Richard Slifer-Criminal Complaint-Barratry-Final
Richard Slifer-Criminal Complaint-Barratry-Final
RICHARD SLIFER
Telephone: ( ) (610) 874-8178
Municipal Office
224 Castle Avenue
Docket No.: Upland, Pennsylvania 19015
Telephone: (610) 874-7317
Date Filed:
OTN:
(Above to be completed by court personnel) (Fill in defendant’s name and address)
Notice: Under Pa.R.Crim.P. 506, your complaint may require approval by the attorney for the Commonwealth before it can be
accepted by the magisterial district court. If the attorney for the Commonwealth disapproves your complaint, you may
petition the court of common pleas for review of the decision of the attorney for the Commonwealth.
Fill in as much information as you have.
Defendant’s Race/Ethnicity Defendant’s Sex Defendant’s D.O.B. Defendant’s SID (State Identification Number)
White Black
Female
Asian Native American ✔ Male
Hispanic Unknown
Defendant’s A.K.A. (also known as) Defendant’s Vehicle Information Defendant’s Driver’s License
Plate Number State Registration Sticker (MM/YY) State Number
I, Carmen Santucci
(Name of Complainant-Please Print or Type)
1. I accuse the above named defendant who lives at the address set forth above
I accuse the defendant whose name is unknown to me but who is described as
I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I have
therefore designated as John Doe
with violating the penal laws of the Commonwealth of Pennsylvania at BOROUGH OF UPLAND
(Place-Political Subdivision)
Participants were: (if there were participants, place their names here, repeating the name of the above defendant)
RICHARD SLIFER
All of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of
Assembly, or in violation of §5109 and
(Section) (Subsection)
3. I ask that process be issued and that the defendant be required to answer the charges I have made.
4. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and
belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa.C.S. § 4904)
relating to unsworn falsification to authorities.
7/22/2022
Date Signature of Complainant
(Name of Attorney for Commonwealth-Please Print or Type) (Signature of Attorney for Commonwealth) (Date)
AND NOW, on this date , I certify that the complaint has been properly completed and verified.
1. Richard Slifer, acting as the Borough of Upland Code Inspector, filed THREE unjust and
vexatious suits against Carmen Santucci, by falsely purporting to possess the Police Power
of a Law Enforcement Officer pursuant to Pennsylvania Title 37 Chapter 21 § 21.1,
which specifically enumerates a Law Enforcement Officer as being a “sheriff, deputy
sheriff, constable, deputy constable, detective, or a police officer”, with the power and
legal authority to file Citations against Santucci and Santucci’s property commonly known
as 515 West 24th Street, Upland, Pennsylvania 19015. (See exhibits A, B, C)
2. Richard Slifer performs Administrative duties for the Borough of Upland, similar to a
parking meter attendant, and possesses no Police and/or Law Enforcement powers to
surveil, investigate, question, detain, cite, or arrest Carmen Santucci, nor Jurisdiction or
authority, whatsoever, to exert acts of Ownership, Interest, or Rights in Santucci’s property,
commonly known as 515 West 24th Street, Upland, Pennsylvania 19015.
“Full-time police officer - A person who is employed by a city, borough,
town, township or county police department (including sheriffs, deputy
sheriffs and county detectives) assigned to law enforcement duties, and
who works a minimum of 200 calendar days per year. The term does not
include persons employed to check parking meters or to perform only
administrative duties, nor does it include auxiliary and fire police. For
the purposes of § 21.16 (relating to exemption for retired police officers),
the term includes a person employed by the Pennsylvania State Police.”
Pennsylvania Title 37 Chapter 21 § 21.1. Definitions
3. Neither Slifer nor the Borough of Upland possess Ownership, Interest, or Rights in
Santucci’s non-commercial property and Slifer, a non-Law Enforcement Officer, FAILED
to file THREE complaints pursuant to Pennsylvania Title 234 § 420, with any Magisterial
District Court. Slifer’s three suits are not only violative of Santucci’s secured rights to
acquire, possess, and protect property (Pennsylvania Constitution Article 1 § 1), his right
1 – Richard Slifer Private Criminal Complaint - 7/22/2022, Cert# 7019 2970 0001 5738 2357
to Due Process of Law (Pennsylvania Constitution Article 1 § 11), and his Inviolate right
to Trial by Jury in ALL matters (Pennsylvania Constitution Article 1 § 6), Slifer’s actions
constitute Barratry pursuant to Title 18 § 5109, as Slifer, who is not a Law Enforcement
Officer, initiated and perpetrated three suits against Santucci and/or Santucci’s property
through the making and filing of Citations R2629367-6, R3295860-1, and R3295987-2,
as opposed to Complaints pursuant to the rules, laws, and constitutions of Pennsylvania
and the United States of America.
“When the affiant is not a law enforcement officer, the affiant shall
institute a criminal proceeding in a summary case by filing a
complaint with the proper issuing authority.” Pennsylvania Title 234
§ Rule 420 - Filing of Complaint.
4. Richard Slifer, is not a Law Enforcement Officer nor a Judical Officer, and has no
Jurisdiction or legal authority to issue citations (writs) against Carmen Santucci
and/or his property commonly known as 515 West 24th Street, Upland,
Pennsylvania 19015. Slifer and the Borough of Upland are not a court of
competent jurisdiction! Slifer has no Jurisdiction or legal authority over Santucci
or Santucci’s property. Slifer has no jurisdiction or legal authority to command
Santucci to appear anywhere at anytime! Slifer has no Jurisdiction or legal
authority to command Santucci to do anything whatsoever!
5. Carmen Santucci was never provided Service of Process containing three complaints
accompanied by the required Summons, so there is no court Jurisdiction, nor is there a legal
or factual basis for these three suits against Santucci; which are wholly unjust, vexatious,
and severely damaging to Santucci and Santucci’s property, commonly known as 515 West
24th Street, Upland, Pennsylvania 19015.
6. These three unjust and vexatious suits constitute an Abuse of Process! The citation process
was not created for Carmen Santucci and was not created for a Borough of Upland Public
Servant to extort, harass, stalk, threaten, abuse and severely damage Santucci, one of the
people of Pennsylvania. The citation process imposed by Richard Slifer does not have
2 – Richard Slifer Private Criminal Complaint - 7/22/2022, Cert# 7019 2970 0001 5738 2357
anything whatsoever to do with the private and personal property of Santucci, which is
non-commercial and used strictly for the Owner’s shelter and conveyance. It begs the
question, what is a code inspector doing involving himself in property that neither he, nor
the Borough of Upland, have any Ownership, Interest, or Rights in?!
7. These three suits are not minor incidents as not only do they constitute Barratry against
Carmen Santucci, they evidence a corrupt organization pursuant to Pennsylvania Title 18
§ 911 - Corrupt organizations, as Richard Slifer, a non-Law Enforcement Officer,
committed a felony of the first degree by conducting and/or participating, directly or
indirectly, in the conduct of the Borough of Upland, through a pattern of racketeering
activity by making and issuing fictitious citations (security instruments) and creating
fictitious obligations against Santucci and the People of Upland and their properties, which
the Borough has no Interest in, Rights in, or Jurisdiction over, and this unlawful conduct
has been imposed against the People of Upland and their properties, with criminal intent,
by Slifer acting for the Borough of Upland, for the Borough’s financial benefit. These three
suits known as MJ-32239-NT-0000393-2022, MJ-32239-NT-0000330-2021, MJ-32246-
NT-0000239-2021 are not isolated occurrences perpetrated against Carmen Santucci, but
serve as evidence of a pattern of WIDE SCALE RACKETEERING being perpetrated
against thousands of People and Properties similarly situated to Santucci and his property,
and this is being done not only in Upland but throughout Delaware County! (See exhibits D, E, F)
I verify that the facts set forth in this complaint are true and correct to the best of my
knowledge or information and belief. This verification is made subject to the penalties of
Section 4904 of the Crimes Code (18 Pa. C.S. § 4904) relating to unsworn falsification to
authorities.
3 - Richard Slifer Private Criminal Complaint - 7/22/2022, Cert# 7019 2970 0001 5738 2357
Jun,29,2022-ll:30
No, 5021 P. 1
Exhibit A
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Exhibit B
lnsrtuted by
(W) ! White (A) U Asian (M) n ftilale (O) D Oi-View lrest
(B) n Black (H) ! Hispanic
(F) n Female (C) tr Citatiorrsummons
$ 40.25
42.
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POt!CE EOPY
COMMONIrMTIH OF PENNSYLVANIA CITATION NO.
NONJRAFFIC CITATION
Exhibit C
I vedly thal the fads set fodh in this cilalion are true lo lhe besi of my knowl€dge, inlormation and beliel. This veriticaton is made subject lo lhe penatiies ot S€dion 49&
of the Cdnes Code (14 Pa.C-S- S 4904) relating to unswoB talsfication lo aulhodti*. I cenify ihis nling compties with the UJS Case Records Plbtic A@ess Potiry.
407-95 (Rev.04/2018)
POLICE COPY
Exhibit D
COMMONWEALTH OF PENNSYLVANIA SUMMONS FOR SUMMARY CASE
COUNTY OF DELAWARE
NON-TRAFFIC
Telephone: 610-874-8178
Charqe(s)
ILO of Nuisance. parkinq on unpaved areas
¡q4J[1
1
134 (Lead) Uaved Parkinq
FINE AND COSTS:
I Fine:
if
1.
PLEAD NOT GUIL TY by notifying the magisterial district judge above
in
writing and forwarding an amount equal to the total due specified above, or the fine and
costs are not specified, forward the sum of $50.00 as collateral for your appearance at trial; OR,
district judge shall
2. PLEAD NOT GUIL TY by appearing before the magisterial district judge above and posting such collateral for your appearance as the magisterial
require; OR,
a plea; OR,
3. If you cannot afford to pay the total due specified above or the $50.00 collateral, you must appear before the magisterial district judge above to enter
4. PLEAD GUILTY by notifying the magisterial district judge above in writing, signing the appropriate plea under the MAIL IN PLEA section, and forwarding an amount
equal to the total due specified above; OR,
5. PLEAD GUILTY by appearing before the magisterial district judge above the total due
if is not specified,
or if you are required to appear because lhe offense with
is
carries a mandatory sentence of imprisonment, for example, a violation of 75 Pa.C.S. Section 1543(b) (Driving while operating privilege
which you are charged
suspended or revoked)
DISTRICT JUDGE AND WISH TO APPEAL, YOU HAVE THIRTY (30) DAYS TO REQUEST A TRIAL DE NOVO
• IF YOU ARE FOUND GUILTY BY THE MAGISTERIAL
IN THE COURT OF COMMON PLEAS
PAYABLE TO "MAGISTERIAL DISTRICT NO MDJ-32-2-39"
• ALL CHECKS OR MONEY ORDERS FOR FINE, COSTS, FEES, OR FOR COLLATERAL, SHALL BE MADE
Unified Judicial System web portal. Visit the portal at https:1/ujsportal.pacourts.us/epay to make a
You can make case payments online through Pennsylvania's
payment.
• IF YOU FAIL TO RESPOND TO THIS SUMMONS WITHIN THE TIME
SPECIFIED ABOVE, A WARRANT FOR YOUR ARREST SHALL BE ISSUED.
IF YOU INTEND TO RESPOND BY MAIL:
Detach and complete the lower portion of this summons with your signature on the appropriate plea line, (1) or (2).
If you PLEAD NOT GUIL TY, your check or money order must be
in the
amount of the total due specified above. If the total due
is not specified,
your check or money
be notified by mail of your date and lime for trial.
order must be in the amount of $50.00 which will be held for collateral for your appearance at trial. You will
If you PLEAD GUILTY, enclose a check or money order in the amount of the total due specified above. Failure to remit the full amount
of the fine, costs, and fees may
result in the issuance of a warrant for your arrest. Your check or money order shall be made payable to "Magisterial District No MDJ-32-2-39". -- -- - -
- - -
-
- - - - - - - - - -
-· - - -· -
HERE) - - -
-··
(DETACH -- - -
PLEA MAIL IN
(Failure to indicate a plea when forwarding an amount equal to the total due
I
2. PLEAD GUILTY
(Signature)
MDJS617
Printed: 07/12/2021 10:37:05AM
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Exhibit E'
Telephone: 610-566-3495
,------------------7
Your Ro!e: Defendant 1
L _ _ _ _
Charge(s)
ILO 134
1
(Lead) Unpaved Parkinq Areas: Declaration of Nuisance. parkinq on unpaved areas
A Summary Trial has been scheduled for the above captioned case to be held on/at:
Date: Wednesday, December 29, 2021 Place: Magisterial District Court 32-2-46, Media
939 North Providence Road
Media, PA 19063
Time: 10:00 AM
610-566-3495
This court has received your plea of NOT GUILTY to the above summary violation(s). The sum of $0.00 has been accepted as
collateral for your appearance at trial.
You have the right to be represented by an attorney. You have the right to have any witnesses present. It is
your responsibility to
notify your attorney and/or witnesses of this trial date/time.
Failure to appear for your trial shall constitute consent to trial in your absence and
if
you are found guilty, the collateral deposited
for a trial de
shall be forfeited and applied toward the fines, costs, and restitution. You shall have the right to appeal within 30 days
novo.
If
you have any questions, please call the above office immediately.
Shct.t!d you fail to appear for your summary trial, a warrant may be issued for your arrest.
Telephone: 610-874-8178
Costs/Fees:
/
L_ '¡{lf, Server Fees: Restitution: Total Due: j{¡,L/r
WITHIN TEN (10) DAYS OF RECEIPT OF THIS SUMMONS YOU MUST:
if
1. PLEAD NOT GUIL TY by notifying the magisterial district judge above in writing anti f()rwarding an amount equal to the total due specified above, or the fine and
costs are not specified, forward the sum of $50.00 as collateral for your appearance at trial; OR.
2. PLEAD NOT GUILTY by appearing before the magisterial district judge above and posting such collateral for your appearance as the magisterial district judge shall
require: OR,
3. If you cannot afford to pay the total due specified above or the $50.00 collateral, you must
appear before the magisterial district judge above to enter a plea; OR,
4. PLEAD GUIL TY by notifying the magisterial district judge above in writing, signing the appropriate plea under the MAIL IN PLEA section, and forwarding an amount
equal to the total due specified above; OR,
5. PLEAD GUIL TY by appearing before the magisterial district judge above if the total due is not specified, or if you are required to appear because the offense with
is
which you are charged carries a mandatory sentence of imprisonment, for example, a violation of 75 Pa.C.S. Section 1543(b) (Driving while operating privilege
suspended or revoked)
NOVO
• IF YOU ARE FOUND GUILTY BY THE MAGISTERIAL DISTRICT JUDGE AND WISH TO APPEAL, YOU HAVE THIRTY (30) DAYS TO REQUEST A TRIAL DE
IN THE COURT OF COMMON PLEAS
NO MDJ-32-2-39"
• ALL CHECKS OR MONEY ORDERS FOR FINE, COSTS, FEES, OR FOR COLLATERAL, SHALL BE MADE PAYABLE TO "MAGISTERIAL DISTRICT
You can make case payments online through Pennsylvania's Unified Judicial System web portal. Visit the portal at https:llujsportal.pacourts.us/epay to make a
payment.
• IF YOU FAIL TO RESPOND TO THIS SUMMONS WITHIN THE TIME SPECIFIED ABOVE, A WARRANT FOR YOUR ARREST SHALL BE ISSUED.
IF YOU INTEND TO RESPOND BY MAIL:
Detach and complete the lower portion of this summons with your signature on the appropriate plea line, (1) or (2).
If you PLEAD NOT GUILTY, your check or money order must be in the amount of the total due specified above. If the total due is not specified, your check or money
order must be in the amount of $50.00 which will be held for collateral for your appearance at trial. You will be notified by mail of your date and lime for trial.
If you PLEAD GUILTY, enclose a check or money order in the amount of the total due specified above. Failure to remit the full amount of the fine, costs, and fees may
resuit In the i:;suancc of a warrant for your arrE:<st. Your cht::ck or 111oneyor<.ier sticti1 o r11êtde pQyctUi to '1v'Tagislelidi Vitric.;i iù iviDJ-J2-2··3S".
-
-- - - -
(DETACH HERE) - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
MAIL IN PLEA
an amount equal to the total due
I I
represent that make this plea knowingly, voluntarily, and intelligently. (Failure to indicate a plea when forwarding
specified above will result in a guilty plea being recorded.)
Docket No: MJ-32239-NT-0000393-2022 Citation No: R 3295987-2 Defendant: Santucci, Carmen
I
2. PLEAD GUILTY
(Signature)
If
you are disabled and require a reasonable accommodation to gain access to the Magisterial District Court and its services,
please contact the Magisterial District Court at the above address or telephone number. We are unable to provide transportation.
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Printed: 06/30/2022 2:45:51 PM
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Ill Iii::.- 610-565-6990