Beruflich Dokumente
Kultur Dokumente
Caterbone
ADVANCED MEDIA GROUP
Freedom From Covert Harassment &
Surveillance,
Registered in Pennsylvania
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
stancaterbone@gmail.com
717-327-1566
Aware or not, I visited your PRISON on Friday, June 23, 2017 at approximately 9:00
am and spoke to your Desk Sargent regarding my visitation of Lisa Michelle Lambert.
As per our agreement, I provided your letter of February 17, 2017 GRANTING ME
VISITATION PRIVILEGES AND A COPY OF THE APPLICATION FOR CLEMENCY FROM THE
PENNSYLVANIA BOARD OF PRISONS, which I had purchased on March 31, 2017 in
person at the OFFICE OF THE BOARD OF PRISONS IN HARRISBURG, PA.
I was forced by the LANCASTER CITY POLICE DEPARTMENT to leave the vicinity of
the City of Lancaster for UNKOWN REASONS, AGAIN, and made the decision in the early
morning of Thursday, June 22, 2017 that it was the BEST OPPORTUNITY to finally take
advantage of the privileges that you have previously granted. Unfortunately, Best Buy
had refused to provide me a PREPAID DATA PLAN on at least 3 occasions, both in
Lancaster and Harrisburg, so I was without GPS and I arrived in Framingham at
approximately 7:00pm on Thursday evening, which would have allowed me an hour of
visitation, however, I could not find the facility or a convenient WIFI connection. So I
stayed at the Motel 6 in Framingham and proceeded to your facility the next morning.
In a text message to Dave Brown, the Co-Author of Lisa's Book LOVE, MURDER, AND
CORRUPTION IN LANCASTER COUNTY, I stated Tell Lisa I am Sorry but I had to turn
around and head back to Lancaster, a HOSTILE COINTELPRO OPERATION WAS
INSTALLED IN FRAMINGHAM, tell Lisa I have her package ready for USPS. I am
paraphrasing.
LETTER TO SUPERINTENDENT HALLETT Page No. 1 of 228 Saturday June 24, 2017
I KNOW WHAT FLAGGING OPERATIONS ENTAIL. UNIFORMED POLICE WERE NEVER
INCLUDED IN OUR CONTRACTS WHO IN THE FUCK CAN AFFORD UNIFORMED POLICE
as FLAGGERS FOR CONTRUCTION PROJECTS?
ADDING INSULT TO INJURY, I HAD STOPPED AND ASKED ONE OF THESE ASSHOLES
FOR DIRECTIONS AND HE SENT ME IN THE OPPOSITE DIRECTION, NOW KNOWING I
HAD PREVIOUSLY UPDATED MY PHONE WITH THE ATTACHED PDF FILE. WHAT A
FUCKING IDIOT HE IS.
Respectfully,
_______________________
Stan J. Caterbone, Pro Se Litigant
ADVANCED MEDIA GROUP
Freedom From Covert Harassment & Surveillance,
Registered in Pennsylvania
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
stancaterbone@gmail.com
717-327-1566
Notice and Disclaimer: Stan J. Caterbone and the Advanced Media Group have been slandered, defamed, and
publicly discredited since 1987 due to going public (Whistle Blower) with allegations of misconduct and fraud
within International Signal & Control, Plc. of Lancaster, Pa. (ISC pleaded guilty to selling arms to Iraq via
South Africa and a $1 Billion Fraud in 1992). Unfortunately we are forced to defend our reputation and the
truth without the aid of law enforcement and the media, which would normally prosecute and expose public
corruption. We utilize our communications to thwart further libelous and malicious attacks on our person, our
property, and our business. We continue our fight for justice through the Courts, and some communications
are a means of protecting our rights to continue our pursuit of justice. Advanced Media Group is also a
member of the media. Reply if you wish to be removed from our Contact List. How long can Lancaster County
and Lancaster City hide me and Continue to Cover-Up my Whistle Blowing of the ISC Scandel (And the Torture
from U.S. Sponsored Mind Control)?
LETTER TO SUPERINTENDENT HALLETT Page No. 2 of 228 Saturday June 24, 2017
ACTIVE COURT CASESACTIVE COURT CASES
J.C. No. 03-16-90005 Office of the Circuit Executive, United States Third Circuit Court of Appeals -
COMPLAINT OF JUDICIALMISCONDUCT OR DISABILITY re 15-3400 and 16-1149; 03-16-900046 re
ALL FEDERAL LITIGATION TO DATE
U.S. Supreme Court Case No. 16-6822 PETITION FOR WRIT OF CERTIORARI re Case No. 16-1149
MOVANT for Lisa Michelle Lambert
U.S.C.A. Third Circuit Court of Appeals Case No. 16-3284; Case No. 16-1149 MOVANT for Lisa Michelle
Lambert;15-3400 MOVANT for Lisa Michelle Lambert;; 16-1001; 07-4474
U.S. District Court Eastern District of PA Case No. 17-01233 Chapter 11 Appeal for 17-10615; Case No.
17-0867 Preliminary Injunction from Middle District; Case No. 16-4014 CATERBONE v. United States,
et.al.; Case No. 16-cv-49; 15-03984; 14-02559 MOVANT for Lisa Michelle Lambert; 05-2288; 06-4650,
08-02982;
U.S. District Court Middle District of PA Case No. 16- 2513 INJUNCTION; Case No. 16-cv-1751
PETITION FOR HABEUS CORPUS
Commonwealth of Pennsylvania Judicial Conduct Board Case No. 2016-462 Complaint against
Lancaster County Court of Common Pleas Judge Leonard Brown III
Pennsylvania Supreme Court Case No. 353 MT 2016; 354 MT 2016; 108 MM 2016 Amicus for Kathleen
Kane
Superior Court of Pennsylvania 3575 EDA 2016 Amicus for Kathleen Kane; Summary Appeal Case No.
CP-36-SA-0000219-2016, AMICUS for Kathleen Kane Case No. 1164 EDA 2016; Case No. 1561 MDA
2015; 1519 MDA 2015; 16-1219 Preliminary Injunction Case of 2016
Lancaster County Court of Common Pleas Case No. 16-05815 Injunction; Case No. 16-08472
INJUNCTION re Pain Meds; Case No. 15-10167 Film Commission; Case No. 08-13373; 15-10167; 06-
03349, CI-06-03401
U.S. Bankruptcy Court for The Eastern District of Pennsylvania Case No. 17-10615; Case No. 16-10157
LETTER TO SUPERINTENDENT HALLETT Page No. 3 of 228 Saturday June 24, 2017
Stan J. Caterbone
ADVANCED MEDIA GROUP
Freedom From Covert Harassment &
Surveillance,
Registered in Pennsylvania
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
stancaterbone@gmail.com
717-528-2200
MARCH 21, 2017
Notice and Disclaimer: Stan J. Caterbone and the Advanced Media Group have been slandered, defamed, and
publicly discredited since 1987 due to going public (Whistle Blower) with allegations of misconduct and fraud
within International Signal & Control, Plc. of Lancaster, Pa. (ISC pleaded guilty to selling arms to Iraq via
South Africa and a $1 Billion Fraud in 1992). Unfortunately we are forced to defend our reputation and the
truth without the aid of law enforcement and the media, which would normally prosecute and expose public
corruption. We utilize our communications to thwart further libelous and malicious attacks on our person, our
property, and our business. We continue our fight for justice through the Courts, and some communications
are a means of protecting our rights to continue our pursuit of justice. Advanced Media Group is also a
member of the media. Reply if you wish to be removed from our Contact List. How long can Lancaster County
and Lancaster City hide me and Continue to Cover-Up my Whistle Blowing of the ISC Scandel (And the Torture
from U.S. Sponsored Mind Control)?
LETTER TO SUPERINTENDENT HALLETT Page No. 4 of 228 Saturday June 24, 2017
ACTIVE COURT CASES
J.C. No. 03-16-90005 Office of the Circuit Executive, United States Third Circuit Court of Appeals -
COMPLAINT OF JUDICIALMISCONDUCT OR DISABILITY re 15-3400 and 16-1149; 03-16-900046 re
ALL FEDERAL LITIGATION TO DATE
U.S. Supreme Court Case No. 16-6822 PETITION FOR WRIT OF CERTIORARI re Case No. 16-1149
MOVANT for Lisa Michelle Lambert
U.S.C.A. Third Circuit Court of Appeals Case No. 16-3284; Case No. 16-1149 MOVANT for Lisa Michelle
Lambert;15-3400 MOVANT for Lisa Michelle Lambert;; 16-1001; 07-4474
U.S. District Court Eastern District of PA Case No. 17-867 CATERBONE v. NSA, et.al., Preliminary
Injunction for EMERGENCY RELIEF; Case No. 16-4014 CATERBONE v. United States, et.al.; Case No.
16-cv-49; 15-03984; 14-02559 MOVANT for Lisa Michelle Lambert; 05-2288; 06-4650, 08-02982;
U.S. District Court Eastern District of PA FEDERAL PRIVATE CRIMINAL COMPLAINT, March 8, 2017.
Chapter 11 Bankruptcy Appeal from 17-10615
U.S. District Court Middle District of PA Case No. 16- 2513 INJUNCTION; Case No. 16-cv-1751
PETITION FOR HABEUS CORPUS
Commonwealth of Pennsylvania Judicial Conduct Board Case No. 2016-462 Complaint against
Lancaster County Court of Common Pleas Judge Leonard Brown III
Pennsylvania Supreme Court Case No. 353 MT 2016; 354 MT 2016; 108 MM 2016 Amicus for Kathleen
Kane
Superior Court of Pennsylvania 3575 EDA 2016 Amicus for Kathleen Kane; Summary Appeal Case No.
CP-36-SA-0000219-2016, AMICUS for Kathleen Kane Case No. 1164 EDA 2016; Case No. 1561 MDA
2015; 1519 MDA 2015; 16-1219 Preliminary Injunction Case of 2016
Lancaster County Court of Common Pleas Case No. 16-05815 Injunction; Case No. 16-08472
INJUNCTION re Pain Meds; Case No. 15-10167 Film Commission; Case No. 08-13373; 15-10167; 06-
03349, CI-06-03401
U.S. Bankruptcy Court for The Eastern District of Pennsylvania Case No. 17-10615; Case No. 16-10157
LETTER TO SUPERINTENDENT HALLETT Page No. 5 of 228 Saturday June 24, 2017
STAN J. CATERBONE & ADVANCED MEDIA GROUP
SOCIAL MEDIA SITES
_________________________
LETTER TO SUPERINTENDENT HALLETT Page No. 6 of 228 Saturday June 24, 2017
23 NEW LINKS OF EVIDENCE FOR ALL CLAIMS
4. History of the Internet - DARPA and Stan J. Caterbone and Advanced Media Group
March 12, 2017 https://www.scribd.com/document/341681178/History-of-the-Internet-
DARPA-and-Stan-J-Caterbone-and-Advanced-Media-Group-March-12-2017
LETTER TO SUPERINTENDENT HALLETT Page No. 7 of 228 Saturday June 24, 2017
https://www.scribd.com/document/340996107/Stan-J-Caterbone-LETTER-to-Matthew-H-
Haverstick-re-MARTIN-v-Reese-CI-17-04626-March-5-2017
11. STAN J. CATERBONE NEW CASE IN U.S. FEDERAL DISTRICT COURT IN EASTERN
DISTRICT CASE No. 17-867 CATERBONE v. NSA, et.al., PRELIMINARY INJUCTION
FOR EMERGENCY RELIEF https://www.scribd.com/document/340923402/STAN-J-
CATERBONE-NEW-CASE-Case-No-17-cv-00867-EGS-Preliminary-Injunction-for-
EMERGENCY-RELIEF-in-U-S-EASTERN-District-of-Pennsylvania-March-4-20
19. STAN J. CATERBONE LANCASTER COUNTY COURT OF COMMON PLEAS CASE No.
CI-08-13373 PREACIPE TO ADD DEFENDANTS MASON PFLUMM et.al., February
25, 2017 https://www.scribd.com/document/340354387/Lancaster-County-Court-Case-
No-08-CI-13373-re-PRAECIPE-TO-ADD-DEFENDANTS-February-25-2017
LETTER TO SUPERINTENDENT HALLETT Page No. 8 of 228 Saturday June 24, 2017
20. PENNSYLVANIA DEPARTMENT OF INSURANCE COMPLAINT No. 055746172-0101
re GEICO COMPLAINT FOR ACCIDENT OF FEBRUARY 28, 2017 WITH NOTARIZED
AFFIDAVIT https://www.scribd.com/document/340278864/PENNSYLVANIA-
DEPARTMENT-OF-INSURANCE-COMPLAINT-re-STAN-J-CATERBONE-GEICO-
CLAIM-NUMBER-055746172-0101-030-with-NOTARIZED-AFFIDAVIT-February-25-20
LETTER TO SUPERINTENDENT HALLETT Page No. 9 of 228 Saturday June 24, 2017
84 INTERNET LINKS OF EVIDENCE OF ALL CLAIMS
1. ERIC COHEN AND ROBERT BERUBE, Federal Public Defender for Esteban Santiago, Ft.
Lauderdale Shooter, INVOICE AND FEE SCHEDULE January 20, 2017
https://www.scribd.com/document/337072519/ERIC-COHEN-Federal-Public-
Defender-for-Esteban-Santiago-Ft-Lauderdale-Shooter-INVOICE-AND-FEE-
SCHEDULE-January-20-2017
5. Video: Media Blacks Out Edward Snowdens Talk On COINTELPRO & History Of Mass
Surveillance
http://www.mintpressnews.com/video-media-blacks-out-edward-snowdens-talk-
on-cointelpro-history-of-mass-surveillance/224222/
6. Letters: Snowden deserves pardon by John and Bonnie Raines, Philadelphia of the
Citizens Commission to Investigate the FBI in 1971
http://www.philly.com/philly/opinion/20170119_Letters__Snowden_deserves_pa
rdon.html
LETTER TO SUPERINTENDENT HALLETT Page No. 10 of 228 Saturday June 24, 2017
8. Congressman Robert Walker Pleading July 7 1991 Important
https://www.scribd.com/document/270267368/Congressman-Robert-Walker-
Pleading-July-7-1991-Important
9. That time the CIA was convinced a self-proclaimed psychic had paranormal abilities
https://www.washingtonpost.com/news/post-nation/wp/2017/01/19/that-time-
the-cia-was-convinced-a-self-proclaimed-psychic-had-paranormal-abilities/?
postshare=8421484844095309&tid=ss_tw&utm_term=.b487b6ae00e7
10. Obama's most enduring legacy may be the establishment of the modern US
surveillance state
http://www.businessinsider.com/obamas-most-enduring-legacy-the-modern-us-
surveillance-state-2017-1
11. The Extortion of 220 Stone Hill Road, Conestoga, Pa by COINTELPRO PROGRAMS
January 17, 2017
https://www.scribd.com/document/336832214/The-Extortion-of-220-Stone-Hill-
Road-Conestoga-Pa-by-COINTELPRO-PROGRAMS-January-17-2017
12. AMG LEGAL SYSTEMS PROTOTYPE Mastered on April 16, 1991 at Commadore Inc.,
January 17, 2017
https://www.scribd.com/document/336787897/AMG-LEGAL-SYSTEMS-
PROTOTYPE-Mastered-on-April-16-1991-at-Commadore-Inc-January-17-2017
13. Stan J. Caterbone, Controller of Pflumm Contractors, Inc., 1993 to 1998 January 17,
2017
https://www.scribd.com/document/336787739/Stan-J-Caterbone-Controller-of-
Pflumm-Contractors-Inc-1993-to-1998-January-17-2017
14. Sam Lombardo and Raolph Mazzochi Charlotte Street Proposal by Advanced Media
Group and Stan J. Caterbone January 17, 2017
https://www.scribd.com/document/336787416/Sam-Lombardo-and-Raolph-Mazzochi-
Charlotte-Street-Proposal-by-Advanced-Media-Group-and-Stan-J-Caterbone-January-
17-2017
16. 1999 Excelsior Place Business Plan by Stan J. Caterbone January 16, 2017
https://www.scribd.com/document/336719627/1999-Excelsior-Place-Business-Plan-
by-Stan-J-Caterbone-January-16-2017
17. Stan J. Caterbone AIM MUTUAL FUNDS Consulting From 1999 to 2002 January 16,
2017
https://www.scribd.com/document/336738750/Stan-J-Caterbone-AIM-MUTUAL-
FUNDS-Consulting-From-1999-to-2002-January-16-2017
18. Pro Financial Group Brochure and Eastern Regional Free Agent Camp by Stan J.
Caterbone January 16, 2017
https://www.scribd.com/document/336704842/Pro-Financial-Group-Brochure-and-
Eastern-Regional-Free-Agent-Camp-by-Stan-J-Caterbone-January-16-2017
LETTER TO SUPERINTENDENT HALLETT Page No. 11 of 228 Saturday June 24, 2017
19. STAN J. CATERBONE ADVANCED MEDIA GROUP JOINT VENTURE WITH DALE HIGH
January 15, 2017
https://www.scribd.com/document/336637179/56-STAN-J-CATERBONE-ADVANCED-
MEDIA-GROUP-JOINT-VENTURE-WITH-DALE-HIGH-January-15-2017
21. 1987 JOINT VENTURE - Tony Bongiovi, Power Station Studios, and Flatbush Films
with Stan J. Caterbone January 15, 2017
https://www.scribd.com/document/336637176/55-1987-JOINT-VENTURE-Tony-
Bongiovi-Power-Station-Studios-and-Flatbush-Films-with-Stan-J-Caterbone-January-
15-2017
22. STAN J. CATERBONE'S Financial Management Group, Ltd., Anti-Trust Litigation File
of October 17, 2015
https://www.scribd.com/document/336637173/57-STAN-J-CATERBONE-S-Financial-
Management-Group-Ltd-Anti-Trust-Litigation-File-of-October-17-2015
24. Letter REQUEST for COMMUTATION of the Sentence of Lisa Michell Lambert to
President Obama, November 15, 2016
25. Stan J. Caterbone and Conflicts With the Trump Administration - Monday November
14, 2016 | False Claims Act | Military
26. STAN J. CATERBONE and the DEPARTMENT of DEFENSE Documents and Evidence of
Conspiracy to .... Saturday November 12, 2016
27. Feds Probe Fulton Bank and 3 Other Subsidiary Banks of Fulton Financial With Stan
J. Caterbone Civil Actions and Mind Control Research of Monday November 9, 2016 |
29. Letter to James Comey, Director of FBI Re Cointelpro Used to Obstruct Justice
Monday November 28, 2016 | Federal Bureau Of Investigation | Central Intelligence
Agency
30. VITALLY IMPORTANT - LETTER and DOCUMENT to Cappello & Noel, LLP of Santa
Barbara, CA Friday November 25, 2016
32. Pro Se Legal Representation In The United States | Motion In United States Law
33. Lancaster Mayor Rick Gray Says There is Room for Improvement in Police
LETTER TO SUPERINTENDENT HALLETT Page No. 12 of 228 Saturday June 24, 2017
34. Communication - CATERBONE v. Lancaster City Police Bureau, et.al., November 22,
2016 | Central Intelligence Agency
35. Chapter 12 - ROHYPNOL AND SATELLITE and Chapter 11 - NEIGHBORS FROM HELL,
from Satellite Terrorism in America, by Dr. John Hall Copyright 2009
37. JIM GUERIN, FOUNDER OF ISC, FAREWELL LETTER OF 1989 December 26, 2016 |
Justice | Government
38. CHRISTOPHER PATTERSON Candidate for JUDGESHIP and His 1987 EFFORT FOR MY
GUARDIANSHIP Friday December 16, 2016
39. ANOTHER LANCASTER COVER-UP THE SALE OF THE MASONIC HALL IN THE CITY OF
LANCASTER, by The Advanced Media Group, December 15, 2016 | Fraternal Service
Organizations
41. My Friend and Colleague Soleilmavis Liu of China a Victim of Mind Control Living in
China Who Started Peacepink- August 28, 2016
42. TD Ameritrade TRADEKEEPER PROFIT-LOSS FOR 2004 TRADES and 2017 FULTON
STOCK January 9, 2017
43. POLICE INCIDENT REPORTS OF PHYSICAL ASSAULTS FOR STAN J. CATERBONE 2005
TO 2016 January 6, 2017
44. Judiciaries
48. Torture
49. Stan J. Caterbone on Twitter: "I'm reading FALSE IMPRISONMENT AND ILLEGAL
INTERROGATIONS by U.S. Intelligence... on @Scribd! https://t.co/T3D9nIYvMt
#ReadMore"
50. Lancaster County Court Case No. 08-CI-13373 re PRAECIPE TO ADD DEFENDANTS
COMEY AND TRUMP REMOVE OBAMA January 23, 2017
51. INVOICE AND Letter to James Comey, Director of FBI Re Pro Se Billings Invoice
Wednesday November 30, 2016
LETTER TO SUPERINTENDENT HALLETT Page No. 13 of 228 Saturday June 24, 2017
52. Kathy Harrison (KATHLEEN HARRISON NAMED IN SAVAGE SUIT v. Dave Brown)
Email Re Bi Polar March 10, 2005
54. LANCASTER COUNTY COURT OF COMMON PLEAS Cases No. CI-17-00210 and CI-17-
00206 BOWMAN and SAVAGE v. BROWN, et.al.,
55. REQUEST FOR APPEARANCE and AMICUS BRIEF January 25, 2017.pdf | Amicus
Curiae | National Security Agency
56. Family of Karlie Hall files suit against Millersville University, others; calls death
preventable January 25, 2017 | Law Reference | Government
57. Stan J. Caterbone Chapter 11 Bankruptcy Case Filled in Forms January 27, 2017
58. U.S. BANKRUPTCY COURT ISSUANCE LETTER FOR NEW CASE NO. 17-10615-ref To
Judge Fehling Friday January 27, 2017
59. Stan J. Caterbone Chapter 11 Bankruptcy Case No. 17-10615 Judge Fehling Filed On
January 27, 2017 - CASE FILE | Plea | Defamation
60. Lancaster County Court Case No. 08-CI-13373 EXHIBIT re THE DONALD TRUMP
PRESIDENCY and STAN J. CATERBONE as of January 28, 2017 - electronically filed |
Federal Bureau Of Investigation | Nasa
61. ACCIDENT REPORT NO. 1701-029468 LANCASTER CITY POLICE OFFICER REPPERT
SATURDAY JANUARY 28, 2017
62. Lancaster County Court Case No. 08-CI-13373 PRAECIPE TO AMEND COMPLAINT
January 29, 2017 - FILED ELECTRONICALLY January 29, 2017
64. 16-cv-2513 Preliminary Injunction for Emergency Relief in Middle District NOTICE
OF APPEAL TO USCA THIRD CIRCUIT January 26, 2017 | Defamation
66. Stanley J. Caterbone, Pro Se, U.S.C.A. Third Circuit BRIEF STATEMENT OF JUDICIAL
MISCONDUCT OR DISABILITY of February 1, 2017
69. Jeremy Scahill on Donald Trump and the Military-Industrial Complex - Truthdig
In an interview with acTVism, the investigative journalist also discusses the
LETTER TO SUPERINTENDENT HALLETT Page No. 14 of 228 Saturday June 24, 2017
70. significance of the Ramstein Air Base in Germany. - 2017/02/02
71. Pennsylvania State Police Liquor Control Enforcement Formal Complaint AGAINST
DOWNTOWN LANCASTER BARS, August 12, 2016 | Lawsuit | United States Courts Of
Appeals
73. Torture LAW and the United States - Wikipedia by Stan J. Caterbone and ADVANCED
MEDIA GROUP, February 4, 2017
74. CI-16-08472 DOCKET SHEET February 3, 2017 and Torture LAW and the United
States - Wikipedia by Stan J. Caterbone and ADVANCED MEDIA GROUP, February 4,
2017
75. LIP News - CORRUPTION IN THE LANCASTER CITY POLICE DEPARTMENT AND LNP -
February 4, 2017
78. 16-Cv-2513 Preliminary Injunction for EMERGENCY RELIEF in Middle District ORDER
by JUDGE KANE TRANSFER to EASTERN DISTRICT PHIL January 31, 2017
82. Third Circuit Senior Judge Maryanne Trump Barry, who is President Donald
Trump’s older sister, decided this week to go inactive on the bench, relinquishing
her staff and chambers despite being scheduled to hear cases this year.
83. STAN J. CATERBONE June 18, 2008 US District Court Case 08-02982 CATERBONE v.
Lancaster City Police Bureau, et.al., CASE FILE | Complaint
LETTER TO SUPERINTENDENT HALLETT Page No. 15 of 228 Saturday June 24, 2017
DOCUMENT DIVIDER
LETTER TO SUPERINTENDENT HALLETT Page No. 16 of 228 Saturday June 24, 2017
Love, Murder, and Corruption in Lancaster County: My Story: Lisa Mich... http://www.amazon.com/Love-Murder-Corruption-Lancaster-County/dp...
All lisa michelle lambert Go Stan's Account for Business Wish List
Books Advanced Search New Releases Best Sellers The New York Times Best Sellers Children's Books Textbooks Textbook Rentals
Share
Love, Murder, and Corruption in
Lancaster County: My Story
Paperback February 15, 2016
by Lisa Michelle Lambert and David Brown (Author)
LETTER TO SUPERINTENDENT HALLETT Page No. 17 of 228 Saturday June 24, 2017
1 of 3 1/15/2016 6:01 AM
Directions to MCI - Framingham http://www.mass.gov/eopss/law-enforce-and-cj/prisons/doc-facilities/doc...
Public Safety
Home Law Enforcement & Criminal Justice Prisons DOC Facilities Directions to State Correctional Facilities Directions to MCI - Framingham
Domestic Violence
Call 1-508-850-STOP From the West: Take the Massachusetts Turnpike East to exit 12 (Route 9
East). Take a right onto Route 126 South. Go through downtown Framingham,
Victim Services Unit crossing a set of railroad tracks and Route 135. Bear left onto Irving Street
Call 1-866-6VICTIM (Tedeschi Food on right). Go through 2 sets of traffic lights and at the third set
go straight past Fire Station on left. MCI-Framingham is approximately 1/4 of a
Employee Assistance Services Unit
mile down on the left.
Office of Diversity and Equal
Opportunity
-Mentor Program
-Job Shadow Program
-EEOP Utilization Report
1 of 2 6/23/17, 2:54 AM
Directions to MCI - Framingham http://www.mass.gov/eopss/law-enforce-and-cj/prisons/doc-facilities/doc...
Proposed Amendments to
Regulations
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 2 of 141 Friday June 23, 2017
2 of 2 6/23/17, 2:54 AM
MCI Framingham Visiting Policy http://www.mass.gov/eopss/law-enforce-and-cj/prisons/doc-facilities/doc...
Public Safety
Home Law Enforcement & Criminal Justice Prisons DOC Facilities State Correctional Facilities Visiting Policies MCI Framingham Visiting Policy/Hours
General Population
State Correctional Facilities MCI - Framingham
Visiting hours are from 1 to 8:45 p.m.; on Sunday, Tuesday, Thursday and
Offender Programs Directions to MCI - Framingham
Saturday for all inmates housed in general population.
DOC Staff List and Directory MCI Framingham Visiting
Civil Commitments
Policy/Hours
Reentry & Reintegration
The civil commitment population shall follow general population rules and
MCI - Framingham Offender
regulations for visits. Civil Commitments must be escorted to and from the
Programs
Visiting Room during non-movement times. Visiting Hours for civil
commitments are as follows: Visitors Dress Code
Recruitment be processed through the trap. Inmates who can not be properly
Volunteer Opportunities
Call: 1-866-WRK-4DOC processed will remain the Visiting Room on an out-count until which time
Fax: (508) 422-3624 they can be properly processed. Those who choose to remain may not Massachusetts Correctional
egress until directed by the visiting room OIC. Industries
Internship Program
Massachusetts Department of Visitor Processing will continue through the trap closing times. All
Correction paperwork will be processed however, inmates will not be called for visits
Office of Diversity until which time the trap reopens and visitors will not be processed
50 Maple Street
through the trap during count or shift change.
Milford, MA 01757
Opportunities for College Students Inmates are allowed a maximum number of five (5) visiting periods per week.
A visiting period is 1 - 5 p.m. and/or 4 - 8:45 p.m. An inmate who is on a
Domestic Violence visit for any portion of either period shall be charged with utilization of one
Call 1-508-850-STOP visit (i.e. if the visit runs from 2 to 6 p.m. then the inmate shall be charged
with two (2) visiting periods.)
Victim Services Unit
Call 1-866-6VICTIM Maximum number of visitors allowed per visit will be (2) adults and three (3)
children.
Employee Assistance Services Unit
Visitors may visit for the entire scheduled visiting period. In emergency
Office of Diversity and Equal
situations and overcrowding, at the discretion of the Shift Commander, visits
Opportunity
may be limited to no less than one (1) hour in duration to accommodated all
-Mentor Program
visitors. Visits that started earliest will be terminated first (excluding visitors
-Job Shadow Program
-EEOP Utilization Report who traveled over 100 miles) to provide room when visitors are waiting to
enter the visiting room due to overcrowding.
Global Tel Link (GTL)/Inmate
Telephone Services Visitors who have been convicted of a felony or who have been sentenced to
- Calling Rates a penal institution must complete a Felony/Background Form and receive
(English & Spanish ) permission from the Superintendent, prior to visiting.
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 3 of 141 Friday June 23, 2017
1 of 7 6/22/17, 8:36 AM
MCI Framingham Visiting Policy http://www.mass.gov/eopss/law-enforce-and-cj/prisons/doc-facilities/doc...
Implementation of Debit Calling Visitors must present photo identification, which in the opinion of the
- English Notice admitting officer(s) is adequate. A current Massachusetts Driver's license,
- Spanish Notice passport or an identification card issued by the Department of Transitional
Assistance shall be sufficient. Inmate visitors are not required to leave this
Inmate fund deposits (Canteen)
documentation with the visit processing officer for general population visits.
Department of Correction Public If the visitor is escorted to a non-contact visit in CCU, the photo ID (only) will
Records Requests be retained. The ID shall be placed in the designated slot in the visitor trap.
Proposed Amendments to Attorney, law students, and paralegal visits will be conducted in one of the
Regulations three (3) designated attorney-visiting rooms. This will allow offenders
confidential contact with their attorneys/representatives.
Objective Point Base Classification
Manuals Visits for inmates admitted to outside hospital shall be conducted in
accordance with 103 DOC 521.
The Visiting Room log in the IMS shall be maintained throughout all visits by
the Officer in Charge of the visiting room.
Special Visits
Requests for Special Visits must be made in writing one week in advance.
Requests made outside this time frame due to a family crisis or emergency
shall be handled on an individual basis.
No child who was a victim of the inmate's offense shall be authorized to visit
without the authorization of the Commissioner of or designee.
A parent entering with their minor child must have a copy of the minor's birth
certificate and appropriate identification with them each time they visit.
If the adult entering with a minor is the minor's legal guardian, staff shall
ensure they have a court document indicating they are the appointed legal
guardian, they must present that court document, along with a copy of the
minor's birth certificate and appropriate identification, each time they visit.
An individual that is not the parent or legal guardian of a minor must submit a
completed Minor Request Form to the Superintendent, and obtain the
Superintendent's approval to bring the minor in to visit prior to visiting.
Staff must verify that there is an approved Minor Consent Form on file for
the minor, and that the individual accompanying the minor has a copy of the
approved minor form, along with the minor's birth certificate and appropriate
identification.
NOTE: If there is no approved Minor Consent Form on file, the officer will
give the individual a blank form and advise them that the minor's parent or
legal guardian must complete the form then submit the form to the
Superintendent with necessary documentation for approval.
If the MCI-Framingham inmate is the parent of the minor and wishes the
minor to visit, the inmate may fill out a Minor Consent Form and submit to the
Superintendent. The inmate must ensure that:
The form is filled out completely, noting the name and address of the adult
that will bring the minor to MCI-Framingham.
A copy of the birth certificate is provided for attachment to the Minor Consent
Form.
Upon the Superintendent's approval, the form will be returned to the inmate;
a copy of same, along with the birth certificate, will be sent to the adult
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In any case involving a minor, if the individual who is trying to visit with
the minor is not the person authorized on the minor consent form the
minor will not be allowed to visit.
Vending Machines
The machines and their contents are made available for inmates and their
visitors for their personal consumption in the visiting room.
There will be no food or drink removed from the visiting area by any visitor or
inmate. Inmates must consume or dispose of all food/drink prior to entering
the strip search waiting area.
It is the responsibility of the inmate to ensure that all trash is deposited into
the appropriate receptacles.
Only two (2) people at a time are allowed at the vending machine. Inmates
are not allowed to operate or have direct access to the vending machine.
Parenting Room
Inmates who receive visits, which include children under 14 years of age are
encouraged to utilize the parenting room in the visiting area.
All toys are to remain in the parenting room and are to be put away at the
end of the visit.
Inmates and visitors who abuse the privileges of the parenting room may be
subject to loss of visiting privileges.
Inmates entering the Visiting Area must wear clothing that is neat and
presentable. At a minimum, clothing shall include a shirt or blouse with
sleeves, pants, socks, with underpants and bra. The Visiting Room
Sergeant/OIC shall make the determination of presentability.
Dress shirts do not need to be tucked in, however undershirts must be neatly
tucked in.
Inmates are allowed to enter the Visiting Area with a handkerchief, religious
medal, medic-alert bracelet/necklace, wedding band, and their identification
card. Legal material will be allowed for attorney visits.
No other items are to be brought to or worn in the Visiting Area, other than
those items approved in the dress code.
Upon entrance to the Visiting Room, inmates will provide the Visiting Room
Officer their movement and institutional ID card.
Seating will be on a first come first served basis and only in those areas
designated for inmates. As the Inmates enter the visiting room they will take
a plastic chair from the stack and place it across from their visitors seats.
When the visit has ended they will return their plastic chair to the stack and
wait to be strip searched prior to exiting the visiting room. The Visiting Room
Sergeant or the Officer in Charge will monitor seating.
Inmates as well as visitors, are required to sit with their back flat against the
chair and their feet flat on the ground. Legs may not be crossed and there is
no straddling on the chairs.
Inmates are not allowed to take or give any item to visitors. The exception to
this is items purchased from the vending machine. Inmates are not allowed
to share items from the vending machine with their visitors.
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In the event an infant needs a diaper change visiting room staff will do the
following:
The Officer inspecting the diaper will remain in the immediate area but
will NOT maintain constant observation of the infant during the diaper
change.
The toilet facilities shall be searched prior to any visitor entering and after the
visitor has exited and a personal search of the visitor has been completed.
Visitors may purchase a debit card in the lobby for vending machine
purchases. Money is not allowed in the visiting room.
Visitors may only visit with one inmate at a time during their incarceration at
MCI-Framingham unless the Superintendent or her designee has provided
special approval. (Visitors cannot visit one inmate on one day and another
inmate on another day).
Visitors to MCI Framingham, their vehicles and their possessions are subject
to search while on state property.
All visitors must park their vehicles in the area assigned for Visitors Parking.
All vehicles must be locked while on state property. Visitors will be required
to list the registration number of the vehicle they arrived in on the Request to
Visit Form. Visitors are not allowed to loiter in the parking lot.
a. The inmate may bring with them a non-squeaking dog toy, dog treats
and a mat into the visiting room. (No bones are allowed.)
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d. Handlers must give the dog the opportunity to "break" prior to entering
the visiting room. If the puppy needs to "break", they must notify
correctional staff and will be allowed to go into the courtyard on the hour.
Searches of Visitors
The trap officer shall advise all the visitors prior to entering the trap of the
items that allowed to be carried on the person prior to entering the visiting
room. (Locker key, vending card, approved personal medication, wedding
ring/band, and medical alert jewelry). All other items should be secured
inside the lockers.
Visitors shall be directed by the pedestrian trap officer to remain at the front
of the entrance, until the officer gives further direction.
Prior to allowing an inmate visitor entrance into the facility, the Outer control
OIC must ensure proper staffing in the Visiting Room and Visiting Room
Trap/Sally Port. At least one officer must be present to man the Visiting
Room Trap/Sally Port prior to allowing visitors access.
Officers assigned to the Visitor Pedestrian Trap shall search the clean room
and Visitor Pedestrian Trap prior to processing any visitors, and should
search these areas periodically and at the conclusion of their tour of duty.
A maximum of four (4) visitors to include children will be allowed in the visitor
trap at any one time. The pedestrian trap officer may process less than three
(3) visitors to maintain proper security, if deemed necessary. The shift
commander will be notified for authorization.
NOTE: In the event drug detection dogs are used by Correctional Staff
to conduct searches of visitors no more than 3 persons (including
children) shall be allowed in the visitor trap.
The visiting trap officer shall check each individual for the current "stamp of
the day" utilizing the hand held black light prior to allowing access into the
Visiting Room Trap/Sally Port. Visitors will remove all outer garments, belts,
glasses and shoes, placing them on the table. All items in their pockets to
include approved medication will be placed into the containers provided in
the area. All garments pockets shall be turned inside out. (All pockets that
cannot be turned inside out shall be searched by the Trap Officer.) The trap
Officer shall search all the personal belongings for contraband (outer
garments / all items inside the bucket) and place it on the table near the inner
door of visiting room, away from the visitor's search.
The Visiting Trap Officer shall then conduct a visual search of the visitor to
include that of out turned pockets, open mouth hairline etc. This shall be
accomplished prior to the individual passing thru the metal detector.
At a minimum, all visitors must successfully pass through the metal detector
and/or hand held scanner. Each Shift Commander shall designate the
personal search number of the shift "number of the day". In this instance the
designated personal search will always be a "pat search". This search is
conducted after the individual walks thru the walk thru metal detector. The
individual to be searched must sign the trap log book prior to said search.
The visiting trap officer will instruct each visitor to pass through the walk thru
metal detector (one at a time). The only exception shall be any individual with
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Visitors who are not able to successfully pass through the metal detector
shall be required to submit to a more thorough personal search. More
thorough personal and strip searches will be conducted in the clean search
room located in the Visiting Trap area. In this circumstance the Shift
Commander will be notified for authorization prior to the more thorough
personal search being conducted and an incident report shall be written. Any
visitor who refuses any type of personal search must be informed that they
may leave the institution and forfeit the opportunity to visit rather than submit
to the search. This procedure will be followed for each visitor prior to being
directed to the clean room. The shift commander should be notified as soon
as possible prior to visitor leaving.
Visitors that have artificial limbs or prosthetic devices shall remove those
items for inspection by correctional staff. Such searches shall be done in an
area out of view of other visitors, and by a correctional staff member of the
same gender as the visitor. Employees conducting searches shall do so in a
professional and courteous manner.
All searches of minors and infants must be conducted in the presence of the
adult (legal guardian / parent) who is accompanying them. Any further search
of a child/minor shall be done only with the approval of the parent/legal
guardian and in their presence. Children with diapers will not be required to
have diapers removed for "search purposes" unless there is reasonable
suspicion to conduct such a search and prior approval is given by the
Superintendent or designee. The diaper may be visually inspected, to ensure
that no contraband is present. This search shall also be conducted out of
view of other visitors and consent by the parent/legal guardian shall be
recorded in the appropriate log. The parent /Legal Guardian shall sign the log
prior to the search taking place.
At no time should the minor be placed in the designated clean room with the
visitor who is not the parent or legal guardian of the minor. All minors will be
processed with their parent or legal guardian only. With the exception of
security staff and parent or legal guardian, no other adult visitor should be
present while processing minors inside the pedestrian trap.
At no time should the officer open the inner door to the visiting room, unless
all visitors have successfully passed the required search and they have
received the "signal of the day."
Should for any reason it is determined that the above procedure has been
compromised, the trap officer shall re-search all the visitors inside the trap
area prior to giving access inside the visiting room.
Visiting room staff shall ensure all areas of the room are searched prior to
any visitors or inmates allowed in the area, and again once all visitors and
inmates have exited the area. This shall be documented as a common area
search in IMS.
The visitor shall be granted the opportunity to leave the institution rather than
submit to search and may leave at any time during the strip search unless:
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b. The employee has probable cause to believe that the visitor has
committed an arrestable offense and the employee has probable cause
to believe that the visitor has seizable evidence concealed on his person.
c. The employee has probable cause to believe that the visitor has
seizable evidence concealed on his/her person.
The officer(s) conducting any strip search shall do so in accordance with 103
FRA 506 S.II (B). The Officer(s) shall file an incident report concerning the
search with the Superintendent, prior to the end of the shift. The report shall
contain the name of the visitor, the name(s) of the searching officer(s) and of
the official who approved the search, the extent of the search, and what, if
anything was found.
Any person refusing to submit to any aspect of the search procedures shall
be denied entrance to the institution. Where the refusal occurs under
circumstances indicating that the most likely motive for refusal may be to
prevent discovery of concealed articles, where a suspicious pattern of
refusals is apparent, or where a visitor engages in offensive or assaultive
behavior during the search process, his/her visiting privileges may be
suspended or terminated. The procedure outlined in 103 CMR 483.16 shall
be followed.
Papers and documents carried in or out by any judge, attorney, law student
paralegal, the Governor, any legislator or member of the Parole Board may
be inspected for concealed articles but shall not be read.
If contraband is found which may lead to an arrest refer to 103 FRA 501
Attachment XI- Arrests of Individuals on the Grounds of MCI Framingham.
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STAN J. CATERBONE MCI-FRAMINGHAM Page No. 9 of 141 Friday June 23, 2017
7 of 7 6/22/17, 8:36 AM
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
DOCUMENT DIVIDER
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 10 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 11 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 12 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 13 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 14 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 15 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 16 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 17 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 18 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 19 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 20 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 21 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 22 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 23 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 24 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
DOCUMENT DIVIDER
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 25 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 26 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 27 of 141 Friday June 23, 2017
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
DOCUMENT DIVIDER
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 28 of 141 Friday June 23, 2017
United States District Court Eastern District of Pennsylvania https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?122772715415236-L_1_0-1
Petitioner
LISA MICHELLE LAMBERT represented by JEREMY H.G. IBRAHIM
LAW OFFICES OF JEREMY H.
GONZALEZ IBRAHIM
P.O. BOX 1025
CHADDS FORD, PA 19317
215-568-1943
Email: jeremyibrahim.esq@verizon.net
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
DAVID W. BROWN
BORJESON & MAIZEL LLC
1500 WALNUT ST STE 413
PHILADELPHIA, PA 19012
215-772-3020
Email: dbrown@levinlegalgroup.com
ATTORNEY TO BE NOTICED
V.
Respondent
LYNN BISSONETTE
SUPERINTENDENT,
MCI-FRAMINGHAM
Respondent
THE DISTRICT ATTORNEY OF
LANCASTER COUNTY,
PENNSYLVANIA
Respondent
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 29 of 141 Friday June 23, 2017
1 of 4 1/20/2016 8:30 PM
United States District Court Eastern District of Pennsylvania https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?122772715415236-L_1_0-1
V.
Movant
STANLEY J. CATERBONE represented by STANLEY J. CATERBONE
AND ADVANCED MEDIA GROUP 1250 FREMONT STREET
LANCASTER, PA 17603
717-669-2163
PRO SE
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 30 of 141 Friday June 23, 2017
2 of 4 1/20/2016 8:30 PM
United States District Court Eastern District of Pennsylvania https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?122772715415236-L_1_0-1
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 31 of 141 Friday June 23, 2017
3 of 4 1/20/2016 8:30 PM
United States District Court Eastern District of Pennsylvania https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?122772715415236-L_1_0-1
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 32 of 141 Friday June 23, 2017
4 of 4 1/20/2016 8:30 PM
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
DOCUMENT DIVIDER
STAN J. CATERBONE MCI-FRAMINGHAM Page No. 33 of 141 Friday June 23, 2017
Search - Supreme Court of the United States https://www.supremecourt.gov/search.aspx?filename=/docketfiles/16-68...
Stan J. Caterbone v. Allison Hallet, Superintendent MASS Correction Institution re LISA MICHELLE LAMBERT
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
1 of 2 1/10/2017 5:14 PM
Stan J. Caterbone v. Allison Hallet, Superintendent MASS Correction Institution re LISA MICHELLE LAMBERT
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Stan J. Caterbone
MOVANT
1250 Fremont Street
Lancaster, PA 17603
scaterbone@live.com
717-669-2163
717-459-7588 Fax
The following is a copy of the 1998 AFFIDAVIT to Judge Dalzall. The original file is
the original complaint filed on May 16, 2005 for Case No. 05-2288 in the U.S. District
Court for the Eastern District of Pennsylvania; however the document is not viewable
on the U.S. District Court Court Filing System. I do not know why. The affidavit
was delivered on a CD-ROM to an Inbox outside the chambers of Judge Stewart
Dalzall. Back at that time the public could access the halls of the chambers to U.S.
District Judges in Philadelphia, Pennsylvania.
Also attached is the DOCKET for Lisa Michelle Lambert's 2014 Habeus Corpus
which I am a party, as being named the MOVANT on June 23, 2015 with the filing of
my AMICUS.
Page 2
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 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.
Respectfully,
Stan J. Caterbone
V.
Respondent
LYNN BISSONETTE
SUPERINTENDENT, MCI-FRAMINGHAM
Respondent
THE DISTRICT ATTORNEY OF LANCASTER
COUNTY, PENNSYLVANIA
Respondent
THE ATTORNEY GENERAL OF PENNSYLVANIA
V.
Movant
STANLEY J. CATERBONE represented by STANLEY J. CATERBONE
AND ADVANCED MEDIA GROUP 1250 FREMONT STREET
LANCASTER, PA 17603
PRO SE
1 of 2 8/19/2015 1:16 AM
United States District Court Eastern District of Pennsylvania https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?121153035547044-L_1_0-1
Sunday
StanJanuary
J. Caterbone
22, 2017
v. Allison Hallet, Superintendent
Page 1021
MASSof 2301
Correction Stan
Institution
J. Caterbone
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
PACER Service Center
Transaction Receipt
08/19/2015 01:14:50
PACER Login: am6446:3514696:0 Client Code:
Description: Docket Report Search Criteria: 5:14-cv-02559-PD
Billable Pages: 2 Cost: 0.20
2 of 2 8/19/2015 1:16 AM
Sunday
StanJanuary
J. Caterbone
22, 2017
v. Allison Hallet, Superintendent
Page 1022
MASSof 2301
Correction Stan
Institution
J. Caterbone
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
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.
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. These issues and incidents identified herein have attempted to conceal my
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
considerations would exceed $1 million.
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 self-
serving 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.
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.. The activities of International Signal & Control,
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. Such disclosures threatened the integrity of
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.
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. Defendants responsible for administering
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. . Commonwealth National Bank (Mellon) would have less
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.
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
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.
Sunday January 22, 2017 Page 1028 of 2301 Stan J. Caterbone LAMBERT CASE FILE
To President
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No. Lambert
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by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
AFFIDAVIT OR DECLARATION
IN SUPPORT OF MOTION FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. For both you and your spouse estimate the average amount of money received from each of
the following sources during the past 12 months. Adjust any amount that was received
weekly, biweekly, quarterly, semiannually, or annually to show the monthly rate. Use gross
amounts, that is, amounts before any deductions for taxes or otherwise.
Employment $ $ $ $
Self-employment $ $ $ $
Gifts $ $ $ $
Alimony $ $ $ $
Child Support $ $ $ $
Unemployment payments $ $ $ $
Public-assistance $ $ $ $
(such as welfare)
Other (specify): $ $ $ $
U.S.C.A.
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2. List your employment history for the past two years, most recent rst. (Gross monthly pay
is before taxes or other deductions.)
3. List your spouses employment history for the past two years, most recent employer rst.
(Gross monthly pay is before taxes or other deductions.)
Financial institution Type of account Amount you have Amount your spouse has
Members1st Checking $ 1,000.00 $
TD Ameritrade Money Market $ 12,000.00 $
$ $
5. List the assets, and their values, which you own or your spouse owns. Do not list clothing
and ordinary household furnishings.
D
X Home D Other real estate
Value 25% of 80,000.00 Value
D Other assets
Description 997,000 Shares of NON-MARKETABLE Stock in Advanced Media Group, Ltd.,
Value
U.S.C.A.
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FILE
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To President
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Obama
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No. Lambert
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by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Life $ $
Health $ $
Motor Vehicle $ $
(specify): $ $
Installment payments
Motor Vehicle $ $
Credit card(s) $ $
Department store(s) $ $
Other: $ $
Other (specify):
Home Improvement $ 500.00 $
U.S.C.A.
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FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
To President
US Supreme Court
Obama
Case
re Lisa
No. Lambert
16-6822 Page
Page22
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DRAFT
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LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
No.
IN THE
STANLEY J. CATERBONE
PETITIONER
(Your Name)
vs.
Stanley J. Caterbone
(Your Name)
(Address)
Lancaster, PA 17603
(717) 669-2163
(Phone Number)
U.S.C.A.
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DRAFT
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LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
QUESTION(S) PRESENTED
July 18, 2016 C.A. 16-1149 ORDER Present Chargaras, Jordan, and Venaskie -
[The foregoing motion for reconsideration of the Clerk's Order is construed as a motion to review
that order and is denied as meritless. The Clerk has the authority under 3d Cir. LAR 3.3 and Misc.
107.1(a) to dismiss an appeal for failure to satisfy the fee requirement. Appellant received
written notice of the need to take care of his fee obligation, and he failed to respond with either
payment of the fees or a motion seeking leave to proceed in forma pauperis (IFP). Appellant's
contention that he is being unjustly taxed twice for the same appeal is erroneous Appellant
incurred a fee obligation by filling a notice of appeal. See Fed. R. App. P. 3(e) (Upon filing a
notice of appeal, the appellant must pay the district clerk all required fees.). He filed two
separate appeals (C.A. Nos. 15-3400 and 16-1149), and he incurred two fee obligations.
Moreover, we note that appellant suffered no monetary loss for his appeal at C.A. No. 15-3400 as
the Court granted his motion to voluntarily withdraw that appeal before his IFP motion was
considered or any fee remitted.
WHY DID THE COURT FAIL TO COMPLY WITH OR CONSIDER DOCKET ENTRY NO.
DECEMBER 31, 2015 - THE LETTER TO THE COURT REQUESTING TO RESCIND THE
MOTION TO DISMISS?
U.S.C.A.
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FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
To President
US Supreme Court
Obama
Case
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No. Lambert
16-6822 Page
Page25
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by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
TABLE OF CONTENTS
12
OPINIONS BELOW ........................................................................................................ 1
13
JURISDICTION...................................................................................................................
CONCLUSION....................................................................................................................
27
INDEX TO APPENDICES
APPENDIX A .............................................................................................................. 36
APPENDIX B ............................................................................................................... 41
APPENDIX C .............................................................................................................. 43
APPENDIX D .............................................................................................................. 47
APPENDIX E .............................................................................................................. 55
APPENDIX F .............................................................................................................. 60
APPENDIX G .............................................................................................................. 64
APPENDIX H .............................................................................................................. 71
APPENDIX I ............................................................................................................... 73
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DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Pointer v. Texas, 380 U.S. 400, 85 S.Ct. 1065, 13 L.Ed.2d 923 (1965); Appendix B -
OTHER
U.S.C.A.
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LAMBERT
COPY
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by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
IN THE
Petitioner respectfully prays that a writ of certiorari issue to review the judgment below.
OPINIONS BELOW
The opinion of the highest state court to review the merits appears at
Appendix to the petition and is
[ ] reported at ; or,
[ ] has been designated for publication but is not yet reported; or,
[ ] is unpublished.
1.
U.S.C.A.
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DRAFT
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LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
JURISDICTION
The date on which the United States Court of Appeals decided my case
was June 15, 2016 .
[ ] A timely petition for rehearing was denied by the United States Court of
Appeals on the following date: July 18, 2015 , and a copy of the
order denying rehearing appears at Appendix A .
The date on which the highest state court decided my case was .
A copy of that decision appears at Appendix .
[ ] A timely petition for rehearing was thereafter denied on the following date:
, and a copy of the order denying rehearing
appears at Appendix .
U.S.C.A.
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POINTER
v.
TEXAS.
No. 577.
Supreme Court of United States.
Argued March 15, 1965.
Decided April 5, 1965.
CERTIORARI TO THE COURT OF CRIMINAL APPEALS OF TEXAS.
Orville A. Harlan, by appointment of the Court, 379 U.S. 911, argued the cause and filed a brief
for petitioner.
Gilbert J. Pena, Assistant Attorney General of Texas, argued the cause for respondent. With him
on the brief were Waggoner Carr, Attorney General of Texas, Hawthorne Phillips, First Assistant
Attorney General, Stanton Stone, Executive Assistant Attorney General, and Howard M. Fender
and Allo B. Crow, Jr., Assistant Attorneys General.
MR. JUSTICE BLACK delivered the opinion of the Court.
The Sixth Amendment provides in part that:
"In all criminal prosecutions, the accused shall enjoy the right . . . to be confronted
with the witnesses *401 against him . . . and to have the Assistance of Counsel for his
defence."
U.S.C.A.
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by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Two years ago in Gideon v. Wainwright, 372 U.S. 335, we held that the Fourteenth Amendment
makes the Sixth Amendment's guarantee of right to counsel obligatory upon the States. The
question we find necessary to decide in this case is whether the Amendment's guarantee of a
defendant's right "to be confronted with the witnesses against him," which has been held to
include the right to cross-examine those witnesses, is also made applicable to the States by the
Fourteenth Amendment.
The petitioner Pointer and one Dillard were arrested in Texas and taken before a state judge for a
preliminary hearing (in Texas called the "examining trial") on a charge of having robbed Kenneth
W. Phillips of $375 "by assault, or violence, or by putting in fear of life or bodily injury," in
violation of Texas Penal Code Art. 1408. At this hearing an Assistant District Attorney conducted
the prosecution and examined witnesses, but neither of the defendants, both of whom were
laymen, had a lawyer. Phillips as chief witness for the State gave his version of the alleged
robbery in detail, identifying petitioner as the man who had robbed him at gunpoint. Apparently
Dillard tried to cross-examine Phillips but Pointer did not, although Pointer was said to have tried
to cross-examine some other witnesses at the hearing. Petitioner was subsequently indicted on a
charge of having committed the robbery. Some time before the trial was held, Phillips moved to
California. After putting in evidence to show that Phillips had moved and did not intend to return
to Texas, the State at the trial offered the transcript of Phillips' testimony given at the preliminary
hearing as evidence against petitioner. Petitioner's counsel immediately objected to introduction of
the transcript, stating, "Your Honor, we will object to that, as it is a denial of the confrontment of
the witnesses against the Defendant." *402 Similar objections were repeatedly made by
petitioner's counsel but were overruled by the trial judge, apparently in part because, as the judge
viewed it, petitioner had been present at the preliminary hearing and therefore had been
"accorded the opportunity of cross examining the witnesses there against him." The Texas Court
of Criminal Appeals, the highest state court to which the case could be taken, affirmed petitioner's
conviction, rejecting his contention that use of the transcript to convict him denied him rights
guaranteed by the Sixth and Fourteenth Amendments. 375 S.W.2d 293. We granted certiorari to
consider the important constitutional question the case involves. 379 U.S. 815.
In this Court we do not find it necessary to decide one aspect of the question petitioner raises,
that is, whether failure to appoint counsel to represent him at the preliminary hearing
unconstitutionally denied him the assistance of counsel within the meaning of Gideon v.
Wainwright, supra. In making that argument petitioner relies mainly on White v. Maryland, 373
U.S. 59, in which this Court reversed a conviction based in part upon evidence that the defendant
had pleaded guilty to the crime at a preliminary hearing where he was without counsel. Since the
preliminary hearing there, as in Hamilton v. Alabama, 368 U.S. 52, was one in which pleas to the
charge could be made, we held in White as in Hamilton that a preliminary proceeding of that
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nature was so critical a stage in the prosecution that a defendant at that point was entitled to
counsel. But the State informs us that at a Texas preliminary hearing, such as is involved here,
pleas of guilty are not guilty are not accepted and that the judge decides only whether the
accused should be bound over to the grand jury and if so whether he should be admitted to bail.
Because of these significant differences in the procedures of the respective States, we cannot say
that the White case is necessarily controlling *403 as to the right to counsel. Whether there might
be other circumstances making this Texas preliminary hearing so critical to the defendant as to
call for appointment of counsel at that stage we need not decide on this record, and that question
we reserve. In this case the objections and arguments in the trial court as well as the arguments
in the Court of Criminal Appeals and before us make it clear that petitioner's objection is based
not so much on the fact that he had no lawyer when Phillips made his statement at the
preliminary hearing, as on the fact that use of the transcript of that statement at the trial denied
petitioner any opportunity to have the benefit of counsel's cross-examination of the principal
witness against him. It is that latter question which we decide here.
I.
The Sixth Amendment is a part of what is called our Bill of Rights. In Gideon v. Wainwright, supra,
in which this Court held that the Sixth Amendment's right to the assistance of counsel is
obligatory upon the States, we did so on the ground that "a provision of the Bill of Rights which is
`fundamental and essential to a fair trial' is made obligatory upon the States by the Fourteenth
Amendment." 372 U. S., at 342. And last Term in Malloy v. Hogan, 378 U.S. 1, in holding that the
Fifth Amendment's guarantee against self-incrimination was made applicable to the States by the
Fourteenth, we reiterated the holding of Gideon that the Sixth Amendment's right-to-counsel
guarantee is " `a fundamental right, essential to a fair trial,' " and "thus was made obligatory on
the States by the Fourteenth Amendment." 378 U. S., at 6. See also Murphy v. Waterfront
Comm'n, 378 U.S. 52. We hold today that the Sixth Amendment's right of an accused to confront
the witnesses against him is likewise a fundamental right and is made obligatory on the States by
the Fourteenth Amendment.
*404 It cannot seriously be doubted at this late date that the right of cross-examination is
included in the right of an accused in a criminal case to confront the witnesses against him. And
probably no one, certainly no one experienced in the trial of lawsuits, would deny the value of
cross-examination in exposing falsehood and bringing out the truth in the trial of a criminal case.
See, e. g., 5 Wigmore, Evidence 1367 (3d ed. 1940). The fact that this right appears in the
Sixth Amendment of our Bill of Rights reflects the belief of the Framers of those liberties and
safeguards that confrontation was a fundamental right essential to a fair trial in a criminal
prosecution. Moreover, the decisions of this Court and other courts [*] throughout the years have
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"They have ancient roots. They find expression in the Sixth Amendment which provides
that in all *405 criminal cases the accused shall enjoy the right `to be confronted with
the witnesses against him.' This Court has been zealous to protect these rights from
erosion." 360 U. S., at 496-497 (footnote omitted).
There are few subjects, perhaps, upon which this Court and other courts have been more nearly
unanimous than in their expressions of belief that the right of confrontation and cross-examination
is an essential and fundamental requirement for the kind of fair trial which is this country's
constitutional goal. Indeed, we have expressly declared that to deprive an accused of the right to
cross-examine the witnesses against him is a denial of the Fourteenth Amendment's guarantee of
due process of law. In In re Oliver, 333 U.S. 257, this Court said:
"A person's right to reasonable notice of a charge against him, and an opportunity to
be heard in his defensea right to his day in courtare basic in our system of
jurisprudence; and these rights include, as a minimum, a right to examine the
witnesses against him, to offer testimony, and to be represented by counsel." 333 U.
S., at 273 (footnote omitted).
And earlier this Term in Turner v. Louisiana, 379 U.S. 466, 472-473, we held:
"In the constitutional sense, trial by jury in a criminal case necessarily implies at the
very least that the `evidence developed' against a defendant shall come from the
witness stand in a public courtroom where there is full judicial protection of the
defendant's right of confrontation, of cross-examination, and of counsel."
Compare Willner v. Committee on Character & Fitness, 373 U.S. 96, 103-104.
*406 We are aware that some cases, particularly West v. Louisiana, 194 U.S. 258, 264, have
stated that the Sixth Amendment's right of confrontation does not apply to trials in state courts,
on the ground that the entire Sixth Amendment does not so apply. See also Stein v. New York,
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346 U.S. 156, 195-196. But of course since Gideon v. Wainwright, supra, it no longer can broadly
be said that the Sixth Amendment does not apply to state courts. And as this Court said in Malloy
v. Hogan, supra, "The Court has not hesitated to re-examine past decisions according the
Fourteenth Amendment a less central role in the preservation of basic liberties than that which
was contemplated by its Framers when they added the Amendment to our constitutional scheme."
378 U. S., at 5. In the light of Gideon, Malloy, and other cases cited in those opinions holding
various provisions of the Bill of Rights applicable to the States by virtue of the Fourteenth
Amendment, the statements made in West and similar cases generally declaring that the Sixth
Amendment does not apply to the States can no longer be regarded as the law. We hold that
petitioner was entitled to be tried in accordance with the protection of the confrontation guarantee
of the Sixth Amendment, and that that guarantee, like the right against compelled self-
incrimination, is "to be enforced against the States under the Fourteenth Amendment according to
the same standards that protect those personal rights against federal encroachment." Malloy v.
Hogan, supra, 378 U. S., at 10.
II.
Under this Court's prior decisions, the Sixth Amendment's guarantee of confrontation and cross-
examination was unquestionably denied petitioner in this case. As has been pointed out, a major
reason underlying the *407 constitutional confrontation rule is to give a defendant charged with
crime an opportunity to cross-examine the witnesses against him. See, e. g., Dowdell v. United
States, 221 U.S. 325, 330; Motes v. United States, 178 U.S. 458, 474; Kirby v. United States, 174
U.S. 47, 55-56; Mattox v. United States, 156 U.S. 237, 242-243. Cf. Hopt v. Utah, 110 U.S. 574,
581; Queen v. Hepburn, 7 Cranch 290, 295. This Court has recognized the admissibility against an
accused of dying declarations, Mattox v. United States, 146 U.S. 140, 151, and of testimony of a
deceased witness who has testified at a former trial, Mattox v. United States, 156 U.S. 237, 240-
244. See also Dowdell v. United States, supra, 221 U. S., at 330; Kirby v. United States, supra,
174 U. S., at 61. Nothing we hold here is to the contrary. The case before us would be quite a
different one had Phillips' statement been taken at a full-fledged hearing at which petitioner had
been represented by counsel who had been given a complete and adequate opportunity to cross-
examine. Compare Motes v. United States, supra, 178 U. S., at 474. There are other analogous
situations which might not fall within the scope of the constitutional rule requiring confrontation of
witnesses. The case before us, however, does not present any situation like those mentioned
above or others analogous to them. Because the transcript of Phillips' statement offered against
petitioner at his trial had not been taken at a time and under circumstances affording petitioner
through counsel an adequate opportunity to cross-examine Phillips, its introduction in a federal
court in a criminal case against Pointer would have amounted to denial of the privilege of
confrontation guaranteed by the Sixth Amendment. Since we hold that the right of an accused to
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be confronted with the witnesses against him must be determined by the same standards whether
the right is denied in a federal or state proceeding, *408 it follows that use of the transcript to
convict petitioner denied him a constitutional right, and that his conviction must be reversed.
I agree that in the circumstances the admission of the statement in question deprived the
petitioner of a right of "confrontation" assured by the Fourteenth Amendment. I cannot subscribe,
however, to the constitutional reasoning of the Court.
The Court holds that the right of confrontation guaranteed by the Sixth Amendment in federal
criminal trials is carried into state criminal cases by the Fourteenth Amendment. This is another
step in the onward march of the long-since discredited "incorporation" doctrine (see, e. g.,
Fairman, Does the Fourteenth Amendment Incorporate the Bill of Rights? The Original
Understanding, 2 Stan. L. Rev. 5 (1949); Frankfurter, Memorandum on "Incorporation" of the Bill
of Rights Into the Due Process Clause of the Fourteenth Amendment, 78 Harv. L. Rev. 746
(1965)), which for some reason that I have not yet been able to fathom has come into the
sunlight in recent years. See, e. g., Mapp v. Ohio, 367 U.S. 643; Ker v. California, 374 U.S. 23;
Malloy v. Hogan, 378 U.S. 1.
For me this state judgment must be reversed because a right of confrontation is "implicit in the
concept of ordered liberty," Palko v. Connecticut, 302 U.S. 319, 325, reflected in the Due Process
Clause of the Fourteenth Amendment independently of the Sixth.
While either of these constitutional approaches brings one to the same end result in this particular
case, there is a basic difference between the two in the kind of future constitutional development
they portend. The concept of Fourteenth Amendment due process embodied in Palko *409 and a
host of other thoughtful past decisions now rapidly falling into discard, recognizes that our
Constitution tolerates, indeed encourages, differences between the methods used to effectuate
legitimate federal and state concerns, subject to the requirements of fundamental fairness
"implicit in the concept of ordered liberty." The philosophy of "incorporation," on the other hand,
subordinates all such state differences to the particular requirements of the Federal Bill of Rights
(but see Ker v. California, supra, at 34) and increasingly subjects state legal processes to
enveloping federal judicial authority. "Selective" incorporation or "absorption" amounts to little
more than a diluted form of the full incorporation theory. Whereas it rejects full incorporation
because of recognition that not all of the guarantees of the Bill of Rights should be deemed
"fundamental," it at the same time ignores the possibility that not all phases of any given
guaranty described in the Bill of Rights are necessarily fundamental.
It is too often forgotten in these times that the American federal system is itself constitutionally
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ordained, that it embodies values profoundly making for lasting liberties in this country, and that
its legitimate requirements demand continuing solid recognition in all phases of the work of this
Court. The "incorporation" doctrines, whether full blown or selective, are both historically and
constitutionally unsound and incompatible with the maintenance of our federal system on even
course.
I join in the judgment reversing this conviction, for the reason that the petitioner was denied the
opportunity to cross-examine, through counsel, the chief witness for the prosecution. But I do not
join in the Court's pronouncement which makes "the Sixth Amendment's right of an accused to
confront the witnesses against him . . . obligatory *410 on the States." That questionable tour de
force seems to me entirely unnecessary to the decision of this case, which I think is directly
controlled by the Fourteenth Amendment's guarantee that no State shall "deprive any person of
life, liberty, or property, without due process of law."
The right of defense counsel in a criminal case to cross-examine the prosecutor's living witnesses
is "[o]ne of the fundamental guarantees of life and liberty,"[1] and "one of the safeguards
essential to a fair trial."[2] It is, I think, as indispensable an ingredient as the "right to be tried in
a courtroom presided over by a judge."[3] Indeed, this Court has said so this very Term. Turner v.
Here that right was completely denied. Therefore, as the Court correctly points out, we need not
consider the case which could be presented if Phillips' statement had been taken at a hearing at
which the petitioner's counsel was given a full opportunity to cross-examine. See West v.
Louisiana, 194 U.S. 258.
I agree with the holding of the Court that "the Sixth Amendment's right of an accused to confront
the witnesses against him is . . . a fundamental right and is made obligatory on the States by the
Fourteenth Amendment." Ante, at 403. I therefore join in the opinion and judgment of the Court.
My Brother HARLAN, while agreeing with the result reached by the Court, deplores the Court's
*411 reasoning as "another step in the onward march of the long-since discredited `incorporation'
doctrine," ante, at 408. Since I was not on the Court when the incorporation issue was joined, see
Adamson v. California, 332 U.S. 46, I deem it appropriate to set forth briefly my view on this
subject.
I need not recapitulate the arguments for or against incorporation whether "total" or "selective."
They have been set forth adequately elsewhere.[1] My Brother BLACK'S view of incorporation has
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never commanded a majority of the Court, though in Adamson it was assented to by four Justices.
The Court in its decisions has followed a course whereby certain guarantees "have been taken
over from the earlier articles of the federal bill of rights and brought within the Fourteenth
Amendment," Palko v. Connecticut, 302 U.S. 319, 326, by a process which might aptly be
described as "a process of absorption." Ibid. See Cohen v. Hurley, 366 U.S. 117, 154 (dissenting
opinion of MR. JUSTICE BRENNAN); Brennan, The Bill of Rights and the States, 36 N. Y. U. L. Rev.
761 (1961). Thus the Court has held that the Fourteenth *412 Amendment guarantees against
infringement by the States the liberties of the First Amendment,[2] the Fourth Amendment,[3]
the Just Compensation Clause of the Fifth Amendment,[4] the Fifth Amendment's privilege against
prosecution.[7]
With all deference to my Brother HARLAN, I cannot agree that this process has "come into the
sunlight in recent years." Ante, at 408. Rather, I believe that it has its origins at least as far back
as Twining v. New Jersey, 211 U.S. 78, 99, where the Court stated that "it is possible that some of
the personal rights safeguarded by the first eight Amendments against National action may also
be safeguarded against state action, because a denial of them would be a denial of due process of
law. Chicago, Burlington & Quincy Railroad v. Chicago, 166 U.S. 226." This passage and the
authority cited make clear that what is protected by the Fourteenth Amendment are "rights,"
which apply in every case, not solely in those cases where it seems "fair" to a majority of the
Court to afford the protection. Later cases reaffirm that the process of "absorption" is one of
extending "rights." See Ker v. California, 374 U.S. 23; Malloy v. Hogan, 378 U.S. 1, and cases
cited by MR. JUSTICE BRENNAN in his dissenting opinion in Cohen v. Hurley, supra, at 156. I
agree with these decisions, as is apparent from my votes in *413 Gideon v. Wainwright, 372 U.S.
335; Malloy v. Hogan, supra, and Murphy v. Waterfront Comm'n, 378 U.S. 52, and my concurring
opinion in New York Times Co. v. Sullivan, 376 U.S. 254, 297, and I subscribe to the process by
which fundamental guarantees of the Bill of Rights are absorbed by the Fourteenth Amendment
and thereby applied to the States.
Furthermore, I do not agree with my Brother HARLAN that once a provision of the Bill of Rights
has been held applicable to the States by the Fourteenth Amendment, it does not apply to the
States in full strength. Such a view would have the Fourteenth Amendment apply to the States
"only a `watered-down, subjective version of the individual guarantees of the Bill of Rights.' "
Malloy v. Hogan, supra, at 10-11. It would allow the States greater latitude than the Federal
Government to abridge concededly fundamental liberties protected by the Constitution. While I
quite agree with Mr. Justice Brandeis that "[i]t is one of the happy incidents of the federal system
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that a . . . State may . . . serve as a laboratory; and try novel social and economic experiments,"
New State Ice Co. v. Liebmann, 285 U.S. 262, 280, 311 (dissenting opinion), I do not believe that
this includes the power to experiment with the fundamental liberties of citizens safeguarded by
the Bill of Rights. My Brother HARLAN'S view would also require this Court to make the extremely
subjective and excessively discretionary determination as to whether a practice, forbidden the
Federal Government by a fundamental constitutional guarantee, is, as viewed in the factual
circumstances surrounding each individual case, sufficiently repugnant to the notion of due
process as to be forbidden the States.
Finally, I do not see that my Brother HARLAN'S view would further any legitimate interests of
federalism. It would require this Court to intervene in the state judicial process with considerable
lack of predictability and with *414 a consequent likelihood of considerable friction. This is well
illustrated by the difficulties which were faced and were articulated by the state courts attempting
to apply this Court's now discarded rule of Betts v. Brady, 316 U.S. 455. See Green, The Bill of
Rights, the Fourteenth Amendment and the Supreme Court, 46 Mich. L. Rev. 869, 897-898. These
difficulties led the Attorneys General of 22 States to urge that this Court overrule Betts v. Brady
and apply fully the Sixth Amendment's guarantee of right to counsel to the States through the
Fourteenth Amendment. See Gideon v. Wainwright, supra, at 336. And, to deny to the States the
power to impair a fundamental constitutional right is not to increase federal power, but, rather, to
limit the power of both federal and state governments in favor of safeguarding the fundamental
rights and liberties of the individual. In my view this promotes rather than undermines the basic
policy of avoiding excess concentration of power in government, federal or state, which underlines
our concepts of federalism.
I adhere to and support the process of absorption by means of which the Court holds that certain
fundamental guarantees of the Bill of Rights are made obligatory on the States through the
Fourteenth Amendment. Although, as this case illustrates, there are differences among members
of the Court as to the theory by which the Fourteenth Amendment protects the fundamental
liberties of individual citizens, it is noteworthy that there is a large area of agreement, both here
and in other cases, that certain basic rights are fundamentalnot to be denied the individual by
either the state or federal governments under the Constitution. See, e. g., Cantwell v.
Connecticut, 310 U.S. 296; NAACP v. Alabama ex rel. Patterson, 357 U.S. 449; Gideon v.
Wainwright, supra; New York Times Co. v. Sullivan, supra; Turner v. Louisiana, 379 U.S. 466.
NOTES
[*] See state and English cases collected in 5 Wigmore, Evidence 1367, 1395 (3d ed. 1940).
State constitutional and statutory provisions similar to the Sixth Amendment are collected in 5
Wigmore, supra, 1397, n. 1.
[1] Kirby v. United States, 174 U.S. 47, 55.
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On June 23, 2015 APPELLANT, Stanley J. Caterbone, filed an Amicus Curei Brief in the U.S.
District Court Case No. 14-02559 in PETITIONER LISA MICHELLE LAMBERT'S HABEUS CORPUS,
which was originally filed on May 14, 2014. On September 2, 2015 APPELLANT filed a MOTION
FOR SUMMARY JUDGEMENT. On September 14, 2015 U.S. District Judge Paul S. Diamond
ORDERED that Mr. Caterbones Motions for Summary Judgment (Doc. Nos. 8, 9) and
Motions to File Exhibits or Statements (Doc. Nos. 10, 11, 12, 14) are DENIED as
frivolous. It is FURTHER ORDERED that Stanley J. Caterbone may no longer submit
filingswhether electronic or in paper formatin the above-captioned case. The Clerk
shall not docket any such filings without my approval.
On September 30, 2015 APPELLANT filed an APPEAL to U.S.C.A. To the Third Circuit Case
No. 15-3400. On November 24, 2015 Stanley J. Caterbone FILED a Motion for a 30 Day Extension
of Time, which was GRANTED. On December 14, 2015 Stanley J. Caterbone FILED a LETTER to
the Clerk requesting to WITHDRAW appeal no. 15-3400 in the Third Circuit due among other
things the APPELLANT'S computer was taken by the GEEK SQUAD, whom refused to return it. On
December 17, 2015 APPELLANT FILED a LETTER to the Clerk CLARIFYING the Withdraw as a
MOTION to WITHDRAW WITHOUT PREJUDICE. On December 31, 2015 Stanley J. Caterbone
FILED a LETTER to the COURT RESCINDING his MOTION TO WITHDRAW.1
On January 12, 2016 FISHER, JORDAN and VANASKIE, Circuit Judges, ISSUED AN ORDER
in Case No. 15-3400 MOTION TO WITHDRAW GRANTED.2 On January 12, 2016 FISHER, JORDAN
and VANASKIE, Circuit Judges, ISSUED AN ORDER in Case No. 15-3400 MOTION TO WITHDRAW
GRANTED.3 On January 13, 2016 Stanley J. Caterbone FILED a MOTION TO REINSTATE the Appeal
in the Third Circuit. On January 15, 2016 (FISHER, JORDAN and VANASKIE, Circuit Judges
ISSUED AN ORDER DENIED MOTION TO REINSTATE the Appeal in the Third Circuit. On January
17, 2015 in the United States District Court for the Eastern District of Pennsylvania in Case No.
14-02559 APPELLANT FILED a NOTICE OF APPEAL and U.S District Court, 14-02559, January 17,
2015 in the United States District Court for the Eastern District of Pennsylvania in Case No. 14-
02559 Clerk's Notice to USCA re 25 Notice of Appeal : (jpd, ) (Entered: 01/20/2016). On January
1
The Letter to Rescind was either hidden from FISHER, JORDAN and VANASKIE or FISHER, JORDAN and VANASKIE
ignored the Letter to Rescind. This would have preserved the entire Record of Case No. 15-3400 including EXHIBITS,
MOTIONS, ETC.,.
2
This DELETED AND REMOVED FROM THE PUBLIC DOMAIN and from DELIBERATIONS the entire the Record of Case No.
15-3400 including EXHIBITS, MOTIONS, ETC., which SUPPORTS AND PROVIDES EVIDENCE FOR AFFIRMATION OF THE
MOTION FOR SUMMARY JUDGEMENT in Case No. 14-02559 and a FAVORABLE Ruling in the U.S. Third Circuit Court of
Appeals for the Complainant, and Pro Se Appellant.
3
This DELETED AND REMOVED FROM THE PUBLIC DOMAIN and from DELIBERATIONS the entire the Record of Case No.
15-3400 including EXHIBITS, MOTIONS, ETC., which SUPPORTS AND PROVIDES EVIDENCE FOR AFFIRMATION OF THE
MOTION FOR SUMMARY JUDGEMENT in Case No. 14-02559 and a FAVORABLE Ruling in the U.S. Third Circuit Court of
Appeals for the Complainant, and Pro Se Appellant.
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22, 2016 in the U.S. THIRD CIRCUIT Clerk Issues New Docket No. 16-1149.
On February 16, 2016 the Clerk ORDERED the APPEAL dismissed due to F.R.A.P. (3) a and
FRAP 3.3 and Misc 107.1(a) for failure to pay the filing fee for the Notice of Appeal. On March 15,
2016 APPELLANT filed a Motion for Reconsideration and finally on July 28, 2016 Judges Chargaras,
Jordan, and Venaskie ORDERED The foregoing motion for reconsideration of the Clerk's
Order is construed as a motion to review that order and is denied as meritless. The
Clerk has the authority under 3d Cir. LAR 3.3 and Misc. 107.1(a) to dismiss an appeal
for failure to satisfy the fee requirement.
It is clear that the omission for considerations the Letter of December 31, 2015 instructing
the COURTS to rescind the Motion to Withdraw was a clear violation of APPELLANT'S right to due
process and right to appeal that set in motion filings and decisions which should be considered as
MOOT to the original APPEAL. The APPELLANT wishes the COURT to reverse this obstruction of
justice.
U.S.C.A.
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FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
It is clear that the omission for considerations of the Letter of December 31, 2015
instructing the COURTS to rescind the Motion to Withdraw was a clear violation of APPELLANT'S
right to due process and right to appeal that set in motion filings and decisions which should be
considered as MOOT to the original APPEAL. The APPELLANT wishes the COURT to reverse this
obstruction of justice.
That being said there is a broader issue that is woven through the history of this
unprecedented case starting; with the original HABEUS CORPUS written and filed by PETITIONER
Lisa Michelle Lambert in 1997, the findings of U.S. District Judge Stewert Dalzall's that this case
contained one of the worst cases of prosecutorial misconduct in the English speaking language
and releasing Lisa Michelle Lambert from prison; and ultimately the contamination of
wrongdoings in this case. This again is another case of JUDICIAL MISCONDUCT and
PROSECUTORIAL MISCONDUCT at the WORST or a case of ERRORS and OMMISSIONS at best
regarding the adjudication of the APPELLANT'S original Amicus Curie Brief and Motion for
Summary Judgment in PETITIONER'S Lisa Michelle Lambert's Habeus Corpus of May of 2014.
This case was of national importance and received national attention immediately following
the findings of U.S. District Judge Stewert Dalzall and the release of Lisa Michelle Lambert from
prison in 1997. A&E TV did a documentary, which aired on national television titled American
Justice: A Teenage Murder Mystery and also sells the DVD online today. See Appendix H. The LA
Times published a 3-part series beginning on November 10, 1997 by Journalist Barry Seigel. See
Appendix I.
It is in the public's best interest to restore integrity to the COURTS and to the Prosecutors
and Judges and the COURTS that are honest and fair; and provide the means to which Lisa
Michelle Lambert's meritorious plight for RELIEF and RELEASE from Prison can then be
accomplished, as it should.
U.S.C.A.
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by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
To President
US Supreme Court
Obama
Case
re Lisa
No. Lambert
16-6822 Page
Page43
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by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
To President
US Supreme Court
Obama
Case
re Lisa
No. Lambert
16-6822 Page
Page44
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by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
PROOF OF SERVICE
Mr. XXXXXXXXX
Doug Behmer,Bruce Beemer
Pennsylvania State Attorney General
16th Floor Strawberry Square
Harrisburg, PA 17120
Ibrahim, Jeremy
Ibrahim Jeremy Attorney
1700 Race St
Philadelphia, PA 19103
Phone: (215) 568-1943
U.S.C.A.
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DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
October 2015
OFFICE OF THE CLERK
WASHINGTON, D. C. 20543
CERTIORARI
I. Introduction
These instructions and forms are designed to assist petitioners who are proceeding in
forma pauperis and without the assistance of counsel. A copy of the Rules of the
Supreme Court, which establish the procedures that must be followed, is also enclosed.
Be sure to read the following Rules carefully:
It is important to note that review in this Court by means of a writ of certiorari is not
a matter of right, but of judicial discretion. The primary concern of the Supreme
Court is not to correct errors in lower court decisions, but to decide cases presenting
issues of importance beyond the particular facts and parties involved. The Court
grants and hears argument in only about 1% of the cases that are led each Term.
The vast majority of petitions are simply denied by the Court without comment or
explanation. The denial of a petition for a writ of certiorari signies only that the
Court has chosen not to accept the case for review and does not express the Courts
view of the merits of the case.
Every petitioner for a writ of certiorari is advised to read carefully the Considerations
Governing Review on Certiorari set forth in Rule 10. Important considerations for
accepting a case for review include the existence of a conict between the decision of
which review is sought and a decision of another appellate court on the same issue.
An important function of the Supreme Court is to resolve disagreements among lower
courts about specic legal questions. Another consideration is the importance to the
public of the issue.
You must le your petition for a writ of certiorari within 90 days from the date of the
entry of the nal judgment in the United States court of appeals or highest state
appellate court or 90 days from the denial of a timely led petition for rehearing. The
issuance of a mandate or remittitur after judgment has been entered has no bearing
on the computation of time and does not extend the time for ling. See Rules 13.1 and
U.S.C.A.
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DRAFT
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LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
13.3. Filing in the Supreme Court means the actual receipt of documents by the Clerk;
or their deposit in the United States mail, with rst-class postage prepaid, on or before
the nal date allowed for ling; or their delivery to a third-party commercial carrier,
on or before the nal date allowed for ling, for delivery to the Clerk within 3 calendar
days. See Rule 29.2.
Unless you are an inmate conned in an institution and not represented by counsel,
le:
An original and ten copies of a motion for leave to proceed in forma pauperis and
an original and 10 copies of an afdavit or declaration in support thereof. See Rule 39.
One afdavit or declaration showing that all opposing parties or their counsel have
been served with a copy of the papers led in this Court. See Rule 29.
If you are an inmate conned in an institution and not represented by counsel, you need
le only the original of the motion for leave to proceed in forma pauperis, afdavit or
declaration when needed in support of the motion for leave to proceed in forma pau
peris, the petition for a writ of certiorari, and proof of service.
If the court below appointed counsel in the current proceeding, no afdavit or declara
tion is required, but the motion should cite the provision of law under which counsel
was appointed, or a copy of the order of appointment should be appended to the motion.
See Rule 39.1.
The attached forms may be used for the original motion, afdavit or declaration, and
petition, and should be stapled together in that order. The proof of service should be
included as a detached sheet, and the form provided may be used.
V. Page Limitation
The petition for a writ of certiorari may not exceed 40 pages excluding the pages that
precede Page 1 of the form. The documents required to be contained in the appendix
to the petition do not count toward the page limit. See Rule 33.2(b).
All documents to be led in this Court must be addressed to the Clerk, Supreme Court
of the United States, Washington, D. C. 20543 and must be served on opposing parties
or their counsel in accordance with Rule 29.
U.S.C.A.
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DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
On the form provided, answer fully each of the questions. If the answer to a question
is 0, none, or not applicable (N/A), enter that response. If you need more space
to answer a question or to explain your answer, attach a separate sheet of paper,
identied with your name and the question number. Unless each question is fully
answered, the Clerk will not accept the petition. The form must either be notarized
or be in the form of a declaration. See 28 U. S. C. 1746.
U.S.C.A.
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COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
D. Enter your name, address, and telephone number in the appropriate spaces.
V. List of Parties
On the page provided, check either the box indicating that the names of all parties
appear in the caption of the case on the cover page or the box indicating that there are
additional parties. If there are additional parties, list them. Rule 12.6 states that all
parties to the proceeding whose judgment is sought to be reviewed shall be deemed
parties in this Court, and that all parties other than petitioner shall be respondents.
The court whose judgment you seek to have this Court review is not a party.
A. Federal Courts
If you are asking the Court to review a decision of a federal court, the decision
of the United States court of appeals should be designated Appendix A.
Appendix A should be followed by the decision of the United States District
Court and the ndings and recommendations of the United States magistrate
judge, if there were any. If the United States court of appeals denied a timely
led petition for rehearing, a copy of that order should be appended next. If
you are seeking review of a decision in a habeas corpus case, and the decision of
either the United States District Court or the United States Court of Appeals
makes reference to a state court decision in which you were a party, a copy of
the state court decision must be included in the appendix.
B. State Courts
If you are asking the Court to review a decision of a state court, the decision of
which review is sought should be designated Appendix A. Appendix A should
be followed by the decision of the lower court or agency that was reviewed in
the decision designated Appendix A. If the highest court of the state in which a
U.S.C.A.
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decision could be had denied discretionary review, a copy of that order should
follow. If an order denying a timely led petition for rehearing starts the run
ning of the time for ling a petition for a writ of certiorari pursuant to Rule 13.3,
a copy of the order should be appended next.
As an example, if the state trial court ruled against you, the intermediate court
of appeals afrmed the decision of the trial court, the state supreme court denied
discretionary review and then denied a timely petition for rehearing, the appen
dices should appear in the following order:
On the page provided, list the cases, statutes, treatises, and articles that you reference
in your petition, and the page number of your petition where each authority appears.
In the space provided, indicate whether the opinions of the lower courts in your case
have been published, and if so, the citation for the opinion below. For example, opin
ions of the United States courts of appeals are published in the Federal Reporter. If
the opinion in your case appears at page 100 of volume 30 of the Federal Reporter,
Third Series, indicate that the opinion is reported at 30 F. 3d 100. If the opinion has
been designated for publication but has not yet been published, check the appropriate
space. Also indicate where in the appendix each decision, reported or unreported,
appears.
X. Jurisdiction
The purpose of the jurisdiction section of the petition is to establish the statutory
source for the Courts jurisdiction and the dates that determine whether the petition
is timely led. The form sets out the pertinent statutes for federal and state cases.
You need provide only the dates of the lower court decisions that establish the timeli
ness of the petition for a writ of certiorari. If an extension of time within which to
le the petition for a writ of certiorari was granted, you must provide the requested
information pertaining to the extension. If you seek to have the Court review a deci
sion of a state court, you must provide the date the highest state court decided your
case, either by ruling on the merits or denying discretionary review.
U.S.C.A.
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LAMBERT
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by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Set out verbatim the constitutional provisions, treaties, statutes, ordinances and regu
lations involved in the case. If the provisions involved are lengthy, provide their cita
tion and indicate where in the Appendix to the petition the text of the provisions
appears.
Provide a concise statement of the case containing the facts material to the consider
ation of the question(s) presented; you should summarize the relevant facts of the case
and the proceedings that took place in the lower courts. You may need to attach
additional pages, but the statement should be concise and limited to the relevant facts
of the case.
The purpose of this section of the petition is to explain to the Court why it should
grant certiorari. It is important to read Rule 10 and address what compelling reasons
exist for the exercise of the Courts discretionary jurisdiction. Try to show not only
why the decision of the lower court may be erroneous, but the national importance of
having the Supreme Court decide the question involved. It is important to show
whether the decision of the court that decided your case is in conict with the decisions
of another appellate court; the importance of the case not only to you but to others
similarly situated; and the ways the decision of the lower court in your case was errone
ous. You will need to attach additional pages, but the reasons should be as concise as
possible, consistent with the purpose of this section of the petition.
XIV. Conclusion
Enter your name and the date that you submit the petition.
You must serve a copy of your petition on counsel for respondent(s) as required by
Rule 29. If you serve the petition by rst-class mail or by third-party commercial
carrier, you may use the enclosed proof of service form. If the United States or any
department, ofce, agency, ofcer, or employee thereof is a party, you must serve the
Solicitor General of the United States, Room 5614, Department of Justice, 950 Pennsyl
vania Ave., N.W., Washington, D. C. 205300001. The lower courts that ruled on your
case are not parties and need not be served with a copy of the petition. The proof of
service may be in the form of a declaration pursuant to 28 U. S. C. 1746.
U.S.C.A.
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by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
APPENDIX A
U.S.C.A.
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COPY
U.S.C.A.
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U.S.C.A.
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by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
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U.S.C.A.
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APPENDIX B
U.S.C.A.
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InstitutionFiled:
J. Caterbone
OF 12/31/2015
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Stan J. Caterbone
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
scaterbone@live.com
717-669-2163
IMPORTANT Accordingly, I wish to rescind my MOTION TO DISMISS and would ask that if
you require a Motion to contact me as soon as possible.
/S/
Stan J. Caterbone, Pro Se APPELLANT
ADVANCED MEDIA GROUP
1250 Fremont Street
Lancaster, PA 17603
www.amgglobalentetainmentgroup.com
scaterbone@live.com
717-669-2163
U.S.C.A.
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ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
APPENDIX C
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page59
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WednesdayNovember
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January12,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1072
70
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page60
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January
October12,
10,
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9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1073
71
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page61
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January
October12,
10,
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9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1074
72
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page62
34of
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January
October12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1075
73
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
APPENDIX D
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page63
47of
50 of108
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WednesdayNovember
October
January12,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1076
74
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page64
35of
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November
October
January
October12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1077
75
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page65
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10,
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9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1078
76
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page66
37of
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January
October12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1079
77
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page67
38of
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October12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1080
78
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page68
39of
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55 of108
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November
October
January
October12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1081
79
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page69
40of
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January
October12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1082
80
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page70
41of
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November
October
January
October12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1083
81
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
APPENDIX E
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page71
55of
58 of108
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WednesdayNovember
October
January12,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1084
82
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page72
42of
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October
January
October12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1085
83
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page73
43of
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January
October12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1086
84
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page74
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October
January
October12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1087
85
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page75
45of
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62 of108
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November
October
January
October12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1088
86
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
APPENDIX F
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page76
60of
63 of108
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January12,
15,
9, 2017
2016
January
Sunday
StanJanuary
22, Case
J. Caterbone
201722, v. 5:14-cv-02559-PD
2017 Allison
REQUEST Document
Hallet, Superintendent
FOR COMMUTATION
Page
Page1089
87
MASS 15
ofof1299Filed
2301 THE 09/14/15
Correction
OF SENTENCE
Stan Page
Institution 1 of
J. Caterbone
OF
re LISA 3
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
ORDER
I previously dismissed Petitioners pro se motion for habeas relief so that she could file a
counseled motion. (Doc. No. 3.) She has not yet done so. On June 23, 2015, Stanley
Caterbonewho has nothing to do with Petitioner, her motion, or this casefiled a pro se
amicus brief in support of the dismissed motion. (Doc. No. 4.) Caterbone neither sought leave
to file, nor indicated that he had received the Parties consent to file an amicus brief. Fed. R.
Civ. P. 29(a).
dismissed motionessentially focuses on the damages Caterbone allegedly suffered from his
organized stalking by more than 100 people. (Doc. No. 4 at 7, 9). He also includes a lengthy
discussion of the perplexing question of Stan Caterbones intelligence, or lack thereof, and his
work on a digital movie that is directly responsible for the development of the internet.
(Id. at 16-26). In addition, he details thirty governmental attempts at mind control, including:
thoughts via remote sensing technologies; and 3) Making me mentally hear others voices
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page77
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15,
9, 2017
2016
January
Sunday
StanJanuary
22, Case
J. Caterbone
201722, v. 5:14-cv-02559-PD
2017 Allison
REQUEST Document
Hallet, Superintendent
FOR COMMUTATION
Page
Page1090
88
MASS 15
ofof1299Filed
2301 THE 09/14/15
Correction
OF SENTENCE
Stan Page
Institution 2 of
J. Caterbone
OF
re LISA 3
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Caterbones involvement in the matter did not end with his amicus brief. On July 6,
2015, he filed with this Court an email that he had sent to the Lancaster Police, asserting that he
has synthetic telepathy. (Doc. No. 5.) On September 2 and 3, 2015, Caterbone moved for
summary judgment. (Doc. Nos. 8, 9.) On September 3, 2015, he moved to file a copy of his
motion for reconsideration of the denial of his petition to proceed in forma pauperis in
Pennsylvania state court, (which had been dismissed as frivolous). (Doc. No. 10.) On
September 9, 2015, he also moved to file: 1) an email exchange with the subject Muslims Using
exhibit of billing statements of his estimated fees for his 2007 work on wholly unrelated federal
and state court cases. (Doc. Nos. 11, 12, 14.) On September 9, 2015, Caterbone called my
Chambers, demanding to speak with me, and then abruptly hung up.
I have already denied Caterbones request to file documents electronically. (Doc. No. 9.)
He has nonetheless continued to submit filings that have nothing to do with this case.
Page 2 of 3
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page78
55of
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January12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22, Case
J. Caterbone
201722, v. 5:14-cv-02559-PD
2017 Allison
REQUEST Document
Hallet, Superintendent
FOR COMMUTATION
Page
Page1091
89
MASS 15
ofof1299Filed
2301 THE 09/14/15
Correction
OF SENTENCE
Stan Page
Institution 3 of
J. Caterbone
OF
re LISA 3
LAMBERT
MICHELLE
DRAFT
CASE
LAMBERT
COPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
AND NOW, this 11th day of September, 2015, it is hereby ORDERED that Mr.
Caterbones Motions for Summary Judgment (Doc. Nos. 8, 9) and Motions to File Exhibits or
Statements (Doc. Nos. 10, 11, 12, 14) are DENIED as frivolous. It is FURTHER ORDERED
that Stanley J. Caterbone may no longer submit filingswhether electronic or in paper format
in the above-captioned case. The Clerk shall not docket any such filings without my approval.
AND IT IS SO ORDERED.
_________________________
September 11, 2015 Paul S. Diamond, J.
Page 3 of 3
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page79
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Tuesday
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January12,
10,
15,
9, 2017
2016
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1092
90
MASS
ofof1299
2301
Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
APPENDIX G
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page80
64of
67 of108
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WednesdayNovember
October
January12,
15,
9, 2017
2016
Sunday
January 22, 201722,Case
StanJanuary
J. Caterbone2017 5:14-cv-02559-PD
v. Allison
REQUEST Document
Hallet, Superintendent MASS
FOR COMMUTATION
Page
Page1093
91 92301
Filed
ofof1299
OF THE09/03/15
Correction
SENTENCE
Stan Page
Institution 1 ofLAMBERT
re LISA
J. Caterbone
OF 6
MICHELLE LAMBERT
DRAFT
CASECOPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Petitioner
v.
LYNN BISSONETTE, SUPERINTENDENT, Civ. No. 5:14-cv-02559-PD
MCI-FRAMINGHAM,
and
CRAIG STEDMAN, THE DISTRICT ATfOR-
NEY OF LANCASTER
COUNTY, PENNSYLVANIA
F uu~t:
S 17=n
lY
and SEP - 3 2D15
KATHLEEN KANE, THE ATfORNEY GEN-
ERAL OF PENNSYLVANIA, MICHAELE. KUNZ, Clerk
Respondents By Dep. Clerk
AND NOW comes before the said court Stanley J. Caterbone, appearing Pro Se, and Advanced
Media Group, as Movant, to file the following Motion for Summary Judgement according to rule 56
which reads:
(b) TIME TO FILE A MOTION. Unless a different time is set by local rule or the court orders otherwise,
a party may file a motion for summary judgment at any time until 30 days after the close of all discov-
ery, II
1
U.S.C.A.
To
US President
16-1149
Supreme Obama
ToCase
Court US
re Lisa
Supreme
No. Lambert
Court
16-6822 Page81
Page 57of
65
68 of108
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Tuesday
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October
January12,
10,
15, 2016
9, 2017
Sunday
January 22, 201722,Case
StanJanuary
J. Caterbone2017 5:14-cv-02559-PD
v. Allison
REQUEST Document
Hallet, Superintendent MASS
FOR COMMUTATION
Page
Page1094
92 92301
Filed
ofof1299
OF THE09/03/15
Correction
SENTENCE
Stan Page
Institution 2 ofLAMBERT
re LISA
J. Caterbone
OF 6
MICHELLE LAMBERT
DRAFT
CASECOPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Given the preponderance of evidence associated with the MOVANT'S AMICUS and STATEMENTS,
the courts must conclude that In The United States District Court For The Eastern District of Pennsylva-
nia, Federal Judge Stuart Dalzall's findings of April 14, 1997, in the Lisa Lambert case identifying acts
of prosecutorial Misconduct, now, by virtue of the MOVANT'S AMICUS and STATEMENTS, now discloses
evidence of a bona fide pattern of prosecutorial misconduct, in the Commonwealth of Pennsylvania and
in the County of Lancaster.
Criminal law may determine if these disclosures would warrant investigations of a possible crim-
inal enterprise. The MOVANT'S AMICUS and STATEMENTS is of material interest to the Habeus Corpus
filed by Lisa Michelle Lambert in May of 2014, for the very fact that this MOVANT'S AMICUS and
STATEMENTS 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 MOVANT'S AMICUS and STATEMENTS, The Commonwealth must concede
and immediately release Lisa Michelle Lambert from incarceration in order to balance the scales of jus-
tice, which no other act could accomplish. The Commonwealth must yield the criminal culpability of
Lisa Michelle Lambert to the superior matter of restoring the integrity to the courts; by it's own admis-
sion of wrongdoing, assuring the peoples of it's commitment to administer equalities of justice, not in-
equalities of justice, balancing the scales of justice. Anything less, would take the full scope of jurisdic-
tion out of the boundaries of our laws, negating our democracy and impugning the Constitution of the
United States.
2
U.S.C.A.
To
US President
16-1149
Supreme Obama
ToCase
Court US
re Lisa
Supreme
No. Lambert
Court
16-6822 Page82
Page 58of
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October
January12,
10,
15, 2016
9, 2017
Sunday
January 22, 201722,Case
StanJanuary
J. Caterbone2017 5:14-cv-02559-PD
v. Allison
REQUEST Document
Hallet, Superintendent MASS
FOR COMMUTATION
Page
Page1095
93 92301
Filed
ofof1299
OF THE09/03/15
Correction
SENTENCE
Stan Page
Institution 3 ofLAMBERT
re LISA
J. Caterbone
OF 6
MICHELLE LAMBERT
DRAFT
CASECOPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
"I, Stanley J. Caterbone being duly sworn according to law, make the following affidavit con-
cerning 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 de-
tail 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 digi-
tal mediums. A "Findings of Facts" is attached herewith providing merits and the facts pertaining to
this affidavit. These issues and incidents identified herein have attempted to conceal my disclosures of
International Signal & Control, Pie. 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 considera-
tions would exceed $1 million. 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, Pie., 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 & Con-
trol., Pie.. I will also prove intentional undo influence against family and friends towards compromising
the credibility of myself, with malicious and self serving 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."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 tech-
nologies 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, Pie., as
early as June of 1987 ;demonstrated actions were proven to protect the National Security of the United
States .. The activities of International Signal & Control, Pl~., placed American troops in harms way. The
plaintiff's actions should have taken the American troops out of harms way causing the activities of the
International Signal & Control, Pie., 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 to-
wards the Plaintiff's 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 Common-
wealth of Pennsylvania, and the County of Lancaster administer justice, United States troops may have
3
U.S.C.A.
To
US President
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Supreme Obama
ToCase
Court US
re Lisa
Supreme
No. Lambert
Court
16-6822 Page83
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9, 2017
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'
22, 201722,Case
StanJanuary
J. Caterbone2017 5:14-cv-02559-PD
v. Allison
REQUEST Document
Hallet, Superintendent MASS
FOR COMMUTATION
Page
Page1096
94 92301
Filed
ofof1299
OF THE09/03/15
Correction
SENTENCE
Stan Page
Institution 4 ofLAMBERT
re LISA
J. Caterbone
OF 6
MICHELLE LAMBERT
DRAFT
CASECOPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
been taken out of harms way, as a direct result of ceasing the operations of International Signal &
Control, Pie., in as early as 1987.
2. The plaintiff will successfully prove that the following activities and the prosecutorial miscon-
duct were directed at intimidating the plaintiff from continuing his public disclosures regarding illegal
activities within International Signal & Control, Pie,. On June 23, 1998, International Signal & Control,
Pie was negotiating for the $1.14 billion merger with Ferranti International, of England. Such disclo-
sures threatened the integrity of International Signal & Control's organization, and Mr. James Guerin
himself, consequently resulting in adverse financial considerations to all parties if such disclosures pro-
vided 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.
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
plaintiff's failed business dealings will demonstrate and substantiate financial incentive and motive. De-
fendants responsible for administering undo influence and interference in the plaintiff's business and
commercial enterprises had financial interests. The Commonwealth of Pennsylvania as a taxing author-
ity, Lancaster County had a great investment who's demise would facilitate grave consequences to it's
economic development.. Commonwealth National Bank (Mellon) would have less competition in the
mortgage banking business and other financial services, violating the lender liability laws. The Stein-
man Enterprise's, 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 plaintiff's continued and obstructed right to due process of the law, beginning in June of
I
1987 and continuing to the present, the plaintiff must be given fair access to the law with the opportu-
nity 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 limita-
tions. Given the plaintiff's genuine efforts for due process has been inherently and maliciously ob-
structed, the courts must provide the opportunity for any and all remedial actions deserving to the
plaintiff.
5. Under current laws, the plaintiff's intellectual capacity has been exploited as means of dis-
crediting the plaintiff's disclosures and obstructing the plaintiff's 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 plaintiff's 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
4
U.S.C.A.
To
US President
16-1149
Supreme Obama
ToCase
Court US
re Lisa
Supreme
No. Lambert
Court
16-6822 Page84
Page 60of
68
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Sunday
January 22, 201722,Case
StanJanuary
J. Caterbone2017 5:14-cv-02559-PD
v. Allison
REQUEST Document
Hallet, Superintendent MASS
FOR COMMUTATION
Page
Page1097
95 92301
Filed
ofof1299
OF THE09/03/15
Correction
SENTENCE
Stan Page
Institution 5 ofLAMBERT
re LISA
J. Caterbone
OF 6
MICHELLE LAMBERT
DRAFT
CASECOPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Syndrome. 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 plaintiff's alleged intellectual capacity. The plaintiff successfully argue that his "mental capacity" is
of very little legal consequence, if any; other than in it's malicious representations used to diminish the
credibility of the plaintiff.
6. The plaintiff will demonstrate that the following incidents of illegal prosecutions were pur-
posefully directed at intimidating the plaintiff from further public disclosure into the activities of Inter-
national Signal & Control, Pie., consequently obstructing the plaintiff's access to due process of the law.
Due to the fact that these activities to which the plaintiff's perpetrators were protecting were illegal ac-
tivities, 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
Dalzall's findings of April 14, 1997, in the Lisa Lambert case identifying acts of prosecutorial Miscon-
duct, 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 peo-
ples 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. Commonwealth
must yield the criminal culpability of Lisa Michelle Lambert to the superior matter of restoring the in-
tegrity to the courts; by it's own admission of wrongdoing, assuring the peoples of it's 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 democ-
racy and impugning the Constitution of the United States. The plaintiff must be restored to whole."
5
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Supreme Obama
ToCase
Court US
re Lisa
Supreme
No. Lambert
Court
16-6822 Page85
Page 61of
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9, 2017
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Sunday
January
22, 201722,Case
StanJanuary
J. Caterbone2017 5:14-cv-02559-PD
v. Allison
REQUEST Document
Hallet, Superintendent MASS
FOR COMMUTATION
Page
Page1098
96 92301
Filed
ofof1299
OF THE09/03/15
Correction
SENTENCE
Stan Page
Institution 6 ofLAMBERT
re LISA
J. Caterbone
OF 6
MICHELLE LAMBERT
DRAFT
CASECOPY
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
scaterbone@live.com
6
U.S.C.A.
To
US President
16-1149
Supreme Obama
ToCase
Court US
re Lisa
Supreme
No. Lambert
Court
16-6822 Page86
Page 62of
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22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1099
97
MASS
ofof1299
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Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
APPENDIX H
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page87
71of
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A Teenage Murder Mystery DVD http://store.aetv.com/html/product/index.jhtml?id=75922
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1100
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OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
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It is one of the more extraordinary cases ever tried in Pennsylvania, not because of the crime,
which was certainly heinous, but for what has come afterwards. One woman has been convicted
--> twice, by the same judge, of the same crime, and has gone to jail twice.
AMERICAN JUSTICE recounts every step of the strange journey of Lisa Michelle Lambert in this
gripping program. Hear from Hazel Snow, the victim's mother, who says her daughter whispered
"Michelle did it" as she lay dying in her arms with a slit throat and a rope around her neck.
Examine the conflicting testimony that Lisa and her two codefendants have given. And unravel the
bizarre web of legal decisions that have made this case into one of the most complicated in the
history of Pennsylvania.
Featuring interviews with the prosecutors who tried the case, the Attorney General of
Pennsylvania, friends of the victim and Lisa herself, this is a fascinating look at a case that may
yet have surprises in store.
This DVD is one of the many titles in our DVD Library and is created in the DVD+R format.
This disc does not feature menu pages or special features like standard DVDs, simply the high
quality programming you've come to expect from us. Click here for more details.
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page88
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ADVANCED MEDIA GROUP Page 1 of 4 05.28.2007
1 of 2 5/28/2007 3:35 PM
January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1101
99
MASS
ofof1299
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Correction
OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
APPENDIX I
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page89
73of
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J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1102
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of1299
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OF THE SENTENCE
Stan
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J. Caterbone
OF
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Commonwealth of Pennsylvania v. Lisa Michelle Lambert
A Bitter Lesson for Lancaster County; Judge says Pennsylvania community 'lost
its soul' in push to convict woman of murder.
Right or wrong, his ruling challenges U.S. court system's balance of power.
[Home Edition]
BARRY SIEGEL.
By midmorning on the first day of Lisa Michelle Lambert's federal habeas corpus hearing, U.S. District
Judge Stewart Dalzell already could be seen displaying alarm over what he was hearing. From the lawyers'
briefs alone, he'd read enough to persuade him to grant Lisa's request for this uncommon federal review
of a state murder conviction. He'd read enough to suspect that just possibly, Lisa Lambert, although
sentenced to life without parole, hadn't killed Laurie Show over a teenage romantic rivalry. He'd read
enough to surmise that just maybe, Lisa's boyfriend,
Lawrence "Butch" Yunkin, along with a girl named Tabitha Buck, had killed Laurie. Now, he was listening
to evidence that served only to deepen his concerns regarding Lancaster County's prosecution of Lisa. It
was March 31. Computers, boxes of documents and piles of papers filled the small hearing room on the
fifth floor of the federal courthouse in downtown Philadelphia. Lisa's parents sat in the first row, Laurie
Show's behind them. Reporters and court personnel occupied the jury box. On the stand, an expert
witness for Lisa's side, Northwestern University speech professor Charles Larson, was testifying.
Contrary to the autopsy report, Larson believed--as did three emergency medical technicians and the
Philadelphia medical examiner--that Laurie Show's left carotid artery had been severed by whoever
slashed her throat. This, he explained, left her unable to say "Michelle did it," as Laurie's mother, Hazel,
had claimed. Her vocal tract was "destroyed," her left brain hemisphere "dying." She was "totally
incapable of speech."
How, asked Lisa's attorney, Christina Rainville, could two doctors have signed an autopsy report saying
that the carotid arteries weren't "involved"?
Those two doctors were both Lancaster County physicians, one the part-time coroner, the other an ear-
nose-and-throat specialist. "I don't think they were telling the truth," Larson replied. Dalzell peered over
gold wire-rimmed bifocals at the witness.
That this hearing was even being held appalled most in Lancaster County, about 75 miles west of
Philadelphia. In the 1991 killing of Laurie Show, Lisa had already been found guilty of first-degree murder,
Tabitha Buck of second-degree, Butch Yunkin of third-degree.
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page90
74of
77 of108
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Advanced Media Group Page 1 of 15 10/20/2007
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Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1103
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of
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OF THE SENTENCE
Stan
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OF
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Now here was Lisa, claiming her innocence, claiming all sorts of prosecutorial abuse. Now here was Lisa,
seeking a federal order freeing her because the state had illegally imprisoned her.
For Lisa to cast herself as an innocent victim was maddening enough. For a federal judge to take her
seriously was unimaginable. Yet that was just what was happening in this Philadelphia courtroom.
The second day of the hearing found Dalzell puzzling over two quite different versions of a videotaped
police search of the Susquehanna River. The one initially provided by the Lancaster County district
attorney, eight minutes long, had no soundtrack, and no images of police finding a pink bag Lisa said
she'd thrown there. The second, obtained through discovery only after Rainville realized she'd been sent
an edited tape, was four minutes longer. It had sound. It also had an officer kicking at a pink bag while
another asked, "What do you got, a bag?"
After watching these tapes, Dalzell removed his glasses and rubbed his eyes, something he'd do more
than once during the three-week hearing. He studied Lisa, also something he'd do more than once,
especially in the hearing's early days. Lisa, sobbing off and on, was staring down at the table where she
sat, bent over, her hands between her legs. Dalzell looked as if he were trying to fathom her character.
The third day found Dalzell puzzling over Lisa's initial statement to the police. He listened to East
Lampeter Police Det. Raymond Solt try to reconcile the typewritten first page, where Lisa says she wore
her own clothes at the murder scene, and a handwritten last page where Lisa says she wore Butch's
sweatpants. He listened to Solt explain how he destroyed all his notes from the interview. By the time Solt
stepped down, the judge was referring openly to "Ms. Lambert's alleged statement."
With Det. Ronald Barley on the stand later that afternoon, Dalzell grew even more openly dissatisfied.
Barley was a well-regarded detective in Lancaster County. A "very thorough investigator" is how Ted
Darcus, chairman of Lancaster's City Council, considered him. Barley "dealt well with people in our
community accused of crimes." Yet this wasn't apparent to Dalzell.
Barley, being questioned about the taped interview he helped conduct with Butch Yunkin--a tape full of
laughter, clicks and obvious gaps--kept waffling so much that Dalzell finally snapped: "Answer her
question! Yes or no?" Rather than heed the suggestion, Barley grew even more evasive. Asked about a
critical spot where the recorder clicked off, he denied even being in the interview room at that moment.
He called a recess and ordered all the lawyers into his chambers. "I want to know what is going on here,"
he told Lancaster County Dist. Atty. Joseph Madenspacher. "I'm hearing perjured testimony. . . . As we
had with Det. Solt, {Barley} is contradicting his own statement. . . . My patience has just run out. . . . I'm
afraid the commonwealth is allowing perjured testimony in federal court. . . . I'm being lied to. . . . This
man gives me the unbelievably fantastic statement that suddenly he 'evaporated.' It's totally incredible,
and I'm afraid I'm going to have to refer this, if this keeps up, to the United States attorney. . . ."
Madenspacher shifted uneasily. This hadn't been his case to try. He'd left the prosecution to his seasoned
first assistant, John Kenneff. "I understand what the court is saying . . .," he replied. "I don't know what
I'm going to do, but I'm going to do something."
Little changed, though, when Barley resumed the stand. He didn't recall his colleague, Det. Ronald "Slick"
Savage, turning the tape recorder on and off. He destroyed his notes after taking Butch's statement.
"No, no . . . please answer her questions. Will you do that?" Dalzell interrupted at one point.
"You knew . . . because you took the statement?" the judge asked later. "Or did you disappear for that
part? . . . Oh, do you have that ability to appear and disappear at will?"
By the time Barley tried to explain how he "completely forgot" they'd found a pink bag during the river
search--a pink bag that Lisa told them contained Butch Yunkin's bloodied sneakers--Dalzell was beside
himself. It helped his mood little when, with Barley still on the stand, Rainville moments later played the
segment of unedited videotape that showed an officer kicking the pink bag, then waving the camera off.
U.S.C.A.
To
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Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
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No. Lambert
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Court Page
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22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
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J. Caterbone
OF
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
Again she moved the tape forward. Now the man at the river could be seen clearly.
"That is me," Barley allowed. "I don't know why I waved at that point."
Dalzell again peered over his eyeglasses. "Who were you waving to? The record should reflect that the
witness definitely waved directly at the camera. What in the world were you doing, if you weren't waving
to the camera?"
Defendant Alleges Gang Rape On the seventh day, Dalzell began to hear Lisa Lambert's story of being
gang-raped by three policemen six months before Show's murder.
Lisa--her extravagant eye makeup toned down but still too thick for Rainville's taste--had started
testifying the previous day.
Now she described being stalked by an officer named Robin Weaver, of vainly calling his police chief to
complain, of receiving threatening calls after the alleged attack. She explained how fear had kept her from
telling this story before. Finally, she explained why she now was willing to talk.
In a deposition given to Lisa's attorneys before the hearing, Weaver, without being asked, had referred to
the gang- rape accusation. He thought Lisa had cited it in her habeas petition, but she had not. The
charge had never been raised publicly. To Lisa, Weaver's comment, therefore, provided independent proof
of her claim: "There is no way that he could have ever known about that unless he was there and he did
it. It was not raised in the petition."
"That is true, your honor," said Rainville, who had been appointed by the judge to represent Lisa on a pro-
bono basis.
Dalzell again had heard enough: "We'll take another recess. . . . I want {Weaver} here this afternoon, and
I don't want anyone to say a word about what has come up here. If he resists, please tell me. I will have
the marshal arrest him, OK?"
Moments later, Dalzell learned that prosecutor John Kenneff already had discussed the rape allegation
with Weaver.
The judge's budding animosity toward Kenneff was palpable. The prosecutor had not yet appeared before
him, but the residue of his work at the Lambert trial was everywhere.
"I'm going to direct that Mr. Kenneff have no further contact with any witness in this case. . . ," Dalzell
declared. "And he might want to consult with counsel. . . . I'm going to want to hear about this, because
in the context of this case, Mr. Kenneff, God help untruths" being aimed at our police, urged East
Lampeter Supervisor Chairman John Shertzer. Don't "rush to judgment." It's "unfortunate that so much is
being made of such insignificant points."
In his opening statement at the hearing, Madenspacher, the district attorney, had allowed that the
investigation hadn't been "perfect," that maybe they'd been a little "careless," maybe a little "sloppy."
Others, though, refused even to acknowledge that much. All sorts of citizens instead continued to offer
glowing tributes to the police and prosecutors.
U.S.C.A.
To
US President
Supreme
16-1149
Court
Obama
ToCase
US
re Lisa
Supreme
No. Lambert
16-6822
Court Page
Page92
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2016
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January
Sunday
StanJanuary
22,
J. Caterbone
201722, 2017
v. Allison
REQUEST
Hallet, Superintendent
FOR COMMUTATION
Page
Page1105
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OF THE SENTENCE
Stan
Institution
J. Caterbone
OF
re LISA LAMBERT
MICHELLECASE
LAMBERT
FILE
by Stan J. Caterbone, MOVANT FOR LISA MICHELLE LAMBERT
No one official drew more accolades than did John Kenneff. He is a big, heavyset man with a full, broad
Irish face. Growing up in Lancaster County, Kenneff was considered a fine schoolboy, a high achiever. Not
Harvard-level material, but his college, Villanova University, was nonetheless a good school. Not as good
as the University of Pennsylvania, but the next step.
He'd come back after law school, opened a private practice, worked his way up through the D.A.'s office.
He came to all the Fourth of July picnics; he brought his family, he brought his dog. He was known as a
committed, persistent prosecutor, one of the fairest and most reasonable in the county.
Even the defense attorneys who went up against him said as much. Even they called him a decent, honest
guy. To Terry Kauffman, a dairy farmer and chairman of the board of county commissioners, that
particularly carried a lot of weight: "A lot of people I know here, from both sides of the aisle, say he's the
best. I know them, and I've known Jack Kenneff for years. I don't know Stewart Dalzell."
Darcus--the chairman of the Lancaster City Council, a black man from West Virginia who followed a Boys'
Club job to Lancaster 30 years ago and happily settled--believed he possessed an especially close take on
John Kenneff's character. They'd been involved together in a "Weed and Seed" anti-crime development
program in Lancaster's minority community. So Darcus saw Kenneff not just as a prosecutor, but a
community leader. Also as a father: Kenneff's children went to the same Catholic school as Darcus' son.
"I've seen how he cares about people," Darcus said. "I've seen him deal with people in my community.
I've seen him go beyond what was needed. Knowing Jack Kenneff, I just can't picture this man doing what
the judge says. I wonder how that judge sleeps at night."
Denials From the Prosecutor No, John Kenneff insisted. No, he didn't think Butch Yunkin's sweatpants
were a critical issue at the murder trial. No, he had no recollection of looking at the sweatpants the state
put into evidence.
It was April 15, the hearing's 11th day. Kenneff had taken the witness stand soon after court convened.
Questioning him was Peter Greenberg, Rainville's husband, a partner at their law firm and one of
Philadelphia's most-accomplished litigators.
At the trial, the state's theory of the murder had Lisa wearing Butch's extra-large men's sweatpants,
found full of blood in a dumpster after the attack. Trial judge Lawrence F. Stengel accepted this theory
and thought it significant. So Kenneff's answers now caused Dalzell to lean forward.
"Did you make a conscious judgment at trial as to who was wearing the clothing that you put into
evidence?" Greenberg asked.
"It was my understanding that Miss Lambert had admitted to wearing the clothing . . . ," Kenneff replied.
Dalzell interrupted: "I don't think that's the question he asked you. And I think you ought to listen more
carefully to Mr. Greenberg's questions because I don't think you're answering them. . . . That question can
be answered yes or no."
So it went through much of the morning. Lancaster County citizens were right: Dalzell by then couldn't
hide his dismay for their assistant district attorney. The moments when the judge removed his glasses and
rubbed his eyes were adding up.
For 10 days he'd been exposed to an ever-more disturbing portrait of how Kenneff had prosecuted Lisa
Lambert. He'd listenedto the pathologist Isidore Mihalakis--a defense witness at Lisa's murder trial--
describe private conversations with Kenneff that Dalzell thought constituted witness-tampering. He'd
heard how authorities had concealed critical testimony by Hazel Show's neighbor Kathleen Bayan. He'd
been presented evidence that convinced him the state had "lost" an earring of Butch's found on the
victim's body. He'd been presented evidence that convinced him the state had edited critical video and
audiotapes.
Now the man who oversaw the state's efforts sat before Dalzell on the witness stand.
No, Kenneff was testifying. He didn't recall looking at the river-search video.
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"I didn't think what happened at the river was a contested issue," Kenneff replied.
This time, Greenberg snapped before the judge could: "You've been in this business long enough to know
that when I ask a question you're supposed to answer it?"
Dalzell joined in now: "It would be nice if you would do that. . . . I want to warn you, sir, that, if you don't
do that, you are going to put me into a position where this will have to get unpleasant. Do you understand
that? . . . The record should reflect that you have been consistently unresponsive to the questions. . . . "
Greenberg turned back to the matter of Butch's sweatpants. Now, Kenneff has even resisted saying he
based the case on the theory that Lisa wore Butch's clothing. He no longer, in fact, was sure whether the
sweatpants were Butch's.
The pair he'd produced for the habeas hearing, after all, were much smaller than men's extra-large. "The
sweatpants would have looked ridiculous if worn by 6-foot-1-inch-tall Butch," Kenneff had argued in a
written response just before the hearing.
"You are the same person . . . " Greenberg asked, "saying that the sweatpants would have looked
ridiculous on Butch, who put Butch on to testify in Lisa's trial . . . that they were his sweatpants, these
very same sweatpants that would have looked ridiculous on him?"
"Correct."
"These are the same sweatpants that Judge Stengel found belonged to Butch?"
"Correct."
"And if you had your way, Lisa would have been executed based on that evidence, wouldn't she?"
Greenberg erupted: "Do you think this is some kind of game? . . . Do you realize that there is a human
being sitting here who is in jail serving a life sentence based on the evidence you put on . . . that you are
now disowning. . . . Not only are you disowning it, you are committing perjury. . . . Are you sure it is Miss
Lambert who is a dangerous person in this courtroom?"
Handling of Letter Infuriated Judge In the end, the commonwealth's handling of the controversial 29
Question Letter was what most inflamed Dalzell.
Lisa had written Butch from jail, asking a series of questions. The answers Butch had scrawled under each
question, the judge felt, left no doubt that he was the murderer of Laurie, and that his accomplice was
Tabitha Buck. That the letter was authentic seemed equally certain to Dalzell: Both the state and defense
experts had affirmed there'd been no alteration.
Yet, Kenneff--after stipulating to the experts' opinions--had let Butch testify at Lambert's trial that the
questions were altered.
That the prosecutor knew his witness was committing perjury appeared obvious to Dalzell. At Butch's
plea-bargain hearing after Lisa's conviction, Kenneff wanted to revoke their deal precisely because of this
perjury.
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Experts had reviewed the 29 Questions Letter and Butch's trial testimony, Kenneff told the judge at that
Oct. 10, 1992, hearing.
"They advised us that his testimony . . . regarding that {letter} that was false . . . . It is our opinion that
he testified falsely . . . on that basis we feel we are entitled to withdraw from the original plea
agreement."
There just was no ambiguity, Dalzell felt: Kenneff knew that Butch committed perjury on a material issue,
regarding a document that established Lisa's innocence.
Under such circumstances, Dalzell believed Kenneff had an unambiguous ethical obligation to take
remedial action with the court that convicted Lambert. The Pennsylvania Rule of Professional Conduct was
clear about this: "A lawyer shall not knowingly . . . offer evidence that the lawyer knows to be false. If a
lawyer has offered material evidence and comes to know of its falsity, the lawyer shall take reasonable
remedial steps."
Yet far from complying with this rule, it looked to Dalzell as if Kenneff had encouraged Judge Stengel to
accept Butch's perjured testimony. "I think he's just like any other witness," Kenneff told Stengel when
Lisa's attorney moved for a mistrial based on Butch's perjury. "You can believe some of it, all of it, or
none."
It was worse than that, in Dalzell's eyes. For, after obtaining a conviction based partly on this perjured
testimony, Kenneff had coolly proceeded to seek the death penalty for Lisa Lambert.
Now, remarkably, Kenneff at this habeas hearing--and in written responses that looked to Dalzell to be
blatantly false--was back to arguing that some of the 29 questions had been initially written in pencil, then
altered. In other words, Kenneff, before Dalzell, was defending testimony by Butch that he had told two
other judges was a lie.
"Do you want to take remedial actions with Judge Dalzell?" Peter Greenberg asked.
Here the judge interceded: "I was just going to ask that myself. . . ."
It was the morning of April 16, the hearing's 12th day. Kenneff had been on the stand for hours.
"Well, your honor," Kenneff responded. "I think I still feel the same way about the 29 questions. . . . That
there is some type of tampering with it. . . . "
"No, no, no, sir," Dalzell interrupted. "I am going to jump in here. You said in your answer to me that
there was pencil. And you have testified under oath here that your expert and the defense expert said
there was no graphite. . . . "
Dalzell spoke over him: "I want to warn you, sir, you are under oath, and you are subject to the rules of
professional responsibility. . . . Do you retract that statement that you signed . . . as to pencil? Yes or
no?"
"I just don't think I can answer that question yes or no, judge."
Dalzell turned to Madenspacher, Kenneff's supervisor. "Does the commonwealth retract it?"
"Thank you," Dalzell said. He turned back to Kenneff. "Your boss just retracted it. Next question."
The climax came minutes later, when Greenberg began listing all the pieces of evidence that the district
attorney's office kept from Roy Shirk, Lisa's attorney at her trial. What if Shirk had the names of the
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emergency medical technicians? What if he knew the police had found a pink bag? What if he had the
unedited river-search video? What if he knew a neighbor had seen Butch at the crime scene?
"Well," Kenneff tried to answer, "the Pennsylvania Rule provides for certain . . . "
That's as far as he got. Dalzell exploded: "No. Excuse me. We're talking here--let me just make something
clear to you. We're talking here about something called the United States Constitution, and in particular
the 14th Amendment thereof, which has a clause in it that refers to due process of law.
"Yes sir."
"That's what we're talking about. . . . So we're not talking about the Pennsylvania Rules of Criminal
Procedure. We're talking about due process of law here. . . . That's what we're talking about here. You got
it? Do you understand?"
Biggest Drama Begins to Unfold As it happened, the confrontation between Dalzell and Kenneff was
neither the most dramatic nor revealing sequence to occur on this 12th day of Lisa's habeas hearing. The
event that would eclipse it began only after Kenneff left the witness stand, and court adjourned for lunch.
Madenspacher, walking toward his hotel, bumped into Hazel Show's brother, who reported that his sister
needed to talk to him.
Back at the Holiday Inn in downtown Philadelphia, where both were staying, Madenspacher walked up to
Show's room.
Sobbing as she talked, the murder victim's mother told him her story.
During the hearing that morning, she'd suddenly recalled the morning of the murder: As she drove up
Black Oak Road to her condo, on her way to find Laurie's body, a brownish-colored car passed, heading
out of the condo complex. It was Butch's car.
She looked at Butch. There was recognition on his face. He pushed down someone with blond hair. There
was also a third person in the back seat, with black hair.
She'd told this to Det. Ron Savage back then. Savage had come to her house saying one of her neighbors
had seen Butch's car leave the complex. She'd started to say she had too. Savage had stopped her, told
her not to dwell on that. They had so many witnesses saying Butch wasn't there. Besides, this neighbor
lady was kind of disturbed anyhow. Probably wouldn't be a reliable witness. We were better to go with
Butch not being there.
Hazel was sobbing harder now. She'd forgotten about it, she told Madenspacher. She'd put it aside. Until
now.
Madenspacher was reeling. Hazel's story fit exactly with testimony given by that "neighbor lady," Kathleen
Bayan, on the hearing's fourth day. Testimony that Hazel hadn't heard because she'd left the courtroom
early that day. Testimony that had never been produced at Lisa's murder trial. Testimony that Kenneff
knew about back then but had never shared with Lambert's attorney. Testimony that Savage had tried to
water down while taking Bayan's initial statement, then dismissed as coming from a woman with "an
emotional problem."
Hazel's story also fit perfectly with something else: Lisa Lambert's testimony at her trial. There she'd told
of driving by Hazel Show, of Butch saying, "Oh . . . it's Hazel," of Butch pushing her head down.
Madenspacher pondered. If true, it seemed to him that this story knocked out the underlying theory of the
trial, which was that Butch wasn't at the condo. It didn't mean Butch was actually inside; it didn't clear
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Lisa; it could be explained. But it was a new story. It changed the theory of the case. Madenspacher felt
as if he were slipping into shock.
Madenspacher had no choice: He had to get this to the judge. He couldn't suppress it. The only question
was, when and how? It was going to come out anyway, Madenspacher figured. So let's get the bad news
over with.
The conference in Dalzell's chambers began at 1:40 p.m. that day. Present were the judge, the lawyers
for all sides, Hazel Show and Lisa Lambert.
Hazel Show told her story again, this time before a court reporter: Well, when I was sitting in the
courtroom today, I realized that I had seen Lawrence's {Butch's} car with passengers drive out of our
condominium complex. . . . Det. Savage said that I wasn't to dwell on it. . . . I never thought anymore
about it until I was sitting in there. . . . It all just came back.
To Dalzell, this revelation was the final straw. Throughout Lisa's trial the state had been at pains to keep
Butch as far from the Show condo as possible. No doubt that was why the state had never disclosed
anything about Hazel's report or Bayan.
To Dalzell, it wasn't just that Hazel's and Bayan's accounts were consistent with Lisa's testimony at trial
five years ago: Just about everything being revealed at this hearing was consistent with Lisa's testimony
back then.
From all he'd heard, Dalzell now believed that the commonwealth's misconduct had been so substantive, it
had undermined the state court's ability to find the truth. He believed the commonwealth had committed
at least 25 separate instances of prosecutorial misconduct--all constitutional violations, all violations of the
norms of a civilized society.
It seemed clear to him that Laurie Show did not say "Michelle did it." It seemed clear that Butch, in the 29
Questions Letter, confessed to the murder. It seemed clear Lisa didn't wear Butch's sweatpants on the
morning of the murder. It seemed clear the police had fabricated Lisa's initial statement.
Worse yet, in Dalzell's view, the commonwealth still hadn't stopped its treachery. At this habeas hearing
the state had produced not the extra-large sweatpants of Butch's from the original trial, but a smaller
girl's pair. The commonwealth, Dalzell believed, had perpetrated a fraud on the federal court; the
commonwealth had swapped evidence.
At least six state witnesses, by Dalzell's count, had perjured themselves before him. One, Ron Savage--
now an elected district justice in Lancaster County--likely obstructed justice. And now this: now Hazel's
revelation, right before his eyes. Hazel had every reason to want Lisa's petition denied; Hazel sincerely
believed Lambert did it. Yet still she'd felt compelled to tell this story. Dalzell had never seen a more
courageous act.
"Well," the judge told those gathered in his chambers. "Now we come to the question of relief. Does the
commonwealth intend to defend this case?"
The Lancaster County district attorney had been looking uncomfortable in recent days. Nothing he'd heard
rose to the level of conscious misconduct or obstruction, he kept insisting. But he had to admit, it hadn't
been a perfect trial or investigation. He wished certain things had been done differently.
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In Lancaster County, then as now, there were many who wanted their district attorney to fight ferociously.
There were many who wanted their district attorney to defend their honor, to insist they'd done nothing
wrong, to match Lisa's lawyers blow for blow.
Yet, Madenspacher, at this moment, wasn't sure what should be done. Everything, he would say later, was
"spinning in my mind." It was "awful tough" operating away from the office. It "would have been nice" to
have known everything from the start.
"Now, obviously . . . " he finally told the judge. "There is some relief that is justified in this particular case.
. . ."
That was all Dalzell needed; he now had the commonwealth's assent. The state hadn't even put on its
case yet, but he meant to get Lisa out of prison. He also meant to get Savage off the bench forever; he
didn't see how Savage could hear cases anymore, and he planned to tell the Pennsylvania Supreme Court
just that.
"You can make a choice overnight," Dalzell advised the district attorney, "whether you want to defend this
case, put on your own witnesses. In the meantime, I'm going to release Ms. Lambert into some agreed-
upon custody. . . . Because it's quite clear now that the petitioner is entitled to relief, the only question is
how much."
Off to one side, a dismayed Hazel Show tried to interject: "Laurie told me she did it. . . . "
Madenspacher's voice overrode hers. "Yes, I agree relief is warranted, and I think we're talking now. . . . "
"I can tell you, Mr. Madenspacher, that I've thought about nothing else but this case for over three weeks,
and in my experience, sir, and I invite you to disabuse me of this at oral argument, I want you and I want
the Schnader firm to look for any case in any jurisdiction in the English-speaking world where there has
been as much prosecutorial misconduct, because I haven't found it. .
. . So are we agreed that the petitioner will tonight be released into the custody of Ms. Rainville?"
Madenspacher nodded. "I don't see how I can object to that, your honor."
Stunned Response in Lancaster County In bars and cafes, street corners and living rooms, the citizens of
Lancaster County gasped at the news of Lisa's release. Their district attorney may not have seen reason to
object, but they did. Most sounded stunned; many sounded enraged. One man, at 8 a.m. on the morning
after her release, anonymously called in a phone threat to the Lancaster Sunday News, saying he would
kill Lambert if she returned to Lancaster.
Maybe there were "mistakes," the more rational by now were willing to allow. Maybe there was "sloppy"
police work. Maybe Lisa even deserves a new trial. Nothing more than that, though. Certainly not her
freedom. She was there, she was an accomplice, she was a co-conspirator. Give her a new trial, remand it
elsewhere even. But don't just let her go. You can't just let her go.
"Lambert is not innocent--how could she be?" the Lancaster New Era editorialized the day after Hazel
Show's revelation. " . . .
even with newly revealed evidence that supports her claims, Lambert is still irrevocably involved in the
events that lead to Laurie Show's murder. These facts must not be drowned out by the explosive
revelations at Lambert's federal appeals hearing. . . . "
As it happened, these thoughts exactly echoed those offered by Judge Stengel, who'd presided at Lisa's
murder trial. "Even if Lambert's story at trial was completely credible," Stengel had declared in his written
opinions, "she would still be an accomplice to the crime of murder. . . . The single most important fact on
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the issue of guilt is whether Ms. Lambert was present in the Show condominium at the time of the killing.
By her own admission, she was present. . . . "
Dalzell, however, simply did not accept this notion, at least not in a federal habeas hearing.
On the proceeding's final day, when Madenspacher in his closing argument spoke of Lambert being guilty
at least as an accomplice or conspirator, Dalzell waved him off. "She wasn't charged with conspiracy was
she?" he declared. "She was charged with first-degree murder. So the only issue before me is actual
innocence of first-degree murder. That is what she was convicted of."
In fact, the law is murky on this point. Lisa was actually charged with criminal homicide, which in
Pennsylvania encompasses all degrees of murder. How her conviction for first-degree murder affects her
exposure to lesser murder charges is a matter for debate.
So, Madenspacher tried to argue: "What I am saying here is that charged with criminal homicide, she
could be found guilty of murder in the first degree . . . or she could have been found guilty of second
degree . . . or she could be found guilty of third degree."
That didn't sway Dalzell: "But if one took her testimony, she said that she did everything possible to de-
escalate what spun out of control. . . . By her own testimony she exited when it started spinning out of
control. So therefore, it was not 'reasonably foreseeable' from her point of view, so the argument would
go."
The judge then cut things off: "Let's not waste time debating that."
Dalzell had good reason for not wishing to bother further with this issue. By then--after 14 days of
testimony covering 3,225 pages of transcript--the judge wasn't thinking only about Lisa's conduct at the
Show condo. He was thinking about the 14th Amendment of the Constitution, and the role of a federal
habeas corpus in upholding the unalienable right of due process.
Among other historic cases, Dalzell's mind was on a 1973 opinion by then-Justice William H. Rehnquist, in
United States vs. Russell. There, Rehnquist predicted that "we may some day be presented with a
situation in which the conduct of law enforcement agents is so outrageous that due process principles
would absolutely bar the government from invoking the judicial processes to obtain a conviction."
That day, Dalzell decided at the close of Lambert's hearing, had come.
While presiding at a habeas hearing, he reminded himself, he effectively sat as a court of equity--a court
operating under a system of law designed to protect rights and deliver remedial justice. He recalled the
ancient maxim that "equity delights to do justice, and not by halves." To give Lisa full relief, it seemed to
him imperative that he do nothing to benefit or empower those who had wronged her.
He would not just release Lisa, Dalzell decided. An outrageous violation of due process required even more
severe sanction. He would bar the state from ever retrying her. He would strip the state of its natural right
to adjudicate a murder committed within its boundaries.
He wrote his 90-page opinion over the weekend, after court adjourned at 4:10 p.m. on Friday, April 18.
Before a packed courtroom late the following Monday morning, he declared Lisa "by clear and convincing
evidence" to be "actually innocent of first-degree murder."
"If Lisa Lambert's is not the 'situation' to which Chief Justice Rehnquist referred, then there is no
prosecutorial malfeasance outrageous enough to bar a reprosecution. . . ." he proclaimed. "We have now
concluded that Ms. Lambert has presented an extraordinary, indeed, it appears, unprecedented case. We
therefore hold that the writ should issue, that Lisa Lambert should be immediately released, and that she
should not be retried."
In scorching language, Dalzell explained just why: "We have found that virtually all of the evidence which
the commonwealth used to convict Lisa Lambert of first-degree murder was either perjured, altered or
fabricated. Such total contempt for due process of law demands serious sanctions. The question we must
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now answer is whether . . . the commonwealth is entitled to get another try at convicting Lisa Lambert
and sending her to prison for the rest of her life. . . . In short, the question is whether we may accept a
promise from anyone on behalf of the commonwealth that a trial will be fair 'next time.' "
"We hold that the due process clause of the 14th Amendment bars the commonwealth from invoking
judicial or any other proceedings against Lisa Lambert for the murder of Laurie Show. . . . Equitable
considerations preclude our leaving the decision whether to retry Lisa Lambert in the hands of those who
created this gross injustice. . . . "
As far as legal researchers could tell, there was an accepted basis, but no exact precedent for a federal
judge in Dalzell's situation to take such action. Dalzell did not stop there.
He was, he announced in his opinion, going to refer the matter of Kenneff's "blatantly unethical and
unconstitutional" actions to the Pennsylvania Disciplinary Board. He also was going to refer the whole
Lambert prosecution to the U.S. attorney for investigation of "possible witness intimidation, apparent
perjury by at least five witnesses in a federal proceeding, and possible violations of the federal criminal
civil rights laws."
Still, Dalzell wasn't finished. He felt compelled, in the two final pages of his opinion, to address the
question of just why all this had happened in Lancaster County.
"Those who have read this sad history," he wrote, "may well ask themselves, 'How could a place idealized
in Peter Weir's'Witness' become like the world in David Lynch's 'Blue Velvet'?' Because it is so important to
that community and indeed tomany others to prevent a recurrence of this nightmare, we offer a few
reflections on the record."
Laurie Show's grandfather, Dalzell pointed out, was, in the 1980s, the coroner of Lancaster County. Her
mother was "a paragon of morality" who kept "a picture-perfect home." By contrast, Lisa Lambert was "as
though delivered from Central Casting for the part of villainess." By the testimony of even those who loved
her, "she was at the time literally 'trailer trash.' " The community "thus closed ranks behind the good
family Show and exacted instant revenge against this supposed villainess." Almost immediately after "the
snap judgment" was made, law enforcement officials uncovered "inconvenient facts," but soon "discovered
a balm for these evidentiary bruises, Lawrence Yunkin." Thus "Lancaster's best made a pact with
Lancaster's worst to convict the 'trailer trash' of first-degree murder."
Dalzell's parting words: "In making a pact with this devil, Lancaster County made a Faustian bargain. It
lost its soul and it almost executed an innocent, abused woman. Its legal edifice now in ashes, we can
only hope for a 'Witness'-like barn-raising of the temple of justice."
Uprising Began With Calls, Letters The uprising in Lancaster County in the wake of Dalzell's ruling began
first with the usual letters to editors and calls to radio talk shows.
The legal system is a "crock of crap." How could Dalzell destroy the reputation of "honorable and decent
people" for the purpose of freeing a "cold-blooded killer?" What kind of justice do we have?
Soon enough, such talk escalated. All sorts of theories about Dalzell's motives began circulating.
Something's been going on behind the scenes, it was suggested. Something behind what Dalzell did,
something we don't know about.
Ted Byrne, the conservative radio talk show host in Lancaster County, pored through Dalzell's decisions in
a law library. Then, seeking hidden connections, he analyzed the activities of the attorneys at Dalzell's old
law firm and Rainville's firm.
It was considered significant that Dalzell and Greenberg, 30 years before, had been classmates at the
University of Pennsylvania. Some talk had it that they were old pals. Some talk had it that Dalzell had
handed the Lambert case to his own "carefully assembled defense team."
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Had Dalzell reached the end of a career path? Had he felt unfulfilled? Had he wondered how he might
become an appellate judge? Had he seen a challenge to the controversial habeas corpus situation as a
means to garner attention?
For that matter, how did the Lambert case get to Dalzell in the first place? Had not Dalzell displayed an
excessive personal interest in Lisa in his chambers? Was it possible that they had a relationship?
"We must begin to think who it was that had to gain from this travesty of justice other than Lambert,"
suggested one citizen in a letter to the editor. "My vote goes to Judge Stewart Dalzell. It would appear
that it is an appropriate time for this newspaper to dig very deep into the archives of the noteworthy
judge to determine what it was or who it was that set him on his grudge mission to 'punish' the county for
sins of the past committed against him."
Such comments reflected as much bewilderment as paranoia. They came from a citizenry who well knew
Lisa Lambert, and well knew those who had prosecuted her. Yet rarely did anyone, amid all the outpouring
of emotion and speculation, feel inclined to discuss the particulars of the Lambert case as revealed in
Dalzell's courtroom.
More common was East Lampeter Supervisor Chairman John Shertzer's response. "There were a lot of
false accusations throughout the trial. . . . We never had the opportunity to address those," Shertzer told
a reporter, before confessing that he, in fact, couldn't address them: "There are some things about this
that I don't have a lot of background in. But I just know these people. . . . They were treated very
abusively on the stand by Lambert's attorneys as well as the judge."
Lancaster's citizens were struggling to hold together a way of viewing their world. Even those willing to
acknowledge certain blemishes in that world--even those willing to acknowledge official wrongdoing in the
Lambert case--found themselves laboring to understand what Dalzell had done. No matter what was
revealed in a Philadelphia courtroom, no matter what Lancaster authorities did or failed to do, it seemed
incomprehensible that Dalzell would let Lisa Lambert walk free, without at least a retrial.
Not even Lisa's parents had hoped for that back when their daughter's appeals first started. Their dream,
Leonard Lambert told a reporter then, was that Lisa receive "a level of punishment that's not greater than
what's deserved. . . . It's a known fact that she was there. But something could argue that maybe she
doesn't deserve more than aggravated assault or third-degree murder."
Dalzell went too far, even the more reasonable in Lancaster County now declared. He was a disgrace to
the legal profession.
Hazel Show, more than anyone, sounded the clarion. "Thank you for listening to me," she'd told Dalzell on
the hearing's last day. "My parents brought me up to be truthful, and I believe in God. . . . So it is up to
me to tell the truth." Yet soon after, whether out of confusion or regret at what she'd wrought, Show
began to backtrack and revise.
Never in her "wildest dreams," she declared, had she thought her story would free Lisa. All her story
proved was that she got home just as the killers left, in time to hear her daughter's dying declaration. But
the judge "didn't want to hear that." The judge "wouldn't let me say that."
No matter that Madenspacher insisted Hazel never mentioned this notion to him in their hotel meeting. No
matter that she never mentioned this notion while on the witness stand on the hearing's last day. It now
became her constant refrain. "We have to get this judge off the bench," she began declaring publicly.
"There is not one bit of justice in him."
They began first with a petition drive. Hazel's ex-husband, John Show, drew it up, calling for Congress to
"investigate" Dalzell and take "corrective action," including impeachment. Show's girlfriend took it to her
beauty shop, where customers clamored to sign it. Local businesses started stocking piles on their front
counters. Volunteers called for extra copies, carried them door to door, offered them at yard sales. One
couple outside a Kmart parking lot on a hot Sunday collected more than 500 signatures.
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On the morning after an ad for the petition appeared in the Lancaster newspapers, John Show walked to
his mailbox and found 300 envelopes. By mid-September, he had 37,000 signatures.
Then came Hazel Show's 10-page "Citizens Action Report," the keystone of her newly launched national
campaign seeking to reform the entire federal judiciary. Now the Shows wanted, among a host of items,
to bar federal judges from banning retrials, to fix stricter guidelines for appointing federal judges, to limit
federal judges' terms in office. Hazel Show's words and image soon became ubiquitous in Lancaster
County.
Television provided one forum, both local talk shows and the national tabloids. Politicians provided
another. The Washington-based Judicial Selection Monitoring Project, an arch-conservative organization
seeking to block the appointment of what it calls "activist liberal judges," featured both Shows in a 15-
minute videotape that lambasted Dalzell and misidentified him as a Clinton appointee.
The Shows, accompanied by 16 friends and relatives, took their campaign to Washington on Sept. 17,
where Pennsylvania Sen. Arlen Specter, along with Reps. Joseph R. Pitts and George W. Gekas, accepted
cartloads of petitions. The lawmakers, weeks before, had introduced legislation that would severely
restrict federal judges' power to bar retrials during habeas proceedings--a bill specifically designed to
reverse Dalzell's decision. Now, to the Shows, Specter agreed to call it the "Laurie Bill" and promised them
a Senate Judiciary Committee hearing. Wherever they went, the Shows were applauded and courted.
"How often do you get to do this?" Hazel observed.
Argument That Judge Brought It on Himself It can fairly be argued that Dalzell brought some of this on
himself. He may have overly embraced Lisa Lambert's account of events, and unduly diminished her role.
He may not have needed to rough up witnesses in his courtroom as much as he did. He certainly need not
have painted Lancaster County with such a broad brush at the end of his opinion.
How could he claim to know this county, his critics asked. How could he claim to know our citizens? How
could he say such things about us?
Yet, valid as such claims may be, it most likely will be Dalzell who leaves a lasting impact, not those
fueling the backlash against him.
Whether right or wrong, whether he operated entirely within his bounds, a federal judge consumed by
moral outrage has, as he intended, sent a message. The idea behind Lisa Lambert's outright release was
not, finally, to let a guilty person go free. It was to let the powers of the state know they can't violate
bedrock principles of the Constitution and get away with it.
They haven't.
In early May, the U.S. attorney's office in Philadelphia, responding to Dalzell's referral, announced it had
launched a criminal investigation into those who investigated and prosecuted Lisa Lambert. Aiding them
will be the FBI and the Justice Department's civil rights division. They will focus on John Kenneff and
seven police officers, among them Ronald Savage, Ronald Barley, Robin Weaver and Raymond Solt.
Days later, the U.S. 3rd Circuit Court of Appeals, in refusing Lancaster County's motion for a temporary
stay of Dalzell's order, said "the commonwealth has not demonstrated that it is likely to prevail on the
merits of its appeal. . . . We remind the commonwealth that Judge Dalzell's factual findings are based on
his view of the credibility of the witnesses and testimony. . . .
In that written opinion, the appellate panel also chastised the commonwealth for calling Lisa Lambert a
"convicted killer" in its brief. She "no longer has that status," the 3rd Circuit reminded. "Indeed, that
description is inflammatory and inappropriate, given {Dalzell's} findings of actual innocence. . . . "
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What remains to be seen is whether Dalzell will ultimately be allowed his unprecedented involvement in a
state's sovereign affairs. At the habeas hearing's end, Lancaster County hired its own high-powered
Pennsylvania law firm, Sprague & Lewis, known for its political connections, particularly to the Republican
Party. On Oct. 21, when lawyers for both sides argued the merits of the county's appeal before a 3rd
Circuit panel, the appellate judges grilled them on a critical question: Did Lisa Lambert exhaust all her
appeals in Pennsylvania's courts before turning to a federal judge for help?
This issue, rather than any question of Lisa's innocence or a prosecutor's malfeasance, is what presently
fuels a nationwide debate in the legal community and beyond. Elemental principles of law and government
in this country normally restrain federal intrusion until a state has heard all claims, and has been given
the chance to correct its own errors. Just weeks ago, a 3rd Circuit panel--saying "we are sensitive to the
independence of the Pennsylvania courts and of that state's sovereignty"denied another convict's habeas
petition because he hadn't exhausted his state appeals.
Dalzell, in his opinion, recognized these principles, then essentially dismissed them. The Pennsylvania
General Assembly, he pointed out, amended its statutes in 1995 to exclude "actual innocence" as a basis
for certain appeals. By doing so, Dalzell declared, Pennsylvania, in effect, relinquished its jurisdiction over
claims such as Lisa Lambert's, and placed them "squarely into the federal forum." And even if
Pennsylvania were willing to consider some of Lambert's claims, Dalzell added, "we find that the state
proceedings that would follow if we dismissed this action are ineffective to protect the rights of Ms.
Lambert."
By thus declaring his utter distrust in Pennsylvania's ability to deliver justice, Dalzell has challenged the
fundamental balance ofpower between state and federal courts that governs the judicial system. This is
why five state attorneys generalincluding California's--have joined Pennsylvania in an amicus brief that
talks of the Dalzell ruling's "potential to seriously weaken, if not to dismantle entirely, the system for
litigating habeas actions." This is why law-and-order-minded national politicians have their knives out for
Dalzell. This is why Lisa Lambert's federal hearing promises to be one of the most carefully reviewed cases
in criminal law for a long time to come.
This is also why Dalzell's actions will leave a legacy no matter what the outcome of the present appeals.
His ruling may or may not stand, his ruling may or may not establish a formal precedent, but--by granting
a hearing and allowing widespread discovery--Dalzell has required that attention be paid to what
happened in a Lancaster County courtroom in the summer of 1992. He's shown why the federal habeas
corpus action is essential to the integrity of the judicial system.
Dalzell has also set a moral, if not legal, example. Rulings in one case often affect other rulings. One
judge's decision shapes not just the outcome of a particular case, but also the character of justice. What
he doesn't allow, others likewise forbid.
In mid-May, in Lancaster County court, Lisa Lambert's original trial lawyer, Roy Shirk, serving as defense
attorney in a routine burglary case, rose to ask for a mistrial. As in the Lambert case, he argued,
prosecutors in this one had failed to turn over exculpatory evidence to the defense. Shirk most likely
meant only to put this commonplace claim into the record for later review, but Judge Paul K. Allison, to
the lawyers' astonishment, promptly granted his request.
Yes, the judge said in declaring a mistrial, this is exactly what Dalzell felt happened to Lisa Lambert.
PHOTO: Lisa Michelle Lambert walks ahead of lawyers, Peter Greenberg and Christina Rainville, to court
hearing.;
PHOTO: Lancaster County Dist. Atty. Joseph Madenspacher talks to news media after judge ruled Lisa
Michelle Lambert innocent of charges.;
PHOTOGRAPHER: Associated Press;
PHOTO: Hazel Show, left, stands in bedroom where daughter, Laurie, was murdered.;
PHOTOGRAPHER: Associated Press;
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PHOTO: U.S. District Judge Stewart Dalzell was assigned the writ of habeas corpus that
set him on a course to freeing Lisa Michelle Lambert.;
PHOTOGRAPHER: Associated Press
Reproduced with permission of the copyright owner. Further reproduction or distribution is prohibited
without permission.
Subjects: Judicial reviews, Acquittals & mistrials, Murders & murder attempts, Prosecutions, Series &
special reports
ISSN/ISBN: 04583035
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