Angle Retires?

Not by choice...in November "The People" retire him.
Why, because he has mislead, misinformed and mistreated the great NorCo for far too long now. "We The People" are sick and tired of the fabrications made by this miscreant to benefit no other than himself.

The People of district 4 MUST understand by now that Mr. Angles angle is to continue to serve himself, throw some bones to his proclaimed lawyer BO, and in The Peoples opinion conspire with Mr. Stoffa to hurt the County even more than they already have, all the while helping only themselves.

Recall Stoffa...still a possibility because he has disgraced NorCo in many ways. How so, well for example, if any member of the Coalition of Alzheimer's Families even attempted to walk into the courthouse without going through the metal detector they would probably end up in cuffs...but it appears that BO can do as he pleases because he has been observed entering bypassing the detector. Seemingly the county executive allows it, and that in our opinion is a disgrace because BO has been known to commit wrongful acts which the entire county is aware of. So what are we to believe? That stoffa gave his permission, after all he is the CE. In the opinion of many of The People of NorCo, BO is a vicious lunatic capable of anything, his past is the evidence of his potential. Let us hope and pray that his wicked deeds do not lead to an atrocity in the courthouse. If so, who should we hold responsible? Ultimately...Mr. Stoffa.

Mr. Angle needs to break out his golf clubs, and he may as well clear the dust  off of his fishing gear...soon he will have plenty of time to use them. No one in his district fears him anymore, thanks to the grass root group which stood against him like David against Goliath...and GoliAngle went down just like the history book tells us he did.

When will they understand, and what else must they see, hear and smell before they comprehend that with GOD on your side...NO ONE CAN STAND AGAINST YOU.

Eventually They Will Pay

IN THE NORTHAMPTON COUNTY COURT OF COMMON PLEAS

CIVIL DIVISION-LAW

IN RE: PETITION FOR INITIATIVE TO PREVENT              :

THE SALE AND/OR LEASE OF GRACEDALE                                  : DOCKET NO:

FILED WITH NORTHAMPTON COUNTY ELECTIONS      : 48-CV-2011-755

COMMISSION JANUARY 18, 2011                                             : Election Matter

APPELLANT’S STATEMENT OF MATTERS COMPLAINED OF

 ON APPEAL PURSUANT TO PA RAP 1925(b)

To Honorable Stephen G. Baratta:

            Appellants Gracedale Initiative Petition Committee (GIPC), a/k/a, Coalition of Alzheimer’s Families (COAF), by and through it counsel Lawrence M. Otter, Esquire, file this Statement of Matters Complained of on Appeal pursuant to PA RAP 1925(b), and say:

1. Judge Baratta failed to take into account in his decision and order denying reconsideration the recent precedential decision of our Supreme Court in  In re Farnese, ___ Pa. ____,  17 A.3d 375 (March 29, 2011), in which the Supreme Court clearly laid out the standards for awarding counsel fees and costs in an election matter.
2. Judge Baratta ignored the fact that the petition committee was the prevailing party in this matter. 25 P.S. § 2937; In re Farnese, supra.
3. Judge Baratta ignored serious allegations in this matter concerning the alleged improper conduct of the objectors and the county government in using tax money to prepare a page and line challenge to approximately 300 of the 507 petition pages and over 1000 signatures and hid these facts until exposed by the county controller and the local media. The point we make is that these allegations tend to show the objector’s awareness and acceptance of these irregularities, the evidence would have been relevant to the important question of whether the court and the public had been deceived.
4. Judge Baratta’s conclusion that evidence of illegal activity directly tying O’Hare and Angle to criminal acts by the County Executive  related to the objector’s challenge was irrelevant is an error of law and fact
5. Judge Baratta applied the wrong legal standards in denying the Amended Motion for Reconsideration in an election petition challenge. In re Farnese, supra.
6. Judge Baratta abused his discretion in denying the reconsideration despite the proffer of appellants wherein the GIPC would offer the testimony of elected officials and documents attached to the original motion and Amended Motion for Reconsideration  showing that tax money was used to fund the “private” litigation brought by Messrs. O’Hare, individually and Angle, individually and as a member of County Council and further that County Executive John Stoffa in furtherance of his own political agenda, improperly used a disbarred attorney to bring the election petition challenge against 23,000 signatures collected by GIPC/COAF to place a question on the primary ballot.
7. Judge Baratta erred in denying the reconsideration and abused his discretion in determining that a petition challenge against a ballot question is “not a partisan issue”.
8. Judge Baratta abused his discretion in not reconsidering the assessment of costs against the objectors without identifying any reason specific to this case or, indeed, in these types of cases, why justice would demand shifting costs to them.
9. Judge Baratta  ignored Section 977 of the Pennsylvania Election Code, 25 P.S. § 2937, which conditions the assessment of costs on whether the award would be "just". There is ample justification for an assessment of cost in the context of this particular case.
10. Judge Baratta ignored the objective factors submitted in the motion here which reveal circumstances that would necessarily or obviously require an award of costs. The conduct of the objectors, both in initiating and then pursuing their challenge, indicated bad faith, harassment, misconduct and illegal aid from the county government right out of the Bonusgate playbook in pursing the challenge.
11. Judge Baratta ignored the GIPC/COAf’s proffer  of objectors’ fraud, bad faith, and/or gross misconduct which if proven  may require an award of costs. It is equally self-evident that a party's conduct need not proceed to such an extreme before an award of costs may be dictated by justice. The conduct of the parties and the relative strength of their legal positions are not the only factors relevant to the discretionary assessment of whether to shift costs to the losing party in an election contest.

Respectfully submitted,

                                                                        /s/ Lawrence M. Otter, Esquire

                                                                        __________________________

                                                                        LAWRENCE M. OTTER, ESQUIRE

                                                                        ATTORNEY FOR GIPC/COAF

                                                                        PA ATTORNEY ID  31383

                                                                        PO Box 2131

                                                                        Doylestown, PA 18901

                                                                        267-261-2948

                                                                        215-230-7197 (FAX)

                                                                        EMAIL: larryotter@hotmail.com

IN THE NORTHAMPTON COUNTY COURT OF COMMON PLEAS

CIVIL DIVISION-LAW

IN RE: PETITION FOR INITIATIVE TO PREVENT              :

THE SALE AND/OR LEASE OF GRACEDALE                                  : DOCKET NO:

FILED WITH NORTHAMPTON COUNTY ELECTIONS      : 48-CV-2011-755

COMMISSION JANUARY 18, 2011                                             :Election Matter

CERTIFICATE OF SERVICE

            This is to certify that a copy of the attached APPELLANT’S STATEMENT OF MATTERS COMPLAINED OF  ON APPEAL PURSUANT TO PA RAP 1925(b)  has been served on petitioners of record and the Court  by email and USPS first class mail or as otherwise noted:

BY HAND DELIVERY

Judge Stephen Baratta

Northampton County Court of Common Pleas

669 Washington St.

Easton, PA 18042

 Bernie O’Hare

bohare5948@aol.com

Ron Angle

669 Washington St.

Easton, PA 18042

famerangle@hotmail.com

                                                                       

                                                                        /s/ Lawrence M. Otter, Esquire

DATE 9/22/11                                                            ______________________________

                                                                        LAWRENCE M. OTTER, ESQUIRE

We Can See The Light

How do we know that our forefathers had it right when they wrote our Constitution? because of the milestone reached tonight during the CC meeting.

At some future point we will look back and realize that it was not just a milestone...but a true miracle.

Consider the night 13 months ago that Angle threw a childish fit stating "We will be here until 2 in the morning if need be, but we will vote to sell Gracedale". And tonight he voted along with the other eight councilmen/women to turn over the capital improvement projects to a private organization that will work to help Gracedale succeed.

Who would have ever thought they (CC) could all agree on this matter...and did not have to stay until 2am. The Coalition Of Alzhiemers Families thats who, and they honored the Constitution in the process.

Please read:
http://www.mcall.com/news/local/mc-northampton-county-gracedale-mcclure-20110915,0,965839.story

Angle Is Blowing Smoke Again

Can we agree with Mr. Stoffa on this presentation? Probably. It really is a no brain-er.

All of the work necessary at Gracedale should have been done over the last 20 years but politicians like Ron Angle diverted funds to pet projects of their own. Now he sits and complains that the proposal by the executive is "open ended" and he (angle) does not feel comfortable taking the word of reputable companies such as McClure and PPL.

Angle is a joke - he says he doesn't feel easy about this because he has no control, and if he did...he could once again set Gracedale up for failure. If Angle has no control...Gracedale succeeds.

Angle needs to understand that he is not such a good business man and we all know that, in fact, he feels uneasy because he is so accustom to conducting shady deals himself that he believes other business people do the same thing. Let us just say that not all business people conduct business the way Angle does, always looking to line his pocket while never concerning himself with who he hurts or how he hurts them.

NO, NO, NO... we're done with this poor excuse of a councilman. OUT YOU GO IN NOVEMBER.

VOTE SCOTT PARSONS

Please read:
http://www.lehighvalleylive.com/northampton-county/index.ssf/2011/09/gracedale_energy_savings_plan.html

http://www.mcall.com/news/local/mc-northampton-county-gracedale-capital-20110914,0,5365939.story

Let Us All Remember

                        LET  US  ALL  REMEMBER  9 - 11
My we bow our head's  in prayer or silence for the people lost that day ,  their families and friends.
For  all the people that were a part of that day for what ever reason ,  large or small for all Americans.
For all our men and women serving to keep our great country safe and free.

           REMEMBER   FREEDOM   IS  NOT   FREE  !

           MY  GOD  BLESS  AMERICA

We Will Never Ever Give Up

In case you haven't noticed, will never give up!!!

http://www.wfmz.com/news/Group-appeals-ruling-over-legal-fees-in-nursing-home-case/-/121458/768444/-/rhev85z/-/index.html

Liar Liar - Stoffa's Pants On Fire

Stoffa still does not understand that the truth is always the truth.

Must READ:
http://www.lehighvalleylive.com/northampton-county/index.ssf/2011/09/environmental_protection_agenc.html