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  • Copeland v. BluntCivil - Miscellaneous - Quo Warranto document preview
  • Copeland v. BluntCivil - Miscellaneous - Quo Warranto document preview
  • Copeland v. BluntCivil - Miscellaneous - Quo Warranto document preview
  • Copeland v. BluntCivil - Miscellaneous - Quo Warranto document preview
  • Copeland v. BluntCivil - Miscellaneous - Quo Warranto document preview
  • Copeland v. BluntCivil - Miscellaneous - Quo Warranto document preview
  • Copeland v. BluntCivil - Miscellaneous - Quo Warranto document preview
  • Copeland v. BluntCivil - Miscellaneous - Quo Warranto document preview
						
                                

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For Prothonotary Use Only: 7 % g PH I: You Docket No: supplement or replace the filing and service of pleadings or other papers as required by law o1 | Se po ' 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 i | Dollar Amount Requested: Ciwithin arbitration limits : 5 Are money damages requested? T) Yes No (check one) Gloutside arbitration limits | | | 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 Zoran n 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 fog | - COpYERO RECORD D spi tadoit” ANGELA L. MARTINEZ, ESQ.| DIRECTOR . OFFICE OF JUDICIAL sunpeny I L. ‘ Z, - Trial (Date) LAL . i tit. Counsel for Defendant Judge. CL Mae Atel Court Ni - Above is certified as correct. | | YZ, Crekiy. big Assistant Distyict Attorney Y Deputy Cleric,EFENDANT NAME DATE feNTRIES Bert bus Chaar ENTRIES: ei s-op Ri, ADIN Full FRO Fre — 7p. - OP E FLD RE oduy on Z Mah. 0-12-97 PHs~TRIAL CONRERENGE HEID- By ays» “tid "Wy / M4-2p- SRTER OF RULE 1100 FID NZ yO , Moa Sy UE JURE” AS Da- finiig belie Kk uL Dy aide heed. aap 2. pb terrnent: Oui el, Veber ‘0? fires SEP 15 ia GO fp A Maybe & i -3, all arsre shecyaefa) 4 Oen eh Ube ’ Mtn rat. be Demian - wwatticined tr ts pi fisebh, (hi 2 + gag sostti tir, Cho (33 on fact thse pre bat Secll. Duarte L, Vorice! het » Chhilete \-1, bd, » D3 pbebeap ada Nes “dase sgpstlcliin bnaanns Dita Lashom ves ad Duns 3, Wrote, Qaeda watz, Dpbewl bot nS, U hermes View oun nb Ahn cee ne) ee Raed atan Wi BA acute ee biti ts telat DAL a Debodl Yt gil, arte Vos we | KN lata e, aah fake Z Is Supplementary Form Used for Additional Entries? @@) No w105 12782hak, Orta ELasasd DATE ENTRIES OCKET| j.cLenK4, CLERK Jer 7-9 suoee {| Ranson. Biz 72 7 Le i Bay all costs, 2p. 3. = ad oe ims wentin the Wye 286 OL. os om COURT ROOM gf... bdrm . Perl Clock hilo “0? merges id / bn. B AOD And now to-wit" D>” the within named deft. i is sentenced or the Caurt as fol ~.To ray all cect... £ = Pov fine of B= Uncle ge fr und stam com ted until “thi 0, eentencte ke cory‘ 19 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, | 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 | 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, | all_of which is against the Act of Assembly and the peace and dignity of the Commonwealth. | 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 | . the essential elements and factual allegations thereof being set forth tnytee criminal I | 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; | 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. | | | | | | | NM zeabllidecs N 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 | 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 1 | 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