.' IN THE COURT OF THE COMMONWEALTH OF PENNSYLVANIA COMMON PLEAS MONTGOMERY COUNTY PENNSYLVANIA f"',,) c.n The Commonwealth Of Pennsylvania ,- Vs. '.:) Dorothiea Roberts ---' 301 Whitpain Hills co Blue Bell Penna. 19422 Docket No. CP-46-CR-00O5207-2005 (Defendant Pro Se) April, 25th.2006 IN THE COURT OF TflE COMMONWEALTH OF PENNSYLVANIA COMMON PLEAS MONTGOMERY COUNTY PENNSYLVANIA Motion For Change Of Venue! Motion To Transfer The accused, Dorothiea Roberts (Pro Se) Tenders this motion to transfer this case from the Common Pleas Court Of Montgomery County Pennsylvania to a district outside of Montgomery County. The accused submit this Court should consider the merits of this motion, but that the designation of the district to which the case is transferred, and that the location should be determined by the Honorable Judge of the Court. This motion is submitted under the ambit of Rule 22, Fed.R.Crim.P. In accordance with Local Rule 14(F), a brief in support is being submitted simultaneously with this motion and a proposed order granting the relief requested is also tendered. fully§,u~:~ 301 Whitpain Hills Blue Bell Penna. 19422 Docket No. CP-46-CR-0005207-2005 (Defendant Pro Se) IN THE COURT OF THE COMMONWEALTH OF PENNSYL VANIA COMMON PLEAS MONTGOMERY COUNTY PENNSYLVANIA r,") -". en The Commonwealth Of Pennsylvania -0 Vs. ,~;;;~g Dorothiea Roberts 1""'-' V} 301 Whitpain Hills co ---, Blue Bell Penna. 19422 Docket No. CP-46-CR-0005207-2005 (Defendant Pro Se) April, 25th.2006 IN THE COURT OF THE COMMONWEALTH OF PENNSYLVANIA COMMON PLEAS MONTGOMERY COUNTY PENNSYLVANIA Brief In Support Of Motion For Change Of Venue/Motion To Transer I Dorothiea Roberts, the accused defendant, submit this brief which is being submitted simultaneously with my Motion to Transfer this case to a Common Pleas Court outside of Montgomery Co~mty Pennsylvania. 1. I the accused, Dorothiea Roberts, is accused of harassment, and of making terrorist threats to the District Attorney of Montgomery County, Bruce Castor. 2. The accused has for the last 15 going on 16 years been the target of an ongoing unwarranted criminal investigation by the District Attorney's office as well as the F.B.I. And the Department of Justice, and the National Security Agency. 3. This unwarranted investigation and surveillance and wiretapping is the result of a complaint made against the accused by State Rep. Louise William Bishop, and Rev. Clearance Blair, and William Raymond, and Anthony Rosato of Metro Traffic, and other members of Bright Hope Baptist Church in Philadelphia, where the accused attended and was a member. These complaints were made in retaliation for the accused having told the woman to call the police regarding her son. The accused did not even know the persons who made the complaint against her. 4. Though the accused did not even know the complainants, and had never threaten them. They made these actuations against the accused and the accused was arrested, by members of the Horsham Police Dept. 5. This incidents stem from the accused having advised a woman, who she had befriended at the Church, to go to the police, when the woman, who had two young boys, told her that she suspected that a man in the church had raped her son. The man she was accusing turned out to be William Raymond, an, congressional aide to Congressman William Gray, who is the Pastor of Bright Hope Baptist Church, and was the accused Pastor. 6. The accused had been having trouble with William Raymond, because of his contumely trying to pry into her financial affairs, concerning her bankruptcy and real state, but after this incident concerning the young boy, William Raymond got mad at the accused and made these unfound complaints against her, him, and got State Rep. Louise William Bishop to do the same. 7. From 1990-Present: The accused has been arrested over 14 times. The District Attorney has always arranged that there is no trial and that the accused against her will is placed in Norristown Hospital, and declared incompetent to stand trial, therefore ensuring that he does not have to answer, as to why he has her and her daughter under surveillance and wiretapping them. The Accuses Informal Brief/Statement and Chronology Of Events In Her Own Words: My name is Dorothiea Roberts. I am a fifty five year old Black African American Woman. I was born on July 14, 1950. I have one daughter, named Zenita Henderson who is now age 38. My daughter and myself have resided in Montgomery County Penna. for approximately thirty four years, at addresses 2907 Aspen Circle, Blue Bell Penna. We also lived at 2 Jackladder Circle in Horsham Township, were these incidents occurred, and now we are living in Whitpain Township. In 2001 my daughter, Zenita; bought a home here in Whitpain Hills, at 301 Whitpain Hills, Whitpain Township, where we have resided for going on 5 years. I shall try to explain how we came to live here in Montgomery County Penna. In February of 1972 I married, my now ex. husband.sylvester Roberts Jr. I was at the time living in Philadelphia, and my now, ex. husband was living with his family in Glenside Penna., which is in Montgomery County Penna. Upon our marriage, I moved to Montgomery County, because my husband worked in the County, at Western Electric Co. in King of Prussia Penna. We moved to 2907 Aspen Circle Blue Bell Penna. We were one of about 10 black families that live in the development in which we rented our townhouse, in Blue Bell. In December of 1978 my ex. husband Sylvester Roberts Jr. and myself bought a home in Horsham Township, which is a predominately white suburb of Philadelphia. Horsham Township at that time was a very small Township in Montgomery county and 98 % white. There were only about three Black families who owned their own home in Horsham Township at the time that we bought our home in 1978. There have been many more black families that own homes there now. We were one of the first families, black or white to purchase a home in Sawmill Crossing which is the name of the development we bought our home, there in Horsham. I was made aware of Horsham Township's Police departments feelings towards Blacks in Horsham almost immediately after we had bought and moved into our new home located at No.2 Jackladder Circle, Horsham Pa. 19040., but nothing could have prepared me for the blatant hatred, and violation of our Constitutional and Civil Rights, that my daughter and I have suffered as a victim of racism by the Horsham Police Dept., namely Ltd. Robert Del DelSoldo, Sgt. Dave Wolfman, Sgt. Jon Clark, Officer Douglas B. Bohl and members of the media, Anthony Rosato and John Brown, and Troy Morris, and others of Metro Traffic, here in Penna. as well as Metro Traffic in Washington DC., and the District Attorneys of Montgomery County, Michael Marino, Bruce Castor, and District Justice Richard Price. The former District Attorney Michael Marino, as well as our present District Attorney Bruce Castor, have refused to allow me to file a complaint. I tired to file a complaint with the Office of Attorney General here in Montgomery County Penna. I received a letter from a Mr. John Burfete, stating that his office did not have the authority to investigate my claim against the Horsham Police and the District Attorney, and that they could not help me. I also filed a complaint with the U.S Department Of Justice, in 1995. I received a letter from a Mr. Deval L. Patrick and a Daniel Mestas of the Civil Rights Division of the Department of Justice stating that they had investigated and found no violation to my constitutional rights by the Horsham Police dept. or the District Attorney's office. I then filed a complaint with the FBI, again I was told there was nothing that they could do to help me. This Sir a disgrace on behalf of the Justice Department. They are very much aware of what is going on here in Montgomery County Penna. as they were in Washington DC. I feel that their tolerance of this type of hate crime, racism and blatant disrespect for the Constitutional and Civil Rights of my daughter and myself, is criminal. We as United States Citizens expect more from our Police, and District Attorneys, and I will not tolerate or except this kind of treatment from our Justice Department. Both Janet Reno, as well as John Ashcroft, refused to take responsibility for what is going on here in Montgomery County. What they are doing to my daughter and myself, can only be described as psychological t9rture, as well as a hate crime, against two black women. For the last 14 years,. My daughter and myself have lived under conditions that can only be described as illegal and inhumane. I understand that a unwarranted complaint had been filed against me by State Rep. Louise William Bishop of Penna. and ex. Congressmen William Gray's aide William Raymond. This complaint stem from a incident where a young boy, who along with his family attended Bright Hope Baptist where William Raymond is a Deacon, was being sexually assaulted. I was told of this episode by the young boy's mother, and upon hearing of it I told her she should immediately notify the Police. I was overheard and William Raymond was told what I had said, thus the trouble erupted between William Raymond and myself. I at the time did not even know that the mother of the young boy was talking about William Raymond. But even if I had and Myself visited at Bright Hope often after that, and eventually we joined the Church. It was during the orientation as a new member of the Church that I met Deacon Bill Raymond. He seemed very nice and was interested in all of the new members. During our first meeting we talked about many things. I told him that I was divorced and that I owned a home in Montgomery County. He seemed to be really concerned about me. I told him that since my divorce, I had been trying to keep my home going by myself, and that though it was hard to do, that God had always made away. He told me that keeping the house by myself might not be what God would have me to do, because it might be to much for me financially. After that conversation he would always, when ever I would run into him at Church, ask me how I was making it out with my home, and if I ever wanted to sell my home to let him know first, because the Church often bought homes from it's members. I told him that I had no intentions of selling my home. He told me that if I ever did change my mind to come to him. He even wanted to know how much lowed on my home. He said he knew the area in which I lived and that the homes were worth a lot. He told me not to be ashamed to come to him if I need any help, that Rev. Gray was a Congressman and that he often helped members of the Church with their problems concerning their real estate, as well as other issues. He kept trying to pressure me to tell him about my financial situation and how much lowed on my home. I was very uncomfortable with this conversatiop so I always just told him that if I ever decide to sell my home I would let him know, and I would try to change the subject. I did not feel that Deacon Raymond had any right to press me for my personal business. Deacon Raymond would often call me at home and ask how I was doing, but the conversation would always end with him asking about my home and had I decide to stay on there and wasn't to much of a responsibility for me alone. I would always tell him as I had told him before, that should I plan to sell my home I would let him know! Then one Sunday Deacon Raymond saw me in the hall of the Church right before services had began and he asked me to stay after the service was over that he wanted to talk to me. I had no idea of what he wanted to say to me, I agreed. I thought he had wanted to talk to me concerning some business about the Club that I belonged to there at the Church. When we met Deacon Raymond informed me that he had been told that I had filed a Chapter 13 Bankruptcy and that I was going to lose my home and that he wanted to help me. He went on to say that he had somebody that might want to buy the house from me and that I should think about it ! I was outraged! I asked him how did he know about my personal business. He just laughed and said that he had ways, that Congressman Gray always knew who was in his Church or something like that. I told him that I did not think that my home or finances was any of their business and that I was very hurt that they were prying into my business. I was very hurt and angry, Deacon Raymond kept telling me not to be angry that he wanted to help me. I told him that I felt that he had no right to pry into my life. He tired to explain to me that Congressmen Gray had to know who was in his Church because of his position as Congressman and for Security reasons and that it was no big thing. I left the Church that day feeling very upset about this conversation. He tired to call me on the phone several times that evening at my home, but I would not talk to him. I continued to attend Church there but I tried to avoid Deacon Raymond. About 3 mos. later as I was standing in the Church hallway, when a woman, that had joined the Church the same time as my daughter and myself, came up to me in tears. I tried to get her to tell me what was wrong. finally she told me that she expected that there was a man in the Church that was doing things to her son that was improper. I was astounded, I asked her had she been to the Police? She was so upset and crying so loud that other people in the Church hallway were coming over to us. I kept telling her not to cry and that she should have called the Police. A woman by the name of Ms. Boyer, who is was an elderly woman in the Church came up while I was trying to console her, and heard me say that she should have called the Police. Mrs. Boyer asked her what was she so upset about and who was I telling her to call the Police on. She told Mrs. Boyer that she knew that her son had been assaulted by someone in the Church. Mrs. Boyer became ery upset also, she asked her who did she think would do such a thing? The woman said that she knew it was Deacon Bill Raymond. At this Mrs. Boyer said that she didn't believe the woman and that I had better watch giving advice to people to call the Police. She went on to say that she had been a member of the Church for 37 yrs. and that she had known Bill Raymond since he was a baby! She said that she was going right away and tell Congressmen Gray before this got any further. She went running towards the Church office. From then on Deacon Raymond never spoke to me again in Church. About this time there was a rumor spread around the Church that there was a woman in the Church who was going to be arrested soon, that she had used about 33 different names and that she had been to jail and was under investigation for bank fraud, insurance fraud, arson, and all type of things. Everyone was talking about it and wondering who it was. Then I got a call one night at home from Deacon Raymond, he told me that I had better watch myself and that he had heard what I had told that woman, she should have done called the Police. He told me that I should be the last one to tell anyone to call the Police, because he had found out everything about me and that he had a friend named Anthony who did the traffic reports for radio and that he was friends with members of the Horsham Police Dept. and that he knew that I was being investigated for all sorts of things. I told him that was a lie, I also told him not to call my home anymore. He just laughed, and said that I was not going to have any home soon that he had taken care of that! He then hung up. I did not go back to the Church again after this. It was about this time that my home started to be illegally entered. I had joined another Church and came home from Bible studies one night to find that my front door was open. my home had been entered and ransacked. Things were broken everywhere. I called the Horsham Police but they would not come to my home. I was outraged! I was told to find out if any thing was stolen and to make a list and send it to them, but not to call them because they were not coming to my home. I could just send them a list of any thing that was destroyed. The Police Offiicer that was on the phone just laughed and told me that they would only come to my home if caught the person who broke in to my home and kept them there till they got there! This was just the start of everything that has happen in my life for the last 14 1/2 years. I have tired unsuccessfully for the last 7 1/2 years to find out the nature of their complaint but the District Attorney here in Montgomery County Penn. Bruce Castor, as well as the former District Attorney, Michael Marino, has refused to tell me. My home has been repeatedly broken into by those that the District Attorney has hired to investigate me and when I complained to him about it, I was arrested for harassment and making terrorist threats against members of the Horsham Police Dept., Clarence Blair & Anthony Rosato, and other members of Metro Traffic Inc. I have spent almost three years in prison off and on for the last 14 years, and the District Attorneys here in Montgomery County even had me committed to a mental hospital. I moved to Washington D.C. in May of 1997, with the hope of starting my life over there with my family, but the wire tapping and breaking into my home there continued. After my having caught a member of Metro Traffic illegally entering into my home in Washington, I was arrested there in Washington on the charges of . Terrorist Threats. They claimed that they had me on tape threatening them. This was not so! They only told this lie to get me arrested. The Judge there in Washington later dismissed the case after they could not produce the tapes. I was represented in this case by a court appointed Lawyer. I have tired to file a Freedom of Information Act to find out what is going on. 1- On August 11, 1993. I was arrested at my home located at no. 2 Jackladder Circle, Horsham, Penna. 19044 by Sgt. Robert DelSoldo and other members of the Horsham Police Dept. and two men from the Emergency Services Mental Health staff from building SOof Norristown State Psychiatric Hospital in Norristown Penna. 2. - I was taken before Judge Richard Price the Horsham Township's District Justice, for a Preliminary Hearing. I was not represented by an Attorney. I was not read my rights. I was only told that a Criminal Complaint had been filed against me by Anthony Rosato of Metro Traffic, Network Services Inc., and that I was being arrested on the charges of Stalking, Terrorist Threats and Harassment by Communications against Anthony Rosato. I was outraged, because for the last two years, I had been telling the Horsham Police and the Montgomery County District Attorney, Michael Marino, that Sgt. Robert DelSoldo and other members of the Horsham Police Dept. and members of Metro Network Traffic Services, as well as members of Bright Hope Baptist Church has been illegally entering into my home. 3.- Members of the News Media and the Papers were present in the Court room. District Justice Richard Price refused to allow me my right to waive my Preliminary Hearing. He said that I better not open my mouth, that he was going to teach me a lesson because I had continued to insist that members of his Police Dept. and Anthony Rosato, etc.,. were breaking and illegally entering into my home. It was alleged that I had went to Metro Traffic Network Services in Phila., and that I had entered into their suit of offices, announced to the receptionist that I was there to kill Anthony Rosato Then threaten to shot the receptionist then made it pass their security and into their studios and that once in the studio I had to be removed from the studio by the Police and the Security on the premises. None of this is the truth. The truth is that I never entered into Metro Traffic. Metro Traffic at the time of this alleged incident was located in a one room apartment. They had no receptionist and I never was removed by any Police dept. or Security Officer. The fact is I never even entered Metro Traffic. I had only stood in the hallway of the apartment and knocked on the door. It was answered by a young man who told me when I asked for the station manager that he was not there. I then told the young man to please tell Anthony Rosato to stay out of my home. I did not have a gun nor did I threaten anyone. Because of this incident I was arrested on a complaint filed against me by Anthony Rosato. The District Attorney's own witness at the time of my trial stated that I had never entered into Metro Traffic and that I had not been removed from their studios by anyone. The District Justice Richard Price refused to listen to this witness, and I was then ordered that I be taken to the Norristown State Hospital , building # 50 for a Psychiatric examination. Jqdge Richard Price also stated that Sgt. Robert DelSoldo , who is one of the Police Officers that I had identified as having been one of the Police Officers that I had seen breaking into my home, had already made the arrangements and that he had already committed me . involuntarily. I was also told that my Bail of one hundred thousand dollars, would be raised even higher if I managed to raise the $100.000.00 . Judge Price said that he was making by Bail high so that if I didn't be recommitted by the Doctors at Norristown State Hospital, I would still be kept in jail. I told Judge Price that I had never been in jail or in any Mental Hospital or had any mental illness. He just laughed and said he was going to teach me a lesson. 4.- After this Hearing before Judge Richard Price, Sgt. Robert DelSoldo transported me to the Emergency Services Building 50 of Norristown State Hospital. The men who Sgt. Robert DelSoldo had bought to my home from Building #50 would not transport me, because they said they saw no reason to committee me to the facility, and they left after the Hearing. One of the men told me that I had better get an Attorney fast, and that he nor his men were going to have anything to do with me as far as committing me. On our way to the Norristown State Hospital in the Police car, Sgt. Robert DelSoldo kept laughing at me. He told me that "I should have taken his advice and got my black ass out of that house when he told me too." He told me that he had to "de - house me", because I didn't listen to him" He also told me that" he hoped that the doctors when he got me to the hospital shot me up with drugs and give me a frontal lobotomy ". He went on to say how no one was ever going to believe me, when I tell them that he or Anthony Rosato, or anybody else broke into my home. He told me how well liked Anthony Rosato was in Montgomery County, and that nobody was going to take the word of a "black crazy ass woman" over his. He also told me t I that he was going to see that I spent years in the Mental hospital and the County jail, he kept saying" I should have gotten my black ass out of that house while I had the chance". 5.- When we arrived at the Hospital I was spoken to by a Psychiatrist by the name, Dr. Venu Merkeejee. Dr. Merkeejee told me that she had already read the Police report prepared by Sgt. Robert DelSoldo, and she had also talked to him earlier that day and that she didn't believe that him or anyone else had broken into my home. She said that she believed that I had stalked Anthony Rosato and that not only was Anthony Rosato and Robert DelSoldo not coming into my home, she said that I was a liar and a very sick woman and she was going to help me! I kept trying to tell her that I was not telling a lie. After no more than 20 mins. of her telling me that she didn't believe me, She diagnosed me as being dangerous to myself and others and Delusional. She then committed me to Norristown State Hospital. I was devastated. I could not believe that Dr. Merkeejee whom I had never met before in my life and who knew nothing about me other than the lies and half truths that Sgt. Robert DelSoldo had wrote in the Police report would make such a diagnosis of anyone. I tried telling her that Sgt. DelSoldo was just trying to stop me from trying to file a complaint against him because I had caught him leaving out of my home after h~ had searched it with out a warrant. She wouldn't believe me! She told me that she was going to keep me there in the Hospital until I started thinking clearly, and stopped accusing Sgt. Robert DelSoldo and Anthony Rosato and other of illegally breaking and entering into my home. 6.- On August 17,1993 seven days after Sgt. Robert DelSold had 302 me into Norristown State Hospital, a Mental Health Hearing was held at building # 50 . I was not represented by an Attorney. Sgt. Robert DelSoldo testified that I had stalked Anthony Rosato and that I had phoned him hundreds of times, all of this is a lie. I tired to tell the Doctor by the name of Rico Nell that Sgt. DelSoldo had made up the story because I had caught him in my home. Dr. Venu Merkeejee was there and also testified that she didn't believe me and that none of it happen that I was Delusional. She also said that because I had refused to take the medication by the name of Hadol that she had prescribe for me that, she was recommending that I be recommitted for an additional 90 days for further treatment. I tried to explain that I didn't even drink and that I had never taken any drugs. Dr. Rico Nell said that she agreed with Dr. Merkeejee that I needed further treatment. On August 17th. I was again involuntarily committed to Norristown State Hospital, only this time I was committed to Building # 1 which is the Civil section of the hospital, for persons who have yet to go to trial. I will never understand how these Doctors were treating me for Stalking and Terrorist Threats and I had never been to Court where my guilt or innocence could be determined. I had no money for an Attorney. I remained in Norristown State Hospital for 90 more days before I was released. In the mean time my daughter got an Attorney, who got my Bail reduced from $100,000.00 to 9,500.00. I used my home as collateral.
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