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supplement or replace the filing and service of pleadings or other papers as required by law o1
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Se po
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Commencement of Action:
Ss Complaint 1 writ of Summons O Petition
| Er (G Transfer from Another Jurisdiction {J Declaration of Taking
| Cc Lead Plaintiff's Name: Lead Defendant’s Name:
! T Commonwealth ex rel Katayoun Copeland Bruce Edward Blunt
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| Dollar Amount Requested: Ciwithin arbitration limits
: 5 Are money damages requested? T) Yes No (check one) Gloutside arbitration limits
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| N | Is this a Class Action Suit? Yes Is thisan MDJ Appeal? © {Zl Yes No
| A | Name of Plaintiff/Appellant’s Attorney: Thomas F. Lawrie, Jr., Esquire
Check here if you have no attorney (are a Self-Represented [Pro Se] Litigant)
PRIMARY CASE. If you are making more than one type of clain
. you consider most important:
TORT (6 not include Mass Tort) CONTRACT (40 not include Judgments) | | CIVIL APPEALS
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i Intentional (2) Buyer Plaintiff Administrative Agencies
G Malicious Prosecution Debt Collection: Credit Card 1B Board of Assessment
{Gi Motor Vehicle Debt Collection: Other {i Board of Elections
Gi Nuisance {Cl Dept. of Transportation
Premises Liability 1 Statutory Appeal: Other
Product peel (does not include oc Employment Dispute:
i? iscrimination
a Sraneiighel Refemeton () Employment Dispute: Other 1B Zoning Board
SSS. i Other:
i Other: -
MASS TORT
(Bi Asbestos
[Bi Tobacco
[Gi Toxic Tort - DES
Ej Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
Bi Toxic Waste (Bi Ejectment [J Common Law/Statutory Arbitration
{3 Eminent Domain/Condemnation {Fl Declaratory Judgment
Ground Rent {E] Mandamus »
Landlord/Tenant Dispute ] Non-Domestic Relations
Gi Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABLITY (2 Mortgage Foreclosure: Commercial & x} Quo Warranto
Dental 1 Partition 2 Replevin
G Legal Quiet Title Bother: |
Medical {2 Other:
{Cl Other Professional:
Updated 1/1/2011DISTRICT ATTORNEY OF
DELAWARE COUNTY, .
PENNSYLVANIA |
BY: KATAYOUN M. COPELAND !
LD. NO. 67889
DELAWARE COUNTY COURTHOUSE
201 WEST FRONT STREET
MEDIA, PA 19063-2783
(610) 891-4161
IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY, |
PENNSYLVANIA :
CIVIL ACTION - LAW
COMMONWEALTH EX REL.
KATAYOUN COPELAND ‘
DISTRICT ATTORNEY OF DELAWARE COUNTY,
PENNSYLVANIA j
Plaintiff NOL CV> do) F> 00/065
VS.
BRUCE EDWARD BLUNT, QUO WARRANTO
MAYOR OF BOROUGH OF MORTON ‘
MORTON, PENNSYLVANIA
Defendant
NOTICE TO DEFEND ;
You have been sued in court. If you wish to defend against the claims set forth in
the following pages, you must take action within twenty (20) days after this complaint
and notice are served by entering a written appearance personally or by an attorney and
filing in writing with the court your defenses or objections to the claims set forth against
you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without further notice for any money
claimed in the complaint or for any other claim or relief requested by the plaintiff. You
may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP. |
LAWYER’S REFERENCE SERVICE |
FRONT AND LEMON STREETS
MEDIA, PA 19063
(610) 566-6625DISTRICT ATTORNEY OF :
DELAWARE COUNTY, - fk ; : wo
before me this 6th day wer Ce KR sf -Or-—
OLuf 1988 DET. R.W. \SWEISFURTH: JR.EXHIBIT Ctae.
IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY, PENNA.
Ib "CRIMINAL DIVISION
Commonwealth va.
No. 323
Sessions, 19 FJ
Transeript No.
Defendant Arraigned 2/88
pia!) Ay ek: Date
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- COpYERO RECORD
D spi tadoit”
ANGELA L. MARTINEZ, ESQ.| DIRECTOR .
OFFICE OF JUDICIAL sunpeny
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Counsel for Defendant Judge.
CL Mae Atel Court Ni
- Above is certified as correct. | |
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Assistant Distyict Attorney
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On (Or about)... ccc ee eee ences 9s neee », in said County of iplewares
wee eeeeeeeeeeaeen BRUCE EDWARD BLUNT sic ccccaeceesescesesecssesecaessdefendant, did
(1) intentionally, knowingly or recklessly cause or did attempt to qause
bodily injury to...:...¢ JOHN GALLAGHER cece eae geese MS
(2) negligently cause bodily injury to......... + em Mee Rat oo ee see
with a deadly weapon, to wit: ......... «of, Me ee eM vececeeseveesece 3
(3) attempt by physical meanace to put....OHN GALLAGHER ye geeges
in fear of imminent serious bodily injury; CERTIFIED A TRUE:
COPY FROM
THIS. a DAY,
ANGELA L, ‘MARTINEZ, ESQ., DIRECTOR
OFFICE OF JUDICIAL SUP
rad < Leh
all of which is against the Act of Assembly and the peace and dignity of the Commonwealth.
SIMPLE ASSAULT \
iin counts) Commonweal th
Act No. 334, Dec. 6,
Effective June 6, 1973 .
18 P.S., $2701 : DATE FILED ;
Penalty: (see code) 3/15/88
Attorney for
«+, the above named defendant having
..to the above charges.oo. IN THE COURT OF COMMON PLEAS ct
COUNTY OF DELAWARE, PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA CRIMINAL INFORMATION
v 1
PRICE SDMARD BLUNT won Af of (19... 88,
The District Attorney of Delaware County by this Information charges that,
on (or about) JANUARY 6th ».19..88..,.in said County of Delaware;
BRYCE EDWARD BLUNT ee cecuceelewtiaeees seeeee-defendant, did
(1) intentionally, knowingly or recklessly .cause or did attempt to cause
: TERRANCE ‘GUMPPER
bodily injury to................. TERRANCE |GUMPPER,, ns Was Mae eee cd
(2) negligently cause bodily injury to.....:... seep, sed eeeneeeaes dees
with a deadly weapon, to wit: ......... dete bonececeeeeees teeeeeee ewes 3
(3) attempt by physical meanace to put........... TERRANCE ,GUMPPER, ... pees
in fear of imminent serious bodily injury;
all.of which is against the Act of Assembly and the peace and dignity of the Commonwealth.ake IN THE COURT OF COMMON PLEAS
COUNTY OF DELAWARE, PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA CRIMINAL INFORMATION
. |
|
v
ae ee teen No.2 PF eeeeee OF 19... Pr
- The District Attorney of Delaware County by this Information charges that,
on (or about). JANUARY. 6th... eee » 19..88.., in said County of Delaware,
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beeseeeucceeeees BRUGE, EDWARD, BLUNT. o.oo... ccceeeceeeesseseseeses defendant, did
(1) intentionally, knowingly or recklessly cause or did attempt to cause
bodil y injury to.......+. MICHAEL, CASTAGLIULO,....... BR... fe veeeee 3
(2) negligently cause bodily injury tOvececees Wr cases pe eeeeneee
with a deadly weapon, to.Wit: .....-....-- vypeeeeees seeeee wee ee een teed
(3) attempt by physical meanace to put..........- MICHAEL, CASTAGLIDLO...,.....
i
in fear of imminent serious bodily injury;
all of which is against the Act of Assembly and the. peace: and dignity of the Commonwealth.IN THE COURT OF COMMON PLEAS
COUNTY OF DELAWARE
COMMONWEALTH OF PENNSYLVANIA CRIMINAL INFORMATION |
v . .
BRUCE EDWARD BLUNT No. 323 L. 19 188
The District Attorney of Delaware County by this Information charges that,
on or about Shtary Geb y 19 928,"
BRUCE EDWARD BLUNT defendant
(1) did attempt to cause, or intentionally, knowingly or recklessly did cause serious
bodily injury to __TERRANCE CUMPPER | ;
under circumstances manifesting extreme indifference to the value of human life, and/or
(2) did attempt to cause, or intentionally, knowingly, of recklessly did cause serious
bodily injury to TERRANCE GUMPPER L ;
a police officer, a firefighter in the performance of duty, or to an employee of an agency,
company or other entity engaged in. public transportation, while in the performance of
duty, and/or i
3) did attempt to cause, or intentionally or knowingly did cause bodily injury to
@) P TaRRANGE GUMBPER yinany ,
a police officer, a firefighter in the performance of duty, and/or
(4) did attempt to cause, or intentionally or knowingly did cause bodily injury to
with a deadly weapon, to wit: ; and/or
(5) did attempt to cause, or intentionally or knowingly did cause bodily injury;to
an employee or student of any elementary or secondary private school licensed by the
Department of Education or any elementary or secondary parochial school while acting
in the scope of his or her employment or because of his or her employment relationship to
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the school; . i
1
all of which is against the Act of Assembly and the peace and dignity of the Commonwealth.IN THE COURT OF COMMON PLEAS
COUNTY OF DELAWARE i
COMMONWEALTH OF PENNSYLVANIA CRIMINAL INFORMATION |
v |
BRUCE EDWARD BLUNT No. 323 19 | 88
The District Attorney of Delaware County by this Information charges that
on or about __ JANUARY_6th “1988 _|
: BRUCE EDWARD BLUNT defendant,
(1) did attempt to cause, or intentionally, knowingly or recklessly did cause serious
bodily injury to MXCHAEL CASTAGLIULO |
under circumstances manifesting extreme indifference to the value-of human life, and/or
(2) did attempt to cause, or intentionally, knowingly or recklessly did cause serious
bodily injury to MICHAEL CASTAGLIULO ‘
a police officer, a firefighter in the performance of duty, or to an employee of an agency,
company or other entity engaged in public transportation, while in the performance of
duty, and/or :
(3) did attempt to cause, or intentionally or knowingly did cause bodily injury to
MICHAEL CASTAGLIULO ,
a police officer, a firefighter in the performance of duty, and/or
(4) did attempt to cause, or intentionally or knowingly did cause bodily injury ‘to
with a deadly weapon, to wit: a and/or
(5) did attempt to cause, or intentionally or knowingly did cause bodily injury ito
{
an employee or student of any elementary or secondary private school licensed by the
Department of Education or any elementary or secondary parochial school while acting
in the scope of his or her employment or because of his or her employment relationship to
the school; . !
all of which is against the Act of Assembly and the peace and dignity of the Commonwealth.
jmkt
‘me IN THE COURT OF COMMON PLEAS '
COUNTY OF DELAWARE |
COMMONWEALTH OF PENNSYLVANIA CRIMINAL INFORMATION
y |
BRUCE EDWARD BLUNT No. 323 19 | 88
|
The District Attorney of Delaware County by this Information charges that,
on or about JANUARY 6th ,19_ 88 |
BRUCE EDWARD BLUNT
defendant,
7
(1) did attempt to cause, or intentionally, knowingly or recklessly did cause serious
bodily injury to JOHN GALLAGHER ! ,
under circumstances manifesting extreme indifference to the value of human life, and/or
(2) did attempt to cause, or intentionally, knowingly or recklessly did cause serious
bodily injury to JOHN GALLAGHER 1
a police officer, a firefighter in the performance of duty, or to an employee ofan agency,
company or other entity engaged in public transportation, while in the performance of
duty, and/or t
(3) did attempt to cause, or intentionally or knowingly did cause bodily injury to
‘Youn GALLAGHER. !
a police officer, a firefighter in the performance of duty, and/or
(4) did attempt to cause, or intentionally or knowingly did cause bodily injury to
with a deadly weapon, to wit: 1 and/or
(5) did attempt to cause, or intentionally or knowingly did cause bodily injury, to
an employee or student of any elementary or secondary private school licensed by the
Department of Education or any elementary or secondary parochial school while acting
in the scope of his or her employment or because of his or her employment relationship to
the school;
all of which is against the Act of Assembly and the peace and dignity of the Commonwealth.
AGGRAVATED ASSAULT ( 3 counts ) Mop fp, ho ¢
Act #334, Dec. 6, 1972 tha
Effective June 6, 1973
18 Pa. C.S.A. $2702 as amended
Atto
Penalty: Subsection (A) (1) & (2) DATE FILED
Felony First Degree; Subsection
(A) (3) (4) & (5) Felony Second Degree 3/15/88
And now this day of 19 , the above named defendant
having been arraigned, pleads - to the above charges.
SIGNATURE
Revised 1/87 JMS DAmic IN THE COURT OF COMMON PLEAS j
COUNTY OF DELAWARE, PENNSYLVANIA
COMMONWEALTH OF PENNSYLVANIA CRIMINAL INFORMATION
v.
323 Ly of
«+...» BRUCE EDWARD .BLUNT...... teeeeee bene eeee re NO... PEP. ee ee
The District Attorney of Delaware County by this Information charges ‘hats
on (or about)....... JANUARY .6th.....,......, 19... 88, in said County of Delaware,
BRUCE EDWARD BLUNT | +e
. . seeeeveeye defendant, did
unlawfully engage in conduct which placed or may place |
JOHN GALLAGHER, TERRANCE GUMPPER, MICHAEL CASTAGLIULO :
1
in danger of death or serious bodily injury,
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all_of which is against the Act of Assembly and the peace and dignity of the Commonwealth.
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c
RECKLESSLY ENDANGERING ANOTHER PERSON
Act #334, Dec. 6, 1972 |
DATE FILED
Effective June 6, 1973
18 Pa. C.S.A. 82705 |
lies 3/15/88.)....004.
Misdemeanor ( 2nd degree )
And now this,.,..-.---day Of ......-- veveeuvatearesns I9:eerues the above named defendant
4
to the above charges.
naving been arraigned, pleads ...... pence enna
Signature imke :
IN THE COURT OF COMMON PLEAS |
COUNTY OF DELAWARE
COMMONWEALTH OF PENNSYLVANIA CRIMINAL INFORMATION
y .
weeeeeeess BRUCE EDWARD, BLUNT, 1... cece eens ve MO ot 19....88.,
The District Attorney of Delaware County by this Information charges |that,
on or about.. JANUARY, 6th eee ee eee 19. 88..., in said County of felaware
BRUCE EDWARD BLUNT |
sete eee e cece eect e eee rete eeeeteens Seve ceccegeeeccscetectecncgoececeees defendant,
|
did, with the intent of preventing a public servant from effecting a lawful arrest or
discharging another duty, unlawfully create a substantial risk of bodily injury to the
public servant or another or did employ means justifying or requiring substantial force
to overcome the resistance, i
PUBLIC SERVANT: — wtcHART, CASTAGLIULO, TERRANCE CUMPPER, JOHN GALLAGHER |
all of which is against the Act of Assembly and the peace and dignity of the Commonwealth.
CITATION-STATUTE-SECT ION
RESISTING ARREST OR OTHER « LEM CLLLECEIER MLE OD cee
LAW ENFORCEMENT Attorney Foy e Commonwealth
Act No. 334, Dec. 6, 1972 :
Effective June 6, 1973 kK DATE FILED:
18 Pa. C.S.A., $5104) :
Misdemeanor (2nd degree) PPS sna ee ee BLTSIBB |. vee ee res
And now this......... day Of ....c ce ceeeeeeeeee 19....., the above named “efpniant having
arraigned, pleads.........ceecccccceeceee eee e et eeeeeeneees to the above charges.
eerste cee e een eeeeeeee
aad C10a we nAmkt
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. the essential elements and factual allegations thereof being set forth tnytee criminal
I
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IN THE COURT OF COMMON PLEAS
COUNTY OF DELAWARE
COMMONWEALTH OF PENNSYLVANIA CRIMINAL INFORMATION ,
‘ EB |
BRUCE, EDWARD BLUNT NO. eevee OF 19... cc eae
The District Attorney of Delaware County by this Information charges that,
on or about........6. 4 JANUARY OCB cease 19,.88....., in said County of DeTaware
BRUCE EDWARD BLUNT defendant
did commit the following summary offense. (s): : {
COUNT ONE: DISORDERLY CONDUCT 18 Pa.'C.S.A. 85503 {
complaint and/or attached affidavit filed in-the instant matter and which: are
incorporated by reference herein;
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all of which is against the Act of Assembly and. the peace and dignity of: tre Commonwealth,
CITATION-STATUTE-SECT ION
SEE ABOVE
DATE FILED
3/15/88
doce eceecenneeeerceseecters
sead R/QA IMCS NA |NOTICE OF PROPOSED JOINDER UNDER
, PA, RULE OF CRIMINAL PROCEDURE, |
RULE 1127 |
Dear Sir or Madam:
Please be advised that the Commonwealth of Pennsylvania through the District Attorney's office of
Delaware County intends to try together any and all informations contained in the following
transcripts:
BLUNT
(1) Commonwealth of Pennsylvania vs.
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NM zeabllidecs
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323-88
lo.
ATTORNEY, COMMONWEALTH
White Original-Otfice of Judicial Support: Yellow Copy-District Attorney: Pink Copy—DefendantEXHIBIT FNOTE CAREFULLY: If “Section 17” or Section 18” appears, this is 35 P.S, §§ 780-117 or-118 without adjudication of guilt
DELAWARE COUNTY COURT OF COMMON PLEAS
CERTIFICATE OF IMPOSITION OF JUDGMENT OF SENTENCE qs,
COMMONWEALTH OF PENNSYLVANIA V. Eh
Qruce
Case Record No. OTN No:
B23 - 2 QTIZVZIS-8
Charges
Info Charges Info
fas heigl sent IE) pig Goad oo Oi
Bues Ugyevatel (fedabt E.. 0; hl Cor Lave
g
Info ‘Term of Probation STATE CTY FINE
Sentence was imposed on (date) as follows:
1-7-S
AL TOTAL CONFINEMENT is imposed with regard'to the following charges:
Info Minimum Maximum Dep ___SCI__FINE
Bets] 5 mos, AB mes, | (aera
p toned, fee
L | O mas, a3 mms, uu
mn G_Oenn. ox, ft-fpe C gpm
B. PROBATION is imposed with regard to the following charges:
CERTIFIED A TRU AND CORRECT
COPY FRO RECORD
tHis/2_pay bape hold (5
ANGELA L. MARTINEY, ESQ., DIREC
OFFICE OF yh IAL SUPI
ysl | ALAR
Cc. List SPECIFIC CONDITION of CONFINEMENT or PROBATION (ie.,”
(__)Pre-release/Work Release Status (__)Partial Confinement)
Dbdte be frrtnsgtalSfuom for. @ bin Fi Ob pm.
bp & upok Tet
D. Defendant is ordered to pay RESTITUTION to the following persons:
Address
Name Sum
E. (_.) DETERMINATION OF GUILT WITHOUT FURTHER PENALTY or
( UYNO SENTENCE IS IMPOSED BECAUSE OF THE MERGER PRINCIPLE with respect to
the following charges:
Vapor" merge afbofe,b?
F, FINE ONLY (list amount and charges applicable):
i or.
G. The defendant shall receive such credit for time served as he is entitled by the laws of the Common-
wealth of Pennsylvania. The sentences, confinement, and/or probation imposed shall be consecutive or
concurrent as follows: 4 Z “Ob 1, Kms of 32
The aggregate term of confinement is a period of not less than FADS =
nor more than 23 eS.
‘The aggregate term of probation is
Costs of tion are imposed on the ( _)defendant (_)D, aan Cty
Costs of proseeution pi i Dela
) NOLLE PROSSE REMAINING CHARGES (check MK
pate:_//=2- Sf
Sentencing Judge
:
Name willl Bimduesr Name Det Atty: Quad bh tadeayEXHIBIT GCERTIFICATE
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I HEREBY CERTIFY that the attached is a true, correct and complete copy of
the 2018 Oath of Office.
WITNESS my hand and seal of the Borough of Morton, Delaware, County,
Pennsylvania, on this Jo” day ot putas 2018. I
(SEAL) Natt Lpsofr-—
Martha Preston
Secretary of the Borough of MortonBOROUGH OF MORTON '
MORTON |
DELAWARE COUNTY, PA
OATH OF OFFICE |
|, Bruce Blunt, do solemnly swear [or affirm] that | will support, obey, and defend
the Constitution of the United States and the Constitution of this Commonwealth
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and that | will discharge the duties of my office with fidelity.
Taken, sworn or affirmed and itil Ie Uf
subscribed before me this
20d day of January A.D. 2018 Su ee p