THE LANCASETER COUNTY COURT OF COMMON PLEASCIVIL DIVISION

In Re: STANLEY J. CATERBONEand ADVANCED MEDIA GROUP,

PETITIONERS

v. Case No. 15-06985RESIDENTS of the County of Lancaster Pennsylvania

DEFENDANTS

APPEAL FOR RECONSIDERATION

AND NOW, on this 24TH day of August, 2015 I, STANLEY J. CATERBONE and ADVANCED

MEDIA GROUP, Plaintiff's, appearing pro se, and In Forma Pauperis, do hereby file the Appeal for

Reconsideration pertaining to the ORDER filed on August 20, 2015 that states: “IT IS HEREBY

ORDERED that 15-06985 is DISMISSED as frivolous in that it lacks any arguable basis either in

fact or in law”.

Dated August 24, 2015

Stanley J. CaterboneAdvanced Media Group, President and OwnerPro Se Litigant, U.S. District Court & Pennsylvania Common Pleas Court Scaterbone@Live.com1250 Fremont StreetLancaster, PA 17603717-669-2163

BACKGROUND

On June 25, 2015 the PETITIONERS were named the MOVANT in the Lisa Michelle Lambert

Habeus Corpus filed in the United States District Court for the Eastern District of Pennsylvania,

CASE NO. 5:14-cv-02559-PD. The following is a history of the Lisa Michelle Lambert Case:

Lambert was convicted on July 20, 1992 for the December 19th, 1991 stalking, and brutal

stabbing murder. Investigators for the defense stated that it'd been brought to their attention by

those they'd interviwed that "Lisa Lambert was a serious liar and very good at it." Between her

various changing stories about the killing, claims against her co-conspirators/killers, and her

claims against local police officers who were investigating the murder, Lambert has certainly lived

up to those claims.

Lambert was previously incarcerated in Cambridge Springs Correctional Facility, Pennsylvania but

was transferred to Clinton, New Jersey, then to the Women's Correctional Facility at Baylor,

Delaware. Later she was transferred to Framingham, Massachusetts.

Lambert's co-conspirators Tabitha Buck was convicted of second degree murder and received a life

sentence. Lawrence Yunkin initially received a year in prison under a plea bargain, but that deal

fell through because of his perjury and he was sentenced to 10 to 20 years. Yunkin served 12

years and was released in 2004.

1992: Lambert filed post verdict motions claiming that her conviction was "against the weight of

the evidence."

1994: The physical findings at the crime scene, the testimony at trial of the defendant, the trial

testimony of Hazel Show, the history of ill will between defendant and the victim and the

circumstantial evidence developed at trial all lead to the conclusion that defendant was guilty of

the murder of Laurie Show.

1996: Lambert filed a lawsuit claiming that prison guard James Eicher had attacked her six times

during 1994, and that another official had fondled her. Further, that she was videotaped during a

strip search. Eicher was convicted of aggravated indecent assault and sentenced to two years in

prison.

1997: Lambert was freed briefly when a federal district judge ruled that Lambert was "actually

innocent." A Federal Appeals court overturned the ruling and Lambert was returned to prison. The

court found that Lambert had brought her case to the Federal Courts prematurely without

exhausting her opportunities for appeal in Pennsylvania.

The following is a copy of the LA Times Story by Barry Siegel that details the 1997 Habeus Corpus

Hearing where the Honorable Stwert Dalzall, the federal judge, FREED Lambert:

A Bitter Lesson for Lancaster County; Judge says Pennsylvania

community 'lost its soul' in push to convict woman of murder.

Residents claim he, not they, are mocking justice.

Right or wrong, his ruling challenges U.S. court system's balance of

power.

BARRY SIEGEL.

Los Angeles Times

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.

"Oh," he said. "Well, OK."

So it went, hour by hour, for 15 days.

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.

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.

Dalzell had heard enough.

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.

"No, that's not me," Barley said.

Rainville inched the videotape ahead a moment. "No, no ma'am."

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?"

Barley looked blank. "I don't recall, sir."

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."

Dalzell interrupted: "Is that true?"

"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.

"So he's been coached . . . ," Dalzell exclaimed.

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.

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 listened to 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.

"You didn't think it worthwhile to look at the video?" Greenberg asked.

"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?"

"Right," Kenneff agreed.

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?"

Kenneff hesitated; Dalzell spoke: "Yes or no," the judge ordered.

"That would be correct."

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.

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. . . . "

"Judge," Kenneff began.

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?"

Madenspacher rose. "Yes, your honor. We retract it."

"Thank you," Dalzell said. He turned back to Kenneff. "Your boss just retracted it. Next question."

Their confrontation hadn't peaked yet.

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 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.

OK? Have you heard of that?"

"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?"

"Yes," Kenneff replied.

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 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.

"You sure?" he asked. "Let's hear it again."

Hazel repeated her story.

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.

By now, Lisa was sobbing along with Hazel.

"It's OK, Miss Lambert," Dalzell said. "It's OK."

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?"

All eyes turned to Madenspacher.

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.

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. . . . "

"About what relief," the judge said.

"What relief, your honor . . . "

"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 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 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.' "

No, Dalzell concluded, we cannot.

"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."

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.

He had made a mockery of justice. He was a man without honor.

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.

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.

"I think we made an impact," John offered.

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. . . .

We can only reverse if we find them clearly erroneous."

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. . . . "

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 general—including 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.

1997: Lisa Lambert's appeal – DENIED

1998: Conviction upheld, Lambert's claim that she was framed by prosecutors rejected.

2003: Eight Law Enforcement Officers cleared of misconduct in Lambert's case.

2005: Appeal to the Supreme Court - Supreme Court refused to hear her case. Incarcerated in

Clinton, N.J. Lambert has now exhausted all of her appeals. She will continue to serve out her life

sentence.

2007: A Lancaster County judge has determined that a civil lawsuit filed by State Correctional

Institution-Cambridge Springs inmate Lisa Michelle Lambert against administrators at the facility

for allegedly failing to prevent her from being sexually abused by employees was scheduled to be

heard by a jury.

2007: The state of Pennsylvania has decided to settle a lawsuit brought by convicted killer Lisa

Michelle Lambert, who claimed she was sexually assaulted by guards at the Cambridge Springs

State Correctional Institution. The civil lawsuit had been placed on hold until Lambert had

exhausted all of her appeals in her criminal case. The money, $35K, will go to pay court costs,

restitution, and if any is left, will go to Lambert's parents, who are raising her and Lawrence

Yunkin's daughter.

The following is what I wrote in an AFFIDAVIT:

AFFIDAVIT OF 1998 TO HONORABLE JUDGE STEWART DALZELL

“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 selfserving accusations

of “insanity”. I conclude that the courts must provide me with fair access to the law, and most

certainly, the process must void any technical deficiencies found in this filing as being material to

the conclusions. Such arrogance by the Courts would only challenge the judicial integrity of our

Constitution.”

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

plaintiff’s 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 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 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 & Control’s 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 plaintiff’s failed business dealings will demonstrate and substantiate financial incentive and

motive. Defendants 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 authority, 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 Steinman 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 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 plaintiff’s 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 plaintiff’s intellectual capacity has been exploited as means of

discrediting 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 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

purposefully directed at intimidating the plaintiff from further public disclosure into the activities of

International Signal & Control, Plc., 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 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 Dalzall’s 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.

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 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 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.

APPEAL FOR RECONSIDERATION

Your ORDER of August 20, 2015 could be construed as an “Abuse of Process” and you

should follow the rule of law and provide either an affirmative action for my Preliminary Injunction

or provide a legal opinion to your claims in the ORDER.

Dated August 24, 2015

Stanley J. CaterboneAdvanced Media Group, President and OwnerPro Se Litigant, U.S. District Court & Pennsylvania Common Pleas Court Scaterbone@Live.com1250 Fremont StreetLancaster, PA 17603717-669-2163