Meet The Chief of The Lancaster City Police Bureau by Stan J. Caterbone October 9, 2015 Copyright 2015

Case 2:04-cv-04544-JKG Document 19 Filed 10/07/05 Page 1 of 12
UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF PENNSYLVANIA
Rosa Sadler
:
:
V.
:
:
Commonwealth of Pennsylvania,
:
Pennsylvania State Police, Colonel
:
Jeffrey B. Miller, individually and
:
in his capacity as Commander of
:
the Pennsylvania State Police, Captain :
Frank E. Pawlowski, individually and :
in his capacity as Commander of
:
Troop J, and Trooper Anthony W.
:
Suber, individually and in his
:
capacity as an officer of Troop J
:
Civil Action No. 04-CV-4544
AMENDED COMPLAINT
Jurisdiction and Venue
1. This action is brought pursuant to 42 U.S.C. 1983. Jurisdiction is
founded upon 28 U.S.C. 1331, 1343(1), (3), (4), and the aforementioned statutory
provision. Plaintiff further invokes the supplemental jurisdiction of this Court under 28
U.S.C. 1367(a) to hear and adjudicate state law claims. Venue is proper in this district
by reason of 28 U.S.C. 1391(b)(2) in that the cause of action arose in this district.
Parties
2. Plaintiff Rosa Sadler is and was at all times relevant to this action
a resident of the Eastern District of Pennsylvania.
3. Defendant Pennsylvania State Police is an Executive Department of
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Friday, October 09, 2015
Defendant Commonwealth of Pennsylvania and maintains its headquarters at 1800

Elmerton Avenue, Harrisburg, Pennsylvania 17110.
4. Defendant Jeffrey B. Miller is the Commander of the Pennsylvania State
Police, and at all times relevant to this action was acting under color of state law. He is
being sued in both his individual and official capacity. The Pennsylvania State Police
maintains its headquarters at 1800 Elmerton Avenue, Harrisburg, Pennsylvania 17110.
5. Defendant Captain Frank E. Pawlowski is and was at all times relevant to this
action the Commander of Troop J of the Pennsylvania State Police and acting under
color of state law. He is being sued in both his individual and official capacity. Troop J
is located at 2099 Lincoln Highway East, Lancaster, Pennsylvania 17602.
6. Defendant Trooper Anthony W. Suber is and was at all times relevant to this
action an officer of Troop J of the Pennsylvania State Police and acting under color of
state law. He is being sued in both his individual and official capacity.
7. At all times relevant to this action, all Defendants were acting under color of
state law and the actions taken by all Defendants deprived Plaintiff of her constitutional
and statutory rights.
Factual Allegations
8. On September 27, 2002, at approximately 7:05 a.m. in the area of 1740 South
Port Drive, Lancaster, Pennsylvania 17603, Plaintiff and Defendant Suber, who had had
a recent prior romantic relationship, were engaged in conversation relating to that
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relationship. Abruptly during the conversation, Defendant Suber crossed the street and
entered his official Pennsylvania State Police vehicle, which had been parked across the
street from 1740 South Port Drive, and started the vehicle.
9. Plaintiff immediately crossed the street, walked to the passenger side door of
the vehicle, and attempted to open the passenger door to get into the vehicle to continue
the discussion with Defendant Suber.
10. Upon observing Plaintiff attempt to enter the vehicle, Defendant Suber
depressed the accelerator of the vehicle and began to drive off. His sudden and violent
action caused Plaintiff to fall forward, at which point she grabbed the passenger side
mirror to attempt to avoid falling in the street. Defendant Suber continued to drive off,
while Plaintiff screamed and held on to the mirror.
11. Defendant Suber drove the vehicle at an ever-increasing rate of speed, with
Plaintiff screaming and hanging onto the mirror, for approximately 100 feet until
Plaintiff lost her grip on the mirror and fell, face first, onto the street, causing her to
suffer numerous, severe, and permanent injuries as described herein, and momentarily
lose consciousness. Defendant Suber observed Plaintiff lose her grip on the mirror and
fall to the street.
12. While lying bleeding in the street, Plaintiff regained consciousness and
began to walk in the direction that Defendant Suber had driven. Defendant Suber made
a u-turn and drove back in Plaintiffs direction as she walked in the street.
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13. As Defendant Suber approached Plaintiff and observed her bleeding from
the head, he asked Plaintiff, are you OK? Plaintiff replied, No, Im hurt. I need help.
Can you take me back to my apartment? Defendant Suber replied, no. Plaintiff then
said, Can you take me to a hospital? Defendant Suber replied, no, and drove away.
14. Defendant Suber never left the vehicle to examine Plaintiffs obvious
injuries, never treated Plaintiffs injuries on the scene, and never called for medical
assistance for Plaintiff.
15. Shortly after Defendant Suber drove off leaving Plaintiff bleeding and
injured in the street, he called her on her cell phone and asked her to lie to the
authorities about what had happened. Plaintiff refused to do so.
16. Plaintiff called for an ambulance to attend to her injuries. Upon arrival,
Plaintiff told the paramedics what had occurred. An officer with the Lancaster Bureau
of Police arrived, entered the ambulance, and questioned Plaintiff about what had
occurred.
17. Plaintiff ultimately received treatment for her injuries.
18. As a direct and proximate result of Defendant Subers actions, Plaintiff
suffered numerous serious, severe, and permanent injuries, including serious cuts,
scrapes, and abrasions to her face and head, injury to her right eye, her left eye retina
became detached, and she permanently lost the peripheral vision in her left eye.
19. Because of their prior relationship, Defendant Suber knew that any impact to
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Plaintiffs head could cause serious and permanent injury to her left eye, which had
been the subject of prior retinal surgery.
20. Subsequent to September 27, 2002, Plaintiff complained to the Pennsylvania
State Police about Defendant Subers actions. Defendant Pawlowski told Plaintiff that
the Pennsylvania State Police would investigate the incident and that, if warranted,
appropriate disciplinary action would be taken against Defendant Suber.
21. On information and belief, only Plaintiff and Defendant Suber were
interviewed in connection with the alleged investigation. Defendant Pawlowski then
informed Plaintiff that the investigation determined that Plaintiff was at fault, and
further, that he did not believe that she had ever asked Defendant Suber for medical
assistance.
22. Defendants did not discipline Defendant Suber in any respect for his actions
during the incident.
23. At no time did Plaintiff commit any offense against the laws of the
Commonwealth of Pennsylvania, the United States, or the City of Lancaster for which
justified any use of force against her. At no time Plaintiff improperly strike or attempt
to strike Defendant Suber or any law enforcement officers. At no time did Plaintiff pose
a threat to Defendant Suber or to the safety of any other persons. At no time did
Plaintiff harass, threaten, commit any illegal acts, or engage in any conduct which in
any way justified the actions of Defendant Suber.
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24. As a direct and proximate result of the actions of all Defendants, Plaintiff
suffered and continues to suffer physical injuries, pain and suffering, emotional distress
and psychological harm, some or all of which may be permanent, as well as financial
losses.
25. Defendant Suber knew that he was without authority to use force on
Plaintiff and to refuse to offer aid and assistance to Plaintiff .
26. The actions of Defendant Suber were willful, wanton, malicious, intentional,
outrageous, deliberate, and/or so egregious as to shock the conscience.
27. Defendant Suber engaged in the aforesaid conduct for the purpose of
violating Plaintiffs constitutional rights by subjecting Plaintiff to excessive force and by
failing and/or refusing to render aid and/or to provide necessary medical treatment in
deliberate indifference to her serious medical needs.
28. Defendant Pawlowski knew that he was without authority to refuse to
properly or adequately investigate Plaintiffs complaint.
29. The actions of Defendant Pawlowski were willful, wanton, malicious,
intentional, outrageous, deliberate, and/or so egregious as to shock the conscience.
30. Defendant Pawlowski engaged in the aforesaid conduct for the purpose of
violating Plaintiffs constitutional rights by failing and/or refusing to redress Plaintiffs
legitimate grievance against Defendant Suber and by failing to adequately and properly
investigate her complaint in deliberate indifference to her constitutional right not to be
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subjected to conduct from Defendant Suber that violated her constitutional rights. The
actions of Defendant Pawlowski were undertaken, at least in part, in retaliation for
Plaintiffs exercise of her First Amendment right to criticize official governmental action
and misconduct and to chill the free exercise of those rights.
First Cause Of Action
Federal Civil Rights Violations
31. The allegations set forth in paragraphs 1-30, inclusive, are incorporated
herein as though fully set forth.
32. As a direct and proximate result of all Defendants conduct, committed
under color of state law, all Defendants deprived Plaintiff of her right to be free from
the excessive use of force, to be secure in her person and property, to due process of
law, to redress of grievances, to criticize official governmental action and misconduct, to
be free from unlawful and unreasonable seizure, and to be free from governmental
action or inaction in deliberate indifference to her serious medical needs. As a result,
Plaintiff suffered and continues to suffer harm, in violation of Plaintiffs rights under the
laws and Constitution of the United States, in particular the First, Fourth, Eighth and
Fourteenth Amendments thereof, and 42 U.S.C. 1983.
33. As a direct and proximate result of the acts and omissions of all Defendants,
Plaintiff sustained physical injuries, pain and suffering, emotional distress,
psychological harm and financial losses, all to Plaintiffs detriment and loss.
34. The Commonwealth of Pennsylvania, Pennsylvania State Police, has
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encouraged, tolerated, ratified and has been deliberately indifferent to a pattern,

practice and custom of
a. Excessive use of force and unlawful and unreasonable seizures by Troopers;
b. Abuse of police powers, including but not limited to false imprisonment,
unreasonable seizures, excessive force, violation of citizens free speech rights,
particularly in connection with perceived challenges to official authority, failure to
render aid and provide medical assistance;
c. Psychologically unfit persons serving as Troopers;
d. Failure of Troopers to prevent, deter, report, or take action against the
unlawful conduct of other Troopers under such circumstances as presented herein; and
e. Failure of Troopers to follow established policies, procedures, directives, and
instructions regarding the use of force and rendering aid and providing medical
assistance under such circumstances as presented herein.
35. The Commonwealth of Pennsylvania, Pennsylvania State Police, has been
deliberately indifferent to the need for more or different training, supervision,
investigation or discipline in the areas of:
a. The use of excessive force and unlawful seizures by Troopers;
b. The proper exercise of police powers, including but not limited to the
excessive use of force and unlawful seizures, and violations of citizens free speech
rights, particularly in connection with perceived challenges to police authority;
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c. The monitoring of Troopers whom it knew or should have known were

suffering from emotional and/or psychological problems that impaired their ability to
function as Troopers;
d. Troopers use of their status as Troopers to employ the use of excessive force
and unlawful seizure, or to achieve ends not reasonably related to their police duties;
and
e. The failure of Troopers to follow established policies, procedures, directives,
and instructions regarding the use of force and rendering aid and providing medical
assistance under such circumstances as presented herein.
36. Defendant Miller, the Commonwealth of Pennsylvania, Pennsylvania State
Police, has failed to properly sanction or discipline Troopers who are aware of and
subsequently conceal and/or aid and abet violations of constitutional rights of citizens
by other Troopers, thereby encouraging and causing Troopers, including Defendants
Suber and Pawlowski in this case, to violate the rights of citizens such as Plaintiff.
37. By these actions, Defendants have deprived Plaintiff of rights secured by the
First, Fourth, Eighth, and Fourteenth Amendments to the United States Constitution in
violation of 42 U.S.C. 1983.
Second Cause of Action
State Law Claims
38. Plaintiff hereby realleges paragraphs 1-37, inclusive, of this Complaint as
though fully set forth herein.
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39. The acts and conduct of all Defendants alleged in the above stated Cause of
Action constitute assault and battery, false imprisonment, intentional infliction of
emotional distress, violations of state constitutional free speech rights, negligence, gross
negligence, and negligent hiring, training, retention, and supervision under the laws of
the Commonwealth of Pennsylvania, and this Court his supplemental jurisdiction to
hear and adjudicate all of the aforesaid claims.
Third Cause of Action
Claim For Prospective Equitable Relief
40. Plaintiff hereby realleges paragraphs 1-39, inclusive, of this Complaint as
though set forth in full.
41. The acts and conduct of the individual Defendants alleged above in their
official capacities violated Plaintiffs federal constitutional and statutory rights and
entitles Plaintiff to obtain prospective equitable relief against them.
42. Plaintiff requests that the Court enjoin each of the individual defendants
from
a. Using excessive force and/or unreasonably seizing persons;
b. Abusing their police powers by committing acts of false imprisonment,
unreasonable seizure, and excessive force, and from violating citizens free speech
rights, particularly in connection with perceived challenges to official authority;
c. Failing to render aid and/or provide medical assistance to citizens;
d. Failing to prevent, deter, report, or take action against the unlawful conduct
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of Troopers; and
e. Failing to require Troopers to follow established policies, procedures,
directives, and instructions regarding the use of force and rendering aid and providing
medical assistance to citizens.
43. To effectuate the requested prospective equitable relief, Plaintiff requests
that the Court appoint a Special Master for a period of at least three (3) years to monitor
the individual defendants compliance with the relief ordered pursuant to paragraph 42
and to develop appropriate training, monitoring, supervisory, investigatory, and
disciplinary mechanisms to ensure such compliance.
Jury Demand
44. Plaintiff demands a jury trial as to each Defendant and as to each Count.
WHEREFORE, Plaintiff, Rosa Sadler, hereby demands judgment in her favor and
against all Defendants for the following relief:
a. Compensatory damages;
b. Punitive damages;
c. Reasonable attorneys fees, costs, and disbursements; and
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d. Such other and further relief as the Court deems just, reasonable, and
appropriate.
__________________________________________
Robert T Vance Jr (RTV3988)
Law Offices of Robert T Vance Jr
1616 Walnut Street, Suite 700
Philadelphia, PA 19103
215 772 0300
Attorney for Plaintiff Rosa Sadler
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PROTHONOTARY OF LANCASTER COUNTY

Katherine Wood-Jacobs
Prothonotary
George Alspach
Solicitor
ROSA SADLER
vs.
ANTHONY W SUBER
Case Number
CI-07-06783
PROTHONOTARY DOCKET ENTRIES

07/06/2007
CAPTION ENTRY IS: ROSA SADLER VS. ANTHONY W. SUBER
07/06/2007
COMPLAINT FILED BY ROBERT T. VANCE, JR., ESQ.
07/17/2007
COPY OF COMPLAINT (2) WITH RECEIPT TO ATTORNEY
09/27/2007
PRAECIPE-ENTER APPEARANCE OF DANIEL R. GOODEMOTE, ESQ. ON BEHALF OF DEFENDANT,

ANTHONY W. SUBER. FILED BY: DANIEL R. GOODEMOTE, ESQ. CERTIFICATE OF SERVICE OF
THE SAME.
11/02/2007
ANSWER AND NEW MATTER FILED BY: DANIEL R. GOODEMOTE, ESQ. CERTIFICATE OF SERVICE
OF THE SAME.
11/21/2007
ANSWER OF PLAINTIFFS TO NEW MATTER. FILED BY: ROBERT T. VANCE, JR., ESQ. CERTIFICATE
OF SERVICE OF THE SAME.
12/21/2007
PRAECIPE TO REINSTATE COMPLAINT. REINSTATED AS DIRECTED BY RANDALL O. WENGER,

PROTHONOTARY. FILED BY: ROBERT J. VANCE, ESQ.
09/21/2009
PRAECIPE-PRE-TRIAL CONFERENCE WITH PLAINTIFF'S STATUS REPORT AND CERTIFICATE OF

SERVICE. FILED BY ROBERT T. VANCE, JR., ESQ. (ASSIGNED TO PRESIDENT JUDGE FARINA OCTOBER 13, 2009)
09/21/2009
PROOF OF SERVICE OF THE PRAECIPE FOR PRE-TRIAL CONFERENCE AND PLAINTIFF'S STATUS
REPORT PURSUANT TO LOCAL RULE 212.2A. FILED BY ROBERT T. VANCE, JR., ESQ.
09/25/2009
STATUS REPORT OF DEFENDANT ANTHONY W. SUBER'S FILED BY: DANIEL R. GOODEMOTE,

ESQ. CERTIFICATE OF SERVICE OF SAME.
10/15/2009
FILE RECEIVED BY PRESIDENT JUDGE FARINA.
10/19/2009
ORDER (NO FEE) FILED. AND NOW, THIS 19TH DAY OF OCTOBER, 2009, PLAINTIFF'S REQUEST
FOR A PRE-TRIAL CONFERENCE IS DENIED AS PREMATURE. DISCOVERY IS NOT COMPLETE.
PLAINTIFF MAY REQUEST A PRE-TRIAL CONFERENCE AFTER FIVE (5) MONTHS FROM THIS
DATE. BY THE COURT: LOUIS J. FARINA, PRESIDENT JUDGE. CC'S WITH 236 NOTICE TO:
ROBERT T. VANCE, JR., ESQ (1) AND DANIEL R. GOODEMOTE, SR. DEP. ATTY. GENERAL (1).
MAILED ON 10/20/09.
04/13/2011
PRAECIPE-PRE-TRIAL CONFERENCE FILED BY ROBERT T. VANCE, JR., ESQ. CERTIFICATE OF

SERVICE OF SAME. (ASSIGNED TO JUDGE FARINA - APRIL 15, 2011)
04/18/2011
FILE RECEIVED BY JUDGE FARINA.
04/19/2011
ORDER (NO FEE) FILED AND NOW, THIS 19TH DAY OF APRIL, 2011, A PRE-TRIAL CONFERENCE
PURSUANT TO LANCASTER COUNTY RULE OF CIVIL PROCEDURE 212.2A IS SCHEDULE DIN
CHAMBERS NO. 10 OF THE LANCASTER COUNTY COURTHOUSE ON MAY 25, 2011 AT 11:00 A.M.
SEE CASE FILE FOR COMPLETE DETAILS.
BY THE COURT: LOUIS J. FARINA, JUDGE. COPIES WITH NOTICE 236 TO ROBERT T. VANCE JR.,
ESQ., DANIEL R. GOODEMOTE, ESQ. 4-20-11
04/27/2011
STATUS REPORT FILED BY DANIEL R. GOODEMOTE, ESQ. CERTIFICATE OF SERVICE OF SAME.
Page 13 of 33
(c) CountySuite Prothonotary, Teleosoft, Inc.
05/09/2011
ORDER (NO FEE) FILED AND NOW, THIS 9TH DAY OF MAY, 2011, THE PRE-TRIAL CONFERENCE
SCHEDULED PURSUANT TO LANCASTER COUNTY RULE OF CIVIL PROCEDURE 212.2A FOR MAY
25, 2011 AT 11:00 A.M. IS RESCHEDULED TO JUNE 15, 2011 AT 10:30 A.M. IN CHAMBERS NO. 10 OF
THE LANCASTER COUNTY COURTHOUSE. THE COURT DIRECTS ALL COUNSEL TO TIMELY FILE A
PRE-TRIAL STATEMENT IN ACCORDANCE WITH RULE NO. 212.2A, SUB-PARAGRAPH F, NO LATER
THAN ONE WEEK PRIOR TO THE CONFERENCE, WHICH CONFORMS TO THE REQUIREMENTS
OF SUB-PARAGRAPH F. COUNSEL IS FURTHER DIRECTED TO SEND A COURTESY COPY OF THE
PRE-TRIAL STATEMENT DIRECTLY TO THE UNDERSIGNED AT CHAMBERS NO. 10. THE EARLIEST
AVAILABLE CIVIL TRIAL TERM, AT THIS TIME, IS FEBRUARY, 2012. BY THE COURT: LOUIS J.
FARINA, JUDGE. COPIES WITH NOTICE 236 MAILED TO ROBERT T. VANCE, JR., ESQ (2) AND
DANIEL R. GOODEMOTE, ESQ. 5-10-11
06/07/2011
PRE-TRIAL MEMORANDUM OF DEFENDANT FILED BY DANIEL R. GOODEMOTE, ESQ.

CERTIFICATE OF SERVICE OF SAME.
06/13/2011
PRE-TRIAL MEMORANDUM OF PLAINTIFF. FILED BY ROBERT T. VANCE, JR., ESQ. CERTIFICATE

OF SERVICE OF SAME.
06/16/2011
CERTIFICATION ORDER FILED CERTIFICATION ORDER. AN DNOW, THIS 15TH DAY OF JUNE,
2011, PURSUANT TO LANCASTER COUNTY RULE OF CIVIL PROCEDURE NO. 212.2A, THIS ACTION
IS READY FOR TRIAL AND SHALL BE PLACED ON THE TRIAL LIST FOR THE WEEK OF APRIL, 2012.
THIS CASE IS LISTED FOR TRIAL BY JURY AND THE ESTIMATED LENGTH OF TRIAL IS 3 DAYS.
SEE CASE FILE FOR ALL DETAILS. BY THE COURT: LOUIS J. FARINA, JUDGE. COPIES WITH
NOTICE 236 TO ROBERT T. VANCE, JR., ESQ AND DANIEL R. GOODEMOTE, SR AND COURT
ADMIN, CIVIL SCHEDULING. 6-16-11
03/21/2012
POINTS FOR CHARGE OF DEFENDANT'S FOR CHARGE. FILED BY DANIEL R. GOODEMOTE, ESQ.
03/21/2012
PROPOSED VOIR DIRE QUESTIONS OF DEFENDANT, ANTHONY W. SUBER. FILED BY DANIEL R.

GOODEMOTE, ESQ. CERTIFICATE OF SERVICE OF SAME.
03/28/2012
MOTION PLAINTIFF'S MOTION FOR CONTINUANCE OF TRIAL. FILED BY ROBERT T. VANCE, ESQ.
(SENT TO ASSIGNED JUDGE FARINA ON 3/28/12 - BT)
03/28/2012
ORDER (NO FEE) FILED AND NOW THIS 28TH DAY OF MARCH, 2012, UPON CONSIDERATION OF
PLAINTIFF'S MOTION FOR CONTINUANCE OF THE TRIAL OF THIS CASE SCHEDULED TO
COMMENCE APRIL 9. 2012 AND THE DEFENDANT'S RESPONSE THERETO THE MOTION IS
DENIED. THIS CASE HAS BEEN SCHEDULED AND ATTACHED FOR TRIAL IN THE APRIL 2012 TRIAL
TERM SINCE JUNE 15, 2011, FOR WHICH THE START DATE OF APRIL 9, 2012 WAS KNOWN OR
SHOULD HAVE BEEN KNOWN BY PLAINTIFF'S COUNSEL SINCE PUBLICATION OF THE COURT
CALENDAR IN JANUARY 2012. BY THE COURT: JOSEPH C. MADENSPACHER, JUDGE. COPIES
WITH NOTICE 236 TO ROBERT T. VANCE, JR., ESQ. AND DANIEL R. GOODEMOTE, SR. 3-29-12
03/30/2012
RESPONSE DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION FOR CONTINUANCE OF TRIAL

FILED DANIEL R. GOODEMOTE, ESQ. CERTIFICATE OF SERVICE OF SAME FILED.
04/02/2012
DEFENDANT(S) SUBER'S TRIAL BRIEF FILED BY: DANIEL R. GOODEMOTE, ESQ. CERTIFICATE
OF SERVICE OF SAME.
04/02/2012
MOTION IN LIMINE OF DEFENDANT. FILED BY DANIEL R. GOODEMOTE, SENIOR DEPUTY

ATTORNEY GENERAL. CERTIFICATE OF SERVICE OF SAME.
04/05/2012
POINTS FOR CHARGE PLAINTIFF'S REQUESTED. FILED BY ROBERT T. VANCE, JR., ESQ.
04/05/2012
PROPOSED VOIR DIRE OF PLAINTIFF. FILED BY ROBERT T. VANCE, JR., ESQ. CERTIFICATE OF
SERVICE OF SAME.
04/09/2012
ANSWER PLAINTIFF'S ANSWER TO DEFENDANT SUBER'S MOTIONS IN LIMINE FILED BY:

ROBERT T. VANCE, JR., ESQ. CERTIFICATE OF SERVICE OF SAME.
04/09/2012
JURY VERDICT A JURY BEING CALLED THE FOLLOWING CAME TO WIT: TWELVE GOOD AND
LAWFUL MEN AND WOMEN OF LANCASTER COUNTY WHO ACCORDING TO THEIR RESPECTIVE
OATHS OR AFFIRMATIONS RESPECTIVELY, SO SAY THEY FIND: IN FAVOR OF DEFENDANT. DATE
& TIME: APRIL 10, 2012 AT 3:15 PM. JUDGE LOUIS J. FARINA. COURT REPORTER CATHY MERTZ.
Page 14 of 33
04/11/2012
MOLDED VERDICT ORDER FILED. AND NOW, THIS 10 DAY OF APRIL, 2012, BASED ON THE
INTERROGATORIES ANSWERED BY THE JURY, I HEREBY MOLD THE JURY'S VERDICT AND ON
PLAINTIFF ROSA SADLER'S CLAIM AGAINST ANTHONY W. SUBER, DEFENDANT, FIND IN FAVOR
OF DEFENDANT AND AGAINST THE PLAINTIFF AND DISMISS PLAINTIFF'S COMPLAINT. BY THE
COURT: LOUIS J. FARINA, JUDGE. COPIES WITH 236 NOTICE MAILED ON 4-17-12 TO ROBERT T.
VANCE, JR., ESQ. AND DANIEL R. GOODEMOTE, SR. DEP. ATTY. GENERAL.
05/09/2012
APPEAL TO HIGHER COURT FILED. NOTICE OF APPEAL TO THE SUPERIOR COURT OF

PENNSYLVANIA FROM THE ORDER ENTERED ON APRIL 12, 2011. FILED BY ROBERT T. VANCE,
JR., ESQ.
05/09/2012
CERTIFICATE OF SERVICE OF THE NOTICE OF APPEAL AND ORDER FOR TRANSCRIPT UPON
DANIEL R. GOODEMOTE, ESQ., HONORABLE LOUIS J. FARINA AND KATHY MERTZ COURT
REPORTER. FILED BY ROBERT T. VANCE, JR., ESQ.
05/22/2012
COURT COST 2 DAYS AT $14.00 PER DAY. TOTAL DUE $28.00.
05/23/2012
ORDER (NO FEE) FILED. AND NOW, THIS 22 DAY OF MAY, 2012, THE COURT, HAVING RECEIVED
NOTICE THAT THE PLAINTIFF HAS FILED A NOTICE OF APPEAL TO THE SUPERIOR COURT OF
PENNSYLVANIA FROM THE ORDER ENTERED IN THIS MATTER ON APRIL 10, 2012, DOES HEREBY
ORDER AND DIRECT THAT, PURSUANT TO PA.R.A.P. 1925: 1. THE DEFENDANT SHALL FILE AND
SERVE A STATEMENT OF MATTERS COMPLAINED OF ON APPEAL, WITH DEVELOPED
SUPPORTING ARGUMENT, WITHIN TWENTY-ONE (21) DAYS; 2. THE STATEMENT SHALL BE
FILED OF RECORD; 3. THE STATEMENT SHALL BE SERVED UPON THE UNDERSIGNED
PURSUANT TO PA.R.A.P. 1925(B)(1); 4. ANY ISSUE NOT PROPERLY INCLUDED IN THE
STATEMENT TIMELY FILED AND SERVED PURSUANT TO PA.R.A.P. 1925(B) SHALL BE DEEMED
WAIVED. 5. THE PLAINTIFF SHALL FILE ITS RESPONSE WITHIN TEN (10) DAYS THEREAFTER.
BY THE COURT: LOUIS J. FARINA, JUDGE. COPIES WITH 236 NOTICE MAILED ON 5-23-12 TO
ROBERT T. VANCE, JR., ESQ. AND DANIEL R. GOODEMOTE, SR. DEP. ATTY. GENERAL
06/19/2012
ORDER (NO FEE) FILED. AND NOW, THIS 19TH DAY OF JUNE, 2012, THE COURT'S ORDER OF
MAY 22, 2012, ISSUED PURSUANT TO PA.R.C.P. 1925 IS VACATED. (FOOTNOTES 1 & 2) BY THE
COURT: LOUIS J. FARINA, JUDGE. COPIES WITH 236 NOTICE MAILED ON 6-21-12 TO ROBERT T.
VANCE, JR., ESQ. AND DANIEL R. GOODEMOTE, SR. DEP. ATTY. GENERAL.
1. IN LIGHT OF THE SUPERIOR COURT'S PER CURIAM ORDER DATED JUNE 8, 2012 AT NO. 881
MDA 2012 DIRECTING PLAINTIFF/APPELLANT TO SHOW CAUSE WHY HER APPEAL SHOULD NOT
BE DISMISSED FOR FAILURE TO FILE POST TRIAL MOTIONS NO FURTHER ACTION WILL BE
TAKEN BY THIS COURT UNTIL RESOLUTION OF THE SUPERIOR COURT'S SHOW CAUSE ORDER.
2. BY CORRESPONDENCE DATED JUNE 18, 2012, PLAINTIFF/APPELLANT'S COUNSEL POINTED
OUT THAT THE COURT'S ORDER OF MAY 22, 2012, VACATED ABOVE, HAD MISIDENTIFIED
DEFENDANT AS THE APPELLANT (AN OBVIOUS TRANS-POSITIONAL ERROR), AND REQUESTED A
CORRECTIVE ORDER. FOR THE REASON EXPLAINED IN FOOTNOTE 1 ABOVE, NO CORRECTIVE
ACTION WILL BE TAKEN AT THIS TIME.
08/22/2012
CERTIFIED COPY OF ORDER FROM THE SUPERIOR COURT OF PENNSYLVANIA - NO. 881 MDA
2012, FILED.
October 09, 2015
Page 15 of 33
United States District Court Eastern District of Pennsylvania
1 of 6
https://ecf.paed.uscourts.gov/cgi-bin/DktRpt.pl?940354727892697-L_1_0-1
CLOSED,A/R,CASREF,STANDARD
United States District Court

Eastern District of Pennsylvania (Philadelphia)
CIVIL DOCKET FOR CASE #: 2:04-cv-04544-JKG
SADLER v. COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA STATE

POLICE et al
Assigned to: HONORABLE JAMES KNOLL GARDNER
Referred to: MAGISTRATE JUDGE HENRY S. PERKIN (Settlement)
Cause: 42:1983 Civil Rights Act
Date Filed: 09/27/2004

Date Terminated: 06/06/2007
Jury Demand: Defendant
Nature of Suit: 440 Civil Rights: Other
Jurisdiction: Federal Question
Plaintiff
ROSA SADLER
represented by ROBERT T. VANCE , JR.

LAW OFFICES OF ROBERT T. VANCE, JR.
100 S. BROAD STREET
SUITE 910
PHILADELPHIA, PA 19110
215-557-9550
Fax: 215-278-7992
Email: rvance@vancelf.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
V.
Defendant
COMMONWEALTH OF PENNSYLVANIA,
PENNSYLVANIA STATE POLICE
TERMINATED: 08/25/2006
represented by GREGG W. MARSANO

RUBIN FORTUNATO & HARBISON P.C.
10 SOUTH LEOPARD ROAD
PAOLI, PA 19301
610-854-4321
Email: gmarsano@rubinfortunato.com
LEAD ATTORNEY
SUE ANN UNGER
OFFICE OF ATTORNEY GENERAL
21 SOUTH 12TH STREET
3RD FLOOR
PHILADELPHIA, PA 19107
215-560-2127
Fax: 215-560-1031
Email: sunger@attorneygeneral.gov
LEAD ATTORNEY
Defendant
JEFFREY B. MILLER
COLONEL, INDIVIDUALLY AND IN HIS CAPACITY AS
COMMANDER OF THE PENNSYLVANIA STATE POLICE

(See above for address)
LEAD ATTORNEY
RANDALL J. HENZES
OFFICE OF ATTORNEY GENERAL
21 S. 12TH ST., 3RD FL
PHILADELPHIA, PA 19107-3603
215-560-2136
Fax: 215-560-1031
Email: rhenzes@attorneygeneral.gov
LEAD ATTORNEY
SUE ANN UNGER
LEAD ATTORNEY
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Defendant
FRANK E. PAWLOWSKI
CAPTAIN, INDIVIDUALLY AND IN HIS CAPACITY AS
COMMANDER OF TROOP J

LEAD ATTORNEY
RANDALL J. HENZES
LEAD ATTORNEY
SUE ANN UNGER
LEAD ATTORNEY
Defendant
ANTHONY W. SUBER
TROOPER, INDIVIDUALLY AND IN HIS CAPACITY AS AN
OFFICER OF TROOP J
represented by FRANCINE Z. TAYLOR

28 NORTH LIME ST
LANCASTER, PA 17602-2949
717-393-6311
Fax: 717-509-4217
Email: taylorf717@aol.com
Date Filed
Docket Text
09/27/2004
1 COMPLAINT against COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA STATE POLICE, JEFFREY B. MILLER,

FRANK E. PAWLOWSKI, ANTHONY W. SUBER ( Filing fee $ 150 receipt number 909185.), filed by ROSA SADLER.(tj, )
(Entered: 09/28/2004)
09/27/2004
Summons Issued; 4 Mailed to counsel 9/28/04 as to COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA STATE POLICE,
JEFFREY B. MILLER, FRANK E. PAWLOWSKI, ANTHONY W. SUBER. (tj, ) (Entered: 09/28/2004)
09/27/2004
DEMAND for Trial by Jury by ROSA SADLER. (tj, ) (Entered: 09/28/2004)
10/29/2004
2 WAIVER OF SERVICE Returned Executed by ROSA SADLER. JEFFREY B. MILLER waiver sent on 10/1/2004, answer due
11/30/2004; FRANK E. PAWLOWSKI waiver sent on 10/1/2004, answer due 11/30/2004. (ac, ) (Entered: 10/29/2004)
11/10/2004
3 ORDER THAT THE WITHIN MATTER IS REFERRED TO U.S. MAGISTRATE JUDGE ARNOLD C. RAPOPORT TO
SCHEDULE AND CONDUCT A SETTLEMENT CONFERENCE. IT IS FURTHERED ORDERED THAT IN THE EVENT ANY
DEFT. HAS NOT YET ENTERED AN APPEARANCE AT THE TIME OF THIS ORDER, PLAINTIFF SHALL SERVE A COPY
OF THIS ORDER UPON THAT DEFT. SIGNED BY JUDGE JAMES KNOLL GARDNER ON 11/10/04. SIGNED BY JUDGE
JAMES KNOLL GARDNER ON 11/10/04. 11/12/04 ENTERED AND COPIES MAILED, E-MAILED AND FAXED.(er, ) (Entered:
11/12/2004)
11/29/2004
4 MOTION to Dismiss Complaint filed by COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA STATE POLICE, JEFFREY
B. MILLER, FRANK E. PAWLOWSKI.Memorandum, Certificate of Service.(MARSANO, GREGG) (Entered: 11/29/2004)
12/07/2004
5 NOTICE of Appearance by FRANCINE Z. TAYLOR on behalf of ANTHONY W. SUBER (TAYLOR, FRANCINE) (Entered:
12/07/2004)
12/15/2004
6 MOTION to Dismiss filed by ANTHONY W. SUBER.memorandum.(TAYLOR, FRANCINE) Modified on 12/16/2004 (md) (MEMO
FILED IN ERROR BY ATTY AS A MOTION) (Entered: 12/15/2004)
12/15/2004
7 MOTION to Dismiss filed by ANTHONY W. SUBER.Motion to Dismiss.(TAYLOR, FRANCINE) (Entered: 12/15/2004)
12/15/2004
8 MOTION for Order filed by ANTHONY W. SUBER.ORDER FOR MOTION TO DISMISS.(TAYLOR, FRANCINE) Modified on
12/16/2004 (md) (PROPOSED ORDER FILED IN ERROR BY ATTY AS A MOTION) (Entered: 12/15/2004)
12/15/2004
9 CERTIFICATE OF SERVICE by ANTHONY W. SUBER re 8 MOTION for Order, 5 Notice of Appearance, 6 MOTION to Dismiss, 7
MOTION to Dismiss (TAYLOR, FRANCINE) (Entered: 12/15/2004)
12/16/2004
10 PLAINTIFF'S MOTION FOR AN ENLARGEMENT OF TIME ANSWER THE COMMONWEALTH DEFENDANTS' MOTION TO
DISMISS PLAINTIFF'S COMPLAINT FILED BY ROSA SADLER.MEMORANDUM OF LAW, CERTIFICATE OF SERVICE.
(Attachments: # 1 MEMORANDUM# 2 CERTIFICATE OF SERVICE# 3 PROPOSED ORDER)(wgc, ) (Entered: 12/17/2004)
12/27/2004
11 PLAINTIFF'S ANSWER TO THE COMMONWEALTH DEFENDANTS' MOTION TO DISMISS PLAINTIFF'S COMPLAINT

FILED BY ROSA SADLER, MEMORANDUM, CERTIFICATE OF SERVICE. (ac, ) Additional attachment(s) added on 12/28/2004
(ac, ). (Entered: 12/28/2004)
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12 ORDER THAT PLAINTIFF'S MOTION FOR ENLARGEMENT OF TIME TO ANSWER THE COMMONWEALTH
DEFENDANTS' MOTION TO DISMISS PLAINTIFF'S COMPLAINT IS GRANTED. IT IS ORDERED THAT PLAINTIFF SHALL
HAVE UNTIL 12/30/04 TO RESPOND TO COMMONWEALTH DEFENDANTS' MOTION TO DISMISS PLAINTIFF'S
COMPLAINT. SIGNED BY JUDGE JAMES KNOLL GARDNER ON 12/27/04. 12/28/04 ENTERED AND COPIES E-MAILED
AND FAXED.(ky, ) (Entered: 12/28/2004)
01/05/2005
13 PLAINTIFF'S MOTION FOR AN ENLARGEMENT OF TIME TO ANSWER DEFENDANT ANTHONY W. SUBER'S MOTION
TO DISMISS PLAINTIFF'S COMPLAINT FILED BY ROSA SADLER.MEMORANDUM, CERTIFICATE OF SERVICE.
(Attachments: # 1 MEMO# 2 CERTIFICATE OF SERVICE# 3 PROPOSED ORDER)(wgc, ) (Entered: 01/05/2005)
01/10/2005
14 Plaintiff' Answer to Defendant Anthony W. Suber's Motion to Dismiss Plaintiff's Complaint with Memorandum and Certificate of
Service filed by ROSA SADLER. (Attachments: # 1 Memo# 2 Certificate of Service# 3 Proposed Order)(wgc, ) (Entered: 01/10/2005)
04/18/2005
15 ORDER THAT ORAL ARGUMENT IS SCHEDULED FOR 7/25/2005 AT 9:30 A.M. BEFORE THE HONORABLE JAMES
KNOLL GARDNER. SIGNED BY JUDGE JAMES KNOLL GARDNER ON 4/18/05. 4/18/05 ENTERED AND COPIES
E-MAILED.(ky, ) (Entered: 04/18/2005)
07/26/2005
16 Minute Entry for proceedings held before Judge JAMES KNOLL GARDNER re: ARGUMENT ON MOTION TO DISMISS FILED
BY ANTHONY W. SUBER; MOTION TO DISMISS FILED BY THE COMMONWEALTH OF PENNSYLVANIA,
PENNSYLVANIA STATE POLICE, JEFFREY B. MILLER, FRANK E. PAWLOWSKI, was held on 7/25/05. Attorneys argue motions
on behalf of PLAINTIFFS. COURT deliberates, grants motions in part and denies in part. The portion which has not been ruled on is
taken under advisement. Court Reporter: E.S.R. (ky, ) (Entered: 07/26/2005)
09/28/2005
17 ORDER THAT DEFENDANTS' MOTIONS TO DISMISS PLAINTIFF'S COMPLAINT ARE GRANTED IN PART, DENIED IN
PART AND TAKEN UNDER ADVISEMENT IN PART. SIGNED BY JUDGE JAMES KNOLL GARDNER ON 7/25/05. 9/28/05
ENTERED AND COPIES E-MAILED. (ky, ) (Entered: 09/28/2005)
09/28/2005
18 ORDER THAT COMMONWEALTH DEFENDANTS' MOTIONS TO DISMISS PLAINTIFF'S COMPLAINT ARE DENIED. IT IS
FURTHER ORDERED THAT PLAINTIFF'S REQUEST TO AMEND HER COMPLAINT IS GRANTED. IT IS FURTHER
ORDERED THAT PLAINTIFF SHALL HAVE UNTIL 10/12/05 TO FILE AN AMENDED COMPLAINT. SIGNED BY JUDGE
JAMES KNOLL GARDNER ON 9/27/05. 9/27/05 ENTERED AND COPIES E-MAILED. (ky, ) (Entered: 09/28/2005)
10/07/2005
19 AMENDED COMPLAINT AGAINST COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA STATE POLICE, JEFFREY

B. MILLER, FRANK E. PAWLOWSKI, ANTHONY W. SUBER FILED BY ROSA SADLER, CERTIFICATE OF SERVICE.
(Attachments: # 1 Cover)(ac, ) (Entered: 10/07/2005)
10/24/2005
20 MOTION to Dismiss for Lack of Jurisdiction and for failure to state a claim filed by COMMONWEALTH OF PENNSYLVANIA,
PENNSYLVANIA STATE POLICE, JEFFREY B. MILLER, FRANK E. PAWLOWSKI.Memorandum and Certificate of Service.
(MARSANO, GREGG) (Entered: 10/24/2005)
10/24/2005
21 MOTION to Dismiss filed by ANTHONY W. SUBER.memorandum, certificate of service, motion to dismiss. (Attachments: # 1 # 2 #
3)(TAYLOR, FRANCINE) (Entered: 10/24/2005)
11/18/2005
22 RESPONSE to Motion re 20 MOTION to Dismiss for Lack of Jurisdiction and for failure to state a claim by Commonwealth
Defendants filed by ROSA SADLER, Memorandum, Certificate of Service. (VANCE, ROBERT) Modified on 11/21/2005 (np).
(Entered: 11/18/2005)
11/18/2005
23 RESPONSE to Motion re 21 MOTION to Dismiss of Anthony W. Suber filed by ROSA SADLER, Memorandum, Certificate of
Service. (VANCE, ROBERT) Modified on 11/21/2005 (np). (Entered: 11/18/2005)
02/07/2006
24 STIPULATION AND ORDER THAT PLAINTIFF'S RESPONSES TO BOTH MOTIONS TO DISMISS, WHICH RESPONSES
WERE FILED 11/18/05, WILL BE DEEMED TIMELY. SIGNED BY JUDGE JAMES KNOLL GARDNER ON 2/6/06. 2/7/06
ENTERED AND COPIES E-MAILED.(ky, ) (Entered: 02/07/2006)
04/06/2006
25 NOTICE of Appearance by SUE ANN UNGER on behalf of COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA STATE
POLICE, JEFFREY B. MILLER, FRANK E. PAWLOWSKI with Certificate of Service (UNGER, SUE) (Entered: 04/06/2006)
04/06/2006
26 NOTICE of Recent Decision by COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA STATE POLICE, JEFFREY B.

MILLER, FRANK E. PAWLOWSKI re 20 MOTION to Dismiss for Lack of Jurisdiction and for failure to state a claim, 22 Response
to Motion, Certificate of Service. (UNGER, SUE) Modified on 4/10/2006 (fh) (Entered: 04/06/2006)
04/12/2006
27 NOTICE of Withdrawal of Appearance by GREGG W. MARSANO on behalf of COMMONWEALTH OF PENNSYLVANIA,

PENNSYLVANIA STATE POLICE, JEFFREY B. MILLER, FRANK E. PAWLOWSKI (MARSANO, GREGG) (Entered: 04/12/2006)
05/30/2006
28 ORDER THAT A RULE 16 CONFERENCE BY TELEPHONE CONFERENCE CALL IS SCHEDULED ON 8/24/06 AT 9:15 A.M.
WITH JUDGE JAMES KNOLL GARDNER, ETC. SIGNED BY JUDGE JAMES KNOLL GARDNER ON 5/30/06. 5/30/06
ENTERED AND COPIES E-MAILED.(er, ) (Entered: 05/30/2006)
08/24/2006
29 Minute Entry for proceedings held before Judge JAMES KNOLL GARDNER re: A Telephonic Scheduling Conference was held on
8/24/06. This proceeding was not placed on the record. (ky, ) (Entered: 08/24/2006)
08/25/2006
30 RULE 16 STATUS CONFERENCE ORDER THAT DEFENDANTS SHALL HAVE UNTIL 9/25/06 TO ANSWER PLAINTIFF'S
AMENDED COMPLAINT. IT IS FURTHER ORDERED THAT DISCOVERY SHALL NOT BEGIN UNTIL DEFENDANTS HAVE
ANSWERED PLAINTIFF'S AMENDED COMPLAINT. IT IS FURTHER ORDERED THAT A SECOND TELEPHONE STATUS
CONFERENCE WITH THE UNDERSIGNED SHALL BE HELD ON 10/3/06 AT 9:15 A.M. SIGNED BY JUDGE JAMES KNOLL
GARDNER ON 8/24/06. 8/25/06 ENTERED AND COPIES E-MAILED.(ky, ) (Entered: 08/25/2006)
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08/25/2006
31 ORDER THAT DEFENDANTS' MOTIONS TO DISMISS ARE GRANTED IN PART AND DENIED IN PART. IT IS FURTHER
ORDERED THAT THE COMMONWEALTH OF PENNSYLVANIA STATE POLICE IS DISMISSED AS A DEFENDANT IN THIS
CASE, ETC., AND THAT ALL CLAIMS AGAINST DEFENDANT ANTHONY W. SUBER ARE DISMISSED FROM
PLAINTIFF'S AMENDED COMPLAINT. SIGNED BY JUDGE JAMES KNOLL GARDNER ON 8/24/06. 8/25/06 ENTERED AND
COPIES E-MAILED. (ky, ) (Entered: 08/28/2006)
08/31/2006
32 ORDER THAT A SECOND RULE 16 TELEPHONE CONFERENCE IS SCHEDULED FOR 10/3/2006 AT 9:15 A.M. BEFORE THE
HONORABLE JAMES KNOLL GARDNER. SIGNED BY JUDGE JAMES KNOLL GARDNER ON 8/30/06. 8/31/06 ENTERED
AND COPIES E-MAILED.(ky, ) (Entered: 08/31/2006)
09/19/2006
33 Minute Entry for proceedings held before Judge ARNOLD C. RAPOPORT re: A Telephonic Settlement Conference was held on
09/21/2006
34 ANSWER to Amended Complaint by ANTHONY W. SUBER with Affirmative Defenses, Certificate of Service. (TAYLOR,
FRANCINE) Modified on 9/22/2006 (np). (Entered: 09/21/2006)
09/25/2006
35 ANSWER to Amended Complaint with Affirmative Defenses by JEFFREY B. MILLER, FRANK E. PAWLOWSKI.(UNGER, SUE)
(Entered: 09/25/2006)
09/25/2006
36 MOTION for Judgment on the Pleadings To require a response to the answer asserting immunities, to stay discovery and tog rant
judgment on the pleadings filed by JEFFREY B. MILLER, FRANK E. PAWLOWSKI.Memorandum, Certificate of Service.(UNGER,
SUE) (Entered: 09/25/2006)
09/28/2006
37 MOTION for Judgment on Partial Findings filed by ANTHONY W. SUBER.brief, certificate of service.(TAYLOR, FRANCINE)
(Entered: 09/28/2006)
09/28/2006
38 Brief 38 MOTION for Judgment on the Pleadings filed by ANTHONY W. SUBER. (TAYLOR, FRANCINE) Modified on 10/2/2006
(np). (Entered: 09/28/2006)
10/03/2006
39 Minute Entry for proceedings held before Judge JAMES KNOLL GARDNER re: A Telephonic Scheduling Conference was held on
10/16/2006
40 RESPONSE in Opposition re 36 MOTION for Judgment on the Pleadings To require a response to the answer asserting immunities, to
stay discovery and tog rant judgment on the pleadings filed by ROSA SADLER. (VANCE, ROBERT) (Entered: 10/16/2006)
10/16/2006
41 RESPONSE in Opposition re 37 MOTION for Judgment on Partial Findings filed by ROSA SADLER. (VANCE, ROBERT) (Entered:
10/16/2006)
10/30/2006
42 SECOND RULE 16 STATUS CONFERENCE ORDER THAT AFTER A STATUS CONFERENCE BY TELEPHONE WITH THE
UNDERSIGNED ON THIS DATE, IT IS ORDERED THAT AT THIRD TELEPHONE SCHEDULING CONFERENCE SHALL BE
HELD FOLLOWING THE DISPOSITION OF MOTION OF DEFENDANTS MILLER AND PAWLOWSKI TO REQUIRE A
RESPONSE TO THE ANSWER ASSERTING IMMUNITIES, TO STAY DISCOVERY AND TO GRANT JUDGMENT ON THE
PLEADINGS AND DEFENDANT SUBER'S MOTION FOR PARTIAL JUDGMENT ON THE PLEADINGS. IT IS FURTHER
ORDERED THAT DISCOVERY SHALL NOT BEGIN BEFORE THE THIRD TELEPHONE SCHEDULING CONFERENCE.
SIGNED BY JUDGE JAMES KNOLL GARDNER ON 10/3/06. 10/31/06 ENTERED AND COPIES E-MAILED.(ky, ) (Entered:
10/31/2006)
12/08/2006
43 MOTION for Extension of Time to File Answer re 36 MOTION for Judgment on the Pleadings To require a response to the answer
asserting immunities, to stay discovery and tog rant judgment on the pleadings filed by ROSA SADLER., Memorandum.(VANCE,
ROBERT) (Entered: 12/08/2006)
12/13/2006
44 RESPONSE in Opposition re 43 MOTION for Extension of Time to File Answer re 36 MOTION for Judgment on the Pleadings To
require a response to the answer asserting immunities, to stay discovery and tog rant judgment on the pleadings filed by JEFFREY B.
MILLER, FRANK E. PAWLOWSKI. (UNGER, SUE) (Entered: 12/13/2006)
02/28/2007
45 ORDER THAT DEFENDANT ANTHONY W. SUBER'S MOTION FOR PARTIAL JUDGMENT ON THE PLEADINGS IS
GRANTED. IT IS FURTHER ORDERED THAT DEFENDANT SUBER'S LETTER REQUEST TO FILE A REPLY BRIEF IS
GRANTED, AND THE CLERK OF COURT SHALL FILE THE REPLY BRIEF OF DEFENDANT ANTHONY W. SUBER IN
SUPPORT OF HIS MOTION FOR PARTIAL JUDGMENT ON THE PLEADINGS, WHICH IS ATTACHED TO THE WITHIN
ORDER. IT IS FURTHER ORDERED THAT PLAINTIFF'S FIRST CAUSE OF ACTION AS IT RELATES TO DEFENDANT
SUBER IS DISMISSED FROM PLAINTIFF'S AMENDED COMPLAINT. SIGNED BY JUDGE JAMES KNOLL GARDNER ON
2/28/07. 3/1/07 ENTERED AND COPIES E-MAILED.(ky, ) (Entered: 03/01/2007)
02/28/2007
46 REPLY BRIEF OF DEFENDANT ANTHONY W. SUBER IN SUPPORT OF HIS MOTION FOR PARTIAL JUDGMENT ON THE
PLEADINGS. (ky, ) (bp, ). (Entered: 03/01/2007)
04/16/2007
47 ORDER THAT PLAINTIFF'S MOTION FOR AN ENLARGEMENT OF TIME TO ANSWER THE MOTION OF DEFENDANT
MILLER AND PAWLOSKI TO REQUIRE A RESPONSE TO THE ANSWER ASSERTING IMMUNITIES, TO STAY DISCOVERY
AND TO GRANT JUDGMENT ON THE PLEADINGS IS GRANTED. IT IS FURTHER ORDERED THAT THE MOTION OF
DEFENDANTS MILLER AND PAWLOSKI TO REQUIRE A RESPONSE TO THE ANSWER ASSERTING IMMUNITIES, TO
STAY DISCOVERY AND TO GRANT JUDGMENT ON THE PLEADINGS IS GRANTED. SIGNED BY JUDGE JAMES KNOLL
GARDNER ON 4/16/07. 4/16/07 ENTERED AND COPIES E-MAILED.(ky, ) (Entered: 04/16/2007)
04/16/2007
48 MOTION for Extension of Time to File a Supplemental Brief in Support of Motion for Judgment on the Pleadings filed by JEFFREY
B. MILLER, FRANK E. PAWLOWSKI.Memorandum, Certificate of Service.(UNGER, SUE) (Entered: 04/16/2007)
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49 ORDER THAT DEFENDANTS MILLER AND PAWLOSKI'S MOTION FOR EXTENSION OF TIME TO FILE A
SUPPLEMENTAL BRIEF IN SUPPORT OF THEIR MOTION FOR JUDGMENT ON THE PLEADINGS IS GRANTED. IT IS
FURTHER ORDERED THAT DEFENDANTS MILLER AND PAWLOSKI SHALL HAVE UNTIL 5/18/07 TO FILE A
SUPPLEMENTAL BRIEF IN SUPPORT OF THEIR MOTION FOR JUDGMENT ON THE PLEADINGS. IT IS FURTHER
ORDERED THAT PLAINTIFF SHALL HAVE UNTIL 6/1/07 TO FILE A BRIEF IN OPPOSITION TO DEFENDANTS' MOTION
FOR JUDGMENT ON THE PLEADINGS. SIGNED BY JUDGE JAMES KNOLL GARDNER ON 4/25/07.4/26/07 ENTERED AND
COPIES E-MAILED.(ky, ) (Entered: 04/26/2007)
04/27/2007
50 Response in Opposition to Anwer and Affirmative Defenses of Defendants Miller and Pawlowski Asserting Immunities by ROSA
SADLER, CERTIFICATE OF SERVICE. (VANCE, ROBERT) Modified on 5/1/2007 (afm, ). (Entered: 04/27/2007)
05/17/2007
51 RESPONSE in Support re 36 MOTION for Judgment on the Pleadings To require a response to the answer asserting immunities, to
stay discovery and tog rant judgment on the pleadings Supplemental Brief pursuant to Order of April 16, 2007 filed by JEFFREY B.
MILLER, FRANK E. PAWLOWSKI, CERTIFICATE OF SERVICE. (UNGER, SUE) Modified on 5/18/2007 (afm, ). (Entered:
05/17/2007)
05/17/2007
52 Answer and Affirmative Defenses to Plaintiff's More Definite Statement by JEFFREY B. MILLER, FRANK E. PAWLOWSKI,
CERTIFICATE OF SERVICE. (UNGER, SUE) Modified on 5/18/2007 (afm, ). (Entered: 05/17/2007)
05/18/2007
53 ORDER THAT A JURY TRIAL IS SCHEDULED FOR 7/17/2007 AT 9:30 A.M. IN COURT BEFORE THE HONORABLE JAMES
KNOLL GARDNER. SIGNED BY JUDGE JAMES KNOLL GARDNER ON 5/15/07. 5/21/07 ENTERED AND COPIES
E-MAILED.(ky, ) (Entered: 05/21/2007)
05/21/2007
54 APPLICATION/PETITION for continuance - unopposed by JEFFREY B. MILLER, FRANK E. PAWLOWSKI. (UNGER, SUE)
(Entered: 05/21/2007)
05/29/2007
55 Minute Entry for proceedings held before Judge HENRY S. PERKIN : a Telephonic Settlement Conference held on 5/29/07. Court
Reporter: None. (er, ) (Entered: 05/30/2007)
05/31/2007
56 ORDER THAT EXCEPT AS OTHERWISE PROVIDED BELOW, ALL DISCOVERY SHALL BE COMPLETED BY 6/8/07, ETC.
IT IS FURTHER ORDERED THAT ALL MOTIONS IN LIMINE SHALL BE FILED AND SERVED ON OR BEFORE 6/20/07,
ETC. IT IS FURTHER ORDERED THAT A JURY TRIAL OF THE WITHIN CASE, SHALL COMMENCE BEFORE THE
UNDERSIGNED ON 7/17/07 AT 9:30 A.M. OR AS SOON THEREAFTER AS THE SCHEDULE OF THE COURT PERMITS,
WITH THE SELECTION OF A JURY AT THE U.S. COURTHOUSE, PHILADELPHIA, PA, ETC. SIGNED BY JUDGE JAMES
KNOLL GARDNER ON 5/30/07. 5/31/07 ENTERED AND COPIES E-MAILED.(er, ) (Entered: 05/31/2007)
05/31/2007
57 APPLICATION FOR CONTINUANCE AND ORDER THAT THE APPLICATION IS DENIED. SIGNED BY JUDGE JAMES
KNOLL GARDNER ON 5/30/07. 5/31/07 ENTERED AND COPIES MAILED.(er, ) Additional attachment(s) added on 6/4/2007
(afm, ). (Entered: 05/31/2007)
05/31/2007
58 NOTICE of Appearance by RANDALL J. HENZES on behalf of JEFFREY B. MILLER, FRANK E. PAWLOWSKI with certificate of
service(HENZES, RANDALL) (Entered: 05/31/2007)
06/01/2007
59 Minute Entry for proceedings held before Judge HENRY S. PERKIN: a Telephonic Settlement Conference held on 6/1/07. Court
06/01/2007
60 Emergency MOTION to Modify the Order Dated May 30, 2007 to Enlarge the Discovery Period and to Reschedule Trial filed by
ROSA SADLER., and Memorandum.(VANCE, ROBERT) (Entered: 06/01/2007)
06/01/2007
61 ORDER THAT EACH REFERRAL ORDER FOR SETTLEMENT CONFERENCE FILED IN THE ABOVE-CAPTIONED CASES
IS VACATED. IT IS FURTHER ORDERED THAT EACH OF THE ABOVE-CAPTIONED CASES IS REFERRED TO U.S.
MAGISTRATE JUDGE HENRY S. PERKIN TO SCHEDULE AND CONDUCT A SETTLEMENT CONFERENCE. SIGNED BY
JUDGE JAMES KNOLL GARDNER ON 6/1/07. 6/1/07 ENTERED AND COPIES E-MAILED.(er, ) (Entered: 06/01/2007)
06/01/2007
62 RESPONSE in Opposition re 36 MOTION for Judgment on the Pleadings To require a response to the answer asserting immunities, to
stay discovery and tog rant judgment on the pleadings filed by ROSA SADLER, MEMORANDUM. (VANCE, ROBERT) Modified on
6/5/2007 (afm, ). (Entered: 06/01/2007)
06/04/2007
63 Minute Entry for proceedings held before Judge HENRY S. PERKIN : a Telephonic Settlement Conference held on 6/4/07. Court
06/06/2007
64 Minute Entry for proceedings held before Judge HENRY S. PERKIN re: An In Person Settlement Conference was held on 6/6/07. The
terms of the stipulation were placed on the record. (ky, ) (Entered: 06/06/2007)
06/06/2007
65 STIPULATION AND ORDER THAT ALL CLAIMS AGAINST DEFENDANTS MILLER AND PAWLOWSKI ARE DISMISSED
WITH PREJUDICE. IT IS FURTHER ORDERED THAT ALL OF PLAINTIFF'S STATE LAW CLAIMS AGAINST DEFENDANT
SUBER SHALL BE DISMISSED WITHOUT PREJUDICE FOR THE PLAINTIFF TO REFILE THESE CLAIMS IN THE
LANCASTER COUNTY COURT OF COMMON PLEAS WITHIN 30 DAYS OF THE DATE OF THIS ORDER. IT IS FURTHER
ORDERED THAT THE CLERK OF COURT SHALL MARK THIS CASE CLOSED FOR STATISTICAL PURPOSES. SIGNED BY
JUDGE JAMES KNOLL GARDNER ON 6/6/07. 6/6/07 ENTERED AND COPIES E-MAILED.(ky, ) (Entered: 06/06/2007)
06/07/2007
66 ORDER THAT PLAINTIFF'S UNOPPOSED EMERGENCY MOTION TO MODIFY THE ORDER DATED 5/30/07 IS DISMISSED
AS MOOT. SIGNED BY JUDGE JAMES KNOLL GARDNER ON 6/6/07. 6/7/07 ENTERED AND COPIES E-MAILED.(ky, )
(Entered: 06/07/2007)
06/20/2007
67 MOTION for Attorney Fees filed by ANTHONY W. SUBER.brief, affidavit.(TAYLOR, FRANCINE) (Entered: 06/20/2007)
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68 AFFIDAVIT by ANTHONY W. SUBER. (TAYLOR, FRANCINE) (Entered: 06/20/2007)
06/20/2007
69 BRIEF IN SUPPORT OF MOTION for Attorney Fees filed by ANTHONY W. SUBER. (TAYLOR, FRANCINE) Modified on
6/21/2007 (afm, ). Modified on 3/19/2008 (soc, ). (Entered: 06/20/2007)
06/20/2007
70 CERTIFICATE OF SERVICE RE: MOTION FOR ATTORNEY FEES, BRIEF AND AFFIDAVIT by ANTHONY W. SUBER.
(TAYLOR, FRANCINE) Modified on 6/21/2007 (afm, ). (Entered: 06/20/2007)
07/09/2007
71 RESPONSE in Opposition re 67 MOTION for Attorney Fees filed by ROSA SADLER, MEMORANDUM AND CERTIFICATE OF
SERVICE. (VANCE, ROBERT) Modified on 7/10/2007 (afm, ). (Entered: 07/09/2007)
07/17/2007
72 PLAINTIFF'S APPENDIX IN OPPOSITION TO DEFENDANT SUBER'S MOTI0N FOR ATTORNEY'S FEES BY ROSA
SADLER.(ac, ) (Additional attachment(s) added on 12/18/2007: # 1 Appendix) (er, ). (Entered: 07/17/2007)
08/29/2007
73 MOTION TO GRANT PERMISSION TO FILE A REPLY IN SUPPORT OF MOTION for Attorney Fees filed by ANTHONY W.
SUBER. Certificate of Service (REPLY ATTACHED). (Attachments: # 1 motion to reply, reply brief, order, cert. of service# 2 # 3 #
4)(TAYLOR, FRANCINE) Modified on 8/31/2007 (afm, ). (Entered: 08/29/2007)
08/29/2007
75 DEFENDANT ANTHONY W. SUBER'S REPLY BRIEF IN SUPPORT OF HIS MOTION FOR ATTORNEY FEES. (ky, ) (Entered:
03/26/2008)
03/19/2008
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10/9/2015 1:32 AM
Behind The Blue Wall: [PA] Jill Burella and Rosa Torres-Sadler turn up t...
http://behindthebluewall.blogspot.com/2010/03/pa-jill-burella-and-rosa-t...
Police Officer Involved Domestic Violence. Lighting a candle of

remembrance for those who've lost their lives to domestic violence
behind the blue wall, for strength and wisdom to those still there, and
a non-ending prayer for those who thought they had escaped but
can't stop being afraid.
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[PA] Jill Burella and Rosa

Torres-Sadler turn up the
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Jill Burella and Rosa Torres-Sadler, both whom I've posted on
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earlier here, only recently met one another and formed an instant
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pact of speaking out together. In just a couple of weeks they
[NY] Good-bye
Rose...
have already been interviewed by a local television station and

radio show. The details of their cases are different but their goals
are closely aligned and overlapping. What's exactly the same is
that they both demand change, both are adamant about it, and
they are both determined.
No more walking the hard path alone. No more wondering if
anyone is listening. Jill and Rosa are now the buzz. Go my sweet
[OH] Cleveland
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sisters. Go.
Page 22 of 33
1 of 7

10/9/2015 1:33 AM
Behind The Blue Wall: [PA] Jill Burella and Rosa Torres-Sadler turn up t...
http://behindthebluewall.blogspot.com/2010/03/pa-jill-burella-and-rosa-t...
VIDEO EXCERPTS FROM:

Jill Burella & Rosa Torres-Sadler on Philadelphia's WNWR
[WA] Husband of
King County
Corrections
Officer Ne...
New World Radio's Kat With Hat Radio Show speaking on

officer-involved domestic violence, along with guest Deloris
Jordan, author of "In my Family's Shadow," and sister of NBA
basketball player Michael Jordan.
Hosted By James Royal
[SC] Officer
Stevens charged
with criminal
domesti...
[FL] Waiting on the
investigation
results for Cath...
March 7, 2010 - 7 A.M. EST

Note: The station invited Philadelphia Police representatives to attend in order to be
balanced and fair, but the offer was declined.
Parts 1, 2, and 3
[FL] Escambia Co.

Sheriff's Sgt.
Henley back on
jo...
[TX] Son of Allen
Police Officers
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be...
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girlf...
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Workman
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battery...
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"SUPERVISOR
MUST SHOW
WHEN COP
FIGHTS KIN" (I...
[TX] Anna
Rodriguez was
here. Officer's
wife wante...
[PA] Before
murder-suicide,
Sunbury Police
Chief "...
[VA] Officer
Feldmann
accused of
domestic assault
...
[SC] Trooper
Page 23 of 33
2 of 7

10/9/2015 1:33 AM
* SADLER ABUSED EX-WIFE *** BREAKING NEWS *** @ LIP News
1 of 10
http://lipnews.com/2012/07/sadler-abused-ex-wife-breaking-news/
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Posted on July 29th, 2012 Becky 77 comments
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*** BREAKING NEWS! ***

POLICE CHIEF SADLER
BEAT HIS WIFE!
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Rosaura Torres wrote a book about it published in 2010,

Abuse Hidden Behind the Badge. He caused a retinal
detachment that left her with permanent vision loss.
Please check back later for more on this unbelievable breaking
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77 responses to * SADLER ABUSED EX-WIFE *** BREAKING NEWS ***

1. Becky July 29th, 2012 at 12:39
This comment came in under the story immediately below and I am also posting it here:
We must bring an end to the cover up. Too many innocent people are being lost. My
prayers are with the victims and survivors.
Sincerely,
Author Rosaura Torres-Sader
Abuse Hidden Behind The Badge.
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2. Becky July 29th, 2012 at 12:41

Her comment below also has this link:
http://www.torrespublishing.com/Pages/default.aspx
3. Barbequed chicken July 29th, 2012 at 12:46
Is this the reason, his abuse and dislike of women, that Sadler hasnt pressed his team to solve
the murder of Mrs. Kaylor?
4. Becky July 29th, 2012 at 13:00
Rosaura,
Thank you for speaking with me on the phone! This is so unbelievable. Im working as fast as I
can.
5. Rosaura Torres Sadler July 29th, 2012 at 13:12
I am here to help and support all victims and survivors of Domestic Violence. God bless you
Becky for the wonderful work you are doing.
Be blessed always.
Rosaura
6. FWIW July 29th, 2012 at 14:17
Why isnt the chief and the Trooper named on her website or anywhere else? If they beat her,
why not call them out all over the web? And what ever came of the abuse? Were they
prosecuted? Was internal affairs notified? When did it happen?
7. It's time to make the donuts July 29th, 2012 at 14:18
WOW!!..tommorw morning the donuts arent goin to go down the same..WOW.
8. Becky July 29th, 2012 at 14:54
Hello my friend, thank you for the wonderful Complement. I understanding about having the
scars of the past abuse you and I sustained. My abusers caused me to have retinal detachment in
both eyes. My ex husband who is Chief of Police In Lancaster, PA (Keith Sadler) caused my
first detachment, then the trooper who is retired now caused me second, this is why I decided to
write my story and continue my journey to help others. I refuse to keep the Code of SIlence. You
are amazing.
http://www.youtube.com/watch?v=1vFoYl8KKvw
9. Becky July 29th, 2012 at 15:08
Sadler is the second photo down http://ciaracolonoidvsurvivorcom.blogspot.com/2012/03
/demons-in-their-own-right.html
Thanks to a friend who is doing research for me! There is so much to do
10. Becky July 29th, 2012 at 15:13
Her husband was called The Golden Child by city officials and the Commissioner because of
his spotless record, work ethics, and career path. Going to his family or the police for assistance
was impossible. He went for my face when abusing her, punching, slapping, even causing a
retinal detachment creating permanent loss of peripheral vision. Finally, he left me for his
mistress. He is now a Chief of Police, and on a Domestic Violence Advisory Board.
http://www.examiner.com/article/abuse-hidden-behind-the-badge-when-dv-offenders-are-cops
11. Anonymous July 29th, 2012 at 16:35
http://www.examiner.com/article/abuse-hidden-behind-the-badge-when-dv-offenders-are-cops
Married when they were 23, Torres remembers her husband, a Philadelphia Police Officer,
showed signs of abuse in courtship. He was controlling by telling her how to dress and how to
behave. Having grown up in a loving, nurturing family, Torres did not understand the signs of an
abuser. For years, I played the blame, shame, guilt game, she explains; I protected him, his
career, and his image as a police officer. His African-American family was also abusive toward
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Torres, who is of Puerto Rican descent, constantly telling her Latinas were the lowest of
people. His grandmother was a founder of Jack and Jill, and they were very racist always
(had) something racist to say to me. Her husband was called The Golden Child by city
officials and the Commissioner because of his spotless record, work ethics, and career path.
Going to his family or the police for assistance was impossible. He went for my face when
abusing her, punching, slapping, even causing a retinal detachment creating permanent loss of
peripheral vision. Finally, he left me for his mistress. He is now a Chief of Police, and on a
Domestic Violence Advisory Board.
TO FWIW, I DID REPORT IT.Your courts in Lancaster would not prosecute the trooper. If
you are wondering who he is, his name is Anthony Suber. I have no reason to lie. Imagine being
afraid; not knowing what could happened. I will share this with you, when he was Chief
Inspector, I was warned by a other officer that he was going to bring false charges against me
and have me arrested. She told me to run..I
The Mr. Suber was not charged because they protected him. I file a civil suit; not because of the
money but.The justice. There were emails him admitting to hurting me, the jury felt he was
not liable for my injuries. My case is in appeals.
I apologize for some of my mistakes. My reason for writing my book was to tell how so many
still live in fear. Many would rather believe an officer of the law because its difficult for them to
even phantom a Officer of the Law would do this unspeakable abuse. We look for them for
protection.
What happens when it is the Police Officer we fear?
To FIWI: I changed your chief name in the book, not to protect him but.to protect our
children. They are now all adults. Many do not even realize he had another family.
FIWI, Your chief is not a great importance to me. What is important to me; is how we can help
other victims and survivors of Domestic Violence.
15. Chunky Blue Line July 29th, 2012 at 18:20
Sadler beat a woman and got away with it without accountability. His martial arts must have
come in handy when he used his wife for a punching bag.
Sadler is a LOSER and the worst job in the world for a thug loser is in law enforcement where
they have no accountability.
Thank you for all your support Chunky Blue Line.
17. Busted down to patrolman July 29th, 2012 at 20:11
Rosaura, You are a brave woman. Your reaction to the abuse you endured at the hands of this
monster is normal. There is nothing worse than being afraid of the police, being unable to get a
response to your legitimate allegations. Even the good cops are afraid to step up and deal with
their buddies in blue. Hopefully the rest of us have the courage to now stand up and rid the
police departments of the abusers.
I now think of the current Lancaster City Lt. who was involved in the beating of two Spanish
guys some years ago. Was that just before this chief showed up?
Who did Sadlers background check. I think that could be an interesting fact.
18. Becky July 29th, 2012 at 20:16
I am still in shock by this whole thing. Apparently theres a very good reason this big chief
inspector from Philly packed his bags and headed to this little town. Unbelievable!
19. Denny July 29th, 2012 at 20:31
I agree with Busted, who did the vetting for the chief? I have had background checks done for
employment and they were thorough, they even spoke with prior neighbors. Obviously this was
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lacking with Sadler. Bravo Rosaura for speaking out!

20. FWIW July 29th, 2012 at 21:23
TORRES- I dont doubt your experiences, I was just curious as to what happened. I had/have so
many questions. And the chief is not my chief, I dont live in the city.
Thank you all for your support. What is so important is to now hold those who are abuser
accountable for there actions. We must not continue to push any abuse under the rug. FWIW, I
am a open book, you can ask me any questions.
This is why I decided to write my story. I am honored and humbled, because I am still here to
help others.
22. Jim July 30th, 2012 at 05:02
NOWwell have to see what LNP does with this
23. Jim July 30th, 2012 at 05:03
NOW.well have to see what LNP does with this shocking info..
24. Becky July 30th, 2012 at 06:54
Yup! Theyve ignored all the unsolved murders and crimes but can they ignore this?
25. Becky July 30th, 2012 at 07:35
And what is Mayor Gray going to do? OMG!
26. Chunky Blue Line July 30th, 2012 at 10:01
Rosaura thank you for the work you do to help victims of domestic violence. You are very
brave and honorable.
I was so angry when I read the information on your website and saw the YouTube video because
we rely on government officials to do the right thing when vetting candidates for important
positions. Our tax dollars pay these individuals a VERY good salary to do their job. I am still
shocked that Keith Sadler was hired for such a vital position in law enforcement. Im guessing
the Philadelphia police department exhaled a huge sigh of relief when their problem was taken
off their hands. Shove it under the rug or in this case, move him to Lancaster.
The mugshot of Rodriguez-Colon showed a face swollen and bruised without explanation. The
police chief uses his fists on a WOMAN looks like this is standard operating procedure in his
jurisdiction. Just like corporations, the guy at the top sets the tone for the entire culture. Any
honorable soul on the police force has to keep their mouth shut to keep their job.
27. Becky July 30th, 2012 at 10:41
The Rodriguez-Colon assault should be investigated. From the LNP article, Suspects bruises
still a mystery there is this:
He received stitches and other treatment before being arraigned and taken to the prison.
Investigators still werent sure Friday how Rodriguez-Colon, 35, was injured.
There was no crime reported, city police Lt. Todd Umstead said.
Isnt that cute? The police spokesperson Umstead makes a little joke about it. So when are you
allowed to beat someone to a pulp in Lancaster? Only if they allegedly abuse children? Or if
they steal your wallet can you beat them up? Or if their dog poops on your yard can you beat
them up? Disgusting! This police department is completely out of control!
http://lancasteronline.com/article/local/670019_Suspect-s-bruises-still-a-mystery.html
Chunky Blue Line, thank you for all your compassion and support. I pray that one DAY I will
receive justice.
God bless all of you.
Rosaura
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29. Two sides July 30th, 2012 at 13:13

Im shocked
30. Two sides July 30th, 2012 at 13:15
Question was the husband the only abusve one and was it everyday beatings was he a angry
drunk that would come home just to beat the wife and was he the only abuser in the family and
out of both parents
No he was not an angry drunk controlling, dictator. I quote My home is a communist home
and I am the dictator and what I says goes.. Yes I did hit my boys. I admitted this in the book.
I have said time and time again, I was wrong and what happened to them was wrong. I hold
myself accountable for what happened to my boys.
32. G.R.S. July 30th, 2012 at 16:21
Time for all to move forward and just Live. I lost my primo last week I have more things to
worry about then the past the past made me strong and alert and that is why I am me so nope
wont hold onto past just time to move forward and live my life
33. Becky July 30th, 2012 at 16:36
Has Sadler received any type of therapy? Has he done anything to address and control his
abusive personality? This man repeatedly abused his wife for years. He has no respect for
women. There are not enough words to express how this man should not be a police chief, let
alone a police officer. This is outrageous!
Becky, no he did not. No he did not address this. I feel I must share this with your readers. My
abuse caused me retinal detachment and there is not a day I do not pray I can go back in time. I
have permanent damage. I know, I will never drive again or traveling but.I am now here to
help others. Until the day I go home with my parents; I will remember the abuse that caused me
my vision.
35. Goldilocks July 30th, 2012 at 18:33
Wow, this sure is unbelievable news about Chief Sadler. Becky, I fear for your safety in
revealing this news. You never know what abusive people and their supporters will do in order
to protect their jobs, reputation, etc. Please be careful.
36. Anonymous July 30th, 2012 at 20:52
People .dont believe everything you read!!!!! This sound like a whole bunch of
nonsense. She waited soooo long to report the abuse Why??? It sounds to me like a case
of a breakup gone wrong And Mrs Torres You should hire an editor for your next book)
37. Becky July 30th, 2012 at 20:57
No, she didnt wait so long. She filed for a PFA in 1999. What about that dont you understand?
Becky thank you. Sounds to me this person is a bit jealous. I am going to pray for you. I feel no
anger or hate. Again, what matters here is what we can do to help victims who are afraid to
speak out. I tried to get help. I received no help absolutely Nothing. I will not turn my back on
another SURVIVOR OF Officer Involved Domestic Violence OIVD or any victim of Domestic
Violence.
Look how many treat the victims of Sandusky. They made comments how they only want
money. So many children, women and men, yes men lives with the memory of abuse.
40. anonymous July 30th, 2012 at 22:54
Question??? Are there any other women claiming abuse by this man!!! Why are you naming
him and not the trooper??? Why did you wait to open up about the abuse!!?? Are you hiding
anything???? Have you always been the victim or have you ever been the abuser????
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I would love to hear what the CHILDREN who grew up in that household have to say!!!!! Ive
been in the same exact situation and Im beyond positive that this women is leaving somethings
out!!!!
So i guess its PRESIDENT OBAMAS fault for all the unsolved murders across the United
States???? No!!!!!! Its the cowards how commit the crime!!!! So I question this women even
more!!!! It seems that your only goal and mission is to destroy this man!!!!!! You seem like an
vindictive, manipulator!!!!! Youre all about yourself!!!! Your only chance and shot to fame was
this book!!! It has been two years since you published and it was a flop!!!! I read up on you and
him!!! He is married and has a new baby!!! So its obvious for very very bitter and jealous!!!!
Yall keep believing what you are reading, cause I guarantee lies are being told!!!!
If you watched the interview he gave before becoming Chief, he mentioned having FIVE
CHILDREN!!!!!!!!!!!!!!
44. It's time to make the donuts July 31st, 2012 at 09:54
Anon..could you be the one in denial?.Im thinking your related to the wife abusing
chief!!!!!!!!!!!!!!!!!!!.
45. Chunky Blue Line July 31st, 2012 at 12:18
Anonymous sounds like he doth protest too much. Check the IP address Becky, I would guess
its coming from CHUNKYs home address based on the time. Hes probably wise enough not
to use the Police Dept computer.
oh, and !!!!!!!!!!!!!!!!! [just sayin]
46. Denny July 31st, 2012 at 12:36
Anonymous, how can you guarantee lies are being told when you hide behind your identity?
47. It's time to make the donuts July 31st, 2012 at 12:56
LoL!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!chunky blue line
48. Chunky Blue Line July 31st, 2012 at 15:23
July 30, 10:54 p.m.
Scene: Chunky at home, wife/kids asleep, working on his 3rd Jack&Coke reads LIP News
and angrily responds.
Another swig of Jack&Coke, posts again at 11:01 p.m.
Two more swigs of Jack&Coke, eyes bulging and red faced it takes several minutes to type
another handful of comments holding down the ! key for emphasis, 11:19 p.m.
Final comment 11:25 p.m. Chunky spills the 4th Jack&Coke on the keyboard and heads to bed.
He may be angry, but hes still large and in charge of his domicile and county department.
-scene49. Rosaura Torres Sadler July 31st, 2012 at 17:08
Most people would rather point the finger at the victim. AMON, are you Denise? Are you one of
his followers. Many would rather blame, shame and guilt the victim. Shame on you
AMONUntil you walk into any victims shoes you would never know the damage that has
been caused. Again, I will pray for you because this is all I can give you; is my prayers.
Becky, GOD BLESS YOU!!!!
50. Rosaura Torres Sadler July 31st, 2012 at 17:14
If you look at his BIO AMON, my and your chief children do not exist. When he was sworn in
as chief; did you see any of our adult children? NO. If you have any questions for me, just ask. I
am right here. Be blessed.
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51. Clara Bell Leonard July 31st, 2012 at 19:18

I am no supporter of abusers, but i am also not a supporter of a lifelong sentence and drag about
of all or any one thing that someone is accused of. What is the purpose of this? Why cant
Sadler be on a board that serves to protect the women of abuse? In rehab facilities often the best
counselors are ones that have been in the shoes before, same for alcohilics etc. A person is
capable of seeing the wrong if any and making amends to that end. They may never pay enough
in your or my eyes, but luckily you and I dont have the final say. forgive and let live then you
can be free.
52. Rosaura Torres Sadler July 31st, 2012 at 20:36
Clara you are so right, I agree he should be a part of all of these outstanding facilities
but.How can he advice on any such issues such as Domestic Violence, when the abuser will
deny any abuse. I have permitted damage to my vision. It does not matter what he did to me,
what matter is what we can do to help others. How can we help others. How can we stop the
ABUSE!
53. Clara Bell Leonard August 1st, 2012 at 10:00
Sadly it is a loophole that you cannot go back an weave shut. it doesnt really matter what
method one uses to cleanse theirself or shed bad behaviors, as long as they do. Unless and until
his current wife decides to come out with something it does not really pose any threat in the
performance of his job as police chief. From what I am reading it is not you necessarily calling
for him to lose his job, but more dear Becky. I recognize you have a story you want to tell, but it
really looks like Becky is riding your coat tails and pushing your buttons to further her dislike or
disappointment of Sadlers performance. 2 separate things that should not be coupled together.
Your story your life and if it were me I would protect those which I hold to be my truth and be
uhhhm, choicier?? of who I give audience to. Life and time are precious and I am not trying to
further somebody elses gosh danged agenda. At the end of the day, you dont need
acknowledgement from any abuser, not if you have to ask for it, see that the longer you punish
them the longer you are punishing yourself.
54. Becky August 1st, 2012 at 10:15
Clara, LOL! Riding her coat tails? Ive been publishing daily for almost 9 years! I dont do coat
tails. Did you watch the video by Lt. Todd Umstead that I linked to? The Lancaster Police deal
with 3,000 domestic calls a year it is their most common call. Tell me how you can have a
domestic abuser as the police chief under those conditions?
http://www.youtube.com/watch?v=jMR2UAAwTN0
September 25, 2012 will be the nine year anniversary of this site, Clara!
Becky I dont mean you need her, I just mean you WANT to use her. I have a site, its been up
since sites were allowed to be had. hoop dee freaking dooo!
Yeah, yeah, yeah.
I listened to Rosa on the blogtalk interview and the one on YouTube where she talks with
another wife of a philly cop. anyway, Rosa could have her own blogtalk or other medium to
discuss her story the way she likes, she can give her goals, her mission, and her plan and tell us
all how we can help. so Becks, what are your goals, what is your mission, what is you plan to
have the rest of us help make Lancaster a better place or the best it can be?
Obviously as a new reader Clara, you wouldnt know but in the last six months or so I have
uncovered the following and plan to pursue and help get the situations corrected so that
Lancaster can move forward:
1. Blatant racial discrimination in hiring by the County of Lancster. This is an ongoing series.
2. Public officials not being held accountable in one case particularly the coroner. He failed
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to perform his job duties by not performing autopsies on two women found hanging from trees
within a week of each other in the county. One looks very much like a murder, not a suicide as
he declared (without benefit of an autopsy. There will be more on that coming.
3. A terrible lack of diversity on the Lancaster Police force. Lancaster is over 50% minority.
Check out the Honor Guard on the police website. Check out their three new hires! This is
disgraceful and is also an ongoing part of a series.
4. The Lancaster Polices terrible record in solving murder and crimes. Check out the
UNSOLVED MURDERS and the UNSOLVED CRIMES tabs at the top of my site.
5. Blatant racism in sentencing by Lancaster County Judges.
6. Blantant racial discrimination in hiring by the Lancaster Newspapers which has allowed many
of the above inequalities to exist. They have one minority on their editorial staffs the editor of
La Voz (its in Spanish and hence they needed someone fluet in Spanish!) I have been writing
about this subject for years!
7. Trying to bring awareness about the sexual abuse of children including incest. This has been
ongoing on this site for years.
I could keep going but Ill stop now because I have work to do!
Okay, Clara, if youre going to get nasty and make personal attacks your comments are not
going to be posted. Okay, Clara boo?
61. Rosaura Torres Sadler August 1st, 2012 at 11:22
It is time to come together to help the citizen of Lancaster and I believe in my heart that Becky
is trying to do just that.
Rosa, Im a going to leave this conversation for 2 reasons.
1. I dont stick around for any abusive conversation or ones that i feel degrade the person I am
tryin to be.
2. You appear to have never stopped being a victim and until you do, nothing can help you. I
believe you were wronged, but unless people are really going to band together and put some fire
under our system, little change will come. I wish you better outcomes and eventual peace. I have
it.
63. Jen Hopkins August 1st, 2012 at 12:58
Wow.. It is truly amazing how this woman decided to write a book only after Mr. Sadler became
a Chief in Lancaster. Also, she only claimed abuse after he left the marriage only to dismiss the
claim to get money. Really? This is truly a case of jealousy and need for revenge. I also find it
interesting that she is so focused in destroying Mr. Sadlers reputation but talks very little about
the State Trooper whom she claims abused her too. I have to admit that reading her book was
painful because of so many grammatical errors and inconsistency in her story. She claims that
she was terrified of him but also admits to being unfaithful, Im not sure how a terrified
woman that feared for her life can go ahead and be unfaithful to the man she fears. I personally
think that Ms. Torres has been on a campaign to destroy the Chief and her efforts have been
useless. I agree with Anonymous, I would love to hear from the children that lived in that
household. I would also love to hear from other people who witnessed the abuse, and how
about his current wife? Is she claiming abuse too? My predictions are that the Chief will
continue to be the Chief and Mrs. Torres will continue hating him for it.
I advise Ms. Torres to move on and do some soul searching in order to be happy and forget
about her ex-husband who left her over a decade ago. That is way too long to hold on to hate.
Also, Ms. Torres, you should take a basic grammar lesson before you call yourself an author.
Clara Bell, You as a survivor are aware that Domestic Violence is a lifetime of healing but.We
do live. So many victims and survivors live with Post Traumatic Stress Disorder. I am no longer
a victim but.Every day I am reminded just like so many of my sisters and brothers of the
damage they will live with them for the rest of their lives.
Should we tell those young men who were sexually abused to get over it? No, those young men
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are our children. We must not stand and ignore what has happened to so many. I have never
shown any bitterness towards you. I am a good decent person. I will continue to treat you with
respect. Be blessed Clara Bell.
Do I hate Keith? No, I have spoken to many women and just as myself, they want
acknowledgement, accountability for what happened to them. If I live to be a 100, I will always
remember what Keith Sadler and Anthony Suber did to me.
I started writing my book back in 1999. I decided to come out after the death of my father. My
mother and father told me not to give up, to speak out and I did. There were many errors in my
book. My editor did a horrible job on the first fifty copies and it was corrected but.This does
not matter. The truth is the truth. No matter how many errors there were, it does not change the
fact that Keith is my past abuser. I did mention Anthony Suber, I wrote to Sotomayer about this,
I contacted the US Attorney Generals office, I put in a complaint. I did it all
I dont care if they dont like my book, I and many more knew what he did. My children are
adults, if you wish to contact them, be my guest.
Jen, are you a member of Keiths current family? I received an email from a friend saying
people are confused and think the book is written by his current wife. The people in Lancaster
know nothing about his prior wife, Rosa, because we never heard one word about it in the press!
On the weekends, he plays taxi driver for his 13- and 17-year-old daughters, masters the
grill in almost any weather, hits the gym for a 90-minute Saturday-morning workout and
is able to wrest control of the TV remote for a blessed few hours.
Read more: http://lancasteronline.com/article/local/353634_Police-chief-hits-the-gymthe-grilland-the-tube.html#ixzz22JqiruNu
Rosa, this is about as much as anyone in Lancaster knew about his family. The reporter did not
tell us or maybe Sadler didnt tell him that the daughters are not his biological daughters!
OH MY GOD Becky, so many of your followers and readers would rather ignore the
truth.Just like the Penn State Scandal. Many wanted them to go away. Now I understand why
their names were never mentioned, look what is staking place on your Web Site..Why do they
continue to blame and abuse the survivor. They refuse to hold the abuser ACCOUNTABLE.
Becky, continue your work!!! I am honored to know you!!!!
Rosa, I think its one or two people who know Keith who have been posting comments all day
long. I think most of my reades are supportive of you. Nobody knew about his previous family.
Becky, Keith had a Favorite saying out of sight out of mind. My children are a reminder of the
past. When I was in court in April in Lancaster one of our sons stopped to see him. Sadly, his
staff was shocked. I wonder why, could it be some did not know about me? I could not answer
that but.I can answer this. I knew that it was time. So many of us continue to keep the CODE
OF SILENCE. I refuse to keep the CODE OF SILENCE.
Rosa, a friend sent me an email saying people are confused because they did not know he had a
first wife! Maybe you could outline a brief bit about your life with him when married, when
divorced, how many kids, etc. and I could also run it as the story this afternoon. People in
Lancaster are stunned! They knew nothing about this and a different family in his past!
God bless you Becky, I posted my comments..If they have any questions for me, I am right
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here..I know in my heart that my parents are proud of me.Because they wanted me to
continue the fight and I did
Thank you Becky, I must apologize to your followers. I am reading some of these horrible
comments, whoever this person is family or friend would rather protect my past abusers Keith
Sadler and Anthony Suber.
I will write a short story for you. Thank you Becky.
Perfect. As you said his own staff were shocked all the people in Lancaster are as well! WE
DIDNT KNOW! A brief story would be great! Thanks, Rosa.
77. Chunky Blue Line August 1st, 2012 at 16:55
Rosa, when the truth is revealed the abusers and his supporters will go after you the victim. It
happens all the time. Stay strong and know that there are people reading these stories who
understand your pain and support you in standing up and taking your power back. I applaud
you! Plus Ive sent relevant links far and wide to tell your story.
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Meet The Chief of The Lancaster City Police Bureau by Stan J. Caterbone October 9, 2015 Copyright 2015

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Case 2:04-cv-04544-JKG Document 19 Filed 10/07/05 Page 1 of 12

UNITED STATES DISTRICT COURT

Civil Action No. 04-CV-4544

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Case 2:04-cv-04544-JKG Document 19 Filed 10/07/05 Page 2 of 12

Defendant Commonwealth of Pennsylvania and maintains its headquarters at 1800

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Friday, October 09, 2015

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Friday, October 09, 2015

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encouraged, tolerated, ratified and has been deliberately indifferent to a pattern,

Friday, October 09, 2015

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c. The monitoring of Troopers whom it knew or should have known were

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Friday, October 09, 2015

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Friday, October 09, 2015

Case 2:04-cv-04544-JKG Document 19 Filed 10/07/05 Page 12 of 12

Attorney for Plaintiff Rosa Sadler

Friday, October 09, 2015

PROTHONOTARY OF LANCASTER COUNTY

PROTHONOTARY DOCKET ENTRIES

CAPTION ENTRY IS: ROSA SADLER VS. ANTHONY W. SUBER

COMPLAINT FILED BY ROBERT T. VANCE, JR., ESQ.

COPY OF COMPLAINT (2) WITH RECEIPT TO ATTORNEY

PRAECIPE-ENTER APPEARANCE OF DANIEL R. GOODEMOTE, ESQ. ON BEHALF OF DEFENDANT,

PRAECIPE TO REINSTATE COMPLAINT. REINSTATED AS DIRECTED BY RANDALL O. WENGER,

PRAECIPE-PRE-TRIAL CONFERENCE WITH PLAINTIFF'S STATUS REPORT AND CERTIFICATE OF

STATUS REPORT OF DEFENDANT ANTHONY W. SUBER'S FILED BY: DANIEL R. GOODEMOTE,

FILE RECEIVED BY PRESIDENT JUDGE FARINA.

PRAECIPE-PRE-TRIAL CONFERENCE FILED BY ROBERT T. VANCE, JR., ESQ. CERTIFICATE OF

FILE RECEIVED BY JUDGE FARINA.

STATUS REPORT FILED BY DANIEL R. GOODEMOTE, ESQ. CERTIFICATE OF SERVICE OF SAME.

(c) CountySuite Prothonotary, Teleosoft, Inc.

Friday, October 09, 2015

PRE-TRIAL MEMORANDUM OF DEFENDANT FILED BY DANIEL R. GOODEMOTE, ESQ.

PRE-TRIAL MEMORANDUM OF PLAINTIFF. FILED BY ROBERT T. VANCE, JR., ESQ. CERTIFICATE

PROPOSED VOIR DIRE QUESTIONS OF DEFENDANT, ANTHONY W. SUBER. FILED BY DANIEL R.

RESPONSE DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION FOR CONTINUANCE OF TRIAL

MOTION IN LIMINE OF DEFENDANT. FILED BY DANIEL R. GOODEMOTE, SENIOR DEPUTY

ANSWER PLAINTIFF'S ANSWER TO DEFENDANT SUBER'S MOTIONS IN LIMINE FILED BY:

(c) CountySuite Prothonotary, Teleosoft, Inc.

Friday, October 09, 2015

APPEAL TO HIGHER COURT FILED. NOTICE OF APPEAL TO THE SUPERIOR COURT OF

COURT COST 2 DAYS AT $14.00 PER DAY. TOTAL DUE $28.00.

October 09, 2015

(c) CountySuite Prothonotary, Teleosoft, Inc.

Friday, October 09, 2015

United States District Court Eastern District of Pennsylvania

United States District Court

SADLER v. COMMONWEALTH OF PENNSYLVANIA, PENNSYLVANIA STATE

Date Filed: 09/27/2004

represented by ROBERT T. VANCE , JR.

* SADLER ABUSED EX-WIFE * BREAKING NEWS * @ LIP News

* SADLER ABUSED EX-WIFE * BREAKING NEWS *

* BREAKING NEWS! *

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* SADLER ABUSED EX-WIFE * BREAKING NEWS * @ LIP News

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* SADLER ABUSED EX-WIFE * BREAKING NEWS * @ LIP News

* SADLER ABUSED EX-WIFE * BREAKING NEWS * @ LIP News

* SADLER ABUSED EX-WIFE * BREAKING NEWS * @ LIP News

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