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IN THE UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA Russ Diamond,
individually and as Chair of : PACleanSweep, Inc.
and PACleanSweep, Inc., : In its own right and
on behalf of its members : Who are lawfully
entitled to vote in the May 16, : 2006 Primary
elections and its : candidates for public
office : Plaintiffs : :Docket
No: v.
:1:CV-06-0370 : Bob Nye, individually
and as owner and : Publisher of
uncleansweep.com and as an : Employee of the House
Republican Caucus : State Representative
John Doe, : individually and in his/her official capacity : as a State
Representative and member of the : House Republican
Caucus; : Senator John Doe, (R
) individually and in his/ : Her official capacity
as a State Senator; and : The Republican House
Caucus : Defendants :
JURY TRIAL DEMANDED FIRST AMENDED COMPLAINT INTRODUCTION Plaintiff Russ Diamond is a citizen of the United States residing in Annville, Lebanon County, Pennsylvania within the Middle District of Pennsylvania. Plaintiff, PACleanSweep, Inc. is a Pennsylvania political body and non profit corporation founded for the purpose of opposing the midnight pay raise of the Pennsylvania Legislature in July 2005 and fielding candidates in the 2006 Primary and General Elections. Plaintiff PACleanSweep, Inc. is headquartered and located in Annville, Lebanon County, Pennsylvania within the Middle District of Pennsylvania. Bob Nye, an employee of the House Republican Caucus, is the creator of the content of a website under the name of uncleansweep.com. the website was created in Lancaster and Dauphin Counties. Computers used for this purpose include those owned by Defendant Nye and the Pennsylvania House of Representatives. Senator John Doe and State Representative John Doe are also involved with the creation and publication of the defamatory statements on uncleansweep.com in a concerted effort to protect their public office. The website appears to have been created by the defendants on or about February 8, 2006. It was modified on February 9, 2006 using taxpayer paid computers and will Mr. Nye was on the time clock for the House Republican caucus. Notice of the web site being launched went out in the early morning hours of February 11, 2006. The timing of the launch was to coincide with the nomination petition gathering that was to commence on February 14, 2006. Nye and others published a page which clearly links PACleanSweep, Inc. and Russ Diamond with the fraud and criminal activities of the Enron Corporation and its Chairman Ken Lay. The implication is crystal clear, PACleanSweep, Inc. is a criminal enterprise and Russ Diamond is a criminal. JURISDICTION AND VENUE 1. The court’s jurisdiction is found at 42 U.S.C. § 1983 and § 1985. Venue is properly in the Middle District of Pennsylvania as established by the facts below. PARTIES 2. Plaintiff Russ Diamond is a citizen of the United States residing in Annville, Lebanon County, Pennsylvania within the Middle District of Pennsylvania. Diamond is also the chairman of PACleanSweep, Inc. 3. Plaintiff, PACleanSweep, Inc. is a Pennsylvania non profit corporation founded in 2005 for the purpose of opposing the midnight pay raise of the Pennsylvania Legislature in July, 2005. Plaintiff is also located in Annville, Lebanon County, Pennsylvania within the Middle District of Pennsylvania. 4. Bob Nye, the author of the content of a website owned and operated by him under the name of uncleansweep.com, resides at 683 Rockwood Drive, Elizabethtown, Lancaster County, Pennsylvania and has an office in room 329 Ryan Office Building in the State Capitol, Harrisburg, within the Middle District of Pennsylvania. Nye was employed as an operative by the Republican National Committee in Washington, D.C. and is currently employed by the Pennsylvania House Republican Caucus in Harrisburg. 5. State Senator John Doe ( R) and State Representative John Doe ( R) are public officials with offices at the State Capitol, Harrisburg, Pennsylvania, within the Middle District of Pennsylvania, who are acting in concert with Defendant Bob Nye to publish uncleansweep.com. 6. The House Republican Caucus is a
political entity composed of all
Republican members of the Pennsylvania House of Representatives with offices in
the Ryan Office Building on the grounds of the State Capitol in Harrisburg,
Dauphin County, Pennsylvania. FACTS 6. On February 8, 2006 Defendant
Nye began to create a website with the address www.uncleansweep.com (See Exhibit A attached hereto),
utilizing a computer with an IP address 69.137.26.73. (See Exhibit B attached hereto). 7. On February 9, 2006, Defendant
Nye accessed the website uncleansweep.com, only this time, he used a computer
with the IP address 192.216.120.25. (See Exhibit B attached hereto). 8. The computer with the IP address 69.137.26.73 is located in Lancaster County. 9. The computer with the IP address
192.216.120.25 is located in the House of Representatives in
Harrisburg, Dauphin County and more specifically the Ryan Office Building where
Defendant Nye has an office in room 329.
(See Exhibit C attached hereto). 10. On February 10, 2006, more construction work was performed on the website. 11. In the early morning hours of February 11, 2006 an email barrage was sent around the Commonwealth announcing the website. (See Exhibit B). Shortly thereafter Defendants published pages which link Plaintiffs with the criminal conduct of Enron Corporation and Ken Lay. (See Exhibit D attached hereto). 12. The website was launched just prior to the beginning of the crucial and onerous election petition signature period which commenced on February 14 and ended on March 7, 2004. 13. The primary targets of the web page content were Pennsylvania voters, the May 16 Pennsylvania primary, Pennsylvania print and electronic media, PACleanSweep’s efforts to recruit candidates and Russ Diamond. 14. Upon information and belief, Defendants in fact entertained serious doubts as to the truth of the publication. 15. Upon information and belief, Defendants wrote the ad copy and then authorized and paid for the publication of the web pages containing numerous reckless, malicious and unsubstantiated falsehoods relating to Russ Diamond and PACleanSweep, Plaintiffs herein. 16. Among the numerous reckless, malicious and unsubstantiated falsehoods contained therein were the following statements and pictures: A. that Plaintiff Russ Diamond improperly and unethically used PACleanSweep funds for his personal use; (embezzlement) B. that Plaintiff Russ Diamond and PACleanSweep are fraudulently accounting for money raised and spent in their efforts regarding the pay raise; (fraud) C. that Plaintiff Russ Diamond is a criminal involved in schemes similar to the infamous Enron Corporation; (criminal fraud) D. that Russ Diamond was handcuffed and under arrest for criminal activity. E. that Russ Diamond and PACleanSweep regularly associate with thieves, crooks and liars; F. that PACleanSweep and Russ Diamond are involved in a Racketeer Influenced and Corrupt Organizations (RICO) enterprise, (criminal conspiracy) and G. that PACleanSweep is synonymous with the infamy and criminality of Enron Corporation. 17. Defendants’ web pages regarding Plaintiffs herein were made with knowledge that such statements were false and/or with reckless disregard for the truth of same, and defendant acted with malice and wanton disregard of the rights of Plaintiffs. 18. Defendants knew at all relevant times that all of the false and defamatory statements, suggestions, misstatements, innuendos, insinuations and inferences in Defendants website were false. 19. Defendants maliciously and recklessly published the aforementioned statements, suggestions, misstatements, innuendos, insinuations and inferences in Defendants website with outrageous and reckless disregard for the truth. 20. Defendants falsely imputed to Plaintiffs a course of criminal and/or other misconduct and injured Plaintiffs in their profession and otherwise. 21. Defendants’ false statements and their implications that PACleanSweep and Russ Diamond are libelous, per se. 22. Libel is not a form of protected speech under the First Amendment. 23. Under Pennsylvania law, “a person commits an offense if he applies or disposes of property that has been entrusted to him as a fiduciary, or property of the government or of a financial institution, in a manner which he knows is unlawful and involves substantial risk of loss or detriment to the owner of the property or to a person for whose benefit the property was entrusted.” 18 Pa. C. S.A. § 4113. 24. Under Pennsylvania law, “a person is guilty of bribery, a felony of the third degree, if he offers, confers or agrees to confer upon another…any pecuniary benefit as consideration for the decision, opinion, recommendation, vote or other exercise of discretion as a public servant…by the recipient…” 18 Pa. C.S. § 4701(a)(1). 25. Under Pennsylvania law, “a person is guilty of bribery, a felony of the third degree, if he offers, confers or agrees to confer upon another…any benefit as consideration for a violation of a known legal duty as public servant…” 18 Pa. C.S. § 4701(a)(3). 26. Under Pennsylvania law, “a person is guilty of conspiracy with another person or persons to commit a crime if the intent of promoting or facilitating its commission he…agrees with such other person or persons that they or one or more of them will engage in conduct which constitutes such crime or an attempt or solicitation to commit such crime…” 18 Pa. C.S. § 903(a)(1). 27. Under Pennsylvania law, “a person is guilty of conspiracy with another person or persons to commit a crime if the intent of promoting or facilitating its commission he…agrees to aid such other person or persons in the planning or commission of such crime or of an attempt or solicitation to commit such crime more of them will engage in conduct which constitutes such crime or an attempt or solicitation to commit such crime…” 18 Pa. C.S. § 903(a)(2). 28. Neither a political campaign nor an Internet political blog nor “political commentary” offers justification or privilege to malicious publish falsehoods about Plaintiffs. 29. The Pennsylvania Constitution, Article 1, DECLARATION OF RIGHTS, states, inter alia, “The free communication of thoughts and opinions is one of the invaluable rights of man, and every citizen may freely speak, write and print on any subject, being responsible for the abuse of that liberty.” (Emphasis added). 30. Defendants have irresponsibly abused their liberty and injured Plaintiffs’ good names and professional reputations. 31. On or about March 9, 2006, Counsel for Mr. Nye filed a Motion to dismiss Plaintiffs’ Complaint. 32. In support of the motion, Mr. Nye and his counsel proffered a Declaration of Robert R. Nye, Jr. wherein he sates under penalty of perjury, inter alia, that “4. No one other than me participated in the creation and writing of the website. 5. All of my work on the website was done at my home in Elizabethtown, Lancaster County, Pennsylvania, on my personal computer. and 6. None of the work I did for the website was performed anywhere other than my home, on my personal computer.” See Exhibit E attached hereto. 33. Defendant Nye’s declaration appears to be less than candid with the Court. See Exhibits B & C and paragraphs 6 through 10, supra. 34. The multiple IP computer numbers and their locations suggest that Mr. Nye worked on the website at his home and at his office in Harrisburg and worked with the assistance of his colleagues in the House Republican Caucus on the third floor of the Ryan Office Building. This work was done while Defendant Nye and his colleagues were being paid with taxpayer funds and using government equipment for purely political, illegal and malevolent purposes with the full intent to disrupt the ability of PACleanSweep candidates in the petitioning process thereby disrupting the May 16 Primary election and with the full knowledge of his superiors in the House Republican Caucus. 35. The blatant misuse of government property, specifically a computer owned by the Pennsylvania House of Representatives bearing the IP number 192.216.120.25 and located in the House of Representatives in Harrisburg, Dauphin County, more specifically the Ryan Office Building by government employees doing the bidding of their political masters in the Pennsylvania House Republican Caucus suggests state action for purposes of this matter. COUNT ONE- DEFAMATION, LIBEL AND FALSE LIGHT REPRESENTION 36. Plaintiffs incorporate paragraphs 1 to 35 as if set forth fully herein. 37. Plaintiffs’ reputations are damaged daily by Defendants’ publications which commenced on or about February 8, 2006 and continue to this day. 38. Plaintiffs’ reputations are damaged by the false light with which the Defendants’ words and pictures portray them as criminals. 39. Plaintiffs reputations are damaged by the libelous nature of the words and pictures which clearly suggest crimes are being committed by Plaintiffs and the obvious negative implications of Enron’s criminality placed upon them in particular. 40. Defendants’ aforementioned statements, suggestions, misstatements, innuendos, insinuations, pictures and the inferences therefrom published in their web pages are defamatory and libelous, per se in that they falsely attribute criminal, unethical, immoral and improper conduct to Plaintiffs and published by defendants with the knowledge of their falsity and/or with reckless disregard as to their truth or falsity. WHEREFORE, Plaintiffs demand judgment against all Defendants, individually and jointly and severally for compensatory damages in excess of $150,000 and punitive damages and the costs of this action. COUNT TWO- VIOLATION OF CIVIL RIGHTS OF
PLAINTIFFS 41. Plaintiffs incorporate paragraphs 1 to 40 as if set forth fully herein. 42. Defendant Bob Nye, in agreement with and at the direction of Defendants State Senator John Doe and/or State Representative John Doe and/or Defendant House Republican Caucus, individually and in their official capacities as elected state officials have defamed, libeled and painted Plaintiffs in a false light by comparing them with the criminal misdeeds of Enron Corporation and Kenneth Lay. 43. All Defendants knew, at all relevant times that all of the statements, suggestions, misstatements, innuendos, insinuations and inferences in the uncleansweep.com web pages were false and defamatory. 44. Defendants maliciously and recklessly published the aforementioned statements, suggestions, misstatements, innuendos, insinuations and inferences in the uncleansweep.com web pages with outrageous and reckless disregard for the truth. 45. Defendants have performed this character assassination of Plaintiffs hoping to effect the voting in the May 16 Pennsylvania Primary for various state offices including State Senator and State Representative where PACleanSweep has fielded over 81 candidates in opposition to Defendant elected officials and their cohorts. 46. Defendant elected state officials using and misusing the power of their offices and taxpayer funds, under color of state law, impermissibly interfere with Plaintiff PACleanSweep’s candidates s’ right to vote, PACleanSweep’s ability to field candidates for election to public office, PACleanSweep’s candidates’ ability to circulate and file nomination petitions in certain Republican Party Primaries, run for public office, free speech and equal protection of the law under both the Pennsylvania and United States Constitutions. WHEREFORE, Plaintiff demands a trial by jury and judgment from the Court as follows: 1. Find in favor of Plaintiffs against Defendants and award compensatory damages in excess of $150,000.00 and punitive damages. 2. Order Defendant s to pay an award of attorney fees and costs to plaintiffs pursuant to the authority under 42 U.S.C. Section 1988(b). 3. Order any other relief deemed reasonable and appropriate by the Court. COUNT THREE- CONSPIRACY TO VIOLATE PLAINTIFFS’ CIVIL RIGHTS 47. Plaintiffs incorporate paragraphs 1 to 46 as if set forth fully herein. 48. A conspiracy is a combination or agreement of two or more persons to accomplish some unlawful purpose, impermissibly interfering with Plaintiff PACleanSweep’s members, supporters and candidates’ right to vote, PACleanSweep’s ability to field candidates for election to public office, PACleanSweep’s candidates’ ability to circulate and file nomination petitions in certain Republican Party Primaries, run for public office, free speech and equal protection of the law under both the Pennsylvania and United States Constitutions. 49. All defendants acted in a manner, positively or tacitly, and reached a mutual understanding to try to accomplish a common and unlawful plan to save the seats of Republican office holders in the Pennsylvania House and Senate and impermissibly interfere with Plaintiff PACleanSweep’s candidates’ right to vote, PACleanSweep’s ability to field candidates for election to public office, PACleanSweep’s candidates’ ability to circulate and file nomination petitions under the laws of the Commonwealth known as the Election code in certain Republican Party Primaries, run for public office, free speech and equal protection of the law under both the Pennsylvania and United States Constitutions by publishing a website with false and libelous information for the purpose of interfering with lawful political activity of PACleanSweep candidates. 50. Defendant Nye, and as yet unnamed other state officials, conspired to go upon the Internet highway, anonymously and in disguise, as uncleansweep.com, to create a malicious website that defamed Plaintiffs, interfered with their civil and constitutional rights to vote, equal protection of the law and injured their good names. 51. Defendant Nye, and as yet unnamed other state officials, conspired to prevent by intimidation and threat through the website uncleansweep.com, Plaintiffs as citizens who are lawfully entitled to vote and advocate in a legal manor in favor of candidates for state and federal office in the May 16, 2006 Primary election. 52. Nye conspired with officials in the Pennsylvania House of Representatives and Pennsylvania Senate in the creation of the web attack on Plaintiffs. In furtherance of the conspiracy they utilized computers and other electronic equipment, specifically computers or hand held Blackberries which utilized IP addresses192.216.120.27 (House) and 170.47.14.146; 170.47.4.2; 170.47.5.5; 216.157.112.2 (Senate) on February 11, 2006 before it became common knowledge that the website uncleansweep.com existed. See Exhibits B & C. 52. In any case of conspiracy set forth in 42 U.S.C. § 1985, if one or more persons engaged therein do, or cause to be done, any act in furtherance of the object of such conspiracy, whereby another is injured in his person or property, i.e., defamation, or deprived of having and exercising any right or privilege of a citizen of the United States, i.e., the right to vote, the party so injured or deprived may have an action for the recovery of damages occasioned by such injury or deprivation, against any one or more of the conspirators. WHEREFORE, Plaintiff demands a trial by jury and judgment from the Court as follows: 1. Find in favor of Plaintiffs against Defendants and award compensatory damages in excess of $150,000.00 and punitive damages. 2. Order Defendant s to pay an award of attorney fees and costs to plaintiffs pursuant to the authority under 42 U.S.C. Section 1988(b). 3. Order any other relief deemed reasonable and appropriate by the Court. Respectfully submitted, ________________________________ LAWRENCE M. OTTER, ESQUIRE ATTORNEY FOR PLAINTIFFS Attorney ID No: 31383 PO BOX 2131 Doylestown, PA 18901 215-230-5330 215-230-7197(fax) email: larryotter@hotmail.com
EXHIBIT A EXHIBIT B UNCLEANSWEEP LOG HIGHLIGHTS LISTING
COMPUTER IP ADDRESSES AND INTERSTATE AND INTRASTATE ACTIVITIES RELATED TO
UNCLEANSWEEP.COM UNCLEANSWEEP LOG HIGHLIGHTS
69.137.26.73 - -
[08/Feb/2006:21:45:27 -0700] "GET / HTTP/1.1" 200 12443 "-"
"Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.7.12) Gecko/20050915
Firefox/1.0.7 (ax)" 69.137.26.73 is likely
Nye’s home computer; connected through Comcast.
69.137.26.73 -
bnye76 [11/Feb/2006:09:11:37 -0700] "GET /stats HTTP/1.1" 401 486
"http://app3.websitetonight.com/controlpanel/default.aspx"
"Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.8.0.1)
Gecko/20060111 Firefox/1.5.0.1" Same computer checking website statistics using godaddy.com services. 64.12.116.9 - -
[08/Feb/2006:21:47:08 -0700] "GET / HTTP/1.0" 200 12407 "-"
"Mozilla/4.0 (compatible; MSIE 6.0; AOL 9.0; Windows NT 5.0;
Q312461)" 64.12.116.xxx is an America Online server in New York; Nye likely checking to see how his work appears through AOL; classic webmaster tactic to make sure website appears the same to all viewers. 192.216.120.25 - -
[09/Feb/2006:08:05:33 -0700] "GET / HTTP/1.1" 200 13252 "-"
"Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.0; FunWebProducts; .NET
CLR 1.1.4322)" 192.216.120.25 - -
[10/Feb/2006:05:56:01 -0700] "GET /images/nav/button_vfgy.png
HTTP/1.1" 200 680
"http://www.uncleansweep.com/The_Real_Russ.html" "Mozilla/4.0
(compatible; MSIE 6.0; Windows NT 5.1; .NET CLR 1.1.4322)" 192.216.120.25
with multiple listings throughout a two day period. 192.216.120.25 listed as
Harrisburg PA – House of Representatives. 192.216.120.25 - -
[12/Feb/2006:10:37:08 -0700] "GET / HTTP/1.1" 200 13596 "-"
"Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.0; .NET CLR
1.1.4322)" 68.80.161.102 - -
[09/Feb/2006:08:04:19 -0700] "GET / HTTP/1.0" 200 13216
"http://www.google.com/search?hl=en&lr=&q=www.uncleansweep.com&btnG=Search"
"Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR
1.1.4322)" 68.80.161.102 –
another Comcast server. 172.19.33.9 - -
[10/Feb/2006:23:49:14 -0700] "GET / HTTP/1.1" 200 13252 "-"
"Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; Maxthon; .NET CLR
1.1.4322)" 172.19.33.9 – not
sure, but could simply be some kind of relay server or domain agent. 200.122.153.250 - -
[10/Feb/2006:23:57:58 -0700] "GET / HTTP/1.1" 200 13252
"http://app3.websitetonight.com/publish/done.aspx" "Mozilla/5.0
(Windows; U; Windows NT 5.1; en-US; rv:1.8.0.1) Gecko/20060111
Firefox/1.5.0.1" 200.122.153.250 –
another like above? BEGINNING OF OTHER,
IDENTIFIABLE IP ACCESS – likely beginning of public distribution
70.105.215.83 - -
[11/Feb/2006:01:42:27 -0700] "GET / HTTP/1.1" 200 13596 "-"
"Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; FDM; .NET CLR
2.0.50727)" Pottsville PA
24.115.91.189 - -
[11/Feb/2006:02:40:48 -0700] "GET / HTTP/1.1" 200 13596 "-"
"Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR
1.1.4322)" Reading PA
199.224.82.192 - -
[11/Feb/2006:03:27:35 -0700] "GET / HTTP/1.1" 200 13596 "-"
"Mozilla/5.0 (Windows; U; Windows NT 5.1; en-US; rv:1.7.2) Gecko/20040804
Netscape/7.2 (ax)" Valley View PA
71.242.4.216 - -
[11/Feb/2006:03:58:00 -0700] "GET /styles.css HTTP/1.1" 200 5169
"http://www.uncleansweep.com/" "Mozilla/4.0 (compatible; MSIE
6.0; Windows NT 5.1; SV1)" Easton PA
205.201.4.34 - -
[11/Feb/2006:04:12:50 -0700] "GET /scripts/imageSwap.js HTTP/1.1" 200
1051 "http://www.uncleansweep.com/" "Mozilla/4.0 (compatible;
MSIE 6.0; Windows NT 5.1; SV1)" West Mifflin PA
Etc, etc, etc. ACCESS BY PA HOUSE OF REPRESENTATIVES IP ADDRESSES OTHER THAN 192.216.120.25 192.216.120.27 - -
[11/Feb/2006:05:02:37 -0700] "GET / HTTP/1.1" 200 13596 "-"
"Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR
1.0.3705)" ACCESS BY PA SENATE IP ADDRESSES 170.47.14.146 - - [11/Feb/2006:10:18:28 -0700] "GET / HTTP/1.0" 200 13560 "-" "BlackBerry7250/4.0.0 Profile/MIDP-2.0 Configuration/CLDC-1.1" 170.47.4.2 - - [11/Feb/2006:14:00:05 -0700] "GET / HTTP/1.0" 200 13560 "-" "Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1; .NET CLR 1.1.4322)" 170.47.5.5 - -
[13/Feb/2006:11:25:45 -0700] "GET /images/nav/button_wuyu_mouseover.png
HTTP/1.0" 404 1792 "http://www.uncleansweep.com/"
"Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.0)" 216.157.112.2 - -
[14/Feb/2006:13:53:06 -0700] "GET / HTTP/1.1" 200 13596 "-"
"Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; .NET CLR
1.1.4322)" ACCESS BY US
SENATE IP ADDRESSES 156.33.76.243 - -
[14/Feb/2006:12:10:19 -0700] "GET / HTTP/1.1" 200 13596 "-"
"Mozilla/4.0 (compatible; MSIE 6.0; Windows NT 5.1; SV1)"
EXHIBIT C WHOIS SEARCH RESULTS FOR COMPUTERS WITH
THE FOLLOWING IP ADDRESSES IP address
69.137.26.73 LANCASTER COUNTY IP address
192.216.120.25 PENNSYLVANIA HOUSE OF
REPRESENTATIVES IP address
192.216.120.27 PENNSYLVANIA HOUSE OF
REPRESENTATIVES IP address
170.47.14.146 PENNSYLVANIA SENATE IP address
170.47.4.2; PENNSYLVANIA SENATE IP address
170.47.5.5; PENNSYLVANIA SENATE IP address
216.157.112.2 PENNSYLVANIA SENATE
EXHIBIT D
EXHIBIT E | ||||||||||||||||||||||||||
