
of justice even further from the peoples deserving rights..
In the truthfulness of this affidavit, The Commonwealth must concede Lisa Michelle
Lambert to balance the scales of justice, which no other act could accomplish. The
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Commonwealth must yield the criminal culpability of Lisa Michelle Lambert to the superior
matter of restoring the integrity to the courts; by its own admission of wrongdoing,
assuring the peoples of its commitment to administer equalities of justice, not inequalities
of justice. Balancing the scales of justice. Anything less, would take the full scope of
jurisdiction out of the boundaries of our laws, negating our democracy and impugning the
Constitution of the United States. The plaintiff must be restored to whole.
I was not defending the criminal culpability of Lisa Michelle Lambert, but rather assaulting
the judicial integrity of the Lancaster County Judicial System, from first-hand experience;
and making the point that such conduct eludes every major stakeholder from the truth
and justice prosecution and defense alike.
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PLAINTIFFS REPLY
PLAINTIFF filed the original complaint on May 16, 2005 prematurely due to the undo
influence and intimidation of several DEFENDANTS and other persons, entities, and or
organizations; specifically the threat of a fabricated criminal prosecution. PLAINTIFF readily
recognized the deficiencies in the filing and the lack of a formal complaint (affidavit and
finding of facts only), and had repeatedly requested information and procedural guidance
from the Court during the course of time that had elapsed until the ORDER of the Honor on
January 7, 2006. This had seemed especially difficult in light of the fact that the original filing
was sealed. In 1998 PLAINTIFF stated to the courts the following: I conclude that the
courts must provide me with fair access to the law, and most certainly, the process
must void any technical deficiencies found in this filing as being material to the
conclusions. Such arrogance by the Courts would only challenge the judicial integrity
of our Constitution. PLAINTIFF acknowledges that the preceding statement contains an
emotional response to the situation, and readily requests that the Court interprets the legal
intention and merits of the PLAINTIFFs request for a fair and reasonable access to the Court
to hear and adjudicate the PLAINTIFFs complaint.
PLAINTIFF has filed numerous formal complaints with the Federal Bureau of Investigations
Internet Crime Complaint Center.
I05120804514805; and
I06010506177009.
Southern Regional Police Department of Conestoga, and the Lancaster County District
Attorneys Office with Chief Detective Michael J. Landis during the course of the last 2 years,
where the PLAINTIFFS computer and online broadband connections was hacked. At times
when PLAINTIFF attempted to search and find Rules of Civil Procedure (Federal and
Pennsylvania) and related subject matters, including but not limited to the effective service
for DEFENDANTS, certain provisions were missing and or replaced with erroneous and
misinformation, thus resulting in an improper Certificate of Service and violation of the Rules
of Civil Procedure relating to the Service of the complaint.
Plaintiff deliberately provided no response to all previous Motions to Dismiss filed by several
DEFENDANTS due to the vagueness of the ORDER of January 7, 2006 instructing the
PLAINTIFF to only serve all DEFENDANTS with the complaint. That ORDER stated: IT IS
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HEREBY ORDERED that the plaintiff shall serve the summons and complaint on or
before January 25, 2006. If the plaintiff does not do so, the Court will dismiss the
complaint without prejudice. The Court will consider the plaintiff's request to amend
the complaint and for a hearing after the summons and complaint are served.
The court provided not instructions or demands of the PLAINTIFF to proceed with any
additional motions, responses, and or replies after the effectively serving the original
complaint to all of the DEFENDANTS. PLAINTIFF will argue that continuing with litigating
the original complaint bears no purpose, nor serves any interests of the Court in providing
the PLAINTIFF with due process and access to the Courts due to the fact that the original
complaint was not appropriately formulated to ensure that the PLAINTIFFS allegations of
misconduct and violations of Federal Law were constructed sufficiently for the Court.
PLAINTIFF, on June 2, 2006, appropriately and formally requested that meeting with the
Court to amend the original complaint in the Motion for Ex Parte Meeting with the Honorable
Mary A. McLaughlin.
PLAINTIFF seeks no advantage, special treatment, nor special considerations from the
Court. PLAINTIFF is seeking the ex parte meeting for procedural guidance to amend the
original complaint and to address the ramifications of the sealing of the complaint with
special regards to issues of National Security and documented and factual threats on the
PLAINTIFFs life . The following is the excerpt from the PLAINTIFFs Finding of Facts:
June 11, 1991 - Stan Caterbone 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,
Stan Caterbone noticed a car following him closely. Suspicious, Stan Caterbone 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, Stan
Caterbone 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, Stan
Caterbone looked for an abrupt turn-off, in hopes of dashing the eluding vehicle, by loosing sight of
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6/12/2006
his taillights. There was little or no traffic on the route during the early morning hours, and Stan
Caterbone 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, Stan Caterbone noticed a narrow 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. Stan Caterbone 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 Stan
Caterbone, 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 Stan Caterbone, with its high beams on, and continued straight for his vehicle, or what appeared to
be a head-on-collision. Stan Caterbone 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
northbound lane, heading south. Stan Caterbone, shaking and sweating furiously, noticed the cars
brake lights go on, and the car apparently turned around, and began pursuing Stan Caterbone again.
Stan Caterbone drove as fast as he could to Route 55, hoping to find traffic in order to hide and loose
the pursuing car. Stan Caterbone 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, Stan Caterbone noticed the car
following him. In an effort to identify the license plate, Stan Caterbone 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. Stan Caterbone 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. Stan
Caterbone then used a flashlight, in order not to reveal his presence, and returned to his vehicle,
sometime in the early morning, during daylight.
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Respectfully submitted,
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Page 11
6/12/2006
STANLEY J. CATERBONE,
Plaintiff
v.
No. 05-CV-2288
JURY TRIAL
ORDER
AND NOW, this - day of ,2006, upon consideration of Plaintiffs Motion for Ex Parte Meeting
with the Honorable Mary A. McLaughlin, and Fulton Bank's response thereto, it is hereby
ORDERED AND DECREED that the Motion is AFFIRMED.
BY THE COURT:
________________________________
Mary A. McLaughlin, J.
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6/12/2006
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Reply to Response to
Motion for Ex Parte Meeting has been served this 12th day of June, 2006, by first class mail,
Postage prepaid, upon:
Michael Donahue
Harbor Police Administration Building
9508 2nd Avenue
Stone Harbor. NJ 08247
Stephen Basse, Esquire
817 East Landis Avenue
Vineland, NJ 08360
I HEREBY CERTIFY that a true and correct copy of the foregoing Reply to Response to
Motion for Ex Parte Meeting has been served in person to the offices below on this 12th day
of June ,2006,:
Howard L. Kelin, Esquire
Kegel, Kelin, Almy & Grimm
24 North Lime Street
Lancaster, PA 17602
Respectfully submitted,
Confidential
Page 13
6/12/2006
._-.
-
Defamation of C h a r a c t e r
Slander
Mental Duress
Malice
Unfair C a T p e t i t i o n
Wrongful I n t e r f e r e with BusiRelations
Wrongful I n t e r f e r e m w i t h C o n t r a c t s
Trezpass to P e r s s n
Burglary
Theft
Criminal Mischief
I n v a s i o n o f Privacy
T r e z p a s s to Personal P r o p e r t y
Undoinf l u e m
Fraud
Conspiracy
EMxzzlmnt
Breach of C o n t r a c t
Extortion
Forgery
S b r h o l d e r Freeze-cut
- -
Cornno-lth
M t l 0 ~Bank
1
Penn m a r e
Lancaster, PA
176432
W l l o n Bank
Pittsburg, PA
Parent Carpany
Mike W o l f , Executive Vice President of Comnercial Lending
f ' w PEAJBLOS
U(;ATIONS.:
Defamation o f Character
Slander
Mental Duress
Malie
Unfair Cocrpetition
Wrongful I n t e r f e r e ~ zw i t h Business Relations
Wrongful Interference w i t h Contracts
Trespass t o Person
T M t
Criminal Mischief
Invasion o f Privacy
Trespass to Personal Property
Undoinf luenoe
Fraud
Conspiracy
EntEzzlement
Breach of Contract
Extortion
Defamation of Character
Slander
Mental IXlress
Malice
Unfair Conpetition
Wrowful Interference with BusiRelatiom
Wrowful Interference w i t h Contracts
T r e s p a s to Person
Theft
C r i m i m l Mischief
Invasion of Privacy
Trespass to Personal Property
Urdoinf luence
Fraud
? Corqsiracy
I EmSezzlement
Breach of Contract
Extortion
r/Aw ,455
PLLE%~.ICNS:
Defamation of Character
Slaoder
Mental Duress
Mall03
Unfalr Corrpetr t i o n
Wrongful Interference w l t h BusiRelations
Wrongful Interference w l t h Contracts
T r e z p a s t o Pemn
,ary
.
- .
Theft
Invaslon of Prlvacy
Trespass t o Perzonal
Undolnfluence
Fraud
Cor?zplracy
Breach of Contract
t Extortion
C'
Property
Hunllton Bank
Oregon Plke
Lamaster, PA
17601
Defamation of Character
Slander
Mental Duress
Malice
Unfair Conpetit i o n
Wrongful Interference with Business Relations
Wrongful Interference with Contracts
Trt o Person
Trto Personal Prcperty
Undoinf luence
Fraud
Coqiracy
Breach of Contract
Extortion
F u l t o n Bank
O l d Hickory B r a n c h
Stor L a n c a s t e r . PA
17601
?6tl
U n f a i r Conpeti t i o n
Wrongful I n t e r f e r e n c e w i t h B u s i n e s s R e l a t i o m
Wrongful I n t e r f e r e with Contracts
Undoinfluem
Fraud
Comiracy
Erkezzlement
B r e a c h of C o n t r a c t
Extortion
Cor
Brc
Berdett T m l l n Hospital
Cape Nay County Courthouse
Stone Harbor, NJ
08247
Social Worker
Psychiatrist 1
Psychiatrist 2
WEGAT IONS:
Defamation of Character
Slarder
k n t a l Duress
Malice
Unfalr Carpetrtlon
Wrongful Interferew l t h Busines Relatiow
Wrongful Interference w i t h Contracts
Tnzspass to Person
Irwa~lon
of Prrvacy
Trespass to Percsml Property
Undolnf luence
Fraud
Cowpiracy
Breach of Contract
~orgsry
Neg11gsnce
Officer Dean
Fat Aswrciate
Defamation of Character
Slander
Mental Duress
Malice
Unfair Conpetition
Wrongful Interference with Business Relations
Wrongful Interference with Contracts
Trespass to Percan
Burglary
Theft
Criminal M i x h i e f
Itwasion o f Privacy
Trto Personal Property
Undoinf l u e n z
Fraud
Conspiracy
En'&ezzlmnt
Breach of Contract
Extortion
Forsew
Sharholder Freeze-out
mligence
k n h i m Towrship P o l i c e Deparbnent
C i r c l e Drive
Lancaster, PA
17601
D e t e c t i v e Mathias
Officer 1
Officer 2
Officer 3
Officer 4
Defamation of C h a r a c t e r
Slander
k n t a l hresr
Malice
'j
Wrongful I n t e r f e r e n c e w i t h Business R e l a t i o n s
Wrongful I n t e r f e r e with Contracts
T r e s p a s s to Person
8urglat-y
Theft
C r i m i n a l Mischief
Invasion of Privacy
T r e s p a s s to Personal P r o p e r t y
Undoinf l u e m
Conspiracy
Breach of C o n t r a c t
Negligznce
L a n e a s t e r P o l l c e Department
W. Chestrwt S t r e e t
L a n e a s t e r , PA
17602
Defamation of C h a r a c t e r
Slander
Mental DuMalioe
Wrongful I n t e r f e r e n c e w i t h B u s i n e s s R e l a t i o w
Wrongful I n t e r f e r e n c e w i t h C o n t r a c t s
Trto Person
Undoinfluence
Fraud
Conspiracy
Breach of C o n t r a c t
Negligence
Jocsh R c d a , E s q .
301 C l p k r Building
36 E. K i y Street
L a m a s t e r , PA
17602
(717) 397-5791
Defamation of Character
Slander
k n t a l Duress
Malice
Unfair Conpeti t i o n
Wrongful I n t e r f e r e w i t h Business R e l a t i o m
Wrongful I n t e r f e r e with Contracts
Undoinfluence
Fraud
Colqriracy
Embezzlenmt
Breach of Contract
Extortion
S h a r b l d e r Freeze-cut
Neglisnce
Lou S c ~ l l e r Esq.
,
V a l o r e , M c A l l i s t e r , W i x o r e l a n d , Gould, V e s p e r & Sctwartz
Northfield, NJ
(609) 64-1111
Mental Duress
Malice
U n f a i r Gorrpetltion
Wrongful I n t e r f e r e n c e w i t h B u s i n e s s R e l a t i o n s
Wrongful I n t e r f e r e n c e w i t h C o n t r a c t s
Undoinf l u e n c e
Fraud
Conspiracy
mzzlement
Breach of C o n t r a c t
Extortion
Negligence
D r . W r s h a l l L e v i r e , E ffl D P A
l a 1 T i l t o n Road
N o r t h f i e l d , NJ
(653) 646-2011
D e f a m t i o n of C h a r a c t e r
Slander
Mental LXlresr
Malice
Unfair C a r p e t i t i o n
Wrongful I n t e r f e r e n c e w i t h B u s i n e s s Relations
Wrongful Interference w i t h C o n t r a c t s
T r e a s s to Person
I n v a s i o n of P r i v a c y
Undoinf l u e e
Fraud
Comiracy
Fdxzzlmnt
Breach of C o n t r a c t
Extortion
Neglige-
https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?536747398298484...
Appellant
STANLEY CATERBONE
V.
Debtor-in-Possess
STANLEY CATERBONE
Trustee
UNITED STATES TRUSTEE
Date Filed
11/14/2005
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Docket Text
7 Letter from U.S. BANKRUPTCY COURT re: received original record on
11/10/05. (afm, ) (Entered: 11/14/2005)
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SUSPENSE
Plaintiff
STANLEY J. CATERBONE
V.
Defendant
LANCASTER COUNTY PRISON
TERMINATED: 06/13/2006
Defendant
MANHEIM TOWNSHIP POLICE
DEPT.
Defendant
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Defendant
COMMONWEALTH NATIONAL
BANK
i.e. MELLON BANK
Defendant
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FULTON BANK
Date Filed
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06/30/2006
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APPEAL, FeeDue
Debtor
Stanley J. Caterbone
220 Stone Hill Road
Conestoga, PA 17516
SSN: xxx-xx-0959
U.S. Trustee
United States Trustee
Office of the U.S. Trustee
833 Chestnut Street
Suite 500
Philadelphia, PA 19107
(215) 597-4411
Filing Date
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66
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Order Granting Motion for Relief from Stay Regarding Property 220
Stone Hill Road, Conestoga, PA Filed by Fulton Bank Represented by
SHAWN M. LONG (Related Doc # 31) (R., Sara) (Entered:
02/23/2006)
02/21/2006
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Hearing Held on 31 Motion for Relief from Stay Filed by Fulton Bank
Represented by SHAWN M. LONG (Counsel). Matter Taken Under
Advisement. (S., Barbara) (Entered: 02/21/2006)
02/10/2006
41
Monthly Operating Report for Filing for the month of January 2006
Filed by Stanley J. Caterbone . (P., Cathy) (Entered: 02/10/2006)
02/02/2006
40
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Advanced Media Group Income Statements for the year 2005 Filed by
Stanley J. Caterbone . (Attachments: # 1 Continuation of Reports) (P.,
Cathy) (Entered: 01/31/2006)
01/30/2006
35
01/24/2006
33
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Motion for Relief from Stay. Fee Amount $150, Filed by Fulton Bank
Represented by SHAWN M. LONG (Counsel). Objections due by
2/8/2006. (Attachments: # 1 Exhibits A and B- Note and Mortgage# 2
Proposed Order # 3 Certification of Service and Notice) (LONG,
SHAWN) (Entered: 01/24/2006)
01/23/2006
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STANDARD
IN RE: CATERBONE
Assigned to: HONORABLE ANITA B. BRODY
Related Case: 2:05-cv-03689-AB
Case in other court: U.S. Bankruptcy Court E.D. of
Pennsylvania, 05-23059
Cause: 28:0158 Notice of Appeal re Bankruptcy Matter (BA
Appellant
STANLEY J. CATERBONE
V.
Appellee
FULTON BANK
V.
Debtor-in-Possess
STANLEY J. CATERBONE
Trustee
UNITED STATES TRUSTEE
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PHILADELPHIA, PA 19107
PRO SE
Date Filed
Docket Text
06/12/2006
05/30/2006
05/15/2006
05/03/2006
04/26/2006
04/25/2006
04/11/2006
04/11/2006
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http://en.wikipedia.org/wiki/RICO_(law)
The Racketeer Influenced and Corrupt Organizations Act (commonly referred to as 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.
It has been speculated that the name and acronym were selected in a sly reference to the movie Little Caesar, which
featured a notorious gangster named "Rico." The original drafter of the bill, G. Robert Blakey, has refused to
confirm or deny this.[1]
Contents
1 Summary
2 RICO offenses and definitions
3 Where RICO laws might be applied
4 Famous cases
5 References
6 External links
Summary
Under RICO, a person or group who commits any two of 35 crimes27 federal crimes and 8 state crimeswithin
a 10-year period and, in the opinion of the US Attorney bringing the case, has committed those crimes with similar
purpose or results can be charged with racketeering. Those found guilty of racketeering can be fined up to $25,000
and/or sentenced to 20 years in prison. In addition, the racketeer must forfeit all ill-gotten gains and interest in any
business gained through a pattern of "racketeering activity." The act also contains a civil component that allows
plaintiffs to sue for triple damages.
When the U.S. Attorney decides to indict someone under RICO, he has the option of seeking a pre-trial restraining
order or injunction to prevent the transfer of potentially forfeitable property, as well as require the defendant to put
up a performance bond. This provision is intended to force a defendant to plead guilty before indictment.
There is also a provision for private parties to sue. A "person damaged in his business or property" can sue one or
more "racketeers." There must also be an "enterprise." The defendant(s) are not the enterprise, in other words, the
defendant(s) and the enterprise are not one and the same. There must be one of four specified relationships between
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http://en.wikipedia.org/wiki/RICO_(law)
the defendant(s) and the enterprise. This lawsuit, like all Federal civil lawsuits, can take place in either Federal or
State court. http://www.dealer-magazine.com/index.asp?article=481
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http://en.wikipedia.org/wiki/RICO_(law)
Famous cases
On November 21, 1980, Frank "Funzi" Tieri was the first Cosa Nostra boss to be convicted under the RICO Act.
In 1988, the owner of Florida Title Insurance, Inc. in Panama City, Florida sent copies of proposed qui.tam suit
against 32 defendants with 12 Counts of Racketeering to the Justice Department as required, just to get them
returned in a plain manila envelope with no cover letter regarding the RICO Act violations involving a competitor
company, the IRS, with the IRS Agent threatening the life of Plaintiff on behalf of defendants and others. IRS
Agent was found dead just days after being served by U.S. Marshals. Autopsy was conducted by Coroner later
convicted of Murder. Case went before numerous Federal Judges in Northern District of Florida, who denied all
motions including one for discovery conference, seizure of assets due to the defendant's failure to appear, 11th
Circuit on Appeal with 15 minute argument (first hearing) with most spent trying to get the Government to have an
independent autopsy of the IRS Agent and was denied access to Supreme Court due to minute error in spacing and
Clerical Abuse of Discretion in pro.ce case.
In 2002, the former minority owners of the Montral Expos baseball team filed charges under the RICO Act
against Major League Baseball commissioner Bud Selig and former Expos owner Jeffrey Loria, claiming that Selig
and Loria deliberately conspired to devalue the team for personal benefit in preparation for a move. If found guilty,
Major League Baseball could have been found liable for up to $300 million in punitive damages. The case lasted
for two years, successfully stalling the Expos' move to Washington or contraction during that time. It was
eventually sent to arbitration and settled for an undisclosed sum, permitting the move to Washington to take place.
This happened notably after Loria, now owner of the Florida Marlins, had received a significant financial boost
after winning the World Series and Selig refused to permit the Expos to engage in September callups, effectively
ending their chances at making the playoffs.
RICO laws were cited in NOW v. Scheidler, a suit in which certain parties sought damages and an injunction
against anti-abortion activists who physically block access to abortion clinics.
In 2005, Tanya Andersen of Oregon responded to a lawsuit on behalf of Atlantic Records by in turn suing them
under the RICO laws. Her suit alleges that RIAA members, in this particular case Atlantic, engaged in illegal
computer trespass, extortion, and unfair trade practices under Oregon state law.
On April 26, 2006 the Supreme Court heard Mohawk Industries, Inc. v. Williams, which concerned what sort of
corporations fell under the scope of RICO. Mohawk Industries had alledgely hired illegal alliens, in violation of
RICO. The court will decide whether or not Mohawk Industries, along with recruiting agencies, constitutes an
'enterprise' that can be prosecuted under RICO.
References
1. ^ RICO Suave (http://www.snopes.com/language/acronyms/rico.asp) . Snopes.com: (21 December 2004).
Retrieved on 2006-03-26.
External links
RICO Act from Cornell University's U. S. Code database
(http://www.law.cornell.edu/uscode/html/uscode18/usc_sup_01_18_10_I_20_96.html)
Detail of Tanya Andersen's claim against Atlantic Records
(http://recordingindustryvspeople.blogspot.com/2005/10/oregon-riaa-victim-fights-back-sues.html)
Retrieved from "http://en.wikipedia.org/wiki/Racketeer_Influenced_and_Corrupt_Organizations_Act"
Categories: Articles with weasel words | United States federal legislation | Organized crime terminology | 1970 in
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law
4 of 4
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STANLEY J. CATERBONE
v.
LANCASTER COUNTY PRISON, $''&EL
NO. 05-2288
ORDER
-- -
plaintiff on May 16, 2005, and whereas the plaintiff has not served
the summons and complaint within 120 days after filing
- the
. ,... .
. ..
' . .
- ,
complaint, as required by ~ i l e4(m) of the ~ e h e r k~ U l kof Civil
If the
plaintiff does not do so, the Court will dismiss the complaint
without prejudice. The Court will consider the plaintiff's request
to amend the complaint and for a hearing after the summons and
complaint are served.
IT IS FURTHER ORDERED that the plaintiff's motion to
A document
+@i'
v. Borough
se
pleadings, the plaintiff has not brought suit under a statute that
requires t h e - s U g _ o f the-record, or +own
so. The plaintiff alleges that several threats have been made on
his life, but does not provide any facts to support this
allegation, or explain how these alleged threats relate to his
complaint.
BY THE COURT:
STANLEY J. CATERBONE
CIVIL ACTION
NO. 05-2288
v.
MOTION
I hereby request a meeting, ex parte, with the Honorable Mary A. McLaughlin as per the
ORDER of January 6th, 2006. The PLAINTIFF requests the meeting to discuss the
problems of preceding this action without obstruction of justice; and to amend the original
complaint as discussed previously.
DATED:
__________________________
Advanced Media Group
Stanley J. Caterbone, Pro Se
220 Stone Hill Road
Conestoga, PA 17516
717-431-8184
717-421-1621 Facsimile
EXHIBIT A
EXHIBIT B
Respectfully,
Stanley J. Caterbone
Attachment:
Cc:
file
Mr. Hugh Ward, Department of Justice, Office of Trustee
Honorable Judge Thomas M. Twardowski, United States Bankruptcy
Court, Eastern District of Pennsylvania
STANLEY J. CATERBONE
v.
LANCASTER COUNTY PRISON, $''&EL
NO. 05-2288
ORDER
-- -
plaintiff on May 16, 2005, and whereas the plaintiff has not served
the summons and complaint within 120 days after filing
- the
. ,... .
. ..
' . .
- ,
complaint, as required by ~ i l e4(m) of the ~ e h e r k~ U l kof Civil
If the
plaintiff does not do so, the Court will dismiss the complaint
without prejudice. The Court will consider the plaintiff's request
to amend the complaint and for a hearing after the summons and
complaint are served.
IT IS FURTHER ORDERED that the plaintiff's motion to
A document
+@i'
v. Borough
se
pleadings, the plaintiff has not brought suit under a statute that
requires t h e - s U g _ o f the-record, or +own
so. The plaintiff alleges that several threats have been made on
his life, but does not provide any facts to support this
allegation, or explain how these alleged threats relate to his
complaint.
BY THE COURT:
International Fraud
Date of Complaint: 1/5/2006 6:17:08 AM
Victim Information
Business Name:
Advanced Media Group
Name:
Stan Caterbone Caterbone
DOB:
07/15/1958
Gender:
M
Phone #:
717-799-5915
Email:
amgroup01@msn.com
Address:
220 Stone Hill Road
Conestoga, PA 17516
Live in city limits: No
County:
Lancaster
Country:
USA
Do you have pertinent documents in paper form? Yes
Please indicate who your local law enforcement agency is:
Southern Regional Police Department
Please List the easiest way and most convenient time to contact you:
cell phone, email, anytime
Information about the Business that victimized you.
Name:
Gender: U
Phone #:
Current Email:
Address:
Country: USA
Contact between you and the Person/company that victimized you.
Type of Contact: Web Page
Date of Contact: 01/30/2005
tampered with, and my final trip home was extended an additional 3 hours,
this was after the delay of another 4 hours by the Southwest flight from
Orlando to Philadelphia.
I had been randomly selected for private searches by the Homeland
Security agents upon every stop, and in Houston, Texas, was accused by an
inspection device (false positive reading) as carrying a plastic explosive
in my carry-on luggage, and was treated as such.
In addition, a portable storage device was also corrupted during this
process, via the Internet.
Spending New Years Eve in the PVR airport, cold with only rigid, hard,
and very uncomfortable seating, with no one that understood English, all
the while experiencing extreme back pain (currently under a physicians
care and treatment) ---- priceless.
Description of how you were defrauded:
On January 30 I had planned to visit Los Cabos, Mexico, for a business
trip. I had used the Internet to locate the airport (PTO) for that
destination to locate and book the necessary travel accommodations.
PVR (Puerto Vallarta, Mexico) appeared on several Google searches as
that airport. I accordingly booked flight itinerary and tickets for
that trip. On January 31 I booked a flight from Houston Hobby airport
to PVR (Continental Flight 1768, Seat 10D). I had some knowledge of
the PTO system, having the national register for PTOs when I had my
plane operating, the Piper Navajo Chieftain, in 1987. I had logged
several flights, as far away as Atlanta, and booked it for charter to
several clients.
PVR was not, in fact, the airport for that destination. I had
consumed an estimated $2,000 in expenses for that trip, and never was
able to travel to Los Cabos as planned. I was denied a car rental
after landing in PVR without any lodging accommodations. I had to
spend 3 evenings in the PVR airport because of no lodging
accommodations. The only accommodation I could find was at a price of
$389.00 (Marriot Hotel) per night, well beyond my budget.
I was not allowed fair access to certain return flights to Houston
Hobby airport, and was in a constant state of intimidation by the
agents at PVR that were under the employ of Continental Airlines.
Continental Airlines made no attempt to remedy any of these problems,
or make any attempt to accommodate my concerns or complaints.
Southwest Airlines conveniently lost my only piece of carryon luggage
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HUGH J. WARD
U.S. DEPT OF JUSTICE
833 CHESTNUT ST
STE 500
PHILADELPHIA, PA 19107-4414
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JUDGE T. M. TWARDOWS
U.S. BANKRUPTCY COUR
400 WASHINGTON ST
READING, PA 19601-3915
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SUSPENSE
Plaintiff
STANLEY J. CATERBONE
V.
Defendant
LANCASTER COUNTY PRISON
TERMINATED: 06/13/2006
Defendant
MANHEIM TOWNSHIP POLICE
DEPT.
Defendant
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Defendant
COMMONWEALTH NATIONAL
BANK
i.e. MELLON BANK
Defendant
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FULTON BANK
Date Filed
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06/30/2006
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06/19/2006)
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30
STANLEY J. CATERBONE
CIVIL ACTION
v.
NO. 0 5 - 2 2 8 8
as MOOT.
BY THE COURT:
J?
\LED
T h , c A ~ ? . 5 ~ ! ~9Je.,
. ~',2iI<
CIVIL ACTION
NO. 05-2288
I>ii '
cy/-
I.
the ground that the plaintiff has failed to state a timely claim.'
The United States Court of Appeals for the Third Circuit peh&K
ER
dismiss under Rule 12(b) (6) if the time-bar is apparent on the face
of the complaint. Robinson v. Johnson, 313 F.3d 128, 135 (3d Cir.
2002).
The plaintiff
(7)
&
No. 252 Annuity Fund v. Newbridqe SeC., 93 F.3d 1171, 1186 (3d Cir.
1996) (a breach of fiduciary duty is tortious conduct, subject to a
two year statute of limitations); 42 Pa.C.S.
5525(a) (imposing
him, and unnamed officers used excessive force against him; and (4)
in January 1991, a Lt. Madenspacher called the plaintiff regarding
his letter to the Department of Defense about alleged blackmail
occurring in 1987, but failed to attend a scheduled meeting.
(Compl. at 5-6, 33, 39-40, 59.)
Again construing the allegations in the complaint in the
light most favorable to the plaintiff, he has arguably asserted:
(1) assault, battery, false imprisonment, false arrest, malicious
42 Pa. C.S.
5524(1).
Plaintiffs must also bring any 5 1983 civil rights claims within
two years.
(2)
embezzled
$5,000 from his checking account in 1990, did not credit the
account for more than 60 days, and never credited the lost interest
income; and ( 3 ) refused to allow the plaintiff's brother, Thomas
Caterbone, to deposit a check in 1996, on the grounds that no funds
were available, and was therefore responsible for his
suicide/wrongful death later that year.
Fulton Bank for: (1) breach of fiduciary duty, fraud, and/or unjust
enrichment, for its actions toward the plaintiff in 1990; and (2)
fraud or wrongful death, for its actions toward the plaintiff's
brother in 1996. These claims are time barred as well. As
explained above, there is a two-year statute of limitations on
actions for breach of fiduciary duty or fraud. 42 Pa. C.S. $3
5524(3) and (7). There is a four-year statute of limitations on
5525(4).
(Compl. at 81.)
11.
serve the complaint and summons, and has therefore failed to compl)
with the Court's January
5,
2006 Order.
Grand Entertainment
Grouw, Ltd. v. Star Media Sales, Inc., 988 F.2d 476, 488 (3d Cir.
1993).
The plaintiff has not submitted any evidence that he
attempted to serve the Southern Regional Police Department.
For each of the other defendants, the plaintiff filed a
The plaintiff's
Each of these
&
Grimm, LLP in
The
days.
Mr. Basse are the appropriate persons to receive service for these
public bodies.
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BY THE COURT:
CIVIL ACTION
v.
LANCASTER COUNTY PRISON.
NO. 05-2288
ORDER
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.
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Fed. R. Civ. P.
15(a); Shane v. Fauver, 213 F.3d 113, 115 (3d Cir. 2000). NO
responsive pleading has yet been filed in this case.
BY TEE COURT:
JUN 1 9 2006
CLERK OF C O U H ~