SPRAGUE SPRAGUE

Richard A. Spmguc, Esquire, (ID. 04266)
Joseph R. Fodraza, In, Esquire (ID. 53612)
William H. Trask, Esquire (1D. A 318229)
The Wellington Building, Suite 400

135 Snuin 19'" Street

Philadelphia, PA 19103

(215) 561-7681

Filed and Master: by the
office of Juan'u'nl xecords
23 JAN 2019 10:11: 
M. sum

Attorneys/gr 

 

HONORABLE DAYLIN LEACH
601 Suulh Henderson Road -- Suite 208
King ofI'russia, PA 19406

Plaintiff,
v.

CARA TAYLOR
--

Bani, PA 18014

and

GWEN SNYDER
--
Philadelphia, PA 19104

and
COLLEEN KENNEDY
--

Havenown, PA 19083

Defendants.

IN THE COURT 01" COMMON PLEAS
PHILADELPHIA COUNTY

CIVIL ACTION

Term:

No.

NOTICE TO DEFEND

NOTICE

You inve been sued in courL It you wixh Io defend
lglinst me claims sel form in me lollnwing pages,
you must [Ike mum wimin many (20) days oner
mu complaint and nolice are servcd. by entering .
Inca personally or by "(army and
filing in wnung wilh lhe mun your defenses or
objections die claims set forth nglinsl you. Vou
are warned um it you fail to do so die care may
proceed win-out you .nd a judgment may be
enlered nglinsl you by the cnurl without further

 

AVISO

Le hon demandnda . usted en la corte. Si usled quim
due-idem de esus demands: expurriu en in
paginns um. uned Ilene veinle (2n) din d:
piuo ui pmir de la {echa de I: demand: In
norincocion. Hm (an. amenmr um comparencil
escriu en penunl 0 con |ll| nbngadn entregar i.
cone en lorm. escriln sus defensn: in! objeclnnes .
In: dcmandas en tonlrd de su persona. Se. avisadn
que si uned no se defiende. In con: mini medians 
puede mminulr la demand. en comr- suyn sin

 

 

Case ID: 190102559

notice for any money claimed in the complaint of

for any other claim or relief

requested

by

the

plaintiff. You may lose rnoney or property or other
rights important to you.
You should tøke thís pøper to your løwyer øt once. If
you do not høve ø løwyer or cannot øfford one, go to
or telephone the office set forth below to find out
where you cøn get legal help.

Philadelphia Bar Association

Lawyer Referral
and Information Service
One Reading Center

Philadelphia, Pennsylvania 19107

(2ls) 238-ó333
TTY (21s) 4sr-6197

previo aviso o notificacion. Ademas, la corte puede
decider a favor del demandante y requiere que usted
cumpla con todas las provisiones de esta demanda.
Usted puede perder dinero o sus propiedades u otros
derechos importantes para usted.

Lleve ests demøndø ø un øbogødo immedíøtqmente. Si
no tíene øbogødo o sí no tíene el dínero suficíente de
pagar tøl semício. Vøyø en personø o lløme por teleþno
ø Iø oficína cuyø direccìon se encuentrø escrítø øbajo
pørø øveríguør donde se puede conseguír øsístencìø
legø1.

Asociacion De Licenciados
De Filadelfia
Servicio De Referencia E

Informacion Legal
One Reading Center
Filadelfiao Pennsylvani a 19107
(21s) 238-6333
TTY (21s) 4sL-6197

Case ID: 190102559

 SPRAGUE st SPRAGUE

Richard A. Sprague, Esquire (1.1). 04266)
Joseph R. Podraza, JI., Esquire (ID. 53612)
William H. Trask, Esquire (ID. at 318229)
The Wellington Building, Suite 400

135 South 19m Street

Philadelphia, PA 19103

 

 

 

(215) 56177681 Altomeysforplaimi/f
HONORABLE DAYLIN LEACH, 
501 South Henderson Road 7 Suite 208 IN THE COURT OF COMMON PLEAs
King of Prussia PA 19405, PHILADELPHIA COUNTY
Pluiml'fl, CIVIL ACTION
v. Term:

CARA TAYLOR No.
--
Eath, PA 18014

and 
GWEN SNYDER,
--

 

Philadelphia, PA 19104

and

COLLEEN KENNEDY

--
Havenown, PA 190831

 

 

Defendants.

 

 

I. INTRODUCTION

Defendants, jointly and severally, have combined to publish republish, and widely
disseminate a salacious and despicable falsehood about plaintiff that they know to be false. One
fabricator of the lie against plaintiffis an admitted liar and notorious perjurer. The other two cos

conspirators have shown a reckless disregard for the truth in gleefully republishing and

Case ID: 190102559

embellishing upon the serial liar's fabrication about plaintiff for the admitted purposes of
destroying plaintiffs reputation. cutting short his career in public service. and harassing and
harming his family. The three defendants have sought to achieve their goals by seeking to exploit
for their own malicious purposes an important political movement in order to broaden the
audience of their false claim among a trusting unknowing and unsuspecting public, to
wrongfully mobilize and incite unwitting accomplices against plaintiff. and to inflict maximum
harm on plaintiff and his family based on accusations they know to be false. The defendants
have openly admitted the sole purpose of their endeavor is to see plaintiffs "head" mounted as
"a trophy on their wall" regardless of truth and common decency. This action is brought to

champion the Lrulh and redress Ihe defendanls' malicious falsehood.

H. PARTIES

1. Plaintiff. the Honorable Daylin leach ("Leach") is an adult individual and citizen
of the Commonwealth of who maintains a business address at 601 South
Henderson Road, Suite 208. King of Prussia 19406. leach has served in the
Senate representing 17m senatorial district since 2009. and
previously was a member of the House of Representatives representing the 149'"
district from 2003 to 2009. Prior to 2003, Leach pmcticed law for 16 years and was an adjunct
professor at two colleges in He is married and the father of two children.

2. Defendant Cara Taylor. f/k/a/ Cam Kuhns ("Taylor") is an adult individual and

citizen of the Commonwealth of residing, upon information and belief. at 

Bath. 18014.

Case ID: 190102559

3. Defendam Colleen Kennedy ("Kennedy") is an adult individual and citizen of the
Commonwealth of residing upon informaiion and belief, at --
Havertown, 19083, who is a political and public policy expert.

4. Defendam Gwen Snyder ("Snyder") is an adult individual and citizen of the
Commonwealth of residing, upon informaiion and belief, at --

Philadelphia, 19104 is a selfrdescribed grassroots movement

strategist and previously accused an elderly man of sexual assault who later was acquitted of her

accusation following (rial in a court of law.
JURISDICTION AND VENUE

5. The Court has jurisdiction over all parties pursuant to 42 Pa.C.s. 5301.
5. Venue is proper in the Court of Common Pleas of Philadelphia County pursuant

to Rule of Civil Procedure 1006(c)( 1 

1v. FACTS
A. Taylor is an Admitted Perjurer Who has Fabricated Lies
About Leach
7. Defendam Taylor is an admitted and judicially determined perjurer and serial liar,

who has willingly conceded that she will lie without compunction to promote her personal
interest and agenda.

8. In sworn testimony in a court oflaw provided in 1992, Taylor has admitted that,
even as a young teenager, she was willing to repeatedly lie to obtain employment under false
pretenses, and would move from employer to employer to avoid detection. (N.T., Jun. 91 1992 at

p. 1:15721, hereto at Exhibil 

Case ID: 190102559

9.

As an adult, Taylor lied under oath at her mother’s 1992 trial for the attempted

murder of Taylor’s step-father. At the trial, Taylor falsely swore that she, not her mother, was
responsible for the attempted murder of Taylor’s step-father. (Id. at p. 5:18-23.)
10.

As a result, Taylor was charged by the Lehigh County District Attorney with

perjury and false swearing after the 1992 trial and later pleaded guilty to charges of felony
perjury and false swearing for which she was incarcerated. (See N.T., Apr. 15, 1999 at p. 7:1724, attached hereto at Exhibit “B.”)
11.

Indeed, during the original 1992 attempted-murder trial, Taylor made clear her

willingness to lie for her own benefit and for that of her mother, which admissions may have
contributed to the jury’s disregard for her false testimony and unanimous guilty verdict. (See,
e.g., N.T. Jun. 10, 1992 at pp. 92:25 – 93:7, Exhibit A.)
12.

Leach, criminal defense counsel in Taylor’s mother’s 1992 criminal trial, was an

early victim of Taylor’s stated willingness to lie in order to achieve her ends by any means.
13.

In neither her mother’s sentencing for attempted homicide, nor in her own

sentencing for perjury did Taylor allege any unethical or inappropriate conduct on the part of
Leach, despite the fact that allegations of such misconduct, if believed, would have potentially
helped both her and her mother avoid or shorten incarceration.
14.

At her sentencing for perjury, Taylor testified under oath that lying and

perpetrating a fraud on the court in her mother’s criminal trial was her idea alone.
15.

After Taylor’s mother was sentenced for attempted homicide, Leach no longer

had any involvement in her case, and had no further contact with either Taylor or her mother
outside of testifying at Taylor’s mother’s 1999 post-conviction proceedings.

 

4

Case ID: 190102559

 16.

Taylor’s mother unsuccessfully pursued the full gamut of direct appeal options for

seven years.
17.

Seven years after her trial, in 1999, during post-conviction proceedings to

challenge the conviction for the attempted murder of Taylor’s step-father, and in an effort to
secure her release from prison, Taylor’s mother filed a Post Conviction Relief Act (“PCRA”)
Petition which fabricated a story of an improper, one-time years-earlier sexual encounter
between Taylor and Leach as a ground for overturning her mother’s 1992 conviction.
18.

Despite the allegations in the Petition, when afforded the opportunity in 1999 to

testify under oath in a court of law, Taylor declined, and her mother agreed to voluntarily
withdraw Taylor’s false and salacious allegation against Leach rather than see Taylor face the
prospect of a second perjury conviction with an accompanying longer prison sentence. (N.T.,
Apr. 15, 1999 at pp. 6:12 – 8:20, Exhibit B.)
19.

Taylor and her mother withdrew the false and defamatory allegation, despite the

court making it clear that they would be forever waiving the opportunity to gain any benefit that
the false allegation might afford them.
20.

Taylor’s mother even opined on the record at the April 15, 1999 court proceeding

that she was voluntarily withdrawing the false allegation of improper conduct against Leach by
Taylor because her daughter, Taylor, was a convicted perjurer whose fabrications could not be
believed. (Id. at p. 8:6-8.)
21.

Despite the fact that the false and salacious allegation was withdrawn by Taylor

and her mother, Leach voluntarily testified at the hearing that he had no physical relationship
with Taylor at any time. He so testified under oath, something Taylor refused to do at that same
hearing. (Id. at p. 53:11-20.)

 

5

Case ID: 190102559

 22.

Moreover, Taylor’s false testimony and subsequent guilty pleas on the charge of

perjury and false swearing were widely reported in the contemporaneous media.
23.

For example, the November issue of The Morning Call reported that Taylor

would “spend 30 days in jail for lying when she testified in her mother’s Lehigh County trial,”
and although “[n]ot everyone who fibs in court is charged with perjury, [Taylor’s] lie was one of
‘monstrous proportions.’” (Debbie Garliki, Woman gets jail term for lying at mom’s trial, THE
MORNING CALL, Nov. 13, 1993, p. 91, attached hereto as Exhibit “C.”)
B.

The Defendants Weaponize and Embellish Taylor’s Knowingly
False Accusation

24.

Kennedy volunteered a number of times on Leach’s Congressional campaign of

25.

At the conclusion of the 2014 campaign, Leach and Kennedy parted on good

2014.

terms, with Kennedy posting friendly and positive messages on Leach’s social media accounts.
To Leach’s knowledge, he and Kennedy have never been in the same room together or
communicated in person again.
26.

Leach has, to his knowledge, never personally met, or spoken to, Snyder.

27.

Leach’s first became aware of the existence of Snyder when she began attacking

him on social media as “predatory,” an “abuser,” an “assaulter” and a “rapist.”
28.

During the course of the preceding year, Kennedy and Snyder, upon information

and belief, have become increasingly close associates of Taylor. In fact, it is believed and
therefore averred that the three defendants are in constant contact through social media and
regularly meet in-person.
29.

Kennedy and Snyder operate on the fringes of state and local politics and in

collaboration with Taylor, have recently taken to exploiting the energetic fervor of legitimate
 

6

Case ID: 190102559

 political activists to amplify their concerted attacks on Leach to advance their own private
ambitions and vindictive agendas.
30.

Now Kennedy and Snyder, using the inconsistent and demonstrably false

accusation of a known and convicted perjurer (Taylor), have dogged Leach continually with
outrageous accusations of sexual misconduct.
31.

At all times Kennedy and Snyder knew that Taylor was personally not credible

and that her claim of sexual misconduct by Leach was not credible. Nevertheless, Kennedy and
Snyder spread Taylor’s false allegation against Leach despite Taylor’s known long history of
lying and deceit, thereby acting in blatant and reckless disregard of the truth.
32.

And all three Defendants knew and have known that Taylor’s allegation of rape

against Leach is false before and at the time they nevertheless decided to recklessly broadcast
Taylor’s false claim against Leach through the Internet and elsewhere.
33.

At all times relevant hereto, Snyder and Kennedy knew of Taylor’s felony

conviction in 1993 and of the withdrawal of her heinous and false allegation of improper conduct
by Leach under the threat of new perjury charges if this allegation was actually pursued before
the Court at the 1999 hearing.
34.

Nevertheless, despite having knowledge of the falsity of Taylor’s sexual-

misconduct claim against Leach, Snyder and Kennedy agreed to conspire with Taylor to extend
the public reach of Taylor’s false claims for the sole purpose of injuring Leach’s professional
and personal reputations and to shamefully subject him and his family to public ridicule and
scorn under false pretenses.
35.

By way of illustration, Taylor, who upon information and belief enjoyed the

support and encouragement of Snyder and Kennedy, maliciously published on her publicly

 

7

Case ID: 190102559

 accessible Facebook page her fabricated account of prior contact with Leach, stating repeatedly
beginning in February 2018 that Leach “drove [Taylor] to his apartment and sexually assaulted
[Taylor].” (Exhibit “D” at p. 6 of 7.)
36.

Thereafter, and throughout 2018, Taylor repeatedly published and republished her

false attacks on Leach as evidenced by a sampling thereof, a compilation of which is attached
hereto as Exhibit “E.”
37.

During this time, upon information and belief, Snyder and Kennedy encouraged

Taylor’s increasing dissemination of her knowingly false allegation against Leach while assisting
Taylor in expanding the reach of Taylor’s false attacks by separately republishing them online,
by appearing at public events to harass Leach about Taylor’s false claim, and by encouraging
others in person and over social media to take action against Leach based on Taylor’s knowingly
false allegation against Leach.
38.

Not only did Snyder and Kennedy republish Taylor’s false accusation against

Leach, they also incredibly embellished this false claim to better serve their own malicious
objectives.
39.

For instance, Snyder took to every corner of the Internet proclaiming as a

“confirmed” fact that Leach is a “rapist and a predator,” (Exhibit “F”) criticizing Leach’s
activities during the “MLK Day of Service” with a non sequitur “reminder” that “Daylin is
credibly accused of raping a 17 year old….” (Exhibit “G.”) Snyder made these false claims
against Leach knowing them to be false at the time of their making or with reckless disregard as
to the truthfulness of these claims predicated on Taylor’s made-up accusation against Leach.
40.

And at a recent protest march in Center City Philadelphia, Snyder lured a gaggle

of unsuspecting protestors off their route with her bullhorn, imploring her unwitting audience, on

 

8

Case ID: 190102559

 the basis of her knowingly false accusations, to contact Leach and demand that he resign (Exhibit
“H”) because “we’re done with rapists holding office.” (Exhibit “I.”) Snyder’s efforts, initially
directed at those physically present, were captured on video and rebroadcast over the Internet.
41.

Similarly, Kennedy, in an unsolicited response to a post announcing a public open

house appearance to discuss public health issues, announced she would not be attending Leach’s
open house because “He statutory raped [Taylor],” a factual representation which she knew and
knows is false. (Exhibit “J.”)
42.

Elsewhere and at other times Kennedy wrote with malice and/or reckless

indifference to the truth that “Daylin Leach sexually assaulted [Taylor] when she was 17 years
old” (Exhibit “K”), and accused Leach of “prey[ing] upon the most vulnerable.” (Exhibit “L.”)
43.

Emboldened by Snyder’s and Kennedy’s malicious advocacy, Taylor, by the fall

of 2018, had adopted not only her co-conspirators’ tactics but their rhetoric as well, increasingly
referring to Leach as “my rapist,” a knowingly false claim. (Exhibit “M.”)
44.

Not satisfied with confining these malicious attacks to the Internet and individuals

who could be physically reached at public gatherings, Taylor, with upon information and belief
the advice and encouragement of Snyder and Kennedy, fabricated a “private criminal complaint”
in November 2018 setting forth in salacious detail one version of the fictional 1991 encounter
with Leach that she previously refused to confirm under oath.
45.

But just as she had been unwilling to share her fabricated story under oath at her

mother’s PCRA proceeding, Taylor conveniently declined to sign her purported “complaint” in
November 2018 thereby avoiding the admonition contained therein that by signing the
document, she verifies, subject to criminal penalty, the truth of the facts alleged. (Exhibit “N.”)

 

9

Case ID: 190102559

 46.

And rather than submit the November 2018 “complaint” to the appropriate

authorities, Taylor, with upon information and belief the assistance of her co-conspirators Snyder
and Kennedy, distributed the unsigned and unsworn document, albeit styled as a private criminal
complaint, to the offices of Leach’s colleagues at the state capital in Harrisburg, which has since
caused the senate leadership to initiate an independent investigation.
47.

Although relieved Taylor’s fabrication will finally be subjected to scrutiny and

confident that any investigation will confirm what has been known to all three of the defendants
from the start—that Taylor’s malicious accusation against Leach is categorically false—Leach
and his family have nevertheless suffered and continue to suffer harassment, humiliation, and
embarrassment as a result of the defendants’ obscene misconduct.
48.

Not only has the oft-repeated, demonstrably-false allegation by Taylor against

Leach besmirched the reputation of Leach and materially affected his ability to perform some
duties of his public office, but his family has been similarly affected.
49.

Leach’s minor children have been subjected to public ridicule and harassment,

and his wife developed health issues, including loss of feeling in her extremities, necessitating a
diagnostic brain scan, as a result of the stress of the highly humiliating and public false attacks.
50.

As a result of the actions of the defendant, the plaintiff has been subjected to

numerous other people posting on social media, calling him a “rapist” and a “creep” and an
“abuser” and demanding his resignation.
51.

The public incitement based on the defendants’ malicious and wrongful conduct

delineated in this pleading has even compelled Leach to recently upgrade the security systems
installed at his private residence out of concern for his safety and that of his family.

 

10

Case ID: 190102559

 52.

And defendants, themselves, have even confirmed the sole sick objective of their

unconscionable defamatory assault on Leach through a recent Internet post by Snyder: “Y’all,
I’m a sexual misconduct accountability trophy hunter these days. I have Marcel Groen’s head on
my wall, a place next to it reserved for Daylin’s, and plenty of space left over for more[,]”
regardless of truth, basic common decency, or the Law. (Exhibit “O.”)
Count I – Defamation
(Leach v. All Defendants)
53.

Plaintiff incorporates by reference the averments contained in the foregoing

paragraphs of plaintiff’s Complaint as though fully set forth at length herein.
54.

Defendants published the above-mentioned statements, innuendos and

implications concerning Daylin Leach on repeated occasions as set forth above and in the
attached exhibits.
55.

Each of the statements, innuendoes and implications concerning Leach were false

and defamatory.
56.

These statements, innuendoes and implications accuse Leach of criminal conduct

and thus are defamatory per se.
57.

The above-mentioned statements, innuendoes and implications concerning Leach

were published to individuals, including individuals in Philadelphia County, who understood
said statements, innuendos and implications to refer to, and defame, Leach.
58.

Defendants knew that the statements, innuendoes and implications concerning

Leach were totally false. In the alternative, Defendants Snyder and Kennedy made the
statements, innuendos, and implications with a reckless disregard for their truth or falsity.

 

11

Case ID: 190102559

 59.

Defendants maliciously published, republished and distributed the aforementioned

defamatory statements, innuendoes and implications concerning Leach, knowing that they were
false, or with reckless disregard for their truth or falsity.
60.

Defendants’ false and defamatory statements, innuendoes and implications have

severely injured Leach in that they have tended to: (a) blacken and besmirch Leach’s reputation;
(b) expose Leach to public contempt, ridicule or hatred; (c) convey the impression that Leach is a
rapist, a criminal, and a sexual predator; (d) detract from Leach’s respect as a state senator in
Pennsylvania, (e) subject Leach to embarrassment and humiliation within the Commonwealth
and local community; and (f) interfere with Leach’s ability to conduct some of his duties as an
elected official.
61.

Each of the aforementioned defamatory statements, innuendoes and implications

was understood by third parties, including in the Philadelphia area, to pertain to, and defame,
Leach.
62.

Defendants’ defamatory publications were so outrageous and malicious as to

warrant the imposition of punitive damages.
63.

As a proximate result of defendants’ malicious, intentional and/or reckless

publication of these false and defamatory statements and innuendos, Leach’s good name and
reputation has been and will continue to be harmed, and Leach is entitled to such damages as will
compensate Leach for the injury to his reputation, as well as punitive damages to punish the
defendants for their conduct and deter them and others similarly situated from like acts in the
future.
WHEREFORE, plaintiff Daylin Leach demands judgment against defendants Cara
Taylor, Gwen Snyder and Colleen Kennedy, jointly and severally, in an amount of compensatory

 

12

Case ID: 190102559

 damages in excess of Fifty Thousand Dollars ($50,000.00), together with interest and costs, and
punitive damages in an amount which will punish the defendants for their conduct and deter
them and others similarly situated from like acts in the future.
SPRAGUE & SPRAGUE

By:

 

/s/ Joseph R. Podraza, Jr.
Joseph R. Podraza, Jr., Esquire

13

Case ID: 190102559

 vERrFrcaTIo¡{
[, Daylin Leach, am the plaintiff in the subject action and verify that the statements in the
foregoing document are true and correct to the best of my knowledge, information ¡nd belief,

I

do further understand that these statements are made subject to the penalties of l8 Pa.C.S. $4904,
relating to unsworn falsification to authorities.

tg
Date

Hon. Daylin

Case ID: 190102559

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Case ID: 190102559

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Case ID: 190102559

 MR. LEACH:
Try to make it reach me, Cate. when you

speak. How old are you now, Cara?

A 13.

okay. Where do you presently reside?

Allentown.

Okay. How long have you lived there?
A Two years new I would say.

Okay. Do you know Kathy Speech?

A Yes, I do.

And who is Kathy speth to you?

A She is my mother-

Okay. And do you know Delwyn Speth?
A Yes, I do.

And what is -- How do you know him?
A He is my stepfather.

Okay. Cara, do you know of your own

knowledge whether your mother attempted to kill

Delwyn Speth on February 28th?

A I know my mother didn't do it.

How do you know your mother didn't do did?
A I did it.

Now, Cara, I am going to go through this in

detail with you. First. I would like to ask you a

 

 

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And who were you living with?

A My boyfriend, Scott.

0 Were you guys married at the time?

A No, we were not.

0 Okay. How did you suppozt yourself at that
time?

A I was dancing, I was an exotic dancer at

the time.

Okay. I am sorry, Cara. but what is an
exotic dancer? Can, if you you can tell the jury.
A We, we dance. We dance exoticaily in bars.
Take our clothes off in front of strangers for a

lot of money.

Okay. And were you of age at. the time?
A No, I was not.
Then how did you manage to get into the

bars to do this?

A Nobody really ever asked me, you know. I,
when they did, I just woulfin't work at that place.
I'd go down the street.

Okay. Where were you working on the
evening of February 27th/28th?
A I was at the Grandview Inn in Gouldsboro

off of Route 380.

 

 

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T dörr''b t,hi¡ilr årlybrdy ås uaying Ðhat,

Ï5
16

$1R.,
!{onc¡ r

I¡BACIdc Sbjet;ticnr

lour

r

fïr$ CûtJRtl¡ objech,åon

77
a¿t
¿(,

suËtæined.

'i

BY II,IR.

I{C 51{TYR E ;

¿.v

ü

T"etç

1'¡

¿J

lnt,erest ån whetl¡er your $:sril gêås *onvicùed.
;{
I al ready sa i d llÊsr f do+
Ðo you have an int,erest?
e

î"4

ft

s

I

e

Âncl y0u lrave tolqi us t,ha ù

d¡

2,2

¡rH

¿,

-,

a

s laol+ in'eo whebher Ðr nÕt you lrave

dont

t want t*

Ëee

her

rJa

ån

tç Jail"r rlo¡
if it,¡s in y0ur

Case ID: 190102559

 93

1

+

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2

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ú.

{t

6
"t

al

Ci

åli
t¡

'¡ 15.Ì

-l

ir¡'l;erest y*iå êre prCI¡:e i:û Iieo is ,chaL riEht?
Va

Ét

<:

yoir Ï¡ave varir$Ë i¡rtereËt s i¡l
ttris cåsÊ¡ dønr t you? First of ð.1Lr åë 3r$u sai$
þefçre¡ yo love yÐur n¡othen ancå you lrate $e3.r,ayn
speths *cc{¡rdång tr: yûrJr ri,ght?
$kay o

IJ

Tå

¡gÞr

xx,

ÄlL right.

ct
Þ¡

les.
rr
fio I t,ake åL that, åf yüu !tated hÈ,m ÊhouËh
to ki"l.i hånio y{rlí hat.e l"lisr enoirgir to Eei: osl thaL
nit

13

wi.'Lirsös s'sand

¿ú¡

lhaL

L6
'î

'7
-t- I

1iï
'¡q
2,û

?1
2,r.

and lie

it

ie wouJ"d hurL !rim¡ is

faår ståtement,?
fi
f{or þecauge I I ¡n nöt 1yf.ng.
Ä1L r{ght,
Lêtr sr let,¡ s analyze this $ËrÊr
You habe â Ë)erËrn enougtr to kill themr tç talie
a

LJ

their very lif e frrcm 'cheir lrodyr but yaü rlsn!t
hate hir¡t enouçh tö Lie on t,he wåtnâss stand abçut,
t¡Ímr ås tþ¡at wt¡at youtre teIIinE us?
f.\
ft would trurt me if I wês i¡p h¡ere lyingr
I
dçrrr t $¡anL tq hurt, 'ßiðr ï dont t eäre abouL hi¡n at,

â3

àll.

Êê

*
i*?

2b

Ifated hå¡rr enouEh tç kåLl"niuln

right?

I

1q

idô',.r¡

?ühat i f yûu t,houEht yêu coul d Eet âway wÍth
Case ID: 190102559

 Exhibit 

ase ID: 190102559

(

COURT OF COMMON PLEAS OF LEHICH COUNIY.
PENNSYLVANTA

CRIMINAL DIVISION

COMMONWEALTH OF PENNSYLVANIA

vs.

)

No. l99l/llß6

)

KATHLEEN SPETH

)
)

Defendant

NIOTES

PCRA

E

)
)

)

Or T[sTtMOily

FnTrlrpil FrA¡rp 4pBrL r& reqg

BEF'ORE THE HONONABLE LAÌT'RENCE J. BRENNER

t,
APPEARANCES;

CHARLES SIEGER, ESQUTRE
... for tho Dcfcndant

c.
cl

Õ

C¡J

l-a

sË

Tì

Ê:-.

=::.
t.:,a"

[flCllAEL McINTYRE, ESeUrRE
... for the Commonwe¡lth

l\t
(.o

.a

=9.
Ét<

s([!-:

¿

rn

.E
.

#ñ"'

t\) I,EJ
r::¡

t¡l

Court Monitor:

Glorir Rocd Bobo

Irla
REtOaD F¡r.ã¡) ¡î{ supEn¡cn ocuh-f

APR ã ?

UOOÍ'

OÍ)URÌ

JUL

t99g

7o

Case ID: 190102559

 ó
I

(

2
3

4
5

6
7

I
I

A.
a.

Two and a quarrer years ago

it took about e year fo¡ the rranscript to be
did it no¡?

Fourtcen months.

Now, Kethleen. in your petition For post

conviction coilater¡r Relief you've rrtegod e nur¡bcr of
thingr. and I w¡nt ro go through those things with you.
Okay?

A.

Alt right.

¡0

I

(,

Court's indulgence for a moment.

t2

A.

l3

Now. one of the things thrt you allogc in your
Pclition cotrserns your Attorney, Daylin Lc¡ch, ¡nd his

l4

involvemcnt with your drughtcr, corrçct?

t5

A.
a.
A.
a-

l7

Í

l8
t9

i
a

20

¡

2l

!

22

!

23

(

MR. STEGER: Wirb rhc

ll

tó
¡

did.

And

prepared,

A.
a.

I

24
23

Yss.

You ¡nd

I h¡ve talkcd sbor¡t th¡t,

H¿vc wc nor?

Yes.

And we'vc talkcd ebout thË pros and cone of
following up with that ettegatio¡, h¡vc wc not?

Aa.

Yos.

Whethcr

it

would be advis¡ble or -THE COURT:

ttoil. lct ms

ray th¡s. I rm ¡ot going to -- br¡icrlly wo rrc hcrc today.
this is your hcrring. Gctting ¿nothrr onc of thc¡c po¡t
Conviction Relicf Aot! onc wry or lnothcr, dcponding
on

Case ID: 190102559

 7

tt'hat ¡ would do.

I

f

will Ìot

coms Gesy undcr the prcsent

law. Today is thc time, Mrs. Spcth.
If thsrG is rnything
hore now is thc timc to prGsGnt
thG tostimo[y. B¡¡l
certainly you ¡rc frec to do rs you
deem eppropriatc.

2
3

4
5

MR. STEGER: And rft¡t.s

6

wh¡t I'm attcmpting to investigrtc hçrc.

?

a'
Miss spcth, your daughtcr subrcqucur
to your trìrr
wtl chargcd with and convictod of perjury,
wrg shc not?
A.
Ycs.

I
9

t0

IftR- McINTyRE: your

il

Honor, rnry

$

t2

(

I posG rD objcctìon? r rnow that you ryrnt to
grtnt somc lecwty. Evorything h¡s bccn
toading out of

t3

Attorrêy Sieger. lVc should gct ¡r from

t4

THE COURT: The objection

to thc form ie sust!¡nGd.

l5
tó

I
ã

t

MR. SIEGER; Okry.

l7

a.

't8

trial

Wee your daughter ohrrged

t9

A.

Yes. ¡ho

20

a.

And wh¡t hrpponcd

I

2t

A.

She w¡c givcn

22

yctrr probrtion.

23

A,

So rhc

24

A

Conviclod fclon

2S

a

I
(

witt r crime after your

?

i
a
I

_-

wrr

cherged with pcrjury.

¡

tr r reeult of rh¡t?

sGntencG

ofthirty dayr to fivc

wr¡ co¡victcd?

rt eightccn yerr¡ old. yc¡.
And r¡ ¡ rcruft ofth¡t htvo you rnd
I t¡lkcd

¡bout

Case ID: 190102559

 E

whether or not

t

(

it

would bc a¡lvisrblc to continuG on
with rhe allegation thrt I h¡d mentioned eerlicr?

2

A.
a.

yês.

5

And what wrc your decision with regard to mtÌing
that allogation?

6

A.

ltoll, in light

7

convicted perjurer, whicb would prevcnt eny onc
from
bclieving hcr to¡timony, ir rcrlly mtke¡ no scnÊG.

3

4

8

9

lo

a,

Okry.

of rhe flcr rhrt ny drughrcr

So as a rcsutt of

I

i¡ r

convcrslt¡oû bctwocn

ll

yoursctf and myrclf, is it your dccision to not
continuc on
w¡th thrt rllcgrtion lE r -- rr r ground¡ for iucffcctivc

è

il

l2

a8sistrnce of soun¡cl by AüorDey Lcrch?

t.

t3

A.
a.
A.
a.

CI

l4
l5
t6

l7

t
I

tE

t9

i
a

20

¡a

2a

I
I

22

wcrG two

prrts

__

Just thrr ono ground.

(No rosponoc)

Did you -- d¡d you dccidc thrt thrt one ellegrtlon,
concorning Mr. Le¡ch's incffccrive t¡sistrnce of countel,
would not be followcd concorning hic rllcgcd involvoncnt
with your daughtcr -- scxually?

A.
a.

YG¡,

thrt porrion.

Now, thc -- rnd Attorncy Lo¡ch, w¡¡ ho privato
coun¡ol or trrr ho rppointcd to rcproscnt you?

23
(,.

lVcll, thcro

^,

Pri yttG.

24

Q.

Did you pry him?

25

A"

A thou¡rnd

doll¡r¡.

And hc rgrcGd to

wl¡t for

rhc

Case ID: 190102559

 53

t

I

her thc risks snd what she'd be giving up. Which I

2

believc Judge Brçnner exptained to her again the day of

3

eentenci ng.

4

At no t¡mc did I coerce hcr to withdraw

5

appeal. Thcre is no advantsgc to ms of her withdrawing

ó

her rppeal. And. you know. thc onty contribution I madc

7

to that

8

her

9

I know thet docsn't rddrcss ell of ir, but thrt'¡ thc
onc thing I rcally wanted to say.

l0

tt

tð

slibi

to tell hcr a ûew trisl would h¡vc to be withour

witness.

Thc ¡econd thing -- one othor thing

l3

I rcrlly
wantcd to sty for the record- Uthish is thrt I, you &nov,
C¡r¡ would com€ to my officc, I don't k¡ow. rclativcly

t4

froquently, I'd ray çvery other week on ¡ver¡gc to drop

r5

off ¡omcthing or tålk to me about hcr mon. Or shc would

Ió

elwayr comc with hcr mom, too, whcn hcr mom c&mc. But

l7

at

'{

rrlas

her

t2

a

20

th¡t's ¡s far es my rê¡¡tionship with hcr cvcr wGnt. A¡d.
you know. ¡he told me tt thc time ¡he would csy snyth¡ng
to güt out of -- to gct her morher out of thi6. And I
supposc .- I don't know if thet coDtitruê¡ or trot.

t
I
I

2l

But, I just wantcd to rry thrr ¡¡ well. If tbcro i¡

I
I

I

(

r8

t9

2Z

FomG

2!

¡t,

24

2s

othat issue you want olclred up, I'll bc hrppy to do

MR. MoINTYRE: I've no

furlhcr qüG¡t¡on¡. You mry crot¡ èx¡minG.

Case ID: 190102559

 Exhibit 

ase ID: 190102559

gsts iai I term
ãt mom'$

I

ourm*i

Clipped from The Morning CaIl, 13 Nov 1993,-SaL Main Edition, Page 91

Case ID: 190102559

 Exhibit 

ase ID: 190102559

lq

w

Èara Taylor
Fnbru;lry 13 *t 13,?3;trl ' l¡t

http:fÅav,w.phllly.conr/.. "lcÕil'ÌmËn. .. rTltthtk-*pinion-?Û18t'l û7.hlml

Don't þe lit<e me; don't lte*p the secrcTs tf your abuËÈ¡'s. You deserve beTter'
Yoi¡ don't deserve lÕ bË ÈmbarrãsËed Or äshãmed for whaT wã$ dcnË T0
yffl. l\üas wlotìg lo dü thäL No moneThe Artlcle lrelor,v is one thåt Ssnãtû'r Dãy }n {-each had puhtished, (\¡vhlüft
dçes nùt ãllOW nümments} €nd lt iS titled: 'nWhåt t håve Leämed." You cnn
rËäd lt ilyou like, lrut everytTring tl'lall lrave in quotes ls what he said in the
a¡1icle. lt fs hiç response to lhe allegæTions of sextla! h*rassment lrom
numërÐus 01hËrwÕ¡üen. S¡ntü the Senatcr i$ ãllowed t0 pgbl¡5n Flls
"üplniön" wllhütlt ållÐwing comments, this fs rny respoffiË:

Cara Tnylor: WnåT lve learned b mät ü*ylin Leacft is a ltar. I lcnow because
alx a llar, too"

I

"Tñe [ast lew weekr nävÈ glveft me time Tor lntroËpettlon'"
I believe yütt. lt's ålÌ äwft¡! thing to geT caugfrt in a web üf lies' I have had ä5
yeãrs ta devole to Introspection because ül nline" Do ycu remember thase
lles? They weI* The lles lhat yúl"r knew ãþttit, *nccruragecland thën finnlly
nsËd agaltlst me ta pr$leËT yottr*elY. I"ty Telnny record r*merflbsß them" Sa
Soes every ËmFlOyErWho eyer refilsed t* lrire rne *nd every landlord wfto
ürlngËd at the thouglit Of rent¡n$ to nne. My nÕlv grülvn chilclren rËffiemþËr
Thenr, too. Thcse lies a¡e the reas*r¡ I muldn't ättend ÌhËir 3chÕðlTleld trips
ür voluntËËr Tüx thËir ülàssroörn pãrtles"
"Frlnr to the rÈtent stÕry abÐut ffiË ifi the lnqt¡irer. I wss aware That reporters
werc calling dcrens tl fiy ËmpltljëËs" former Êmployees, acquaintances'
ancl oppcnents tc as¡( tf¡e¡'n !f ! had ever rnade tF¡em or ånyçne they lmew
unrümTürlãble. Thal s*rt tf sürutlny Ten$s tc ptlt one in Silnlvål mÕde,
triggertng sowrethlng akiu to a füghl-cr-figfrt respansË. When the sfolv t¡nälly
ËatnË ùut, {was angry a$d defensive" llashed uut, which I regret."

ntte. Whät did ycu do with all that prËp linË?
Wfrat yru did to me, what yctt frarl planned Íor nre, I never saw iT cürn¡ng.
Were you scåred ünçe yüu knevç? lwxs petrified. What were yol¡ ängry
aþr:ut? Yenh, gÊtTing caUght silcks, I lqno*¡- YÐu Tsld me I never ìrveu¡d; yÖtl
n¡ust have belinved the sarne thing for yourself. lt's r¡ot fun to have the
neu/spåpers 5äy lïÈän thüngs ãbüuï yôU, $5lt? T know. They said mËän thtngs
äbout me, tuü, but tlrey were nlltrruç. Are tfiey lying aþoilt you? Düe3
ËVerynnË iie exËÈpt Toryou? SLÌrV¡Val ffiüde you say? I've been ln survival
rfirr1Ë Tnr the last qr.larler uT a cen{ury, yaull gÈt usëd Ta it, I ditl. }*lenial wcrlt
fnr nrlnimal pay ts¡n't so lrad üftcç yÐr.A .ac[Ëpï the fact that thal's all you'll ever
you dnnT
flc.tälity Toç !f you'rc even luclty er,nugh to ge! thaT. Be grateful if
end up vrËh n¡ghtmarËs sr an uncontrpllalile Lwitch eithet becat¡se I still
haven't figured öut hCITtr Io avoid lhçse tFrings. YÕ$ have regrets? Welwme to

ThaT foresight nrust have þeen

Case ID: 190102559

 .

Vüil glve Llp th¡nkhg you WllËver be ählå tÕ ådequâte:y prÕvidË Tor your
fätïlly. You glve ilp thlnhlns that anyone willevËr believe anyfhhg yoti hãve
'to say, evër äSain, You giVe up vründÊrlnü ¡f you'll eT/er be given forgivÈnes$'
ïbu reatize yoilr best yeärs are þEhtnd you betaltsË ThË würld knows your
shãmË ãnd sËf-Nüäthlng. tft, wä¡l. no, yot¡ shðuld be ok. Foryet evërything I
peÕple whs äre sorry for whãt thËy
Just sãid" ThoBË thlngs orTly häppgn I0
dfd, not mrry thãt theY gnt cåuüht.
"As I began trying to reckon wiTfr what happened, I reache.d out tt friends,
ct¡lËâgues, änd ëVen sürne people who dçnI lhink vÊry highly üf rne' I did a
l*t of lislenlng.'
I believe ttrls" too. lïs * goutf strãlÐgy. ltnowledge is pcwer. ËotTä knntry what
people wlll say so a þetlevable rleïense cän bË rTTãnulactilrËd, I rememÞer. lt
Jil$t üidnt würk üut 5ü wËll fÕr mË, dld it?

"l lenrned ttrat I have been largely rhlivitus to the näture of pewer dynanrlcs
ãnd prfullege, b6th hetween ffiÈn f,nd wtmën änd betryËÐn BnptÙyel's änd
ëff¡ployÉes. I nãVË nëver ËünBidËrËd rnyself very püwerful or inttmldatlng' I
have never bnen comTortable with ä hierarchical structure änd häve always
triecl ta trËatË working envirünmf,nts that wËre lnfürmal and rÉlãtivËly
egäl¡tärlän. Thus, I was under än lntün'ëct assumptlcn thaï anycne urhÜ hãd
än issue wlln me would lcelfree to sdüress me direcïþ. I nuw tlnderstanrl
thãT pëüple, especially ytung $rtrnen, rnight be reluctant to approach me
wllh ffincËrns ãb*ilt humorlâey ftrËfi't tomfûrtåble ïv¡th'"

allab*ul the nature oI pðwer dynannics nnd privilege
whgrT yÕt¡ tested them nHT *n mË 35 yenrs äüt" Am I wong? Was lhere a
cbfld or a yüung würTT*F beïore me? üö ytti tnhk I leltft'ne tç dlrÈctly
åddress ytu vvltn ãny tüntërfis I hed whÉn yüU drove me lc your apartment,
miles ffÕm my fìÈmË, ilnüËrlhÉ gtllse ül"helplng my mülher whn ha$ nc
rnüney ãnd nË*ded å läwyef'while you lald nxked on your bed sTrüKinS yotlr
I þelleve you lËårnËd

help yolt Õilr"? wËrË ltüu he¡ng hunnorous?
Was ¡t au just ã Jötre? Dld yüu Ìhlnh lriy teãrs, $näking inla the beny lubrlcanl
you pnured ün your$elf, wËrÊ ü,lnny? Fower and intlmldation wËre yçHr
T\teâfJonË of choire. T0 tjse lfrgse lscln now, incorporated intCI such a
lranrparent statemenT, UiVËs ilf1È ån ËvËF bigger, mnre horfific sense of
reËpon3ibillty towãrds äll Bf yûHr viËttms ùver the Nast 25 yÊars than I ãlrËady
eretrTinn, dlrentlnu r'ÌË

to*ttffie

had.

"l ÐlsÕ äskÈd PËûPle ît I trad ever dcne änl4hing ta tnahn tl¡em
ijnconÌfürTabte^ Frankly, lwas laolting fÛr reãËsurance, hoping ftr resp0nses
lllqe'Abpçlulely nnt, Daylin."'There ïryäË å gÐüd þit of thaï, wf¡ich I am grateful
for. ts$t sümÈ peüple wer€ [ãndid ¡il tÈllinü me that m]r hunnór tÇulcl be ðif*
color Ðr offenslve. Sorns lsld rne they häd been cffended by my httmtlr ln the
past, while solte told me etl¡e¡"s rnlght feelthat way'"
girt w*s c*rnfortahle being
year
whs f¡eld thç lileral lile af
man
old
c*rnersd ar¡d *ssaulted by a 3ü
f:ersnlf, her" mplher and her Hffite slster in hîs hands wä5 ã cçmfortaþle
fËeling, tlren N t¡ave absolcJtely rrc abflily lo fnrgive yüu whaT:snevÈr. l'lr nüt

Frnnk[y, tf you ever

tlrtugl* a '17 year cld

J¡flT¡
Case ID: 190102559

 ä5Kecl people fi I hscl erer dtnË ãnythlng Tü maKe tnem
uncomlÕrïÊble. Frankly, I was looking for reassurånte" hopinE lor responses
like'Absclulely not, Dëylin."'There wãs ñ gÕod bn oTthat. whith I am gratefgl

"¡

nlsr

Suggesterl

fcr. Ðut sotllË people were tãnd¡d ln telling me Tflat my humor cuuld be otr*
cotor sr offensive. Some told me they had been cffended by my humor in the
past, whilÊ some lotd rne cthers might Teelthat way."
Frankly, if you ever thüught a 17 year old girl was çtmftrtãble þeing
cürnered and assaulted by a 3t year old man who ileld the literal life of
herself" her mather ãnd f¡er ttttle sister in his hands Wãs ã cornftrtable
feeling, then I have absoluïely no äþility tn forglve yûu lrì¡ftäÌsoever. l'm nof
that big of a person. I dpn't even wanl to be.

t'3'

r

1,]"'lå rn*n

"My dlscussisns w¡th others dldn't end at humor- I have always heËn a
ssrnewnat touchy per$ün in conversalion wltlt both men a¡rd wçmen and,
thernfore, I always assumed ll was ÜK. Eut nct everyone *as the sãme
cornfofi levelwlth toaching" lt never occüffËd to me lc even think about this
before, which I am mortlfied tc admit."
I believe you did and dc believe that yottr touchlng is ClK. Did I tearh you
that it was üK þecause I was toc afrald to say rro? Did you think you had a

rlgfrl to dÕ what you dt$ to me because I wæs.ittst a slrtpper and I needed
yoilr help? Are you mortiïierf? lwås,lsCI. I stillãm" Every nnce in a while I
wçuld hear something abaut yüu ðn the news. Õr see son:ething about you
in the newspËpËr, anü I wauld get mortitied all cver agaìn. I got rid of unþle' I
stoFped reåding newspäpers. Then I \å18Ë only mcrlified whsn tht Te¡Õny yüu
trelped rrchestrale agxlnst me would PrÈvent me from livtng xnylh¡ng even
remotelir rðselnþlln$ a Tull and complete life by being able to enjoy even the
simplest ol pleasures. MprÍified fs a gaad wçrd. I don't lhink you t<now whal it
ffieäns.

"All*lthis

hæs IeË me

shsken. lt has alpc talce*t a lotlon my faüT¡ly and staff-"

Yeah. Me, toa For 25 yËars" And there's no enEf ln stgltl Ttr rne or mine. I
tâke lt you ccnsider Xhe tast ä5 years *Íyuur llfe prnductive, prospersus...
nüt me. nüI my Nile. I donT feel sorry f*r you.
"l spent my chilclhoarl in profoundly uncomlorlabte situalions. I hüd VÊry
lirnited pËrentätcontäËt" nt siblings, and lived in ¿ series tf chãllenging
foster honrep" I learned eaÉy on tf¡al hurnor and perscnal contact lrrere ways
tp maÍ<e frierids ãnd Filt people at ease. This is not an €xtttsË, þut an
explanation. While mãny Feople have said pos?tive lhinss åbÐtrt my humcr
over the yeärs, it i5 cleãr now That ffiY 'gense of whüI is and ¡s not $¡elcomÊ in
a given situation has, at tirnes, been flawed" lwas sumetinres impulsive and

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thouglrtless, Ttrat needs lo ctrange. I should nËver put humor beTsrÊ
kindneg$."
Uncomfortabl* situations ä5 a chilcl, you say? Me, tso. Yotlweren't the first
pedophile to vislæle rne. hty s¡5tËf5 lather was ä disgLüsting pervert, too, I
f¡ad n hfbìë thuñìping hypccrite for a step fãther r¡¡he nnade ¡iÎe st ilnbeärable
that I left home Tvhen I was '15 and a mtTher who wanted nne lc talte lhe
bta¡ne fçr her aTtempTed n'lurder räp; yûu thinlç thaT was the lirst time she

Case ID: 190102559

 UncomTortable sitt¡ations as ã child, you say? ltIe, tos, YoH weren't the ñrST
pedophìte ta uiolate rne. My siste/s father was a disgusting pervert, too. I

$ugg*slec

l¡ad a hible thLrm¡:ing hypocrite for a step father whs niade lÈle so unþearable
that I left honre Wnen ¡ was 15 and n niother who wanted nne to take the
blame for her attenìpted rnurder rãp; you think thal was the first time she
snccessftlNly nranip$ated me? But you know what? I dld what t did. I rnade
choices. I was impulsive and thoughtless" lwas alss a child wiler¡ I was
irnpulsive *nd thoughTless" I didn't contin$e my lrehavior inlo aclulthood ancl I
dtdn't mäke extuses, or explanations, tc continue h$rfifl$ other people. You
need a new excuse-

'Ag I'ye ËOntËtnplãted wiere to go from here, üne thing is cerlain: I anr truly
sorry lür ever saying tr doifig ænything thal has nn*de äfiyone uneasyunconîortable, ordistÍessed" lf there is any way io rnake things right, I want
to do that" lf ãnyone wants to conTact me to tallt ahnul this, I'm eãsy tÕ find
and eager to listen."
Ars yüu contenrplatlns where to gc from hËFe? l-et me ilelp yttl out; lT
$HüULDN'T BE THE IüNGRESS ÕF 01-,R UNITEÐ STATES" People like
ycu sfroutd nat be allowed tCI govern Over ãn enlire popufation of people.
And I lmow how you feel. I r¿¡as "tB years old wilh a brand nel baby and a 15
jail *nd nc where TÛ gt' I
:1eär"tld tlttle sistet, w¡Th lrNy mcther in
coãtemplãtËd, too, With your help, N Þeçame a þpr¡añde liaç a perjuret a
felçn, and I contemptated where T* go far 35 yeãrs- Every time I needed a
jab, l contemplated" Every tiff¡e lwas afraiel sometnË recognized me, I
ccntemplaled" Every tirne I wasn't altcwed To participate in a schoolfunctiCIn
with my chlldren, lc*nlemplated- When I stayed in a loveless maniage
because I imew I cottld never mafce enpugh mcney to suppotl my children
by mysell ap a felon, I contenrplated. Every tirne scrneçne had wronged me
and I had *n opportunity to rigl-rt it and decided äEãinstiuslice for myself or
my Tamily because I lffÌew nü üne wouTd believe a lying fehn" I
cantemplated. Every time I wanted tc volunteer in !ïy çümmilnity and was
told ¡'ro, I cnnlenrplaTed" Every tirfle I allowed rnyself tt believe thaT I was
more than what Twas being allowed to þe, I conternplated. Are you certain af
cne lhing? I am, laa" I am certain that you are not sçny fcr anitone but
yourself. lf you were, your deplorabte, abusive, iüst¡RÊd in your own mind
behavior wtuld not have cçnlinued for the tast 25 yeä15" And forthe record, I
will not be cantacting you to lalk about this. The Tact lhat you think anyone
would just goes tpward your blatant arrogance. Ðc not uantact me" I am
ãfr?¡d ûf you" I rlo not ulant you phys¡Ëälly neär mË ever again.

t't',

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K*yst*ne

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"The nçvelist Graig SttvË1t wrote that an apology 'dsesn"t talte things hack,
but it puslres lhi¡?gs forrruard." I th¡nk the þestway for rne to apnlogize is to
change rËy ctndu#. I promise tç dP thaï."
Do yOU lilre quctes? !-{etre's One: "l have learned silence frorn the tallutive,

loterance fram Tl-re intolerant and kindness Írorn the unl{nd; ye? strangely
enough" I am ungratefults these teaËhers." Khalil Gibrah" Thankx Íor all the
lessons. You çan stup anyTime nÐw. I'm not grateful-

Case ID: 190102559

 -'l

Do you like quotes? l-lere's sne: have learned silence from the talletive"
tolerance from tfe intolerant ancl lcindness from the unkind; yet strangely
'ehough, I äm unsrateful to these teachers." Khalil Gibrah. Thankx for all the

lesscns. Yûu can stû'F anytime novu. l'm not grateful.

"l arn trying tû learn. t lçnow this won't satisff everybody. Þut hopefully, over
tirne, any skeptic will be csnvinced of nny sincerity- I bel¡eve that there must
H room for growth and fotgiveness ün lh¡s ¡ssue and in all areas of life-"
Sorry" hutthis slteptic knnr¡vs better because I believe the wornen who spolte
rrJï ãgäÌnst you, after you did lvhät yüu tlitl lo me. And I lfiow you're wrtng
about growth and forgiveness, too" Felons don't ever get eitherof those. My
growth has been stunted for 25 yeãrs and there is no one to lorgive mefor
what I dld. My sin remains written and viewable for anyone with a cornputer
and $1ü. And äs petty as I'rÌ sure ttris tnakes me, I'm glad yours finally is,
toç. Mã1tþe this willfinally stop you frarn hurting others.
"We are liv[ng through a time in which humanity seems to be in desperalely
short supply. I hape rrve cÐn all loo?c at each olher as flawed human beings
whc are constanüytrying to irnprove. I promise that ts what I will be lrying to

do."

Nr ur_ë ãren'l and ¡¡ou are lying. With obvlous exception. people are generally
gcod, decent, caring human beings whn don't use their power and positions
antl influ*nce tc hurt oTher people. Tl¡ere is a marked diffierence between a
rne time rnomentary lapse in iudgement, and ccnsistent self serving,
deplorable behaviorthat greatly affects the lives ololhem, vievsed as
"hurncf. I have gr$Jvn up and I ne longer þelieve yaur lies" You should do
lhe sarne,
lF I AM LYING I WA¡riT Y0U TO SUE ME-

¡

II

Cara Taylor; daughter, mother, wife, gnandmother, felon^

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Ðuylin l*ach: l$hat I\'e learned I tpinion - Phiþ

Case ID: 190102559

 Sign the petition: Senator Leach: Time s Up
liust signed a peliliun ts Sen. Baylin Leach. Pennsylvania State Senator: Despite
rnultiFle, crediùle accr¡sations oT sexilal harassmenÌ, Daylin l-Èåch cont¡nuÊs in his bid
lor Congress. This is unacc*pt*hle- \û,Je, til* undersigned. den:and that Daylin l-each...
FÊ?¡Ì'i *T'å5. $,4rlitËr]'.', ûrr"ü

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*lse is taii<ìnE si:*r-rl

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John $teilz Done! I will NEVER vote for a candidate lvho has clearly
engaged in sexualharassmenl. Nst in the Denrocralic prlmary. Not in
the generalelectian"..even if this meän* a Republican wins the
election. {And I know that F,4 Ðistrict 4 is s criticalseat for the
Dsmscrsts to take control of the U$ hlcuse uf Representatlves.) I live
in Mnntcc in tl'le proposed PA District 4.

Litre Repry

4d

Q

t

Mich*e} Doyle Ðone
Lilqe RePt¡'

4<$

Julie A. frams*y Please everyone who has signed, share the petitianl

Like Reply' .ld
Cara Teylor 25 years agc, urhen I rvas 17 years old and Daylln leach
was representing my nrother, he drove me to his ap*rtment and
sexr.l*lly assaulted me. l-le then nrade sure I l¿as convicied af perjury
so tl'rat nr Ðne would ever believe n:e if I told. Thank you for doing this"
Thank yau"

Lil.;e Repty l$
ì1,.,;ii:A

¿ C,:fl"ln:*nt.

ç)El@r¡

Juli* A, Ramsey Lc!:¡ilãå€rl nÈi rl*ìiei ¡ri'l*lr:

Case ID: 190102559

 {lr

ry

Cara Taylcr
Feþr$ary ?5 a{ 8:3ïpm

' tû

l want to apologize tÐ wÐmen everywhere. for being sucf! a coward" I am sorry
that I feared for my own reputalion rnore thar-r I feared for the future victims cf

Dayl¡n Leach.
I am sorry that lceeping my skeletons hidder¡ ïvas more important than

tellirç

someüne who matteredI am sorry that I was more worried aÞout what people wsuld say about fiïe or
how they would judge methan I was sf exposing a predator.
I am sorrythat I was too wrapped up in my pvdn sellpity to realize that I might

be able to save someone else ffom the same fate that I experienced, and that
when I diil realize it, I ignored it- I am sorry lhat I chose to ignore it- I ann sony I
made that choice tirne and time again because I clid. Because it was the easier
thing to do. I chose þnorance and hiding because it was easy- I ¿¡m st
increclibly sorry lt was wrûng. I was wrong. I t{täs wrong on so rnãny levels.
I hope that these wcrds dont feelas ernpty foryou as they do for me. f hope
that you don't hate me ts much as I hate rnysef. I seffishly hope you can

forgive me.
It will NEVER happen again.

fi

t-i*e

Ç

Comment

þ Share

O

-

Case ID: 190102559

 Exhibit 

ase ID: 190102559

2t28t2}18 Cara Taylor on Twitter: "Ripping families apart? Remember when you ripped mine apart? Do you remember when you sexually violated me and ...

a
-

Tw.ct¡

Cara Taylor

4

@AltonsOma

Daylin leech

tui

I

Following

Follow¡r¡

Likc¡

29

l8

6

@daylinleach ' Feb

Follow

v

10

You control all three branches of government NOW. You do know that, right you
human abacus? What have you done about #DACA other than ripping families
apart?

Donald J. Trump{l @realDonaldTrump
Republicans want to fix DACA far more than the Democrats do. The Dems
had allThree branches of government back in 2008-2011, and they decided
not to do anything about DACA. They only want to use it as a campaign
issue. Vote Republicanl

Çrs

a

tf¿l

g

178

Cara Taylor

Follow

@AltonsOma

Replying to @daylinleach

Ripping families apart? Remember when you
ripped mine apart? Do you remember when
you sexually violated me and then sentenced
me to a life of poverty when you consp¡red to
have me convicted of perjury so no one
would ever believe me? lf lm lying then SUE
ME.
11:304M - 10 Feb 2018
15 Retweets

2sukes

Çs

tlts

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26 g

i'*""tr"""0',
K¡ndall A. Brll @kashleybell ' Feb

10

Replying to @AltonsOma @daylinleach
Riiiiiiight. You're not a bot, or anything. Entirely credible. Yup. You're probably not
even a woman. How's the weather in Moscow?

4

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https ://twitter.com/AltonsOma/status/962408563930030080

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Case ID: 190102559
112

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-Ës

February ä4 a1.{:Sfipm

,l*r

11

ffi Julia

A. Ram'sÊy
FsbrualT ?3 *t 1: {ð*nr '

tl

ãüÊrunt$ of miscanüurt, $enatcr Lsach is unfit für
rffiÊe" We rnu*t fnave a clean line of rËrü-tülËränü* fü,n $*xttaß ruisc*nduct

W[ütit rîrulttpl€ credfrhte

fsr uffic*

lir,.,

Se* fu{sn*

,SIgn the

petitinn: $enator Leath: TÍmels IJp

*ügnsd e Falilion to #en. ûsylin Ls*ch, F*nnsyËvania I'tat* S*nntcr: te$ite
muÍtiËls, ff*dibtç acn¡*a*nnn* nf gexuai hårg$srTrÉnt, Baïlün l-sash *antinues in ltis
þÍd for tollgress. Tfrüs üF [rrr*üfisptable. rÍfe, lhs undercignsfl,, fl*Ìnãnd lhat ü*ylin",,

lir¡*t

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TliT l ü*'3S,f,'T

ülrErl

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Sss,¡¡hE¡ *{g# is tal*'rnil ah*r"¡t

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petitisrl

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Comment

Seq Fosts

#

$hnre

 lCase ID: 190102559

 ,Sign the

petÍtion: $sna,tor Leach; Time's

TJp

liust signed a petilion to $en, tlaylln Lsach, Fsnnsyhenie $tatt $sn¡tnr: ÐaspitE
ruultlFl*, cr¡dlbla eccuaatisn* çf rexu*f hEraEament, Oaïlin Leach contlnueE ln hl* þld
fbr *angråË*. Thls le unaccEptaþfÊ, l¡Ve, thç undaraþned, d'emsnd thet tnylin f.sach,..
ftËTt"$

üi,i$

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Stt*r'¡¡h* e$s* ¡s ü*tllij¡'try ãt¡#ilt

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J*hn $te[te Songf I rvill FüEUER r¡ntn for a candldats u¡ha hac clerrlg
engägÊ{ in ssxual ham*snr*nt, [t]ot in thç Ðsmscratic primany, F'lct in
tha generst slscliürT",,Êv€rÌ if this m€ânË a Republican ïufn* the
eleclion, {And I know that FA Ðistdct 4 is,a crlticat sået for the
Fsmqcrat* ta tak* cnntral of the U$ Houer of R*pr*r*n:t;aËiv*n,] I liv*
ln i¡lontro in the pr$Fossd Få tfEtrict d,

Éi

L¡lqe Repry "ttl
I'diehael 0nyïa
LIIEn HspH

tona

4 t*

Julia A, Ha,ms,ey FlaarË Êufffûne who ha* rigned, shnr* thn petitinnl

Lihe Reptf

'

4{å

whan Xr¡¡as 1T yerre old andr Oaylin lsEch
rrrag rËprÊnanling rny mnthar* ha dr*ve me tu his ap*rtmsnt and
**xunl[y amaulted me. Ha th*n mad* Ëurs I wæ canuictad nf pariurl¡
sa that no onå wauld Ërår heliava nna if Í tofd" Thank you for dning thir,
Thank fril.

Cara Trylur ã5 ynaru

LilqE'REplf'3*å

ä$ü,,

Case ID: 190102559

 l

Cara Taylor @Altnnstma ' Feb ?4

Õ

W*enq.
eütiur-

Senator Leach: Time's Up
I just signed a petition tn Sen- Daylin Leach,
Fennsytvania Sta*te Senator: Despite rnultiple" credible
accusatians of sexual harassment, Daylin Leach contin--petitions"m6vË0n-0rg

E}

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ü

a/

Gara Thylor 6]Altsns0ma ' Feb J1
Reply,ing

ts @anna arsn

25 years ago, when I was 17. rvhîle he was representing my m*then this man
drcve me tn hîs apartrnent and sexually assaulted me" How is he allowed to
govern over an entire population of peaple?

-

Ç

I

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t-Ie

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El

Cam Taylor @Altçns0ms 'Feb 1ü
Replying

ta @daylinleach

Ripping f¡milies apart? Renrember u¡hen you ripped mine apart? Do you
rernernber lvhen yüu sexually violated me and then sentenced nre to a life of
poverty when yru rünspired to have me convicted of pÉ{ury st nÕ ane would
ever helieve me? lf lm lying then SUE ME.

Çs

Îf rs

tl¿6

El
ü

Case ID: 190102559

 Ëeie ïnyfrur @Åltonstrna ' Zl

m

rr

ts @GpçsncrTannllfslf
Hnw is it thst Senator Beyüïn lnsch wtrs drmre mÊ tü his epertment when I rres
1î snd sexualþ æ,ssuked me, end urhs lree hurt nthers- ls ellsrryed tn grendstend
from * podiufit, Õn thcse irsucr? Completing wad* for vietirns shauld indude nÕrt
Replying

having predatcrs invsived in these insues.

Ç

ffi

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Ël

Case ID: 190102559

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t-{Ê

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fiara Taylar

Follnw

@'Altnnstnra

\1

Replying tÐ @pghÌr¡üRML @JnhnFetterrnsn and Z çthers

Your cause is grËät, but Senatur Daylin Leach
is not. When I was 17, he drove mË ts his
apãrtmËnt and sexuãlly assãulted rnË and he
has hurt others since thËn. I dün't knüw why
äny$ne $Iüuld suFpürt fi predat0r.
9:44 AM - Z6 Sep f$n

I Retweet

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Case ID: 190102559

 E*m Tiiylnr @Åltonçûms

- 6rR

\/

H*plyi*rg to ffi fiesseFirsF*{ @devllnleech

Wh*n I wEs I7, senetsr Srrylln Lr*ch droue mE to hir apertment end rexuelly
ersåÌJltÊd me, and hes hurt rnÊny othsrs *inrê, Now yüu knsr'u.
ficehnnhcnm/ca ra,taylü n I ff .,
,

q)

ffi.

trr

EI

Case ID: 190102559

 Earn Tie¡rbr @Altnnsürma ' Zl rn
Replying tü @GnvernnrTnmWslf

Hsw ls Tt thst Senator,Bayltln Lsach whn dn*r¡s me tÕ ïrie apartmÊnt when I wss
17 snd sexuelty sssåulted me and wlls ilss hurt ntfiera ls slltùr'red to grendstand
frnin a pndiufiT¡ üñ thesê îssues? Completing wark far victirns should indud'e nüt
having predatars inu$lved in tllese iËsuÊË.
Ç

r3

üt

EI

Case ID: 190102559

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t-{r

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t*,!

Cara Taylor

Fotrtrqw

@-Atttrnsünra

nrr

Replying tü @pghl',I$Rtb'll @Jçhr¡Fetterffr€m and 2 sthers

Your cause is grÊat, but Senatür Daylin Leach
is not. When I was 17, he drove me to his
äFãrtment and sËxually ässãulted me änd he
has hurt others since then" I dsn't knüw why
crnynne would support ä predatür"
9:44 Atrtl - ãõ Sep Aü1fi

1 Reürn¡e,et

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q]

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Case ID: 190102559

 Exhibit 

ase ID: 190102559

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Co¡nrrrents
wâsted your tlme. You could
have as.., se¡r Mçrc

?nì Like Reply

*

Owrn 8nydrr
Turêa, greppllng ând ãsklng
questlons ls totally pârt of thls

work,
And Colleen sald she *isnT*
saylng you should be klcked
out, I'm not elther.
But thls ls a group about

supportlng survlvors of sexual
essåult by powerful men and
havlng thelr backs.
Daylln ls a raplst and a
predator, a fact confirmed by
multlple women in thls group.
lf you donT belleve them, you

cêrtalnly have a rlght to that
oolnlon. however

fõì

l¿Vrite a reolv..
trr

@o

Case ID: 190102559

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Conrnrents

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Daylln is a rapist and a
predator, a fact confirmed by
multlple women in this group.

lf you dont believe them, you
certainly have a right to that
opinion, however
disappointing I find lt.
But lf you don't belleve them, I
don't understand why you
would want to be lnvolved ln a
movement about supportlng
and bellevlng survlvors and ln
partlcular survivors of
powerful politicians.

And I'll say for mysell we
started talklng after the Daylin
party, ând I was really exclted
to work wlth you and trled to
be really vulnerable and

honest, lt made me really sad
to frnd out that you had been
part of a host committee for

O

þrite

a reply...

@e

Case ID: 190102559

 Exhibit 

ase ID: 190102559

Gwslr Snydcr
' ' l.j:,ilì

l,i,

:ì:

lt ¡
,,: i ,¡ ' :;il 'j:j

il 5 r'rt ilt* [,i *¡rl rrcr;tti¿: il i] Jr il tì iUnt lllegol ly
deleted seuersl cornrnenls, including cne frorn black
as âct¡vlst &l*s:;r"lç {Jsåii},,r,rì3 calling ihem ñut fÐr
uslng a photc af taylln Leach FcËir¡g with a yûung
hlach g¡r[ ññ pårt rf their eute liitle 'þo hrnar MLK bv
¡:icklng up trash' faeebook Boat"
F

€i ì n$ Th,r ni

I

As ü rêfifildet Saylin ts +t*dtfrly ðt*usêd of raping n
lT y€ür dd and cümnr¡ttlng vâr¡olts ä*t$ üf seruål
nris*onduet egeínst å nl¡ffihÈr nf other yäutlg wårnÈn.
l#e¡rs already looking to go a{ter Faylir,r for il}egally
hlocking his çovernrn*nt reecurcçd ïwitler frsrn public
viewing, *nd ¡t nðulr it lusks like ifi* säuel.rs ls fixing te
get sueel, tna.
¡!{rl

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@cassieowens

Gwen Snyder, a local activist,
addressed the crowd, instructing
demonstrators to tweet calls for
State Senator Daylin Leach's
res¡gnation: "lt's time for Daylin to be

gone," she sa¡d. "He put his twitter
on protected status, but that's not
going to stop us."
10:43 AM . 1119119 . Twitter for iPhone

7 Retweets 24 Likes
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. 1119119

- Tweet your reply
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Gwen Snyder is uncivil
@gwensnyderPH L

THANK YOU to all the badass

#WomensMarch20l 9 #philly folks
who are taking out your phones
today and letting @daylinleach know
that #TimesUp and we're done with
rapists holding office.
Tcgether, we win.

r*

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12:33 PM . 1119119 . Twitter for Android

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Retweets 18 Likes

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Case ID: 190102559

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i helieve her,

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@baCKennedy

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Visit @daylinlsarh's tpen Houss sn Addictîon To¡.¡r stop in
Harherth an THURSDAY fram fr to $pm....
8:25 AM - 36 Sep 3üIfr

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PRIVATE

A-- CRIMINAL COMPLAINT

COMMONWEALTN OF 
VS,




NAME and ADDRESS
Daylin Leach

601 8 Henderson Rd Suite 208
King of Prussia, PA 19406



 

(Axum be oer-mum [11 com Danni-ml)

lee- Under 

 

Fill in us much iniormaiion as you iuvn.

(Fill in &lt;Defend: 5 Name Dayiln Leach
Docket Number. PRIVATE

CRIMINAL COMPLAINT

2. The acts eommitted by the accused were:

lsu . mumm- hm mam out: sum-u aim. mm um mm mm". A mutton mm mm mus mum 
l. maul, In .mmw can, you ml a. [wan no "man" mn- ulna-drywall: I

 

Sexual assault of a minor by forcible oompulsio . Durlng the Summer of 1991, during which
time the private swimming pool br-panments was open and available for use
to the residents, Daylin Leach picked me up from my home located at --
in Allentown, PA, telling me we had to talk about my mothers case, as he was her 
attomay, and drove me to his apartment located In the _Apartment Complex
where he sexually assaulted me. was 17 years old, having turned 17 on March 25th of this
same year. Upon entering the apartment, afier getting himself a drink from the refrigerator,
Daylln disappeared into a room and then called my name. I got up and went to where I had
heard his voice coming from. I tound him naked. with only his socks on, lying on his bad
stroking his erection. Daylin then said. "Come help me out". I did as I was toldI getting on
lhe bed. on my knees between his legs and put his penis in my mouth. When my tears had
annoyed him. he took a bottle of red lubricant from his bedside table and poured It
onto his genitals. After he ejaculated, I went into the bathroom to clean his body fluid off of

myself and when I returned to his bedroom he was dressed holding his keys. I followed him
out the doorand he drove me home.

All of which were against the peace and dignity at lhe oI and contrary to the Act of

 

Assembly. in vlalallnn 01mew-l
3 I ask that wens" b0 Issued and the dalerldant he teoulrad Io answer the charges I have made
4. I verify thal the flat: set forth in this complalnt are true and correct Io me best of my knowledge or Information and

Dellef. This verification I: made subject to ma ot Section 4904 at the Crime: Code (13 Vacs. 4904)
rotallng to unewom to authorities.

5. I certify that lhis fully; complies with the of the cm Records Public Access Policy ollne UnIfied Judicial

System that Inquire filing mnfidential infamauan and documents dltrevemly than nun-confidential
Intermalion and damments,

Data 

otfice Mthe Attorney forms Commonwealth EI Mann/ed Dlsawrnved because

 

 

 

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Dill-1:35, Wm"!

Case ID: 190102559

 

CRIMINAL COMPLAINT FOR USE IN TURE CRIMES
COMMITTED BY PA SENATOR DAYLIN LEACH

Wri . hr

My name is Cara Taylor and i am a sexual assault victim. My ahuier's name it Daylin Leach and he is
currently a PA Senator. was 17 years old when he assaulted me. He was my mother's criminal defense
attorney. Daylin didn't just physically abuse me. He also convinced me, through severe and repeated
manipulation tacties. to commit perjury by taking the bliime tor what my mother had done. and because of
this.l have been It lelun for my entire adult life. Daylln Ilsa convinced me to have child in an utternpl to
have a medical reason tor a requested continuance oi my mother's trial. I was a stripper during this period
of my life. Currently, I am a 44 year old wife, mother. and grandmother I am not a career criminal.
This is my true story.

1990: My age-- 16.1 lirst met Daylin at this time when my buytriend and i needed a lawyer iora
landlord/tenant issue. My father came down trom New York to pay Daylin {or his help with my legal issue. i
was living with my hoyin'end in an apartment in PA. 1 had leit home when was 15.

Feb 1991 -- My mother(Kalhieen Speth, was Irmted and charged with attempted
homicide. hud tried to itill my stepiathertnelwyn Speth). When my motherwas arrested, 1 took my little
sister to live with me. Once my mother wos bailed oul she came to live with us.

Spring 1991 - Due to my mother's eontinued crying and pleading regarding her fears surrounding having a
public defender, approached Daylin about helping my mother with her case. accepted.

Spring and Summer [99] -- My I turned 17 an ereh 25 of this year. Dlylin had been talking to
me on the phone and In person. although it was mostly in person, for weeks. During this time, Daylin would
talk to me nbout how he did that knew! how to defend my mother unless someone else had done it. He would
ask me questionx about where was that night, about my life, about why i had len home at such a young
age. He would ask me questions about what it was like to be a "ripper, how much money I made,wherel
worked. He explained to me how I Wus only 16 when the crime was committed, how the DA would never
switch defendants and how even if they did, with me being I juvenile, minimal time would be Served
whereas my mother was looking at decades behind bars. Dayiin assured me that perjury wasn't an option
for the DA either, that no one ever got charged with perjury. Every time i would ask him a question like,
"What do you want lrum me?" or "i don't know what to say, what am I suppose to say?" Daylin would tell
me to go home Ind to my mother. After weeks Ind weeks nfthis, and weeks Ind Weeks of my mother
crying lbaut how the didn't know how she going to get out of this, after talking ta my mother about
how Daylin wouldn't answer my questions and having her explain Io me that there were certain things a
lawyer couldn't be involved ln.l knew what I ind to do. I remember the day I walked into into Daylin's
oiliee to give both him and my mother what they wanted from me like it was yesterday, and for decades 1
have taken more than my share of responsihility {or this. It was my idea to agree to this plan, but the plan
we: never my idea.

My assault - During the Summer at 1991, during which time the private swimming pool tor 

Case ID: 190102559

 

Apartments was open and available for use to the residents, Daylin Leash picked me up from my home
located at_ in Allentown, PA, telling me we had to talk about my mother's use, and
drove me to his apartment located In the -- Apartment Complex when he sexually assaulted me
using forcible compulsion. I was 17 years old, having turned 17 on March of this same year. Upon
entering the apartment, after getting himself a dn'nk from the refrigerator, Daylin disappeared into a room
and then called my name. I got up and went to where I had heard his Voice ooming from. I found him naked,
with only his socks on, lying on his bed stroking his erection. Daylin said, "Come help me out". I did as I was
told, getting on Ihe hell on my knees between his legs and put his penis in my mouth. When my tears had
visibly annoyed him, he took a bottle of red lubricant lrom his bedside table and poured It unto his genitals.
After he eiacullted. I went inlo the bathroom to clean h'n hndy lluld off of myself and when I returned to his
bedroom he Wu dressed holding his keys. I followed him out the door and he drove me home.

Late Summer 1991 My age -- 17. Daylln told me that he was out or reasons ior continuing mom's trial date.
He told me that was a key witness and that ill were to break a leg, get rich, or get pregnant, that he would
have a valid reason ior asking for a postponement. He said he needed one. that he wasn't prepared at all to
defend her. I completely believed this becautc we neverspoke about anything important the way I thought
we should have. He told me that ifI were to have a halyy, Ihlt Ihey definitely wouldn't go to hard on me if
they decided to come alter me {or the actual crime. 1 didn't want to break a bone or get sick, sol got
pregnant. 1 did that. i did that horrihle act to two completely innocent liver and have hated myself ever
since. My son was born on F1992, and live days later 1 turned 13. Daylin got the continuance he
wanted and 1 was an adult en committed my crime nfperjury.

June 9 and 10, 1992 My age -- is. i turned 18 on -1thls year I spent 2 days testifying that i had
done whet my mother was accused of. was the only defense witness.

June [992 -- My mother was found guilty. 0n the day of this verdict, [was out in the courthouse hall when
DIlen told me I had to meet him at his office right away. I did as I was told and Walked over. He came out at
his office and told me there was trouble. He said they were coming after me far Ind that he
never saw that coming and that it was a bad thing He told me that i was smart, that i was a good girl, that
he was going to (all me into his office in few minutes and that I had to l'ollow his lead and Answer his
questions, that he knew I would know how to do that. He told me We had to record it. He told me I had to
cry. He left me and went back into his office. When he came back to get me, he took me in his office and held
his linger up to his mouth and pointed to the tape recorder sitting on his desk. He held his hands on
his head and sat in his chair while he said "Cara, please tell me I did not just send an innocent woman to
jail." I was instantly petrified. I knew something had was happening, but I didn't know what, and i was to
scared, I instantly started crying. I answered all of his questions the way I knew I was suppose to. I knew I
was protecting him and me. but i also knew 1 was no longer protecting mom and that made me feel rick. it
didn't last long, and when it was over. he literally pushed me out the door, telling me to go home, that he
would call me.

1992--1 was charged with perjury and false swearing.
November 12, 1993 -- 1 entered a guilty plea.

November is. 1993 @9am-l turned myseuin, as ordered, to serve my sentence.

December 17, 1017 -- An article in the Philly inouirer came out about Daylln sexually harassing female staff.
This same day, 1 contacted one of the reporters, Angela She met with me and spent months
vetting me, only to have her editors pull the story days belore pubhcation due to Daylin's lawyers
threatening to sue. was told. ironically enough, that because at Daylin denyi any kind or a "relationship"

with me in a PCRA hearing, that the paper would basically be accusing him oi perjury and that was a pretty
bad thing to do, so they would not be printing my story.

Case ID: 190102559

 

Daylin did what he did to me, but there âre mâny other people who failed me during this time, other than
my own crazy mothen None of the rdult profession¡ls involved in any of this stepped up to help me or to
even try to do the right thing. Corporal Stnte TFooperArsenio Rosn went to the ADA, about his wÍtnessing
Daylin feeding me answers while I was on the stnnd, yet Corporal Ross was the one to fill out and file the
Criminnl Complaint for perjury agrinst me. Rosa never filed anything against Daylin. My public dcfender,
Karen Schuler, she was made twâre of what Daylin did to me and not only dÍd she choose to ignore the
inform¡tion but she then didntt even bother to show up on the day I plead guilty; r man was there to help
me and he asked me if I could resd. The Disciplinary Board was notified and dismissed the claim. Charles
Seiger, a new attorney for my mother, was told also and not only did this man not report the crime that was
reported to him, he also talked my mother out of talking about what Daylin did to me during that snme
PCRA hearing in 1999' while she was on the stand, because I was a felon for periury. And last but certainly
not least, there is formerADA Michael Mclntyre, who has admitted, pubticly and privatel¡ to knowing what
Daylin wrs "up toD yet refused to notify the prnper ¡uthorities and instead called for charges against me.

My intent is neither to absolve myself of blame nor justify my crime, but rather to share responsibility with
those who desene to share it with me in nn effort to bring attention to the wittful ignorance of mandated
repoÉers in the hopes that this type of self-preserving behavior can be prevented from happenlng to
someone else. Blnme can be a harmful, ugly thing. Unless it Ís deserved,

But now, this is no longer about me. It is all too late for me. Tlventy-seven yerrs have passed nnd I am ae
broken oras whole as I will ever bG, nothÍng can change th¡t for me and I am partþ to bl¡me for all of it.
What can change is the ability of all of us fo help thc next person. Whoever it is who h¡s come fo you with a
claim against Drylin, please listen to them and please know that they nre not nlone. Please know that there is
mueh proof' and many other people, who have been immeasurably harmed by this man; this man who is
allowed to make and vote on laws that govern over the rest of us. This man who pretends to be a champion
of women's rights' lÍterally surrounding himself with a potential victim pool. Please know that you, as a
person in a position of power, hold not only the ability to possibly right a wrong to the extent that the lnw
allows, but to also play a large role in saving nnother victim from all of the crippling effects that come along
wifh feeling powerless against a powerful man and an even more powerful system, Justice can be a harmful,
ugly thing foo, and I have rarely been comforted by the meaning of it lVhatts done is done. Time can't be
taken bacþ hurts can't be undone, lives can't be relived. You can apologize all you want to a broken plate on
the lloor, but it doesntt chnnge the fact that the plate will never be the same. \ilhat ean happen, thoughn what
we should strive to have happen, where there mþht be some small amount of justice, that hopeful reality lies
in our ability to prevent the repeated behrvior of known predators and real criminals, no matter how
powerful they have become.
Ple¡se help, however you can, whoever it is who has come to you. Please tell them that they are not alone.
tell them that I will hate myself forever for what my own inaction has contributed to, in what has
happened to them, and while I rtalize that the utter emptiness of my regret witl do nothing to contribute to
their wholcne$s, please tell them that I promise it will never happen again, It will NEVER happen again.
Please

Case ID: 190102559

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Case ID: 190102559