Exh Emails 2021 Feb 22 Thru 27 Sunseri Sham Injunction Etc Redact BN

From: uvoneck@outlook.
com
Subject: FW: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court, Unfair Trade Practices
Consumer Protection Law, Fraud, etc. 3 of several
Date: Wednesday, February 24, 2021 2:09:42 PM
Attachments: Art Goldberg LinkedIn profile on 2020-12-14 19.36.52.pdf
image001.png
Arthur-Goldberg - BELLROCK viewed 02.23.2021.pdf
Revised highlight ESA FORM IH DIAND AND BOB JULY 2018.Recieved.12.13, 2020 email.docx
Arthur-Goldberg - BELLROCK viewed 02.23.2021.pdf
Cover Letter for Package REVISED 7-24-2020.pdf
image002.png
Uta von Eckartsberg, Esq.

412.207.7742(ph)
301.461.7445 ©
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From: Uta von Eckartsberg

Sent: Tuesday, February 23, 2021 6:19 PM
To: 'Arthur Goldberg' <artgoldberg@verizon.net>; 'Fred Jug' <fjug@bmr-law.com>; 'Robert
Bernstein' <robert.s.bernstein@gmail.com>; 'Deb Knox' <deb@knox412.com>
Cc: lizhrenda@comcast.net; shandel.gilbert@verizon.net; sylvholland@aol.com;
stlrfanpgh@aol.com; pj92926@gmail.com; shirleykmeyers@msn.com; ethelweikers1@gmail.com;
frisch@duq.edu; bloberant@yahoo.com; rgrif@cmu.com; nloberant@yahoo.com;
stephen.tirone@gmail.com; antis1209@comcast.net; 1 neil.cosgrove@verizon.net;
roblschwartz@aol.com; reiko.becker@gmail.com; dandee26@verizon.com;
mjmckenna42@hotmail.com; maxifish1@aol.com; bunkerc@pitt.edu; william.lindgren@sru.edu;
joeldon@aol.com; danehower@gmail.com; vicky.humphrey23@gmail.com; reneeramo@gmail.com;
johnstonann@att.net; wjjohnston@firstcommand.com; patmiles1@aol.com; nanwm@verizon.net;
jbaccordion@gmail.com; smithkmt@gmail.com; bonnie17961@gmail.com; amq02@comcast.net;
rmolyneauxrmx@gmail.com; sheilaryannp@aol.com; eiko.becker@gmail.com; ritzec@comcast.net;
shirleykmeyers@msn.com; pj92926@gmail.com; hwerstil@aol.com; lew@andrew.cmu.edu;
hellman@pitt.edu; amq02@comcast.net
Subject: RE: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court, Unfair Trade
Practices Consumer Protection Law, Fraud, etc. 3 of several
So the person is the attached is not you? If not, then I guess you owe me a big thank you because
you are a victim of identity fraud. And that criminal imposter is using your name to flip units in the
building as well. If that is the case, then you should be thanking me because you need to report the
person to the FBI immediately because that imposter has flipped at three units in the building using
your identity – including Units Unit 1009 (Bellrock), 815 and 807! The unit owner that you
EvE_000200
charged thousands of dollars for contracting violations….. . I mean look at how many deeds and
mortgages this person took out in your name together with others of course. I’ll send you all the
securities forms next so you could protect yourself from people like me who get it wrong. Definitely
let me know because I still have a few friends at the FBI. And Bernstein, didn’t forget you. Sorry
but you have no plausible deniability on the systemic violations of the FHA and Pennsylvania’s
Human Rights Act.
.
EvE_000201
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.
From: Arthur Goldberg <artgoldberg@verizon.net>

To: 'Uta von Eckartsberg' <uvoneck@outlook.com>; 'Fred Jug' <fjug@bmr-law.com>; 'Robert
Ms. von Eckartsberg - You made the decision to spread false information to our neighbors without
verifying that the Arthur Goldberg you were referring to was not me. I have never been in the
securities business and you have accused me without attempting to verify that fact. This person was
not me and you smeared my good name with our neighbors. I am demanding that you immediately
retract these false claims to all those who received your email.
You also fail to admit that you were given numerous opportunities to work with the Association, as
the governing documents require, and this failure is established by the emails attached to the motion
pending in court. You ignored numerous requests from me and the Association attorney to meet in
person or even via email to resolve this without forcing us to go to court.
You have still not arranged for access into your unit which could have avoided the court action from
being necessary and have accused me and the Association’s Attorney of improper conduct which is
not based on the facts or the law. Again, you must cease and desist from this activity.
From: Uta von Eckartsberg <uvoneck@outlook.com>

EvE_000202
To: 'Fred Jug' <fjug@bmr-law.com>; Arthur Goldberg <artgoldberg@verizon.net>; 'Robert Bernstein'
<robert.s.bernstein@gmail.com>; Deb Knox <deb@knox412.com>
Subject: FW: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court, Unfair
Trade Practices Consumer Protection Law, Fraud, etc. 3 of several
Importance: High

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

EvE_000203
Subject: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court, Unfair Trade
Practices Consumer Protection Law, Fraud, etc.
Importance: High
First, pull the case off the docket. there is no leak. There was never any leak whatsoever
attributable to me. See attached photographic evidence. Second, per the attached evidentiary you
have the unmitigated to seek extraordinary measures ex pare to force me to pay for nonexistent
damages when the attached demonstrate your failure to maintain this property given the abundant
evidence all over the garage and the more than two-years of discussion regarding the leaking electric
vault to P-1. See representative examples of the indisputable evidence of our collective bad faith in
seeking ex parte special injunctive based upon lie upon lie for purely retaliatory and predatory
reasons. And furthermore, you know or are reckless for not knowing that your client is wholly
responsible for the dangerous condition on P-Q are reckless in not knowing that your client
(whomever that may be) is admittedly responsible for the dangerous condition on P-1 (per Exh. to
your so-called complaint) that has gone unaddressed after more than two years. See attached. And,
it appears that this dangerous condition is due to the fact that the right of way granted to Duquesne
Light to the incorporator of “Imperial House Condominium Association, Inc., runs with the owner
not the land. And the owner is the actual and sole incorporator of the IHCA; specifically, Kenny
Ross. See Attached. Given that this building is nine-floors, is sprinkler-free, with an alarm system
that I can barely hear, the failure to address this issue does in fact represent a true risk of imminent
harm. See also, the records of multiple violations due to this BOD’s failure to comply with
applicable regualatios.
Furthermore, as you well know or are reckless in not knowing, the overwhelming evidence that
Arthur Goldberg, a notorious violator of the securities laws and at least an affiliate of the subjects of
my years-long investigation of organized crime on Wall Street, is harassing, extorting, and stalking
me. Since my last direct communication to the BOD, I investigated Mr. Goldberg given the threats
of charging me $1000 per day for a fictious violation of a rule that does not exist after the BOD has
repeatedly denied my requests for a copy of the Rules, Regulations, Bylaws, and the Applicable
Declaration. And not only did I learn that I am being harassed and bullied by an affiliate and
associate of my five-year investigation into organized criminal networks but also that he is running a
securities fraud from my mother’s building. \ Goldberg persistence escalated as did his baseless
attempts to coerce me to pay money for unlawful debts. Thus, I undertook an investigation of
Goldberg only to learn that he notorious violator of the federal securities laws and a known affiliate,
co-conspirator of the subjects of my years-long investigation of organized crime on Wall Street
many of whom are currently targets of criminal investigations all over the country.
Furthermore, he is running a securities fraud from the building and from at least 2016 to the present
made multiple material false and misleading representation in furtherance of the sale of restricted,
control securities as free trading stock when in fact no exemption was or is available. He falsely
certified Unit 1009 as the corporate headquarters of the issuer even after he flipped the unit in 2016.
Furthermore the regulatory filings contain misrepresentations regarding the location of his
coconspirators. Clearly, he puts our safety at risk and is using the residential only property for a
commercial enterprise. The representative intrastate regulatory filings as well as the corporate are
each subject to criminal penalty for unsworn statement to regulators, false statements and securities
fraud in my opinion. In addition, it appears he is engaging in the unauthorized practice of law in this
jurisdiction. Furthermore, his CPA is inactive and thus he barred from performing any work inside the scope of
accountancy and from representing that he has a license. Similarly, per the attached public records he definitely
holds himself out as lawyer, CPA and attorney for the association.
Your conduct and the conduct of all implicated attorneys violates the integrity of our judicial system
EvE_000204
and is directly adverse to our judicial process which I believe is about truth, fairness, and justice.
You subvert the course of justice by filing a frivolous, baseless lawsuit that has caused the estates
thousands of dollars of limited funds all for the purpose of reaping debt. illegal gains. You made a
false certification of service. Attempted to evade any lawful service of process. You knowingly
allowed Goldberg in executing a false verification. Further, you know without a doubt that a court
in equity does not have jurisdiction over a claim for money damages absent an ownership or lien
because such complaint does not sound in equity. You have no damages nor suffered whatsoever
per your per your own spurious complaint which you falsely certified as served on February 2016 –
2 days before you emailed the materially misleading email which is attached as an exhibit. Your
papers are rife with material misstatements. You overly violate every applicable civil rule
governing motions practice to the extent there exists the optics of your having cherry-picked your
Judge given he is not the motions court judge this week together with the fact that the mattered is
mandated to be set for general motions court. With utmost respect to Judge Dellaveccia, he is not
Motions Court judge this week and thus the optics of your conduct do him no favor. Furthermore,
you violate and circumvent every rule of civil procedure governing process, means of service, false
certifications, knowingly false representations, failing to attach the writings you claim support your
utterly deficient excuse for a complaint. which is disfavored by the Courts. Your complaint is an
insult to the integrity of the court. Furthermore, this would obviously be a contested motion yet I am
not afforded even that much due process because apparently you do not have to comply the rules of
court in Allegheny county.
For you, to leverage your knowledge, sophistication, resources, and insider status against pro se,
disabled former public servant who has little to no state court experiences is the epitome of abuse of
process among particularly in the context of ex parte relief With respect to your scurrilous,
defamatory vicious predatory lawsuit, the evidence speaks for itself. Overall, the above described
conduct forms the basis for disciplinary investigation for violation of various Rules of Professional
Responsibility including : Rule 1.16(a)(1) - A lawyer is prohibited - from representing a client if the
representation will result in violation of the Rules of Professional Conduct or other law; RPC 8.4(a)
— A lawyer is prohibited from violating or attempting to violate the Rules of Professional Conduct,
knowingly assist or inducing another to do so, or do so through the acts of another; RPC 8.4(b) A
lawyer is prohibited from committing a criminal act that reflects dishonesty, a lack
of trustworthiness or fitness as a lawyer; RPC 8.4 (c) — A lawyer is prohibited from engaging in
conduct involving misrepresentation; RPC 8.4 (d) —- A lawyer is prohibited from engaging in
conduct that is prejudicial to the administration of justice; RPC 8.4(e) — A lawyer is prohibited from
exercising, stating, or implying an ability to improperly influence a government agency or official or
to receive results by means that violate the Rules of Professional Conduct or other law; RPC 8.4
(f) — A lawyer is prohibited from recklessly or knowingly assisting a judge or judicial officer in
conduct that is a violation of applicable rules of judicial conduct or other law, RPC 5.5(a) — A
lawyer is prohibited from practicing law in a jurisdiction in violation of the regulation of that
jurisdiction (Goldberg); and PC 5.5(b)(2) — A lawyer who is not admitted to practice in this
jurisdiction is prohibited from holding out to the public as being admitted to practice law in this
jurisdiction (and from aiding and abetting the same).

Each of you and others known and not known are at least subject to individual and joint liability to
the estate on multiple fronts including but, not limited, to violations of common law fraud,
conspiracy, defamation, libel, intentional infliction of emotional distress, violations of the Fair Debt
Collection Practices Act, 15 U.S.C. § 1692 et seq. violations of 66 Pa C.S.A.§ 1313) (Price upon
resale of public utility service); Pennsylvania Fair Credit Extension Uniformity Act, 73 Pa.Stat. Ann.
§ 2270 et seq.; the Pennsylvania Unfair Trade Practices and Consumer Protection Law, 73 Pa. Stat.
Ann. § 201–1 et seq. fraud by deception, Punitive damages are expressly permitted under the UCA
and the UPCA for a willful violation of the statute. See UCA § 3412 and UPCA § 5412 Under the
ILSFDA penalties may be imposed for willful violations, including criminal penalties of up to a
$10,000 fine, or up to five (5) years of imprisonment, or both, and civil penalties of up to $1,000 for
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each violation. Note, under the ILSFDA civil penalties can be imposed on anyone who “knowingly
and materially” violates the act, and “knowingly” is defined to mean “having actual knowledge of or
acting with deliberate ignorance of or reckless disregard for the prohibitions” of the act. See
ILSFDA §§ 1717 and 1717(a). Furthermore per my emails of December 2020, this association is
mandated to address members' claims of harassment on the basis of race, color, religion, national
origin, sex, familial status, and disability. This includes harassment by other residents, board
members, managers, and vendors. The law requires that boards take prompt steps to investigate and
end harassment. (Code of Fed. Reg. §100.7(a)(1)(iii).) You collectively have escalated your
harassment in response to my claims. Accordingly, each and every one of you is subject to personal
as well joint liability for your utter disdain and disregard for the rights of particularly members of
protected classes, theft common law fraud, extortion, theft by deception, criminal harassment, sales
of harrassment, stalking (Goldberg), sales of unregistered securities in violation of Section 5 of the
Securities Act of 1933, as well as potential Rico and Rico conspiracy liability in addition to control
group liability jointly and severally for all wrongful conduct of a controlled issuer or entity under the
applicable control theories of liability. I remind that Pennsylvania recognizes the crime/fraud
exception to attorney client. Clearly you are on notice of anticipated litigation and are under a duty
to preserve any all relevant documents, material, etc. This email is the consequence of the pressure
and duress you impose upon me by your inexcusable conduct. I am not able to appear today and I
will seek an emergency, disability accommodation if necessary. Should you proceed with this
course of conduct and obtain a ex parte injunction then so be it.. I will move to dissolve
immediately. And I cannot all evidentiary records due to volume, I will therefore follow up by
separate email.
The attached documents speak for themselves but a screenshot of the contents follows:

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.
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EvE_000207
From: Gusty A.E. Sunseri
To: Uta Von eckartsberg
Subject: Fw: Imperial House Condominium v. Von Eckartsberg GD 21-001293
Date: Thursday, February 18, 2021 1:48:32 PM
Attachments: doc00425620210218123024.pdf
IMPERIAL HOUSE PROPOSED ORDER.docx

Sent: Thursday, February 18, 2021 1:45 PM
To: Uta Von eckartsberg
Subject: Fw: Imperial House Condominium v. Von Eckartsberg GD 21-001293
Uta The attached was just sent to me. Please call me for discussion.
From: Fred C Jug

To: Civilgenmotions@alleghenycourts.us
Cc: 'Uta von Eckartsberg' ; gusty-sunseri@verizon.net
Subject: Imperial House Condominium v. Von Eckartsberg GD 21-001293
Please find attached an Emergency Motion For Special Injunction and a Proposed Order. The
Proposed Order is provided in word format pursuant to the Standard Operating Procedures of
the Court. The Plaintiff would appreciate this matter now be scheduled. The Motion has also
been mailed to the Defendant and the defendant is copied on this email. A courtesy copy is
also being provided to counsel for the estate who is also copied on this email as no appearance
has been entered yet in this case. Your attention to this matter is appreciated.
Fred C. Jug, Jr. Attorney

Brandt, Milnes & Rea, P.C.
1109 Grant Building
310 Grant Street
Pittsburgh, PA 15219
Phone (412) 255-6500
Fax (412) 255-6504
Email: fjug@bmr-law.com
This electronic message and any attachments transmitted with it contain information that may
be privileged and confidential. The information is intended for the use of the intended
recipients only. If you are not an intended recipient, note that any disclosure, copying,
distribution or use of the contents of this message is prohibited. If you have received this
message in error, please contact the above sender and delete this message immediately.
EvE_000208
From: Fred C Jug
Cc: "Uta von Eckartsberg"; gusty-sunseri@verizon.net
Attachments: doc00425620210218123024.pdf
IMPERIAL HOUSE PROPOSED ORDER.docx

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
EvE_000209
From: Fred C Jug
To: "Uta von Eckartsberg"
Subject: RE: CEASE & Desist and Identity fraud (offers and sales of unregistered securities)l
Attachments: image001.png
image002.png
The Hearing today was scheduled by the Judge after it was assigned by the General Motions
office. You should be aware of that based on the prior email chain and this establishes that
your prior email about “cherry-picking the Judge” is false and completely without merit. As an
attorney, you also should be award the Hearing which has now been scheduled by the Court
shall remain scheduled until the Judge postpones it. If you wish to request a postponement
then you will need to make that request with a copy to opposing counsel. Finally, my client
remains willing to explore an amicable resolution as I discussed with Mr. Sunseri the other
day. If you share in that goal then please email me your proposal so I can share it with the
Board.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

Sent: Wednesday, February 24, 2021 11:35 AM
To: Arthur Goldberg <artgoldberg@verizon.net>; 'Fred Jug' <fjug@bmr-law.com>; 'Robert Bernstein'
<robert.s.bernstein@gmail.com>; 'Deb Knox' <deb@knox412.com>
stlrfanpgh@aol.com; pj92926@gmail.com; ethelweikers1@gmail.com; frisch@duq.edu;
bloberant@yahoo.com; rgrif@cmu.com; nloberant@yahoo.com; stephen.tirone@gmail.com;
antis1209@comcast.net; 1 neil.cosgrove@verizon.net; roblschwartz@aol.com;
reiko.becker@gmail.com; shirleykmeyers@msn.com; dandee26@verizon.com;
EvE_000210
Importance: High
Attached are exemplars of multiple federal and state regulatory filings relates sales the restricted,
securities of Bellrock from at least 2015 through 2018 where an individual identified as Arthur
Goldberg CFO identified either 815 and/or 1009 5600 as the residence of the control person of the
issuer as its corporate headquarters. I have not yet had the opportunity to check for a reply to my
email but to the extent that this is a criminal imposter, you should know this person seems to have
used your identity to commit mail and/or fraud to offer and sell unregistered securities.
Since you firmly represented to us all that you know nothing about securities, I will do you the
courtesy of explaining that based upon a cursory review of public records, none of the shares sold by
this person were by a registration statement and there was no exemption or safe harbor for the sales
of securities in unregistered transactions allegedly raising in excess of $8 million. Accordingly, in
addition to identity fraud concerns, they would almost certainly be exposed to criminal laicity given
that the this is a essentially a strict liability offense, even in the criminal landscape (state and
federal) given that the Government’s only burden is to prove that the bad actor knew that the
securities not registered and not exempt when sold. And of course most bad actors in this space are
market professionals with no plausible defense.
And speaking as a former prosecutor, the beauty of a case like this that all injured investors have an
immediate right to demand recession for sales of unregistered securities absent an applicable
exemption. Not giving you legal advice or anything, just the benefit of the public record and
historical knowledge. I am copying the FBI and the District Attorney to ensure that no other injured
investors are defrauded. .
Ooops!! Almost forget to mention the most important thing -- this criminal imposter has also
obtained mortgage loans using fictitious property interests in this building – commonly described as
an “air loan.” That can be cause for real concern. I’ll be sure and send the papers to you! Let me
know when you catch up with the criminal folks. Happy to share more detailed info as necessary.
Fictitious loan papers on the way.
Finally, Also, I am quite ill today and request you reasonably accommodate me by withdrawing the
discredited, fraudulent representations furnished to the Court. Given your demonstrated concern for
my good health and wellbeing, I am sure you have already handled this in compliance with the rules
of court, law, and the interests of fair administration of justice.
Also, I am quite ill today and request you reasonably accommodate me the discredited, fraudulent
representations furnished to the Court. Given your demonstrated concern for my good health and
wellbeing, I am sure you have already handled this in compliance with the rules of court, law, and
the interests of fair administration of justice
Uta
301.461.7445 ©
724.631.5212 (fax)
EvE_000211
this message.

Human Rights Act.
EvE_000212
.

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
EvE_000213
this message.


EvE_000214
Importance: High

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

Importance: High
EvE_000215
Declaration.
And not only did I learn that I am being harassed and bullied by an affiliate and associate of my
five-year investigation into organized criminal networks but also that he is running a securities fraud
from my mother’s building. \ Goldberg persistence escalated as did his baseless attempts to coerce
me to pay money for unlawful debts. Thus, I undertook an investigation of Goldberg only to learn
that he notorious violator of the federal securities laws and a known affiliate, co-conspirator of the
subjects of my years-long investigation of organized crime on Wall Street many of whom are
currently targets of criminal investigations all over the country.
jurisdiction. Furthermore, his CPA is inactive and thus he barred from performing any work inside
the scope of accountancy and from representing that he has a license. Similarly, per the attached
public records he definitely holds himself out as lawyer, CPA and attorney for the association.
EvE_000216
papers are rife with material misstatements.
You overly violate every applicable civil rule governing motions practice to the extent there exists
the optics of your having cherry-picked your Judge given he is not the motions court judge this week
together with the fact that the mattered is mandated to be set for general motions court. With utmost
respect to Judge Dellaveccia, he is not Motions Court judge this week and thus the optics of your
conduct do him no favor. Furthermore, you violate and circumvent every rule of civil procedure
governing process, means of service, false certifications, knowingly false representations, failing to
attach the writings you claim support your utterly deficient excuse for a complaint. which is
disfavored by the Courts. Your complaint is an insult to the integrity of the court. Furthermore,
this would obviously be a contested motion yet I am not afforded even that much due process
because apparently you do not have to comply the rules of court in Allegheny county.
Responsibility including :
Rule 1.16(a)(1) - A lawyer is prohibited - from representing a client if the representation will result
in violation of the Rules of Professional Conduct or other law; RPC 8.4(a) — A lawyer is prohibited
from violating or attempting to violate the Rules of Professional Conduct, knowingly assist or
inducing another to do so, or do so through the acts of another;
RPC 8.4(b) A lawyer is prohibited from committing a criminal act that reflects dishonesty, a lack
conduct involving misrepresentation;
RPC 8.4 (d) —- A lawyer is prohibited from engaging in conduct that is prejudicial to the
administration of justice; RPC 8.4(e) — A lawyer is prohibited from exercising, stating, or implying
an ability to improperly influence a government agency or official or to receive results by means
that violate the Rules of Professional Conduct or other law;
RPC 8.4 (f) — A lawyer is prohibited from recklessly or knowingly assisting a judge or judicial
officer in conduct that is a violation of applicable rules of judicial conduct or other law,
RPC 5.5(a) — A lawyer is prohibited from practicing law in a jurisdiction in violation of the

regulation of that jurisdiction (Goldberg); and PC 5.5(b)(2) — A lawyer who is not admitted to
practice in this jurisdiction is prohibited from holding out to the public as being admitted to practice
law in this jurisdiction (and from aiding and abetting the same).

EvE_000217
each violation.
Note, under the ILSFDA civil penalties can be imposed on anyone who “knowingly and materially”
violates the act, and “knowingly” is defined to mean “having actual knowledge of or acting with
deliberate ignorance of or reckless disregard for the prohibitions” of the act. See ILSFDA §§ 1717
and 1717(a). Furthermore per my emails of December 2020, this association is mandated to
address members' claims of harassment on the basis of race, color, religion, national origin, sex,
familial status, and disability. This includes harassment by other residents, board members,
managers, and vendors. The law requires that boards take prompt steps to investigate and end
harassment. (Code of Fed. Reg. §100.7(a)(1)(iii).) You collectively have escalated your harassment
in response to my claims.
Accordingly, each and every one of you is subject to personal as well joint liability for your utter
disdain and disregard for the rights of particularly members of protected classes, theft common law
fraud, extortion, theft by deception, criminal harassment, sales of harrassment, stalking (Goldberg),
sales of unregistered securities in violation of Section 5 of the Securities Act of 1933, as well as
potential Rico and Rico conspiracy liability in addition to control group liability jointly and severally
for all wrongful conduct of a controlled issuer or entity under the applicable control theories of
liability. I remind that Pennsylvania recognizes the crime/fraud exception to attorney client.
Clearly you are on notice of anticipated litigation and are under a duty to preserve any all relevant
documents, material, etc. This email is the consequence of the pressure and duress you impose
upon me by your inexcusable conduct. I am not able to appear today and I will seek an emergency,
disability accommodation if necessary. Should you proceed with this course of conduct and obtain a
ex parte injunction then so be it.. I will move to dissolve immediately. And I cannot all evidentiary
records due to volume, I will therefore follow up by separate email.

412.207.7742(ph)
301.461.7445 ©
EvE_000218
724.631.5212 (fax)
this message.
EvE_000219
From: uvoneck@outlook.com
To: Arthur Goldberg; "Fred Jug"; "Robert Bernstein"; "Deb Knox"
Cc: lizhrenda@comcast.net; shandel.gilbert@verizon.net; sylvholland@aol.com; stlrfanpgh@aol.com;
pj92926@gmail.com; ethelweikers1@gmail.com; frisch@duq.edu; bloberant@yahoo.com; rgrif@cmu.com;
nloberant@yahoo.com; stephen.tirone@gmail.com; antis1209@comcast.net; 1 neil.cosgrove@verizon.net;
roblschwartz@aol.com; reiko.becker@gmail.com; shirleykmeyers@msn.com; dandee26@verizon.com;
shirleykmeyers@msn.com; pj92926@gmail.com; hwerstil@aol.com; lew@andrew.cmu.edu; hellman@pitt.edu;
amq02@comcast.net
Attachments: all cty prop assessment parcel search 00086p001500000 viewed_02.24.2021 - Copy.pdf
image001.png
image002.png
ucc finiancing 2015.06.04 .pdf
Mr. Goldberg,
You said I made a false statement and defamed you. Are you a victim of identity fraud or not?

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

EvE_000220
Importance: High
Uta
301.461.7445 ©
724.631.5212 (fax)
EvE_000221
this message.

Human Rights Act.
EvE_000222
.

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
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this message.


EvE_000224
Importance: High

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

Importance: High
EvE_000225
Declaration.
EvE_000226


EvE_000227
each violation.

412.207.7742(ph)
301.461.7445 ©
EvE_000228
724.631.5212 (fax)
this message.
EvE_000229
From: Fred C Jug
Cc: "Law Linda"; "Charles Gallo"; gusty-sunseri@verizon.net
I informed the Judge of your email earlier today in which you said you were not feeling well.
Rather than proceed today the Judge indicated that he would issue an Order granting you a
postponement until March 10, 2021 at 1:30 pm. We should expect to receive an Order with the
new date. Since Mr. Sunseri was on the original service email as counsel for the Estate I was
directed to again include him and have done so.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Fred C Jug <fjug@bmr-law.com>

Sent: Wednesday, February 24, 2021 2:04 PM
To: 'Uta von Eckartsberg' <uvoneck@outlook.com>
I received your email. The Judge is on the line right now and waiting for you to call in.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
EvE_000230
EvE_000231
From: Fred C Jug
image002.png
I received your email. The Judge is on the line right now and waiting for you to call in.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

Sent: Wednesday, February 24, 2021 2:01 PM
wjjohnston@firstcommand.com; patmiles1@aol.com; nanwm@verizon.net;
Mr. Goldberg,
EvE_000232
You said I made a false statement and defamed you. Are you a victim of identity fraud or not? And
please also attached the air loan executed 2016 by Mr. Goldberg in his corporate form (or his
imposter) which is secured by the entirety of 5600 as identified by Parcel ID versus the name of the
property. Furthermore, see also the attached UCC financing document which encumbers all future
assessments, insurance proceeds, etc., etc. and cites “Decl.” as authority for this commercial loan.
Is this consistent with the declaration you rely on in pleadings and elsewhere? Where is the
Declaration? I have requested the governing documents many, many times and you fail to copy it to
the complaint.

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

Importance: High
EvE_000233
Uta
301.461.7445 ©
724.631.5212 (fax)
this message.

EvE_000234
Human Rights Act.
EvE_000235
.

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
EvE_000236
this message.


EvE_000237
Importance: High

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

Importance: High
EvE_000238
Declaration.
EvE_000239


EvE_000240
each violation.

412.207.7742(ph)
301.461.7445 ©
EvE_000241
724.631.5212 (fax)
this message.
EvE_000242
From: Fred C Jug
Subject: RE: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court, Unfair Trade Practices
Consumer Protection Law, Fraud, etc.
Date: Tuesday, February 23, 2021 2:31:08 PM
This email will briefly respond to your email below. First, the Injunction Hearing is on my
calendar for tomorrow at 2 pm and not today and point this out as it appears that you reference
the Hearing today and this is not correct. You received the same email with that notice as I
did. Next, I could not open the links at the bottom of your email which reference documents
which supposedly speak for themselves. Please forward these documents in a fashion they can
be opened. Next, I am taking the time to respond to you so that there is a record of a denial of
your unfounded assertions and caution you as a licensed attorney that unwarranted threats of
contacting the disciplinary board and/or litigation are themselves improper. Further, contrary
to the ridiculous assertions you have made I did not cherry-pick a judge or play any role in
having this case heard by one judge versus another. Your comment is insulting to myself and
unfairly portrays a respected jurist in a bad light. I also note you copied a significant number
of people. I hereby demand you retract the defamatory comments you have made in your
communication. All of your arguments seem to be an attempt to deflect attention from the
issue at hand which is whether the Association has access to the Unit. The Motion which is
filed cites to the authority for such access. If you disagree, then you or your attorney can
present your legal arguments and the court will then decide the outcome. The need for this
hearing is based on your refusal to respond to the good faith attempts to work out these issues
without ever needing to approach the court. These efforts are memorialized in the email
communications that are attached as an exhibit, and you elected not to respond to them, but
have now saw fit to copy twenty people on your email. The Association would have strongly
preferred to work out these issues without court intervention. This litigation was only
necessary as a result of your refusal to cooperate as required by the governing documents. My
preference remains to resolve this matter in an amicable fashion rather than needing to reserve
our legal rights and remedies as a result of the content of this most recent email. Should you
proceed with any of your threats, we will have no choice but to reserve those rights.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
EvE_000243
Importance: High
attributable to me. See attached photographic evidence. . Second, per the attached evidentiary
you have the unmitigated to seek extraordinary measures ex pare to force me to pay for nonexistent
Declaration. And not only did I learn that I am being harassed and bullied by an affiliate and
associate of my five-year investigation into organized criminal networks but also that he is running a
EvE_000244
securities fraud from my mother’s building. \ Goldberg persistence escalated as did his baseless
attempts to coerce me to pay money for unlawful debts. Thus, I undertook an investigation of
Goldberg only to learn that he notorious violator of the federal securities laws and a known affiliate,
co-conspirator of the subjects of my years-long investigation of organized crime on Wall Street
many of whom are currently targets of criminal investigations all over the country.
jurisdiction. Furthermore, his CPA is inactive and thus he barred from performing any work inside the scope of
accountancy and from representing that he has a license. Similarly, per the attached public records he definitely
holds himself out as lawyer, CPA and attorney for the association.
papers are rife with material misstatements. You overly violate every applicable civil rule
governing motions practice to the extent there exists the optics of your having cherry-picked your
Judge given he is not the motions court judge this week together with the fact that the mattered is
mandated to be set for general motions court. With utmost respect to Judge Dellaveccia, he is not
Motions Court judge this week and thus the optics of your conduct do him no favor. Furthermore,
you violate and circumvent every rule of civil procedure governing process, means of service, false
certifications, knowingly false representations, failing to attach the writings you claim support your
utterly deficient excuse for a complaint. which is disfavored by the Courts. Your complaint is an
insult to the integrity of the court. Furthermore, this would obviously be a contested motion yet I am
not afforded even that much due process because apparently you do not have to comply the rules of
court in Allegheny county.
Responsibility including : Rule 1.16(a)(1) - A lawyer is prohibited - from representing a client if the
representation will result in violation of the Rules of Professional Conduct or other law; RPC 8.4(a)
— A lawyer is prohibited from violating or attempting to violate the Rules of Professional Conduct,
knowingly assist or inducing another to do so, or do so through the acts of another; RPC 8.4(b) A
lawyer is prohibited from committing a criminal act that reflects dishonesty, a lack
conduct involving misrepresentation; RPC 8.4 (d) —- A lawyer is prohibited from engaging in
conduct that is prejudicial to the administration of justice; RPC 8.4(e) — A lawyer is prohibited from
EvE_000245
exercising, stating, or implying an ability to improperly influence a government agency or official or
to receive results by means that violate the Rules of Professional Conduct or other law; RPC 8.4
(f) — A lawyer is prohibited from recklessly or knowingly assisting a judge or judicial officer in
conduct that is a violation of applicable rules of judicial conduct or other law, RPC 5.5(a) — A
lawyer is prohibited from practicing law in a jurisdiction in violation of the regulation of that
jurisdiction (Goldberg); and PC 5.5(b)(2) — A lawyer who is not admitted to practice in this
jurisdiction is prohibited from holding out to the public as being admitted to practice law in this

Collection Practices Act, 15 U.S.C. § 1692 et seq. violations of 66 Pa. C.S.A.§ 1313) (Price upon
and the UPCA for a willful violation of the statute. See UCA § 3412 and UPCA § 5412. Under the
each violation. Note, under the ILSFDA civil penalties can be imposed on anyone who “knowingly
and materially” violates the act, and “knowingly” is defined to mean “having actual knowledge of or
acting with deliberate ignorance of or reckless disregard for the prohibitions” of the act. See
ILSFDA §§ 1717 and 1717(a). Furthermore per my emails of December 2020, this association is
mandated to address members' claims of harassment on the basis of race, color, religion, national
origin, sex, familial status, and disability. This includes harassment by other residents, board
members, managers, and vendors. The law requires that boards take prompt steps to investigate and
end harassment. (Code of Fed. Reg. §100.7(a)(1)(iii).) You collectively have escalated your
harassment in response to my claims. Accordingly, each and every one of you is subject to personal
as well joint liability for your utter disdain and disregard for the rights of particularly members of
protected classes, theft common law fraud, extortion, theft by deception, criminal harassment, sales
of harrassment, stalking (Goldberg), sales of unregistered securities in violation of Section 5 of the
Securities Act of 1933, as well as potential Rico and Rico conspiracy liability in addition to control
group liability jointly and severally for all wrongful conduct of a controlled issuer or entity under the
applicable control theories of liability. I remind that Pennsylvania recognizes the crime/fraud
exception to attorney client. Clearly you are on notice of anticipated litigation and are under a duty
to preserve any all relevant documents, material, etc. This email is the consequence of the pressure
and duress you impose upon me by your inexcusable conduct. I am not able to appear today and I
will seek an emergency, disability accommodation if necessary. Should you proceed with this
course of conduct and obtain a ex parte injunction then so be it.. I will move to dissolve
immediately. And I cannot all evidentiary records due to volume, I will therefore follow up by
separate email.
EvE_000246
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.
EvE_000247
From: Fred C Jug
To: "Law Linda"; uvoneck@outlook.com; gusty-sunseri@verizon.net
Subject: RE: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg
Thank you Linda. I put this on my calendar.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Law Linda <Linda.Law@alleghenycourts.us>

To: fjug@bmr-law.com; uvoneck@outlook.com; gusty-sunseri@verizon.net
Subject: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg
Importance: High
Good afternoon,
Argument on the Emergency Motion for Special Injunction in the above matter will be heard by
Judge Michael A. Della Vecchia on February 24, 2021, at 2:00 p.m. via telephone conference. To
access the argument, please call 1-877-953-7157 and enter conference code 416 7541#
Please feel free to email or call our chambers if you have any questions. We are continuing to work
remotely, but do check voice mail regularly.
Linda Law, Secretary
(412) 350-0281
EvE_000248
From: Fred C Jug
Cc: "Arthur Goldberg"
Subject: RE: active water leak from your apartment
Date: Thursday, February 4, 2021 10:28:28 AM
Dear Ms. Von Eckartsberg: 3 days have now gone by since the email below and you have not
responded. You were provided with the language from Section 3307 of the Act so you were
aware of the authority that exists in the state law to establish the Associations right of access.
Each unit Owner has a duty to provide such access and to prevent damage to the Common
Areas and other Units. The water leak into the common garage continues and the association
must have access to the Unit to inspect the pipes and determine if the source is within the Unit.
As you have not responded the Association is reserving their right to proceed to obtain a Court
Order to gain access. Such action could have been and may still be avoided by responding to
Mr. Goldberg that access will now be provided. However, since the leak continues the
Association must not be ignored any longer.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

Sent: Monday, February 1, 2021 12:31 PM
Cc: 'Arthur Goldberg' <artgoldberg@verizon.net>
Subject: RE: active water leak from your apartment
The Association has referred this issue to our office. Please respond to Mr. Goldberg so that
access can be immediately provided to stop any further damage to your Unit as well as the
Common Elements and/or other Units. This request is supported by the attached language
from Section 3307 of the Act: The Association would sincerely like to resolve this matter
amicably and without the need for Court Intervention. The Association will reserve all legal
right and remedies but again would simply like to resolve this matter without any further delay
EvE_000249
and in an amicable fashion.
1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504

Sent: Monday, February 1, 2021 12:20 PM
Cc: 'Fred Jug' <fjug@bmr-law.com>
Subject: active water leak from your apartment
Uta – PLEASE TAKE NOTICE that there is an active water leak from your unit, 309, and the
management requires IMMEDIATE access to prevent damage to your unit and to the common areas
of Imperial House. Your failure to grant such access will force Imperial House to obtain a court order
allowing such access and we will hold you responsible for damages. Please reply immediately.
Arthur L. Goldberg
President, Board of Directors
201-819-1848
EvE_000250
To: Arthur Goldberg
Cc: Fred Jug; Robert Bernstein; Deb Knox; lizhrenda@comcast.net; shandel.gilbert@verizon.net; sylvholland@aol.com;
stlrfanpgh@aol.com; pj92926@gmail.com; shirleykmeyers@msn.com; ethelweikers1@gmail.com; frisch@duq.edu;
bloberant@yahoo.com; rgrif@cmu.com; nloberant@yahoo.com; stephen.tirone@gmail.com; antis1209@comcast.net; 1
neil.cosgrove@verizon.net; roblschwartz@aol.com; reiko.becker@gmail.com; dandee26@verizon.com;
mjmckenna42@hotmail.com; maxifish1@aol.com; bunkerc@pitt.edu; william.lindgren@sru.edu; joeldon@aol.com;
danehower@gmail.com; vicky.humphrey23@gmail.com; reneeramo@gmail.com; johnstonann@att.net;
wjjohnston@firstcommand.com; patmiles1@aol.com; nanwm@verizon.net; jbaccordion@gmail.com;
smithkmt@gmail.com; bonnie17961@gmail.com; amq02@comcast.net; rmolyneauxrmx@gmail.com;
sheilaryannp@aol.com; eiko.becker@gmail.com; ritzec@comcast.net; hwerstil@aol.com; lew@andrew.cmu.edu;
hellman@pitt.edu
Bcc: uvoneck@outlook.com
Subject: Re: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court, Unfair Trade Practices Consumer
Protection Law, Fraud, etc. 3 of several

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended recipient(s) and
may contain confidential and privileged information. If you are not the intended recipient, please
do not read, distribute, or take action in reliance upon the message. If you have received this
message in error, please notify the sender immediately by return e-mail and promptly delete this
message and its attachments from your computer system. Be advised that no privileges are waived
by the transmission of this message.
On Feb 23, 2021, at 4:12 PM, Arthur Goldberg <artgoldberg@verizon.net> wrote:

Ms. von Eckartsberg - You made the decision to spread false information to our neighbors
without verifying that the Arthur Goldberg you were referring to was not me. I have never
been in the securities business and you have accused me without attempting to verify that
fact. This person was not me and you smeared my good name with our neighbors. I am
demanding that you immediately retract these false claims to all those who received your
email.
You also fail to admit that you were given numerous opportunities to work with the
Association, as the governing documents require, and this failure is established by the emails
attached to the motion pending in court. You ignored numerous requests from me and the
Association attorney to meet in person or even via email to resolve this without forcing us to
go to court.
EvE_000251
You have still not arranged for access into your unit which could have avoided the court
action from being necessary and have accused me and the Association’s Attorney of
improper conduct which is not based on the facts or the law. Again, you must cease and
desist from this activity.

To: 'Fred Jug' <fjug@bmr-law.com>; Arthur Goldberg <artgoldberg@verizon.net>; 'Robert
Bernstein' <robert.s.bernstein@gmail.com>; Deb Knox <deb@knox412.com>
stlrfanpgh@aol.com; pj92926@gmail.com; shirleykmeyers@msn.com;
ethelweikers1@gmail.com; frisch@duq.edu; bloberant@yahoo.com; rgrif@cmu.com;
nloberant@yahoo.com; stephen.tirone@gmail.com; antis1209@comcast.net; 1
neil.cosgrove@verizon.net; roblschwartz@aol.com; reiko.becker@gmail.com;
dandee26@verizon.com; mjmckenna42@hotmail.com; maxifish1@aol.com;
bunkerc@pitt.edu; william.lindgren@sru.edu; joeldon@aol.com; danehower@gmail.com;
vicky.humphrey23@gmail.com; reneeramo@gmail.com; johnstonann@att.net;
jbaccordion@gmail.com; smithkmt@gmail.com; bonnie17961@gmail.com;
amq02@comcast.net; rmolyneauxrmx@gmail.com; sheilaryannp@aol.com;
eiko.becker@gmail.com; ritzec@comcast.net; shirleykmeyers@msn.com;
pj92926@gmail.com; hwerstil@aol.com; lew@andrew.cmu.edu; hellman@pitt.edu;
amq02@comcast.net
Subject: FW: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court,
Unfair Trade Practices Consumer Protection Law, Fraud, etc. 3 of several
Importance: High

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
DISCLAIMER: This e-mail message is intended only for the personal use of the
recipient(s) named above. This message may be an attorney-client communication and as
such privileged and confidential and/or it may include attorney work product. If you are
not an intended recipient, you may not review, copy or distribute this message. If you
have received this communication in error, please notify us immediately by e-mail and
delete the original message and its attachments from your computer system. Please be
advised that no privileges are waived by the transmission of this message.

To: 'Fred Jug' <fjug@bmr-law.com>; Arthur Goldberg <artgoldberg@verizon.net>; 'Robert
Bernstein' <robert.s.bernstein@gmail.com>; Deb Knox <deb@knox412.com>
ethelweikers1@gmail.com; frisch@duq.edu; bloberant@yahoo.com; rgrif@cmu.com;
EvE_000252
nloberant@yahoo.com; stephen.tirone@gmail.com; antis1209@comcast.net; 1
neil.cosgrove@verizon.net; roblschwartz@aol.com; reiko.becker@gmail.com;
dandee26@verizon.com; mjmckenna42@hotmail.com; maxifish1@aol.com;
bunkerc@pitt.edu; william.lindgren@sru.edu; joeldon@aol.com; danehower@gmail.com;
vicky.humphrey23@gmail.com; reneeramo@gmail.com; johnstonann@att.net;
jbaccordion@gmail.com; smithkmt@gmail.com; bonnie17961@gmail.com;
amq02@comcast.net; rmolyneauxrmx@gmail.com; sheilaryannp@aol.com;
eiko.becker@gmail.com; ritzec@comcast.net; shirleykmeyers@msn.com;
pj92926@gmail.com; hwerstil@aol.com; lew@andrew.cmu.edu; hellman@pitt.edu;
amq02@comcast.net
Subject: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court, Unfair
Trade Practices Consumer Protection Law, Fraud, etc.
Importance: High
attributable to me. See attached photographic evidence. Second, per the attached
evidentiary you have the unmitigated to seek extraordinary measures ex pare to force me to
pay for nonexistent damages when the attached demonstrate your failure to maintain this
property given the abundant evidence all over the garage and the more than two-years of
discussion regarding the leaking electric vault to P-1. See representative examples of the
indisputable evidence of our collective bad faith in seeking ex parte special injunctive based
upon lie upon lie for purely retaliatory and predatory reasons. And furthermore, you know
or are reckless for not knowing that your client is wholly responsible for the dangerous
condition on P-Q are reckless in not knowing that your client (whomever that may be) is
admittedly responsible for the dangerous condition on P-1 (per Exh. to your so-called
complaint) that has gone unaddressed after more than two years. See attached. And, it
appears that this dangerous condition is due to the fact that the right of way granted to
Duquesne Light to the incorporator of “Imperial House Condominium Association, Inc.,
runs with the owner not the land. And the owner is the actual and sole incorporator of the
IHCA; specifically, Kenny Ross. See Attached. Given that this building is nine-floors, is
sprinkler-free, with an alarm system that I can barely hear, the failure to address this issue
does in fact represent a true risk of imminent harm. See also, the records of multiple
violations due to this BOD’s failure to comply with applicable regualatios.
Furthermore, as you well know or are reckless in not knowing, the overwhelming evidence
that Arthur Goldberg, a notorious violator of the securities laws and at least an affiliate of
the subjects of my years-long investigation of organized crime on Wall Street, is harassing,
extorting, and stalking me. Since my last direct communication to the BOD, I investigated
Mr. Goldberg given the threats of charging me $1000 per day for a fictious violation of a
rule that does not exist after the BOD has repeatedly denied my requests for a copy of the
Rules, Regulations, Bylaws, and the Applicable Declaration. And not only did I learn that I
am being harassed and bullied by an affiliate and associate of my five-year investigation into
organized criminal networks but also that he is running a securities fraud from my mother’s
building. \ Goldberg persistence escalated as did his baseless attempts to coerce me to pay
money for unlawful debts. Thus, I undertook an investigation of Goldberg only to learn that
he notorious violator of the federal securities laws and a known affiliate, co-conspirator of
the subjects of my years-long investigation of organized crime on Wall Street many of
whom are currently targets of criminal investigations all over the country.
Furthermore, he is running a securities fraud from the building and from at least 2016 to the
present made multiple material false and misleading representation in furtherance of the sale
of restricted, control securities as free trading stock when in fact no exemption was or is
EvE_000253
available. He falsely certified Unit 1009 as the corporate headquarters of the issuer even
after he flipped the unit in 2016. Furthermore the regulatory filings contain
misrepresentations regarding the location of his coconspirators. Clearly, he puts our safety
at risk and is using the residential only property for a commercial enterprise. The
representative intrastate regulatory filings as well as the corporate are each subject to
criminal penalty for unsworn statement to regulators, false statements and securities fraud in
my opinion. In addition, it appears he is engaging in the unauthorized practice of law in this
jurisdiction. Furthermore, his CPA is inactive and thus he barred from performing any work inside the
scope of accountancy and from representing that he has a license. Similarly, per the attached public
records he definitely holds himself out as lawyer, CPA and attorney for the association.
Your conduct and the conduct of all implicated attorneys violates the integrity of our judicial
system and is directly adverse to our judicial process which I believe is about truth, fairness,
and justice. You subvert the course of justice by filing a frivolous, baseless lawsuit that has
caused the estates thousands of dollars of limited funds all for the purpose of reaping debt.
illegal gains. You made a false certification of service. Attempted to evade any lawful
service of process. You knowingly allowed Goldberg in executing a false verification.
Further, you know without a doubt that a court in equity does not have jurisdiction over a
claim for money damages absent an ownership or lien because such complaint does not
sound in equity. You have no damages nor suffered whatsoever per your per your own
spurious complaint which you falsely certified as served on February 2016 – 2 days before
you emailed the materially misleading email which is attached as an exhibit. Your papers
are rife with material misstatements. You overly violate every applicable civil rule
governing motions practice to the extent there exists the optics of your having cherry-picked
your Judge given he is not the motions court judge this week together with the fact that the
mattered is mandated to be set for general motions court. With utmost respect to Judge
Dellaveccia, he is not Motions Court judge this week and thus the optics of your conduct do
him no favor. Furthermore, you violate and circumvent every rule of civil procedure
governing process, means of service, false certifications, knowingly false representations,
failing to attach the writings you claim support your utterly deficient excuse for a complaint.
which is disfavored by the Courts. Your complaint is an insult to the integrity of the court.
Furthermore, this would obviously be a contested motion yet I am not afforded even that
much due process because apparently you do not have to comply the rules of court in
Allegheny county.
For you, to leverage your knowledge, sophistication, resources, and insider status against pro
se, disabled former public servant who has little to no state court experiences is the epitome
of abuse of process among particularly in the context of ex parte relief With respect to your
scurrilous, defamatory vicious predatory lawsuit, the evidence speaks for itself. Overall, the
above described conduct forms the basis for disciplinary investigation for violation of
various Rules of Professional Responsibility including : Rule 1.16(a)(1) - A lawyer is
prohibited - from representing a client if the representation will result in violation of the
Rules of Professional Conduct or other law; RPC 8.4(a) — A lawyer is prohibited from
violating or attempting to violate the Rules of Professional Conduct, knowingly assist or
inducing another to do so, or do so through the acts of another; RPC 8.4(b) A lawyer is
prohibited from committing a criminal act that reflects dishonesty, a lack
of trustworthiness or fitness as a lawyer; RPC 8.4 (c) — A lawyer is prohibited from
engaging in conduct involving misrepresentation; RPC 8.4 (d) —- A lawyer is prohibited
from engaging in conduct that is prejudicial to the administration of justice; RPC 8.4(e) — A
lawyer is prohibited from exercising, stating, or implying an ability to improperly
influence a government agency or official or to receive results by means that violate the
Rules of Professional Conduct or other law; RPC 8.4 (f) — A lawyer is prohibited from
recklessly or knowingly assisting a judge or judicial officer in conduct that is a violation of
applicable rules of judicial conduct or other law, RPC 5.5(a) — A lawyer is prohibited
from practicing law in a jurisdiction in violation of the regulation of that jurisdiction
(Goldberg); and PC 5.5(b)(2) — A lawyer who is not admitted to practice in this jurisdiction
is prohibited from holding out to the public as being admitted to practice law in this
EvE_000254

Each of you and others known and not known are at least subject to individual and joint
liability to the estate on multiple fronts including but, not limited, to violations of common
law fraud, conspiracy, defamation, libel, intentional infliction of emotional distress,
violations of the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. violations of
66 Pa C.S.A.§ 1313) (Price upon resale of public utility service); Pennsylvania Fair Credit
Extension Uniformity Act, 73 Pa.Stat. Ann. § 2270 et seq.; the Pennsylvania Unfair Trade
Practices and Consumer Protection Law, 73 Pa. Stat. Ann. § 201–1 et seq. fraud by
deception, Punitive damages are expressly permitted under the UCA and the UPCA for a
willful violation of the statute. See UCA § 3412 and UPCA § 5412 Under the ILSFDA
penalties may be imposed for willful violations, including criminal penalties of up to a
$10,000 fine, or up to five (5) years of imprisonment, or both, and civil penalties of up to
$1,000 for each violation. Note, under the ILSFDA civil penalties can be imposed on
anyone who “knowingly and materially” violates the act, and “knowingly” is defined to
mean “having actual knowledge of or acting with deliberate ignorance of or reckless
disregard for the prohibitions” of the act. See ILSFDA §§ 1717 and 1717(a). Furthermore
per my emails of December 2020, this association is mandated to address members' claims
of harassment on the basis of race, color, religion, national origin, sex, familial status, and
disability. This includes harassment by other residents, board members, managers, and
vendors. The law requires that boards take prompt steps to investigate and end harassment.
(Code of Fed. Reg. §100.7(a)(1)(iii).) You collectively have escalated your harassment in
response to my claims. Accordingly, each and every one of you is subject to personal as
well joint liability for your utter disdain and disregard for the rights of particularly members
of protected classes, theft common law fraud, extortion, theft by deception, criminal
harassment, sales of harrassment, stalking (Goldberg), sales of unregistered securities in
violation of Section 5 of the Securities Act of 1933, as well as potential Rico and Rico
conspiracy liability in addition to control group liability jointly and severally for all
wrongful conduct of a controlled issuer or entity under the applicable control theories of
liability. I remind that Pennsylvania recognizes the crime/fraud exception to attorney
client. Clearly you are on notice of anticipated litigation and are under a duty to preserve
any all relevant documents, material, etc. This email is the consequence of the pressure and
duress you impose upon me by your inexcusable conduct. I am not able to appear today and
I will seek an emergency, disability accommodation if necessary. Should you proceed with
this course of conduct and obtain a ex parte injunction then so be it.. I will move to dissolve
immediately. And I cannot all evidentiary records due to volume, I will therefore follow up
by separate email.
EvE_000255
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
recipient(s) named above. This message may be an attorney-client communication and as
such privileged and confidential and/or it may include attorney work product. If you are
not an intended recipient, you may not review, copy or distribute this message. If you
have received this communication in error, please notify us immediately by e-mail and
delete the original message and its attachments from your computer system. Please be
EvE_000256
To: Fred Jug; Arthur Goldberg; Robert Bernstein; Deb Knox
Cc: lizhrenda@comcast.net; shandel.gilbert@verizon.net; sylvholland@aol.com; stlrfanpgh@aol.com;
pj92926@gmail.com; shirleykmeyers@msn.com; ethelweikers1@gmail.com; frisch@duq.edu;
antis1209@comcast.net; 1 neil.cosgrove@verizon.net; roblschwartz@aol.com; reiko.becker@gmail.com;
dandee26@verizon.com; mjmckenna42@hotmail.com; maxifish1@aol.com; bunkerc@pitt.edu;
william.lindgren@sru.edu; joeldon@aol.com; danehower@gmail.com; vicky.humphrey23@gmail.com;
reneeramo@gmail.com; johnstonann@att.net; wjjohnston@firstcommand.com; patmiles1@aol.com;
nanwm@verizon.net; jbaccordion@gmail.com; smithkmt@gmail.com; bonnie17961@gmail.com;
amq02@comcast.net; rmolyneauxrmx@gmail.com; sheilaryannp@aol.com; eiko.becker@gmail.com;
ritzec@comcast.net; hwerstil@aol.com; lew@andrew.cmu.edu; hellman@pitt.edu
Bcc: Uta von Eckartsberg
Subject: Re: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the Court, Unfair Trade Practices Consumer
Protection Law, Fraud, etc. 3 of several

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended recipient(s)
and may contain confidential and privileged information. If you are not the intended recipient,
please do not read, distribute, or take action in reliance upon the message. If you have received
this message in error, please notify the sender immediately by return e-mail and promptly
delete this message and its attachments from your computer system. Be advised that no
privileges are waived by the transmission of this message.
On Feb 23, 2021, at 2:24 PM, Uta von Eckartsberg <uvoneck@outlook.com>

wrote:

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
recipient(s) named above. This message may be an attorney-client communication
and as such privileged and confidential and/or it may include attorney work
EvE_000257
product. If you are not an intended recipient, you may not review, copy or
distribute this message. If you have received this communication in error, please
notify us immediately by e-mail and delete the original message and its
attachments from your computer system. Please be advised that no privileges are
waived by the transmission of this message.

To: 'Fred Jug' <fjug@bmr-law.com>; Arthur Goldberg
<artgoldberg@verizon.net>; 'Robert Bernstein' <robert.s.bernstein@gmail.com>;
Deb Knox <deb@knox412.com>
ethelweikers1@gmail.com; frisch@duq.edu; bloberant@yahoo.com;
rgrif@cmu.com; nloberant@yahoo.com; stephen.tirone@gmail.com;
reiko.becker@gmail.com; dandee26@verizon.com; mjmckenna42@hotmail.com;
maxifish1@aol.com; bunkerc@pitt.edu; william.lindgren@sru.edu;
joeldon@aol.com; danehower@gmail.com; vicky.humphrey23@gmail.com;
reneeramo@gmail.com; johnstonann@att.net; wjjohnston@firstcommand.com;
patmiles1@aol.com; nanwm@verizon.net; jbaccordion@gmail.com;
smithkmt@gmail.com; bonnie17961@gmail.com; amq02@comcast.net;
rmolyneauxrmx@gmail.com; sheilaryannp@aol.com; eiko.becker@gmail.com;
ritzec@comcast.net; shirleykmeyers@msn.com; pj92926@gmail.com;
hwerstil@aol.com; lew@andrew.cmu.edu; hellman@pitt.edu;
amq02@comcast.net
Subject: CEASE & Desist - Harassment, Abuse of Process, Fraud, Fraud on the
Court, Unfair Trade Practices Consumer Protection Law, Fraud, etc.
Importance: High
First, pull the case off the docket. there is no leak. There was never any leak
whatsoever attributable to me. See attached photographic evidence. . Second,
per the attached evidentiary you have the unmitigated to seek extraordinary
measures ex pare to force me to pay for nonexistent damages when the attached
demonstrate your failure to maintain this property given the abundant evidence all
over the garage and the more than two-years of discussion regarding the leaking
electric vault to P-1. See representative examples of the indisputable evidence of
our collective bad faith in seeking ex parte special injunctive based upon lie upon
lie for purely retaliatory and predatory reasons. And furthermore, you know or
are reckless for not knowing that your client is wholly responsible for the
dangerous condition on P-Q are reckless in not knowing that your client
(whomever that may be) is admittedly responsible for the dangerous condition on
P-1 (per Exh. to your so-called complaint) that has gone unaddressed after more
than two years. See attached. And, it appears that this dangerous condition is
due to the fact that the right of way granted to Duquesne Light to the incorporator
of “Imperial House Condominium Association, Inc., runs with the owner not the
land. And the owner is the actual and sole incorporator of the IHCA; specifically,
Kenny Ross. See Attached. Given that this building is nine-floors, is sprinkler-
free, with an alarm system that I can barely hear, the failure to address this issue
EvE_000258
does in fact represent a true risk of imminent harm. See also, the records of
multiple violations due to this BOD’s failure to comply with applicable
regualatios.
Furthermore, as you well know or are reckless in not knowing, the overwhelming
evidence that Arthur Goldberg, a notorious violator of the securities laws and at
least an affiliate of the subjects of my years-long investigation of organized crime
on Wall Street, is harassing, extorting, and stalking me. Since my last direct
communication to the BOD, I investigated Mr. Goldberg given the threats of
charging me $1000 per day for a fictious violation of a rule that does not exist
after the BOD has repeatedly denied my requests for a copy of the Rules,
Regulations, Bylaws, and the Applicable Declaration. And not only did I learn
that I am being harassed and bullied by an affiliate and associate of my five-year
investigation into organized criminal networks but also that he is running a
securities fraud from my mother’s building. \ Goldberg persistence escalated as
did his baseless attempts to coerce me to pay money for unlawful debts. Thus, I
undertook an investigation of Goldberg only to learn that he notorious violator of
the federal securities laws and a known affiliate, co-conspirator of the subjects of
my years-long investigation of organized crime on Wall Street many of whom are
Furthermore, he is running a securities fraud from the building and from at least
2016 to the present made multiple material false and misleading representation in
furtherance of the sale of restricted, control securities as free trading stock when
in fact no exemption was or is available. He falsely certified Unit 1009 as the
corporate headquarters of the issuer even after he flipped the unit in 2016.
Furthermore the regulatory filings contain misrepresentations regarding the
location of his coconspirators. Clearly, he puts our safety at risk and is using the
residential only property for a commercial enterprise. The representative
intrastate regulatory filings as well as the corporate are each subject to criminal
penalty for unsworn statement to regulators, false statements and securities fraud
in my opinion. In addition, it appears he is engaging in the unauthorized practice
of law in this jurisdiction. Furthermore, his CPA is inactive and thus he barred
from performing any work inside the scope of accountancy and from representing
that he has a license. Similarly, per the attached public records he definitely holds
himself out as lawyer, CPA and attorney for the association.
Your conduct and the conduct of all implicated attorneys violates the integrity of
our judicial system and is directly adverse to our judicial process which I believe
is about truth, fairness, and justice. You subvert the course of justice by filing a
frivolous, baseless lawsuit that has caused the estates thousands of dollars of
limited funds all for the purpose of reaping debt. illegal gains. You made a false
certification of service. Attempted to evade any lawful service of process. You
knowingly allowed Goldberg in executing a false verification. Further, you know
without a doubt that a court in equity does not have jurisdiction over a claim for
money damages absent an ownership or lien because such complaint does not
sound in equity. You have no damages nor suffered whatsoever per your per your
own spurious complaint which you falsely certified as served on February 2016 –
2 days before you emailed the materially misleading email which is attached as an
exhibit. Your papers are rife with material misstatements. You overly violate
every applicable civil rule governing motions practice to the extent there exists
EvE_000259
the optics of your having cherry-picked your Judge given he is not the motions
court judge this week together with the fact that the mattered is mandated to be set
for general motions court. With utmost respect to Judge Dellaveccia, he is not
Motions Court judge this week and thus the optics of your conduct do him no
favor. Furthermore, you violate and circumvent every rule of civil procedure
governing process, means of service, false certifications, knowingly false
representations, failing to attach the writings you claim support your utterly
deficient excuse for a complaint. which is disfavored by the Courts. Your
complaint is an insult to the integrity of the court. Furthermore, this would
obviously be a contested motion yet I am not afforded even that much due process
because apparently you do not have to comply the rules of court in Allegheny
county.
For you, to leverage your knowledge, sophistication, resources, and insider status
against pro se, disabled former public servant who has little to no state court
experiences is the epitome of abuse of process among particularly in the context
of ex parte relief With respect to your scurrilous, defamatory vicious predatory
lawsuit, the evidence speaks for itself. Overall, the above described conduct
forms the basis for disciplinary investigation for violation of various Rules of
Professional Responsibility including : Rule 1.16(a)(1) - A lawyer is prohibited -
from representing a client if the representation will result in violation of the Rules
of Professional Conduct or other law; RPC 8.4(a) — A lawyer is prohibited from
violating or attempting to violate the Rules of Professional Conduct, knowingly
assist or inducing another to do so, or do so through the acts of another; RPC
8.4(b) A lawyer is prohibited from committing a criminal act that reflects
dishonesty, a lack of trustworthiness or fitness as a lawyer; RPC 8.4 (c) — A
lawyer is prohibited from engaging in conduct involving misrepresentation; RPC
8.4 (d) —- A lawyer is prohibited from engaging in conduct that is prejudicial to
the administration of justice; RPC 8.4(e) — A lawyer is prohibited from
exercising, stating, or implying an ability to improperly influence a government
agency or official or to receive results by means that violate the Rules of
Professional Conduct or other law; RPC 8.4 (f) — A lawyer is prohibited from
recklessly or knowingly assisting a judge or judicial officer in conduct that is a
violation of applicable rules of judicial conduct or other law, RPC 5.5(a) — A
lawyer is prohibited from practicing law in a jurisdiction in violation of the
regulation of that jurisdiction (Goldberg); and PC 5.5(b)(2) — A lawyer who is
not admitted to practice in this jurisdiction is prohibited from holding out to the
public as being admitted to practice law in this jurisdiction (and from aiding and
abetting the same).
Each of you and others known and not known are at least subject to individual
and joint liability to the estate on multiple fronts including but, not limited, to
violations of common law fraud, conspiracy, defamation, libel, intentional
infliction of emotional distress, violations of the Fair Debt Collection Practices
Act, 15 U.S.C. § 1692 et seq. violations of 66 Pa. C.S.A.§ 1313) (Price upon
resale of public utility service); Pennsylvania Fair Credit Extension Uniformity
Act, 73 Pa.Stat. Ann. § 2270 et seq.; the Pennsylvania Unfair Trade Practices and
Consumer Protection Law, 73 Pa. Stat. Ann. § 201–1 et seq. fraud by deception,
Punitive damages are expressly permitted under the UCA and the UPCA for a
EvE_000260
willful violation of the statute. See UCA § 3412 and UPCA § 5412. Under the
ILSFDA penalties may be imposed for willful violations, including criminal
penalties of up to a $10,000 fine, or up to five (5) years of imprisonment, or both,
and civil penalties of up to $1,000 for each violation. Note, under the ILSFDA
civil penalties can be imposed on anyone who “knowingly and materially”
violates the act, and “knowingly” is defined to mean “having actual knowledge of
or acting with deliberate ignorance of or reckless disregard for the prohibitions”
of the act. See ILSFDA §§ 1717 and 1717(a). Furthermore per my emails of
December 2020, this association is mandated to address members' claims of
harassment on the basis of race, color, religion, national origin, sex, familial
status, and disability. This includes harassment by other residents, board
members, managers, and vendors. The law requires that boards take prompt steps
to investigate and end harassment. (Code of Fed. Reg. §100.7(a)(1)(iii).) You
collectively have escalated your harassment in response to my claims.
Accordingly, each and every one of you is subject to personal as well joint
liability for your utter disdain and disregard for the rights of particularly members
of protected classes, theft common law fraud, extortion, theft by deception,
criminal harassment, sales of harrassment, stalking (Goldberg), sales of
unregistered securities in violation of Section 5 of the Securities Act of 1933, as
well as potential Rico and Rico conspiracy liability in addition to control group
liability jointly and severally for all wrongful conduct of a controlled issuer or
entity under the applicable control theories of liability. I remind that
Pennsylvania recognizes the crime/fraud exception to attorney client. Clearly
you are on notice of anticipated litigation and are under a duty to preserve any all
relevant documents, material, etc. This email is the consequence of the pressure
and duress you impose upon me by your inexcusable conduct. I am not able to
appear today and I will seek an emergency, disability accommodation if
necessary. Should you proceed with this course of conduct and obtain a ex parte
injunction then so be it.. I will move to dissolve immediately. And I cannot all
evidentiary records due to volume, I will therefore follow up by separate email.
The attached documents speak for themselves but a screenshot of the contents
follows:
[cid:image001.png@01D709E5.2F4EE7A0]

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
and as such privileged and confidential and/or it may include attorney work
product. If you are not an intended recipient, you may not review, copy or
distribute this message. If you have received this communication in error, please
notify us immediately by e-mail and delete the original message and its
attachments from your computer system. Please be advised that no privileges are
EvE_000261
EvE_000262
To: Fred C Jug ; "Law Linda"; uvoneck@outlook.com
Subject: Re: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg
Date: Monday, February 22, 2021 11:02:27 AM
To All Concerned:
Please be informed that I will not be representing Ms. Von Eckartsberg and the Estate of Elsa
Von Eckarstberg in the above referenced case. My representation is limited to probating the
Estate. Thank you
From: Fred C Jug

To: 'Law Linda' ; uvoneck@outlook.com ; gusty-sunseri@verizon.net
Subject: RE: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg
Thank you Linda. I put this on my calendar.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
From: Law Linda <Linda.Law@alleghenycourts.us>

To: fjug@bmr-law.com; uvoneck@outlook.com; gusty-sunseri@verizon.net
Subject: GD 21-001293; Imperial House Condominium Association v Uta Von Eckartsberg
Importance: High
Good afternoon,
Argument on the Emergency Motion for Special Injunction in the above matter will be heard by
Judge Michael A. Della Vecchia on February 24, 2021, at 2:00 p.m. via telephone conference. To
access the argument, please call 1-877-953-7157 and enter conference code 416 7541#
Please feel free to email or call our chambers if you have any questions. We are continuing to work
EvE_000263
remotely, but do check voice mail regularly.
Linda Law, Secretary
(412) 350-0281
EvE_000264
To: Uta von Eckartsberg
Subject: Re: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got this. How long do I have to
respond; This injunction is a fraud on the Court.
I did not accept service for you or the Estate. I told him that I would have to speak with you to
see if I would be representing you in this. Given the nature of the allegation-potential
continuing water damage-I would suggest that you contact him. Or, if you want me to
represent you in this, I can contact him. Feel free to contact me.

To: Gusty Sunseri
Subject: FW: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got this. How long
do I have to respond; This injunction is a fraud on the Court.
What is the procedure on this? I want to file a motion for special injunction in response…..l;

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.

Cc: 'Uta von Eckartsberg' <uvoneck@outlook.com>; gusty-sunseri@verizon.net

1109 Grant Building
310 Grant Street
EvE_000265
Phone (412) 255-6500
Fax (412) 255-6504
EvE_000266
Rule 1531. Special Relief. Injunctions.

(a) A court shall issue a preliminary or special injunction only after written notice and hearing
unless it appears to the satisfaction of the court that immediate and irreparable injury will be
sustained before notice can be given or a hearing held, in which case the court may issue a
preliminary or special injunction without a hearing or without notice. In determining whether a
preliminary or special injunction should be granted and whether notice or a hearing should be
required, the court may act on the basis of the averments of the pleadings or petition and may
consider affidavits of parties or third persons or any other proof which the court may require.
Official Note
Section 601(b) of the Clean Streams Law, Act of June 22, 1937, P. L. 1987, 35 P. S. § §
691.601(b), relieves the Attorney General, the district attorney or the solicitor of a
municipality from the requirement of bond in injunction proceedings.
Section 7 of the Act of April 11, 1929, P. L. 488, No. 205, 3 P. S. § 297, relating to
certified, inspected or registered seeds, similarly provides that the Attorney General shall not
be required to give bond in injunction proceedings.
(b) Except when the plaintiff is the Commonwealth of Pennsylvania, a political subdivision or
a department, board, commission, instrumentality or officer of the Commonwealth or of a
political subdivision, a preliminary or special injunction shall be granted only if
(1) the plaintiff files a bond in an amount fixed and with security approved by the court,
naming the Commonwealth as obligee, conditioned that if the injunction is dissolved because
improperly granted or for failure to hold a hearing, the plaintiff shall pay to any person injured
all damages sustained by reason of granting the injunction and all legally taxable costs and
fees, or
(2) the plaintiff deposits with the prothonotary legal tender of the United States in an
amount fixed by the court to be held by the prothonotary upon the same condition as provided
for the injunction bond.
Official Note
See Rule 1549(4), (11), (13), (17), (20), (21) and Rule 1550(12), (13), (20), (21), (22), (25),
(26), (27), (29), (30) and (32) for reference to Acts of Assembly containing provisions
relieving the Commonwealth, political subdivisions, and their agencies from the requirement
of bond in injunction proceedings.
(c) Any party may move at any time to dissolve an injunction.
(d) An injunction granted without notice to the defendant shall be deemed dissolved unless a
hearing on the continuance of the injunction is held within five days after the granting of the
EvE_000267
injunction or within such other time as the parties may agree or as the court upon cause shown
shall direct.
Official Note
See subdivision (f) of this rule for special provisions relating to injunction restraining
freedom of expression.
If an injunction has been issued without notice, it is optional with the defendant to waive a
hearing on continuance of the injunction under this subdivision and proceed directly to a final
hearing.
(e) After a preliminary hearing, the court shall make an order dissolving, continuing or
modifying the injunction.
(f)(1) When a preliminary or special injunction involving freedom of expression is issued,
either without notice or after notice and hearing, the court shall hold a final hearing within
three days after demand by the defendant. A final order shall be filed in the office of the
prothonotary within twenty-four hours after the close of the hearing. If the final hearing is not
held within the three-day period, or if the final order is not filed within twenty-four hours after
the close of the hearing, the injunction shall be deemed dissolved.
Official Note
The three-day period is the maximum time. In particular cases a shorter period may be
required. The court is ‘‘always open for the transaction of judicial business.’’ See Section 324
of the Judicial Code, 42 Pa.C.S. § 324.
(2) When the defendant demands such a final hearing, no further pleadings shall be required
and Rule 1038(b) and (c) relating to decision in a trial without and Rules 227.1 to 227.3
relating to post-trial relief shall not apply.
(3) The trial judge shall file a written memorandum supporting the final order within five
days after it is filed.

To: Gusty Sunseri

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
EvE_000268
this message.


1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
EvE_000269
From: Gus Sunseri
No and no
Sent from my iPhone

wrote:

Did he call you? Do you know him?

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
and as such privileged and confidential and/or it may include attorney work product.
If you are not an intended recipient, you may not review, copy or distribute this
message. If you have received this communication in error, please notify us
immediately by e-mail and delete the original message and its attachments from your
computer system. Please be advised that no privileges are waived by the
transmission of this message.
From: Gusty A.E. Sunseri <gusty-sunseri@verizon.net>

To: Uta von Eckartsberg <uvoneck@outlook.com>
Subject: Re: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got
this. How long do I have to respond; This injunction is a fraud on the Court.
I did not accept service for you or the Estate. I told him that I would have to speak
with you to see if I would be representing you in this. Given the nature of the
allegation-potential continuing water damage-I would suggest that you contact
him. Or, if you want me to represent you in this, I can contact him. Feel free to
contact me.

To: Gusty Sunseri
Subject: FW: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got
EvE_000270
What is the procedure on this? I want to file a motion for special injunction in
response…..l;

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
and as such privileged and confidential and/or it may include attorney work product.
If you are not an intended recipient, you may not review, copy or distribute this
message. If you have received this communication in error, please notify us
immediately by e-mail and delete the original message and its attachments from your
computer system. Please be advised that no privileges are waived by the

Please find attached an Emergency Motion For Special Injunction and a Proposed
Order. The Proposed Order is provided in word format pursuant to the Standard
Operating Procedures of the Court. The Plaintiff would appreciate this matter
now be scheduled. The Motion has also been mailed to the Defendant and the
defendant is copied on this email. A courtesy copy is also being provided to
counsel for the estate who is also copied on this email as no appearance has been
entered yet in this case. Your attention to this matter is appreciated.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
This electronic message and any attachments transmitted with it contain

information that may be privileged and confidential. The information is intended
for the use of the intended recipients only. If you are not an intended recipient,
note that any disclosure, copying, distribution or use of the contents of this
message is prohibited. If you have received this message in error, please contact
the above sender and delete this message immediately.
EvE_000271
EvE_000272
Date: Friday, February 19, 2021 10:12:01 AM
Uta Do you want me to handle this for the Estate? Can end up costing the Estate $1500 to
$1800 plus Jug’s attorney fees. We definitely need to talk. Is there a leak in the place?

To: Gus Sunseri
Subject: Re: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got this. How long
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended recipient(s) and may contain
confidential and privileged information. If you are not the intended recipient, please do not read, distribute, or take
action in reliance upon the message. If you have received this message in error, please notify the sender
immediately by return e-mail and promptly delete this message and its attachments from your computer system. Be
On Feb 18, 2021, at 6:21 PM, Gus Sunseri <gusty-sunseri@verizon.net> wrote:
No and no
Sent from my iPhone
On Feb 18, 2021, at 6:14 PM, Uta von Eckartsberg <uvoneck@outlook.com> wrote:


412.207.7742(ph)
EvE_000273
301.461.7445 ©
724.631.5212 (fax)
DISCLAIMER: This e-mail message is intended only for the personal use
of the recipient(s) named above. This message may be an attorney-
client communication and as such privileged and confidential and/or it
may include attorney work product. If you are not an intended recipient,
you may not review, copy or distribute this message. If you have
received this communication in error, please notify us immediately by e-
mail and delete the original message and its attachments from your
computer system. Please be advised that no privileges are waived by
the transmission of this message.

Subject: Re: Imperial House Condominium v. Von Eckartsberg GD 21-
001293 I just got this. How long do I have to respond; This injunction is a
fraud on the Court.
I did not accept service for you or the Estate. I told him that I would
have to speak with you to see if I would be representing you in this.
Given the nature of the allegation-potential continuing water
damage-I would suggest that you contact him. Or, if you want me to
represent you in this, I can contact him. Feel free to contact me.

To: Gusty Sunseri
Subject: FW: Imperial House Condominium v. Von Eckartsberg GD 21-
001293 I just got this. How long do I have to respond; This injunction is a
fraud on the Court.
What is the procedure on this? I want to file a motion for special

injunction in response…..l;

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
DISCLAIMER: This e-mail message is intended only for the personal use
of the recipient(s) named above. This message may be an attorney-
client communication and as such privileged and confidential and/or it
may include attorney work product. If you are not an intended recipient,
you may not review, copy or distribute this message. If you have
received this communication in error, please notify us immediately by e-
mail and delete the original message and its attachments from your
computer system. Please be advised that no privileges are waived by
the transmission of this message.
EvE_000274
Cc: 'Uta von Eckartsberg' <uvoneck@outlook.com>; gusty-
sunseri@verizon.net
Please find attached an Emergency Motion For Special Injunction

and a Proposed Order. The Proposed Order is provided in word
format pursuant to the Standard Operating Procedures of the Court.
The Plaintiff would appreciate this matter now be scheduled. The
Motion has also been mailed to the Defendant and the defendant is
copied on this email. A courtesy copy is also being provided to
counsel for the estate who is also copied on this email as no
appearance has been entered yet in this case. Your attention to this
matter is appreciated.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
This electronic message and any attachments transmitted with it

contain information that may be privileged and confidential. The
information is intended for the use of the intended recipients only. If
you are not an intended recipient, note that any disclosure, copying,
distribution or use of the contents of this message is prohibited. If
you have received this message in error, please contact the above
sender and delete this message immediately.
EvE_000275
Date: Friday, February 19, 2021 4:19:04 PM
Uta I need to know if you want me to represent you in this. If so, we should probably do an
addendum to the engagement letter. Quite honestly, I do not see the harm in allowing them
limited access to the Condo to determine if origins of a leak are happening in that Condo. You
can save a ton of money with not paying me, or Jug’s potential attorney fees, by allowing me
to contact Jug and come to an agreement of giving them limited access ,for a limited time, to
determine the origin or lack of origin in that Condo of a leak. I need to know ASAP. Thanks We
need to talk.

Sent: Friday, February 19, 2021 3:49 PM
To: Gusty A.E. Sunseri
Gusty,
Did you notice that he is doing an end run around @ due process by filing an equity special injunction which means
that I get no due process whatsoever? And that even a special injunction proceeding must be filed with motions
court not with the Judge of your choosing? Special injunctive actions under 1531 are to preserve the status quo
once litigation has commenced. It is attached to a “heretofore” filed action. And absent a lien or dispute as to
ownership, it is well-settled that there is no jurisdiction for the Court to even entertain such an injunctive action.
Furthermore, would be a contested motion which required compliance with motions court practice as to filing.
Also, in case you didn’t notice he is not asking whether you will accept service on the baseless injunction but rather
he is trying to trick you or me to waive service on the several pages of paper attached to the PI motion loosely
described a “Complaint” for some cause of action not intensified, for possible damages related to the “BODs” year
long failure to remedy the leaking of the “electrical” vault into the basement which of course I am not even
minimally responsive for.
He also got someone to enter that baseless “complaint” which does not even minimally satisfy either rule of court
(no affidavit of service, no cover, no damages, etc.) as if he filed a day before the injunctive motion. And all of this is
simply so that he get before the Judge he knows will find for him and whom he obviously contacted directly as if
there were an existing litigation which there is not. And it evident from the fictitious complaint that they are
seeking damages. That is a contract based claim. Furthermore, they are adding me personally as defendant no
reason that they identify in their complaint.
I have no practice experience in Allegheny Court whatsoever so I am concerned that it is not you and Joe who are
pointing this stuff out to me.
He is seeking the extraordinary remedy of ex parte injunctive relief for a leak that by his count had been ongoing for
two weeks (Feb. 1). Again, four floors below me. I have no water leak, their offices right below me have no water
leak, the first floor of the garage has no water leak. This is abuse of process.
Furthermore, I gather that you are not taking my substantive concerns seriously. Arthur Goldberg is dangerous to
EvE_000276
me and he is stalking me. And I can prove that.
How is he allowed to simply circumvent requirements for service of a complaint?
At a bare minimum, can you demand he comply with regular motion practice and file a contested motion?
Three, what are the consequences of my not waiving service?
By the way, Goldberg literally is stalking me. I get emails, letters, phone messages almost every day. And I will
never negotiate with a target of my own investigations as if he had any illegitimacy whatsoever. And I just don’t do
dirty lawyers. I prosecute them. I have respect for the law that these people get paid to circumvent and abuse.
Four, I have zero interest in participating in a rigged proceeding. I would prefer to let them go forward and issue
the utterly baseless injunction for which this court has no jurisdiction and simply file an immediate appeal and
restraining order. What exactly are the steps for appealing a “special injunction” issued in equity and what is the
deadline? Who would hear the appeal?
Gusty, if you were taking me or my situation seriously I just don’t think your only response would be to treat this as
a typical, non-problematic proceeding when it is anything but that.
At this point, I would like to know the risks and benefits of the various courses of action that I may take at this time?
And I want to understand step by step how I comply with rules of court, deadlines, and filing requirements?
Do you have electronic versions of the Rules of Procedure or local rules or anything at all that I can rent from you?
Do you have any forms that I can use as templates for the various types of pleadings I have to make? I can rent
them.
I do not want to be forced into Court prematurely under these circumstances and I should not be. And Gusty, why
am I telling you all this stuff. You are a trial lawyer in Pennsylvania and you must deal with this stuff all the time.
Why am I telling you the difference between a regular injunction or one in equity? Did you know before this email
that he basically tried to trick me/you into waving service for the complaint?
You must understand Motion Court practice so why aren’t you pissed off that Jug is overtly circumventing
mandatory motions practice. I should have at least ten days notice. Even special injunctions have to be filed with
motion and have to comply with all pleading and certification requirements which Jug’s does not and would not be
accepted for motions court at this time.
And furthermore, jug and Goldberg also clearly violated the rules of professional conduct regarding communications
with a represented party given the self-serving request for you to accept service or waive on my behalf. Does any
of this misconduct strike you as even remotely offensive or concerning? I would really appreciate your thoughts on
this.
Thank you for your kind attention to these matters.
Uta
EvE_000277
to addelectrical vault issue 4 floors below me

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended recipient(s) and may contain
confidential and privileged information. If you are not the intended recipient, please do not read, distribute, or take
action in reliance upon the message. If you have received this message in error, please notify the sender
immediately by return e-mail and promptly delete this message and its attachments from your computer system. Be
On Feb 19, 2021, at 10:12 AM, Gusty A.E. Sunseri <gusty-sunseri@verizon.net> wrote:

Uta Do you want me to handle this for the Estate? Can end up costing the Estate
$1500 to $1800 plus Jug’s attorney fees. We definitely need to talk. Is there a leak
in the place?

To: Gus Sunseri
Subject: Re: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got
Good. Thanks.
EvE_000278
412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended recipient(s) and
may contain confidential and privileged information. If you are not the intended recipient, please do
not read, distribute, or take action in reliance upon the message. If you have received this message
in error, please notify the sender immediately by return e-mail and promptly delete this message
and its attachments from your computer system. Be advised that no privileges are waived by the
On Feb 18, 2021, at 6:21 PM, Gus Sunseri <gusty-sunseri@verizon.net> wrote:
No and no
Sent from my iPhone
On Feb 18, 2021, at 6:14 PM, Uta von Eckartsberg

<uvoneck@outlook.com> wrote:


412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
DISCLAIMER: This e-mail message is intended only for the

personal use of the recipient(s) named above. This
message may be an attorney-client communication and as
such privileged and confidential and/or it may include
attorney work product. If you are not an intended recipient,
you may not review, copy or distribute this message. If you
have received this communication in error, please notify us
immediately by e-mail and delete the original message and
its attachments from your computer system. Please be
advised that no privileges are waived by the transmission
of this message.

EvE_000279
Subject: Re: Imperial House Condominium v. Von
Eckartsberg GD 21-001293 I just got this. How long do I have
to respond; This injunction is a fraud on the Court.
I did not accept service for you or the Estate. I told him
that I would have to speak with you to see if I would be
representing you in this. Given the nature of the
allegation-potential continuing water damage-I would
suggest that you contact him. Or, if you want me to
represent you in this, I can contact him. Feel free to
contact me.

To: Gusty Sunseri
Subject: FW: Imperial House Condominium v. Von Eckartsberg
GD 21-001293 I just got this. How long do I have to respond;
This injunction is a fraud on the Court.
What is the procedure on this? I want to file a motion for

special injunction in response…..l;

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
DISCLAIMER: This e-mail message is intended only for the

personal use of the recipient(s) named above. This
message may be an attorney-client communication and as
such privileged and confidential and/or it may include
attorney work product. If you are not an intended recipient,
you may not review, copy or distribute this message. If you
have received this communication in error, please notify us
immediately by e-mail and delete the original message and
its attachments from your computer system. Please be
advised that no privileges are waived by the transmission
of this message.

Cc: 'Uta von Eckartsberg' <uvoneck@outlook.com>; gusty-
sunseri@verizon.net
Subject: Imperial House Condominium v. Von Eckartsberg
GD 21-001293
EvE_000280
Please find attached an Emergency Motion For Special
Injunction and a Proposed Order. The Proposed Order is
provided in word format pursuant to the Standard
Operating Procedures of the Court. The Plaintiff would
appreciate this matter now be scheduled. The Motion has
also been mailed to the Defendant and the defendant is
copied on this email. A courtesy copy is also being
provided to counsel for the estate who is also copied on
this email as no appearance has been entered yet in this
case. Your attention to this matter is appreciated.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
This electronic message and any attachments transmitted

with it contain information that may be privileged and
confidential. The information is intended for the use of
the intended recipients only. If you are not an intended
recipient, note that any disclosure, copying, distribution
or use of the contents of this message is prohibited. If
you have received this message in error, please contact
the above sender and delete this message immediately.
EvE_000281
From: Gus Sunseri
Date: Friday, February 19, 2021 4:32:25 PM
Go to Fifth Judicial District of Pennsylvania

Go to Civil
Motions and local rules are on the Civil Home page
Sent from my iPhone

wrote:
PS. Can you tell me how to access the court calendar? I want to know whether or
not Judge D. is set as motions court judge this week and next. I do not know how
to access the right calendar... thx

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended
recipient(s) and may contain confidential and privileged information. If you are
not the intended recipient, please do not read, distribute, or take action in reliance
upon the message. If you have received this message in error, please notify the
sender immediately by return e-mail and promptly delete this message and its
attachments from your computer system. Be advised that no privileges are waived

Gusty,
Did you notice that he is doing an end run around @ due process by
filing an equity special injunction which means that I get no due
EvE_000282
process whatsoever? And that even a special injunction proceeding
must be filed with motions court not with the Judge of your
choosing? Special injunctive actions under 1531 are to preserve the
status quo once litigation has commenced. It is attached to a
“heretofore” filed action. And absent a lien or dispute as to
ownership, it is well-settled that there is no jurisdiction for the Court
to even entertain such an injunctive action. Furthermore, would be a
contested motion which required compliance with motions court
practice as to filing.
Also, in case you didn’t notice he is not asking whether you will
accept service on the baseless injunction but rather he is trying to
trick you or me to waive service on the several pages of paper
attached to the PI motion loosely described a “Complaint” for some
cause of action not intensified, for possible damages related to the
“BODs” year long failure to remedy the leaking of the “electrical”
vault into the basement which of course I am not even minimally
responsive for.
He also got someone to enter that baseless “complaint” which does
not even minimally satisfy either rule of court (no affidavit of service,
no cover, no damages, etc.) as if he filed a day before the injunctive
motion. And all of this is simply so that he get before the Judge he
knows will find for him and whom he obviously contacted directly as
if there were an existing litigation which there is not. And it evident
from the fictitious complaint that they are seeking damages. That is a
contract based claim. Furthermore, they are adding me personally as
defendant no reason that they identify in their complaint.
I have no practice experience in Allegheny Court whatsoever so I am

concerned that it is not you and Joe who are pointing this stuff out to
me.
He is seeking the extraordinary remedy of ex parte injunctive relief

for a leak that by his count had been ongoing for two weeks (Feb. 1).
Again, four floors below me. I have no water leak, their offices
right below me have no water leak, the first floor of the garage has no
water leak. This is abuse of process.
Furthermore, I gather that you are not taking my substantive concerns

seriously. Arthur Goldberg is dangerous to me and he is stalking me.
And I can prove that.
How is he allowed to simply circumvent requirements for service of a

complaint?
At a bare minimum, can you demand he comply with regular motion

practice and file a contested motion?
EvE_000283
By the way, Goldberg literally is stalking me. I get emails, letters,
phone messages almost every day. And I will never negotiate with a
target of my own investigations as if he had any illegitimacy
whatsoever. And I just don’t do dirty lawyers. I prosecute them. I
have respect for the law that these people get paid to circumvent and
abuse.
Four, I have zero interest in participating in a rigged proceeding. I

would prefer to let them go forward and issue the utterly baseless
injunction for which this court has no jurisdiction and simply file an
immediate appeal and restraining order. What exactly are the steps
for appealing a “special injunction” issued in equity and what is the
deadline? Who would hear the appeal?
Gusty, if you were taking me or my situation seriously I just don’t

think your only response would be to treat this as a typical, non-
problematic proceeding when it is anything but that.
At this point, I would like to know the risks and benefits of the
various courses of action that I may take at this time? And I want to
understand step by step how I comply with rules of court, deadlines,
and filing requirements?
Do you have electronic versions of the Rules of Procedure or local

rules or anything at all that I can rent from you? Do you have any
forms that I can use as templates for the various types of pleadings I
have to make? I can rent them.
I do not want to be forced into Court prematurely under these

circumstances and I should not be. And Gusty, why am I telling you
all this stuff. You are a trial lawyer in Pennsylvania and you must
deal with this stuff all the time.
Why am I telling you the difference between a regular injunction or

one in equity? Did you know before this email that he basically tried
to trick me/you into waving service for the complaint?
You must understand Motion Court practice so why aren’t you pissed
off that Jug is overtly circumventing mandatory motions practice. I
should have at least ten days notice. Even special injunctions have to
be filed with motion and have to comply with all pleading and
certification requirements which Jug’s does not and would not be
accepted for motions court at this time.
And furthermore, jug and Goldberg also clearly violated the rules of
professional conduct regarding communications with a represented
party given the self-serving request for you to accept service or waive
on my behalf. Does any of this misconduct strike you as even
remotely offensive or concerning? I would really appreciate your
thoughts on this.
EvE_000284
Uta

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of
the intended recipient(s) and may contain confidential and privileged
information. If you are not the intended recipient, please do not read,
distribute, or take action in reliance upon the message. If you have
received this message in error, please notify the sender immediately
by return e-mail and promptly delete this message and its attachments
from your computer system. Be advised that no privileges are waived
On Feb 19, 2021, at 10:12 AM, Gusty A.E. Sunseri

<gusty-sunseri@verizon.net> wrote:

Uta Do you want me to handle this for the Estate? Can
end up costing the Estate $1500 to $1800 plus Jug’s
EvE_000285
attorney fees. We definitely need to talk. Is there a leak
in the place?

To: Gus Sunseri
Subject: Re: Imperial House Condominium v. Von Eckartsberg
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of
the intended recipient(s) and may contain confidential and privileged
received this message in error, please notify the sender immediately
by return e-mail and promptly delete this message and its
attachments from your computer system. Be advised that no
privileges are waived by the transmission of this message.
On Feb 18, 2021, at 6:21 PM, Gus Sunseri <gusty-

sunseri@verizon.net> wrote:
No and no
Sent from my iPhone
On Feb 18, 2021, at 6:14 PM, Uta von

Eckartsberg <uvoneck@outlook.com>
wrote:

Did he call you? Do you know
him?
EvE_000286
412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
DISCLAIMER: This e-mail

message is intended only for the
personal use of the recipient(s)
named above. This message may
be an attorney-client
communication and as such
privileged and confidential
and/or it may include attorney
work product. If you are not an
intended recipient, you may not
review, copy or distribute this
message. If you have received
this communication in error,
please notify us immediately by
e-mail and delete the original
message and its attachments
from your computer system.
Please be advised that no
privileges are waived by the
From: Gusty A.E. Sunseri <gusty-

sunseri@verizon.net>
Sent: Thursday, February 18, 2021
4:16 PM
<uvoneck@outlook.com>
Subject: Re: Imperial House
Condominium v. Von Eckartsberg
GD 21-001293 I just got this. How
long do I have to respond; This
injunction is a fraud on the Court.
I did not accept service for you

or the Estate. I told him that I
would have to speak with you
to see if I would be representing
you in this. Given the nature of
the allegation-potential
continuing water damage-I
would suggest that you contact
him. Or, if you want me to
represent you in this, I can
EvE_000287
contact him. Feel free to
contact me.

3:53 PM
To: Gusty Sunseri
Subject: FW: Imperial House
What is the procedure on this? I

want to file a motion for special

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

From: Fred C Jug <fjug@bmr-

law.com>
12:48 PM
To:
Civilgenmotions@alleghenycourts.us
Cc: 'Uta von Eckartsberg'
<uvoneck@outlook.com>; gusty-
EvE_000288
sunseri@verizon.net
Subject: Imperial House
GD 21-001293
Please find attached an

Emergency Motion For Special
Injunction and a Proposed
Order. The Proposed Order is
provided in word format
pursuant to the Standard
Operating Procedures of the
Court. The Plaintiff would
appreciate this matter now be
scheduled. The Motion has also
been mailed to the Defendant
and the defendant is copied on
this email. A courtesy copy is
also being provided to counsel
for the estate who is also copied
on this email as no appearance
has been entered yet in this
case. Your attention to this

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
This electronic message and any

attachments transmitted with it
contain information that may be
privileged and confidential.
The information is intended for
the use of the intended
recipients only. If you are not
an intended recipient, note that
any disclosure, copying,
distribution or use of the
contents of this message is
prohibited. If you have
EvE_000289
received this message in error,
please contact the above sender
and delete this message
immediately.
EvE_000290
Date: Monday, February 22, 2021 10:12:47 AM
Uta need to know he your exact position and terms on which you would allow an evaluation
of the condo.

To: Gus Sunseri
Subject: RE: Imperial House Condominium v. Von Eckartsberg GD 21-001293 I just got this. How long
Thanks.

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
this message.
From: Gus Sunseri <gusty-sunseri@verizon.net>

Go to Fifth Judicial District of Pennsylvania

Go to Civil
Motions and local rules are on the Civil Home page
Sent from my iPhone
On Feb 19, 2021, at 4:25 PM, Uta von Eckartsberg <uvoneck@outlook.com> wrote:
PS. Can you tell me how to access the court calendar? I want to know whether or not
Judge D. is set as motions court judge this week and next. I do not know how to access
the right calendar... thx
EvE_000291
412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the intended
recipient(s) and may contain confidential and privileged information. If you are not the
intended recipient, please do not read, distribute, or take action in reliance upon the
message. If you have received this message in error, please notify the sender
immediately by return e-mail and promptly delete this message and its attachments
from your computer system. Be advised that no privileges are waived by the

Gusty,
Did you notice that he is doing an end run around @ due process by filing
an equity special injunction which means that I get no due process
whatsoever? And that even a special injunction proceeding must be filed
with motions court not with the Judge of your choosing? Special
injunctive actions under 1531 are to preserve the status quo once
litigation has commenced. It is attached to a “heretofore” filed action.
And absent a lien or dispute as to ownership, it is well-settled that there is
no jurisdiction for the Court to even entertain such an injunctive action.
Furthermore, would be a contested motion which required compliance
with motions court practice as to filing.
Also, in case you didn’t notice he is not asking whether you will accept
service on the baseless injunction but rather he is trying to trick you or me
to waive service on the several pages of paper attached to the PI motion
EvE_000292
loosely described a “Complaint” for some cause of action not intensified,
for possible damages related to the “BODs” year long failure to remedy
the leaking of the “electrical” vault into the basement which of course I
am not even minimally responsive for.
He also got someone to enter that baseless “complaint” which does not
even minimally satisfy either rule of court (no affidavit of service, no
cover, no damages, etc.) as if he filed a day before the injunctive motion.
And all of this is simply so that he get before the Judge he knows will find
for him and whom he obviously contacted directly as if there were an
existing litigation which there is not. And it evident from the fictitious
complaint that they are seeking damages. That is a contract based claim.
Furthermore, they are adding me personally as defendant no reason that
they identify in their complaint.
I have no practice experience in Allegheny Court whatsoever so I am

concerned that it is not you and Joe who are pointing this stuff out to me.
He is seeking the extraordinary remedy of ex parte injunctive relief for a

leak that by his count had been ongoing for two weeks (Feb. 1). Again,
four floors below me. I have no water leak, their offices right below me
have no water leak, the first floor of the garage has no water leak. This
is abuse of process.
Furthermore, I gather that you are not taking my substantive concerns

seriously. Arthur Goldberg is dangerous to me and he is stalking me. And
I can prove that.
How is he allowed to simply circumvent requirements for service of a

complaint?
At a bare minimum, can you demand he comply with regular motion

practice and file a contested motion?
By the way, Goldberg literally is stalking me. I get emails, letters, phone
messages almost every day. And I will never negotiate with a target of my
own investigations as if he had any illegitimacy whatsoever. And I just
don’t do dirty lawyers. I prosecute them. I have respect for the law that
these people get paid to circumvent and abuse.
Four, I have zero interest in participating in a rigged proceeding. I would

prefer to let them go forward and issue the utterly baseless injunction for
which this court has no jurisdiction and simply file an immediate appeal
EvE_000293
and restraining order. What exactly are the steps for appealing a “special
injunction” issued in equity and what is the deadline? Who would hear
the appeal?
Gusty, if you were taking me or my situation seriously I just don’t think

your only response would be to treat this as a typical, non-problematic
proceeding when it is anything but that.
At this point, I would like to know the risks and benefits of the various
courses of action that I may take at this time? And I want to understand
step by step how I comply with rules of court, deadlines, and filing
requirements?
Do you have electronic versions of the Rules of Procedure or local rules or

anything at all that I can rent from you? Do you have any forms that I can
use as templates for the various types of pleadings I have to make? I can
rent them.
I do not want to be forced into Court prematurely under these

circumstances and I should not be. And Gusty, why am I telling you all
this stuff. You are a trial lawyer in Pennsylvania and you must deal with
this stuff all the time.
Why am I telling you the difference between a regular injunction or one in

equity? Did you know before this email that he basically tried to trick
me/you into waving service for the complaint?
You must understand Motion Court practice so why aren’t you pissed off
that Jug is overtly circumventing mandatory motions practice. I should
have at least ten days notice. Even special injunctions have to be filed
with motion and have to comply with all pleading and certification
requirements which Jug’s does not and would not be accepted for
motions court at this time.
And furthermore, jug and Goldberg also clearly violated the rules of
professional conduct regarding communications with a represented party
given the self-serving request for you to accept service or waive on my
behalf. Does any of this misconduct strike you as even remotely
offensive or concerning? I would really appreciate your thoughts on
this.
Uta
EvE_000294

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the exclusive use of the
intended recipient(s) and may contain confidential and privileged
received this message in error, please notify the sender immediately by
return e-mail and promptly delete this message and its attachments from
your computer system. Be advised that no privileges are waived by the
On Feb 19, 2021, at 10:12 AM, Gusty A.E. Sunseri <gusty-

sunseri@verizon.net> wrote:
EvE_000295

Uta Do you want me to handle this for the Estate? Can
end up costing the Estate $1500 to $1800 plus Jug’s
attorney fees. We definitely need to talk. Is there a leak
in the place?

To: Gus Sunseri
Subject: Re: Imperial House Condominium v. Von Eckartsberg
Good. Thanks.

412.207.7742 (PH)
301.461.7445 (C)
724.631.5212 (FAX)
This email message (and any attachments) is for the

exclusive use of the intended recipient(s) and may
contain confidential and privileged information. If you
are not the intended recipient, please do not read,
distribute, or take action in reliance upon the message. If
you have received this message in error, please notify
the sender immediately by return e-mail and promptly
delete this message and its attachments from your
computer system. Be advised that no privileges are
On Feb 18, 2021, at 6:21 PM, Gus Sunseri

<gusty-sunseri@verizon.net> wrote:
No and no
EvE_000296
Sent from my iPhone
On Feb 18, 2021, at 6:14 PM,

Uta von Eckartsberg
wrote:

Did he call you? Do you know
him?

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

From: Gusty A.E. Sunseri <gusty-

sunseri@verizon.net>
4:16 PM
Subject: Re: Imperial House
EvE_000297
I did not accept service for you

or the Estate. I told him that I
would have to speak with you
to see if I would be representing
you in this. Given the nature of
the allegation-potential
continuing water damage-I
would suggest that you contact
him. Or, if you want me to
represent you in this, I can
contact him. Feel free to
contact me.

3:53 PM
To: Gusty Sunseri
Subject: FW: Imperial House
What is the procedure on this? I

want to file a motion for special

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)

EvE_000298
From: Fred C Jug <fjug@bmr-

law.com>
12:48 PM
To:
Civilgenmotions@alleghenycourts
.us
Cc: 'Uta von Eckartsberg'
<uvoneck@outlook.com>; gusty-
sunseri@verizon.net
Subject: Imperial House
GD 21-001293
Please find attached an

Emergency Motion For Special
Injunction and a Proposed
Order. The Proposed Order is
provided in word format
pursuant to the Standard
Operating Procedures of the
Court. The Plaintiff would
appreciate this matter now be
scheduled. The Motion has also
been mailed to the Defendant
and the defendant is copied on
this email. A courtesy copy is
also being provided to counsel
for the estate who is also copied
on this email as no appearance
has been entered yet in this
case. Your attention to this

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
EvE_000299
This electronic message and any
attachments transmitted with it
contain information that may be
privileged and confidential.
The information is intended for
the use of the intended
recipients only. If you are not
an intended recipient, note that
any disclosure, copying,
distribution or use of the
contents of this message is
prohibited. If you have
received this message in error,
please contact the above sender
and delete this message
immediately.
EvE_000300
231 Pa. Code § 1531
Current through Register Vol. 51, No. 7, February 13, 2021

Rule 1531 - Special Relief. Injunctions
(a) A court shall issue a preliminary or special injunction
only after written notice and hearing unless it appears to
the satisfaction of the court that immediate and
irreparable injury will be sustained before notice can be
given or a hearing held, in which case the court may
issue a preliminary or special injunction without a
hearing or without notice. In determining whether a
preliminary or special injunction should be granted and
whether notice or a hearing should be required, the
court may act on the basis of the averments of the
pleadings or petition and may consider affidavits of
parties or third persons or any other proof which the
court may require.
(b) Except when the plaintiff is the Commonwealth of
Pennsylvania, a political subdivision or a department,
board, commission, instrumentality or officer of the
Commonwealth or of a political subdivision, a
preliminary or special injunction shall be granted only if
(1) the plaintiff files a bond in an amount fixed and with
security approved by the court, naming the
Commonwealth as obligee, conditioned that if the
injunction is dissolved because improperly granted or
for failure to hold a hearing, the plaintiff shall pay to any
person injured all damages sustained by reason of
granting the injunction and all legally taxable costs and
EvE_000301
fees, or
(2) the plaintiff deposits with the prothonotary legal

tender of the United States in an amount fixed by the
court to be held by the prothonotary upon the same
condition as provided for the injunction bond.
(c) Any party may move at any time to dissolve an

injunction.
(d) An injunction granted without notice to the defendant
shall be deemed dissolved unless a hearing on the
continuance of the injunction is held within five days
after the granting of the injunction or within such other
time as the parties may agree or as the court upon
cause shown shall direct.
(e) After a preliminary hearing, the court shall make an
order dissolving, continuing or modifying the injunction.
(f)
(1) When a preliminary or special injunction involving
freedom of expression is issued, either without notice or
after notice and hearing, the court shall hold a final
hearing within three days after demand by the
defendant. A final order shall be filed in the office of the
prothonotary within twenty-four hours after the close of
the hearing. If the final hearing is not held within the
three-day period, or if the final order is not filed within
twenty-four hours after the close of the hearing, the
injunction shall be deemed dissolved.
231 Pa. Code § 1531

To: Gusty Sunseri
EvE_000302

412.207.7742(ph)
301.461.7445 ©
724.631.5212 (fax)
your computer system. Please be advised that no privileges are waived by the transmission of this
message.

been mailed to the Defendant and the defendant is copied on this email. A courtesy copy is also
being provided to counsel for the estate who is also copied on this email as no appearance has
been entered yet in this case. Your attention to this matter is appreciated.

1109 Grant Building
310 Grant Street
Phone (412) 255-6500
Fax (412) 255-6504
EvE_000303

Exh Emails 2021 Feb 22 Thru 27 Sunseri Sham Injunction Etc Redact BN

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From: uvoneck@outlook.

Uta von Eckartsberg, Esq.

From: Uta von Eckartsberg

Uta von Eckartsberg, Esq.

From: Arthur Goldberg <artgoldberg@verizon.net>

From: Uta von Eckartsberg <uvoneck@outlook.com>

Uta von Eckartsberg, Esq.

From: Uta von Eckartsberg

Uta von Eckartsberg, Esq.

From: Gusty A.E. Sunseri

From: Fred C Jug

Fred C. Jug, Jr. Attorney

Fred C. Jug, Jr. Attorney

Fred C. Jug, Jr. Attorney

From: Uta von Eckartsberg <uvoneck@outlook.com>

From: Uta von Eckartsberg

Uta von Eckartsberg, Esq.

From: Arthur Goldberg <artgoldberg@verizon.net>

From: Uta von Eckartsberg <uvoneck@outlook.com>

Uta von Eckartsberg, Esq.

From: Uta von Eckartsberg

RPC 5.5(a) — A lawyer is prohibited from practicing law in a jurisdiction in violation of the

Uta von Eckartsberg, Esq.

Uta von Eckartsberg, Esq.

From: Uta von Eckartsberg

From: Uta von Eckartsberg

Uta von Eckartsberg, Esq.

From: Arthur Goldberg <artgoldberg@verizon.net>

From: Uta von Eckartsberg <uvoneck@outlook.com>

Uta von Eckartsberg, Esq.

From: Uta von Eckartsberg

RPC 5.5(a) — A lawyer is prohibited from practicing law in a jurisdiction in violation of the

Uta von Eckartsberg, Esq.

Fred C. Jug, Jr. Attorney

From: Fred C Jug <fjug@bmr-law.com>

Fred C. Jug, Jr. Attorney

Fred C. Jug, Jr. Attorney

From: Uta von Eckartsberg <uvoneck@outlook.com>

Uta von Eckartsberg, Esq.

From: Uta von Eckartsberg

From: Uta von Eckartsberg

Uta von Eckartsberg, Esq.

From: Arthur Goldberg <artgoldberg@verizon.net>

From: Uta von Eckartsberg <uvoneck@outlook.com>

Uta von Eckartsberg, Esq.

From: Uta von Eckartsberg

RPC 5.5(a) — A lawyer is prohibited from practicing law in a jurisdiction in violation of the

Uta von Eckartsberg, Esq.

Fred C. Jug, Jr. Attorney

Thank you Linda. I put this on my calendar.

Fred C. Jug, Jr. Attorney

From: Law Linda <Linda.Law@alleghenycourts.us>

Fred C. Jug, Jr. Attorney

From: Fred C Jug <fjug@bmr-law.com>

From: Arthur Goldberg <artgoldberg@verizon.net>

Uta von Eckartsberg, Esq.

On Feb 23, 2021, at 4:12 PM, Arthur Goldberg <artgoldberg@verizon.net> wrote:

From: Uta von Eckartsberg <uvoneck@outlook.com>

Uta von Eckartsberg, Esq.

From: Uta von Eckartsberg

Uta von Eckartsberg, Esq.

Uta von Eckartsberg, Esq.

On Feb 23, 2021, at 2:24 PM, Uta von Eckartsberg <uvoneck@outlook.com>