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Home My WebLink About05-4173ROBERT E. MEADE P.O. Box 58215 Washington, D.C. 20037 Plaintiff V. PATRICIA A. MILLER, ESQUIRE, c/o Walter S. B. Childs, Esquire, her attorney 145 Main Street, Annapolis, MD. 21401 * WALTER S. B. CHILDS, ESQUIRE, 145 Main Street, Annapolis, MD. 21401 AND THE ESTATE OF HELEN V. MEADE, et al. c/o Patricia A. Miller, Esq., or c/o Walter S. B. Childs, Esquire, her attorney * IN THE CIRCUIT COURT FOR CUMBERLAND COUNTY Case No. p -5?-y /13 6.t "AA, Defendants * * * * * * * * * * * * * * * * COMPLAINT Comes now, the Plaintiff and sues the Defendants and states the following: 1. The Defendants have used their judicial contacts and his judicial family lineage ties to obstruct justice and deny the Plaintiff his constitutional rights. 2. The Defendants have denied the Plaintiff from obtaining any disclosure information about the estate with the intent of self-dealing. 3. The Defendants have acted with malice towards the Plaintiff. 4. The Defendants have fraudulently made false statements. 5. The Defendants have stolen monies from the Plaintiff and from the estate. 6. The Defendants have falsely stated that they represent the Plaintiff in order to steal monies from the Plaintiff and from the estate. 7. The Defendants have abused the Plaintiff's rights to oppose the Defendants' illicit actions. 8. The Defendants have conspired with others to obstruct justice and commit cnmes. WHEREFORE, the Plaintiff, Robert E. Meade, demands judgment against Patricia A. Miller, Esquire, Walter S. B. Childs, Esquire, and the estate of Helen V.Meade, et al. for compensatory damages in the amount of nine hundred million dollars each and for punitive damages in the amount of nine hundred million dollars each. R s tfully submitted, L 78" Robert E. Meade P.O. Box 58215 Washington D.C. 20037 (202) 468-1823 REQUEST FOR A TRIAL BY JURY Dear Clerk, The Plaintiff requests a trial by jury. %-4- Robert E. Meade P.O. Box 58215 Washington D.C. 20037 C? ? -n A ` 4 ? L U1 V wr N ROBERT E. MEADE P.O. Box 58215 * IN THE CIRCUIT COURT P /cas e s Try ykI14 e 12 c? s e{, c/ FOR CUMBERLAND COUNTY RECEIPT FOR PAYMENT Cumberland County Prothonotary's Office Carlisle, Pa 17013 MEADE ROBERT E (VS) MILLER PATRICIA A ESQUIRE ET A Case Number 2005-04173 Received of PD ATTY MEADE JEM Total Non-Cash..... + 55.50 Money Order# 5952 Total Cash......... + .00 Change ............. - .00 Receipt total...... = 55.50 Distribution Of Payment Transaction Description Payment Amount COMPLAINT 35.00 TAX ON CMPLT .50 SETTLEMENT 5.00 AUTOMATION 5.00 JCP FEE 10.00 55.50 dcrlavid C,ivirN CourrA a?sc- ourr?,ovS? Sg?ar? ?_r1? i s le PA / CC7013 F1?F[)o-?:?r( f I ''dJ 49s" RoLerr E - Mec-dc C? ,V • l a,..y r, } 7-0 C .GR? Q R D SV J1DNO ®RUgR ?? G,4 x E 3'rA 7701V 2n037 Receipt Date 8/15/2005 Receipt Time 15:30:55 Receipt No. 167532 CUMBERLAND CO GENERAL FUND BUREAU OF RECEIPTS AND CONTROL CUMBERLAND CO GENERAL FUND CUMBERLAND CO AUTOMATION FUND BUREAU OF RECEIPTS AND CONTROL r AFFIDAVIT OF SERVICE I, Alma Erazo, am at least 18 years of age, competent to testify, and not a party to this action. 2. On November 15, 2005, service of the attached notices stamped by the Prothonotary and copies of the complaint filed with this Court was made upon Walter S. B. Childs, Esquire, by delivery to him via certified mail at 145 Main Street, Annapolis, Maryland 21401. Attached is the original of the certified mail receipt. I solemnly affirm under the penalties of perjury that the contents of the foregoing affidavit are true to the best of my knowledge, information and belief. AN a Erazo, Pfbcess Server P.O. Box 1002 Riverdale, Maryland 20738 (202) 974-3334 November 28, 2005 c; 1 :71 1 r.; fk? ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space penults. 1. Article Addressed to: W4Mer 5.8. Chi Ids E6fulre 145' fain Sfrce r A h n aP o l/ 3? /?ar'/ 0.h d? I'f v l RDELIVIERY0 A. X B. D. Is deliv If YES, V6 ? Agent 3. Se ce Type '..,..u, , Certified Mail 11 Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mall ? C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (rransfer from service label) PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 ROBERT E. MEADE P.O. Box 58215 Washington, D.C. 20037 Plaintiff v * IN THE CIRCUIT COURT PATRICIA A. MILLER, ESQUIRE, c/o Walter S. B. Childs, Esquire, her attorney 145 Main Street, Annapolis, MD. 21401 * WALTER S. B. CHILDS, ESQUIRE, 145 Main Street, Annapolis, MD. 21401 AND THE ESTATE OF HELEN V. MEADE, et al. c/o Patricia A. Miller, Esq., or c/o Walter S. B. Childs, Esquire, her attorney Defendants FOR CUMBERLAND COUNTY Case No. 0.5- q173 (v,; j - i- * * * * * * NOTICE 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 days (20) days after this complaint and notice are served, by entering a written appearance personally or by 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. !??„j!U' dde .ti iv rte.. Vw?q r'.Y W`.!w{?t`: xid >fystfl,"....•7 1?0{. 'r liBR: ? ;{71tLr ? !tT? ti%d?l Protharaatent ROBERT E. MEADE P.O. Box 58215 Washington, D.C. 20037 Plaintiff IV. * PATRICIA A. MILLER, ESQUIRE, c/o Walter S. B. Childs, Esquire, her attorney .145 Main Street, Annapolis, MD. 21401 IN THE CIRCUIT COURT FOR CUMBERLAND COUNTY Case No. 05 , y l7,3 aa, WALTER S. B. CHILDS, ESQUIRE, 145 Main Street, Annapolis, MD. 21401 AND THE ESTATE OF HELEN V. MEADE, et al. c/o Patricia A. Miller, Esq., or c/o Walter S. B. Childs, Esquire, her attorney * Defendants * * * * * * * * * * * * * * * * * COMPLAINT Comes now, the Plaintiff and sues the Defendants and states the following: 1. The Defendants have used their judicial contacts and his judicial family lineage ties to obstruct justice and deny the Plaintiff his constitutional rights. 2. The Defendants have denied the Plaintiff from obtaining any disclosure information about the estate with the intent of self-dealing. 3. The Defendants have acted with malice towards the Plaintiff. 4. The Defendants have fraudulently made false statements. 5. The Defendants have stolen monies from the Plaintiff and from the estate. 6. The Defendants have falsely stated that they represent the Plaintiff in order to steal monies from the Plaintiff and from the estate. 7. The Defendants have abused the Plaintiff's rights to oppose the Defendants' illicit actions. 8. The Defendants have conspired with others to obstruct justice and commit comes. WHEREFORE, the Plaintiff, Robert E. Meade, demands judgment against Patricia A. Miller, Esquire, Walter S. B. Childs, Esquire, and the estate of Helen V.Meade, et al. for compensatory damages in the amount of nine hundred million dollars each and for punitive damages in the amount of nine hundred million dollars each. R ectfully submitted(. Robert E. Meade P.O. Box 58215 Washington, D.C. 20037 (202) 468-1823 REQUEST FOR A TRIAL BY JURY Dear Clerk, The Plaintiff requests a trial by jury. aj, E, mj?- Robert E. Meade P.O. Box 58215 Washington, D.C. 20037 ROBERT E. MEADE Plaintiff V. PATRICIA A. MILLER, ESQUIRE, WALTER S. B. CHILDS, ESQUIRE, * IN THE CIRCUIT COURT * FOR CUMBERLAND COUNTY * Case No. 05-4173 Civil Term * * AND THE ESTATE OF HELEN V. OR MEADE, et al. V * R Defendants ANSWER TO MOTION RAISING PRELIMINARY WITH SUPPORTING AFFIDAVIT Comes now, the Plaintiff, Robert E. Meade, and states the following: 1. That all of the Defendants, including Walter S. B. Childs, Esquire, who is the author of the "Motion Raising Preliminary With Supporting Affidavit", are not members of the Pennsylvania Bar. Walter S. B. Childs, Esquire, not being a member of the Pennsylvania Bar, cannot answer the Plaintiff s complaint and cannot file any motion in response to the Plaintiff's complaint in the Circuit Court for Cumberland County, Pennsylvania. Walter S. B. Childs, Esquire, is representing himself, as a Pro Se Defendant attorney, and is also representing all the other Defendants, as a Pro Se Defendant attorney, without being a member of the Pennsylvania Bar. 2. That under the Constitution of the United States, Article 4, Section 2, "the Plaintiff has a right to file an action in the courts of any state to redress wrongs which have been committed against him and the Plaintiff has a right to a trial by jury". 3. That the Defendants, in order to deny the Plaintiff a fair and impartial trial by jury, filed a preliminary motion. The word "preliminary" in the Defendants' Motion always signifies to the judge of the court that the Defendants are indirectly requesting a preliminary hearing to discuss their preliminary motion. Therefore, if this Court denies the Plaintiff s request for a trial by jury, then this Court should set in a preliminary hearing for this case and the Defendants should be assessed the hearing costs and any other related costs. 4. That the affidavit presented by Walter S. B. Childs, Esquire, contains impertinent and false materials, which should be stricken by this Court. The sole purpose of presenting these materials is to prejudice this Court against the Plaintiff and to deter this Court from the merits of the complaint. "Reviewing court may not consider what trial court has done in allegedly similar, but unrelated cases, since reviewing court may not base decision on matters outside record of present case". Seibel v. Allstate his. Co., 499 A. 2d 666, 346 Pa Sup 384 appeal denied 120 A. 2d 1385, 513 Pa. 635 5. That the Defendants are requesting that this Court dismiss the Plaintiff's complaint, at the initial stage, without the Plaintiff having a right to challenge the impertinent and false materials presented by the Defendants. The Plaintiff objects to the Defendants' request, since he does not want his case decided upon by this Court from the Defendant's affidavit and from the Defendant's impertinent and false materials, which should be stricken by this Court. This Court should review the complaint according to its policy of liberal construction of complaints and drawing all inferences in the Plaintiff s favor. That, if the Plaintiffs jurisdictional predicate is defective, it should allow the Plaintiff to amend the complaint. This Court should allow this action to be maintained so that the Plaintiff can prove that jurisdiction does exist and so that the Plaintiff can prove that this Court does have the power to adjudicate the complaint. .4 - 6. That "[T]he Federal Rules of Civil Procedure do not require a claimant to set out in detail the facts upon which he bases his claim. To the contrary, all the Rules require is "a short and plain statement of the claim" that will give the defendant fair notice of what the plaintiff's claim is and the grounds upon which it rests... Such simplified "notice pleading" is made possible by the liberal opportunity for discovery and the other pretrial procedures established by the Rules to disclose more precisely the basis of both claim and defense and to define more narrowly the disputed facts and issues". Conley v. Gibson, 355 U.S. 41, 47-48, 78 S. Ct. 99, 103, 2 L Ed. 2d 80, 85 (1957) 7. That the Plaintiff is entitled to develop and present facts in support of jurisdiction. "Because subject matter jurisdiction often turns on issues of fact, the court should permit each side sufficient discovery to prove its version of jurisdictional reality and to inform the court so that a correct ruling can be made". Urquhart v. American-La France Foamite Corp., 144 F. 2d 542 (D.C. Cir 1944) 8. That this Court should abstain from dismissing the Plaintiff's complaint until both sides have presented their jurisdictional facts. WHEREFORE, the Plaintiff respectfully prays that this Court grants the Plaintiff a trial by jury and the Plaintiff prays that this Court does not dismiss the Plaintiff's complaint without, at least, having a "preliminary" hearing with the hearing costs and any other related costs assessed to the Defendants. Also, the Plaintiff prays that the impertinent and false materials, which were presented by the Defendants in their "Motion Raising Preliminary With Supporting Affidavit", be stricken by this Court. Further, the Plaintiff prays that this Court grants any additional relief as this Court deems appropriate. Re tfully submitted, C &L- Robert E. Meade P.O. Box 58215 Washington, D.C. 20037 (202) 468-1823 CERTIFICATE OF SERVICE XI I hereby certify that on the y of 2005, a copy of the foregoing was mailed, first class, postage prepaid to Patricia A. Miller, Esquire, 170 West Street, Annapolis, Maryland 21401, Walter S. B. Childs, Esquire, 145 Main Street, Annapolis, Maryland 21401, and Joel L. Katz, Esquire, 2060 West Street, Annapolis, Maryland 21401. Robert E. Meade _, - , ' .., ?? - - -?? .,- ?, _ ?-? <_, ?,? <.; =-_ ROBERT E. MEADE Plaintiff V. PATRICIA A. MILLER, ESQ., WALTER S. B. CHILDS, ESQ., AND THE ESTATE OF HELEN V. MEADE Defendants * IN THE * CIRCUIT COURT * FOR * CUMBERLAND COUNTY * CASE NO. 05-4173 CIVIL TERM * * MOTION RAISING PRELIMINARY OBJECTION WITH SUPPORTING AFFIDAVIT The Defendants, Patricia A. Miller, Esquire by Walter S. B. Childs, Walter S. B. Childs Esquire, pro se and as Successor Personal Representative of the Estate of Helen V, Meade (the "Estate"), pursuant to Cumberland County Rules of Procedure, Rule 1028 ( c), hereby file this Motion Raising Preliminary Objection with the Affidavits of Walter S.B. Childs, attached hereto, and states as follows: INTRODUCTION Without justification, in bad faith, and for the purposes of harassment and delay, Plaintiff has now filed ten lawsuits in separate jurisdictions against the Estate, and against Ms. Miller and/or her counsel, which include in addition to the instant case: (a) Baltimore City, MD (see 24-C-02-002436) (b) Washington County, MD (see 21-C-02-014154) (c) Cecil County, MD (see 07-C-03-000094) (d) Baltimore County, MD (see 03-C-02-007029) (e) Dorchester County, MD (see 09-C-03-012210) (f) Queen Anne's County, MD (see CV 10073) (g) Calvert County, MD (see 04-C-04-000309) (h) Alexandria, VA (see CH0400236); and (i) Stafford County, VA (see CL 05-047 and Exhibit B). The Plaintiff filed so many frivolous lawsuits against the Defendants that the Anne Arundel County, Maryland Circuit Court issued a permanent injunction in an effort to restrain Robert from filing more frivolous lawsuits anywhere in the State of Maryland. A true copy of that Final Injunction is attached hereto as Exhibit "A." In the most recent suit, the Circuit Court for Stafford County, Virginia dismissed Plaintiffs case with prejudice. A copy of that Order is attached hereto as Exhibit "B". For more details of Plaintiffs antics, see the Affidavit of Walter S. B. Childs attached hereto as Exhibit "C." The instant Complaint is referenced in Exhibit "C" as entry #324. As verified by Defendant, Walter S.B. Childs, there is no factual basis for jurisdiction for suit against any of the Defendants in Virginia. THIS COURT HAS NO JURISDICTION OVER THE DEFENDANTS OR THE SUBJECT MATTER OF THE COMPLAINT 1. The Defendant, Patricia A. Miller, is an attorney who has a law practice in Annapolis, Anne Arundel County, Maryland and not in Cumberland County, Pennsylvania (or anywhere in Pennsylvania). Ms. Miller resides in Anne Arundel County, Maryland and not in Cumberland County, Pennsylvania (or anywhere in Pennsylvania). Ms. Miller was (but is no longer) the court-appointed successor Personal Representative of the Estate of Helen V. Meade, deceased, currently under administration in Anne Arundel County; Maryland (see Affidavit of Walter S.B. Childs on page 4 hereof.) 2 2. The Defendant, Walter S. B. Childs, is an attorney who has a law practice in Annapolis, Anne Arundel County, Maryland and not in Cumberland County, Pennsylvania (or anywhere in Pennsylvania). Mr. Childs resides in Anne Arundel County, Maryland and not in Cumberland County, Pennsylvania (or anywhere in Pennsylvania). Mr. Childs is now the Personal Representative of the Estate of Helen V. Meade, under administration in Anne Arundel County, Maryland (see Affidavit of Walter S.B. Childs on page 4 hereof.) 3. The matters set forth in the complaint (including claims against the Estate which fails to aver where the alleged wrongs occurred or any facts to support the allegations) arise from events in the administration of the Estate of Helen V. Meade, which is under administration in Anne Arundel County, Maryland and not in Cumberland County, Pennsylvania (or anywhere in Pennsylvania). Whatever it is that Robert Meade complains of, :none of the events occurred in Cumberland County, Pennsylvania (or anywhere in Pennsylvania). The instant complaint fails to allege any basis for jurisdiction over any Defendant in Cumberland County, Pennsylvania (or anywhere in Pennsylvania). (see Affidavit of Walter S.B. Childs on page 4 hereof) 4. The Estate of Helen V. Meade is still open and under administration in the Anne Arundel County Orphans' Court See Estate No 45063) due to the unjustified, bad faith actions of the plaintiff, Robert E. Meade (hereinafter "Robert"). There is no reason for the Plaintiff to go forum shopping - seeking to have Anne Arundel County, Maryland estate administration issues reviewed in another jurisdiction (see Affidavit of Walter S.B. Childs on page 4 hereof.) 5. There is no provision of the Pennsylvania Code or Rules of Court which establishes jurisdiction against the Defendants in the Circuit Court for Cumberland County, Pennsylvania (or anywhere in Pennsylvania). (see Affidavit of Walter S.B. Childs on page 4 hereof). 3 6. There is no nexus between the named Defendants, the Estate, or the events complained of and Cumberland County, Pennsylvania (or anywhere in Pennsylvania) sufficient to make this court an appropriate venue in which to file the instant Complaint. The only Circuit Court where venue for the Plaintiffs Complaint is proper is Anne Arundel County, Maryland (see Affidavit of Walter S.B. Childs below.) 7. This Complaint is one more step in repeated efforts by Robert Meade to relocate Anne Arundel County, Maryland estate administration issues to another jurisdiction. (see Affidavit of Walter S.B. Childs below.) Robert has once again taken his practice of filing frivolous lawsuits across state lines. WHEREFORE, the Defendants respectfully request this Court to dismiss the Plaintiffs Complaint, with prejudice, and grant such other and further relief as to the court shall seem appropriate and just. SUPPORTING AFFIDAVIT OF WALTER S.B. CHILDS I, Walter S.B. Childs, verify under the penalty of perjury that the foregoing facts, along with the additional facts set forth in Exhibit "C", are true and correct to the best of my knowledge, information and belief. ? 6 1 '? - ?')' ??( ?A?I' t?A Walter S.B. Childs 4 Dated: November 18 , 2005 Respectfully submitted, ` L.IN`OWES AND BLOCHER LLP W ;? 2? ? ?J?A.-A A Walter S. B. Childs 145 Main Street Annapolis, Maryland, 21401 410-268-0881 Counsel for Defendants CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this I R1* day of November, 2005, a copy of the foregoing Motion Raising Preliminary Objection with Supporting Affidavit was served by first class mail, postage prepaid, upon: Robert E. Meade P.O. Box 58215 Washington, DC, 20037 01 1A-," t? (bAJA Walter S. B. Childs F. (Meade EstatelPleadingslCumberland Co PA MOTION RASINING PRELIMINARYINJUNCTIONDOC 5 PATRICIA A. MILLER, SUCCESSOR PERSONAL REPRESENTATIVE OF THE ESTATE OF HELEN V. MEADE Petitioner V. ROBERT E. MEADE, et a] * IN THE * * CIRCUIT COURT * FOR * ANNE ARUNDEL COUNTY * Respondents * CASE NO. C - 04-096466 t ar. ORDER GRANTING FINAL INJUNCTION After hearing on the merits, it appearing that the Respondent, Robert E. Meade was on April 23, 2004 effectively served with a writ of summons, the Petition and the orders of this court dated March 22, 2004 and April 20, 2004 and that he has failed to file an answer to the Summons or to the Petition, this court concludes that a final injunction should be entered in this action for the following reasons: The Respondent, Robert E. Meade, (hereinafter "Mr. Meade") for a number of years has been suffering from an undisclosed illness which may account, in part, for his conduct described herein. Mr. Meade has filed multiple repetitious frivolous lawsuits against the Petitioner and others in connection with the administration of the estate to such an extent that the estate cannot be closed or assets distributed unless Mr. Meade is restrained from doing so. As a result of Mr. Meade's litigious actions, the orderly administration of this estate has been frustrated and delayed. He has undertaken and continues to undertake a course of conduct which makes it impossible to economically administer the Estate to closure. The multiplicity of lawsuits EXRW filed by Mr. Meade represents an irrational, intentional, malicious, prolonged effort on the part of Mr. Meade to so tie up the administration of the Estate that the administration process cannot be completed in an orderly fashion. The time and effort on the part of the estate and on the part of the courts to deal with Mr. Meade's various filings of lawsuits has been extraordinary. The goal of fairly dispensing justice is compromised when the courts are forced to devote their limited resources to the processing of repetitious and frivolous requests. Most of Mr. Meade's complaints have been duplicative of prior frivolous lawsuits. If Mr. Meade is not restrained and is permitted to go on endlessly filing frivolous lawsuits which require the time and attention of the Petitioner and her counsel, the assets of the estate will be wholly expended in the effort to oppose such frivolous proceedings and there will be little left in the estate to distribute to the legatees. The consumption of the estate assets in defending against such frivolous litigation will result in irreparable harm to the estate and to both of its legatees, including Mr. Meade. His pattern of repetitive frivolous and malicious filings constitutes a flagrant and serious abuse of the judicial process and must be restricted. Accordingly, it is this XIV day of May, 2004, by the Circuit Court for Anne Arundel County, Maryland, ORDRED, that the Motion for an Injunction be, and the same hereby is, GRANTED; and it is further ORDERED, that an Injunction be, and hereby is, ENTERED and issued against the Respondent, Robert E. Meade; and it is further ORDERED, that Robert E. Meade, his agents, anyone acting on his or their behalf and each of them, be and they are hereby ENJOINED and prohibited from filing in any court of this State a lawsuit, complaint, petition or any similar form of civil action against Patricia A. Miller, 2 her counsel, Walter S. B Childs, or any other person, entity or authority relating in any way to the Estate of Helen V. Meade, its administration or any act by such persons, entities or authorities in connection with such estate or arising from their role as Personal Representative, Administrator or Counsel to the Estate (the "Restricted Lawsuits") without first complying with the following provisions of this Injunction: 1. Robert E. Meade is required to obtain leave of this court prior to filing any of the Restricted Lawsuits. 2. In seeking leave of court to file any new action, Robert E. Meade must certify that the claim or claims he wishes to present are new claims never before raised and disposed of on the merits by any court and never before possible to be raised, asserted or disposed of by any court. He must also certify that the claim or claims are not frivolous or taken in bad faith. 3. The motion for leave to file must be captioned: "Application pursuant to Court Order Seeking Leave to File" and Mr. Meade must affix a copy of this Injunction to that motion. 4. Failure to strictly comply with the terms of this Injunction will be sufficient grounds for denying leave to file and will subject Mr. Meade to contempt of this court's order. 5. Failure to strictly comply with the terms of this Injunction will be sufficient grounds for the immediate dismissal without prejudice of any action filed in violation of such Injunction. And it is further, ORDERED, that this Injunction shall be served promptly on the Respondent, Robert E. Meade by regular and certified mail and shall be binding on him or upon any other person at the time they actually receive verbal or written notice of its issuance. 3 ORDERED: That the clerk of this court shall, within five (5) days of the date of this order, mail to the Clerks of the Circuit Courts in the State of Maryland a test copy of this Injunction. for Anne Copies to: Robert E. Meade P.O. Box 2260 Landover Hills, MD 20784 Joel L. Katz, Esq. 2060 West Street Annapolis, MD 21401 F:Wleade Estate\Pleadings\Ex Porte InjunctiontrO DOG Patricia A. Miller, Esq. 170 West Street Annapolis, MD 21401 Walter S.B. Childs, Esq. 145 Main Street Annapolis, MD 21401 I, RobertP. Dackworth, Clerk of the C.SrtatitCorm forAnneAtut W fnetyr, hereby certify that this is a true copy from the record in this COUIL Witness the )=d and act ofthe undersigned this R -5'4Z of 20 Cit'Cait Cmurt forAm -Arundel Euniy, Matyland 4 E. MEADE Plaintiff V. PATRICIA A. MILLER, ESQ., WALTER S. B. CHILDS, ESQ., AND THE ESTATE OF HELEN V. MEADE and * IN THE * CIRCUIT COURT * FOR * STAFFORD COUNTY * CASE NO. CL 05-047 * * ALAN LEGUM, ESQ., Defendants * * ORDER Upon the consideration of the Plea in Bar filed on behalf of Patricia A. Miller, Esq., Walter S.B. Childs, Esq. and the Estate of Helen V. Meade and Alan Legum, Esq. (the "Defendants"), the Court having held a hearing on October 17, 2005, and it appearing to this Court that it lacks both subject matter and personal jurisdiction over Defendants, it is this I -/-/-A, day of October, 2005, ORDERED, that the Plaintiff's Complaint be and the same is hereby dismissed, with prejudice. Jud ircuit Court for Stafford County We =as" A COPY TESL. P20gi -M' ael weeny Barbara G. Decatur, CLERK ini Bar o. 339 CULT COURT OF STAFFORD Wisconsin Av ue, 81h Floor 1. Bethesda, Marylan 20814-4842 2 7 Counsel for Defendants EXHIBIT "B" We ask for this: Vo1!69, G?G?iuv Robert E. Meade P.O. Box 4054 Arlington, Virginia 22204 Plaintiff cc: Robert E. Meade P.O. Box 4054 Arlington, Virginia 22204 Paul Sweeney 7200 Wisconsin Avenue, 8th Floor Bethesda, Maryland 20814-4842 i L&B 500365v1/09000.0002 Last updated November 18, 2005 ESTATE OF HELEN V. MEADE ADMINISTRATION CHRONOLOGY OR TIME LINE 2. 5. 6. 8. 9. 10. 11 12/13/99 Helen Meade dies in an automobile accident. Prior to her death, Robert Meade was residing with the decedent, his mother. 1/10/00 Juanita Hundley is appointed as initial Personal Representative and finds that all personal papers, stocks, etc. have been removed from the home. 7/10/00 Robert Meade files a (1) notice of objection to the appointment of Hundley as PR (2) notice of objection to the appraisal and also (3) a claim against the estate for $200,000 for such things as mowing his mother's lawn for 26 years. 7/14/00 Robert files a petition to restrain the PR and keep her off of the estate's property. 7/18/00 The Orphans' Court issues an order making Hundley a special administrator and requiring her to make an appointment before entering the property 8/3/001 Aversa attorney for the estate, writes to Laumann, Robert's attorney, to put him on notice to have Robert begin paying rent at $700 per month 8/9/00 Hundley files a Petition to discover assets under oath at a hearing. 8/24/00 Hundley files a denial of Robert's claim for $200,000. 8/29/00 Orphans' Court sets hearing for December 14th on issues of removal of PR Hundley, Objection to the Appraisal (see # 3) and the Petition to discover assets (See #7) 9/8/00 Anne Arundel County sends a violation notice that the grass is not being cut. By this date Robert seems to have abandoned the property. 9/14/00 Hundley files a motion to rescind the order of 7/18 (See 45) and permit her to have access to the property without having to have an appointment. EXHIBIT C 12. 10/3/00 The Orphans' Court denies Hundley's petitions to rescind the order of 7/18 and orders that the PR meet with Robert on October 26s' at 4:00 PM at the property. The court also orders that the hearing on December 14`" include an explanation as to why rent has not been asked for or received. 13. 10/10/00 Hundley petitions for authority to seek summary ejectment of Robert 14. 10/10/00 Joel Katz moves for sanctions against Robert 15. 10/13/00 Laumann files a motion for leave to withdraw appearance 16. 10/20/00 Robert files a motion for allowance of his claim for $200,000, for grass cutting, etc. (See #3 & 8) 17. 10/20/00 Robert files opposition to Hundley's petition for Summary Ejectment (see #13) 18. 10/23/00 Robert files a "Motion to ... Modify Order Concerning Entrance into the Real Property" to restrict access to the house to Hundley and no one else (not her husband, her friends, her relatives, her attorney, etc) and she can only bring a pencil, pad and inventory list when she comes in, etc. 19. 10/24/00 Robert files a "Motion For Continuance of Hearing" to continue the hearing set for 12/14/00 (See #12) saying that he will be out of the country for the months of December 2000 and January 2001. 20. 10/26/00 The Orphans' Court denies Robert's motion (see #19) and separately orders that the PR and Robert meet at the property to inventory the tangible personal property and retrieve mail. The court issues a "clarification" of its order of 10/3 (See # 12.) and says that any hindrance by Robert would be contempt of court. 21. 10/30/00 Joel Katz files a notice of deposition of Robert. 22. l l/l/00 Robert files a "Motion for Appropriate Relief' to avoid being deposed. (See #21) 23. 11/2/00 The Orphans' Court denies Robert's Motion for Continuance (see #18) denies Robert's motion for "relief' to avoid bring deposed (See #22) denies Laumann's request for leave to withdraw as Robert's attorney until the December 14`" hearing. (See #15) 24. 11/9/00 Robert files a "Motion to oppose depositions" by Joel Katz. (see #21 &22) 25. 11/9/00 The Orphans' Court denies Robert's motion filed that day to "Oppose Deposition." The deposition is set to begin at 3:00 PM, but Robert fails to appear. Likewise, Alama Erazo fails to appear. 26. 11/17/00 Laumann files a "Motion for Reconsideration" of his request to withdraw appearance because Robert refuses to follow his advice and wants to file inappropriate motions. 27. 11/20/00 Joel Katz files a "Motion for Sanctions" against Robert and a motion to compel deposition testimony. 28. 11/21/00 Robert files a second "Motion for Continuance of Hearing" to postpone the hearing set for December 14th. This has already been denied once (See #23) 29. 12/5/ 00 Orphans' Court denies Robert's motion to postpone hearing a second time (See #28; the first was #23) 30. 12/11/00 Erazo, through her attorney, Camus moves for a protective order to avoid being deposed. 31. 12/12 00 Robert moves for a protective order to avoid being deposed. This has already been denied once. See # 23 Robert also asks the court to reconsider its denial of his motion for continuance (see #29) his third request. 32. 12/12/00 Laumann asks for a postponement on the basis of kidney stone problems. 33. 12/12/00 The Orphans' Court grants Laumann's request to withdraw his appearance and postpones the Dec 14th hearing. 34. 12/12/00 Robert "fires" his attorney Laumann. and files a motion for a protective order requesting that "there be no discovery, allowed" and files a motion to reconsider sanctions. 35. 1/8/01 Robert writes two separate long letters to the court and says he is searching very hard to find an attorney and wants nothing to be scheduled until he has found an attorney and completed discovery. 36. 1/16/01 Orphans' Court sets hearing for 3/29/01 on sanctions, protective orders and motion for reconsideration filed by Robert; a total of 10 motions. 37. 3/29/01 Orphans' Court orders Robert and Alama Erazo to give a deposition (See 430 & 31) and will rule on the sanctions motion (see 927) at a later date. 38. 4/5/01 Orphans' Court files decision imposing sanctions on Robert on Joel Katz's motion for $2,500 + $500 and ordered Robert to attend his deposition and produce the stock certificates, insurance policies and coin collection. 39. 4/6/01 Joel Katz files a notice to take video deposition of Robert on April 30th at 1:00 PM. 40. 4/9/01 Joel Katz files amended notice of Deposition of Alma for April 24th at 11:30 AM. 41. 4/9/01 Hundley files a motion in Orphans' Court for authorization to sell the property 42. 4/23/01 Robert files a "Motion for Reconsideration"' of the March 29th proceeding (see #37 & 38) at which he was sanctioned, and files a separate "Motion for Rehearing" of the decision to impose sanctions. 43. 4/23/01 Alama Erazo files a "Motion for Protective Order" to a continuance of her deposition for alleged medical reasons. 44. 4/24/01 The Orphans' Court denies Erazo's motion for Protective Order re her deposition. 45. 4/25/01 Robert files opposition to the motion for authorization to sell the property. (See #41) 46. 4/26/01 The Orphans' Court denies Robert's motion for reconsideration & motion for rehearing (see #42). 47. 4/26/01 Robert files an "Emergency Motion for Continuance of Deposition" to delay his video deposition so he can get an attorney. (See #35) 48. 4/30/01 The Orphans' Court denies Robert's Emergency Motion for Continuance of his video Deposition. 49. 4/30/01 Alma Erazo fails to appear at her deposition. 50. 4/30/01 Robert arrives late for his deposition and is deposed but refuses to cooperate, respond to questions, disclose his employment, etc. 51. 5/1/01 The Orphans' Court by Order approves the sale of the property by directive and by court order authorizing the PR to sell the property "for the highest price obtainable". The court notes that the PR is acting as Special administrator. The order of July 18, 2000 (see # 5) is rescinded. 4 52. 5/2/01 Joel Katz files a notice of deposition of Alma Erazo for May 7, 2002 at 1:30 PM 53. 5/7/01 Robert appeals to the circuit court the decisions of the Orphans' Court Orders dated 4/5,(see #38) 26 (see 446) and. 5/01 (see #51)and any additional orders made thereafter to date. This appeal becomes C-2001- 72141.OC. 54. 5/11/01 Robert writes to Aversa saying he will not voluntarily vacate the residence and that Aversa will have to start eviction proceedings; cc to the court file. 55. 5/15/01 The estate files eviction proceedings in District Court to have Robert evicted from the property. 56. 5/21/01 Robert moves for a postponement of the August 23, 2001 hearing so he can get an attorney and have a new appraisal. See #47 & 35. 57. 5/24/01 Robert moves for reconsideration of the May 1st decision which approved the sale (see # 51) 58. 5/25/01 Joel Katz moves for Sanctions against Robert for his refusal to cooperate in his deposition (See #50). 59. 5/24/01 Robert files with the Register a "Motion for Extension" asking to hold orders to the end of the case. 60. 5/24/01 Robert files separate motions to reconsider the decision of May 1, 2001 postpone the hearing set for August 23`d(which he says was meant to replace the 9ostponed hearing of December 14d' see #33) to September 27 . 61. 5/29/01 Robert files to postpone the district court proceeding saying he wants to hire an attorney (see # 57, 47 & 35). 62. 6/01/01 Joel Katz files a notice to depose Robert on 6/22/01 at 10:30AM 63. 6/04/01 Joel Katz files a motion to have the Orphans' Court issue a $3,000 monetary judgment against Robert for the amount of the sanctions ordered on 4/5/01 (See #38) 64. 6/05/01 The Orphans' Court denies Robert's motion for extension (See #59) 65. 6/07/01 The Orphans' Court denies Robert's motion (see # 57) to postpone the August 23`d hearing and denies Robert's motion to reconsider the decision of May 1 authorizing the sale. (See #51) 66. 67. 68. 69. 70. 71. 72. 73. 6/07/01 Robert files an answer to Joel's motion for sanctions (see # 58) and asks the court to "issue a body attachment of Joel L. Katz." 6/11/01 Robert files exceptions to Hundley's 2nd account citing no substantial reasons for excepting. 6/14/01 The Orphans' Court schedules to be heard on 8/23 the petition to Remove PR; petition to discover assets; petition for allowance of claim filed by Robert & the Objection to appraisal and exceptions to the second account 6/19/01 The Orphans' Court schedules to be heard on 10/11 motion for sanctions filed by Joel Katz. (see # 58) 6/28/01 PR files in Orphans' Court a motion for authorization to pay for a bond to get the stocks reissued. 6/30/01 The District Court orders that the estate have possession of the premises. 8/13/01 Robert asks the Circuit Court for a postponement of the hearings set for 9/26 and 10/11 to 11/15 no reason given, 8/16/01 The Orphans' Court issues a "Directive" to remind all parties that at the hearing on 8/23/01 there will be no interrupting the other party during presentation, statement or otherwise. 74. 8/20/01 The circuit court (Judge Silkworth) denies Robert's request to postpone the de novo appeal (see #72). 75 76 8/22/01 The day before the scheduled hearing, Robert files in Orphans' Court a "Motion for Removal" to take the case away from the Orphans' Court claiming it is not the proper "MENUE for litigating a case." 8/23/01 Following a hearing the Orphans' Court denies 1. Robert's motions to remove the PR, 2. Robert's objection to the appraisal, 3. Robert's claim for $200,000 (see #3) and 4. Robert's exceptions to Hundley's second account and Grants 5. authority to use estate funds to post bond and 6. Hundley's petition to discover assets 77 8/23/01 Robert files an amended notice of appeal (see # 53) to include all orders from 5/7 through August 23rd 6 78. 8/23/01 Hundley by letter to the Register, requests leave to resign as PR 79. 8/27/01 Joel Katz recommends P. Miller, Esq. be appointed to serve as Successor PR 80. 8/30/01 Robert fails to appear at the hearing on the estate's Motion to dismiss Robert's appeal in case No. C-2001-7214LOC (See #53) and the Circuit Court (Lerner, J.) dismisses Robert's appeal and awards sanctions 81. 8/30/01 Robert appeals to the court of Special Appeals the circuit court ruling dismissing his appeal to the circuit court. C-2001-7214LOC 82. 9/4/01 The Orphans' Court by directive refuses to permit Robert to appeal all decisions from May 7 to August 23rd saying it cannot accept an amended appeal. (See #77). 83. 9/6/01 The Orphans' Court denies Robert's motion for removal (see #75) 84. 9/17/01 Joel Katz files a "Motion for Attorney's Fees and Expenses under Rule 1- 341. 85. 9/24/01 Robert files in Orphans' Court a "Notice of Appeal" to the circuit court the decisions of the Orphans' Court "from May 7, 2001 to and including August 23, 2001" 86. 9/25/01 The Orphans' Court by directive says it will not accept the notice of appeal (see #85) each Appeal must be filed separately. 87. 9/27/01 The Orphans' Court by directive accepts Hundley's resignation and designates P. Miller as Successor PR upon the filing of her papers. 88. 10/9/01 Robert files an "Emergency motion ... for Continuance" of the hearing set for October 11 on sanctions (See # ) claiming among other things illness and sadness over the 9/11 WTC tragedy. 89. 10/9/01 Robert files a motion for reconsideration of Order accepting resignation by Hundley. 90. 10/9/01 The Orphans' Court, by Judicial Probate Order, appoints Patricia A. Miller as Successor PR. 91. 10/9/01 Robert files an appeal to the Circuit Court from the decision made on September 6, 2001. 92. 10/10/01 Joel Katz files opposition to Robert's motion for continuance (see 488) and a "Motion for Bad Faith" sanctions. 93. 10/11/01 The Orphans' Court at a hearing on sanctions denies Robert's motion for continuance (see #84) and enters sanctions of $500 to Joel Katz. (see #84) 94. 10/10/01 Robert, by "Corrected Notice of Appeal", appeals to the circuit court the August 23`d order. (See #76) 95. 10/11/01 The Orphans' Court denies Robert's motion for reconsideration. (see #85) 96. 10/16/01 The Orphans' Court grants Joel's motion (see #84) for sanctions $500 + $500. 97. 10/16/01 The Orphans' Court issues a show cause order for Robert to appear on December 4, 2001 and show cause why he failed to comply with the order of April 5, 2001 (see #38) regarding production of stock certificates etc. 98. 10/18/01 The Orphans' Court issues a decision entering judgment against Robert for $5,000 fees to Joel Katz $11,000 for costs of the GE stock $35,000 for the coin collection $1,242 to Joel Katz for stenographer costs. 99. 10/29/01 Robert files an appeal from the rulings of the Orphans' Court made on September 27th. (see #87). 100. 10/30/01 The Orphans' Court issues an clarification of its order of 9/6/01 denying the removal. 101. 11/1/01 The Orphans' Court by Order rules that no pleadings be sent to Robert until he provides a proper address. 102. 11/8/01 Robert files a Motion for Supersedeas in the Court Of Special Appeals. 103. 11/13/01 The Orphans' Court issues a directive that it will no longer send mail to Robert at 102 Wallace Ave. 104. Same day Robert files a Motion for Supersedeas in the Circuit Court (see #102) 105. 11/13/01 Robert files an appeal to the Circuit Court the orders of October 11, 2001 and says it relates to the order to pay Joel Katz $500. 106. 11/15/01 Robert files in Orphans' Court an "Emergency Objection to the Selling" of the property. 107. 11/15/01 Robert files in Orphans' Court an appeal to the Circuit Court the order of October 16`" which imposed sanctions (See # 96) 108. 11/19/01 Robert files an appeal to the Circuit Court the Orphans' Court decision of October 18, 2001 (See #98) which imposed sanctions on him. 109. 11/25/01 Robert files in circuit court a "Petition for a Supersedeas" seeking to stay all actions of the Orphans' Court and suspend all earlier orders until all of his appeals are heard. 110. 11/26/01 111. 11/26/01 Robert writes to Ms. Miller and advises that he opposes any action by her to try to sell the home and that he opposes all actions by her and "insist(s)" that she proceed in his chosen manner. Robert files in circuit court an "Emergency Motion to Enjoin the Sale" until all his appeals are heard by the appeals court. 112. 11/ 27/01 Robert files in Orphans' Court a "Notice of Objection" to the appointment of Ms. Miller as PR and petitions for her removal. He files a line to change his address to PO Box in Landover. 113. 11/27/01 Robert files in Orphans' Court a "Petition to Restrain" Ms. Miller from selling the home because of the pending appeal. 114. 11/28/01 The Court of Special Appeals denies Robert's Motion for a Supersedeas (see # 102) 115. 12/3/01 Robert files in circuit court an "Emergency Motion for Reassignment" seeking to have the administrative judge replace the Orphans' Court Judges. 116. 12/4/01 At a hearing before the Orphans' Court on a show cause for contempt re order of April 5th (see # 38) Robert fails to appear. 117. 12/5/01 Robert writes to the Orphans' Court seeking to excuse his failure to appear on December 4a' and attaches a medical record dated December 4`h 118. 12/10/01 Robert writes to Judge Greene opposing a special assignment. He wants a separate Judge for each of his appeals. 119. 12/19/01 Robert files in Orphans' Court exceptions to Hundley's third Account. 120. 12/20/01 Judge Caroom denies Robert's Petition for a Supercedeas (see#104) denies Robert's Motion for reassignment (see #115 denies Robert's Emergency Motion to Enjoin Sale (see #111) 121. 12/20/01 The Orphans' Court schedules a hearing for 4/4/02 on 1. Robert's Objection to Appointment of Ms. Miller as Successor PR and Petition for removal 2. Robert's objection to the selling of the Real Property 3. Robert's Petition to Restrain the Successor PR. 4. Hundley's Petition for a PR Commission 5. Aversa's claim for counsel fees 6. Exceptions to Hundley's third account 122. 1/9/02 On the estate's motion filed 12/28/01 Judge Silkworth consolidates all seven of Robert's appeal cases C-2001 72141, 75816, 75818, 76107, 76474, 76499, and 76617 and sets a scheduling conference for 2/1/02. 123. 1/14/02 The estate files interrogatory questions for answer by Robert. Answers are due on or about 2/14/02. 124. 1/14/02 Robert files a "Non-conforming" Brief in the Court of Special Appeals #01342 (see #81). 125. 1/15/02 Robert files an opposition to the 12/28 motion to consolidate cases. 126. 1/17/02 The estate files a request for production of documents by Robert. Answers are due on or about 2/17/02 127. 1/18/02 Robert writes to Miller and threatens criminal action 128. 1/22/02 Robert files a motion to Continue the hearing set for 2/1/02 AND a motion to reconsider the order to consolidate the cases (See #120). He informs Judge Silkworth by letter that he has to have a separate judge to hear each appeal. 129. 1/22/02 Robert files an appeal to the Court of Special Appeals (his second) from the denial of his motion for Supersedeas by Judge Caroom (see 4119). Note that the CSA has already denied the same relief sought by Robert filing a similar petition in that court (See #114). Robert files in the court of special appeals an objection to the substitution of parties (Miller for Hundley) in #01342 September Term 2001. Robert files in Orphans' Court a Motion to Quash a Subpoena Duces Tecum for Robert's medical records. 130. 1/23/02 The Court of Special Appeals rules that Robert's appeal #01342 (See #124) will be dismissed unless he files a corrected brief by February 15`" 10 131. 2/1/02 Robert fails to appear at scheduling conference before Judge Silkworth (see #122). The conference is rescheduled for 2/22/02 to be heard with Robert having an opportunity to show cause why all of his appeals should not be dismissed. Judge Silkworth declines to issue a body attachment for Robert but rules that the clerk is not to accept for filing any motion, appeal, pleading or paper which does not comply with Rule 1-311. 132. 2/8/2002 Robert files an appeal to the CSA from the ruling which consolidated the cases (see #122) 133. 2/12/02 Orphans' Court orders a hearing for 6/04 on Robert's objection to the appointment of Miller + pet. to have her removed Robert's objection to selling the real estate Robert's petition to restrain Miller 134. Same Day Orphans' Court orders a hearing for 6/11 on Robert et al's Exceptions to Juanita's petition for a commission. Robert et al's exceptions to Aversa's petition for attorney's fees Miller et al's exceptions to the third account 135. 2/12/2002 Robert writes to Judge Green asking for intervention on his behalf. 136. 2/19/2002 Estate files a proposal for distribution of the estate. 137. 2/21/2002 Robert faxes to Judge Silkworth a letter saying he will not appear at the show cause hearing and attaching a December 4, 2001 medical record which he has used before. See #117 138. 2/22/2002 Robert fails to appear at the hearing on the motion to show cause why his appeals should not be dismissed. Judge Silk:worth dismisses the appeals from the Orphans' Court. 139. 2/25/02 Estate files motion for sanctions for Robert's failure to show up for hearings on 2/1/02 & 2/22/02 140. 3/8/02 Robert files motion for reconsideration of the dismissal (see #138) 141. 3/13/02 Estate files interrogatories and a request for production of documents in Orphans' Court 142. 3/14/02 Estate files a notice of discovery for deposition for Robert set for April 9 143. 3/14/02 Estate files an amended plan of distribution 144. 3/19/02 Katz files motion for sanctions against Robert in Circuit Court 11 145. 3/20/02 Estate files motion for sanctions on behalf of Patricia re Robert's failure to show up for hearings on 2/1/02 & 2/22/02 146. 3/20/02 The Court of Special Appeals rules that Robert' appeal shall be submitted on brief and taken out of assignment for oral argument 147. 3/21/02 Robert files an objection to the amended plan of distribution (see #143) 148. 3/25/02 Estate files petition for authority to make distribution of house to Robert and equivalent cash to Roger 149. 3/25/02 Robert files a timely appeal to the order of Judge Silkworth (see #138) dismissing his 6 appeals from the Orphans' Court to the Circuit court 150. 3/28/02 Orphans' Court Orders that no papers are to be received from Robert unless he provides a residence address and phone number 151. 3/29/02 Robert files a motion to Quash his deposition set for April 9, 2002. 152. 4/2/02 Register of Wills sends Robert's motion to quash back to him (see #150 & #151) 153. 4/8/02 Robert files in Circuit Court a motion to rescind the order which required Robert to provide his address (see # 150) 154. 4/9/02 Robert fails to appear for his deposition called for by the estate. 155. 4/9/02 Orphans' Court Orders that Robert's motion to rescind order (see #153) is denied. motion to enjoin sale of property (see # 113) is denied motion to Quash (see #151) is denied and Sanctions of $322.25 were imposed on Robert in favor of the estate. 156. 4/8/02 Robert seeks to have oral argument on his appeal in the Court of Special Appeals (see # 146) 157. 4/15/02 Robert files a motion to quash the interrogatories and request for production (see # 141). 158. 4/16/02 Estate files motion for sanctions against Robert for failure to respond to discovery and requests relief to include a default order. 159. 4/25/02 Orphans' Court denies Robert's motion to Quash the notice of Deposition (see 4151) 12 160. 4/26/02 Robert files in Orphans' Court a Motion to Remove the estate administration to Baltimore City. 161. 4/26/02 Robert files in Circuit Court a motion for Sanctions against Childs, Katz and Miller. 162. 5/3/02 Robert files in Orphans' Court a motion for Sanctions against Childs, Katz and Miller. 163. 5/6/02 Robert (by Alma) files a motion to postpone the hearing 164. 165 5/6/02 Robert fails to appear at the hearing in the Circuit Court (on Robert's appeal) before Judge Silkworth. The judge rules that 5/7/02 166. 5/15/02 167. 5/20/02 the motion to postpone was denied. the estate's motion ne re regarding the appeal of February 8 (see # 130) was denied Robert's motion for sanctions (see #153) was denied and sanctions against Robert were entered for $430. Robert's motion to Rescind Order (see # 150) was denied and the estate's cross motion for sanctions was granted imposing sanctions of $1,075 on Robert and ruling that the clerks were not to accept any papers from Robert. Sanctions were entered in favor of Trish for having to appear on 2/1 & 2/22 for $600. Sanctions were entered in favor of the Estate for Childs having to appear on 2/1 & 2/22 for $1,075. Sanctions were entered in favor of Joel Katz for having to appear on 2/1 & 2/22 for $1,250 and in favor of Roger Meade for $288.46 on the same dates. The Orphans' Court Denies Robert's Motion to Quash Interrogatories and Request for Production of Documents (see 4159) Robert files in Baltimore City (424-C-02-002436) a 10 Billion Dollar Lawsuit against Patricia Miller and prays for a jury trial. Robert files in Washington County (#21-C-02-014154) a 1.2 Billion Dollar Lawsuit against Miller and Childs and prays for a jury trial. 13 168. 5/29/02 Robert files in Baltimore City Circuit Court a Complaint against the "Orphans' Court" and the "Circuit Court for Anne Arundel County" seeking 900 Billion Dollars damages. 169. 5/30/02 The Court of Special Appeals issues an order directing that Robert Show Cause why his appeal #2408 (see #129) should not be dismissed for failure to include transcripts of hearings 170. 6/3/02 Robert files his first petition for Cert to the Maryland Court of Appeals (#197) 171. 6/6/02 Robert fails to appear at the hearing before the Orphans' Court. Following hearing, the Court Orders that Robert is in default for failure to provide discovery and matters are to be taken as established, an order in the nature of a default judgment is entered. Robert's motion to remove to Baltimore City is dismissed and sanctions are entered for $430.00 The estate's petition for authority to make first distributions is approved 172. 6/11/02 Robert fails to appear at the hearing before the Orphans' court. Following the hearing, the court orders that Sanctions are imposed on Robert for $1,290 in costs of obtaining the order of default (see #171) arising from his failing to respond to discovery requests. Tom Aversa/Hundley must file an amended Third Account in accord with the estate's position. Tom Aversa is entitled to be paid fees from the estate for $10,400.00. Ms. Handley is entitled to reimbursement of $47.25 in costs but no commission. 173. 6/17/02 Robert files transcripts in the Court of Special Appeals for appeal #2408 (see #169). 174. 6/26/02 Robert files in the Court of Appeals his second Cert Petition (#258). 175. 7/8/02 Robert files in the Court of Appeals his third Cert Petition (#276). 176. 7/8/02 Robert files in the Court of Appeals his fourth Cert Petition (4277). 177. 7/10/02 Robert writes to the Circuit for Washington County and asks to delay the hearing on the motion to transfer his circuit court complaint to Anne Arundel County (see #167). Judge Wright summarily denies the request. 14 178. 7/11/02 Circuit Court for Baltimore City grants the estate's motion raising preliminary objection to transfer Robert's suit filed in Baltimore City to Anne Arundel County (424-C-02-002436) (see #166) 179. 7/18/02 The Court of Appeals denies cert in all four of Robert's petitions (see #170,174,175,176) 180. 7/24/02 Baltimore City Circuit court dismissed Robert's complaint against the Orphans' Court and Circuit Court (see #168) for failure to state a claim. 181. 8/2/02 The Court of Special Appeals orders that Robert's appeal will be dismissed on September 3, 2002 unless by August 30`h he files his brief and record extract in full compliance with all applicable rules. 182. 8/6/02 The Orphans' Court approves interim legal fees to Childs in the amount of $42,411.78 for services through May 31, 2002. 183. 8/12/02 Robert files motions for reconsideration of the Court of Appeals decisions in all four of his petitions (see 170, 174, 175, 176 & 179). 184. 8/12/02 Robert files an appeal to the Court of Special Appeals from the decision of the Baltimore City Circuit Court to transfer his 10 Billion Dollar lawsuit to Anne Arundel County (see #166 & 178). 185. 8/12/02 Robert in the Court of Appeals files his fifth petition for cert (#358). 186. 8/26/02 Court of Special Appeals affirms the Circuit Court dismissal (#80) of Robert's appeals from the Orphans' Court Orders (see #38, #46, 451 & 453) but remands the matter for a hearing on the award of fees. 187. 9/3/02 Robert files his sixth petition for cert to the court of Appeals (4412). 188. 9/12/02 The Court of Appeals denies Robert's petitions for rehearing in all four of Robert's petitions (see #170, 174, 175, 176, 179) 189. 9/12/02 At 7:18 PM the night before the scheduled :hearing in Washington County Robert faxes a letter to the Clerk of Washington County and asks to have the hearing rescheduled again (see #177) 190. 9/13/02 Robert fails to appear at the hearing on the motion to dismiss his complaint (see #167) and the Washington County Circuit Court orders that Robert's Complaint be transferred to Anne Arundel County. 191. 9/24/02 Robert files a motion in the court of Special Appeals for a reconsideration of the opinion rendered in #1342 (see 4186) 15 192. 10/10/02 The Court of Appeals denies Robert's Cert petition #358 (see #185). 193. 10/11/02 Robert files an appeal to the Court of Special Appeals from the order transferring the file to Anne Arundel County (See #190). 194. 10/22/02 The Court of Special Appeals denies Robert's motion for reconsideration of the decision in 1342 (see #191) 195. 11/6/02 Robert files his 7`h petition for Cert (4544) in the Court of Appeals seeking review of the Court of Appeals decision (see #186) 196. 11/12/02 The Court of Appeals denies Robert's petition for Cert #412 (see 4187). 197. 11/12/02 The Orphans' Court, at a hearing following; notice, (at which Robert fails to appear) orders that attorneys fees awarded to Aversa (see # 172) and to Childs (see # 182) be apportioned 90% to come from the share of Robert and 10% from the share of Roger. 198. 11/15/02 Robert files a Motion for Reconsideration in the Court of Appeals to reconsider the denial of the cert petition in #358 (see#192) 199. 12/12/02 Robert files a Motion for Reconsideration in the Court of Appeals to reconsider the denial of the cert petition in 9412 (see #196) 200. 12/12/02 Robert files his 8`h Cert Petition with the Court of Appeals #601. The issue is the Orphans' court's Order of 11/12/02 imposing 90 % of fees on Robert's share of the estate (See#197). 201. 12/16/02 Robert files a petition for Certiorari to the US Supreme Court (which is returned to him for non-compliance) (Pet. 902-1208). 202. 12/23/02 The Court of Appeals denies Robert's cert petition #544 Robert's #7 (see 4195) and denies Robert's motion for reconsideration of the denial of petition #358 (see #192). 203. 1/10/03 The Court of Appeals denies Robert's motion for reconsideration of the denial of Petition Docket No. 412 (see #199). 204. 1/22/03 Robert files a motion for reconsideration of the denial of his cert petition 4544 (see #202). 205. 1/27/03 At a scheduling conference to which Robert fails to appear, Judge Silkworth dismisses the remand case from the CSA (see #186) and dismisses the proceeding transferred to AA county from Washington County (see 4190) because of Robert's appeal (see #193). 16 206. 2/14/03 The Court of Appeals denies Robert's Cert Petition #601 Robert's 8th (See No.200). 207. 2/25/03 Robert files his brief late in #1873 September Term 2002 - the appeal of the Washington County case. (See No. 190 & 193) The brief was due on February 18d'. 208. 3/10/03 Robert files his 91h petition for Cert #15 September Term 2003 in the Court of Appeals. 209. 3/14/03 Court of Areals denies Robert's Petition f'or reconsideration 4544 Robert's 7t cert petition (See No. 202, 204). 210. 3/14/03 Court of Special Appeals agrees to consolidate Robert's appeals in #01371 (see #184) and 01873 (see #193) 211. 3/17/03 Robert files a motion in the Court of Appeals for Reconsideration of the denial of cert petition #601 (see No.206). 212. 3/24/03 Robert files his 2"d Petition for Certiorari to the US Supreme Court (Pet. 402-1440) complaining about Miller acting while his appeals were pending and legal fees. This would be his second Cert Petition (See #201) to that court. 213. 4/10/03 Robert files his 10th petition for Cert #69 September Term 2003 in the Court of Appeals. His chief complaint is the consolidation of his appeals in the Court of Special Appeals. (see #210) 214. 4/10/03 Robert files a motion for Sanctions in the CSA claiming that he never received the motion to consolidate the appeals. 215. 4/14/03 Estate files a Motion to Revise Court Order of 6/6/02 regarding the sale of the estate's property. (see #171) 216. 4/17/03 Robert serves on Childs his 999 Trillion Dollar Complaint filed in Cecil County against Ms. Miller and Mr. Childs. 217. 4/18/03 Robert files a 999 Trillion dollar suit against the Orphans Court and Circuit Court judges in Charles County #08-C-03-000875. 218. 4/28/03 The US Supreme Court denied Robert's Cert Petition 02-1208 (see 9201). 219. 5/8/03 The Orphans' Court grants the Estate's Motion to Revise Court Order dated 6/6/02 regarding the sale of the Estate's Property (see #215) 17 220. 5/9/03 Maryland Court of Appeals denies Robert's motion for reconsideration of the denial of Petition docket #601 (see #21.1) . 221. 5/9/03 Maryland Court of Appeals denies Robert's Petition for Cert #15 (see #208). 222. 5/13/03 The Orphans' Court grants an Order approving attorney's fees to Patricia Miller, Esq. 223. 5/22/03 The Orphans' Court approves the Fourth Administration Account. 224. 5/23/03 Maryland Court of Special Appeals denies Robert's motion to recall or vacate the Order consolidating the appeals and for sanctions (see #210, 213-214) 225. 5/23/03 Robert files in the US Supreme Court a Petition for Rehearing in Pet. #02- 1208 (see #218) 226. 6/2/03 The Supreme Court denies Robert's motion for Writ of Certiorari #02- 1440 (see # 212) 227. 6/9/03 Robert files his 11th petition for Cert (pet #196) to the Maryland Court of Appeals appealing the 5/8/03 Orphans' Court Order (see #219). 228. 6/12/03 Robert files his third petition for Cert to the US Supreme Court. (Petition docket 402-1804) 229. 6/12/03 Robert files his 12'h petition for Cert (pet #211) to the Maryland Court of Appeals appealing the 5/13/03 Orphans' Court Order (See #221) 230. 6/13/03 The Maryland Court of Appeals denies Robert's Petition for Cert (Petition docket #69) (See # 213) 231. 6/17/03 Robert files a Motion for Reconsideration to the Maryland Court of Appeals seeking further review of Petition Docket No 15 (Robert's 9th) (See # 221) 232. 6/23/03 US Supreme Court denies Robert's Petition, for Rehearing in Petition # 02- 1208 (See #225) 233. 6/25/03 The Cecil County Circuit Court grants the motion raising preliminary objection to transfer Robert's suit filed in Cecil County to Anne Arundel County (407-C-03-000094) (see 4216) 234. 6/27/03 Robert files a Petition for rehearing in the US Supreme Court in case #02- 1440 (see # 226) 18 235. 7/11/03 Robert files his 13`h petition for cert (pet #266) to the Court of Appeals appealing the Orphans' Court decision of 5/22/03 approving the Fourth Administration Account. (see #223) 236. 7/14/03 Robert files a motion in the Court of Appeals seeking a reconsideration of the order denying his petitions for cert pet docket 69 Robert's 10th (See #230) 237. 7/24/03 AA Co. Circuit Court Specially assigns Robert's case first filed in Cecil County (See #216) to Judge Silkworth. 238. 7/24/03 Robert files an appeal to the Court of Special Appeals from the ruling in Cecil County (see #233). 239. 8/4/03 US Supreme Court denies Robert's petition for rehearing in cert petition 02-1440. (see #234) 240. 8/7/03 Robert files his fourth Petition for Cert (Pert Docket 03-198) in the US Supreme Court. 241. 8/19/03 Court of Special Appeals affirms the dismissal of Robert's several appeals by Judge Silkworth #2408 (see #149) 242. 8/27/03 Ms. Miller receives a copy of Robert's $1 Million dollar suit filed against the "Estate" in Baltimore County (#03-C-02-007029) filed on 6/24/2002 243. 8/28/03 Court of Appeals denies Robert's Petition for reconsideration docket 15, (see # 231) & 69 and his petitions for Cert petition docket 196 ( see #199) and 211 (see #228) 244. 9/17/03 Court of Appeals denies Robert's Cert petition #266 his 13Th petition (see # 235) 245. 9/28/03 Robert files his 14th Cert Petition in the court of appeals (#389) 246. 9/28/03 Robert files a motion for reconsideration and motion to extend time to file same in re the CSA decision in #2408 (see 4241). 247. 9/29/03 Robert files a motion for reconsideration in the Court of Appeals re petitions 196 and 211 (see #243) 248. 9/30/03 The Orphans' Court awards fees to Childs for $45,220.73 of which 90% is payable by Robert and 10% payable by Roger. 19 249. 9/30/03 The Court of Special Appeals in consolidated cases No. 1371 (Baltimore City- see #166 ), 1417(against the courts -,-- see #168) and 1873 (Washington County --- see # 167) affirmed the action of the lower courts. 250. 10/6/03 The U.S. Supreme court denies Robert's petitions to Cert 02-1804 (see #228) & 03-198 (see #240) 251. 10/17/03 Robert files a Motion for Reconsideration in the Court of Appeals re Petition #266 (see #244) 252. 10/27/03 Robert files suit in Dorchester County against Miller and Childs 253. 10/30/03 Robert files a petition for cert in the Maryland Court of Appeals #477 September Term 2003. His 15th. This is an appeal from the Orphans' Court ruling of 9/30 see #248. 254. 10/31/03 Robert files a Petition for Rehearing in the Supreme Court from their denial of Cert 02-1804 and 03-198 255. 10/31/03 The Baltimore County Circuit Court grants a Motion raising preliminary objection and Orders the transfer of Robert's case to AA county (see #242) 256. 10/31/03 Robert files a Motion for Reconsideration in the Court of Special Appeals in regard to the opinion rendered in transferring the cases from Baltimore City and Washington County (see #249). 257. 11/17/03 The Court of Appeals denied Robert's Motions for reconsideration in Pet No. 196 & 211.(See #247). 258. 12/1/03 The US Supreme Court denies Robert's petitions for rehearing in 02-1840 and 03-198 (see # 254). 259. 12/1/03 Robert files an Appeal to the CSA from the Decision in Baltimore County (see # 255). 260. 12/16/03 Court of Appeals denies Robert's petition for cert #389 (see #245) 261. 12/16/03 Court of Appeals denies Robert's petition for reconsideration of cert denials 4266 (see#251). 262. 12/15/03 Robert filed his brief in 41004 September Term 2003 being his appeal from the action of the Circuit Court for Cecil County. 263. 12/19/03 Court of Appeals denies the petition for cert 9477 (see #253). 20 264. 1/6/04 CSA denies Robert's Motion for Reconsideration. (see #256). 265. 1/16/04 Robert files in the Wicomico County Circuit Court a 900 BILLION dollar claim against the Anne Arundel County Orphans Court and the Circuit Court case #22-C-000062 266. 1/22/04 Robert files in the Court of Appeals a motion for reconsideration of the denials of cert petitions 389 & 477. (see #260 & #263) 267. 1/23/04 The Circuit Court for Dorchester County grants Miller's Motion raising preliminary Objection and transfers the Dorchester County case (see #252) to Anne Arundel County. 268. 2/18/04 Baltimore City Circuit Court enters judgment against Robert for $774 in accordance with the mandate of the CSA. 269. 2/23/04 Robert files an appeal to the CSA in Dorchester Co from the ruling granting the Transfer to Anne Arundel County (see #267) 270. 2/26/04 Robert files a Cert Petition in Court of Appeals No 662 September Term 2003, his 16"' ---- from the decision by the CSA (see #249) 271. 3/11/04 Court of Appeals denies Robert's two Cert Petitions No. 389 and No. 477 (see #266). 272. 3/23/04 Robert files a complaint in Calvert County (04-C- 04-000309) against Miller, Childs and the Estate. 273. 3/29/04 Robert files a complaint in Queen Anne's County (CV 10073) against Miller, Childs and the Estate. 274. 4/13/04 The Queen Anne's County Circuit Court sua sponte dismisses Robert's lawsuit (see #273). 275. 4/22/04 The Calvert County Circuit Court, seeing a memo from the attorney General's office regarding an injunction against Robert filing more suits closed the file on the suit filed by Robert (see #272) 276. 4/28/03 277. 5/12/04 The Court of Special Appeals denies Robert's motion for Reconsideration in # 2408 (See #246) Court of Special Appeals orders that Robert's appeals 42098 (Baltimore County see 9255) and 42690 (Dorchester County see 4267) be consolidated. 21 278. 5/12/04 Robert files an appeal from the Queen Anne's County dismissal of his lawsuit (see #274) 279. 5/14/04 Court of Appeals denies Robert's Cert Petition No. 662 (Court of Special Appeals Nos. 1371, 1417 & 1873). (see #270). 280. 5/21/04 Robert files his 17th Cert Petition in the Court of Appeals, appealing from the Court of Special Appeals No. 02408 (see #275) 281. 5/25/04 Robert seeks an extension of time from the CSA to file his brief in #2690 from Baltimore County, one of the consolidated cases (see #276). 282. 6/7/04 The Court of Special Appeals affirms the Circuit Court for Cecil County which granted the Motion Raising Preliminary Objection. (see #233). 283. 6/14/04 Robert files an Emergency Motion to "Reopen Case" in the CSA alleging he wanted that case reopened so that typos in the estate's pleadings could be corrected.. 284. 6/18/04 Robert files for reconsideration by the Court of Appeals of the decision in Cert pet 662 (See No.279. 285. 7/15/04 Court of Special Appeals denies Robert's motions to Reopen case (see #282) etc. Robert's brief in 2098 September Term 2003 is due September 1, 2004. 286. 7/21/04 Robert files for a default judgment in Calvert County. 287. 7/27/04 Calvert County Circuit Court dismisses Robert's Complaint See #272 288. 7/28/04 289. 8/5/04 290. 8/17/04 291. 8/19/04 292 Court of Appeals denies Robert Pet for Cert in docket #158 (#2408 in the CSA - see #280) Robert's 17`h cert petition. Robert files for a reconsideration of the CSA ruling of 7/15.04 see #285. Orphans Court orders that the estate pay Childs $32,793.32 for July 1, 2003 through June 30, 2004. Robert files suit in Alexandria, Virginia against Miller, Childs and the Estate for 188 Million dollars 8/23/04 The Court of appeals denies Robert's 16m petition for reconsideration of the denial of his cert petition 4662 from the CSA 1371, 1417 & 1873 see #284 22 293. 8/25/04 Robert files an appeal from the dismissal of his case in Calvert County (see #287) 294. 8/31/04 Court of Special Appeals denied Robert's motion for reconsideration of the unreported opinion issued in the appeal from Cecil County (see #282) 295. 9/16/04 Robert Meade files a petition for Cert (his 18`h) in the Court of Appeals petition # 366 Sept term 2004 seeking a review of the CSA decision on his Cecil County case (see # 282). 296. 10/8/04 Court of Appeals denied Robert pet for reconsideration of the denial of his Cert from CSA #2408 (see #280 & 288). (we never got a copy of the petition) 297. 12/8/04 The Circuit Court for Alexandria Virginia dismissed with prejudice Robert's complaint filed there. (See #291) 298. 12/10/04 Court of Special Appeals affirms the Circuit Courts for Baltimore County (#2098) and Dorchester County(#2690) (see # 277) 299. 12/10/04 Court of Appeals denies Robert's petition for Cert (9366) from the CSA #1004 (see #295) 300. 1/3/05 Robert files a motion in the CSA to strike the appellees brief in 400537 (Queen Anne's County) 301. 1/12/05 Robert files in the CSA a motion to amend the opinion affirming the Circuit Courts for Baltimore County (#2098) and Dorchester County(92690) (see # 298) 302. 1/13/05 Robert files in Alexandria a motion to reopen his case (see #297) 303. 1/26/05 The Court of Special Appeals denies Robert's Motion to Amend its opinion (see #300) 304. 1/26/05 Robert files a new suit against Miller, Childs, the estate and Alan Legum in the Circuit Court for Stafford County, Virginia, but does not serve them until 8/12/05 (see #320) 305. 3/7/05 Robert files a motion for Reconsideration in the CSA to order costs to be paid by the estate and issue a new mandate. 306. 3/ 7 /05 Robert files his brief in CSA #1443 from Calvert County. 307. 3/14/05 Court of Appeals denies the motion for reconsideration in pet doc #366, CSA #1004 (see #299) 23 308. 4/6/05 CSA denies Robert's motions for reconsideration filed in 2098 & 2690 (See #300). 309. 4/21/05 Robert files a motion to strike Appellees Brief in the CSA 1443 (Calvert County) 310. 4/25/05 Robert files a motion to reopen case in Alexandria Va. 311. 5/24/05 CSA affirms (Sept Term 2004 #537) the decision of Queen Anne's County to dismiss Robert's lawsuit based upon the TRO (see # 278). 312. 5/26/05 CSA affirms (Sept Term 2004 #1443) the decision of Calvert County to dismiss Robert's Lawsuit based upon improper venue.(see# 293) 313. 6/16/05 CC for Anne Arundel County strikes Robert's pleading in the case transferred from Cecil County (see #294). 314. 6/17/05 The Court of Appeals denied Robert's cert petition in Petition docket #121 see #307 (CSA # 2690 & 2698) 315. 6/23/05 Robert files in the CSA, a motion for reconsideration in the Queen Anne's County Appeal (Sept Term 2004 #537) (see #311) 316. 6/27/05 Robert files in the CSA a motion for reconsideration in Sept Term 01443 (Calvert County see # 312). 317. 7/18/05 Robert files an appeal to the Court of Special Appeals from the decision of Judge Silkworth to dismiss his case transferred from Cecil County See #313. 318. 7/18/05 Robert files a motion for reconsideration in the Court of Appeals their denial of Cert in re Baltimore County and Dorchester County. See #314. 319. 7/29/05 CSA denies Robert's motions for reconsideration in Sept Term 1443 (Calvert - see #316) & 537 (Queen Anne's - see # 315) 320. 8/12/05 The defendants are served by Certified Mail with Robert's a new complaint against Miller, Childs, the Estate and Alan Legum filed in the Circuit Court for Stafford County, Virginia on January 26, 2005 (see #304). 321. 8/12/05 AA County appeals clerk, by letter, dismisses Robert's appeal from the decision of Judge Silkworth to dismiss his case transferred from Cecil County (see 4317) 24 322. 8/15/05 Robert Files a Cert Petition in the Court of Appeals (4274 -- 2005) from the CSA in the Queen Anne's County case ( See #319) 323. 8/15/05 Robert files a Cert Petition in the Court of Appeals (#275 - 2005) from the CSA in the Calvert County Case (See #319). 324. 8/15/05 Robert files a Complaint in the Circuit Court for Cumberland County (#05-4173 Civil Term) in Carlisle, Pennsylvania against Miller, Childs and the Estate. 325. 9/9/05 Court of Appeals denies Robert's motion for reconsideration in Petition #121 (CSA42690& 2698) (See 4318). 326. 10/17/05 Circuit Court for Stafford Co., Virginia dismissed Robert's Complaint with prejudice (See #320) 327. 11/14/05 Court of Appeals denies Robert's Cert Petition from #1443 CSA (see #319) 328. 11/14/05 Court of Appeals denies Robert's Cert Petition from #537 CSA (see # 315) AFFIDAVIT I hereby certify under the penalties of perjury that the matters and facts set forth in the foregoing ESTATE OF HELEN V. MEADE - ADMINISTRATION CHRONOLOGY OR TIME LINE are true and correct to the best of my knowledge information and belief. -) I /ni W) 11 ,? WU 25 alter S. B. Childs -, r? ? f l -r'I 1 ! ..J l `? _ _ _._ C ' __r ` ROBERT E. MEADE * IN THE Plaintiff * CIRCUIT COURT V. * FOR DEC 2 7 201'1, PATRICIA A. MILLER, ESQ., WALTER S. B. CHILDS, ESQ., CUMBERLAND COUNTY AND THE ESTATE OF HELEN V. MEADE CASE NO. 05-4173 CIVIL TERM * Defendants * ORDER TO ENTER AND STRIKE APPEARANCE Please enter the appearance of Gareth S. Smith, Esquire as counsel for the Defendants: Patricia A. Miller, Esquire, Walter S.B. Childs, Esquire individually and as Personal Representative of the Estate of Helen B. Meade in the above proceeding and strike the appearance of Walter S.B. Childs, Esquire as counsel for said Defendants. Respectfully submitted, LINOWES AND BLOCHER LLP BY Gareth S. Smith, Esquire Pennsylvania Bar No. 92480 Linowes and Blocher LLP 7200 Wisconsin Avenue, Suite 800 Bethesda, Maryland 20814 301-961-5240 BY: U Walter SB145 Main Street Annapolis, Maryland 21401 410-268-0881 Counsel for Defendants Page 1 r CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 20 day of December, 2005, a copy of the foregoing Order to Enter and Strike Appearance was mailed, by first class mail, postage prepaid, to Robert E. Meade, P. O. Box 58215, Washington, D.C. 20037. Walter S. B. Childs C \NrPortbl\IMANAGB\GSS\546065 I.DOC L&B 546065v1 Page 2 ROBERT E. MEADE Plaintiff V. PATRICIA A. MILLER, ESQUIRE, WALTER S. B. CHILDS, ESQUIRE, AND THE ESTATE OF HELEN V. MEADE, et al. Defendants IN THE CIRCUIT COURT FOR CUMBERLAND COUNTY Case No. 05-4173 Civil Term MOTION TO STRIKE THE DEFENDANTS' "PRAECIPE FOR LISTING CASE FOR ARGUMENT" Comes now, the Plaintiff, Robert E. Meade, and stakes the following: 1. That Walter S. B. Childs, Esquire, one of the Defendants, cannot move this Court to act on a praecipe, any pleading, etc. since he is not a member of the Pennsylvania Bar. 2. That the Defendants should be represented by counsel and the first action taken by their counsel should be to answer the Plaintiffs complaint. 3. That this Court should strike the Defendants' "Motion Raising Preliminary With Supporting Affidavit" since the Motion was filed by one of the Defendant attorneys, Walter S. B. Childs, Esquire, who is not a member of the Pennsylvania Bar. 4. That this Court should strike the Defendants' "Praecipe For Listing Case For Argument" since the Praecipe was filed by one of the Defendant attorneys, Walter S. B. Childs, Esquire, who is not a member of the Pennsylvania Bar. 5. That the Defendants cannot set a method of argument, such as by briefs, and cannot set up an argument court date without the Plaintiff's official written agreement. 6. That only this Court can issue an Order delegating the method of argument and only this Court can set an argument date. If this Court issues such an Order, the Plaintiff would appeal such an Order through the entire appeal process. 7. That the Plaintiff totally opposes the Defendants' method of argument since the Plaintiff cannot cross-examine the Defendants' argument on briefs, the Plaintiff cannot cross-examine the Defendants' motions or the Defendants' affidavits, and the Plaintiff cannot cross-examine the Defendants. 8. That the Plaintiff requests that only a trial by jury be held in this court case. That under the Constitution of the United States, Article 4, Section 2, "the Plaintiff has a right to file an action in the courts of any state to redress wrongs which have been committed against him and the Plaintiff has a right to a trial by jury". WHEREFORE, the Plaintiff prays that this Court strikes the Defendants' "Motion Raising Preliminary With Supporting Affidavit" and that this Court strikes the Defendants' "Praecipe For Listing Case For Argument" since they were written by one of the Defendant attorneys, Walter S. B. Childs, Esquire, who is not a member of the Pennsylvania Bar. Also, the Plaintiff prays that this Court issues an Order that the Defendants retain counsel who is a member of the Pennsylvania Bar. Further, the Plaintiff prays that this Court schedule a trial by jury as requested by the Plaintiff in his complaint. Re ctfi lly submitted, k MaL Robert E. Meade P.O. Box 58215 Washington, D.C. 20037 (202) 468-1823 CERTIFICATE OF SERVICE I hereby certify that on the OLO day of EC , 2005, a copy of the foregoing was mailed, first class, postage prepaid to Walter S. B. Childs, Esquire, 145 Main Street, Annapolis, Maryland 21401. i"I ei / Lk Robert E. Meade R ROBERT E. MEADE Plaintiff V. PATRICIA A. MILLER, ESQ., WALTER S. B. CHILDS, ESQ., AND THE ESTATE OF HELEN V. MEADE Defendants * IN THE * CIRCUIT COURT * FOR * CUMBERLAND COUNTY * CASE NO. 05-4173 CIVIL TERM * * RESPONSE TO MOTION TO STRIKE DEFENDANTS' PRAECIPE FOR LISTING CASE FOR ARGUMENT The Defendants, Patricia A. Miller, Esq. and Walter S. B. Childs, Esq., individually and as Personal Representative of the Estate of Helen V. Meade (the `Estate"), by Gareth S. Smith, Esq. and Linowes and Blocher, LLP, hereby file this Response to Plaintiff's Motion to Strike Defendants' "Praecipe For Listing Case for Argument" (the "Motion to Strike") and state as follows: 1. The Plaintiff filed the Complaint in this Case on August 15, 2005, and served it on the Defendants by certified mail on November 18, 2005. Thereafter, defendant Walter S. B. Childs ("Mr. Childs") filed a Motion Raising Preliminary Objections and, on December 13, 2005, submitted a Praecipe listing the case for Argument (the "Praecipe") to Taryn Dixon in the Office of the Court Administrator. As the Praecipe was not filed with the Prothonotary, it was never effectively filed and the case was not listed for Argument. 2. On January 3, 2006, the undersigned counsel entered an appearance on behalf of the Defendants by filing an "Order to Enter and Strike Appearance." 3. On January 5, 2006, the Plaintiff filed the Motion to Strike the Praecipe because it had been submitted by Mr. Childs who, though an attorney and also able to represent himself pro v se, is not a member of the Pennsylvania Bar and cannot therefore represent the other Defendants in this case. 4. By entering an appearance on January 3, 2006, the undersigned counsel has ensured that all Defendants are properly represented before this Court. 5. The Defendants have submitted their preliminary objections to the Complaint, and the Plaintiff already has filed an answer to those objections. 6. Contemporaneously with the filing of this Response, the undersigned counsel is filing a Praecipe to list this case for argument. 7. As the Praecipe submitted by Mr. Childs was never properly filed in this case, and does not appear in this case's docket, there is no need to strike the Praecipe and this motion should accordingly be disregarded and/or denied. Moreover, as undersigned counsel is filing a new Praecipe on behalf of the Defendants, the Plaintiffs challenge to the legitimacy of the Praecipe submitted by Mr. Childs is irrelevant. FOR THE REASONS STATED, the Defendants respectfully request this Court to disregard and/or deny the Plaintiff s Motion to Strike Defendants' "Praecipe For Listing Case for Argument", and grant such additional relief as to the court shall seem appropriate and just. For the Court's convenience, a proposed Order is submitted herewith. Respectfully submitted, LINOWES AND BLOCHER LLP Gareth S. Smith, Esq. Pennsylvania Bar No. 92480 Linowes and Blocher LLP 7200 Wisconsin Avenue, Suite 800 Bethesda, MD 20814-4842 (301) 961-5240 Counsel for Defendants 2 { CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this L,? day of January, 2006, a copy of the foregoing Brief in Support of Motion Raising Preliminary Objection was served by first class mail, postage prepaid, upon: Robert E. Meade P.O. Box 58215 Washington, D.C., 20037 Gareth S. Smith Attorney for the Defendants L&U 553675v I ?_, . , - ?, ,? _ ! --i - <?_ . '_' 1 C.": - :. PRAECIPE FOR LISTING CASE FOR ARGUMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. ROBERT E. MEADE Plaintiff V. PATRICIA A. MILLER, ESQ., WALTER S. B. CHILDS, ESQ., * IN THE * CIRCUIT COURT * FOR * CUMBERLAND COUNTY AND THE ESTATE OF HELEN V. MEADE CASE NO. 05-4173 CIVIL TERM * Defendants * 1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demurrer to complaint, etc.): Defendants' Motion Raising Preliminary Objection 2. Identify counsel who will argue cases: (a) for plaintiff: Robert E. Meade, pro se P.O. Box 58215, Washington, D.C. 20037 (b) for defendants: Gareth S. Smith, Esq. Linowes and Blocher LLP 7200 Wisconsin Avenue, Suite 800, Bethesda, MD 20814 301-961-5240 3. I will notify all parties in writing within two days that this case has been listed for argument. Copy of this Praecipe is being sent to the Plaintiff 4. Argument Court Date: February 15, 2006 . Gareth S. Smith, Esq. O S? Attorney for Defendants Date: (J 0 I HEREBY CERTIFY that on this day of January, 2006, a copy of the foregoing Brief in Support of Motion Raising Preliminary Objection was served by first class mail, postage prepaid, upon: Robert E. Meade, P.O. Box 58215, Washington D.C. 20037. Gareth S. Smith, Esq. L&B 553804,1 -.a _ r, ? ,i c? ;.. ` ROBERT E. MEADE * IN THE CIRCUIT COURT Plaintiff * FOR CUMBERLAND COUNTY V. * PATRICIA A. MILLER, ESQUIRE, Case No. 05-4173 Civil Term * WALTER S. B. CHILDS, ESQUIRE, * AND THE ESTATE OF HELEN V. MEADE, et al. Defendants AMENDED MOTION TO STRIKE THE DEFENDANTS' "PRAECIPE FOR LISTING CASE FOR ARGUMENT" Comes now, the Plaintiff, Robert E. Meade, and states the following: 1. That the Defendants were served the summonses and complaint on November 15, 2005 by certified mail. Walter S. B. Childs, Esquire, one of the Defendants, filed a "Motion Raising Preliminary With Supporting Affidavit" which was stamped in by this Court on December 6, 2005. Apparently, Walter S. B. Childs, Esquire, sent the Plaintiff a copy of his Motion, but he did not send his original Motion to this Court on the same day. His Motion did not adhere to Pennsylvania Rules that require that a preliminary objection be raised within 20 days after service of the summons or complaint. The "Motion Raising Preliminary With Supporting Affidavit"should be stricken because the Motion was untimely and the Motion was presented by Walter S. B. Childs, Esquire, who is not a member of the Pennsylvania Bar. 2. That the Court advised the Plaintiff that the argument by briefs was scheduled. 3. That both the Praecipes presented by Walter S. B. Childs, Esquire, and Gareth S. Smith, Esquire, and the "Brief In Support Of Motion Raising Preliminary Objection" presented to this Court by Counsel for Defendants on December 20, 2005 should be stricken by this Court, in their entirety, because the Defendants' Motion was untimely and the Plaintiff opposes the Defendants' method of argument by briefs since their Brief contains impertinent and false materials and the Plaintiff cannot cross- examine the Defendants' argument by briefs, the Plaintiff cannot cross-examine the Defendants' motions or the Defendants' affidavits. The Plaintiff wants to cross- examine the Defendants in a trial by jury. 4. That this Court should strike the Defendants' "Motion Raising Preliminary With Supporting Affidavit" because it was untimely and the Defendants cannot present an argument by briefs on an untimely Motion. 5. That the Plaintiff requests that only a trial by jury be held in this court case. That under the Constitution of the United States, Article 4, Section 2, "the Plaintiff has a right to file an action in the courts of any state to redress wrongs which have been committed against him and the Plaintiff has a right to a trial by jury". WHEREFORE, the Plaintiff prays that this Court strikes the Defendants' "Motion Raising Preliminary With Supporting Affidavit" because the Motion was untimely and the Plaintiff prays that this Court strikes both the Praecipes, in their entirety, presented by Walter S. B. Childs, Esquire, and Gareth S. Smith, Esquire, and that this Court strikes the Brief presented by Counsel for Defendants. Further, the Plaintiff prays that this Court schedule a trial by jury, as requested by the Plaintiff in his complaint, and not allow an argument by briefs. V, . Y Res ctfully submitted, I e, %jo-- Robert E. Meade P.O. Box 58215 Washington, D.C. 20037 (202) 468-1823 CERTIFICATE OF SERVICE At) I hereby certify that on the ? day of , 2006, a copy of the foregoing was mailed, first class, postage prepaid to Gareth S. Smith, Esquire, 7200 Wisconsin Avenue, Suite 800, Bethesda, Maryland 20814. a,f e'Aj Robert E. Meade r? ?, -i ?i G? i.A «. ? ?. (-? nJ ROBERT E. MEADE * IN THE LJ I. , Plaintiff * CIRCUIT COURT . . V. * FOR - ' ` PATRICIA A. MILLER, ESQ., * CUMBERLAND COUNTY WALTER S. B. CHILDS, ESQ., AND THE ESTATE OF HELEN V. MEADE CASE NO. 05-4173 CIVIL TERM * Defendants * OPPOSITION TO AMENDED MOTION TO STRIKE DEFENDANTS' PRAECIPE FOR LISTING CASE FOR ARGUMENT The Defendants, Patricia A. Miller, Esq. and Walter S. B. Childs, Esq., individually and as Personal Representative of the Estate of Helen V. Meade (the "Estate"), by Gareth S. Smith, Esq. and Linowes and Blocher, LLP, hereby file this Opposition to Plaintiffs Amended Motion to Strike Defendants' "Praecipe For Listing Case for Argument" (the "Motion") and state as follows: 1. The Plaintiff filed the Complaint in this Case on August 15, 2005, and served it on the Defendants by certified mail on November 18, 2005. See Affidavit of Service, attached hereto as Exhibit "A" and filed with this Court on December 2, 2005, which includes a certified mail receipt establishing November 18, 2005 as the date of delivery. i 2. The Defendants filed a Motion Raising Preliminary Objection (with Supporting Affidavit) on December 6, 2005, and undersigned counsel thereafter filed a Praecipe listing the case for argument on the Defendants' Motion Raising Preliminary Objection. While the Affidavit of Service states that service was made on November 15, 2005, according to Pa. R. C. P. 403, service of process is complete upon delivery of the mail. Accordingly, service was not made on the Defendants until November 18, 2005. 3. As this case has been listed for argument on February 15, 2006, see January 26, 2006 Notice, attached hereto as Exhibit "B", the Plaintiff's Motion is moot. The Defendants nevertheless file this Opposition in order to counter an erroneous assertion contained in the Motion. Specifically, in the Motion, the Plaintiff contends that the Defendants filed their preliminary objections after the deadline for doing so, and the Plaintiff consequently requests that this Court strike the Defendants' preliminary objections. 4. Pursuant to the Notice to Defend that accompanied the Complaint, the Defendants' objections were due "within twenty (20) days after this complaint and notice are served." See Exhibit "A". As service was made on November 18, 2005 and the Defendants filed their Motion Raising Preliminary Objection (with Supporting Affidavit) on December 6, 2005, their objections were timely filed. FOR THE REASONS STATED, the Defendants respectfully request this Court to deny the Plaintiffs Amended Motion to Strike Defendants' "Praecipe For Listing Case for Argument," and grant such additional relief as to the court shall seem appropriate and just. For the Court's convenience, a proposed Order is submitted herewith. Respectfully submitted, LINOWES AND BLOCHER LLP Gareth S. Smith, Esq. Pennsylvania Bar No. 92480 Linowes and Blocher LLP 7200 Wisconsin Avenue, Suite 800 Bethesda, MD 20814-4842 (301) 961-5240 Counsel for Defendants 2 Exhibit A ,-?f -V/ ?3 AFFIDAVIT OF SERVICE I, Alma Erazo, am at least 18 years of age, competent to testify, and not a party to this action. 2. On November 15, 2005, service of the attached notices stamped by the Prothonotary and copies of the complaint filed with this Court was made upon Walter S. B. Childs, Esquire, by delivery to him via certified mail at 145 Main Street, Annapolis, Maryland 21401. 3. Attached is the original of the certified mail receipt. I solemnly affirm under the penalties of perjury that the contents of the foregoing affidavit are true to the best of my knowledge, information and belief. Al &a Erazo, P cess Server P.O. Box 1002 Riverdale, Maryland 20738 (202) 974-3334 November 28, 2005 -i -il . rl _ ZL - fu ,. Vr < ¦ Complete Hems 1. 2, and 3. Also complete A. n to ' I Q Anent Hem 4 H Restricted DeWarY Is deetred. on the reverse dd s d X Q Addresses a re s ¦ Print your name an so that we can return the card to you. B. d by(P. N Qf Dowry is Attach this card to the back of the maapiece, L te i) or on the front H space penults. p Is dearery edlAM Yes 1. Article Addressed to. , H YES, enteritEell No WAMer6.B. Chills, ES?uirt a .Cpl, I µs Main Vrce r ? naa i ANN4f+o islMar'/?0.h?tf`fo?. r 3.sery4ce type V'Cettified Mel Q Express Man RESTRICTED ? Registered Q RMM Receipt for Merctwndise DELIVERY Qlnsured Mall QO.C.D. 4. Restricted Delivery? Pft Fee) Yee 2. Article Number (renew iron service WeO Ps Form 3811. February 20D4 Domestic Return Receipt 1=954)2 15,10 ROBERT E. MEADE * IN THE CIRCUIT COURT P.O. Box 58215 Washington, D.C. 20037 FOR CUMBERLAND COUNTY Plaintiff V. * PATRICIA A. MILLER., ESQUIRE, Case No. 05'-5/7-; d; f c/o Walter S. B. Childs, Esquire, her attorney 145 Main Street, Annapolis, MD. 21401 * WALTER S. B. CHILDS, ESQUIRE, 145 Main Street, Annapolis, MD. 21401 AND TEE ESTATE OF HELEN V. MEADE, et al. c/o Patricia A. Miller, Esq., or cto Walter S. B. Childs, Esquire, her attorney Defendants NOTICE 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 days (20) days after this complaint and notice are served, by entering a written appearance personally or by 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. WE COPY 7;'-1CW4 RE?CP41:- In in Too" wiww' i ;;eta ;frilo ." My haiwJ -1-td t!e aw of Saki c = caftw' PL S 1 ? 3Y 4 L4 . e2ea Proihonaluy ROBERT E. MEADE P.O. Box 58215 Washington, D.C. 20037 Plaintiff v. w PATRICIA A. MILLER, ESQUIRE, c/o Walter S. B. Childs, Esquire, her attorney .145 Main Street, Annapolis, MD. 21401 w WALTER S. B. CHILDS, ESQUIRE, 145 Main Street, Annapolis, MD. 21401 AND THE ESTATE OF HELEN V. MEADE, et al. c/o Patricia A. Miller, Esq., or c/o Walter S. B. Childs, Esquire, her attorney w IN THE CIR= COURT FOR CUMBERLAND COUNTY Case No. 05. 4 /73 6,1;a -Itl- Defendants * * * * * w w w w w * w w * w w COMPLAINT Comes now, the Plaintiff and sues the Defendants and states the following: 1. The Defendants have used their judicial contacts and his judicial family lineage ties to obstruct justice and deny the Plaintiff his constitutional rights. 2. The Defendants have denied the Plaintiff from obtaining any disclosure information about the estate with the intent of self-dealing. 3. The Defendants have acted with malice towards the Plaintiff. 4. The Defendants have fraudulently made false statements. 5. The Defendants have stolen monies from the Plaintiff and from the estate. 6. The Defendants have falsely stated that they represent the Plaintiff in order to steal monies from the Plaintiff and from the estate. 7. The Defendants have abused the Plaintiffs rights to oppose the Defendants' illicit actions. 8. The Defendants have conspired with others to obstruct justice and commit crimes. WHEREFORE, the Plaintiff; Robert E. Meade, demands judgment against Patricia A. Miller, Esquire, Walter S. B. Childs, Esquire, and. the estate of Helen V.Meade, et al. for compensatory damages in the amount of nine hundred million dollars each and for punitive damages in the amount of nine hundred million dollars each. full R Robert E. Measubmitted, de P.O. Box 58215 Washington, D.C. 20037 (202) 468-1823 FOUEST FOR A TRIAL BY JURY Dear Clerk, The Plaintiff requests a trial by jury. ;j LI j, Robert E. Meade P.O. Box 58215. Washington, D.C. 20037 Exhibit B Office of the Prothonotary Cumberland County Curtis R. Long Prothonotary GARETH S. SMITH, ESQ. LINEWES AND BLOCHER LLP 7200 WISCONSIN AVENUE SUITE 800 BETHESDA MD 20814 DATE: JANUARY 26, 2006 TO: GARETH S. SMITH, ESQ. : THIS IS TO NOTIFY YOU THAT CASE NUMBER 05-4173 CIVIL, ROBERT E. MEADE VS. PATRICIA A. MILLER. ESO• ET AL HAS BEEN LISTED FOR ARGUMENT ON FEBRUARY 15, 2006. Cumberland County Argument Court Rules 1028(c), 1034(a) and 1035.2(a) shall be strictly enforced. If the issue was listed for prior argument you must re-tile your brief as per Local Rule 1028(c)10. Curtis R. Long Prothonotary CERTIFICATE OF SERVICE aolz?04p1Q4Gy-?/' I HEREBY CERTIFY that on this day of January, 2006,?a copy of theoreg?Sing Brief in Support of Motion Raising Preliminary Objection was served by first class mail, postage prepaid, upon: Robert E. Meade P.O. Box 58215 Washington, D.C., 20037 areth S. Smith Attorney for the Defendants L&B 559665v7 T. C,, ROBERT E. MEADE PLAINTIFF V. PATRICIA A. MILLER, ESQ. WALTER S. B. CHILDS, ESQ. AND THE ESTATE OF HELEN V. MEADE DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 05-4173 CIVIL TERM IN RE: MOTION RAISING PRELIMINARY OBJECTION BEFORE BAYLEY, J. AND EBERT, J. ORDER OF COURT AND NOW, this 17`h day February, 2006, upon consideration of the Motion Raising Preliminary Objection filed on behalf of the defendants, the Answer filed by the Plaintiff and after argument, the Defendants' Motion for Preliminary Objection is GRANTED; IT IS FURTHER ORDERED AND DIRECTED that the Plaintiff's complaint is hereby DISMISSED WITH PREJUDICE. By the Court, he1V\ M. L. Ebert, Jr., J. Robert E. Meade Plaintiff Gareth S. Smith, Esquire --rv ? For Defendants n? Court Administrator bas _, L.4 ??; "' I ?. ;; ? i ? ?_ ROBERT E. MEADE Plaintiff V. PATRICIA A. MILLER, ESQUIRE, WALTER S. B. CHILDS, ESQUIRE, AND THE ESTATE OF HELEN V. MEADE, et al. Defendants * * * * * IN THE CIRCUIT COURT * FOR CUMBERLAND COUNTY * * * * * Case No. 05-4173 Civil Tenn * * * * * * * * * * * * Comes now the Plaintiff and states the following: 1. That the Defendants have now placed before this Court another set of Briefs for argument 2. That the Defendants' second set of Briefs should be stricken since the Defendants' second set of Briefs for argument also contain impertinent and false materials which should not be placed in the record since the impertinent and false materials are allegedly from other cases and have no bearing on this case filed against the Defendants in this Court. 3. That, under the Rules of Civil Procedure, these impertinent and false materials cannot be allowed to taint the validity of the new case and the new case should be determined on its merits. 4. That the Defendants, in their two sets of Briefs, attempt to present these impertinent and false materials as some sort of evidence. That "The trial court may exclude evidence that is irrelevant, confusing, misleading, cumulative, or prejudicial". r Lehigh-Northampton Airport Authority v. Fuller, 862 A. 2d 159 5. That the impertinent and false materials presented by the Defendants should be stricken by this Court in their entirety. The sole purpose of presenting these materials was to prejudice this Court against the Plaintiff and to deter this Court from the merits of the Plaintiff's complaint. "Reviewing court may not consider what trial court has done in allegedly similar, but unrelated cases, since the reviewing court may not base decision on matters outside the record of present case". Seibel v. Allstate Ins. Co., 499 A. 2d 666, 346 Pa Sup 384 appeal denied 120 A. 2d 1385, 513 Pa. 635 6. That the Defendants only presented one affidavit for all the Defendants and that one affidavit was too bald and too broad to include all the Defendants. 7. That the Plaintiff will present jurisdictional facts. That "Specific jurisdiction over a nonresident defendant is focused upon the particular acts of the defendant that gave rise to the underlying cause of action". 42 Pa. C. S. A. § 5322 Commonwealth ex. rel. Papport v. Tapp Pharmaceuticals Products, Inc. 868 A. 2d 624 8. That the Plaintiff is entitled to develop and to present facts in support of jurisdiction. "Because subject matter jurisdiction often turns on issues of fact, the court should permit each side sufficient discovery to prove its version of jurisdictional reality and to inform the court so that a correct ruling can be made". Urquhart v. American-La France Foamite Corp., 144 F. 2d 542 (1944) 9. That the Plaintiff opposes argument by briefs since he cannot cross- examine all of the Defendants. That "When issues of facts are necessary to the determination of a court's subject matter jurisdiction, due process requires that a trial-like hearing be held, in which an opportunity is provided to present evidence and to cross- J ti y v examine adverse witnesses. U.S.C.A. Const. Amend. 14 ". Gordon v. H.N.S. Management Co., Inc., 861 2d 1160, 272 Conn. 81 10. That this Court should strike the Defendants' two set of Briefs for argument and that this Court should schedule a trial by jury as the Plaintiff requested in his complaint. WHEREFORE, the Plaintiff prays that this Court strikes the Defendants' two set of Briefs, in their entirety, and that this Court denies an argument by briefs in this case. Further, the Plaintiff prays that this Court schedules a trial by jury in this case. Res ectful?ly submitted, Robert E. Meade P.O. Box 58215 Washington, D.C. 20037 (202) 468-1823 CERTIFICATE OF SERVICE AJ I hereby certify that on the (3 day of f e? 2006, a copy of the foregoing was mailed, first class, postage prepaid to Gareth S. Smith., Esquire, 7200 Wisconsin Avenue, Suite 800, Bethesda, Maryland 20814. Robert E. Meade -„ _, ?,. ', _. , ROBERT E. MEADE Plaintiff V. PATRICIA A. MILLER, ESQUIRE, WALTER S. B. CHILDS, ESQUIRE, AND THE ESTATE OF HELEN V. MEADE, et al. * IN THE CIRCUIT COURT * FOR CUMBERLAND COUNTY * w w * Case No. 05-4173 Civil Term Defendants w * w w w w w w w w w w w w w w ORDER Upon this Court having read and considered the Plaintiff s Motion To Strike Defendants' Argument By Briefs For Defendants' Second Set of Briefs and any answer filed by the Defendants, it is this day of 2006, ORDERED, that the Plaintiff s Motion To Strike Defendants' Argument By Briefs For Defendants' Second Set of Briefs is hereby GRANTED, and it is further, ORDERED, that the Defendants' two sets of Briefs are hereby stricken in their entirety, and that an argument by briefs is DENIED in this case, and it is further, ORDERED, that a trial by jury be scheduled in this case. Judge ROBERT E. MEADE Plaintiff V. PATRICIA A. MILLER, ESQUIRE, WALTER S. B. CHILDS, ESQUIRE, AND THE ESTATE OF HELEN V. MEADE, et al. Defendants * IN THE CIRCUIT COURT * FOR CUMBERLAND COUNTY * * * * Case No. 05-4173 Civil Term w w • w w w * * w ¦ w ORDER Upon this Court having read and considered the Plaintiff's Motion To Strike Defendants' Argument By Briefs For Defendants' Second Set of Briefs and any answer filed by the Defendants, it is this day of 2006, ORDERED, that the Plaintiff's Motion To Strike Defendants' Argument By Briefs For Defendants' Second Set of Briefs is hereby GRANTED, and it is further, ORDERED, that the Defendants' two sets of Briefs are hereby stricken in their entirety, and that an argument by briefs is DENIED in this case, and it is further, ORDERED, that a trial by jury be scheduled in this case. Judge ROBERT E. MEADE PLAINTIFF V. PATRICIA A. MILLER, ESQ. WALTER S. B. CHILDS, ESQ. AND THE ESTATE OF HELEN V. MEADE DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 05-4173 CIVIL TERM IN RE: PLAINTIFF'S MOTION TO STRIKE DEFENDANT'S ARGUMENT BY BRIEFS FOR DEFENDANT'S SECOND SET OF BRIEFS ORDER OF COURT AND NOW, this 2nd day March, 2006, the Defendant's Motion is DENIED. By the Court, M. L. Ebert, Jr., Robert E. Meade Plaintiff Gareth S. Smith, Esquire For Defendants bas I .% ROBERT E. MEADE Plaintiff V. PATRICIA A. MILLER, ESQUIRE, WALTER S. B. CHILDS, ESQUIRE, AND THE ESTATE OF HELEN V. MEADE, et al. Defendants * * * * * * * * IN THE COURT OF COMMON PLEAS * OF CUMBERLAND COUNTY, * PENNSYLVANIA * * Case No.: 05-4173 Civil Term * * * * * * * * * * * NOTICE OF APPEAL Notice is hereby given that Robert E. Meade, Plaintiff above named, hereby appeals to the Superior Court of Pennsylvania from the Order of February 17, 2006 which was entered in this matter on February 21, 2006. This Order has been entered in the docket as evidenced by the attached copy of the docket entry. Res ctfully submitted, 10 ?` Robert E, Meade P.O. Box 58215 Washington, D.C. 20037 (202) 468-1823 There is no verbatim record of the proceedings. Xj' Robert E. Meade CERTIFICATE OF SERVICE I hereby certify that on the a-0 day of PCf , 2006, a copy of the Notice of Appeal was mailed, first class, postage prepaid to: Office of the Prothonotary Cumberland County Courthouse One Courthouse Square Carlisle, PA. 17013 (717) 240-6195 M. L. Ebert, Jr., Judge One Courthouse Square Carlisle, PA. 17013-3387 (717) 240-6200 Ms. Taryon Dixon Office of the Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA. 17013 (717) 240-6200 Official Court Reporter Office of the Court Reporter Cumberland County Courthouse One Courthouse Square Carlisle, PA. 17013 (717) 240-6200 Gareth S. Smith, Esquire 7200 Wisconsin Avenue, Suite 800 Bethesda, MD. 20814 (301) 961-5240 Counsel for Defendants Robert E. Meade Y ROBERT E. MEADE PLAINTIFF V. PATRICIA A. MILLER, ESQ. WALTER S. B. CHILDS, ESQ. AND THE ESTATE OF HELEN V. MEADE DEFENDANTS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 05-4173 CIVIL TERM IN RE: MOTION RAISING PRELIMINARY OBJECTION BEFORE BAYLEY, J. AND EBERT, J. ORDER OF COURT AND NOW, this 17"' day February, 2006, upon consideration of the Motion Raising Preliminary Objection filed on behalf of the defendants, the Answer filed by the Plaintiff and after argument, the Defendants' Motion for Preliminary Objection is GRANTED; IT IS FURTHER ORDERED AND DIRECTED that the Plaintiff's complaint is hereby DISMISSED WITH PREJUDICE. By the Court, M. L. Ebert, Jr., J. 951k be4 E.°Meade Plaintiff Gareth S. Smith, Esquire For Defendants CC 7 7-0 Court Administrator "._ _ { a cr g < < f "; bas 13371!O03202006 Cumberland County Prothonotary's Office Page 1 PYS510 Civil Case Print 2005-04173 MEADE ROBERT E (vs) MILLER PATRICIA A ESQUIRE ET A Reference No..: Filed........: 8/15/2005 Case Type.....: COMPLAINT Time.........: 3:23 Judgment...... .00 Execution Date 0/00/0000 Judge Assigned: EBERT M L J Jury Trial.... Disposed Desc.: Disposed Date. 0/00/0000 ------------ Case Comments Higher Crt I.: Higher Crt 2.: ******************************************************************************** General Index Attorney Info MEADE ROBERT E PLAINTIFF P O BOX 58215 WASHINGTON DC 20037 MILLER PATRICIA A ESQUIRE DEFENDANT SMITH GARETH S C/O WALTER S B CHILDS ESQUIRE 145 MAIN STREET ANNAPOLIS MD 21401 CHILDS WALTER S B ESQUIRE DEFENDANT SMITH GARETH S 145 MAIN STREET ANNAPOLIS MD 21401 MEADE HELEN V - ESTATE OF DEFENDANT SMITH GARETH S C/0 PATRICIA A MILLER ESQ C/O EALTER S B CHILDS ESQ * Date Entries - - - - - - - FIRST ENTRY - - - - - - - - - - - - - - 8/15/2005 COMPLAINT ------------------------------------------------------------------- 12/05/2005 AFFIDAVIT OF SERVICE - BY ALMA EROZO PROCESS SERVER ------------------------------------------------------------------- 12/05/2005 ANSWER TO MOTION RAISING PRELIMINARY WITH SUPPORTING AFFIDAVIT - BY ROBERT E MEADE ------------------------------------------------------------ 12/06/2005 MOTION RAISING PRELIMINARY OBJECTIONS WITH SUPPORTING AFFIDAVIT - BY WALTER S B CHILDS ESQ FOR DEFTS ---------------------------------------------------------- - 1/03/2005 ORDER TO ENTER FOR GARETH S SMITH ESQ FOR DEFTS AND WITHDRAW APPEARANCE FOR WALTER S B CHILDS ESQ ------------------------------------------------------------------- 1/05/2006 MOTION TO STRIKE THE DEFTS PRAECIPE FOR LISTING CASE FOR ARGUMENT - BY ROBERT E MEADE ------------------------------------------------------------------- 1/18/2006 RESPONSE TO MOTION TO STRIKE DEFTS' PRAECIPE FOR LISTING CASE FOR ARGUMENT - BY GARETH S SMITH ESQ FOR DEFTS ------------------------------------------------ 1/18/2006 PRAECIPE FOR LISTING CASE FOR ARGUMENT - DEFTS' MOTION RAISING PRELIMINARY OBJECTIONS - BY GARETH S SMITH ESQ FOR DEFT ------------------------------------------------------------------- 1/26/2006 AMENDED MOTION TO STRIKE THE DEFTS' PRAECIP FOR LISTING CASE FOR ARGUMENT - BY ROBERT E MEADE ------------------------------------------------------------------- 2/13/2006 OPPOSITION TO AMEND MOTION TO STRIKE DEFTS' PRAECIPE FOR LISTING CASE FOR ARGUMENT - BY GARETH S SMITH ESQ ------------------------------------------------------------------- 2/21/2006 ORDER OF COURT - DATED 2/17/06 - IN RE MOTION RAISING PRELIMINARY OBJECTION - GRANTED - IT IS FURTHER ORDERED AND DECREED AND DIRECTED THAT THE PLFF'S COMPLAINT IS HEREBY DISMISSED WITH PREJUDICE - BY THE COURT M L EBERT JR J COPIES MAILED --------------------------------- ---------------------------------- 2/27/2006 MOTION TO STRIKE DEFTS' ARGUMENT BY BRIEFS FOR DEFTS' SECOND SET OF BRIEFS - BY ROBERT E MEADE ---------------------------------------------------------- 3/03/2006 ORDER OF COURT - DATED 3/2/06 - IN RE PLAINTIFF'S MOTION TO STRIKE DEFENDANT'S ARGUMENT BY BRIEFS FOR DEFENDANT'S SECOND SET OF BRIEFS - DEFENDANT'S MOTION IS DENIED - BY M L EBERT JR J - COPIES MAILED 3/3/06 1.337?U03202006 Cumberland County Prothonotary's Office Page 2 PYS510 Civil Case Print 2005-04173 MEADE ROBERT E (vs) MILLER PATRICIA A ESQUIRE ET A Reference No..: Filed........: 8/15/2005 Case Type.....: COMPLAINT Time.........: 3:23 Judgment...... .00 Execution Date 0/00/0000 Judge Assigned: EBERT M L JR Jury Trial.... Disposed Desc.: Disposed Date. 0/00/0000 ------------ Case Comments Higher Crt 1.: Higher Crt 2.: - - - - - - - - - - - - - - LAST ENTRY - - - - - - - - - - - - - - ******************************************************************************** * Escrow Information * Fees & Debits BP Bal Pmts/Add End Bal COMPLAINT 35.00 35.00 .00 TAX ON CMPLT .50 .50 .00 SETTLEMENT 5.00 5.00 .00 AUTOMATION 5.00 5.00 .00 JCP FEE 10.00 ------------ 10.00 .00 --- 55.50 --------- --- 55.50 --------- .00 ******************************************************************************** * End of Case Information ******************************************************************************** e quE COPY FROM RECORD wimny whereof, I here unto set wry faro ;re seal of said C--onnurAt''+d? C_ar?!iMM. PC ,w ,.. -!) daV 1 Q1dd?? r .1 r« 12:35 P.M. '4 Appeal Docket Sheet Docket Number: Page 1 of 2 March 21, 2006 Superior Court of Pennsylvania 500 MDA 2006 AW, Robert E. Meade, Appellant V. Patricia A. Miller, Esquire, Walter S. B. Childs, Esquire and The Estate Of Helen V. Meade, et al Initiating Document: Notice of Appeal Case Status: Active Case Processing Status: March 21, 2006 Journal Number: Case Category: Civil Awaiting Original Record CaseType: Civil Action Law Consolidated Docket Nos.: Related Docket Nos.: SCHEDULED EVENT Next Event Type: Receive Docketing Statement Next Event Type: Original Record Received Next Event Due Date: April 4, 2006 Next Event Due Date: May 1, 2006 COUNSEL INFORMATION Appellant Meade, Robert E. Pro Se: ProSe Appoint Counsel Status: IFP Status: No Appellant Attorney Information: Attorney: Meade, Robert A. Bar No.: 15330 Law Firm: Address: PO Box 58215 Washington, DC 20037 Phone No.: Fax No.: Receive Mail: Yes E-Mail Address: Receive E-Mail: No Appellee Patricia Miller, Esq., Walter S.B. Childs, Esq., and the Estate of Helen V. Meade, at al Pro Se: Appoint Counsel Status: IFP Status: Appellee Attorney Information: Attorney: Smith, Gareth Schweizer Bar No.: 92480 Law Firm: Linowes and Blocher LLP Address: 7200 Wisconsin Ave Ste 800 Bethesda, MD 20814-4842 Phone No.: (301)654-0504 Fax No.: (301)654-2801 Receive Mail: Yes E-Mail Address: gsmith@linowes-law.com Receive E-Mail: No 3/2112006 3023 12-35 P.M! Appeal Docket Sheet Docket Number: 500 MDA 2006 Page 2 of 2 March 21, 2006 Superior Court of Pennsylvania Alft FEE INFORMATION Paid Fee Date Fee Name Fee Amt Amount Receipt Number 3/21/06 Notice of Appeal 60.00 60.00 2006SPRMD000273 I KIAL GOURT/AGENCY INFORMATION Court Below: Cumberland County Court of Common Pleas County: Cumberland Division: Civil Date of Order Appealed From: February 17, 2006 Judicial District: 9 Date Documents Received: March 21, 2006 Date Notice of Appeal Filed: March 20, 2006 Order Type: Order Entered OTN: Judge: Ebert, Jr., Merle L. Lower Court Docket No.: 054173 Civil Term Judge ORIGINAL RECORD CONTENTS Original Record Item Filed Date Content/Description Date of Remand of Record: BRIEFS DOCKET ENTRIES Filed Date Docket Entry/Document Name Party Type Filed March 21, 2006 Notice of Appeal Filed Appellant Meade, Robert E. March 21, 2006 Docketing Statement Exited (Civil) Middle District Filinq Office 3/21/2006 3023 ^a t4: ^J tN ROBERT E. MEADE Plaintiff V. PATRICIA A. MILLER, ESQ., WALTER S. B. CHILDS, ESQ., and THE ESTATE OF HELEN V. MEADE Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 05-4173 CIVIL TERM IN RE: OPINION PURSUANT TO PA. R.A.P. 1925 EBERT, J., April 4, 2006 In this civil case, Plaintiff has filed a pro se appeal to the Pennsylvania Superior Court following an order granting Defendants' Motion Raising Preliminary Objections and dismissing Plaintiffs complaint with prejudice. This opinion in support of the dismissal of Plaintiff's complaint with prejudice is written pursuant to Pennsylvania Rule of Appellate Procedure 1925(a). 1. STATEMENT OF FACTS Plaintiff's complaint is the latest of eleven total lawsuits filed in separate jurisdictions spanning three states against the Estate of Helen Meade (the "Estate") and against Defendant Patricia A. Miller and/or her counsel since Helen Meade's death in 1999.' Previous to this case, the most recent suit was brought in Stafford County, Virginia, and was dismissed with prejudice for lack of both subject matter and personal jurisdiction.2 ' Defendant's Motion Raising Preliminary Objections with Supporting Affidavit, filed December 6, 2005, (hereinafter "Affidavit"), Exhibit "C" 2 Affidavit, Exhibit T." Plaintiff's complaint in the present case was filed on August 15, 2005, and an affidavit of service was filed on December 5, 2005. Also on December 5, 2005, Defendants responded with a motion raising preliminary objections and asked that the complaint be dismissed for lack of subject matter and personal jurisdiction, to which Plaintiff filed an answer on the same date. In response to Defendants' praecipe to list the case for argument, Plaintiff moved to strike the listing of the case for argument3 and submitted his opposition to argument by briefs.' After opposing submission of the matter on briefs, plaintiff failed to appear for argument on February 15, 2006. On February 17, 2006, an order was entered granting Defendants' preliminary objections and dismissing Plaintiff's complaint with prejudice 5 which Plaintiff now appeals. Defendant, Patricia A. Miller, is an attorney with a law practice in Annapolis, Anne Arundel County, Maryland, and resides in Anne Arundel County, Maryland, and not Cumberland County, Pennsylvania, or anywhere in Pennsylvania. Ms. Miller was (but is no longer) the court-appointed personal representative for the Estate. Defendant, Walter B.S. Childs, is an attorney with a law practice in Annapolis, Anne Arundel County, Maryland, and resides in Anne Arundel County, Maryland, and not Cumberland County, Pennsylvania, or anywhere in Pennsylvania. Mr. Walters is the current personal representative of the Estate. The matters set forth in the complaint refer to disputes regarding the administration of the Estate. The Estate is under administration in Anne Arundel County, Maryland, and not in Cumberland County, Pennsylvania, or anywhere in J Plaintiff's Motion to Strike the Defendants' Praecipe for Listing the Case for Argument, filed January 5, 2006, and Plaintiff's Amended Motion, filed January 26, 2006. a Plaintiff's Opposition to Argument by Briefs s Order of Court, dated February 17, 2006, Bayley, J. and Ebert, J. Pennsylvania. The complaint fails to aver where the Plaintiff resides, where the alleged wrongs occurred, or to assert any basis for jurisdiction over any Defendant in Cumberland County, Pennsylvania, or anywhere in Pennsylvania.6 Previously, the Circuit Court for Anne Arundel County, Maryland, entered a Final Injunction dated May 25, 2004, enjoining Mr. Meade from filing in any court of Maryland a complaint or any similar form of civil action against Ms. Miller, her counsel, Mr. Childs, or any other person, entity or authority relating in any way to the Estate of Helen V. Meade without first obtaining leave of that court and complying with strict provisions, including attaching a copy of the Injunction to any motion seeking leave to file.7 II. LACK OF SUBJECT MATTER AND PERSONAL JURISDICTION Where a preliminary objection raises a question of subject matter jurisdiction, the test is the competency of the court to determine controversies of the general class to which a case presented for its consideration belongs. Strank v. Mercy Hospital of Johnstown, 376 Pa. 305, 102 A.2d 170 (1954). The matters set forth in the complaint at bar refer to allegations regarding the administration of an estate that is being administered in Anne Arundel County, Maryland. The complaint does not allege that any events took place in Cumberland County, Pennsylvania, or anywhere in Pennsylvania. This court lacks the competency to adjudicate events arising under the law of another state. This court also lacks personal jurisdiction over the Defendants. Personal jurisdiction may be asserted over a nonresident defendant if the defendant is present or 6 Plaintiff's Complaint and Affidavit of Service. ' Defendant's Motion Raising Preliminary Objection, Exhibit A: Order Granting Final Injunction. domiciled in the Commonwealth when served, or with consent of the individual. 42 Pa.C.S.A. §5301 (2004). Defendants Childs and Miller reside in Anne Arundel County, Maryland, and the complaint fails to aver that they were ever present or domiciled in Cumberland County, Pennsylvania, or anywhere in Pennsylvania. The Defendant Estate is under administration in Anne Arundel County, Maryland, and the complaint does not allege that any event regarding its administration took place in Cumberland County, Pennsylvania, or anywhere in Pennsylvania. Also absent from the complaint is any averment of where the Plaintiff resides. Not only are the nonresident Defendants' activities unrelated to this forum, they are nonexistent in Pennsylvania, including Cumberland County. There is simply no connection between the Plaintiff or the Defendants and Cumberland County, Pennsylvania. There is no provision in Pennsylvania law which establishes jurisdiction over the Defendants in Cumberland County, Pennsylvania. Furthermore, there is no nexus between the Defendants, the Estate, and/or the events complained of and Cumberland County, Pennsylvania, sufficient to make this court an appropriate venue in which to file this complaint. Plaintiffs penchant for filing frivolous lawsuits has already resulted in an injunction granted by a Circuit Court in Maryland which has jurisdiction of this matter, and this has likely prompted his current attempts at forum-shopping. Pennsylvania Rule of Civil Procedure 1006(e) states that "if there is a county of proper venue within the State the action shall not be dismissed but shall be transferred to the appropriate court of that county." Pa.R.C.P. 1006(e). Not only does no county of proper venue exist within the Commonwealth of Pennsylvania, but the jurisdiction in Maryland, where venue is proper, has enjoined the Plaintiff from filing this type of action against these Defendants. When a trial court cannot transfer the case, the only alternative available is dismissal because in order for a court to adjudicate an action, both jurisdiction and venue must exist simultaneously. Searles v. Estrada, 856 A.2d 85, 91 (Pa. Super. 2004). Because this court lacks both subject matter and personal jurisdiction over each and every Defendant, the dismissal of Plaintiffs complaint with prejudice was properly ordered. Maryland has enjoined the Plaintiff from filing the type of complaint he is attempting to foist upon this Court, and we need not countenance this frivolous litigation aimed at prolonging a matter which clearly falls within the jurisdiction of the State of Maryland. It is the recommendation of this court, that the Appellant be assessed costs damages pursuant to Pa.R.A.P. 2744. BY THE COURT, Robert E. Meade P.O. Box 58215 Washington, DC 20037 Plaintiff Pro Se ,Xreth S. Smith, Esq. Attorney for Defendants ?t Lk'4 V"' Linowes and Blocher, LLP 7200 Wisconsin Ave., Suite 800 Bethesda, MD 20814 'v` M. L. Ebert, Jr., J. O?? ?- 7 '`t ??_ i ?, 1 E+.a {i , 1 ? juG+ ?.i iJ:1 i`i i I Z ROBERT E. MEADE, Plaintiff, V. PATRICIA A. MILLER, ESQUIRE, WALTER S. B. CHILDS, ESQUIRE, AND THE ESTATE OF HELEN V. MEADE, et al., Defendants. * IN THE COURT OF COMMON PLEAS * OF CUMBERLAND COUNTY * * * No.: 05-4173 Civil Term * * * * * * * * * * * * * * * * * * RESPONSE TO OPINION ISSUED BY JUDGE M. L. EBERT JR, Comes now, the Plaintiff, having just received and read the opinion issued by Judge M. L. Ebert, Jr., and states the following: 1. That this opinion is totally bias for the Defendants and totally prejudice against the Plaintiff. 2. That this opinion is not based on the merits of the complaint or factual findings , but this opinion is based on an inadequate, misconstrued record which is a repeat of the Defendants' pleadings, answers and responses to pleadings, and inaccurate statements made by the Defendants in the Defendants' argument by briefs presented to the trial court prior to a hearing, being held without notice to the Plaintiff of that hearing. This opinion is solely a word by word verbatim of the brief presented by the Defendants. 3. That the issue in this complaint filed in Cumberland County is that the Defendants stole property belonging to the Plaintiff located in Pennsylvania. That the Defendants purposely misconstrued the issue to commit fraud on the court and to sway Judge Ebert, Jr. that it was the same issue that is being litigated in Maryland. r 4. That there has been a deliberate scheme on the part of the Defendants to steal and keep property belonging to the Plaintiff in other states. That the Defendants often revert to prejudicing the courts against the Plaintiff so as deter the Plaintiff from presenting evidence. That Judge Ebert, Jr. did not enforce the fact that subject matter jurisdiction is determined by law, not influence interjected by the Defendants' actions concerning property may only be brought where the property is located. 5. That Judge Ebert, Jr. made several errors of procedure for the sake of the Defendants. Judge Elbert, Jr. did not adhere to Pennsylvania's Code of Civility which states: a. "A judge should show respect, courtesy and patience to the lawyers, parties and all participants in the legal process by treating all with civility". b. "A judge should ...give all issues in controversy deliberate, informed and impartial analysis..... C. "A judge should recognize that the conciliation process is an integral part of litigation and this should protect all confidences and remain unbiased with respect to conciliation communications". 6. That the opinion of Judge Ebert, Jr. is just another indication of the strong bias he has for the Defendants and the strong prejudice he has against the Plaintiff. This is only a vindication by Judge Ebert, Jr. of Plaintiffs issues to be raised on appeal as stated by the Plaintiff in the Appellant's civil docketing statement. 7. That Judge Ebert Jr., through his opinion, is seeking to prejudice the appellate court against the Appellant prior to the continuation of the appeal before the next step, which is the briefing stage. 8. That Judge Ebert, Jr. denied the Plaintiff the right to be heard and abused 146 his discretion in not informing the Plaintiff of an official pending hearing and he abused his discretion in not ruling on the Plaintiffs pending motions prior to the scheduling of any type of hearing. 9. That Judge Elbert, Jr. states "The complaint does not allege that any events took place in Cumberland County, Pennsylvania, or anywhere in Pennsylvania". Judge Ebert, Jr. cannot aver to this statement, since he never allowed the Plaintiff to present a prima facie case of the circuit court's jurisdiction in person or cross-examine the Defendants for the purpose of evidence of jurisdiction. Judge Ebert, Jr. only accepted the one false affidavit presented by one of the Defendants for all of the Defendants. 10. That Judge Ebert, Jr. can only use his court's record and cannot use other courts' records. That it is evident that Judge Ebert, Jr. focused on the issues presented in other courts and did not focus on the issue in his court. Judge Ebert, Jr. made several comments without jurisdiction for the sake of the Defendants. Under the Pennsylvania Code of Judicial Conduct, "A judge should abstain from public comment about a pending proceeding in any court ". 11. That the Defendants obstructed justice by making false and libelous statements against the Plaintiff and by committing fraud upon the trial court. Judge Ebert, Jr. abused his discretion in accepting all the Defendants' false statements as true without evidence and erred in restating these false statements verbatim in his opinion. 12. That Judge Ebert, Jr. erred in including false and impertinent materials which were interjected by the Defendants to prejudice the trial court and these false and impertinent materials obviously assisted Judge Ebert, Jr., in the formulation of his bias opinion. 13. That Judge Ebert, Jr. had no jurisdiction to discuss other cases in other courts which were related to the Plaintiff but were not pertinent to this case. In any case presented to a trial court, the trial court judge is just allowed to form an opinion on the case before him in his court. 14. That Judge Ebert. Jr. in his opinion, in the last sentence of paragraph 1, footnote 5, misstates "Order of Court, dated February 17, 2006, Bayley, J. and Ebert, J." when in fact it was only Judge Ebert, Jr. who signed the Order. 15. That the Defendants have convinced Judge Ebert, Jr. to deny the Plaintiff due process so that the Defendants can be shielded from civil prosecution of civil crimes committed by the Defendants against the Plaintiff and against existing property located in Cumberland County, Pennsylvania. 16. That the bias shown by Judge Ebert, Jr. towards the Defendants shielded the Defendants from being held accountable for committing fraud upon the Court by presenting a false affidavit and for stealing existing property located in Cumberland County, Pennsylvania. 17. That Judge Ebert, Jr. did not make his own specific findings of fact and conclusions of law in this case since the record is bald due to the fact that the Plaintiff was denied the right to present his facts of jurisdiction. That the Fourteenth Amendment of the United States Constitution states "It is a fundamental tenet of constitutional law, that an individual may not be deprived of a property interest without due process of law' 18. That Judge Ebert, Jr., in the last sentence of his opinion, made a statement where he recommended that this appellate court assess the Appellant court costs and damages. This recommendation by Judge Ebert, Jr. is totally unwarranted, totally unjustified, and his motives should be questioned for such a totally bias recommendation. This bias recommendation by Judge Ebert, Jr. should not be considered by the appellate court. 19. That the Appellant in the Brief for the Appellant will prove that the cases cited by Judge Ebert, Jr. in his opinion, have no bearing on the Appellant's case, which is before the appellate court. 20. That even though PA. R.A.P, 1925 required Judge Ebert, Jr. to write an opinion, this rule does not give Judge Ebert, Jr. the right to attack the Plaintiffs character or make false statements against the Plaintiff without personally hearing from the Plaintiff. The false statements made by Judge Ebert, Jr, which were obtained from the Defendants, are not supported by any evidence and Judge Ebert, Jr. should not have repeated these false statements in his opinion to the appellate court. Re tfully submitted, Robert E. Meade P.O. Box 58215 Washington, D.C. 20037 (202) 468-1823 CERTIFICATE OF SERVICE I hereby certify that on the aAday of ILLP l_ , 2006, a copy of the foregoing was mailed, first class, postage prepaid to: M. L. Ebert, Jr., Judge One Courthouse Square, Rm. 404 Carlisle, PA. 17013 Gareth S. Smith, Esquire 7200 Wisconsin Avenue, Suite 800 Bethesda, MD. 20814 Counsel for Defendants Robert E. Meade Ti 05 -4173 J. S62015/06 ROBERT E. MEADE, APPELLANT V. PATRICIA A. MILLER, ESQUIRE, WALTER S.B. CHILDS, ESQUIRE AND THE ESTATE OF HELEN V. MEADE, ET. AL. IN THE SUPERIOR COURT OF PENNSYLVANIA No. 500 MDA 2006 ORDER OF COURT The Court hereby DENIES the application filed January 4, 2007, requesting reargument or reconsideration of the decision dated December 21, 2006. PER CURIAM DATE: February 26, 2007 TRUE COPY FROM RECORD Attest: F E B 2 6 2007 e Dep thonotary Superior Court of PA - Middle District No.: 500 MDA 2006 Carbon Copy Recipient List Addressed To: Mr. Robert E. Meade PO Box 58215 Washington, DC 20037 Carbon Copied: West (02) 610 Opperman Drive P.O. Box 64526 St. Paul, MN 55164-0526 Mr. Curtis R. Long Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Gareth Schweizer Smith, Esq. Linowes and Blocher, L.L.P. 7200 Wisconsin Ave Ste 800 Bethesda, MD 20814-4842 The Honorable Merle L. Ebert, Jr. Court of Common Pleas of Cumberland County Cumberland County Courthouse, One Courthouse Sq Carlisle, PA 17013 1013 -10/99 10/1/99 Karen Reid Bramblett, Esq. Prothonotary James D. McCullough, Esq. Deputy Prothonotary Pw e Superior Court of Pennsylvania Middle District February 26, 2007 RE: Meade, R. v. Miller, P. et al No. 500 MDA 2006 Trial Court Docket Number: 05-4173 Civil Term Dear : 100 Pine Street. Suite 400 Harrisbure. PA 17101 717-772-1294 www. superior. court.statc.pa. us Enclosed please find a certified copy of an order dated February 26, 2007 entered in the above-captioned matter. Very truly yours, '_ 711 ° C_ a6guAlk 4mes D. McCullou Deputy Prothonotary TP Enclosure cc: Gareth Schweizer Smith, Esq. The Honorable Merle L. Ebert, Jr. Judge Mr. Curtis R. Long Prothonotary West (02) i 1 Superior Court of Pennsylvania Karen Reid BramblM Esq. Middle District Prothonotary James D. McCullough, Esq. December 21, 2006 Deputy Prothonotary Certificate of Remittal/Remand of Record TO: Mr. Curtis R. Long Prothonotary RE: Meade, R. v. Miller, P. et al No.500 MDA 2006 Trial Court/Agency Dkt. Number: 05-4173 Civil Term Trial Court/Agency Name: Cumberland County Court of Common Pleas Intermediate Appellate Court Number: 100 Pine Street. Suite 400 Harrisburg, PA 17101 717-772-1294 www.superior.court.state.pa.us Annexed hereto pursuant to Pennsylvania Rules of Appellate Procedure 2571 and 2572 is the entire record for the above matter. Contents of Original Record: Original Record Item Part Supplemental Part Filed Date Description May 9, 2006 1 July 18, 2006 1 Date of Remand of Record: SE' 0 6 2007 ORIGINAL RECIPIENT ONLY'- Please acknowledge receipt by signing, dating, and returning the enclosed copy of this certificate to our office. Copy recipients (noted below) need not acknowledge receipt. e C Signature Printed Name /aaw Date _..+ -{ °, 'q ..? ice'' ?«; ?* ?.? _ .? 1. S62015/06 ROBERT E. MEADE, APPELLANT V. PATRICIA A. MILLER, ESQUIRE, WALTER S.B. CHILDS, ESQUIRE AND THE ESTATE OF HELEN V. MEADE, ET. AL. IN THE SUPERIOR COURT OF PENNSYLVANIA No. 500 MDA 2006 The Court hereby DENIES the application filed January 4, 2007, requesting reargument or reconsideration of the decision dated December 21, 2006. PER CURIAM DATE: February 26, 2007 TRUE COPT' I°.16 oft RECORD Attest: S'C'R n,6 z?eA- 7? Deputy Pro1h(- , ; p ., w y Superior Cou.-f ?. t .:" - N iddle DisMet Q -?o Vol, t.-a ;. J-S62015-06 NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37 ROBERT E. MEADE, Appellant V. PATRICIA A. MILLER, ESQUIRE, WALTER S.B. CHILDS, ESQUIRE AND THE ESTATE OF HELEN V. MEADE, ET AL, Appellees IN THE SUPERIOR COURT OF PENNSYLVANIA No. 500 MDA 2006 Appeal from the Order entered February 17, 2006 In the Court of Common Pleas of Cumberland County, Civil Division at No. 05-4173 Civil Term BEFORE: JOYCE, LALLY-GREEN, and TAMILIA, JJ. MEMORANDUM: FILED: December 211 2006 Robert E. Meade appeals from the February 17, 2006 Order granting the preliminary objections of appellees Patricia A. Miller, Esquire, Walter S.B. Childs, Esquire, and the estate of Helen V. Meade, et a/, and dismissing appellant's complaint with prejudice. After careful review, we affirm. On December 13, 1999, Helen V. Meade, appellant's mother, died in an automobile accident. Appellee ; Miller initially was appointed as the estate's personal representative but thereafter, ' appellee Childs was appointed. It is important to note that due in large part to the repeated lawsuits filed by appellant, the estate at issue is being administered and remains open in Anne Arundel County, Maryland. J-S62015-06 Appellant, believing that his mother's estate was being handled improperly by the personal representatives, filed numerous lawsuits naming appellees as defendants. In fact, the record reveals appellant has filed more than ten lawsuits regarding the administration - of his mother's estate in Maryland, Virginia, and now Pennsylvania. Given appellant's numerous frivolous lawsuits, the Circuit Court for Anne Arundel County, Maryland, recently entered an injunction that enjoined appellant from filing any further "...lawsuit, complaint, petition or any similar form of civil action" in the state of Maryland without prior leave of court. See Order Granting Final Injunction; Record, No. 22. Impervious to the court's action, appellant then filed a pro se complaint against appellees, in, Cumberland County, Pennsylvania, demanding "compensatory damages in the amount of nine hundred million dollars each and for punitive damages in the amount of nine hundred million dollars each." See Complaint, 8/15/2005, at 2; Record, No. 2. In response, appellees flied preliminary objections on the grounds Pennsylvania had no jurisdiction because appellant's complaint failed to aver that any of the parties, property, or events have any contacts with Pennsylvania. Record, No. 17. The trial court, upon review, agreed Pennsylvania Courts have no jurisdiction, and on February 17, 2006, granted appellees' preliminary objections and dismissed appellant's complaint with prejudice. Record, No. 101. This timely appeal followed. Record, No. 109., -2- J-S62015-06 On appeal, appellant raises three issues for our review: Was the procedure followed by the trial court erroneous, prejudicial, and a denial of the Appellant's rights? Did the trial court err in not striking the Appellees' false and impertinent materials which were interjected in the Appellees' preliminary objections? Did the trial ; court abuse its discretion in dismissing the Appellant's complaint? Appellant's brief at 4. Our standard of review from an appeal from the grant of preliminary objections is as follows: In determining whether the trial court properly sustained preliminary objections, the appellate court must examine the averments in the complaint, together with the documents and exhibits attached thereto, in order to evaluate the sufficiency of the facts averred. The impetus of our inquiry is to determine the legal sufficiency of the complaint and whether the pleading would permit recovery if ultimately proven. This Court will reverse the trial court's decision regarding preliminary objections only where there has been an error of law or abuse of discretion. When sustaining the trial court's ruling will result in the denial of claim or a dismissal of suit, preliminary objections will be sustained only where the case is free and clear of doubt. City Lighting Products Co. v. Carnegie Institute, 816 A.2d 1196, 1197 (Pa.Super. 2003) (citation omitted). The burden rests upon the party challenging the court's exercise of jurisdiction, and we must consider the evidence in the light most favorable to the non-moving party. Grimes v. -3- J-S62015-06 Wetzler, 749 A.2d 535 (Pa.Super. 2000). "Once the movant has supported its jurisdictional objection, however, the burden shifts to the party asserting jurisdiction to prove that there is statutory and constitutional support for the court's exercise of in personam jurisdiction." Id. at 538 (citation omitted). Here, appellees' preliminary objections challenged the jurisdiction of the Pennsylvania Courts on the basis Pennsylvania had absolutely no contacts with any of the events, property, or persons involved in this matter. Accordingly, the burden shifted to appellant; he failed to respond. Following our careful review, we agree with the trial court and conclude Pennsylvania has neither subject matter nor personal jurisdiction over any party to this action., ..See ?fford v. Jockey Club, 796 A.2d 370 (Pa.Super. 2002) (enumerating the minimum contacts test). Moreover, we find that not only is there an absence of "minimum contacts," there is an absence of any contact. This Court, through its plenary jurisdiction over matters of law and its inherent power and duty to refuse to exercise jurisdiction wrongfully visited upon it, should not permit appellant to enmesh Pennsylvania courts in the horrendous legal entanglements which the Maryland courts have enjoined. We reiterate the well-reasoned conclusions of the trial court below. The matters set forth in the complaint at bar refer to allegations regarding the administration of an estate that is being administered in Anne Arundel County, Maryland. The complaint does not allege that any events took place in Cumberland County, Pennsylvania, or anywhere in Pennsylvania. This -4- J-S62015-06 court lacks the competency to adjudicate events arising under the law of another state. This court also lacks personal jurisdiction over the Defendants. Personal jurisdiction may be asserted over a nonresident defendant if the defendant is present or domiciled in the Commonwealth when served, or with consent of the individual. 42 Pa.C.S.A. § 5301. Defendants Childs and Miller reside in Anne Arundel County, Maryland, and the complaint fails to' aver that they were ever present or domiciled ; in Cumberland County, Pennsylvania, or 'anywhere in Pennsylvania. The Defendant Estate is under administration in Anne Arundel County, Maryland, and the complaint does not allege that any event regarding its administration took place in Cumberland County, Pennsylvania, or anywhere in Pennsylvania. Also absent from the complaint is any averment of where the Plaintiff resides. Not only are the nonresident Defendants' activities unrelated to this forum, they are nonexistent in Pennsylvania, including Cumberland County. There is simply no connection between the Plaintiff or the Defendants and Cumberland County, Pennsylvania. There is no provision in Pennsylvania law which establishes jurisdiction over the Defendants In Cumberland County, Pennsylvania. Furthermore, there is no nexus between the Defendants, the Estate, and/or the events complained of and Cumberland County, Pennsylvania, sufficient to make this court an appropriate venue in which to file this complaint. Plaintiff's penchant for filing frivolous lawsuits has already resulted in an injunction granted by a Circuit Court in Maryland which has jurisdiction of this matter, and this has likely prompted his current attempts at forum-shopping. Trial Court Opinion, Ebert, 1., 4/4/06, at 3-4. Also see Order Granting Final Injunction; Record, No. 22. Accordingly, we find no error on the part of the trial court in granting appellees' preliminary objections and dismissing appellant's complaint with prejudice. _5_ J-S62015-06 Order affirmed.' Concurring and Dissenting Memorandum by Joyce, J. Judgment Fntemd: 711Y Prothonotary December 21, 2006 Date: ' Appellant's motion to strike appellees' brief and supplemental reproduced record is denied. -6- J-S62015-06 ROBERT E. MEADE, Appellant V. PATRICIA A. MILLER, ESQUIRE, WALTER S.B. CHILDS, ESQUIRE AND THE ESTATE OF HELEN V. MEADE, ET AL, Appellees IN THE SUPERIOR COURT OF PENNSYLVANIA No. 500 MDA 2006 Appeal from the Order entered February 17, 2006 In the Court of Common Pleas of Cumberland County, Civil Division at No. 05-4173 Civil Term BEFORE: JOYCE, LALLY-GREEN, and TAMILIA, 33. CONCURRING AND DISSENTING MEMORANDUM BY JOYCE, J.: FILED: December 21, 2006 I wholeheartedly agree with the esteemed Majority's conclusion that Appellant's case is without merit. I add that this case was frivolous from its inception and would recommend sanctions be entered against Appellant for filing this suit and for wasting the judicial resources of this Commonwealth. I am constrained to write separately however, due to what I perceive as a procedural error. Appellant notes that the preliminary objections were filed on Appellees' behalf by Walter S.B. Childs, Esquire, who while licensed to practice law in Maryland, is, not licensed to practice law in Pennsylvania. I note that this error is not fatal because the endorsement of a pleading filed in Pennsylvania by an attorney authorized to practice law in a jurisdiction outside of Pennsylvania is only a formal error; it does not render the J-S62015-06 pleading a nullity, as the error may be cured by filing an amended pleading. Washko v. Piatz, 534 A.2d 522 (Pa. Super. 1987). The record reveals that prior to the trial court ruling on Appellees' preliminary objections, Appellees recognized the need to retain a} duly licensed attorney; it was at this juncture that Gareth Smith, Esquire, an attorney licensed in Pennsylvania undertook representation of Appellees in this matter. See Order to Enter and Strike Appearance, 01/03/06; Response to Motion to Strike Defendant's Praecipe for Listing Case for Argument, 01/18/2006. However, Appellees did not file amended preliminary objections. As stated, the preliminary objections were endorsed by Attorney Childs. Attorney Childs, an out of state attorney, was not permitted to file a pleading on behalf of all Appellees; however, he was certainly permitted to file preliminary objections, pro se, in 'defense of himself. See Pa.R.Civ.P. 1025. Accordingly, I would remand this case to permit Appellees the opportunity to file amended preliminary objections that are endorsed by a licensed Pennsylvania attorney. At that point in time, the preliminary objections should be granted and any motions for sanctions entertained. -2- ...? `.' ,??-?' ??? ?.