1. UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLNAIA
__________________________________________________________________________
LISA MICHELLE LAMBERT,
Petitioner
v.
LYNN BISSONETTE, SUPERINTENDENT,
MCI-FRAMINGHAM,
and
CRAIG STEDMAN, THE DISTRICT ATTOR-
NEY OF LANCASTER
COUNTY, PENNSYLVANIA
and
KATHLEEN KANE, THE ATTORNEY GEN-
ERAL OF PENNSYLVANIA,
Respondents
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: Civ. No. 5:14-cv-02559-PD
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MOTION TO FILE SUMMARY JUDGEMENT
TO THE HONORABLE, THE JUDGES OF THE SAID COURT:
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:
“Rule 56. Summary Judgment
(a) MOTION FOR SUMMARY JUDGMENT OR PARTIAL SUMMARY JUDGMENT. A party may move for
summary judgment, identifying each claim or defense—or the part of each claim or defense—on which
summary judgment is sought. The court shall grant summary judgment if the movant shows that there
is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of
law. The court should state on the record the reasons for granting or denying the motion.
(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.”
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2. MOTION FOR SUMMARY JUDGEMNT
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.
In addition the MOVANT must be restored to whole by administering SUMMARY JUDGEMENTS in
cases 05-2288; 06-4650; and all other cases filed by the MOVANT in this court. SUMMARY JUDGE-
MENTS must also be administered in Case No. 08-13373 in the Lancaster Court of Common Pleas, and
other cases filed by the MOVANT in that said court.
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3. AFFIDAVIT OF 1998 TO HONORABLE JUDGE STEWART DALZELL
“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, 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 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, 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 & Con-
trol., 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 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, 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 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
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4. 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 miscon-
duct 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 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
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
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5. 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, 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 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.”
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