Brad Reinhart, Codes Manager, assuming the position at the City of Reading Codes Office.

CITY OF READING:  Suit against Reading Codes Inspector (Brad Reinhart) seeks statement from district judge.

CITY OF READING:  Is the City of Reading too silly to get the job done?

BRAD REINHART AND THE CITY OF READING SUED AGAIN!  JUNE 23, 2010, Pair claims illegal labor practices in lawsuit against Reading, mayor, police chief, others

THE CITY OF READING:  ABSURDISTAN OR BANANA REPUBLIC?

VIEW THE VIDEO HERE OF BRAD REINHART USING A SLEDGEHAMMER TO SMASH THE DOORS OF A PROPERTY.

CITY OF READING:  THIS IS A "HEALTH & SAFETY INSPECTION":

FLOURIDE IN WATER EXPOSED: Does the City of Reading Flouridate the Water?  How to make people stupid, lethargic and apathetic.  Are the politicians and other criminals in Reading, PA drinking too much Flouride?

• Making people stupid-using flouride
• Flouride Influence
• Flouride Deception
• Flouride Agenda
• Politics or Science?
• Flouride Poisoning of Children
• Flouride Risk in Water
• Flouride Dangers
• Flouride Alert

CITY OF READING INTEL:  Do you know that States, Counties and Cities keep two sets of books?  Read about Comprehensive Annual Financial Reports and how they hide assets owned by government.

• Listen to this audio report on CAFR.

All City of Reading Codes Officers must take an oath of office to obey the Constitution.  They are public servants.  And yet, they violate the Constitution through warrant less searches, refusing to answer basic questions about their forms, and colluded with Magisterial District Justices to increase prosecutions.

"The oath of office:  I _________ do solemnly swear that I will support, obey, and defend the Constitution of the United States, and the Constitution of the Commonwealth of Pennsylvania and the City of Reading Home Rule Charter; and that I take this obligation freely, without any reservation, and that I will faithfully discharge the duties of Codes Enforcement Officer with fidelity, so help me God."

Does the City of Reading Codes Office remind you of Stalin?

THE CITY HALL MANIFESTO  by Guillermo D Jalil

How to deal with bullies in City Hall.

Anyone may copy the contents of this website.  No rights reserved.

THEIR TRAP/THEIR GAME

They issue a citation/violation placing you into a defensive position.  It's a lose-lose situation for you.  If you beat the citation, you still lost time and money fighting the citation.  They operated on work time and got paid.  You lost work time and lost money.  They depend on this to keep you in a defensive posture and aggravated.  All they need to do is write another citation or violation.  You defend, defend, defend costing you time and money.  After work, they go home and forget about you.  You go home thinking about the problem.  If you win, they laugh between themselves.  They know they won by making you upset, poorer or frustrated.

HOW DO YOU TURN THE TABLE ON CITY HALL?

Make your case their headache at work and at home.  When they wake up, you must be the first person on their mind.  When they go to the toilet, they must be thinking about you.  Wear them out and wear them down.  Do this and they will think twice before they ever touch you, or your property, again.  Then, expect their retaliation.  Be ready for the retaliation and use it against them.  That's the best solution to fighting City Hall.  And this website will teach your the principles of how to get this done.

REDEFINE VICTORY.  Don't focus on suing for money.  Rather, focus on exposure and occupying their time.   Make them spend money.  Expose them at every opportunity.  For every minute they are occupied with you, they are not victimizing someone else.  For every person they occupy to defend their position in court, they are disabled from writing up other complaints.

The citations and violations they write are used as a supplemental "tax" on the local peasants.  When you occupy their time, they must spend more money on your case than what it's worth.  Then when they retaliate, they must then defend against your claim of retaliation.  This is the real battle.  The battle is not over money, it's over employee time.  The battle is not over compensation to you.  It should be how they can wrestle free of the complaints you filed, so they can get back to their own schedule, and a normal life.  This is victory.  When they wish you went away, so they can go back to their schedule of easy targets....this is victory.

WHAT TO DO WHEN DEALING WITH A BULLY, AND SOMEONE FINANCIALLY STRONGER  THAN YOURSELF

If you refuse to fight, they'll pick on you again.  If you fight, you'll probably lose.  But...giving them a black eye in the process will make them think twice before picking on you again.  The goal:  Make them know they were in a fight after it's all over.  Make it more expensive for them to fight than they realized.  Make it inconvenient and costly for that City Hall bully.  When the City Hall bully realizes that you're more than a bag of chips, he'll move on to someone else.  He'll retaliate and that's fine...use it against him.  Then use that retaliation as evidence to sue him, his supervisors and the City itself.

THE SOLUTION:  TRAP THE BULLY INTO YOUR FIGHT.  HERE'S WHAT TO DO:

1. VIDEO TAPE/AUDIO TAPE INTERACTION WITH CITY OFFICIALS.  THEY ALWAYS LIE.  USE THEIR LIES AGAINST THEM.  SHOW PROOF IN A PUBLIC FORUM.

2.  POST A WEBSITE.

    Expose their actions in a public forum.  Everyone in your town already knows who is corrupt.  Those considering doing business in your town should know what's going on.  This is important because:

     a.  It emboldens others to act and join your fight.

    b.  The website is a central place for other victims to share stories, strategies and experiences.

    c.  You may be able to find like minded people to help you.

    d.  You may be able to enhance your defense because others will contribute corroborating evidence for your cause.

     e.  It embarrasses the aggressor.

     f.  The aggressor thinks twice before doing it again.  You've taken the wind out of his sails.  Once exposed, he'll think twice before victimizing someone else.

     g.  You're better able to organize your thoughts and your plan.

     h.  You're better able to organize documents on the computer.

     i.  You provide tools and encouragement for others who thought about fighting City Hall, but afraid they were the only one.  Don't let them feel alone.  Be the first and others will follow--I promise.

     h.  Supervisors are aware of the situation and feel aggravated about the website.  Although you may never hear of it, they'll call the aggressor unto the carpet complaining about the website and what happened.  They will cover up their mistake.  Then use their cover-up against them.

3.  ALWAYS TAKE IT TO THE VERY NEXT LEVEL.

Expect to lose at the District Justice level.  Most District Justices in the City of Reading are in collusion with the City.  This particularly applies to DJ William Hall.  He's seemingly 100% in collusion with the City.  Just sit in his "court room" and you'll see the evidence.  Every decision he makes, every comment he states, is in favor of the City.

So, this is what you do on the DJ level in facing the City of Reading Codes Office:

• Subpoena everyone remotely related to your case and occupy their time as much as you can.  This means you subpoena the Assistant City Solicitor, so the City Solicitor must represent the case.   Subpoena the codes officer, the codes officer's direct supervisor, and a few other codes officers that may or may not be connected to the case.   This will occupy the entire morning, or entire afternoon, of the City Solicitor, the Assistant Solicitor and one or more Codes Officers.  This is an accomplishment!  The City can't continue to harass property owners with bogus codes violations when hearings occupy too much of their time.

• In court, get their side of the story and ask as many questions you think are relevant to your case. 

• In court, ask as many simple or stupid questions as you like and occupy their time.

• If District Justic (DJ) William Hall doesn't let you subpoena witnesses, then he violated your rights.   Ask an attorney on how to motion to have the case thrown out because his office didn't allow you to subpoena witnesses.  Or, just appeal the case the Berks County Court of Common Pleas (ask an attorney if you like) by filing paperwork at the courthouse.  Anyone can do it. 

  • Look up the Bill of Rights.  You have the right to call witnesses on your behalf.

    • Sixth Amendment – Trial by jury and rights of the accused; Confrontation Clause, speedy trial, public trial, right to counsel

      In all criminal prosecutions, the accused shall enjoy the right to a speedy and public trial, by an impartial jury of the State and district where in the crime shall have been committed, which district shall have been previously ascertained by law, and to be informed of the nature and cause of the accusation; to be confronted with the witnesses against him; to have compulsory process for obtaining witnesses in his favor, and to have the Assistance of Counsel for his defense.

  • In case you're considering obtaining an attorney for the DJ hearing...  Most people don't.  What the District Justices think and decide are insignificant if they rule against you.   Why is it that they don't count?  If you lose, you can appeal the decision to a real judge:  In the Berks County Court of Common Pleas.    Then the matter will be decided by a competent person who has a real law degree.  And the Berks County Judges actually passed the bar exam!  Although there are many District Justices in Pennsylvania who are competent and respectful, most of DJ's in the City of Reading are biased and unprepared to do the job.  Many them, unfortunately, produce the appearance of due process, but are just a farce.   Accept this and move on.

  • Remember, you get a new hearing once you appeal.  What's said and decided in this hearing is meaningless, even if you are found "guilty" of the codes violation.  What matters is that you occupied their time, you collecting information on what they have as evidence, and you received an education about the system.  Focus on relaxing in court.

  • Use the hearing to take notes on the evidence they have against you.  This is the evidence that they purport to have.  Expect them to lie in court.  Don't be shocked.  This is how they operate.  It's normal to them.  Don't get upset. 

  • Everything that's said at the DJ hearing is not recorded in any way!  The City of Reading Codes Officers can say anything they want, and even change their story, and there's no record to refer to.   If it's not recorded, it doesn't count.  Relax, this is how they do it in the City of Reading.

•   On appeal, subpoena the same characters again!  This means the Solicitor, the Assistant Solicitor, and the Codes Officers must spend a second morning or afternoon defending their position on the same codes violation.  They can't afford to make money this way. 

Remember, City Hall considers their violations and citations as a source of income.  Turn that into a flowing river of headache for the public servants involved.  Make them spend more money defending their violation/citation than what it is worth.

     a.  Expose their actions to the public

     b. Occupy their time as much as possible.  If there's an upcoming hearing, subpoena as many of the city officials, their supervisors and Assistant City Solicitor to every hearing.  This means the City Solicitor must cover the hearing on behalf of the City.

     This ties up their time.  If one person is able to tie up the time of four or five codes officials for one hour or half the morning, that's a net loss for them.  They can't fine others while they are dealing with you.  If more people did this, they would think twice before harassing anyone with frivolous violations.

     Here's the bottom line:  By walking or driving around the City of Reading, anyone can pick out hundreds of flagrant codes violations.  Instead of compelling changes to properties that are a public hazard, they inspect good properties and cite them for frivolous violations.  Therefore, they are targeting property owners who have good properties because they have something valuable to lose--so they are willing to pay up.  And then the Codes Office cites people for failing to file rental permits.  Why?  It's about money for them.  This has nothing to do with health and safety.  Since they really are in the business of collecting fees and fines for their department, they use "health and safety" as a cover for their activity.  This is just an additional tax upon the property owners of the City of Reading under cover of "health and safety inspection."  It is a scam.

HINT:   Look at each city official and their supervisors, and department head.  Many times, they are required to reside in the area.  Many times, they don't follow their own rules.

4.  EXPECT RETALIATION -- AND USE IT AGAINST THEM

Retaliation is their reaction.  It's also to your benefit.  A retaliation claim against them is usually stronger, and carries more weight, than the initial problem or issue.  It makes them look bad.  They always make mistakes when they are retaliating because they are reacting.  When they are reacting--you win.  Their retaliation is almost always emotional and explains why they are so sloppy in its execution.  Expect retaliation when you haven't "gotten the message."  Be ready and then use it against them.  Once they retaliated, repeat the principles stated above and complain some more.  Their retaliation is your reason for legal action.  It's the best foundation for a legal claim.

Bait them to exercise maximum power of their position.  Credibility is lost when they exercise the maximum force behind their authority and it creates a financial negative for them.  Focus on consuming their time, their energy, their effort and their credibility.

5.  LOOK FOR CONFLICTS OF INTEREST

Municipalities are now using traffic cameras to catch violators.  Usually the company that installs or supplies the cameras are in bed (financialy) with the municipality that uses them.  Look for conflicts of interest that to use against them.

6.  RECOGNIZE THE HABITS OF PUBLIC SERVANTS. USE THEIR HABITS AGAINST THEM:

-Most of them are lazy and not results oriented.

-They are paid to do and not to think.  They are paid to show up more than anything else.

-They are focused on avoiding mistakes and handling paperwork.  Use this against them.  Did they do the paperwork?  Did they make a mistake?  Did they lie?

-They lie for one another and back each other up. When they do, use your audio and video surveillance to snag them in their lies.

-They are hiding in public service since they can't make it in industry.

-There is always a hostile relationship between public servants in each office.  They suffer from the chicken syndrome.  Chickens are always picking on a member of their own group until that member is dies, expelled or leaves voluntarily.  That member is your friend.  Posting a website may place you in contact with an angry public servant willing to spill the beans (blow the whistle) to ditch their coworkers.  Find that person and you have an inside track to what they'll do next.

-They lie to their employer and others.  It's commonplace.  Many of them are in violation of an ordinance within their own community (residency requirement, qualifications, etc.)

• ALWAYS TAKE THESE STEPS WHEN INTERACTING WITH A PUBLIC SERVANT:

  • Ask whether what they seek from you is mandatory or voluntary.  If they fail to answer, it's voluntary.  Send them a letter of the exchange and express that you're under no expectation to do a thing.  Tell them that they have ten business days to list what they want and to state whether it's mandatory or voluntary.

  • Ask them under what law it's mandatory.  Ask for a copy of the procedures.  Give them ten days.  Make sure it's in writing. 

  • Send a copy to the supervisors that they didn't respond.  Keep copies for yourself.

  • Always document each call and send them a copy of the documentation.  Ask them to challenge the documentation within ten business days.  If they don't, your documentation is the truth.

  • COMPLAIN, COMPLAIN, COMPLAIN

    • When you complain, forget about the local paper.  The Reading Times and the City of Reading are very much in collusion.  The paper doesn't write negative stories about the leadership of the City of Reading.  This is due to Al Boscov.  He buys a substantial amount of advertising from the Reading Eagle.  Therefore, he disapproves of any story that casts a bad light on the City's management of affairs.  The peasants of the County of Berks don't do anything about this.  They continue to look the other way thinking, "I don't live in the City of Reading, I don't care.  If those people want to live like animals, more power to them."  Don't rely on the Reading Eagle to pick up your story.  The internet is independent of the City of Reading, their minions, and the newspaper.

  • Complain to a higher authority.

  • File a complaint with the State Attorney General and any other agencies that's willing to listen.  Most municipalities often have a board or committee that hears and investigate municipal employees.  They City of Reading has a Charter Board. File complaints.  Keep them busy.  Let them know you're complaining.  Your complaints and their timing are important.  Your complaint must take place before they retaliate against you.  Their retaliation is evidence!

  • Encourage others to file complaints. 

7.  SEEK OUT DISGRUNTLED PRESENT AND PAST EMPLOYEES OF CITY HALL FOR INSIDE INFORMATION. 

• Past employees of City Hall are more likely to talk about internal operations, who controls the office and the way they look at issues
• Present employees won't help you for fear of losing their job.  Your strategies with present employees are the following:
  • Wait until they are fired or quit.  Be nice to the employees that are not victimizing you.  They may be assets in the future. 
  • Even those who took a hand at making your life difficult may turn to help you.  If the City victimizes the employee that wronged you, that employee may be your strongest ally.
  • Sometimes your best asset is time.  Wait for the City to denigrate, victimize and mistreat their own employees.  This may take a couple of years.  But it always happens.  Those employees that had a hand in abusing your rights will soon get their turn from within their group.  It always happens.  Abusers can't help themselves.  It's a form of justice.  Someone always has enough and files a complaint.  Then the complainant receives retaliation and there's a lawsuit.  It's the game they play.  The abusers always assume it's the public's money their wasting--so it doesn't matter.  But it does matter to their own careers.  If you do a proper job of illuminating their conduct, they can't quit and they can't find a better job.  No municipality seeks to hire a codes official that carelessly creates lawsuits.

8.  ALTHOUGH THEY APPEAR TO SUPPORT THEIR EMPLOYEES THAT TARGET YOU, THEY ARE NOT HAPPY BEHIND CLOSED DOORS.

Behind the scenes, they are questioning the judgment of the employee.  If that employee makes too much trouble, produces too much controversy, or creates too much noise, that support will eventually run out. 

EXAMPLE OF SUCCESS:  Look at what happened to Jatinder Khokhar, the former Codes Manager for the City of Reading Codes Office.  He moved to Berks County and refused to live in the City of Reading, as required by the City Charter.  Although he kept his driver's license out of Virginia, he lived in Berks County.  He then violated the rights of property owners spawning several lawsuits against himself, the City of Reading, the Mayor and Solicitor, and several of his subordinates.  Then citizens filed complaints with the City of Reading Charter Board because Jatinder Khokhar deliberately refused to move into the City as required.  He even insulted the City of Reading, by saying that his wife would kill him if he would move his children from Virginia to the City of Reading.  This produced a backlash from taxpayers and property owners.   The litigation, the depositions, the meetings, the conferences, the conference calls, and the internal strife in the department has left the department disorganized and unable to recover.  Jatinder Khokhar was left unable to testify in court against alleged code violators due to his residency challenge with the Charter Board. Further, the Codes Office was unable to handle simple tasks, such as sending out the permit notices.  Eventually, the Mayor got sick of Jatinder Khokhar, the Drama Queen of the Codes Office.  The Mayor arranged for Jatinder Khokhar to be escorted from City Hall.   Bye-bye Jatinder. 

What to learn from Jatinder Khokhar's example?

• Every legitimate complaint you file with the Charter Board, Ethics Board, licensing body and court does the following:

  • Keeps the perpetrators busy defending themselves

  • People who step on others create drama inside their own department--when residents defend their rights.

  • Jatinder Khokhar embarrassed the Mayor for his public comments, for refusing to move into the City as required by the Charter, and for producing lawsuits for the City.

  • Jatinder Khokhar kept the City Solicitor's office overwhelmed with complaints and litigation

  • His retaliatory actions produced evidence for the lawsuit.  The filing of complaints against the perpetrator will generate paperwork and evidence.  There are two types of evidence produced:

    • Evidence of their mistakes and wrong-doing

    • Evidence of retaliation after you complain.  Often times, your retaliation claim against them is stronger than the initial claim of their wrong-doing.

  THE CITY OF READING PAID $40,000 TO PAY OFF ONE GROUP OF PLAINTIFFS AFTER VIOLATING THEIR CONSTITUTIONAL RIGHTS.  THEY HAVE MORE LAWSUITS FILED AGAINST THEM AT TAXPAYERS EXPENSE. 

  • Evidence of wrong-doing on behalf of the perpetrator inside City Hall

  • Evidence of collusion between the departments of City Hall and knowledge of the Mayor, and City Solicitor's Office.

    OR

  • Evidence of collusion, deliberate neglect, or negligence between the Charter Board Investigator, Ethics Board, or other Board or committee responsible to investigate abusive, unconstitutional or irresponsible behavior of public servants. 

    • If the Board or office responsible for investigating malfeasance or abusive behavior is not doing their job, your first order of business is the following:

      • Generate publicity for the board that failed to do their job.

      • File a complaint against members of the board or committee.

      • File a civil complaint (Check with your attorney i.e. Order of Mandamus) to force the board or committee to investigate.

      • Post a website exposing this conduct.

      • Point out individuals within an organization with specific actions they've taken, or failed to take, that breached their duty.

      • Many times the head of a board or committee is an attorney.  That attorney is working as a volunteer or at a reduced rate to obtain credibility in the community, or plans to run for political office.  In your website, make it personal.  Share specific information about what happened, or that didn't happen, about that attorney and identify his law practice.

      • Remember that sunshine makes cockroaches run for cover.  Politicians and lawyers are one in the same.  They are cockroaches.  Open the blinds and watch them scatter like the vile trash roaches they really are.  Vamoos!

Your job is to carry the ball as far as you can to make sure that employee runs his course in terms of spending his credibility points.  This means that you want to exhaust the credibility of that employee by casting attention on that perpetrator, identifying co-perpetrators, finding co-victims, writing that website, and encouraging others to talk and share their story. 

Nobody likes to deal with a drama queen.  And if that employee appears to create drama for the City's supervisors, City Council or the Mayor, he won't be popular.  Although they will defend the employee tooth and nail in the public eye, and in defending legal action, the employee will face the scrutiny of his superiors behind closed doors.  Expect the City to entrench and defend the actions of the City employee every step of the way.  This is normal for inadequate, short-minded, uneducated politicians who are unprepared to do their jobs.

9.  CONTACT THE CHAMBER OF COMMERCE AND ASK FOR A MEETING WITH THE CHAMBER PRESIDENT. Explain the situation and how this situation is anti-business.  The Chamber is important in terms of votes, influence and information.

10.  USE THE INAPPROPRIATE ABUSE OF POWER, RETALIATION, AND INAPPROPRIATE CONDUCT OF PUBLIC SERVANTS AGAINST THEM IN COURT.

11.  IDENTIFY CITY HALL'S INSURANCE COMPANY THAT COVERS THEIR LITIGATION.  SOLICITORS ARE OFTEN OVERWHELMED.  CITY HALL PAYS AN INSURANCE COMPANY TO COVER LEGAL EXPENSES. 

Send a copy of all complaints and issues to the insurer.  You can find out the insurer through the risk management department.  This can cause the insurance rates to increase for the City.  And the City may be pressured by the insurer to back off.  If there's a lawsuit brewing, the stench of the City's actions may be enough to send the Insurer packing, or threatening to increase rates.  The insurer has more weight and influence than you think!

12.  DON'T THINK THE PROBLEM HAS GONE AWAY BECAUSE THERE IS SILENCE.

They may be silent but they are also angry at you.  They are still looking to retaliate.  They are waiting and looking for an excuse.  Fight them using the law, using internal complaint procedures, and let all of it take its course.  Silence is not peace.  They are waiting to do it again.

13.  WHEN SOMETHING HAPPENS, NOTIFY PEOPLE IN WRITING BY CERTIFIED MAIL, RETURN RECEIPT.

This place people on notice.  It also makes co-workers and co-perpetrators stuck in a position.  They can no longer claim they don't know about the situation.  Their action, or failure to act, works against them.  They know this and hate receiving any notice of what is happening.

When you have a telephone conversation with a Codes Officer about any situation.  This is what you do:

Within 24 hours, write a letter to the codes officer about what was discussed.  Then add, "This was the complete substance of our conversation on this date of ____________.  You have ten (10) business days to dispute my account of the conversation.  If you fail to do so within ten (10) business days, then you admit and accept that my account of the conversation is true and correct."

Keep the registered mail information and returned receipt. 

This works because of the following reasons:

• They are disorganized.
• They don't have time to read and respond to this type of correspondence.
• They always fail to keep the correspondence for future hearings.
• They forget that you sent the letter.

14.  IF THE PUBLIC SERVANT HAS A LICENSE TO PERFORM AN INSPECTION, OR TO ENGAGE IN A CERTAIN ACT, FILE A COMPLAINT. 

15.  WHEN THE POLICE ARE INVOLVED, DON'T CRITICIZE THEM.  STAY OUT OF THEIR WAY.

The police work for the Mayor.  They police are just a victim of the Mayor, as are the residents of the City.  They too think he's a pompous self-righteous jerk.  They want to stay away from the politics and just do their job.  They are subject to the arbitrary actions of the politicians and must deal with the crazy criminals on the street.  Even if the police are ordered to do something that violates your rights, be patient with them.  Instead of retaliating against the police, focus on the political idiot who called them to harass you.  If you react emotionally and make a mistake, then you're playing on their turf again...spending your money reacting to their allegations.

Instead, use the administrative remedies from inside City Hall to target the public servants responsible for the violations.  By keeping the police out of civil and criminal charges, they are not emotionally uninvolved-- and unmotivated to retaliate.

16.  KEEP IT LEGAL, KEEP IT CLEAN, ALWAYS TELL THE TRUTH.

17.  LOOK INTO USING RULE 27 OF THE FEDERAL RULES OF CIVIL PROCEDURE TO COLLECT EVIDENCE AND COMPEL TESTIMONY, EVEN WHEN THERE'S NO CASE.

Most people don't know this.  Ask your attorney about this rule.  You are able to order any employee of the City of Reading to give testimony even if you haven't file a lawsuit!  You are then able to use that evidence against them, and can share that evidence with others.   Here's the link:  http://www.law.cornell.edu/rules/frcp/Rule27.htm

If they don't show for the deposition, then your attorney can motion the court to force them to testify.

Rule 27. Depositions to Perpetuate Testimony

(a) Before an Action Is Filed.

(1) Petition.

A person who wants to perpetuate testimony about any matter cognizable in a United States court may file a verified petition in the district court for the district where any expected adverse party resides. The petition must ask for an order authorizing the petitioner to depose the named persons in order to perpetuate their testimony. The petition must be titled in the petitioner's name and must show:

(A) that the petitioner expects to be a party to an action cognizable in a United States court but cannot presently bring it or cause it to be brought;

(B) the subject matter of the expected action and the petitioner's interest;

(C) the facts that the petitioner wants to establish by the proposed testimony and the reasons to perpetuate it;

(D) the names or a description of the persons whom the petitioner expects to be adverse parties and their addresses, so far as known; and

(E) the name, address, and expected substance of the testimony of each deponent.

(2) Notice and Service.

At least 20 days before the hearing date, the petitioner must serve each expected adverse party with a copy of the petition and a notice stating the time and place of the hearing. The notice may be served either inside or outside the district or state in the manner provided in Rule 4. If that service cannot be made with reasonable diligence on an expected adverse party, the court may order service by publication or otherwise. The court must appoint an attorney to represent persons not served in the manner provided in Rule 4 and to cross-examine the deponent if an unserved person is not otherwise represented. If any expected adverse party is a minor or is incompetent, Rule 17(c) applies.

(3) Order and Examination.

If satisfied that perpetuating the testimony may prevent a failure or delay of justice, the court must issue an order that designates or describes the persons whose depositions may be taken, specifies the subject matter of the examinations, and states whether the depositions will be taken orally or by written interrogatories. The depositions may then be taken under these rules, and the court may issue orders like those authorized by Rules 34 and 35. A reference in these rules to the court where an action is pending means, for purposes of this rule, the court where the petition for the deposition was filed.

(4) Using the Deposition.

A deposition to perpetuate testimony may be used under Rule 32(a) in any later-filed district-court action involving the same subject matter if the deposition either was taken under these rules or, although not so taken, would be admissible in evidence in the courts of the state where it was taken.

(b) Pending Appeal.

(1) In General.

The court where a judgment has been rendered may, if an appeal has been taken or may still be taken, permit a party to depose witnesses to perpetuate their testimony for use in the event of further proceedings in that court.

(2) Motion.

The party who wants to perpetuate testimony may move for leave to take the depositions, on the same notice and service as if the action were pending in the district court. The motion must show:

(A) the name, address, and expected substance of the testimony of each deponent; and

(B) the reasons for perpetuating the testimony.

(3) Court Order.

If the court finds that perpetuating the testimony may prevent a failure or delay of justice, the court may permit the depositions to be taken and may issue orders like those authorized by Rules 34 and 35. The depositions may be taken and used as any other deposition taken in a pending district-court action.

(c) Perpetuation by an Action.

This rule does not limit a court's power to entertain an action to perpetuate testimony.

18. Obtain public records at no cost.  Go here:  http://openrecords.state.pa.us

Citizen's guide

ARE YOU A PEASANT?

Peasants permit themselves to be stepped on by others and don't put up a fight.  Peasants witness the persecution and harassment of others and do nothing about it.  If others are not free from tyranny, then neither are you.  So...are you a peasant?  Or, are you a sheep? Bbaa baa baa baa.  Perhaps you're a member of the mindless flock.  If so, get the flock out of there!