www.amgglobalentertainmentgroup.coms caterbone@live.com

717-669-2163

Stanley J. CaterboneAdvanced Media Group1250 Fremont StreetLancaster, PA 17603

IN THE UNITED STATES THIRD CIRCUIT COURT OF APPEALS_______________________________________________________________________________Lisa Michelle Lambert : PETITIONER :

: v. : CASE NO. 3400-2015

::

Lynn Bissonnette, et al., : RESPONDANT :

:

Stanley J. Caterbone : APPELLANT : : :

Motion for Leave to Proceed In Forma Pauperis

I hereby on this 4th day of November, 2015, according to the ORDER dated November 3, 2015, the

APPELLANT hereby submits for considerations in the above captioned case the attached APPLICATION for In

Forma Pauperis

/s/ Stanley J. CaterboneDate: November 4, 2015 Stanley J. Caterbone, Pro Se

Appellant1250 Fremont StreetLancaster, PA 17603(717)-669-2163s caterbone@live.com

http://www.amgglobalentertainmentgroup.com/__

Case: 15-3400 Document: 003112121607 Page: 1 Date Filed: 11/04/2015

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

No. 15-3400

Lambert v. Superintendent Framingham MCI

(E.D. Pa. No. 5-14-cv-02559)

To: Clerk

1) Motion by Appellant, Stanley J. Caterbone, for Leave to Proceed In Forma

Pauperis

The motion to proceed in forma pauperis is held in abeyance pending the

submission of an additional document. Appellant must submit this Court’s affidavit of

poverty 14 days of the date of this order or the appeal may be dismissed.

For the Court,

s/ Marcia M. Waldron

Clerk

Dated: November 3, 2015

CJG/cc: Stanley J. Caterbone

District Attorney Lancaster County

Jeremy H.G. Ibrahim, Sr., Esq.

Case: 15-3400 Document: 003112119015 Page: 1 Date Filed: 11/03/2015

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Case: 15-3400 Document: 003112121607 Page: 2 Date Filed: 11/04/2015

www.amgglobalentertainmentgroup.coms caterbone@live.com

717-669-2163

Stanley J. CaterboneAdvanced Media Group1250 Fremont StreetLancaster, PA 17603

IN THE UNITED STATES THIRD CIRCUIT COURT OF APPEALS_________________________________________________________________

______________Lisa Michelle Lambert : PETITIONER :

: v. : CASE NO. 3400-2015

::

Lynn Bissonnette, et al., : RESPONDANT :

:

Stanley J. Caterbone : APPELLANT : : :

ARGUMENT FOR IN FORMA PAUPERIS STATUS

AND NOW, on this 4th day of November, 2015 I, STANLEY J. CATERBONE and ADVANCED

MEDIA GROUP, APPELLANTS, appearing pro se, do hereby file this ARGUMENT in support of the

APPELLANTS Application to Proceed In Forma Pauperis.

The APPELLANT has been aserting claim to certain assets in the courts, however those

same said assets have had no material worth to the APPELLANT in the past 10 years. In addition

the APPELLANT has had liabilities of over $140,000.00 that were part of the Chapter 11

Bankruptcy Case, 05-23059, which was dismissed on March 11, 2011 in this same said court, case

no. 07-2151, see attached. The debts were not discharged.

If the Court would consider the legal circumstances surrounding my Whistleblowing

activities and the Federal False Claims Act filing of the Petitioner as it relates to the past 28 years

and the myriad of violations of the Lancaster County District Attorney, the Petitioner will argue

that it is wholly unfair and unconstitutional not to grant the Petitioner In Forma Pauperis

Case: 15-3400 Document: 003112121607 Page: 3 Date Filed: 11/04/2015

Status. The Petitioner has filed ample evidence of a pattern and relentless cycle of earning and

accumulating capital and assets, as well building substantial worth through his business interests,

only to have it all extorted through an elaborate civil and criminal scheme to defruad. Therefore

any attempt to subject the Petitioner to more court related fees is only a continuation of

that same said fraud. The above captioned case contains all the said evidence

needed to support my claims. If need be, there are several cases in the United States

District Court for the Eastern District of Pennsylvania, such as 05-2288 and 06-4650

that will suffice. In addition I am claiming that this rejection was also in retaliation for

my recent appeal to the U.S. Third Circuit Court of Appeals in regards to Lisa Lambert v.

Superintendent Framingham MCI, et al.

I am only several weeks away from a decision by a Panel of Third Circuit Judges

that may set Lisa Michelle Lambert FREE for the rest of her natural life! In addition,

before the same said panel is an argument to grant me SUMMARY JUDGEMENT in all

federal and state court cases of which I am the PLAINTIFF seeking redress.

Consideration should be given to Pederson v. South Williamsport Area School District,

where the courts interpreted due process, as “Essentially fundamental fairness is exactly what due

process means”. Furthermore, the United States District Courts in Perry v. Coyler (1978, 524 F

2d. 644) have concluded the following: “Even the probability of unfairness can result in a

defendant being deprived of his due process rights…”. The focus of these claims are recorded in

the United States District Court for the Eastern District of Pennsylvania, 05-2288 and 06-4650. In

addition the Petioner is the MOVANT in the Lisa Michelle Lambrerrt Case and recently filed a

Motion for Summary Judgment, 04-2559, which was recently appealed to the Third Circuit Court

of Appeals. The preceding cases have been preserved by the Third Circuit Court of Appeals in

case no. 07-4474, see attached.

The prosecutorial misconduct the the Petitioner has been subject to has violated his

constitutional rights, but more importantly the abuse or process has prevented the Petitioner from

completing a wealth of claims in both state and federal Courts. §1983 Civil Rights Acts and 18

U.S.C.A. Acts state the following: “The underlying purpose of the scheme of protecting

constitutional rights are to permit victims of constitutional violations to obtain redress, to provide

for federal prosecution of serious constitutional violations when state criminal proceedings are

ineffective for purpose of deterring violations and to strike a balance between protection of

individual rights from state infringement and protection from state and local government from

federal interference”, 18 U.S.C.A. §§ 241, 242; U.S.C.A. – Const. Art. 2, 53; Amend. 13, 14, 5,

15, § 2: 42 U.S.C.A. §§ 1981-1982, 1985, 1988, Fed. Rules Civil Proc. Rule 28, U.S.C.A.

Case: 15-3400 Document: 003112121607 Page: 4 Date Filed: 11/04/2015

A case can be made for a RICO violation as defined in the case of United States v. Holck,

389 F. Supp. 2d. 338, criminal responsibility defines single or multiple conspiracies by the

following: “Governments, without committing variance between single conspiracy charges in an

indictment and it’s proof at trial may establish existence at continuing core conspiracy which

attracts different members at different times and which involves different subgroups committing

acts in furtherance of an overall plan”. This illustrates the legal analysis of the 1987 conspiracy to

cover-up my International Signal & Control, Plc., whistle blowing activities.

The attached 29 False Arrests, which under Pennsylvania Law, constitute a conspiracy that

may be proved by circumstantial evidence that is by acts and circumstances sufficient to warrant

an inference that the unlawful combination has been in front of facts formed for the purpose

charged. See Walcker v. North Wales Boro, 395 F. Supp. 2d. 219. In the same case the following

was supported: “Arrestee’s allegations that the township (Conestoga) and it’s police officers were

acting in concert and conspiracy and with the purpose of violating arrestee’s constitutional rights

by subjecting him to unreasonable force, arrest, search, and malicious prosecution and the two

(2) or more officers acted together in throwing arrestee to the ground (April 5th, 2006 and August

4th, 2006) and forcing him to take two (2) blood tests and holding him in custody”. The preceding

pleaded civil conspiracy claims under Pennsylvania Law.

In order to state a claim for civil conspiracy and a cause of action under Pennsylvania Law, a

plaintiff must allege that two (2) or more persons agree or combine with lawful intent to do an

unlawful act or to do an otherwise lawful act by unlawful means, with proof of malice with intent

to injure the person, his/her property and or business. In the case of United States v. Holck, 389

F. Supp. 2d. 338, criminal responsibility defines single or multiple conspiracies by the following:

“Governments, without committing variance between single conspiracy charges in an indictment

and it’s proof at trial may establish existence at continuing core conspiracy which attracts different

members at different times and which involves different subgroups committing acts in furtherance

of an overall plan”. §1983 Civil Rights Acts and 18 U.S.C.A. Acts state the following: “The

underlying purpose of the scheme of protecting constitutional rights are to permit victims of

constitutional violations to obtain redress, to provide for federal prosecution of serious

constitutional violations when state criminal proceedings are ineffective for purpose of deterring

violations and to strike a balance between protection of individual rights from state infringement

and protection from state and local government from federal interference”, 18 U.S.C.A. §§ 241,

242; U.S.C.A. – Const. Art. 2, 53; Amend. 13, 14, 5, 15, § 2: 42 U.S.C.A. §§ 1981-1982, 1985,

1988, Fed. Rules Civil Proc. Rule 28, U.S.C.A.

Case: 15-3400 Document: 003112121607 Page: 5 Date Filed: 11/04/2015

Under RICO, a person or group who commits any two of 35 crimes—27 federal crimes and

8 state crimes—within a 10-year period and, in the opinion of the US Attorney bringing the case,

has committed those crimes with similar purpose or results can be charged with racketeering.

Those found guilty of racketeering can be fined up to $25,000 and/or sentenced to 20 years in

prison. In addition, the racketeer must forfeit all ill-gotten gains and interest in any business

gained through a pattern of "racketeering activity." The act also contains a civil component that

allows plaintiffs to sue for triple damages. When the U.S. Attorney decides to indict someone

under RICO, he has the option of seeking a pre-trial restraining order or injunction to prevent the

transfer of potentially forfeitable property, as well as require the defendant to put up a

performance bond. This provision is intended to force a defendant to plead guilty before

indictment. There is also a provision for private parties to sue. A "person damaged in his business

or property" can sue one or more "racketeers." There must also be an "enterprise." The

defendant(s) are not the enterprise, in other words, the defendant(s) and the enterprise are not

one and the same. There must be one of four specified relationships between the defendant(s)

and the enterprise. This lawsuit, like all Federal civil lawsuits, can take place in either Federal or

State court. http://www.dealer-magazine.com/index.asp?article=481

Where RICO laws might be applied1

Although some of the RICO predicate acts are extortion and blackmail, one of the most

Successful applications of the RICO laws has been the ability to indict or sanction individuals for

their behavior and actions committed against witnesses and victims in alleged retaliation or

retribution for cooperating with law enforcement or intelligence agencies. The RICO laws can be

alleged in cases where civil lawsuits or criminal charges are brought against individuals or

corporations in retaliation for said individuals or corporations working with law enforcement, or

against individuals or corporations who have sued or filed criminal charges against a defendant.

1ReferencesRICO Suave (http://www.snopes.com/language/acronyms/rico.asp) . Snopes.com: (21 December 2004).Retrieved on 2006-03-26. 1.External linksRICO Act from Cornell University'sU. S. Code database (http://www.law.cornell.edu/uscode/html/uscode18/usc_sup_01_18_10_I_20_96.html) Detail of Tanya Andersen's claim against Atlantic Records (http:/ /recordingindustryvspeople.blogspot.com/2005/10/oregon-riaa-victim-fights-back- sues.html) Retrieved from http://en.wikipedia.org/wiki/Racketeer_Influenced_a nd_Corrupt_Organizations_Act Categories: Articles with weasel words | United States federal legislation | Organized crime terminology

Case: 15-3400 Document: 003112121607 Page: 6 Date Filed: 11/04/2015

Anti-SLAPP (strategic lawsuit against public participation) laws can be applied in an attempt

to curb alleged abuses of the legal system by individuals or corporations who utilize the courts as

a weapon to retaliate against whistle blowers, victims, or to silence another's speech. RICO could

be alleged if it can be shown that lawyers and/or their clients conspired and collaborated to

concoct fictitious legal complaints solely in retribution and retaliation for themselves having been

brought before the courts. These laws also apply to victims of clergy abuse where statute of

limitations has run out.

Dated November 4 , 2015

Stanley J. Caterbone, Pro SeAPPELLANTScaterbone@Live.com1250 Fremont StreetLancaster, PA 17603717-669-2163

Case: 15-3400 Document: 003112121607 Page: 7 Date Filed: 11/04/2015

Affidavit accompanying Motion forPermission to Appeal In Forma Pauperis

United States District Court for the of _

v.

Affidavit In Support of Motion

I swear or affirm under penalty of pe~ury that,because of my poverty. I cannot prepay thedocket fees of my appeal or post a bond forthem. I believe I am entitled to redress. I searor affirm under penalty of perjury that myanswers on this form are true and correct. (28U.S.C. § 1746,18 US.C. § 1621)

Signed: _

My issues on Appeal are:

1

D.C. Case No. _

Third Cir. No. _

InstructIons

Complete all questions on this application andthen sign it. Do not leave any blanks. If theanswer to a question is '0: 'none: or 'notapplicable (N/A): write In that response. If youneed more space to answer a question or toexplain your answer, aUach a separate pieceof paper Identified with your name, your case'sdocket number. and the question number.

Date: _

Case: 15-3400 Document: 003112119016 Page: 1 Date Filed: 11/03/2015

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1. For both you and your spouse estimate the average amount of money received fromeach of the following sources during the past 12 months. Adjust any amount that wasreceived weekly, biweekly, quarterly, semiannually, or annually to show the monthlyrate. Use gross amounts, that is, amounts before any deductions for taxes or otherwise.

INCOME SOURCE AVERAGE MONTHLYAMOUNT DURING THE PAST12 MONTHS

You

AMOUNT EXPECTED NEXTMONTH

Your Spouse

Employment $ _

Self-Employment $, _

Income from real property $, _(such as rental income)

Interest and Dividends $, _

Gifts $ _

Alimony $ _

Child Support $ _

Retirement (such as social $ _security, pensions, annuities,insurance)

Unemployment payments $ _

Disability (such as social $ _security, insurance payments)

Public Assistance (such as $ _welfare)

Other (specify); $, _

Total monthly income $ _

2

$----

$,----

$----

$,---­

$---­

$---­

$,---­

$----

$---­

$----

$----

$----

$----

Case: 15-3400 Document: 003112119016 Page: 2 Date Filed: 11/03/2015

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Case: 15-3400 Document: 003112121607 Page: 9 Date Filed: 11/04/2015

2. List your employment history, most recent employer first. (Gross monthly pay is before taxes or otherdeductions.

Employer Address Dates of Employment Gross Monthly Pay

3. List your spouse's employment history, most recent employer first. (Gross monthly pay is beforetaxes or other deductions.

Employer Address Dates of Employment Gross Monthly Pay

4. How much cash do you and your spouse have? $ _

Below, state any money you or spouse have in bank accounts or in any other financial institution.

Financial Institution Type of Account Amount you have

$---­

$---­

$----

Amount your spousehas

$---­

$---­

$----

If you are a prisoner, you must attach a statement certified by the appropriate Institutional officershowing all receipts, expenditures, and balances during the last six months In your Institutionalaccounts. If you have multiple accounts, perhaps because you have been in multiple institutions,attach one certified statement for each account.

3

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5. List the assets, and their values. which you own or your spouse owns. Do not list clothing andordinary household fumishings.

Home

Motor Vehicle # 2(Value)

(Value) Other real estate (Value) Motor Vehicle # 1(Value)

Make &year:

Model:

Registration # :

Other assets (Value) Other assets (Value)

Make & year: _

Model: _

Registration #: _

6. State every person, business or organization owing you or your spouse money, and the amount owed.

Person owing you or yourspouse money

Amount owed to you Amount owed to your spouse

7. State the persons who rely on you or your spouse for support.

Name Relationship

4

Age

Case: 15-3400 Document: 003112119016 Page: 4 Date Filed: 11/03/2015

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8. Estimate the average monthly expenses of you and your family. Show separately the amounts paidby your spouse. Adjust any payments that are made weekly, biweekly, quarterly, semiannually, orannually to show the monthly rate.

You Your Spouse

Rent or Home Mortgage $ $(Include lot rented for mobilehome)Are real estate taxed

included?Dyes o no

Is property insurance included?Dyes o no

Utilities (electricity, heating fuel, $ $water, sewer, and telephone)

Home maintenance (repairs $ $and upkeep)

Food $ $

Clothing $ $

Laundry and dry-cleaning $ $

Medical and dental expenses $ $

Transportation (not including $ $motor vehicle payments)

Recreation, entertainment, $ $newspapers, magazines, etc.

Insurance (not deducted from $ $wages or included in mortgagepayments)

Homeowners or renters $ $Life $ $Health $ $Motor Vehicle $ $Other: $ $

Taxes (not deducted from $ _wages or included in mortgagepayments}(specify): _

5

$----

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Alimony, maintenance and $ $support paid to others

Regular expenses for operation $ $of business or farm (attachdetailed statement)

Other (specify): $ $

Total monthly expenses: $ $

9. Do you expect any major changes to your monthly income or expenses or in your assets or liabilitiesduring the next 12 months?

DYes D No If yes, describe on an attached sheet.

10. Have you paid __ Or will you be paying __ an attorney any money for services in connectionwith this case, Including the completion of this form?

DYes D No If yes, how much? $ _

If yes state the attorney's name, address and telephone number:

6

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11. Have you paid __ Or will you be paying __ anyone other than attorney (such as a paralegal ortypist) any money for services in connection with this case, including the completion of this form?

o Yes o No If yes, how much? $ _

If yes state the person's name, address and telephone number:

12. Provide any other information that will help explain why you cannot pay the docket fees for yourappeal.

13. State the address of your legal residence.

Your daytime telephone number:~ _

Your age: ___

Rev: 9/29/04

Your years of Schooling: _

7

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Amount owed to youHarlleysville Insurance CompanySam LombardoHigh IndustriesMike CaterboneThomas GrasselDrew Anthon/Eden Resort InnLancaster County Court ofCommon Pleas Fines & CostsPaid (Appeals Won 4/30/07)Fulton Bank

These Amounts Have Been Noncollectable for the past 5 years.

$14,000.00$1,871.00$15,221.00$10,000.00$ Amount not available$ 24,000.00$ 954.00

$ 85,000.00

Case: 15-3400 Document: 003112121607 Page: 15 Date Filed: 11/04/2015

Case 5:14-cv-02559-PD Document 18 Filed 10/01/15 Page 10 of 24Case: 15-3400 Document: 003112121607 Page: 16 Date Filed: 11/04/2015

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