PHOTO: WASD Business Manager Wanda Erb

By Todd Bartley

TalkWilliamsport.com

NEWS@TalkWilliamsport.com

TalkWilliamsport.com obtained the “REPLY TO DEFENDANT WILLIAMSPORT AREA SCHOOL DISTRICT’S STATEMENT OF MATERIAL FACTS IN SUPPORT OF THE MOTION FOR SUMMARY JUDGMENT”.

Included with the 91-page “REPLY” are deposition transcripts previously attached to the “Motion for Summary Judgment” filed by attorneys representing the Williamsport Area School District in the Federal Civil Rights lawsuit filed by John Doe #1 and supplemented in this filing.

John Doe #1 is the former WAHS baseball player who was the victim of a criminal indecent sexual assault during the 2018 WAHS baseball team trip in Myrtle Beach, South Carolina.

John Doe #1 is black the teammate who assaulted him is white.

The depositions contain previously undisclosed facts from the “investigators” employed by the Office of Pennsylvania Attorney General, Williamsport Area School District and Lycoming County.

Attorney Greg Stapp who is representing John Doe #1 was asking the questions and Agent Scicchitano identified below is employed by the Office of Pennsylvania Attorney General was providing the answers

At the time of the investigation in 2020 Josh Shapiro was the Pennsylvania Attorney General.

On Page 13, paragraph 31 is as follows:

31. Denied. Plaintiff is without sufficient information to form a belief as to the truth or falsity of the averments contained in Paragraph 31. Defendant has not provided the layout of Myrtlewood Villas other than the pictures provided in Exh. 21 WASD 00207-00219. Defendant has failed to provide any floor plans of the Myrtlewood Villas and/or the Atlantica Hotel.

As previously reported by TalkWilliamsport.com made numerous Right to Know Law requests were made to the Williamsport School District Business Manager Wanda Erb who also serves as the RTKL Officer for the WASD.

From a previous TalkWilliamsport.com report on the 2018 WAHS Baseball/Myrtle beach case.

Again, Wanda Erb in the October 8, 2019 affidavit offered the following response:

4. Regarding Requestor’s second request, I conducted a thorough examination of files in the possession, custody and control of the Agency for records responsive to the request. As these types of records would be in the possession of the athletic director or REDACTED BY AUTHOR, I spoke with WASD Athletic Director Sean McCann and REDACTED BY AUTHOR. At the time the request was made (6-17-19 original RTK request), neither Mr. McCann nor REDACTED BY AUTHOR had any record identifying which players were assigned to which hotel room. Accordingly, I have made the determination that the records requested are not within the Agency’s possession, custody or control. 

5. Regarding Requestor’s third request, I conducted a thorough examination of files in the possession, custody and control of the Agency for records responsive to the request. As these types of records would be in the possession of the athletic director or head coach, I spoke with WASD Athletic Director Sean McCann and REDACTED BY AUTHOR. At the time the request was made (6-17-19 original RTK request), neither Mr. McCann nor REDACTED BY AUTHOR had any record that was responsive to the request. I have also contacted members, or former members, of the WASD Baseball Boosters Club, and outside organization not within the control of the Agency. As a result of those efforts, I obtained a bus invoice and a hotel invoice which were provided to Requestor’s counsel although they were not paid for by the Agency.

At no time since 2018 has anything regarding the Myrtlewood Villas been provided in response to any Right to Know Law requests made by TalkWilliamsport.com.

Exh. 21 WASD 00207-00219 begins with an email chain with to WAHS Athletic Director Sean McCann on his @wasd.org.

A copy of the referral based on criminal false swearing is also being provided to the Pennsylvania Office of Open Records as they have legal standing to make a referral as well.

Based on the exclusive reporting of TalkWilliamsport.com; a former WASD School Board member was found guilty of criminal false swearing in a voting case. The former WASD School Board member was given a sentence of ARD.

Criminal “false swearing” charge filed against Marc Schefsky, former WASD School Board member

18 § 4903 §§ B. False swearing. (a) False swearing in official matters.–A person who makes a false statement under oath or equivalent affirmation, or swears or affirms the truth of such a statement previously made, when he does not believe the statement to be true is guilty of a misdemeanor of the second degree if: (1) the falsification occurs in an official proceeding; or (2) the falsification is intended to mislead a public servant in performing his official function. (b) Other false swearing.–A person who makes a false statement under oath or equivalent affirmation, or swears or affirms the truth of such a statement previously made, when he does not believe the statement to be true, is guilty of a misdemeanor of the third degree, if the statement is one which is required by law to be sworn or affirmed before a notary or other person authorized to administer oaths.

This is a developing story on TalkWilliamsport.com.

Photos: Former disgraced Lycoming County Chief Detective and Little League World Series Team Host Willie Weber (left)

Current WASD Director of Student Services, Dr. Brandon Pardoe (right)

Q. Based on your investigation, was there a criminal conspiracy between those individuals?

A. In my opinion, yes.

Exh. 8 Scicchitano depo. 244: 17-20.

By Todd Bartley

TalkWilliamsport.com

NEWS@TalkWilliamsport.com

TalkWilliamsport.com obtained the “REPLY TO DEFENDANT WILLIAMSPORT AREA SCHOOL DISTRICT’S STATEMENT OF MATERIAL FACTS IN SUPPORT OF THE MOTION FOR SUMMARY JUDGMENT”.

Included with the 91-page “REPLY” are deposition transcripts previously attached to the “Motion for Summary Judgment” filed by attorneys representing the Williamsport Area School District in the Federal Civil Rights lawsuit filed by John Doe #1 and supplemented in this filing.

John Doe #1 is the former WAHS baseball player who was the victim of a criminal indecent sexual assault during the 2018 WAHS baseball team trip in Myrtle Beach, South Carolina.

John Doe #1 is black the teammate who assaulted him is white.

The depositions contain previously undisclosed facts from the “investigators” employed by the Office of Pennsylvania Attorney General, Williamsport Area School District and Lycoming County.

Attorney Greg Stapp who is representing John Doe #1 was asking the questions and Agent Scicchitano identified below is employed by the Office of Pennsylvania Attorney General was providing the answers

At the time of the investigation in 2020 Josh Shapiro was the Pennsylvania Attorney General.

From the Agent Scicchitano deposition transcript:

Q. Based on your investigation, did anyone employed by Lycoming County commit a crime during the handling of the investigation of the assault of John Doe in Myrtle Beach?

A. Yes.

Q. Who?

A. William Weber

Q. Based on your investigation, did anyone employed by Williamsport Area School District commit a crime during the handling of the investigation of the assault of John Doe in Myrtle Beach?

A. Yes.

Q. Who?

A. Brandon Pardoe

Q. Based on your investigation, were the individuals you just named working in concert together?

A. Yes.

Q. Based on your investigation, was there a criminal conspiracy between those individuals?

A. In my opinion, yes.

Q. You indicated that you had recommended charges in this case? Obviously, I know that’s the AG’s office —

A. I have the opinion that I would like to file charges, but again, not my decision.

TalkWilliamsport.com has reached out to current Pennsylvania Attorney General Dave Sunday for comment on this story.

This is a developing story on TalkWilliamsport.com.

B.M.: What do you mean lying?

MR. MCFARLAND: Do you remember this?

B.M: Yes. Now I do now that I see it.”

By Todd Bartley

TalkWilliamsport.com

NEWS@TalkWilliamsport.com

TalkWilliamsport.com obtained the “REPLY TO DEFENDANT WILLIAMSPORT AREA SCHOOL DISTRICT’S STATEMENT OF MATERIAL FACTS IN SUPPORT OF THE MOTION FOR SUMMARY JUDGMENT”.

Included with the 91-page “REPLY” are deposition transcripts previously attached to the “Motion for Summary Judgment” filed by attorneys representing the Williamsport Area School District in the Federal Civil Rights lawsuit filed by John Doe #1 and supplemented in this filing.

John Doe #1 is the former WAHS baseball player who was the victim of a criminal indecent sexual assault during the 2018 WAHS baseball team trip in Myrtle Beach, South Carolina.

John Doe #1 is black the teammate who assaulted him identified as B.M. is white.

The depositions contain previously undisclosed facts from the “investigators” employed by the Office of Pennsylvania Attorney General, Williamsport Area School District and Lycoming County.

At the time of the investigation in 2020 Josh Shapiro was the Pennsylvania Attorney General.

80. Admitted. By way of further answer, Plaintiff alleges that B.M. testified falsely for over three hours about his sexual assault of John Doe.

Exh. 11 B.M. depo. 150-151: 2-5.

After showing him the video that has been marked as an exhibit in this case, he recanted his prior testimony of over three hours and admitted that his sexual assault of John Doe included him showing his private parts to John Doe’s face and mouth.

Id. at 165-168: 22-5

For purposes of a summary judgment motion, Plaintiffs dispute the fact that B.M. never went out after curfew and doesn’t know anyone who did.

82. Admitted. It is admitted that none of the coaches stayed in the hallways after lights out to make sure that the players weren’t going into each other’s rooms and/or leaving the hotel.

83. Admitted. It is admitted that the Atlantica Resort Hotel was large. By way of further answer, the guest folio’s show that WASD rented rooms on the 1st floor, 4th floor, 5th floor, 7th floor, 8th floor, 10th floor, 12th floor and the 13th floor.

Exh. 23 Atlantica Resort Guest Folios.

The guest folios clearly acknowledge that REDACTED BY AUTHOR and WASD were aware of the spread-out nature of the rooms as early as February 28, 2018.

Id. Defendant has failed to provide any evidence of any attempts by an employee, agent, or servant of WASD to address the spread-out nature of the rooms prior to arriving on March 24, 2018.

84. Admitted in part, denied in part. It is admitted that nothing prevented a player from leaving his room at the Atlantica Resort in Myrtle Beach in 2018. It is specifically denied that this was the same in the Myrtlewood Villas as in prior years. Furthermore, the Myrtlewood Villas, as shown by the photos provided in the email from Myrtlewood Villas is a completely different type of facility involving three story condominiums that are directly adjacent to each other.

Exh. 22 WASD 02206-02222.

87. Admitted. By way of further answer, Defendant has offered the video that shows the sexual assault in which B.M. touched his penis to the lips of John Doe and inserted his penis into his mouth.

See Defendant Exhibit 16 Video Recording.

88. Admitted. By way of further answer, B.R. testified that he observed the video of the sexual assault in the WAHS cafeteria along with numerous other students. As a result of the videotaping by J.Z. being shown to individuals or students, some students at school began to refer to John Doe as “dick lips.”

Exh. 10 Doe depo. 112-113: 20-8; Exh. 14 B.R. depo. 13-14: 2-14.

95. Denied as stated. It is specifically denied that Plaintiff was asleep throughout the “incident.” Plaintiff is not aware of what Defendant means by “the incident.” When Plaintiff awoke, he saw B.M. near him and laughing hysterically after having placed his genitals and butt on Plaintiff’s face and in his mouth. Plaintiff testified as follows:

“Q. The incident itself, you were asleep and I believe you stated you did not wake up after you allege occurred, which was that B.M. put his genital, on your lips?

A. I said in my – well, in between my lips, like in my mouth.”

Exh. 10 Doe depo. 177: 12-18.

Plaintiff also testified that after he woke up, B.M. was kind of just laughing.

“A. Video that was shown to me, well lets put it appeared basically him putting his penis between my lips, kinda like opening my mouth and putting it –

Q. In your mouth?

A. Yeah, I guess you could say that.

Q. That’s what happened?

A. Yes.”

Id. at 93: 2-10

98. Admitted in part, denied in part. It is admitted that Plaintiff says, “B.M. put his penis in between my lips as I was asleep” and that “B.M. put his penis kinda like opening my mouth and putting it —.” It is specifically denied that Plaintiff’s assertion is based only on seeing the video. The video speaks for itself. The video depicts Plaintiff recoiling from something touching his face while simultaneously
showing B.M. with his hands on his hips.

101. Admitted. By way of further answer, the video speaks for itself. Furthermore, the Plaintiff has testified that B.M.’s genitalia touched his face and lips and went into his mouth.

Exh. 10 Doe depo. 93: 2-10.

102. Admitted in part, denied in part. It is admitted that B.M. initially denied that his penis touched any part of Plaintiff.

Exh. 11 B.M. depo. 44-45: 23-1.

It is specifically denied that this is the truth. B.M. was shown the video and the testimony was as follows:

“MR. MCFARLAND: All Right. So for the record, you’re being shown what I’ve marked as Exhibit 3.

You can hit play.   (Video played.)

THE WITNESS: And that was that. Can I replay it?

MR. MCFARLAND: Yeah. (Video played.)

THE WITNESS: That was it

BY MR. MCFARLAND:

Q. Have you seen that video before?

A. Yes, I’ve seen that video before.

Q. And you have seen that video?

A. Yes, that was the video JZ took, but this whole time I thought it was of my butt.

Q. You thought that the video we just watched, which you’ll agree with me the video shows you; right? That’s – that’s you in the video –

A. Yeah, that’s me.

Q. – correct?

MS. HAZEL: Mike, can you – can you have that forwarded?

MR. MCFARLAND: Yeah.

BY MR. MCFARLAND:

Q. Just to be clear; the person wearing the jeans and the black shirt, that’s you?

MS. HAZEL: Okay. Because the video I have only has the clip from there on. So I didn’t see the whole video.

MR. MCFARLAND: It’s the same clip.

MS. HAZEL: Yeah, what I got now.

THE WITNESS: Yeah, that’s me.

BY MR. MCFARLAND:

Q. Okay. So you’re telling me the video we just watched , which you’ll agree with me, Mr. B.M., shows you with your pants down, facing forwards, walk over to the other person on the couch, who is JOHN DOE #1 – (EDITED BY AUTHOR); right?

A. (Witness nods head.)

Q. Yes?

A. Yes.

Q. And then leaning forward and thrusting forward at his head; yes?

A. Yes, but nothing – there was no touch ever.

Q. Well, hold on. Hold on. How do you know there was no touch because five seconds ago you said you didn’t even do this?

A. I’m saying that I never touched him, like I never touched him with anything on my body.

Q. Okay. But you just – you just said that this video is you and every single minute of this deposition up until last minute you said you didn’t do this.

A. I didn’t know that was the video. I thought it was a butt video of me. That is – that’s the only video I’ve ever saw of me.

Q. Which shows you putting your penis in his face.

A. Yes, but nothing ever touched him.

Q. Well, so – okay. You’re confused by what video exists. I’ll ask you again probably for the – for the fourth time, did you put your penis in – in JOHN DOE #1’s – (EDITED BY AUTHOR) face; yes or no?

A. Yes, but it wasn’t – I didn’t touch him.

Q. That’s not my question.

A. Oh.

Q. Did you do it, yes or no?

A. Yes.

Q. Okay. Well, how come you’ve been lying the entire deposition up until this point?

A. What do you mean lying?

Q. You denied it every single time I asked you. So which is it, yes or no, you did it?

A. No, I never touched him with my front of my body, no.

Q. Not – not my question. Not my question. My question is did you put your penis in his face and you said every single time I asked you no, until right there?

A. Because you were telling me that it was my butt.

Q. You said it was your butt. You said that.

A. Yes.

Q. Yeah.

A. This whole time I thought it was.

Q. Do you know where your butt is on your body, sir?

A. Yes.

Q. Do you know where your penis is?

A. Yes.

Q. Yeah.

A. And that is totally me going forward.

Q. Okay. Yeah. So whether or not the video shows one thing or the other, you’re the person that’s in the room; right? You’re the person that was there –

A. Yes.

Q. – correct? Okay. So do you remember this happening? Do you remember this?

A. Yes. Now I do now that I see it.”

Id. at 165-169: 9-13. (emphasis added).

103. Admitted in part, denied in part. It is admitted that B.M. testified that he put his penis in Plaintiff’s face, but it never touched.

Exh. 11 B.M. depo. 167: 18

20. It is specifically denied that that is the truth. See Plaintiff’s response to paragraph 102.

104. Denied. Despite B.M.’s testimony, it is specifically denied that B.M. did not put his penis in Plaintiff’s mouth. See Plaintiff’s response to paragraph 102. Plaintiff also testified that B.M.’s penis was put inside his mouth.

Exh. 10 Doe depo, 98:6-10; 91:24 – 93:11; 92:1-11; and 242:24 – 243:-5.

This is a developing story on TalkWilliamsport.com.

Photos: Former disgraced Lycoming County Chief Detective and Little League World Series Team Host Willie Weber (left)

Current WASD Director of Student Services, Dr. Brandon Pardoe (right)

“By way of further answer,

David Scicchitano also recommended to the Attorney General’s Office

that William Weber, Chief County Detective for Lycoming County,

be arrested for Obstruction of Justice.”

Exh. 8 Scicchitano depo. 245: 15-20.

By Todd Bartley

TalkWilliamsport.com

NEWS@TalkWilliamsport.com

TalkWilliamsport.com obtained the “REPLY TO DEFENDANT WILLIAMSPORT AREA SCHOOL DISTRICT’S STATEMENT OF MATERIAL FACTS IN SUPPORT OF THE MOTION FOR SUMMARY JUDGMENT”.

Included with the 91-page “REPLY” are deposition transcripts previously attached to the “Motion for Summary Judgment” filed by attorneys representing the Williamsport Area School District in the Federal Civil Rights lawsuit filed by John Doe #1 and supplemented in this filing.

John Doe #1 is the former WAHS baseball player who was the victim of a criminal indecent sexual assault during the 2018 WAHS baseball team trip in Myrtle Beach, South Carolina.

John Doe #1 is black the teammate who assaulted him is white.

The depositions contain previously undisclosed facts from the “investigators” employed by the Office of Pennsylvania Attorney General, Williamsport Area School District and Lycoming County.

Attorney Greg Stapp who is representing John Doe #1 was asking the questions and WASD Director of Student Services Dr. Brandon Pardoe was providing the answers.

Agent Scicchitano identified below is employed by the Office of Pennsylvania Attorney General.

At the time of the investigation in 2020 Josh Shapiro was the Pennsylvania Attorney General.

3. Admitted in part, denied in part. It is admitted that B.M. was a freshman at Williamsport Area High School (hereinafter referred to as “WAHS”) and a member of the school’s junior varsity baseball team in the spring of 2018. It is specifically denied that B.M. is an alleged assailant. B.M. was placed in a diversionary program for Second Degree Assault and Battery in the state of South Carolina.

Exh. 17 Horry County Juvenile Complaint and Victim Impact Statement.

By way of further answer, B.M. served a term of probation as a result of his conviction; thereby admitting he was the assailant. Id. B.M. testified that after seeing the video that has been admitted under seal that he put his penis in the face of John Doe. Exh. 11 B.M. depo. 166-167: 18-2.

7. Admitted. By way of further answer, at all times relevant hereto, Nick Caringi (hereinafter “Caringi”) was also an employee, agent, or servant of Little League Baseball International, which made him a mandated reporter during the spring of 2018. Exh. 2 Caringi depo. 7: 11-17. Caringi testified that he is the Director of Operations for Little League Baseball and Softball where he has worked for 30 years. Id.

9. Admitted in part, denied in part. It is admitted that Brandon Pardoe (hereinafter “Pardoe”) was the principal of the WAHS in the spring of 2018 and that he attended the spring 2018 Myrtle Beach WAHS baseball trip. It is specifically denied that he participated in the trip in his capacity as a parent of a player on the baseball team. Specifically,

Pardoe testified at length that he disciplined a child, M.H., while on the trip for purchasing marijuana in violation of the laws of South Carolina. Exh. 3 Pardoe depo. 51: 3-20.

This was within his role as a WAHS employee as he would have no power to discipline said child in his role as a parent to another child on the team. Pardoe went on after lengthy testimony about WASD’s own policies and procedures, and that he failed to report to the state of South Carolina that a student had purchased marijuana illegally. Id. at 59-61: 16-12; see also Exh. 19.

Pardoe also testified that the discipline of the student took place while in Myrtle Beach and that meetings were held with the student and/or other students related to this discipline. Exh. 3 Pardoe depo. 71: 11-19.

Pardoe admitted that Sean McCann (hereinafter “McCann”), the WASD Athletic Director, advised him that a player on the baseball team had purchased illicit drugs. As a result of this action by the player, Pardoe put on his Administrator hat to discipline the player.

Id. at 51: 3-9.

A parent, Todd McQuillen, notified employees of WASD that a player had purchased marijuana following which a meeting was held with Pardoe and McCann. Id. at 52-54: 3-9.

Pardoe testified that he interviewed the player and that the player admitted purchasing marijuana in South Carolina. Id. at 61: 13-24.

Pardoe admitted that WASD policy required him, as principal, to report the purchase of an illegal substance in South Carolina.  Id. at 59: 16-21.

He testified that the player admitted purchasing marijuana and that he recovered drug paraphernalia. After interviewing the player and recovering items related to the purchase of an illicit drug, he admitted that he did not report the crime to the authorities in South Carolina as required by WASD policy. Id. at 60: 4-8; see also Exh. 19.

N.M. testified that there was a meeting on the bus with the players in Myrtle Beach where they were told that M.H. was sent home.
Exh. 4 N.M. depo. 116-117: 22-8.

11. Admitted. Anne Logue is hereinafter referred to as “Logue.” By way of further answer, Anne Logue hired REDACTED BY AUTHOR in violation of state law. (See the testimony provided in paragraph 6).

13. Admitted in part, denied in part. It is admitted that Willie Weber (“Weber”) was the Chief County Detective for Lycoming County in 2018. It is specifically denied that he investigated a Child Line Report related to the incident.

According to Weber’s own testimony, he put Pardoe in charge of investigating the Child Line Report related to the Plaintiff in this case. Exh. 7 Weber depo. 46: 5-20; Weber, page 161-162.

Weber failed to interview witnesses, including but not limited to, the actual perpetrator of the assault, despite being the Chief County Detective for Lycoming County. Id. at 71: 3-25.

Weber testified to a second Child Line Report related to the Myrtle Beach trip of 2018 but admitted that he never saw the second ChildLine report and didn’t know what was in it. Id. at 131: 12-17.

He also stated that other than interviewing Jeanne Reeder, he never followed up with other individuals whose names she gave him, who would have information about the second assault. Id. at 131-132: 18-7.

Her son B.R. was present at home during this interview and had information and evidence related to what happened in Myrtle Beach, but Weber made no effort to interview him. Exh. 14 B.R. depo. 50-51: 18-7.

Talking to Jeanne Reeder was the only “investigation” that Weber performed related to second Child Line Report.

Weber testified that during his investigation, he learned that Pardoe told the kids to delete the videos:

Q. And is it your understanding that Brandon Pardoe told the kids to get rid of either the images or the videos?

A. Sure.

Exh. 7 Weber depo. 54-55: 23-1.

Weber admitted that he never interviewed the REDACTED BY AUTHOR, or the athletic director, McCann, about what happened in Myrtle Beach or what they knew. Id. at 64: 3-22.

Weber never interviewed J.Z., the videographer, about what happened to John Doe. Id. at 70: 14-23.

When Weber was asked why he didn’t interview the perpetrator, B.M., in a sexual assault case, he testified, “George Lepley asked me not to.” Id. at 71: 3-5.

George Lepley was the attorney representing B.M. Id. 16-22.

The Childline report that Weber received reported the following:
“Q. Did you get this narrative when you got the call from Matt Wood about my client, John Doe?
A. I don’t recall.
Q. Is it possible you got it?
A. Yes.
Q. Okay. If you look at the middle paragraph, I’m going to say, because it appears to be paragraphed off, in the part that begins, quote, The video depicts a child sleeping, and then has parenthesis, John Doe, end quote, do you see where I’m referring to that, sir?
A. Yes.
Q. Okay. According to this narrative that we were provided by the county it states, quote, The video depicts a child sleeping, and then has parenthesis, John Doe, close parentheses, B.M. close parentheses, place his exposed penis onto John Doe’s mouth, period. A third party was recording the video and the laughter of numerous others can be heard in the background, period. It’s not clear in the video if there was penetration or not, period, close quote.

First of all, am I reading that paragraph correctly?

A. Yes.

Id. at 92-93: 7-7.

Weber felt the need to have an attorney present when he was interviewed by Agent Scicchitano of the Attorney General’s office because he was the “target of a criminal investigation by the attorney general’s office.” Id. at 98-99: 20-9.

Weber admitted that he never reported the assault of John Doe or the video recording of it to the Myrtle Beach Police Department.

Id. at 112-113: 19-17; 114-115: 3-17.

Weber testified that he did not believe the testimony of John Doe or Jeanne Reeder but did believe the testimony of all the WASD employees. Id. at 123-125: 24-18.

Weber also testified that he believed that Pardoe took the investigation “very seriously” even though he didn’t know who he interviewed or if he interviewed anyone at all. Id. at 135-136: 2-14.

Weber didn’t even know that J.Z. was the player that took the video. Id. at 137-138:17-11.

14. Admitted. By way of further answer, David Scicchitano also recommended to the Attorney General’s Office that William Weber, Chief County Detective for Lycoming County, be arrested for Obstruction of Justice. Exh. 8 Scicchitano depo. 245: 15-20.

16. Admitted. By way of further answer, the Defendant, WASD, never returned to Myrtle Beach for a baseball trip following the 2018 Myrtle Beach baseball trip. Exh. 3 Pardoe depo. 255: 8-11.

Additional details from the voluminous REPLY TO DEFENDANT WILLIAMSPORT AREA SCHOOL DISTRICT’S STATEMENT OF MATERIAL FACTS IN SUPPORT OF THE MOTION FOR SUMMARY JUDGMENT are forthcoming.

Photos: Former disgraced Lycoming County Chief Detective and Little League World Series Team Host Willie Weber (left)

Local attorney George Lepley (right)

Q. Okay. Did you ever try or attempt to interview (PERPETRATOR – REDACTED)?

A. George Lepley asked me not to.

By Todd Bartley

TalkWilliamsport.com

NEWS@TalkWilliamsport.com

TalkWilliamsport.com obtained the deposition transcripts attached to the “Motion for Summary Judgment” filed by attorneys representing the Williamsport Area School District in the Federal Civil Rights lawsuit filed by John Doe #1.

John Doe #1 is the former WAHS baseball player who was the victim of a criminal indecent sexual assault during the 2018 WAHS baseball team trip in Myrtle Beach, South Carolina.

John Doe #1 is black the teammate who assaulted him is white.

The depositions contain previously undisclosed facts from the “investigators” employed by the Williamsport Area School District and Lycoming County.

Attorney Greg Stapp who is representing John Doe #1 was asking the questions and former disgraced Lycoming County Chief Detective and Little League World Series Team Host Willie Weber provided the answers noted below.

Page 71 of the deposition of Willie Weber in part:

Q. Okay. Did you ever try or attempt to interview (PERPETRATOR – REDACTED)?

A. George Lepley asked me not to.

Q. When did George Lepley ask you not to interview (PERPETRATOR – REDACTED)?

A. To the best of my recollection it would have been right around my interview with John Doe.

Q. Which is May 30th, 2018?

A. Yes

Q. And how did that conversation take place? Phone call? Personal meeting?

A. I don’t recall. Could have been in the courthouse. I don’t recall.

GEORGE LEPLEY STAYED AT THE ATLANTICA RESORT

Talk Williamsport recently confirmed George Lepley stayed at the Atlantica Resort in Myrtle Beach, South Carolina from March 24 – March 31, 2018.

Multiple undisputed facts in the case as previously reported by TalkWilliamsport.com, Detective Weber stated he “had no jurisdiction in the case.”

When asked directly TalkWilliamsport.com if he would be sending the video depicting the “criminal indecent sexual assault” of John Doe #1 to the Myrtle Beach Police Department?

Weber replied, “we’re not going to do that.”

As a matter of historical fact neither Weber or Pardoe ever contacted the Myrtle Beach Police Department.

From the WASD filed Motion for Summary Judgment:

137. Det. Weber came to the high school and, using his phone, showed Dr. Pardoe, Freed, and A.D. McCann the video of the incident. Exh. 10 Pardoe Depo. at 103:14-18; Exh. 13 McCann Depo. at 115:21—116:7, and 117:17-22. See also Exh. 22 (Freed’s interview notes May 24, 2018 (OAG001378)); Exh. 23 (Pardoe’s interview notes May 24, 2018 (OAG001367-001377)).

On background:

On May 24, 2018 WAHS defeated West Scranton 14-2 in the PIAA District II District semi-finals.

The perpetrator depicted on the video who was subsequently criminally charged in South Carolina played in the game on May 24, 2018 for WAHS.

Furthermore, on May 28, 2018 WAHS defeated Hazleton Area

4-3 in the PIAA District II District Final.

The perpetrator depicted on the video who was subsequently criminally charged in South Carolina received a Gold Medal after this game.

Based upon previously obtained WASD emails Dr. Pardoe communicated to WASD Superintendent Dr. Timothy Bowers on or about May 30, 2018 “the investigation has just begun.”

The request of Detective Weber by Lepley not to interview (PERPETRATOR – REDACTED) occurred May 30, 2018.

As previously reported by TalkWilliamsport.com, “The Lepley letter of May 31, 2018” was proffered.

Was the letter proffered after Lepley received an assurance from Weber he was abiding by the request?

Weber only attended the interview of John Doe #1 and his mother along with WAHS head principal Dr. Brandon Pardoe, WAHS assistant principal Dr. Roger Freed and WAHS athletic director Sean McCann on May 30, 2018.

Weber did not attend the June 5, 2018 meeting with the (PERPETRATOR – REDACTED) his parents, Attorney George Lepley, WAHS head principal Dr. Brandon Pardoe, WASD Superintendent Dr. Timothy Bowers and WASD Solicitor Fred Holland.

Freed and McCann also sat out the June 5, 2018 meeting.

From WASD emails previously obtained by TalkWilliamsport.com through multiple Right-To-Know Law requests:

Dr. Pardoe: In addition, Agent Weber contacted me yesterday to let me know that he as well has spoken to George Lepley about the incident.

A Baseball Story In The Birthplace Of Little League Baseball – PART XIX

PARDOE INFORMS DR. BOWERS AND SUSIE NEIDIG OF INVESTIGATION

WAHS Head Principal Brandon Pardoe then informs Superintendent Dr. Timothy Bowers and his secretary Susie Neidig in the evening hours of May 30, 2018 of details about the “investigation.”

Subject: FW: Meeting

Date: Wednesday, May 30, 2018 at 8:22:21 PM Eastern Daylight Time

From: Brandon Pardoe

To: Timothy Bowers

CC: Susan A. Neidig

Priority: High 

“We started the investigation with regard to the video taken on the Myrtle Beach trip after speaking with the parent and student today. I can give you more information if we could talk. I contacted the home of (redacted) who is the student that was videoed doing the act to the other student. I requested to meet with them with their son. They appear to be getting an attorney to meet as well. I would imagine that this is something that we would want to reach out to our solicitor about and update to join in a mutual meeting. I do have a recommendation for the interim until we can meet that I would like to run by you.

If we can talk tomorrow that would be great.”

Brandon Pardoe, Ed.D

Head Principal, Williamsport Area High School

2990 West Fourth Street, Williamsport, PA 17701

Phone: (redacted by author)

You know, the same Brandon Pardoe, Dr. Bowers thanked for updating him on an investigation that began May 30, 2018; 12 days after the initial Childline call was made.

The morning of June 1, 2018 Superintendent Bowers replied to Pardoe:

Date: June 1, 2018 6:42 AM

From: Timothy Bowers

To: Brandon Pardoe

Subject: Baseball

“Ok thanks for the follow-up”

Sent from my iPhone

June 1, 2018 email excerpt

Pardoe:

“I know that Fred has spoken to George regarding the matter. In addition, Agent Weber contacted me yesterday to let me know that he as well has spoken to George Lepley about the incident.

It is my understanding that both of these conversations went well.”

Previously, when pressed on similar issues in this story WASD Solicitor Fred Holland offered the following in an e-mail to those involved in the investigation he approved according to the statement offered by the district.

Subject: FW: WASD Questions

Date: Wednesday, September 5, 2018 at 3:52:21 PM Eastern Daylight Time

From: Fred Holland

To: Timothy Bowers, Brandon Pardoe, Susie Bigger

“If he (Bartley) asks again, I won’t justify it with a response…

Photos: Former disgraced Lycoming County Chief Detective and Little League World Series Team Host Willie Weber (left)

Current WASD Director of Student Services, Dr. Brandon Pardoe (right)

I also asked him (OAG Agent Scicchitano) the question,

quote, based on your investigation,

was there a criminal conspiracy between those individuals,

question mark, end quote.

His answer was in my opinion, comma, yes, period.

By Todd Bartley

TalkWilliamsport.com

NEWS@TalkWilliamsport.com

TalkWilliamsport.com obtained the deposition transcripts attached to the “Motion for Summary Judgment” filed by attorneys representing the Williamsport Area School District in the Federal Civil Rights lawsuit filed by John Doe #1.

John Doe #1 is the former WAHS baseball player who was the victim of a criminal indecent sexual assault during the 2018 WAHS baseball team trip in Myrtle Beach, South Carolina.

John Doe #1 is black the teammate who assaulted him is white.

The depositions contain previously undisclosed facts from the “investigators” employed by the Williamsport Area School District and Lycoming County.

Attorney Greg Stapp who is representing John Doe #1 was asking the questions and WASD Director of Student Services Dr. Brandon Pardoe was providing the answers.

Agent Scicchitano identified below is employed by the Office of Pennsylvania Attorney General.

At the time of the investigation in 2020 Josh Shapiro was the Pennsylvania Attorney General.

From the Deposition of Dr. Brandon Pardoe, Tuesday, May 20, 2025.

Q. In the initial deposition of Agent Scicchitano, he was asked the following question, quote, based on your investigation, did anyone employed by the Williamsport Area School District commit a crime during the handling of the investigation of the assault of John Doe in Myrtle Beach, question mark, end quote. His answer was yes.

Are you aware of that testimony?

A. No.

Q. I asked him who that was and he said Brandon Pardoe. Are you aware that he said that?

A. No.

Q. Are you aware that he recommended you be charged with obstruction of justice?

A. No.

Q. Based on — he was also asked this question, quote, based on your investigation of the individuals you just named working in concert
together, that is the end of the question, end quote. He was talking about Agent Weber and yourself. His answer was yes. Are you aware of that testimony?

A. Can you say that again?

Q. He was asked the question, quote, based on your investigation, were the individuals you just named working in concert together, question mark, end quote. His answer was yes. Those individuals were Willie Weber and yourself. Are you aware that he testified to that
effect?

A. No.

Q. Were you working in concert with Willie Weber during this investigation of this incident?

A. No.

Q. I also asked him the question, quote, based on your investigation, was there a criminal conspiracy between those individuals, question mark, end quote. His answer was in my opinion, comma, yes, period.

Are you aware that he testified to that?

A. No.

Q. Are you aware that he referred the matter to the Attorney General’s Office for charges to be filed against you and Agent Weber?

A. No.

Q. Does that surprise you that the agent that investigated this matter and spoke to you recommended that you be charged with crimes?

A. I — I don’t know how to answer that question. How do I — I’m not sure how to answer it. I wasn’t charged. So…

Q. Do you believe that if a person is not charged with a crime, that means that a crime did not occur?

A. I think crimes can occur without being charged with a crime, yes.

On Background:

PHOTOS: Williamsport Councilwoman Liz Miele (left)

Attorney General David Sunday (right)

STAFF REPORTS

TalkWilliamsport.com

An Affiant plans to file a Private Criminal Complaint against current Williamsport Councilwoman Liz Miele with the Office of Lycoming County District Attorney for Dereliction of Duty.

The Affiant filing the PCC will be asking the case to be referred to the Office of Attorney General David Sunday for investigation and potential prosecution.

On background, the PCC is based on her public statements regarding the financial status of the City of Williamsport; referring to them as “the lost years” while she served as the finance committee chairperson as well as her skipping the vote on the authorization of repaying the FTA funds.

Miele recently announced her intention to see reelection to Williamsport City Council.

This is a developing story on TalkWilliamsport.com.

Photo: Current Lycoming County Common Pleas Court Judge Eric Linhardt

STAFF REPORTS TALKWILLIAMSPORT.COM

On Wednesday morning current Lycoming County Common Pleas Court Judge Eric Linhardt issued a Scheduling Order for an “argument” based on the “MOTION TO RECUSE” filed last week by the attorney representing Todd Bartley, his family and a company involved in the case.

The filing is listed in its entirety and linked below.

In short, the Motion to Recuse is based upon as noted in #8 of the MTR, “Since Judge Linhardt will be listed as a fact witness by the Plaintiff in the federal case, he may not preside over the above-captioned case as the underlying reason that the Defendant tortiously interfered with contracts was the facts involved in the case currently pending before the federal court.”

In the filing as noted in #6, Linhardt when District Attorney hired now disgraced former Lycoming County Chief Detective Willie Weber.

“Judge Lindhart hired William Weber as a Lycoming County Detective and was his direct supervisor during a part of the time Weber was employed by Lycoming County. Plaintiffs believe and therefore aver that during Judge Linhardt’s tenure as Lycoming County District Attorney the policies and procedures that were in place as to how to investigate sexual assault cases involving minors were removed. As Chief County Detective, William Weber, was in a position to interfere and to bury the investigation of the sexual assault of a minor during the Williamsport Area High School baseball trip to Myrtle Beach in 2018 which came to light as a direct result of the reporting done by Plaintiff Todd Bartley.”

Linhardt has previously overseen a pair of cases involving the Plaintiff; not without strenuous objection to his involvement in those cases.

The MTR concludes with #13; “Further, Judge Linhardt’s role as a witness in the underlying federal lawsuit and the fact that his actions during his tenure as Lycoming County District Attorney may result in the refiling of a federal lawsuit against Lycoming County puts the entire Lycoming County Court of Common Pleas in a situation in which, at the very least, appear to undermine the integrity of a fair and impartial handling of this matter by the Lycoming County judiciary.”

The filing does not address the phone call received by one of the Plaintiffs from a campaign donor of Linhardt requesting information about “his (Linhardt) involvement in the 2018 Myrtle Beach case”.

On background, the campaign donor has employed the father of the WAHS baseball player who was criminally charged by South Carolina authorities after the botched investigation by Willie Weber and former WAHS head principal Dr. Brandon Pardoe.

The moving Plaintiff in this case is also aware of a letter previously sent by an attorney on behalf of Defendant Dixon to then District Attorney Linhardt threatening legal action after Chief County Detective, William Weber used a “racial slur” in a meeting when referring to Dixon.

On background, as a result of the letter, Linhardt while District Attorney removed Weber from any investigations or pending cases involving Dixon.

After the publication of this story, it is anticipated President Judge Nancy L. Butts will issue a full bench recusal of all Lycoming County Judges from this case as she did in the “Petition to Remove Tom Marino from the Primary Election Ballot” case filed by the Plaintiff in this matter.

Butts has her only conflict of interest in the Webb/Dixon case having previously found Dixon guilty in another case and accepting a plea deal that saw him sentenced in a three-week window when the constitutionality of Megan’s Law was being argued before the Pennsylvania Supreme Court.

This is a developing story on TalkWilliasmport.com.

TODD BARTLEY and MICHELLE
BARTLEY, husband and wife, JOHN
DOE AND JANE DOE, AND
COLONIAL RADIO GROUP OF
WILLIAMSPORT, LLC
Plaintiffs,
v.
JAMES A. WEBB, JR., MORGAN
AIR, INC., WEBB WEEKLY, AND
DARRICK DIXON,
Defendants.
:
:
:
:
DOCKET NO. CV 23-01364
CIVIL ACTION – LAW
JURY TRIAL DEMAND
MOTION TO RECUSE

AND NOW, comes Plaintiffs, Todd Bartley, Michelle Bartley, John Doe, Jane Doe, and Colonial Radio Group of Williamsport, LLC by and through their counsel, Gregory A. Stapp, Esquire and moves this Honorable Court to recuse itself as follows:

1. The Plaintiffs, Todd Bartley, Michelle Bartley, John Doe and Jane Doe filed an Amended Complaint on July 29, 2024. Defendants James A. Webb, Jr., Webb, Webb Weekly and Morgan Air, Inc. filed Preliminary Objections on August 12, 2024. Defendant Darrick Dixon filed Preliminary Objections on August 19, 2024. Judge Eric Linhardt issued a Scheduling Order requiring Plaintiffs to respond to Defendants James A. Webb, Jr., Webb and Morgan Air Inc., d/b/a Webb Weekly’s Preliminary Objections not later than September 1, 2024 (20 days from the issuing of August 20, 2024), and to respond to Defendant Dixon’s Preliminary Objections not later than September 9, 2024 (20 days from the issuing of August 20, 2024). Judge Eric Linhardt ordered arguments on all Defendants’ Preliminary Objections for September 20, 2024.

2. Plaintiff Todd Bartley is a journalist who wrote a series of articles related to a sexual assault of a minor during a trip to Myrtle Beach by the Williamsport Area High School baseball team in March 2018. As part of those articles, allegations of impropriety were made related to Lycoming County and its agents, servants, or employees.

3. A lawsuit was filed in federal court related to the incident and subsequent cover-up of the Williamsport Area High School baseball trip to Myrtle Beach in which Lycoming County, William Weber, in his individual and official capacity Williamsport Area School District, Dr. Brandon Pardoe, Roger Freed, Sean McCann, Ryan Miller, Fred A. Holland, Esq., and John and Jane Does were named as Defendants. (See Middle District of Pennsylvania Docket No. 4:22-cv1387).

4. Although Lycoming County and the individual Defendants were eventually dismissed, it is possible that the Plaintiffs will be refiling against Lycoming County as a result of information obtained as part of the discovery process in the federal lawsuit. However, even without refiling against Lycoming County, the Plaintiffs believe and so aver, that Judge Eric Linhardt will be a witness in the federal case because the Office of Attorney General Agent David Scicchitano testified that the reason that William Weber was not charged with crimes was because the Lycoming County Office of District Attorney did not have policies and procedures in place as to how to handle sexual abuse cases involving minors.

5. Prior to Judge Eric Linhardt’s tenure as Lycoming County District Attorney, the Lycoming County Office of District Attorney did have policies and procedures in place as to how to investigate sexual assault cases involving minors.

6. Judge Lindhart hired William Weber as a Lycoming County Detective and was his direct supervisor during a part of the time Weber was employed by Lycoming County. Plaintiffs believe and therefore aver that during Judge Linhardt’s tenure as Lycoming County District Attorney the policies and procedures that were in place as to how to investigate sexual assault cases involving minors were removed. As Chief County Detective, William Weber, was in a position to interfere and to bury the investigation of the sexual assault of a minor during the Williamsport Area High School baseball trip to Myrtle Beach in 2018 which came to light as a direct result of the reporting done by Plaintiff Todd Bartley.

7. William Weber is a key witness in the case currently before the federal court. As such, it is clear that Judge Linhardt will most likely be listed as a fact witness for the trial of this case.

8. Since Judge Linhardt will be listed as a fact witness by the Plaintiff in the federal case, he may not preside over the above-captioned case as the underlying reason that the Defendant tortiously interfered with contracts was the facts involved in the case currently pending before the federal court.

9. The party seeking to have a judge recused or disqualified is required to raise the objection at the earliest possible moment or the party will suffer the consequences of being time barred. Lomas v. Kravitz, 130 A.3d 107, 120 (Pa. Super. 2015), quoting In re Lokuta, 608 Pa. 223, 11 A.3d 437 (2011).

10. The Preliminary Objections filed by all Defendants is the earliest possible moment in this case.

11. The party that asserts that a trial judge must be disqualified must produce evidence that bias, prejudice or unfairness which raises a substantial doubt as to the judge’s ability to preside impartially. Arnold v. Arnold, 847 A.2d 674, 680 (Pa. Super. 2004). Even if the judge decides that he can be impartial, he must then decide whether his continued involvement in a case creates an appearance of impropriety and/or would tend to undermine the public confidence in the judiciary. Lomas v. Kravitz, 130 A.3d 107, 120 (Pa. Super. 2015).

12. In this case, it is clear that Judge Linhardt must not preside over this case as he is a witness in a case which came to light as a result of reporting done by Plaintiff Todd Bartley. The subsequent investigation and filing of the lawsuit involves decisions made by Judge Linhardt while he was Lycoming County District Attorney and an individual under his direct supervision.

13. Further, Judge Linhardt’s role as a witness in the underlying federal lawsuit and the fact that his actions during his tenure as Lycoming County District Attorney may result in the refiling of a federal lawsuit against Lycoming County puts the entire Lycoming County Court of Common Pleas in a situation in which, at the very least, appear to undermine the integrity of a fair and impartial handling of this matter by the Lycoming County judiciary.

WHEREFORE, Plaintiffs request this Honorable Court to recuse itself from this matter and that the Honorable President Judge Nancy L. Butts request that AOPC assign a judge from outside of Lycoming County to preside over this matter.

Respectfully submitted,
STAPP LAW, LLC
Gregory A. Stapp, Esquire
Counsel for Plaintiffs
Attorney I.D. #78247
153 W. 4th Street, Suite 6
Williamsport, PA 17701
Tel. (570) 326-1077
gstapp@stapplaw.net

TODD BARTLEY and MICHELLEBARTLEY, husband and wife, JOHN DOE AND JANE DOE, AND
COLONIAL RADIO GROUP OF WILLIAMSPORT, LLC
Plaintiffs,
v.
JAMES A. WEBB, JR., MORGAN AIR, INC., WEBB WEEKLY, AND DARRICK DIXON,
Defendants.
:
:
:
:
DOCKET NO. CV 23-01364
CIVIL ACTION – LAW
JURY TRIAL DEMAND
CERTIFICATE OF COMPLIANCE

I certify that this filing complies with the provisions of the Public Access Policy of the
Unified Judicial System of Pennsylvania: Case Records of the Appellate and Trial Courts that
require filing confidential information and documents differently than non-confidential
information and documents.
Signature: ___________________________________
Gregory A. Stapp, Esquire
Attorney No.: 78247

TODD BARTLEY and MICHELLE
BARTLEY, husband and wife, JOHN
DOE AND JANE DOE, AND
COLONIAL RADIO GROUP OF
WILLIAMSPORT, LLC
Plaintiffs,
v.
JAMES A. WEBB, JR., MORGAN
AIR, INC., WEBB WEEKLY, AND
DARRICK DIXON,
Defendants.
:
:
:
:
:
:
:
:
:
:
:
:
DOCKET NO. CV 23-01364
CIVIL ACTION – LAW
JURY TRIAL DEMAND
CERTIFICATE OF SERVICE
I, Gregory A. Stapp, Esquire, hereby certify that a true and correct copy of the foregoing Plaintiffs’ Motion to Recuse was served upon the following parties via email and Lycoming County Courthouse

Mail:
David Wilk, Esquire Christian Lovecchio, Esquire
Blake C. Marks, Esquire 520 West Fourth Street
140 East Third Street Williamsport, PA 17701
Williamsport, PA 17701 (570) 323-3772
(570) 323-3768 christianlovecchioesq@gmail.com
davew@lepleylaw.com
blakem@lepleylaw.com
STAPP LAW, LLC
Dated:
Gregory A. Stapp, Esquire
Attorney for Plaintiff

STAFF REPORTS

TALKWILLIAMSPORT.COM

A civil lawsuit was filed today in Lycoming County Court of Common Pleas by local journalist Todd Bartley against James Webb, Jr., Webb Weekly and Darrick Dixon.

The allegations in the complaint allege a years long “campaign” against Bartley, his wife, his children, his business relationships and standing in the community.

Much of the complaint is based on a fake social media profile and the countless repeated harassing, inappropriate and indecent images sent to and posted regarding the Plaintiffs.

From the Complaint:

10. “In the summer months of 2018, Plaintiff Todd Bartley, an investigative reporter/blogger,

began reporting on an incident involving the sexual assault of a minor

while the minor was on a trip to Myrtle Beach, South Carolina in March 2018,

as a member of the Williamsport Area High School Baseball Team.

Following his investigation into the sexual assault of a minor in Myrtle Beach, South Carolina

and the investigation by Williamsport Area School District officials,

Plaintiff began to publish articles outlining the events of the baseball team trip

and how the events were being handled by the Williamsport Area School District

and Lycoming County officials.

11. Following the publishing of the articles by Plaintiff Todd Bartley,

Plaintiffs began receiving threats of violence and

other harassing behavior such as receiving threats via social media platforms,

vandalism to their home and vehicles,

including but not limited to, flattened tires,

a brick being thrown through the window of a business vehicle

and arson to a personal vehicle.”

“22. Based upon the investigation performed by the

Sheriff’s Office of Frederick County, Virgina,

it is believed and therefore averred that the synthetic profile was owned by

and utilized by Defendant Darrick Dixon.

23. The synthetic profile is owned by a business duly licensed and organized in the

Commonwealth of Pennsylvania doing business as “Hoopers Only TV.”

24. At all times relevant hereto,

Darrick Dixon was an employee of James Webb, Jr. at his business Webb Weekly.”

On background, Hoopers Only TV was granted unfettered access to Lycoming County High School athletic facilities to broadcast sporting events over the past several years.

Plaintiffs are seeking a jury trial as well as financial damages and attorney fees.

Editor’s Note: The addresses of the parties and any reference to said addresses has been REDCATED.

The filing is listed in full below.

TODD BARTLEY and MICHELLE
BARTLEY, husband and wife, JOHN
DOE AND JANE DOE, AND
COLONIAL RADIO GROUP OF
WILLIAMSPORT, LLC
Plaintiffs,
v.
JAMES A. WEBB, JR., WEBB
WEEKLY, AND DARRICK DIXON,
Defendants.

DOCKET NO.
CIVIL ACTION – LAW
JURY TRIAL DEMAND
:

COMPLAINT

AND NOW, comes Plaintiffs, Todd Bartley, Michelle Bartley, John Doe, Jane Doe, and Colonial Radio Group of Williamsport, LLC by and through their counsel, Gregory A. Stapp, Esquire and complains against Defendants, James A. Webb, Jr., Webb Weekly and Darrick Dixon as follows:

1. The Plaintiffs, Todd Bartley is an adult individual residing at REDACTED, Williamsport, Lycoming County, Pennsylvania 17701.

2. The Plaintiffs, Michelle Bartley is an adult individual residing at REDACTED, Williamsport, Lycoming County, Pennsylvania 17701.

3. The Plaintiffs, John Doe was a minor individual residing at REDACTED, Williamsport, Lycoming County, Pennsylvania 17701 at the time of the incident complained of in this Complaint.

4. The Plaintiffs, Jane Doe was a minor individual residing at REDACTED, Williamsport, Lycoming County, Pennsylvania 17701 at the time of the incident complained of in this Complaint.

5. The Plaintiffs, Colonial Radio Group of Williamsport, LLC was a business duly organized and operating under the laws of the Commonwealth of Pennsylvania with a principal address REDACTED, Williamsport, Lycoming County, Pennsylvania 17701 at the time of the incident.

6. The Defendant, James A. Webb, Jr., is an adult individual residing at REDACTED, Montoursville, Lycoming County, Pennsylvania.

7. The Defendant Webb Weekly, is a business duly organized and operating under the laws of the Commonwealth of Pennsylvania with a principal address at REDACTED, South Williamsport, Lycoming County, Pennsylvania.

8. The Defendant, Darrick Dixon, is an adult individual residing at REDACTED, Harrisburg, Dauphin County, Pennsylvania.

9. At all times relevant hereto Todd Bartley was owner and operator of Colonial Radio Group of Williamsport, LLC.

10. In the summer months of 2018, Plaintiff Todd Bartley, an investigative reporter/blogger, began reporting on an incident involving the sexual assault of a minor while the minor was on a trip to Myrtle Beach, South Carolina in March 2018, as a member of the Williamsport Area High School Baseball Team. Following his investigation into the sexual assault of a minor in Myrtle Beach, South Carolina and the investigation by Williamsport Area School District officials, Plaintiff began to publish articles outlining the events of the baseball team trip and how the events were being handled by the Williamsport Area School District and Lycoming County officials.

11. Following the publishing of the articles by Plaintiff Todd Bartley, Plaintiffs began receiving threats of violence and other harassing behavior such as receiving threats via social media platforms, vandalism to their home and vehicles, including but not limited to, flattened tires, a brick being thrown through the window of a business vehicle and arson to a personal vehicle.

12. As Plaintiff Todd Bartley began to publish articles about the handling of the assault of the minor child while on a school trip with the Williamsport High School baseball team, he discovered that Defendant Webb was going to several advertisers with Colonial Radio Group of Williamsport, LLC and spreading false and defamatory statements about Plaintiff Todd Bartley and his reporting on the assault.

13. Plaintiffs believe, and therefore aver, that Defendant Webb also told several advertisers with Colonial Radio Group of Williamsport, LLC that they should stop advertising with Colonial Radio Group because of Plaintiff Todd Bartley’s reporting on the assault.

14. On or about July 01, 2022, Plaintiff Todd Bartley contacted the Sheriff’s Department of Frederick County, Virginia, regarding threats he was receiving via social media platforms while in Frederick County, Virginia for his job. Sheriff Lenny Milholland assigned Investigator Brandon Hazelwood of Frederick County Sheriff’s Office Criminal Investigative Division to investigate the threats.

15. Investigator Hazelwood was provided a plethora of screenshots of direct messages by Plaintiff Todd Bartley that had been sent to his personal social media page and his business social media page from an obviously synthetic identity as well as public posts on his business and personal pages, specifically https://www.facebook.com/talkwilliamsport and https://www.facebook.com/todd.bartley.9. For example, “If He dies…you die.” Which was received by Plaintiff Todd Bartley in December 2021.

16. The focus of the investigation by Frederick County Sheriff’s Office the was on a message dated June 29, 2022, where Meta Profile |talkwilliamsport| was in receipt of “Tick Tick Boom” from Meta Profile https://www.facebook.com/CharlieBrown00. This in and of itself is vague and open ended; however, the circumstances of this “threat” that are credible are as follows:

a. As outlined in Pennsylvania State Police Report REDACTED titled “Arson Vehicle” dated August 18, 2020, was provided to Investigator Hazelwood through Frederick County Crime Analyst Gattshall.

b. Within this report it is reported by responding Troopers and Investigators that suspects were developed in this case and data was captured detailing the “bombing” of Bartley’s car by use of “accelerant” intentionally while it was parked in his driveway of his home causing four fire companies to respond to extinguish the flames. As a result of this “bombing”, the car was considered a total loss and was investigated as an intentional and deliberate Arson.

c. Leads in this arson case were developed and suspects were identified by Pennsylvania authorities and this case was presented for prosecution.

d. The reported “reason” for this intentional “bombing” of Bartley’s car is explained to have stemmed from a Radio broadcast and social media publications from 2018 of a series of stories outlining Bartley’s views of Myrtle Beach’s Police fallacies and Pennsylvania’s prosecutorial mistakes made during the investigation, involving a sexual assault that took place in Myrtle Beach South Carolina that involved students on the Williamsport High School baseball team.

17. Due to this reporting, “trolling” of Plaintiff Todd Bartley’s social media sites was expected by Todd Bartley; however, messages were delivered to him on his business Meta Site and his personal profile page that contained lewd, lascivious, and provocative language whereas a handful of messages were interpreted as circumstantial threats by Investigator Hazelwood.

These threats are as follows:

a. In a majority of the messages that were received through Bartley’s business page since the 2018 reporting and the 2020 car bombing incident, statements are made such as: “if you don’t write back I guess you want us to keep going,” “ok I am about to go on one of the schools pages and unload you don’t want to reply I will delete whatever I’m about to put up all you have to do is
reply to me,” “reply! It’s going to get worse,” “say something,” “or we keep going just like you do our Mayor,” “ok Todd,” “Watch the movie American gangster listen to what Denzel says after the saying that happened to you already listen to what he says. That’s your clue. Since you like to use movies as references. I want to be just like you tired so I’m learning from you,” “now you
throw a jab at Gary Brown again! You are going to pay for all of this Todd Bartley,” “go to his house REDACTED [Bartley residence] and have a conversation.” (In the social media and social engineering circles, this element of publicly posting a subject’s address is known as “doxing.” The sender of this message repeats this tactic several times throughout these message
threads where the synthetic identity posts Bartley’s home address enticing the public to respond to Bartley’s home with ill intentions.

b. These messages are repetitive, with the intent to coerce, intimidate and harass Bartley using indecent language and images whereas the venue of these messages are in both Pennsylvania and Frederick County Virginia. However, these messages are the circumstantial building blocks of the criminal investigation which were utilized by the Frederick County Sheriff to establish probable cause and show a pattern of ramping up “the campaign” using their words as posted by the synthetic identity and the connection with the car bombing that occurred in Pennsylvania in August of 2020.

18. The messenger message received by Bartley to his personal profile page June 29, 2022 while Bartley was present in Frederick County Virginia. This thread is as follows: “look at your cameras from today if they work lol between 9pm -11pm I drove,” “I am closer to you than you know lol [cry/laughing emoji] it’s so funny you can’t figure out who I am,” “doubt your cameras work,” “if they did you would of caught the [lit bomb emoji],” “that’s right you got the cameras after the [explosion emoji],” “lol.”

19. The synthetic profile continued to launch the “campaign” against Bartley stating the following: “Todd I’m giving up soon! This is like a movie I want to get caught so I’m gonna give you tips you are smart with trying to be a detective. I gave you enough clues. And I drove by your house and I gave you the timeframe you have to figure this out soon before it’s too late,” “One more clue?” “I was in there at the last board meeting you went too for Williamsport,” “I was there for 15min,” “[alarm clock emoji] tick Tock night,” “saw. (Line 6 of subsection is followed by screenshots of the Horror thriller movie “Saw” [whereas as victim’s are tricked and or abducted and placed in locked rooms with decisions to kill/maim or disfigure themselves or others in order to save their own lives], “you like movies [popcorn emoji], “ha lol [cry laugh emoji] love this movie,” “we can watch it together Todd,” “let’s play a game” (This line of “let’s play a game is what the main character uses to threaten and intimidate the participants in the movie right before the element of death is provided to the participant in the challenge.)

20. Investigator Hazelwood interpreted these various threats as Plaintiff Todd Bartley now being provided the forethought that this could happen to him or his family, whereas Bartley has provided that he is afraid that this synthetic identity is being managed by several people and could follow through with a threat such as this or cause another car bombing at his home.

21. Additional messages were sent to Plaintiff Todd Bartley related to a reporting of a crash that occurred in Pennsylvania that Todd Bartley reported on, the synthetic profile replies to a commenter on his profile “this is what he does he is not a human being we need to get rid of him and his comrades.”

22. Based upon the investigation performed by the Sheriff’s Office of Frederick County, Virgina, it is believed and therefore averred that the synthetic profile was owned by and utilized by Defendant Darrick Dixon.

23. The synthetic profile is owned by a business duly licensed and organized in the Commonwealth of Pennsylvania doing business as “Hoopers Only TV.”

24. At all times relevant hereto, Darrick Dixon was an employee of James Webb, Jr. at his business Webb Weekly.

COUNT I

TORTIOUS INTERFERENCE

WITH A CONTRACTUAL RELATIONSHIP

(Plaintiffs v. All Defendants)

25. Plaintiffs hereby incorporate the preceding paragraphs by reference as if set forth fully herein.

26. The law has long recognized that the wrongful inducing of a breach of contract or the encouragement of one not to enter into a contract or business relationship with another is an actionable tort. The Restatement of Torts, § 766 (1939). The Restatement described this tort as follows: “one who, without a privilege to do so, induces or otherwise purposely causes a third person not to (a) perform a contract with another, or (b) enter into or continue a business relation with another is liable to the other for the harm caused thereby. Id. The courts have identified two separate instances in which there may have been an alleged interference. One with an existing contract right and another in which the interference charged with affecting prospective contractual relations. See Glenn v. Point Park College, 441 Pa. 474, 272 A.2d 895 (1971).

27. In the present case, the Defendants participated in a civil conspiracy to interfere with Plaintiffs’ existing contract with advertisers and with prospective contractual relations as well.

28. Plaintiff believes, and therefore avers, that Defendant Webb and Defendant Dixon approached existing advertisers of Colonial Radio Group, LLC and discouraged them from continuing to advertise with Colonial Radio Group, LLC because Defendant Webb and Defendant Dixon were upset that Plaintiff Bartley (primary shareholder of Plaintiff Colonial Radio Group of Williamsport, LLC) was continuing to report, publish and to pursue his investigation related to the Williamsport High School Baseball Team and the Williamsport Area School District’s handling of the 2018 Myrtle Beach incident.

29. The necessary elements of cause of action for intentional tortious interference with existing contractual relationships are: (1) the existence of a contractual relationship between the complainant and a third party; (2) an intent on the part of the defendant to harm the Plaintiffs by interfering with that contractual relationship; (3) the absence of or justification on the part of the defendant; and (4) the occasioning of actual damages as a result of defendant’s conduct. See Walnut Street Associates v. Brokerage Concepts, Inc., 982 A.2d 94 (Pa.Super. 2009) and Restatement (Second) of Torts, § 766.

30. Defendants intended to harm the Plaintiffs by interfering with the contractual relationship between Plaintiffs and its current advertisers as well as potential advertisers.

31. The Defendants were without any privilege or justification to act as they did.

32. Due to the Defendants’ behavior, Plaintiff Bartley and Colonial Radio Group of Williamsport, LLC has lost reputation in its industry and may continue to lose reputation in its industry. Plaintiffs believe and therefore aver that Plaintiffs have lost business and/or customers as a result of the Defendant’s behavior resulting in pecuniary loss and may lose prospective customers in the future causing additional pecuniary losses.

WHEREFORE, Plaintiffs pray this Honorable Court Orders the following:

a. Award damages in the form of lost earnings for advertisers lost as a result of the actions of Defendants;

b. Award damages in the form of lost earnings for future prospective customers of Plaintiffs that were interfered with as a result of the actions of Defendants;

c. Award punitive damages; and

d. Order Defendants to pay Plaintiffs attorney’s fees and costs; and such other relief that this Honorable Court deems just and appropriate under the circumstances.

COURT II

TORTIOUS INTERFERENCE WITH A

PROSPECTIVE CONTRACTUAL RELATIONSHIP

(Plaintiffs v. All Defendants)

33. Plaintiffs hereby incorporate the preceding paragraphs by reference as if set forth fully herein.

34. In Glenn v. Point Park College, supra, we established that four elements must appear in a complaint in order for the Plaintiffs to state a cause of action for intentional interference with prospective contractual relations:

(1) a prospective contractual relation;

(2) the purpose or intent to harm the Plaintiffs by preventing the relation from occurring;

(3) the absence of privilege or justification on the part of the defendant; and

(4) the occasioning of actual damage resulting from the defendant’s conduct.

35. The Defendants actions as identified above interfered with prospective advertisers of Plaintiff Colonial Radio Group of Williamsport, LLC in that the Defendants approached business owners and discouraged them from purchasing advertising with Plaintiff Colonial Radio Group of Williamsport, LLC because the Defendants were upset over the reporting and investigation being conducted by Plaintiff Todd Bartley related to the Williamsport High School Baseball Team and the Williamsport Area School District’s handling of the 2018 Myrtle Beach incident.

36. Plaintiffs believes, and therefore avers, that potential advertisers were approached and influenced by the Defendants not to advertise with Plaintiff Colonial Radio Group of Williamsport, LLC.

37. Defendants intended to harm the Plaintiffs by interfering with prospective contractual relationships between Plaintiffs and potential advertisers.

38. The Defendants were without any privilege or justification to act as they did.

39. Due to the Defendants’ behavior, Plaintiff Bartley and Colonial Radio Group of Williamsport, LLC has lost reputation in its industry and may continue to lose reputation in its industry. Plaintiffs believe, and therefore aver that Plaintiffs have lost business and/or customers as a result of the Defendants’ behavior resulting in pecuniary loss and may lose prospective advertisers in the future causing additional pecuniary losses.

WHEREFORE, Plaintiffs pray this Honorable Court Orders the following:

a. Award damages in the form of lost earnings for advertisers lost as a result of the actions of Defendants;

b. Award damages in the form of lost earnings for future prospective advertisers of Plaintiffs that were interfered with as a result of the actions of Defendants;

c. Award punitive damages; and

d. Order Defendants to pay Plaintiffs attorney’s fees and costs; and such other relief that this Honorable Court deems just and appropriate under the circumstances.

COUNT III

VICARIOUS LIABILITY

(All Plaintiffs v. James A. Webb, Jr. and Webb Weekly)

40. Plaintiffs hereby incorporate the preceding paragraphs by reference as if set forth fully herein.

41. Darrick Dixon. was an agent, servant or employee of James A. Webb, Jr. and Webb Weekly are vicariously liable for the actions of their agents, servants or employees.

42. Defendant Darrick Dixon was the apparent agent of Defendant James A. Webb, Jr. and Webb Weekly, which through their actions and conduct or failure to act, held out Defendant Darrick Dixon as their agent, servant, or employee.

43. On information and belief, at all times relevant hereto, Defendant Darrick Dixon was acting within the scope of his employment as agent, servant, or employee of Defendant James A. Webb, Jr. and Webb Weekly.

44. Defendant James A. Webb, Jr. and Webb Weekly are vicariously liable for the commissions and omissions of Defendant Darrick Dixon who is an agent, servant, or employee of theirs or who is apparently held out as such.

45. As a direct and proximate result of the actions of Defendant Dixon and James A. Webb, Jr. and/or other agents, servants or employees, Plaintiffs has suffered and will suffer the loss of advertisers and potential advertisers.

WHEREFORE, Plaintiffs pray this Honorable Court Orders the following:

a. Award damages in the form of lost earnings for advertisers lost by Colonial Radio Group of Williamsport, LLC as a result of the actions of Defendants;

b. Award damages in the form of lost earnings for future prospective customers of Plaintiffs that were interfered with as a result of the actions of Defendants;

c. Award punitive damages; and

d. Order Defendants to pay Plaintiffs’ attorney’s fees and costs; and such other relief that this Honorable Court deems just and appropriate under the circumstances.

WHEREFORE, Plaintiffs demand judgment against Defendant in excess of $50,000.00 with costs and interest, including punitive damages.

COUNT IV

NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

(All Plaintiffs v. Defendant Darrick Dixon)

46. Plaintiffs incorporates herein by reference the preceding paragraphs of this Complaint the same as if fully set forth hereinafter.

47. Defendant Darrick Dixon by and through his contact with Plaintiffs, as described above, negligently and/or recklessly committed multiple acts of extreme and outrageous conduct which caused severe emotional, psychological, and psychiatric injuries, distress, and harm to Plaintiffs, as set forth above in an extreme, outrageous, and harmful manner.

WHEREFORE, Plaintiffs demands judgment against Defendant Darrick Dixon in a sum in excess of Fifty Thousand ($50,000.00) Dollars, and in excess of the prevailing arbitration limits, in compensatory damages and punitive damages, exclusive of pre-judgment interest, post judgment interests and costs.

COUNT V

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

(All Plaintiffs v. Defendant Darrick Dixon)

48. Plaintiffs incorporates herein by reference the preceding paragraphs of this Complaint the same as if fully set forth hereinafter.

49. Defendant Darrick Dixon engaged in the aforementioned conduct, which would constitute violations of Pennsylvania criminal statutes prohibiting Harassment (18 Pa.C.S. § 2709), and/or Disorderly Conduct (18 Pa.C.S. § 5503), and/or Criminal Trespass (18 Pa.C.S. § 3503), and/or Arson (18 Pa.C.S. § 3301), and/or Criminal Mischief (18 Pa.C.S. § 3304).

50. Defendant Darrick Dixon by and through hiscontact with Plaintiffs, as described above, committed intentional and willful misconduct.

51. Defendant Darrick Dixon by and through his contact with Plaintiffs, as described above, acted with actual malice towards Plaintiffs.

52. Defendant Darrick Dixon by and through his contact with Plaintiffs, as described above, intentionally committed multiple acts of extreme and outrageous conduct which caused severe emotional, psychological, and psychiatric injuries, distress, and harm to Plaintiffs, as set forth above, in an extreme, outrageous and harmful manner.

WHEREFORE, Plaintiffs demands judgment against Defendant Darrick Dixon in a sum in excess of Fifty Thousand ($50,000.00) Dollars, and in excess of the prevailing arbitration limits, in compensatory damages and punitive damages, exclusive of pre-judgment interest, post judgment interests and costs.

Respectfully submitted,
STAPP LAW, LLC

Gregory A. Stapp, Esquire
Attorney I.D. #78247
153 W. 4th Street, Suite 6
Williamsport, PA 17701
Tel. (570) 326-1077
Counsel for Plaintiffs

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