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HomeMy WebLinkAbout12-1869John C Flathmann, Pro Se 2221 Gleim Court 8nola, PA 17025 John C Flathmann, Plaintiff Vs. Lawrence Van Loon, Defendant Complaint In The Court Of Common r Pleas Cumberland county, PA fa - 18( 'q 3-v)[Term Docket No.: Civil Complaint 1. Tortuous Intentional Interference with a contract 2. Conspiracy u ( ?f 4 CD (_-j - ,' ^ C..) ... . r Comes now, John C Flathmann, Plaintiff and files this complaint against Lawrence Van Loon, Defendant, and in support thereof the following facts and matters, to wit. Parties and Jurisdiction The Plaintiff is a citizen of Cumberland County and resides at 2221 Gli.em Court, Enola, PA 17025_ The Defendant is a citizen of Cumberland County and resides at 18 Stone Spring Lane, Camp Hill PA 17011 & 4io3.75 PQ Kr-;= [snm0ary of pleading] - 1 e ASW 0 d7a859 Facts I. The Defendant willfully, actively. Wrongfully and torturously interfered with the marital contract' and relationship of Plaintiff and His Wife, Suzanne Flathmann thereby causing an alienation of Mrs. Flathmann's Affections toward thel plaintiff, and by reason thereof, depriving Plaintiff of the society companionship and marital harmony to which was entitled by virtue of their Marriage contract. i 2. The Defendant committed adultery by engaging in Flathmann to which Mrs. Flathmann admitted to the Plaintiff. 3. The Defendant conspired with the Plaintiff's Wife, Mrs. Flathmann exploiting his 25 years experience with the law as a FBI Agent now retired. The Defendant and Plaintiff's Wife conspired for hours a day via telephone (which sample is attached as exhibit A). Mrs. Flathmann phoned PA DRO and immediately phoned Defendant then immediately phoned DRO and / or her attorney. Defendant assisted Plaintiff's Wife in gaining a PFA and having Plaintiff incarcerated for 90 days for violation of PFA [Summary of pleading] - 2 3/23/2012 spectfully submitted John C Flathmann, Pro Se 2221 Gliem Court Enola, PA 17025 Exhibit A sample phone records between the DRO, Attorney's, Suzanne & Larry Van Loon • Red is Suzanne Flathmann's cell phone 717-319-3908 • Blue is The Flathmann's home phone i • fC-`---_!y :hen Suzanne called Larry and then both her lawyer and dor"stic relations and then Larry again and this process we::? mans times clearly conspirip t = i == : ?!-=' __: Fla"------.. ! - c- r. ...'•- - - - - - - - - - - 12/06 8:18P 717-480-3066 Off-Peak M2MAllow Mechanicsb PA Harisbgznl PA 2 Minutes 12/06 8:20P 410-901-1475 Off-Peak N&W Mechanicsb PA Cambridge MD .24 Minutes 12/06 8:39P 410-901-1475 Off-Peak N&W Mechanicsb PA Cambridge MD 1:31 Minutes 12/06/2010 12/07 10:23A Unavailable Peak PlanAllow Mechanicsb PA Incoming CL 12/07 2:09P 717-608-9764 Peak PlanAllow Camp Hill PA Incoming CL 12/07 2:22P 410-901-1475 Peak PlanAllow Camp Hill PA Cambridge MD 12/07/2010 12/08 7:49A 410-901--1475 Peak PlanAliow Mechanicsb PA Cambridge MD 12/08 8:29A 410-901-1475 Peak PlanAllow Mechanicsb PA Cambridge MD 12/08 9:49A :.Unavailable Peak PlanAllow Mechanicsb PA Incoming CL. 12/08 9:23P 410-901-1475 Off-Peak N&W Mechanicsb PA Cambridge MD Total 157 Minutes 5 Minute, 7 Minutes 20 Minutes Total 32 Minutes 12/08/09 03:3.° Prvl CAMBRIDGE, MD 410-9C1-1475 12/08/09 06:0% PNI CAMBRIDGE, MD 410-901-1475 28 Minutes 22 Minutes 11 Minutes 1.40 Minutes 11 Minutes 33 Minutes 12/08/2010 (pathetic) Total 245 Minutes 12/09 5;53P 717-480-3066 Peak M2MAIlow Mechanicsb PA Harisbgznl PA 2 MinutP?s 2/011' ? :36F 410-901-1475 Off-Peak N&W Mechanicsb PA Cambridge ME) 14" Nlir"tt'"S 12/09/09 05:50 F'M CAMBRIDGE, MD 410-901-1475 1 Minutes 12/09109 05:51 FIN". CAMBRIDGE, MD 410-901-1475 ^linut S 12109.109 06:13 PM CAMBRIDGE. MD 410-901 .14'75 16 Plinui:es 12/09/2010 Total 163 Minutes 12111:' C:1-1P 410-901.-1475 Off-Peak PJ&W Mechanicsb PA Cambridge MD 51 Kr1Z.StpE- ? i 0:02.P 410-9Ci1-1475 Off-Peak N&W Mechanicsb PA Cambridge 'lD 28 ?<"','90r'0F' €42:37 PM CAMBRIDGE, MD 410-901-147E 1 ?iiinu'-es ;2`0+ i,? Cra.islBRiDGE, MD 410-90 1475 "> Pit t s 12/10/2010 Total 105 Minutes 121"'; 1!01 1'1::1 AM CAMBRIDGE. MD 410-1901 -14?5 32 Minu'c s i 2t i 1;0S 07:48 PIVI CAMBRIDGE, MD 410-901-14 75 12/11/2010 Total 73 Minutes 9: L "A. 410-90a-1475 Off-Peak N&W Mechanicsb PA Cambridge MD L t= , Ji 1:46A 410-90 -'475 Off-Peak N&W Mechanicsb ?A Cambridge N!" t_ , ' 1'!- Gt unavailable Off-Peak M2MAl1ow Mechanicsb PA Incomine Ci.- -2/12 3:OFP 71.7-48C-3066 Off-Peak fv12MAIIow Mechanicsb PA Harisbgzn_i i °`li"I-112/1:_' L :. SP unavailable Off-Peak M2MAIlow Mechanicsb PA Incominc; CL 13 '`'' °ute 12/12/2010 Total 31 Minutes 12113) 12:12P 717-480-3066 Off Mechanicsb PA Harisbgznl. PA 7 Mwu'Les 12/13/2010 Total 7 Minutes 12/14 8:47A Unavailable Mechanicsb PA Incoming CL 14 Minutes 12/1<1 9:1(-,A 717-480-3066 Peak M2N1Allow Mechanicsb PA Harisbgznl PA 1 Minutes 12/14 9:21A Unavailable Peak PlanAllow Mechanicsb PA Incoming CL 7 Minutes 12/14 12:45P Unavailable Peak PlanAllow Mechanicsb PA Incoming CI_ 4 Minutes 12/14 4:50P l navailable Peak M2MAllow Mechanicsb PA Incoming CL 8 Minutes 12/14/2010 Total 34 Minutes 12/15 8:37A Unavailable Peak M2MAllow Mechanicsb PA Incoming CL' 1 Minutes 12/15 8:56A 717-480-3066 Peak M2MAllow Mechanicsb PA Harisbgznl PA 24 Mine*es PC MEq.ijai . ... .. 12/15 11:38A 717-480-3066 Peak M2MAllow Mechanicsb PA Harisbgznl PA 1 Minutes K r'irV)AiN)IT '1 :j 12'1`1 11:44A 717-480-3066 Peak M2MAllow Mechanicsb PA Harisbgznl PA 2 Minutes 12/15 11:59A Unavailable Peak PlanAliow Mechanicsb PA Incoming CL. 3 Minutes 12/1~i 1:36P 717-480-3066 2MAllow Mechanicsb PA Harisbgznl PA 11 Minutes. 12/15 2:05P 717-480-3066 Peak M2MAllow Mechanicsb PA. Harisbgznl PA 1 Minutes 12/1`; 4:59P 717-480-3066 Peak M2MAllow Mechanicsb PA Harisbgznl. PA 12 Minutes 12/15 6:28P Unavailable Peak M2MAliow Mechanicsb PA Incoming CL 5 Minutes 12/1') 6:33P Unavailable Peak M2MAllow Mechanicsb PA Incoming CL 1 Mir"LfteS 12/15/2010 (15 call Pat: Tc` 7: ." _ 12/16 7:53A. 717-480-306 Mechanicsb PA Harisbgznl PA 23 Minutes 12/:16 10:43A 717-480-3066 Peak M211AIlow Mechanicsb PA Harisbgznl PA 3 Minutes 121/16:; 2:47D 717-480-3066 Peak M2MAllow Mechanicsb PA Harisbgznl PA 1 Minutes December 2009, Suzanne had checked the history on my computer (as she did daily) and learned that I was looking at Porn. Suzanne confronted me and I shared with her that I was sorry, ashamed and this would not happen again. Suzanne called me every name in the book and stated that she did not want to be married to me. After pleading with her and being condemned shamed and abused for two days, I left the house and stayed in a hotel. I spent time at nightclubs and bars. Suzanne has not worked in the whole time we were up until a couple of years ago when she stared doing part time work with permanent make-up and hiding her money from the children and used family money for plastic surgeries, Botox and countless lotions and potions. Suzanne then emptied & 12000 out of the family bank accounts and closed all of the credit cards and lines of credit. Suzanne refused to give me back the money and for weeks as I begged her to go with me to counseling. Her and my daughter started looking at town houses disrespecting (bragging about where they would live) me. Suzanne filed for a temporary protection from abuse order and was granted. I was removed from my home What I did not know at the time was that Suzanne was having an affair with Larry Van Loon which she later admitted to me that she had an affair with (ex-husband & ex FBI Agent) Larry Van Loon and was aiding her with legal advice and conspiring with her to land have the PFA put in place and ultimately in jail. Suzanne admitted to me about the affair, which came as no surprise to me at that point because I knew based on the phone records (5 hours a day) that I stumbled across while paying some bills. Suzanne told me Larry began to call her Cell Phone in November 2009 after a chance meeting @ Giant. Suzanne stated that Larry was reaching out to her based a confidential matter he was having with his daughter Becky that Suzanne abandoned 18 years earlier during their very ABUSIVE (or so Suzanne says) marriage. Just like she has abandoned our son Dylan who has special needs as he has Asperger Syndrome. Suzanne's story Sound was a complete lie and she knew she was caught especially in light of the fact that Larry and Suzanne were calling each other using blocked calls or *67 before the phone number for two months when talking Larry Van Loon should be the last person in the whole world to want to have any relationship with Suzanne or to help. Suzanne Flathmann has destroyed Larry's (just like she is doing to me now) name with anyone that would listen for the past eighteen years. She stated in detail thousands of time to everyone she knew that: Larry was a total scumbag who thinks he is above the law. Larry Van Loon forced her to get her tubes tied. I herd the following 100's of times while Suzanne and I were trying to conceive a family via IVF several times and ultimately adopting our two children "What kind of a man forces a 26 year old girl to get her tubes tied". Suzanne reported that Larry Van Loon beat her on several occasions because he was jealous. Larry cheated on her. (Saying w she could taste lip gel from another woman's lips on Larry's Private). Larry shot and killed a dog right in front of her. Larry always marked the tires on her car so he could see if she went anywhere or moved the car because he was jealous Larry kept a diary on her regarding phone calls to family and friends and making notes about conversations. Suzanne indicated Larry Van Loon told her that jean Van Loon (Larry's current wife and local physician) has clear mental challenges / depression and is not a happy person. Suzanne also stated many times that she thought it was very suspicious that Larry kept a gun in the house while his now deceased first wife was suffering from depression and ultimately killed herself. Larry was a drunk who put booze in his coffee in the morning and drank in the closet during visits from her family, not offering any alcohol to her family. Suzanne bragged to me that while married she screwed her then boyfriend (Chris Green) in Larry's bed while he was at work. So, you could understand my shock and surprise after Suzanne shared with me that she has been in a relationship with and now has such deep respect for Larry and he has been supporting her as she had me removed from the home she and I had built for 15 years. It is now clear to me that for what ever reason Larry was providing support and legal counsel to Suzanne for some time. I do have phone records, (attached) which clearly show 10 - 15 phone conversation per day between Larry and Suzanne. The calls would start at 7:00 am and many nights from 9PM (when the Flathmann Children went t to bed) till 1O'clock in the morning. I phoned Larry Van Loon's Wife jean and shared the good news and the affair stopped. Suzanne dropped the PFA / Divorce Pursuit and we began to heal as a family. I have begged Suzanne to go with me to family counseling (as I did for 18 years) so that I could work through the betrayal and hurt I suffered through her affair with Larry. Suzanne has OCD issues and has abused our two children (see attached letter from Dylan Flathmnn to his mom Suzanne) and myself for many years. After six months of individual counseling that Suzanne had been involved in with Bob Beachy, Suzanne reported to the family that she did not have issues with OCD that her counselor reported that she is simply an over achiever. After I shared this information with Larry's Wife, he has chosen to use the law to silence me and after one 5 minute phone call to his wife's cell phone, Larry contacted me to share that I was not to contact him or he will file charges against me. I made a second phone call to jean Van Loon a month later to share with her that Suzanne had admitted to me that she and Larry had committed adultery. I was issued a non-traffic violation from Jude Placey's Office for Harassment. I paid the $ 287 fine and pleaded not guilty and the case was dismissed. As soon as I shared with jean Van Loon about the affair between Larry and Suzanne, the affair ended. Then Mrs. Flathmann immediately started sexual relation with her father's Boss and The owner of Billet Manufacturing, Michael Billet. In the attached testimony from the first DRO hearing Mrs. Flathmann stated that she started sexual relations with Mr. Billet two weeks after the PFA was served. I will prove that she started sexual relations prior to any separation and / or problems with the marriage. She was dining with Mr. Billet in April of 2010 while I was in India on business, She also visited her fathers tiny welding shop which Billet Owns on several occasions. Fast forward to June 22nd. Suzanne calls Hampden Township Police to report that I had struck her after she bumped he mouth (so she stated) against my head as she was trying to hit me with her cell phone. I was arrested and charged with Simple Assault and Harassment. I spent the night in jail and was released on bail the next morning. Suzanne then went to The Hampden Township Police Dept. to report that I had tried to contact as (I needed a suit and my computer to travel for work) her in violation of the bail order. I was rearrested and spent 24 hours in general population in Cumberland County Prison. Suzanne had again obtained a PFA citing the same instances she used before resuming marital relation with me.. Suzanne upon the order being served immediately emptied all of the quality furniture and accessories out of the Flathmann Residence. It is clear to me that and Larry Van Loon conspired for months and executed a plan for Mrs. Flat Mann to move across the street with her belongings for one month and then move back to the residence without any of her belongings to bait me into the argument which she then accused me of harassment and simple assault. The phone records show for months Suzanne calling Larry Van Loon and as soon as she hung up with Larry she would phone either her attorney / DRO and so on and so forth. This whole scheme was cooked because I would not forgive Mrs. Flathmann of having and admitting to having sexual relations with Larry Van Loon and remove marital assets from The Flathmann Residence. I stated in the very first DRO hearing that Mrs. Flathmann had these affairs. The judge just ignored every truth I ever told and documented her lies. This has gone on for two years. Mrs. Flathmann had me arrested for my phone calling her phone while putting it in my pocket. Which was a 16 second aborted call on record. She had me arrested for driving by her new house. She also had me arrested for trying to see my dog. I plead guilty to all three charges at one hearing and was sentenced to 18 months probation. Then had me incarcerated in Cumberland County Prison for three month based on a text message I sent My Daughter Alana complaining about her mother. Mrs. Flathmann sent very similar text messages to our son Dylan on a daily basis. Mrs. Flathmann would not even take the stand against me during the trial instead made our 15 year old daughter the only witness to testify against her father. After spending three months in Cumberland County Prison Mrs. Flathmann came to visit me two days before release while I was a trustee in the main lobby of the prison. I was released on April 15 2010. Mrs. Flathmann spent 4 hours on the phone with me on April 16th the day after release. When I asked how we could be talking she stated that she was the one who makes the decision whether I go to jail or not. The next day April 17, 2010, Mrs. Flathmann was waiting for me at church to lead me to a seat next to her. She held my hand through the service while weeping. After church she invited my son and I back to her townhouse for lunch. After lunch Mrs. Flathmann laid with me in her bed upstairs' while the children were downstairs watching TV. Mrs. Flathmann and I were romantically hugging and kissing and at one point Mrs. Flathmann showed me her thong under wear and invited me to put my hand in her pants. We soon joined the children. Mrs. Flathmann phoned me a day later and shared with me that her ala- non-sponsor told her she could not date for one year. I explained that we were married for eighteen tears and probably past that point. I asked if I could come over to discuss it with her and Mrs. Flathmann stuck yet another knife in my heart by telling me that she already had plans with Michael Billet her then lover. I got a courtesy call the following day from Hampden PD stating that Mrs. Flathmann wanted to re-implement the PFA. I later call the Chief of Hampden Township Police and asked him how this could be possible. He stated she could basically do what ever she wants with regard to me. He also stated that his brother was in a similar situation and felt it was unfair. Fast-forward six weeks I get pulled over and arrested for DUI. My BAC was.06 however; I had pot in my system. The night before sentencing after already spend two months in county for my first DUI and three months early the same year based on a pack of lies and manipulations from Mrs. Flathmann she sends a letter to Judge Oler (which is attached) actually pleading with him to keep me in jail based on a list of defamatory accusations against me all of which were lies which meant they certainly was not proof. Mrs. Flathmann has falsely testified during everyone of the DRO hearing regarding her income. She is a certified permanent makeup artist and earns & 150.00 per hour when she woks. Mrs. Flathmann has falsified her earning to DRO for two years. Which has gone unchallenged by the support master. I finally went to the IRS Criminal Investigation Division and she will be investigated. Mrs. Flathmann once told me that Larry Van Loon her lover and ex-husband thought he was above the law. It is clear to me that Mrs. Flathmann feels like she is above the law and has made a mockery out of a system designed to protect woman from abuse. Mrs. Flathmann has been a stay at home Mom during both of her marriages. Drives a Mercedes Benz has had 5 breast augmentation operations and spent over a million dollars of Mr. Flathmann's earnings on her self and remolding the Flathmann home compulsively. I think it is time for Mrs. Flathmann to be held accountable. So, I am now raising our mentally disabled child alone with no job and $ 20K in debts for legal, fines and costs. Mrs. Flathmann earned with the $ 17000 in Alimony and Child support over $ 40,000 (that we know about) and I earned $ 7,000 (actually $ 5 K after Mrs. Flathmann filed for my unemployment benefits and emptied the account while I was in jail). As she promised to bring money to the prison for me to use on personal hygiene and telephone calls every two weeks but, she put money on my account once and left me broke the second time as she kept all of my money and for 5 weeks I had nothing. The divorce started and ended because of her adulteress affairs. I said that day one and I will not agree to anything less. I am certain that Mrs. Flathmann and her posse will not have the ability to exploit the legal system any longer to hide her affairs and gain unobstructed access to any and all marital assets the whole community is now on to her. I will also be filing civil actions against Larry Van Loon, Michael Billet for alienation of affections as well as recoup all alimony paid to Mrs. Flathmann in addition to a civil suit for defamation via the letter sent to judge Oler. PRAECIPE FOR LISTING CASE FOR TRIAL ra C3 (Must be typewritten and submitted in triplicate) -v TO THE PROTHONOTARY OF CUMBERLAND COUNTY j-- M Please list the following case: -310? CO 0, ® for JURY trial at the next term of civil court Cn z -n . ? for trial without a jury. X? x ----------------------- -------- --------------------------------------------- _--4?- ------------------- CAPTION OF CASE --? w T.ri (entire caption mast be stated in fidl) (check one) ® Civil Action - Law ? Appeal from arbitration (other) (Plaintiff) vs. The trial list will be called on G A ? , John C Flathmann and 2221 Gleim Court -- Enola, PA 17025 Trials commence on (Defendant) Pretrials will be held on / , 26 ( 2 VS. (Briefs are due 5 days before pretr' Is Lawrence Van Loon 18 Spring Stone Lame No. r Term Camp Hill, PA 17011 Indicate the attorney who will try case for the party who files this praecipe: John C Flathmann, Pro Se Indicate trial counsel for other parties if known: This case is ready for trial. el- Date: / Signed: Print N :John V Flathmann Attorney for: Pro Se (Iasti ?".2739? 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVAN IA John C Flathmann No 2012-1869 Plaintiff VS Lawrence Van Loon Civil Action Law Defendant c - ? b =a Cc r zd A = W z°= ? W VERIFICATION I verify that the statements made in this Complaint are true and correct I further verify that I am a principal in Plaintiff in Plaintiffs corporation and that I am authorized to verify this Complaint on the Plaintiff s behalf I understand that false statements herein are made subject to the penalties of 18 Pa CS 4904 relating to unsworn falsification to authorities 6V /? z Date Emily Long Hoffman, Esquire Attorney I.D. #66307 255 Market St. Millersburg, PA 17061 (717) 979-8849 FILED-OT FICE OF THE r`R0 TNCNuT ;,,?. 2012 APR 19 Pty 4: C 9 CUMBERLAND COUNTY PENNSYLVANIA Attorney for Defendant John C. Flathmann, Plaintiff V. Lawrence Van Loon, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 12-1869 Civil Term DEFENDANT'S PRELIMINARY OBJECTIONS TO PLAINTIFF'S COMPLAINT AND NOW, comes Defendant Lawrence Van Loon by and through his attorney, Emily Long Hoffinan, Esquire, and he preliminarily objects to plaintiffs complaint as follows: 1. The action set forth in the complaint alleges that Defendant willfully, actively, wrongfully and torturously interfered with the marital contact and relationship with Plaintiff and Plaintiffs former wife. 2. Defendant further avers that Defendant conspired with the Plaintiffs ex-wife. PRELIMINARY OBJECTION TO FORM OF COMPLAINT AS NO NOTICE TO DEFEND WAS ATTACHED 3. Paragraphs 1-2 are incorporated herein. 4. Pa.R.C.P. Rule 1018.18(a) requires every complaint to begin with a Notice to Defend. 5. There is not Notice to Defend on Plaintiffs complaint, therefore the pleading is facially and fatally defective. 6. The pleading being defective, Plaintiffs complaint must be stricken. PRELIMINARY OBJECTION TO FAILURE TO CONFORM TO RULES WITH REGARD TO SERVICE OF COMPLAINT 7. Paragraphs 1-6 are incorporated herein. 8. Plaintiff did not properly serve the complaint as required by the Pennsylvania Rules of Civil Procedure. 9. Plaintiff sent the mail by certified mail which was subsequently delivered to a minor child. 10. Service of the complaint was improper under Pa.R.C.P. 401. PRELIMINARY OBJECTION FOR FAILURE TO CONFORM TO LAW OR RULE OF COURT--IMPROPER VERIFICATION 11. Paragraphs 1-10 are incorporated herein. 12. There is no verification attached to plaintiffs' complaint. A true and correct copy of plaintiffs' complaint is attached as Exhibit "A". 13. Pa. R.C.P. 1024 (c) requires that a verification be attached to a pleading. 14. Under Pa.R.C.P. 1028(a)(2), a party may preliminarily object by way of a motion to strike off a pleading because of lack of conformity to rule of court. 15. Plaintiffs complaint is not properly verified as required of a pleading under Rule 1024 (a), and must be stricken. PRELIMINARY OBJECTION FOR FAILURE TO CONFORM TO LAW OR RULE OF COURT - GENERALIZED ALLEGATIONS 16. Paragraphs 1-15 are incorporated herein. 17. Paragraphs one through 3 of plaintiffs complaint violate Rule 1019(a) of the Pa. Rules of civil Procedure in that they do not state the material facts on which a cause of action is based nor are they sufficiently specific to enable Defendant to answer and prepare a proper defense. 18. There is no damage amount requested as the local rules require arbitration for certain actions. 19. Defendant is unable to ascertain whether arbitration for this matter is mandated. 20. Paragraphs one through three fail to conform to the Pennsylvania Rules of civil Procedure which require specific fact pleading and must therefore be stricken from the complaint. PRELIMINARY OBJECTION RAISING A QUESTION OF INSUFFICIENT SPECIFICITY OF A PLEADING 21. Paragraphs 1-20 are incorporated herein. 21. Pennsylvania Rule of Civil Procedure 1028(a)(3) provides that a defendant may object to a pleading because of insufficient specificity. 22. Paragraphs 1 through 3 of the complaint do not plead specific material facts sufficient to allow defendant to answer or prepare a defense and therefore it must be stricken. 23. Plaintiffs complaint fails to limit facts in a paragraph form as required by the rules of civil procedure. 24. Plaintiff fails to specify damages as required to allow Defendant to adequately respond. 25. Plaintiffs complaint must be stricken. MOTION TO STRIKE PURSUANT TO PA.R.C.P. 1028(A)(2) FOR INCLUSION OF SCANDALOUS AND IMPERTINENT MATTER 26. Paragraphs 1-24 are incorporated herein. 27. Plaintiff attached Exhibit A to his complaint which includes scandalous and impertinent material. 28. The allegations in plaintiffs complaint and exhibit A are irrelevant, immaterial and inappropriate to the cause of action asserted in plaintiffs complaint against Defendant and are in violation of the pleading requirements of Pa. R.C.P. 1019 and, accordingly, are impertinent. MOTION FOR SANCTIONS 29. Paragraphs 1-28 are incorporated herein. 30. Plaintiffs allegations in his complaint are consistent with plaintiffs attempts to harass plaintiff and his family. 31. Rule 1023.1 (d) allows the court to impose sanctions on parties that have brought vexatious and frivolous law suits. 32. Defendant will expend at least $1,000 in litigating this frivolous matter. 33. Judge Ebert is involved in the case involving Plaintiff and his ex-wife. WHEREFORE, Defendant respectfully requests that: a. Plaintiffs complaint be stricken as it is facially and fatally defective; b. any return of service filed by Plaintiff be stricken from the record; c. Plaintiffs complaint is not properly verified as required of a pleading under Rule 1024 (a), and must be stricken; d. Plaintiffs paragraphs one through three be stricken from the complaint due to noncompliance with Pa.R.C.P. Rule 1019(a); e. Exhibit A of Plaintiffs complaint must be stricken as scandalous and impertinent. f. Plaintiffs spurious "complaint" entitled Tortuous Intentional Interference with a Contract and conspiracy must be dismissed with prejudice. g. Attorney fees in the amount of $1,000 for raising these spurious allegations shall be awarded to Defendant. . R ctfully submitted, Emi y Long Hoffman Attorney for Defendant Date: April 19, 2012 John C Flatbomm F Pro go 2221 Glain Court 8nola, PA 17025 John C Flathattn, Plaintiff VS. Lawreacs Van Loon, Defendant Cawlaint In The Court Of Ca¦r?on Pleas Cumberland county, PA /a - 180 014Term Docket loo . . Civil Cv?+laint 1. Tortuous Intaatioaal Interference with a contract 2. Conspiracy G q -i can r- rv ?=' v c} r -,- -- Comes now, John C Flathmann, Plaintiff and files this complaint against Lawrence Van Loon, Defendant, and in support thereof the following facts and matters, to wit. Parties and Jurisdiction The Plaintiff is a citizen of Cumberland County and resides at 2221 Gliem Court, Enola, PA 17025. The Defendant is a citizen of Cumberland County and resides ate 18 Stone Spring Lane, Camp Hill PA 17011 41o5.15 PQ V? [8it 2 of pleading] - 1 C W 0 d7a85'9 < Facts I. The Defendant willfully, actively. Wrongfully and torturously interfered with the marital contract' and relationship of Plaintiff and His Wife, Suzanne Flathmann thereby causing an alienation Mrs. Flathmann's Affections toward thel of plaintiff, and by reason thereof, deprivin4i Plaintiff of the society companionship and marital harmony to which was entitled by virtue of their Marriage contract. 2. The Defendant committed adultery by engaging in Flathmann to which Mrs. Flathmann admitted to the Plaintiff. 3. The Defendant conspired with the Plaintiff's Wife, Mrs. Flathmann exploiting his 25 years experience with the law as a FBI Agent now retired. The Defendant and Plaintiff's Wife conspired for hours a day via telephone (which sample is attached as exhibit A). Mrs. Flathmann phoned PA DRO and immediately phoned Defendant then immediately phoned DRO and / or her attorney. Defendant assisted Plaintiff's Wife in gaining a PFA and having Plaintiff incarcerated for 90 days for violation of PFA [S=mmazy of ploadiWj - 2 3/23/2012 Enola, PA 17025 2221 Gliem Court I Exhibit A sample Phone records between the DRO, Attorney's. Suzanne & Larry Van Loon • Red is Suzanne Flathmann's cell phone 717-319-3908 • Blue Is The Flathmann's home phone • r^Mr°sc.^.f :hen Suzanne called Larry and then both her lawyer and d*mstlc relations and then Larry again and this process we;:; ; times clec dy conspiring f=- 12/06 8:18P 717-480-3066 Off-Peak M2MAIlow Mechanicsb PA Harisbgznl PA 2 Minutes 12/06 8:20P 410-901-1475 Off-Peak N&W Mechanicsb PA Cambridge MD 24 Minutes 12/06 8:39P 410-901-1475 Off-Peak N&W Mechanicsb PA Cambridge MD 131 Minutes 12/06/2010 12/07 10:23A Unavailable Peak PlanAllow Mechanicsb PA Incoming CL 12/07 2:09P 717-608-9764 Peak PlanAllow Camp Hill PA Incoming CL 12/07 2:22P 410-901-1475 Peak PlanAllow Camp Hill PA Cambridge MD 12/07/2010 12/08 7:49A 410-901.1475 Peak PlanAllow Mechanicsb PA Cambridge MD 12/08 8:29A 410-901-1475 Peak PlanAllow Mechanicsb PA Cambridge MD 12/08 9:49A Unavailable Peak PlanAllow Mechanicsb PA Incoming CL 12/08 9:23P 410-901-1475 Off-Peak N&W Mechanicsb PA Cambridge MD Total 157 Minutes 5 Minutes 7 Minutes 20 Minutes Total 32 Minutes 12/08/09 03:31" PM CAMBRIDGE, MD 410-901-1475 12/08/09 06:01 PNI CAMBRIDGE, MD 410-901-1475 28 Minutes 22 Minutes 11 Minutes 140 Minutes 11 Minutes 33 Minutes 12/08/2010 (pathetic) Total 245 Minutes 12/09 5:53P 717-480-3066 Peak 112MAllow Mechanicsb PA Harisbgznl PA 2 Minutes 12,inc, S:: 36F 410-901-1475 Off-Peak N&W Mechanicsb PA Cambridge MD 14? Miru:es 12/09/09 05:50 PM CAMBRIDGE, MD 410-901-1475 i Minutes 12109/09 05:51 PM CAMBRIDGE. MD 410-901-1475 1 Minutes 12109.109 06:16 PM CAMBRIDGE, MD 410-901-1475 15 Mlirutes 12/09/2010 Total 153 Minutes 12/1:' S:11' 410-901-1475 Off-Peak N&W Mechanicsb PA Cambridge MD 51 Mir!uteE. 1.' 10:C-P 410-901-1475 Off-Peak N&W Mechanicsb PA Cambridge MD 28 S- ? tii?ttU;ac 2 111 02:37 PNI CAMBRIDGE, MD 410-901-1475 12.1"0!'_)S* 03:'3 PM C ANIBRIDGE, MD 410-901 1475 25 P.iir _t ?s 12/10/2010 Total 105 Minutes 12.11l0? i 1:?1 AM CAMBRIDGE. MD 410-901-1475 32 Minutes 12/1 1;0S 07:18 PM CAMBRIDGE, MD 410-901-1475 4'i iii :'.1:t :'5 12/11/2010 Total 73 Minutes 12;`' 8:1 -A. ,110-901-1475 Off-Peak N&W Mechanicsb PA Cambridge MD 2 r?:ni i. :.2'1.1 8:4CA 410-911,-! 475 Off-Peak. N&W Mechanicsb PA Cambridge MD :.'!1 ?:'!CP I navailable Off-Peak M214Allow Mechanicsb PA Incoming CL 12/12 3:0FP 717-480-3066 Off-Peak M2MA11ow Mechanicsb PA Harisbgznl 12/1' a?navailabie Off-Peak M214AIlow Mechanicsb PA Incoming CL 12/12/2010 Total 12/13) '12:1.2P 717-480-3066 Off Mechanicsb PA Harisbgznl PA 12/13/2010 Total 7 W;-'Ute; 1 "1, :^• U 13 '?t' trta 31 Minutes 7 Minutes 7 Minutes 12/14 8:47A Unavailable Mechanicsb PA Incoming CL 14 Minutes 12/14 9:16A 717-480-3066 Peak M2MAIlow Mechanicsb PA Harisbgznl PA 1 Minutes 12/14 9:21.A Unavailable Peak PlanAllow Mechanicsb PA Incoming CL 7 Minutes 12/14 12:45P Unavailable Peak PlanAliow Mechanicsb PA Incoming CL 4 Minutes 12/14 4:50P Unavailable Peak M2MAIlow Mechanicsb PA Incoming CL 8 Minutes 12/14/2010 Total 34 Minutes 12/15 8:37A Unavailable Peak M2MAIlow Mechanicsb PA Incoming CL' 1 Minutes 12/15 8:56A 717-480-3066 Peak M2MAIlow Mechanicsb PA Harisbgznl PA 24 Minutes r''T ,: .{s+l !; '', ;f• ,t• ...Cl ?,.. 12/15 11:38A 717-480-3066 Peak M2MAIlow Mechanicsb PA Harisbgznl PA 1 Minutes ' - iA -!iik PianA.iio.i. 09 6'X12-MAiiuvi "M. . :n . • J ',: L}Il f E' ,TE 1' i ?'• 12/15 11:44A 717-480-3066 Peak M2MAIlow Mechanicsb PA Harisbgznl PA 2 Minutes 12/15 11:59A Unavailable Peak PlanAllow Mechanicsb PA Incoming CI. 3 Minutes 12/1i 1:36P 717-480-3066 2MAllow Mechanicsb PA Harisbgznl PA 11 Minutes 12/15 2:05P 717-480-3066 Peak M2MAIlow Mechanicsb PA Harisbgznl PA 1 Minutes 12/1'' 4:59P 717-480-3066 Peak M2MAIlow Mechanicsb PA Harisbgznl PA 12 Minutes 12/15 6:28P Unavailable Peak M2MAIlow Mechanicsb PA Incoming CL 5 Minutes 12/1'.) 6:33P Unavailable Peak M2MAIlow Mechanicsb PA Incoming CL 1 Minutes 12/15/2010 (15 call P861--t:_; Tc`z' 7: :::... ' . . 12/16 7:53A 717-480-306 Mechanicsb PA Harisbgznl PA 23 Knutes 12/16 10:43A 717-480-3066 Peak M2MAIlow Mechanicsb PA Harisbgznl PA 3 Minutes 12/10: 2:470 717-480-3066 Peak M2M,dllow Mechanicsb PA Harisbgznl PA 1 Minutes December 2009, Suzanne had checked the history on my computer (as she did daily) and learned that I was looking at Porn. Suzanne confronted me and I shared with her that I was sorry, ashamed and this would not happen again. Suzanne called me every name in the book and stated that she did not want to be married to me. After pleading with her and being condemned shamed and abused for two days, I left the house and stayed in a hotel. I spent time at nightclubs and bars. Suzanne has not worked in the whole time we were up until a couple of years ago when she stared doing part time work with permanent make-up and hiding her money from the children and used family money for plastic surgeries, Botox and countless lotions and potions. Suzanne then emptied & 12000 out of the family bank accounts and closed all of the credit cards and lines of credit Suzanne refused to give me back the money and for weeks as I begged her to go with me to counseling. Her and my daughter started looking at town houses disrespecting (bragging about where they would live) me. Suzanne filed for a temporary protection from abuse order and was granted. I was removed from my home What I did not know at the time was that Suzanne was having an affair with Larry Van Loon which she later admitted to me that she had an affair with (ex-husband & ex FBI Agent) Larry Van Loon and was aiding her with legal advice and conspiring with her to land have the PFA put in place and ultimately in jail. Suzanne admitted to me about the affair, which came as no surprise to me at that point because I knew based on the phone records (5 hours a day) that I stumbled across while paying some bills. Suzanne told me Larry began to call her Cell Phone in November 2009 after a chance meeting @ Giant. Suzanne stated that Larry was reaching out to her based a confidential matter he was having with his daughter Becky that Suzanne abandoned 18 years earlier during their very ABUSIVE (or so Suzanne says) marriage. just like she has abandoned our son Dylan who has special needs as he has Asperger Syndrome. Suzanne's story Sound was a complete lie and she knew she was caught especially in light of the fact that Larry and Suzanne were calling each other using blocked calls or *67 before the phone number for two months when talking Larry Van Loon should be the last person in the whole world to want to have any relationship with Suzanne or to help. Suzanne Flathmann has destroyed Larry's (just like she is doing to me now) name with anyone that would listen for the past eighteen years. She stated in detail thousands of time to everyone she knew that: Larry was a total scumbag who thinks he is above the law. Larry Van Loon forced her to get her tubes tied. I herd the following 100's of times while Suzanne and I were trying to conceive a family via IVF several times and ultimately adopting our two children "What kind of a man forces a 26 year old girl to get her tubes tied". Suzanne reported that Larry Van Loon beat her on several occasions because he was jealous. Larry cheated on her. (Saying w she could taste lip gel from another woman's lips on Larry's Private). Larry shot and killed a dog right in front of her. Larry always marked the tires on her car so he could see if she went anywhere or moved the car because he was jealous Larry kept a diary on her regarding phone calls to family and friends and making notes about conversations. Suzanne indicated Larry Van Loon told her that jean Van Loon (Larry's current wife and local physician) has clear mental challenges / depression and is not a happy person. Suzanne also stated many times that she thought it was very suspicious that Larry kept a gun in the house while his now deceased first wife was suffering from depression and ultimately killed herself. Larry was a drunk who put booze in his coffee in the morning and drank in the closet during visits from her family, not offering any alcohol to her family. Suzanne bragged to me that while married she screwed her then boyfriend (Chris Green) in Larry's bed while he was at work. So, you could understand my shock and surprise after Suzanne shared with me that she has been in a relationship with and now has such deep respect for Larry and he has been supporting her as she had me removed from the home she and I had built for 15 years. It is now clear to me that for what ever reason Larry was providing support and legal counsel to Suzanne for some time. I do have phone records, (attached) which clearly show 10 -15 phone conversation per day between Larry and Suzanne. The calls would start at 7:00 am and many nights from 9PM (when the Flathmann Children went t to bed) till 1 O'clock in the morning. I phoned Larry Van Loon's Wife jean and shared the good news and the affair stopped. Suzanne dropped the PFA / Divorce Pursuit and we began to heal as a family. I have begged Suzanne to go with me to family counseling (as I did for 18 years) so that I could work through the betrayal and hurt I suffered through her affair with Larry. Suzanne has OCD issues and has abused our two children (see attached letter from Dylan Flathmnn to his mom Suzanne) and myself for many years. After six months of individual counseling that Suzanne had been involved in with Bob Beachy, Suzanne reported to the family that she did not have issues with OCD that her counselor reported that she is simply an over achiever. After I shared this information with Larry's Wife, he has chosen to use the law to silence me and after one 5 minute phone call to his wife's cell phone, Larry contacted me to share that I was not to contact him or he will file charges against me. I made a second phone call to jean Van Loon a month later to share with her that Suzanne had admitted to me that she and Larry had committed adultery. I was issued a non-traffic violation from Jude Placey's Office for Harassment. I paid the $ 287 fine and pleaded not guilty and the case was dismissed. As soon as I shared with jean Van Loon about the affair between Larry and Suzanne, the affair ended. Then Mrs. Flathmann immediately started sexual relation with her father's Boss and The owner of Billet Manufacturing, Michael Billet. In the attached testimony from the first DRO hearing Mrs. Flathmann stated that she started sexual relations with Mr. Billet two weeks after the PFA was served. I will prove that she started sexual relations prior to any separation and / or problems with the marriage. She was dining with Mr. Billet in April of 2010 while I was in India on business, She also visited her fathers tiny welding shop which Billet Owns on several occasions. Fast forward to June 22nd. Suzanne calls Hampden Township Police to report that I had struck her after she bumped he mouth (so she stated) against my head as she was trying to hit me with her cell phone. I was arrested and charged with Simple Assault and Harassment. I spent the night in jail and was released on bail the next morning. Suzanne then went to The Hampden Township Police Dept. to report that I had tried to contact as (I needed a suit and my computer to travel for work) her in violation of the bail order. I was rearrested and spent 24 hours in general population in Cumberland County Prison. Suzanne had again obtained a PFA citing the same instances she used before resuming marital relation with me.. Suzanne upon the order being served immediately emptied all of the quality furniture and accessories out of the Flathmann Residence. It is clear to me that and Larry Van Loon conspired for months and executed a plan for Mrs. Flat Mann to move across the street with her belongings for one month and then move back to the residence without any of her belongings to bait me into the argument which she then accused me of harassment and simple assault. The phone records show for months Suzanne calling Larry Van Loon and as soon as she hung up with Larry she would phone either her attorney / DRO and so on and so forth. This whole scheme was cooked because I would not forgive Mrs. Flathmann of having and admitting to having sexual relations with Larry Van Loon and remove marital assets from The Flathmann Residence. I stated in the very first DRO hearing that Mrs. Flathmann had these affairs. The judge just ignored every truth I ever told and documented her lies. This has gone on for two years. Mrs. Flathmann had me arrested for my phone calling her phone while putting it in my pocket. Which was a 16 second aborted call on record. She had me arrested for.driving by her new house. She also had me arrested for trying to see my dog. I plead guilty to all three charges at one hearing and was sentenced to 18 months probation. Then had me incarcerated in Cumberland County Prison for three month based on a text message I sent My Daughter Alana complaining about her mother. Mrs. Flathmann sent very similar text messages to our son Dylan on a daily basis. Mrs. Flathmann would not even take the stand against me during the trial instead made our 15 year old daughter the only witness to testify against her father. After spending three months in Cumberland County Prison Mrs. Flathmann came to visit me two days before release while I was a trustee in the main lobby of the prison. I was released on April 15 2010. Mrs. Flathmann spent 4 hours on the phone with me on April 16ththe day after release. When I asked how we could be talking she stated that she was the one who makes the decision whether I go to jail or not. The next day April 17, 2010, Mrs. Flathmann was waiting for me at church to lead me to a seat next to her. She held my hand through the service while weeping. After church she invited my son and I back to her townhouse for lunch. After lunch Mrs. Flathmann laid with me in her bed upstairs' while the children were downstairs watching TV. Mrs. Flathmann and I were romantically hugging and kissing and atone point Mrs. Flathmann showed me her thong under wear and invited me to put my hand in her pants. We soon joined the children. Mrs. Flathmann phoned me a day later and shared with me that her ala non-sponsor told her she could not date for one year. I explained that we were married for eighteen tears and probably past that point. I asked if I could come over to discuss it with her and Mrs. Flathmann stuck yet another knife in my heart by telling me that she already had plans with Michael Billet her then lover. I got a courtesy call the following day from Hampden PD stating that Mrs. Flathmann wanted to re-implement the PFA. I later call the Chief of Hampden Township Police and asked him how this could be possible. He stated she could basically do what ever she wants with regard to me. He also stated that his brother was in a similar situation and felt it was unfair. Fast-forward six weeks I get pulled over and arrested for DUI. My BAC was.06 however; I had pot in my system. The night before sentencing after already spend two months in county for my first DUI and three months early the same year based on a pack of lies and manipulations from Mrs. Flathmann she sends a letter to Judge Oler (which is attached) actually pleading with him to keep me in jail based on a list of defamatory accusations against me all of which were lies which meant they certainly was not proof. Mrs. Flathmann has falsely testified during everyone of the DRO hearing regarding her income. She is a certified permanent makeup artist and earns & 150.00 per hour when she woks. Mrs. Flathmann has falsified her earning to DRO for two years. Which has gone unchallenged by the support master. I finally went to the IRS Criminal Investigation Division and she will be investigated. Mrs. Flathmann once told me that Larry Van Loon her lover and ex-husband thought he was above the law. It is clear to me that Mrs. Flathmann feels like she is above the law and has made a mockery out of a system designed to protect woman from abuse. Mrs. Flathmann has been a stay at home Mom during both of her marriages. Drives a Mercedes Benz has had 5 breast augmentation operations and spent over a million dollars of Mr. Flathmann's earnings on her self and remolding the Flathmann home compulsively. I think it is time for Mrs. Flathmann to be held accountable. So, I am now raising our mentally disabled child alone with no job and $ 20K in debts for legal, fines and costs. Mrs. Flathmann earned with the $ 17000 in Alimony and Child support over $ 40,000 (that we know about) and I earned $ 7,000 (actually $ 5 K after Mrs. Flathmann filed for my unemployment benefits and emptied the account while I was in jail). As she promised to bring money to the prison for me to use on personal hygiene and telephone calls every two weeks but, she put money on my account once and left me broke the second time as she kept all of my money and for 5 weeks I had nothing. The divorce started and ended because of her adulteress affairs. I said that day one and I will not agree to anything less. I am certain that Mrs. Flathmann and her posse will not have the ability to exploit the legal system any longer to hide her affairs and gain unobstructed access to any and all marital assets the whole community is now on to her. I will also be filing civil actions against Larry Van Loon, Michael Billet for alienation of affections as well as recoup all alimony paid to Mrs. Flathmann in addition to a civil suit for defamation via the letter sent to Judge Oler. VERIFICATION I, Lawrence Van Loon, the undersigned, upon my personal knowledge, information, and belief, aver that the facts averred and statements made in the attached document are true and correct to the best of my knowledge. I understand that false statements or Averments therein a will subject me to the criminal penalties of 18 Pa.C.S. Section 4904 relating to uns o falsification to author Van Loon Date: ?-. - ? C1- a 0 l -?- CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the attached document on Plaintiff by first class U.S. mail as addressed below on this day: John C. Flathmann 221 Gliem Court Enola, PA 17025 By: Emily Long Hoffinan Date: 4/19/2012 JOHN C. FLATHMANN, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. LAWRENCE VAN LOON, DEFENDANT NO. 12-1869 CIVIL ORDER OF COURT AND NOW, this 25th day of April, 2012, upon consideration of John Flathmann's Pro Se "MOTION OPPOSE THE DEFENDANTS MOTION TO OBJECT TO THE PLAINTIFFS COMPLAINT," IT IS HEREBY ORDERED AND DIRECTED that the Pro Se "Motion" shall be considered and Answer to the Defendant's Preliminary Objections; IT IS FURTHER ORDERED AND DIRECTED that the parties shall comply with Rule 1028(c) of the Rules of Court of the Ninth Judicial District, Cumberland County, file briefs as required, and list the case for Argument Court. By the Court, M. L. Ebert, Jr., J. ? John C. Flathmann 221 Gleim Court zrn -0 Enola, PA 17025; CYN Emily Hoffman, Esquire ?- 225 Market Street -- c7t: Millersburg, PA 17061' bas v/a4/a 64. al"- John C FLATHMANN Plaintiff V. Lawrene Van Loon Defendant IN THE COURT OF COMMON PLEAS OF Cumberland County, PENNSYLVANIA la-1s(o9 NO. $2-46% Civil Term C") c ` rnw 3:1. CD 2} -V 5w c_ C'A -?1 r-? t i Distribution: /off C L) Cj i ? Emily Hoffman Esq. 225 Market Street Millersburg, PA 17061 John C Flathmann 2221 Gleim Court, Enola, PA 17025 John C Flathmann PLEAS OF Plaintiff PENNSYLVANIA V. Lawrence Van Loon Defendant: CIVIL TERM rn? ok : IN THE COURT OF COMMON : Cumberland County, NO. 12-1869 PLAINFIFFS MOTION OPPOSE THE DEFENDANTS MOTION TO OBJECT TO THE PLAINTIFFS COMPLAINT AND NOW, COMES DEFENDANT, JOHN C FLATHMANN, PRO SE, AND IN SUPPORT OF HIS MOTION TO OPPOSE THE DEFENDANTS MOTION TO OBJECT THE PLINTIFFS COMPLAINT. 1. Admitted 2. Admitted 3. Admitted 4. NA 5. FILED 4/23/2012 (ADMITTED) 6. YOUR HONOR AS PPRO SE (I HAVE NO MEANS TO PROTECT MY CIVIL RIGHTS OTHER THAN TO CONTINUE TO TRY AND LEARN PRODEDURAL LAW). THE NOTICE TO DEFEND WILL BE FILED MONDAY 4/23/2012 7. Admitted 8. ADMITTED- I PROVIDED THREE COPIES TO THE CC PROYONOTARY OFFICE AS I THOUGHT WAS THE PROCEDURE. AGIAIN, I BEG THE COURTS ENDULGENTS (I HAVE NO MEANS TO PROTECT MY CIVIL RIGHTS OTHER THAN TO CONTINUE TO TRY AND LEARN PRODEDURAL LAW) 9. Admitted - I HAD NO WAY OF KNOWING A MINOR WOULD SIGN FOR THE DOCUMENTS. AGIAIN, I BEG THE COURTS ENDULGENTS 10.1 have new concrete proof of adultery, conspiracy and manipulating of the courts. 11. VERIFICATION WAS FILED (SEE ATTAHED) 12. VERIFICATION WAS FILED (SEE ATTAHED) 13. VERIFICATION WAS FILED (SEE ATTAHED) 14. VERIFICATION WAS FILED (SEE ATTAHED) 15. VERIFICATION WAS FILED (SEE ATTAHED) 16.. NA 17. Tortuous Intentional Interference of a contract and conspiracy (SEE ATTACHED COMPLAINT DATED MARCH 23/ 2012) 18. The DAMAGE AMOUNT IS $ 300,000 FOR 18 MONTHS OF LOST WAGES, LEAL FEE, COURT COST AND FINES. 19 A TRIAL BY JURY HAS BEEM SCHEDULED FOR JULY23, 2012 AGAIN, I BEG THJE COURT INDULGENCE FOR MY PRO SE LACK OF PROCEDURAL PROCESS. 20. THE SEXUAL RELATIONS BETWEE MY EX-WIFE AND THW DEFENANT WERE ADMITTED TO BE MY EX-WIFE. THE PHONE RECORDS SHOW CLEAR CONSIRACY, GUIDANCE AND LEGAL ADVICE. MY EX-WIFE PHONED THE DEFENDANT, IMMEDIATEDLY THEN PHONED DRO, IMMEDIATELY THEN PHONED THE DEFENDANT, THEN IMMEDIATELEY PHONED HER DIVOCE ATTORNEY. THIS WENT ON FOR MONTHS. THIS IS AS SPECIFIC AS ONE COULD POSSIBLY BE. 21. THE SEXUAL RELATIONS BETWEE MY EX-WIFE AND THE DEFENANT WERE ADMITTED TO BE MY EX-WIFE. THE PHONE RECORDS SHOW CLEAR CONSIRACY, GUIDANCE AND LEGAL ADVICE. MY EX-WIFE PHONED THE DEFENDANT, IMMEDIATEDLY THEN PHONED DRO, IMMEDIATELY THEN PHONED THE DEFENDANT, THEN IMMEDIATELEY PHONED HER DIVOCE ATTORNEY. THIS IS AS SPECIFIC AS ONE COULD POSSIBLY BE. Defendant desires to move forward. 22. ADULTRY, CONSPIRACY AND CIVIL RIGHT VIOLATIONS SEEM VERY CLEAR. 23. 1 THINK IT LIMITES THE FACTS CLEARLY. 24-300,000 25. ATTORNEY HOFFMAN, THE DEFANDANT AND MY-EX WIFE HAVE BEEN TYRYING FOR TWO YEARS TO SUPPRESS THE FACTS AND USE EVERY LEAGL EFFORT INEPT OR OTHERWISE TO DO SO. 26. NA 27. THIS IS NO MORE THAN A PRINT OUT OF ACTUAL PHONE RESORDE WHICH CLEARLY SPEDIFY CONSPIRACY. 28. THESE RECORDS ARE APPROPTIATE FACTUAL AND MATERIAL. 29. NA 30. THIS IS A FALSE OUTRAGEOUS AQUSATION AND NOT ATTORNEY HAOOFMAN'S FIRST. ATTORNRY HOFFMAN HAS USED THIS SAME FALSE INFORMATION (HARRASSING) AS A TACTIC DURING DIVORCE PROCEEDINGS WITH MY EX-WIFE TO SUPRESS A COUNTER AFFIDAVIT HEARING. 1 FILED A COMPLAINT WITH THE DISCIPLANARY BOARD OF THE SUPREME COUT OF PENNSYLVANIA (SEE ATTACHED.) IN TWO YEARS I HAVE SPOKEN TO THE DEFENDANTS WIFE TWICE I (IN 2010) TO SHARE WITH HER THE DICOVERY OF THE SEXUAL RELATION BETWEEN THE DEFANDANT AND MY EX-WIFE AND MY 17 YEAR OLD SON WROTE ONE LETTER TO THE DEFENDANTS WIFE. JUDGE PLACEY WHILE DISTRICT MAJESTRATE FOR HAMPDEN TOWNSHIPA DISMISSED COMPLAINT FILED BY THE DEFENDANT IN 2010 FOR SIMILAR ALLEGATIONS TO SUPRESS THE FACTS. THE DEFENDANT CALLED THE THREE PHONES I PAID FOR OVER 300 TIMES WHILE, I ALLEDGE THE DEFENDANT WAS COMMITTING ADULTRY WITH MY THEN WIFE AND COSPIRING WITH HER TO CAUSE LEGAL DAMAGE TO THE PLAINTIFF AND TO GAIN MATERIAL ASSETS. 31. THE ALLEGATINS ARE ANYTHING BUT VEXATIOUS AND FRIVOLOUS 1.Tortuous Intentional Interference of a contract and 2. Conspiracy AND VIOLATIONS OF CIVIL RIGHTS AND DOING ANYTHING IN ONE POWER TO SUPRESS EVIDENCE. THESE ARE VERY SERIOUS ALLEGATIONS AGAIN, ESPECIALLY IN LIGHT OF THE DEFENDANTS CLEAR UNDERSTANDING OF THE LAW AS A RETIRED FBI AGENT OF 25 YEARS. 32. 1 HAVE EXPENDED OVER $ 50,000 IN THE CASES SURROUNDING THE DEFENDANTS MISCONDUCT. 33. WHAT AATTORNEY HOFFMAN IS NOT SAYING HEAR IS THAT SHE AND MY EX-WIFE ARE DOING ANYTHING POSSIBLE TO HVE JUDGE EBERT SUPPRESS MY MOTION. JUDGE EBERT HAS GRANTED A HEARING REGARDING MY EFFORT TO HAVE THE PA DIVORCE CODE CHANGE FROM 3301C IRRECONCILABLE DIFFERENCES TO 3301 A ADULTRY IN THE FINAL DIVORCE DOCUMENTS WHICH, ACURATELY REFLECTS THE CAUSE OF THE FLATHMANN'S DIVORCE. ATTORNEY HOFFMAN HAS AND IS IN THE PROCESS OF DOING WHATEVER INCLUDING PROVINDEING DEFRORMTORTY AND /OR SLANDEROUS COMMENTS ABOUT THE MR. FLATHMANN. THE HEARING IS SCHEDULED FOR 12 JULY 201. 1 ALSO HAVE SCHEDULED A TRIAL BY JURY FOR THE 23RD OF JULY TO HAVE MY EX-WIFE VACATES THE 3301C PA DIVORCE CODE. FINALLY, I ASK THAT THIS COMPLAINT AND TRIAL BE PERMITTED TO MOVE FORWARD. Submitted, April 22012 Distribution: Emily Hoffman Esq. 225 Market Street Millersburg, PA 17061 John C Flathmann 2221 Gleim Court, Enola, PA 17025 ? O?SCIPLINARY 809 OF THE Paul J. Killion Chief Disciplinary Counsel Paul J. Burgoyne Deputy Chief Disciplinary Counsel SUPREME COURT OF PENNSYLVANIA OFFICE OF DISCIPLINARY COUNSEL April 19, 2012 PERSONAL AND CONFIDENTIAL John C. Flathmann 2221 Gleim Court Enola, PA 17025 Re: Emily Long Hoffman, Esquire File No. C3-12-346 Dear Mr. Flathmann: DISTRICT III OFFICE 100 Pine Street Suite 400 Harrisburg, PA 17101-1228 (717) 772-8572 FAX (717) 772-7463 www.padb.us Disciplinary Counsel-In-Charge Edwin W, Frese, Jr. Disciplinary Counsel John Francis Dougherty Joseph J. Huss This will acknowledge receipt of your April 12, 2012 complaint recently filed with this office. We will conduct appropriate reviews of the problem you have described and will contact you again either to obtain further information or to advise you of the outcome of ourinquiries and review. In the event that there is any change in the situation which you have described, please leis know. At the outset, it is important for you to know some limitations on this office's consideration of your disciplinary complaint. First, our jurisdiction and authority is limited to attempting to enforce the Rules of Professional Conduct, a set of minimum ethical standards with which all attorneys must abide. While the Rules are quite broad in their scope, they simply do not prohibit all conduct by an attorney which might be considered as unprofessional, inappropriate, or "unethical." Second, even though you have filed this complaint, this office does not represent you or your personal interests. We are not your attorney and cannot provide you with any personal legal advice. We cannot attempt to obtain any remedy or damages you might feel you are entitled to nor can we interfere with or intercede in any pending or future legal proceedings you might be involved in. We will, however, deal with your complaint in a fair and unbiased manner. Enclosed you will find a copy of your complaint form together with your original documents. If you have any further questions, please direct your inquiry tothe attention of: Suzy S. Moore, Intake Counsel Office of Disciplinary Counsel District II 820 Adams Avenue, Suite 170 Trooper, PA 19403 Phone: 610-650-8210 OFFICE OF DISCIPLINARY COUNSEL INTAKE UNIT E. STATEMENT OF COMPLAINT: (Note: Attach as many additional pages as necessary to fully set forth all of the relevan facts and circumstances surrounding your complaint). Attorney Hoffman has provided false and damaging information to the court (see attach Plaintiff to oppose Counter Affidavit. Bill of Costs, Listing of case and Discovery). Item # 26 witnin the motion states "Plaintiff continues to harrass Plaintiff despite the protection from abuse order" First she referred to me as the Plaintiff in lieu of the Defendant. Secondly I have had no contact with or harrassed the Plaintiff in any way since my incarceration which, I am attempting to prove was a result of an affair my Wife had with her Ex husband who is a reared 25 year FBI Agent which 1 have proof conspired against me to envoke a PFA against me and ultimately have me incarcerated for three months to gain access to madtital assests. Attorney Hoffman has used these types of statements which have gone unchallenged many times simply because of the fact I couldn't afford an attorney and have been representing myself Pro Se. She has taken advantage of me and the whole legal by misrepresenting virtually every tact. This is clearly defamation of character, slander, and could ultimately have me again falsely incarcerated. The Plaintiff, Mrs. Flathmann and Attorney Hoffman will stop at nothing to supress the truth. Item # 19 cliams the petition I filed against The Plaintiff is Frivolous matter. The petition I tiled is charging The Plaintiff with Adultry, False imprisonment, Providing False Testimony. These are very serious charges: certainly not frivilous. Attorney Hoffman filed on February 24th, 2011 (Attached) "PETITION FOR SPECIAL RELIEF PURSUANT TO Pa RCP1920 43 AND FOR CONTEMPT OF COURT" Items 18 through 22 of the petition were grossly exagerated to force the sale of the home while I was incarcerated via the conspiracy between The Plaintiff and ex-husband Lawrence Van Loon. I have since filed a civil lawsuit agaist Mr. Van Loon. F. C ONFIDENTIALITY Staff of the Office of Disciplinary Counsel (ODC) and the Board are required to maintain the confidentiality of complaint and related investigations and proceedings unless and until one of the exceptions to confidentiality, as set forth in Enforcemen Rule 402, applies. O DC s taff in ay i nterview t he re spondent-attorney or other p ersons w ho m ay have i nformation t hat i relevant to your complaint, and may disclose information when disclosure is permitted or required by Court or Board Rules. G. IMMUNITY Enforcement Rule 209(a) provides that any person who communicates with Disciplinary Counsel or the Board relating t, misconduct by respondent attorney or gives testimony before a ari ittee or spe ' mas r in a proceeding conducte pursuant t / Enforce lnt Rules, shall be immune from civil ui ed n such c unica ' nor testimony. (Date) (Your Signature) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVAN IA John C Flathmann No 2012-1869 Plaintiff VS Lawrence Van Loon Civil Action Law Defendant Co VERIFICATION ` C" L? I verify that the statements made in this Complaint are true and correct I further verify that I am a principal in Plaintiff in Plaintiffs corporation and that I am authorized to verify this Complaint on the Plaintiff s behalf I understand that false statements herein are made subject to the penalties of 18 Pa CS 4904 relating to unworn falsification to authorities By wb• Date JOHN C. FLATHMANN, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. LAWRENCE VAN LOON, DEFENDANT NO. 12-1869 CIVIL ORDER OF COURT AND NOW, this 25th day of April, 2012, upon consideration of John Flathmann's Pro Se "MOTION OPPOSE THE DEFENDANTS MOTION TO OBJECT TO THE PLAINTIFFS COMPLAINT," IT IS HEREBY ORDERED AND DIRECTED that the Pro Se "Motion" shall be considered and Answer to the Defendant's Preliminary Objections; IT IS FURTHER ORDERED AND DIRECTED that the parties shall comply with Rule 1028(c) of the Rules of Court of the Ninth Judicial District, Cumberland County, file briefs as required, and list the case for Argument Court. By the Court, /John C. Flathmann 221 Gleim Court Enola, PA 17025 Emily Hoffman, Esquire 225 Market Street Millersburg, PA 17061 bas N\-( M. L. Ebert, Jr., J. u, r a N N Q1 ?j -a ..a -V rv --t c, ra C ° Commonwealth of Pennsylvania - ^° County of Cumberland R' , r taare -nd-^ Laoi Vll.?? re /0 0,A) M =M -M. :Do File No 2009-86299 . <CD and n -n File No. 12-1869 w CD Motion to Quash Subpoenas & Produce Documents 1. The moving parties are husband and wife who reside at 1201 Kings Circle, Mechanicsburg, Cumberland County, PA, 17050, and are former neighbors of Plaintiff. 2. From about November 2009 through the present, Plaintiff and his estranged wife, Suzanne E. Flathmann, have had severe marital difficulties, which resulted in the Court ordering the C 4 ?i CD -r incarceration of Plaintiff on or about March of 2011 and then again in June 2011 for about three months. 3. In or about May and June of 2010, the moving parties allowed Plaintiffs wife and daughter to live in their home because they feared for their safety from Plaintiff, who, it is believed, later had PFA orders issued against him to refrain from being in close physical or other contact 4. Plaintiff seeks the moving parties' detailed phone records for 717-732-1537 (home phone) from "May 1, 2010 through June 30, 2010" in Case No. 12-1869, and from " May 10, 2010 through June 23, 2010" in Case No. 2009-8629. 5. The moving parties do not have such phone records, but on the basis of privacy for themselves and the people they communicated with per the said phone numbers, they move to Quash the said subpoena of Plaintiff. 6. Objection on the said document requests are also made on the basis that any requested information is irrelevant and intended to harass. 7. The moving parties were never personally served with the said subpoenas. WHEREFORE, the moving parties, Richard Skaare and Jane Skaare, request that this Honorable Court issue an order Quashing the subpoenas to produce documents and grant the moving parties attorneys' fees and damages in the event they have to do anything further in this matter. ?I 7LRichard Skaare a? ( / Jane Skaare Certificate of Service I, Richard Skaare, hereby say that I served the Plaintiff by depositing a copy of this Motion in the mail on May 1, 2012, and sending it to him by first class mail at: 2221 Gleim Ct Enola, PA 17025 J 1,2 Richard Skaare PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in triplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next Argument Court.) CAPTION.OF CASE (entire caption must be stated in full) John C. Flathmann -,j vs. Lawrence Van Loon 1869 201 C? No. Teg 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrfff to complaint, etc.): Defendant's Preliminary Objections. 2. Identify all counsel who will argue cases: (a) for plaintiffs: John C. Flathmann, pro se (Name and Address) 221 Gliem Court, Enola, PA 17025 (b) for defendants: Emily Long Hoffman, Esquire (Name and Address) 255 Market Street, Millersburg, PA 17061 3. 1 will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: June 1, 2012 ?r 14?,,- ? Signature Print your na e Defendant, Lawrence Van Loon 4/23/2012 Attorney for Date: INSTRUCTIONS: 1. Original and two copies of all briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) before argument. 2. The moving party shall file and serve their brief 14 days prior to argument. 3. The responding party shall file their brief 7 days prior to argument. 4. If argument is continued new briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) after the case is relisted. Dc 't JOHN C. FLATHMANN, PLAINTIFF V. LAWRENCE VAN LOON, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 12-1869 CIVIL IN RE: DEFENDANT'S PRELIMINARY OBJECTIONS BEFORE GUIDO. J. AND EBERT, J. ORDER OF COURT AND NOW, this 4th day of June, 2012, upon consideration of Defendant Lawrence Van Loon's Preliminary Objections, and Plaintiff's various responses thereto, the briefs filed by the Parties, and after oral argument; IT IS HEREBY ORDERED AND DIRECTED that Defendant's Preliminary Objections are SUSTAINED. The Complaint filed by the Plaintiff is DISMISSED WITH PREJUDICE. Plaintiff shall pay to Defendant Attorney's fees in the amount of $750.00. /John C. Flathmann, Pro Se Plaintiff 2221 Gliem Court Enola, PA 17025 Emily Long Hoffman, Esquire Attorney for Defendant 255 Market Street Millersburg, PA 17061 By the Court, 4 == __ -77 a "`kY• +FS: ,u w\ ^ w ..et ' \U \\ I, \\ ',- Cil \ . \ M L Ebert Jr . . , ., bas COP es 9,4a, leyl & Is/l?, AvG