Attorney General Motion to Transfer by lmg14795


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      The Commonwealth Of Pennsylvania                                                       ,-
              Dorothiea Roberts                                                                      ---'
              301 Whitpain Hills                                                        co
             Blue Bell Penna. 19422
       Docket No. CP-46-CR-00O5207-2005
               (Defendant Pro Se)                                April, 25th.2006


                     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.

     301 Whitpain Hills
     Blue Bell Penna. 19422
     Docket No. CP-46-CR-0005207-2005
         (Defendant Pro Se)


 The Commonwealth Of Pennsylvania                                                      -0
                 Vs.                                                                            ,~;;;~g
         Dorothiea Roberts                                                             1""'-'
         301 Whitpain Hills                                                            co        ---,
        Blue Bell Penna. 19422
  Docket No. CP-46-CR-0005207-2005
          (Defendant Pro Se)                                 April, 25th.2006


 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

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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