1. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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IN THE COURT OF COMMON PLEAS OF WAYNE COUNTY PENNSYLVANIA
Michael C. Morris, PRO SE,
MICHAEL C. MORRIS and STEPHEN G.
SMITH,
Defendants/Petitioners
vs.
BOROUGH OF HONESDALE,
WAYNE COUNTY, PENNSYLVANIA
Plaintiff/Respondents
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Wayne County Case : 400-CV-2016 AND
401-CV-2016
ANSWER OF COMPLAINT 400-CV-2016
and 401-CV-2016 AND COUNTERCLAIM,
ADDITION OF DCED AND
ADDITIONAL INDISPENSABLE
PARTIES AND REQUEST and REQUEST
FOR TREBLE DAMAGES AND
REQUEST FOR INJUNCTIVE RELIEF
I. ANSWERS TO COMPLAINT
The Defendants/Petitioners in answering the allegations of the Complaint on file herein, affirms,
denies and alleges as follows:
1. Agreed
2. Agreed
3. Denied. SMH LLC agreed to give the Borough of Honesdale the grant that was approved
FOR SMH LLC. By DCED. That grant money which was the property of DCED,
awarded to SMH LLC was given to the Borough of Honesdale to create the Revolving
Loan Fund. On the very next day after the April 25th
closing, all contact with the
Borough of Honesdale was “broken” as they would not return calls, email or messages
left at the Borough Office. This alone renders the contracts null and void on “bad faith”.
4. Denied. The Personal Guaranty and Surety ship Agreement was told as being a State
requirement as part of the Anchor Building Project grant requirements when in fact it was
not. Solicitor Richard Henry colluded/conspired with Edward Geiger of the Pennsylvania
Department of Community and Economic Development (DCED) to express to SMH LLC
and the Defendants/Petitioners that they were a requirement when they were under threat

2. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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of financial ruin. The document was presented in “bad faith” and fraud with unclean
hands. Additionally, the original closing with was April 25, 2013, where through the
direct fault of the Borough of Honesdale the closing was null and void and then the
Borough of Honesdale filed as false criminal complaint against the
Defendants/Petitioners that will be fully adjudicated in Wayne County Case: 317-2015-
CV.
5. Denied. The Personal Guaranty and Suretyship Agreement were told as being a State
requirement as part of the Anchor Building Project grant requirements when in fact it was
not. Solicitor Richard Henry colluded/conspired with Edward Geiger of the Pennsylvania
Department of Community and Economic Development (DCED) to express to SMH LLC
and the Defendants/Petitioners that they were a requirement when they were not under
threat of financial ruin. The document was presented in “bad faith”.
6. Agreed and in part Denied. Stephen G. Smith’s work address is not 22 village road as it
is the home of Michael C. Morris and his family.
7. Agreed
8. Agreed
9. Agreed
10. Denied. No Disclosure of Confession of Judgment is part of the paperwork nor is any
Disclosure of Confession of Judgment signed by Michael C. Morris or Stephen G. Smith
personally.
11. Denied. No personal Disclosure of Confession of Judgment has ever been signed or
presented. The only Disclosure of Confession of Judgment to Michael C. Morris was as
part of his duties as a Managing Member of Smith & Morris Holdings LLC.
12. Denied. In the instant action, Respondent has failed to comply with the Pennsylvania
Rules of Civil Procedure, and specifically rule 2952. Additionally, Plaintiff/Respondents
have filed two (2) civil suits in what looks like on the face will potentially create two (2)
judgments of $304,176.31 in the court system. The suits should have been brought as
one action and based on the past history and conduct of the Plaintiff/Respondents does fit
a pattern of questionable actions and behavior.
13. Agreed and in part Denied. No payments were made because the Borough of Honesdale
did willfully and with malice failed administer the Anchor Building Project and is the

3. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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direct cause of the default and collapse and the loss of millions of dollars and hundreds of
jobs to the area.
14. Agreed
15. Denied. The Personal Guaranty and Suretyship Agreement were told as being a State
requirement as part of the Anchor Building Project grant requirements when in fact it was
not. Solicitor Richard Henry colluded/conspired with Edward Geiger of the Pennsylvania
Department of Community and Economic Development (DCED) to express to SMH LLC
and the Defendants/Petitioners that they were a requirement when they were not under
threat of financial ruin. The document was presented in “bad faith”.
16. Denied. This move along with the moves in the Bankruptcy court is to attempt to
“squash” the law suits filed against the Borough as the Borough was never the “owner”
of the funds and only a facilitator of the funds as the Borough did not contribute “one
penny” to the fund amount. They are trying to collect money that was never theirs unless
the project was completed. Being that the Borough of Honesdale is the direct cause of
the failure of the project, to attempt to collect money is reprehensible with no standing to
do so.
17. Agreed
18. Agreed
AFFIRMATIVE DEFENSES
FIRST AFFIRMATIVE DEFENSE
(Fraud, Deceit or Misrepresentation by Plaintiff)
FOR AND AS A FIRST AFFIRMATIVE DEFENSE the Defendants/Petitioners, MICHAEL C.
MORRIS, STEPHEN G. SMITH asserts that the plaintiffs obtained the Defendants/Petitioners
consent to the contract through fraud, deceit or misrepresentation by the plaintiffs, and that as a
result the contract is invalid.
SECOND AFFIRMATIVE DEFENSE
(Unclean Hands)
FOR AND AS A SECOND AFFIRMATIVE DEFENSE to all causes of action in the complaint,
these answering defendants allege that plaintiffs are barred from recovery, if any, by unclean hands.

4. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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THIRD AFFIRMATIVE DEFENSE
(Breach of Contract)
FOR AND AS A THIRD AFFIRMATIVE DEFENSE to all causes of action in the complaint, these
answering defendants allege that plaintiffs are barred from recovery, because of their breaches of
contract, and by their breaches of the covenants and conditions of the grant agreement including the
covenant of good faith and fair dealing, thereby extinguishing and terminating the duties allegedly
owed by these answering defendants, and/or reducing or abating the amount of damages to which
plaintiffs are entitled, if any.
FORTH AFFIRMATIVE DEFENSE
(Carelessness, Negligence, and/or Fault by Plaintiff)
FOR AND AS A FORTH AFFIRMATIVE DEFENSE to all causes of actions alleged in the
complaint, these answering defendants allege that plaintiffs are barred from recovering any
damages because of plaintiffs’ own acts of carelessness, negligence and/or other fault, and further,
that such carelessness, negligence and/or other fault proximately contributed to the default by
SMH LLC and Defendants/Petitioners.
FIFTH AFFIRMATIVE DEFENSE
(Alleged Damages not caused by Defendants)
FOR AND AS A FIFTH AFFIRMATIVE DEFENSE to all causes of actions alleged in the
complaint, these answering defendants allege that to the extent that plaintiffs suffered any damages
alleged, such damages were not caused by defendants but by the acts or omissions of plaintiffs
and/or others.
SIXTH AFFIRMATIVE DEFENSE
(Failure of Performance)
FOR AND AS A SIXTH AFFIRMATIVE DEFENSE to all causes of action in the complaint, these
answering defendants allege that plaintiffs are barred from any recovery because plaintiffs failed to
perform their obligations under the grant agreement.
SEVENTH AFFIRMATIVE DEFENSE
(Violations of State and Local Laws)
FOR AND AS A SEVENTH AFFIRMATIVE DEFENSE to all causes of action in the complaint,
these answering defendants allege that plaintiffs are barred from any relief, based on plaintiffs’
violations of State and Local Laws.

5. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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EIGHTH AFFIRMATIVE DEFENSE
(Fraud)
FOR AND AS A EIGHTH AFFIRMATIVE DEFENSE to all causes of action in the complaint,
these answering defendants allege that plaintiffs are barred from any relief, based on fraud by
plaintiffs and/or their agents.
NINTH AFFIRMATIVE DEFENSE
(UNJUST ENRICHMENT)
FOR AND AS A NINTH AFFIRMATIVE DEFENSE to all causes of action in the complaint, these
answering defendants allege that plaintiffs are barred from any relief, as the plaintiffs and/or their
agents are the direct cause of the default by defendants in this matter and that it was intentional and
with malice.
TENTH AFFIRMATIVE DEFENSE
(LACK OF STANDING)
FOR AND AS A TENTH AFFIRMATIVE DEFENSE to all causes of action in the complaint,
these answering defendants allege that plaintiffs are barred from any relief, as the plaintiffs and/or
their agents are the direct cause of the default by defendants in this matter and that it was intentional
and with malice and the plaintiffs cannot establish legal ownership of the moneys or therefore the
debt as the moneys are the property of the taxpayers of Pennsylvania, granted to Smith & Morris
Holding LLC by DCED and given to the Borough of Honesdale by SMG LLC for the Revolving
Loan Fund. Once the contract (Project) was completed, then and only then was the debt the
property of the Borough of Honesdale. Since that did not occur, the Borough of Honesdale has no
Standing to request the grant back from Defendants/Petitioners.
II. FACTUAL BACKGROUND
1. On or about May 2011, Smith & Morris Holding, LLC and the Borough of
Honesdale entered into negotiations to seek a Keystone Communities Program Grant
from the Pennsylvania Department of Community & Economic Development
(hereinafter “DCED”) pursuant to the Keystone Main Streets program for funding
and technical assistance for a community's downtown revitalization and the Keystone

6. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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Communities Development Project that provides grants and grants-to-loans for
physical improvements in the community.
2. Defendants/Petitioners invested substantial time, expertise and funds in assisting the
Plaintiff/Respondents Borough of Honesdale in applying to the DCED for grants and
grants-to-loans for physical improvements to a building formally owned by Smith &
Morris Holding, LLC and located at 560 Main Street, Honesdale, Wayne County,
Pennsylvania, hereinafter referred to as the “Anchor Building Project”.
3. It was Smith & Morris Holding, LLC who applied, was approved and provided the
“matching funds” for the grant requirements and this was done with the help of Mary
Beth Woods of WEDCO. Then the WEDCO Board approved the request and it was
forwarded to the DCED for approval. The project was approved and it was suggested
that we allow Honesdale of create and administer the “Revolving Loan Fund” instead
of WEDCO as they were in charge of the downtown and it would only just make
sense to do it that way. Defendants/Petitioners agreed and the paperwork was started
to accomplish that goal.
4. As a result of the efforts of the Defendants/Petitioners, the Anchor Building
renovation project was approved by the DCED and a grant was made to
Defendants/Petitioners and given to the Plaintiff/Respondents Borough of Honesdale
to administer in the amount of $255,076.00 because DCED determined the renovation
project would result in a true and measurable benefit to the economy of Defendants
Honesdale Borough and Wayne County. (See Keystone Communities Grant Contract
between DCED and Honesdale Borough Exhibit 5)
5. Smith & Morris Holding, LLC was to act as the contractor of the building renovation
project as the Grant belonged to Smith & Morris Holding, LLC.
6. As part of the understanding between Smith & Morris Holding, LLC and the Borough
of Honesdale, The Dime Bank of Honesdale was to provide “bridge funding” to

7. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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commence the construction of the project, based upon the commitment of the grant
funding made by Plaintiff/Respondents DCED.
7. As part of the closing of the “bridge loan” with the Dime Bank of Honesdale, the
Plaintiff/Respondents required Smith & Morris Holding, LLC to execute certain
documents including:
(A)a Promissory Note dated April 25, 2013 to the Borough of Honesdale, in the
amount of Two Hundred Fifty-Five Thousand Seventy-Six ($255,076.00)
Dollars (a copy of which is attached hereto and made part hereof as Exhibit
1);
(B) a Mortgage and Security Agreement dated April 25, 2013 to the Borough of
Honesdale, in the amount of Two Hundred Fifty-Five Thousand Seventy-Six
($255,076.00) Dollars, providing the real estate at 552 Main Street,
Honesdale, Wayne County, Pennsylvania as security for the Promissory Note
(a copy of which is attached hereto and made part hereof as Exhibit 2);
(C) a Construction Loan Agreement dated April 25, 2013 with the Borough of
Honesdale (a copy of which is attached hereto and made part hereof as Exhibit
3); and,
(D) a Assignment of Leases and Rents to the Borough of Honesdale (a copy of which
is attached hereto and made part hereof as Exhibit 4).
8. Although not required by law to do so, Plaintiff/Respondents the Borough of
Honesdale required the Defendants/Petitioners Michael C. Morris and Stephen Smith
to execute Personal Guaranty and Surety ship agreements in favor of the Borough of
Honesdale, personally guaranteeing the obligations of Smith & Morris Holdings, LLC
under the hereinbefore mentioned Promissory Note, Construction Loan Agreement
and other agreements related to the Anchor Building Loan. The State has confirmed
that this is not a State requirement as told to Defendants/Petitioners that it was and
that it was not required by DCED and was done on behalf of a Honesdale Borough
request. (Note: Plaintiff/Respondents the Borough of Honesdale passed the Anchor

8. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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Building Project WITHOUT requiring Personal Guaranty and Surety ship
agreements. See Minutes - Borough Council Minutes - 2013 - Regular Mtg Feb-19
Exhibit 6)
9. Plaintiff/Respondents affirmed that it was Defendant Richard Henry who deserves the
credit for the Personal Guaranty and Surety ship agreements in an article date March
18th
2016. (See Wayne IND Mar 18-2016 Exhibit 7)
10. The Defendants/Petitioners have several confirmations from Cindy Campbell of
DCED that tell the Defendants/Petitioners that Personal Guarantees WERE NOT
required as the Defendants/Petitioners had more than enough capital invested into the
project to cover the grant. (See appraisal 4-22-2015, final property evaluation,
Exhibit 8)
11. During a final phone conversation with Edward Geiger of DCED, the
Defendants/Petitioners were also told that if we did not sign the personal guarantees’
we could not proceed forward with the Anchor Building project after substantial
monetary investment had already been expended thereby constituting a threat of
financial harm unless compliant.
12. Based on the above and what will be adjudicated in Wayne County Case : 317-2015-
CV which will be with both the criminal and civil aspects of this case, in the matter at
hand, this filing of the judgment was an intentional and with malice attempt at
extortion for the following reasons:
a) The Borough of Honesdale does not have standing in this case as the grant (the
tax payer money) was the property and reasonability of DCED and given to
SMH LLC to be used to create the Revolving loan fund. This is in the
contract signed by the Borough of Honesdale and DCED contained Keystone
Communities Grant Contract between DCED and Honesdale Borough Exhibit
5 contained on page 27, Appendix A, under Special Conditions paragraph 4
and signed by DCED and the Borough of Honesdale. It is also verified that

9. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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the grant was the property of SMH LLC as highlighted in Minutes - Borough
Council Minutes - 2013 - Regular Mtg Feb-19 Exhibit 6. The actual grant is
available upon request and will be part of Wayne County Case: 317-2015-CV.
b) Being that this was a grant, from the tax payers of Pennsylvania, administered by
DCED and given to SMH LLC as SMH LLC filed for, qualified for and was
approved for the grant, the only entity with standing to request the money
back is DCED. To date DCED has made no such request of SMH LLC or
Michael C. Morris or Stephen G. Smith.
c) Being that the Borough of Honesdale did not contribute “one penny” to the grant
to loan program, and they are one of the direct causes of the failure of the
project, to try to “collect” the money is reprehensible.
d) IF the Borough of Honesdale is under demand by DCED to return the Grant, the
only condition in which that can occur is when DCED or OIG has adjudicated
the Borough of Honesdale and found them guilty of Negligence in the
administration of this contract. That provision is also found in the Keystone
Communities Grant Contract between DCED and Honesdale Borough Exhibit
5 and in Minutes - Borough Council Minutes - 2015 - 06-08-15 Council
Minutes Exhibit 9 where and to quote “Solicitor Henry stated that the
Borough may be called upon by the Commonwealth to pay the money back
because it didn’t properly administer the loan. Councilor Jennings stated that a
letter to that fact was received.”
e) While we cannot confirm or deny 2, it would seem by the records of the Borough
of Honesdale minutes that in FACT DCED did find the Borough of Honesdale
Negligent in the administration of the loan and therefore Negligent in Wayne
County Case: 317-2015-CV. Therefore we request of the court the power to
subpoena and obtain all records and documentation from DCED, the Borough
of Honesdale and any other Legal firm or Agency involved in the Anchor
Building Project case.
f) If 2 is true and correct and verified then all contracts and notes in the possession
of the Borough of Honesdale are NULL and VOID. If it is not verified then
the contracts are still NULL and VOID as to charges forthcoming in Wayne

10. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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County Case: 317-2015-CV including Breach of Contract, Filing a false
criminal complaint (on the contracts) RICO and additional potential criminal
charges will show willful gross negligence in this matter.
g) A full adjudication of Wayne County Case: 317-2015-CV must be completed
before any judgments can be awarded as the Plaintiff/Respondents are the
direct cause of actions in Wayne County Case: 317-2015-CV and to do
otherwise would be premature.
PARTIES
1. The Petitioners herein are the Defendants, MICHAEL C. MORRIS, and STEPHEN G.
SMITH (collectively, “Petitioners”).
2. This complaint seeks to add these indispensable parties to the complaint and add the
following Plaintiff/Respondents as further investigation showed that they participated in
the failure of the “project” and/or aided the conspirators in their acts. The following
Defendants should be added:
3. The Respondent herein is the Plaintiff/Respondents, SCOTT J. SMITH, F. J.
MONAGHAN, JAMES L. BRENNAN, JR., JUANITA PISANO, BILL CANFIELD,
ROBERT JENNINGS, TIFFANY S. KOMINSKI, CAROLYN J. LORENT, HARRY
DEVRIEZE, MICHAEL AUGELLO, JEREMY EBERT, CHRIS MURRAY, TROY
JOHNSON, MICHAEL DUX, RICHARD B. HENRY ESQ. Individually their personal
capacities and as Council people for the BOROUGH OF HONESDALE and the
BOROUGH OF HONESDALE, WAYNE COUNTY, PENNSYLVANIA, MAYERS,
MENNIES & SHERR, LLP, ANTHONY R. SHERR, PENNSYLVANIA
DEPARTMENT OF COMMUNITY AND ECONOMIC DEVELOPMENT (DCED)
(“Respondent(s)”).

11. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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III.CAUSES OF ACTION - COUNTERCLAIM
Count I. EXTORTION Hobbs Act (18 U.S.C. § 1951)
2404. Hobbs Act -- Under Color of Official Right1
1. On July 26th
2016, Michael C. Morris sent an email to Mr. Tony Sherr, Attorney for the
Borough of Honesdale. In that email Michael C. Morris explained in part the
following (See Exhibit 10):
a. “Just in case you are going to try collect on the Anchor Building Project, I would
suggest that you read and understand the truth since you clients seem unable to
tell the truth.”
b. “It was SMH LLC that applied and was approved for the grant. It was SMH LLC
that have the project that qualified for the grant. It was SMH LLC that AGREED
to GIVE the grant to the Borough of Honesdale to become a revolving loan fund
for the betterment of the community. See enclosed.”
2. Enclosed was Minutes - Borough Council Minutes - 2013 - Regular Mtg July 08 (Exhibit
9a) where it states that SMH LLC applied to DCED for the grant.
3. That Attorney Sherr did not do his “do diligence” or that his clients lied to him is not the
responsibility of Michael C. Morris or Stephen G. Smith. Mr. Sherr was even given
fair warning to get the truth PRIOR to filing a knowingly false Judgment in an
attempt to extort money Under Color of Official Right from Michael C. Morris or
Stephen G. Smith.
4. In the Keystone Communities Grant Contract between DCED and Honesdale Borough
Exhibit 5 Section XV(a) DCED should have suspended and terminated the contract
within the first few days of the contract as was requested in writing and have it moved
back to WEDCO as requested over 10 times by Michael C. Morris and Stephen G.
Smith. By not “shutting down” the Borough of Honesdale in this matter to date
including that if they have demanded the GRANT back from the Borough of
Honesdale and thereby have found the Borough of Honesdale guilty of Negligence in
1 Some courts have held that a Hobbs Act violation does not require that the public official have de jure power to
perform any official act paid for as long as it was reasonable to believe that he/she had the de facto power to perform
the requested act. See United States v. Nedza, 880 F.2d 896, 902 (7th Cir. 1989) (victim reasonably believed state
senator had the ability to impact a local business) Most courts have held that a Hobbs Act violation does not
require that the public official be the recipient of the benefit of the extortion, and that a Hobbs Act case
exists where the corpus of the corrupt payment went to a third party.

12. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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the administration of the loan, by not resolving this situation with Michael C. Morris
and Stephen G. Smith and allowing the Borough of Honesdale to knowingly file a
false Judgment, they through their actions condone the actions and violations of their
own contract with the Borough of Honesdale, as contained in the Keystone
Communities Grant Contract between DCED and Honesdale Borough Exhibit 5 and
have proven to the business community that DCED is not trustworthy and honest to
their stated mission or even honorable in keeping a contract.
5. The Plaintiff/Respondents did willfully and with malice violate the Hobbs Act 18 U.S.C.
§ 1951 2404, Extortion, and have meet the standards of the Act by forcing
Defendants/Petitioners to execute Personal Guarantees through threat of financial ruin
that were not required by the State of Pennsylvania DCED with the help of the
DCED, Edward Geiger, as part of the Anchor Building Program with no intent to
perform the duties of their office and then in both published in a local paper and then
by threat of suit/judgment attempted to collect that money Under Color of Official
Right that they did not fund and knew that their failure in the administration of the
Anchor Building Project Loan was the cause of the failure of the Anchor Building
Project that will be adjudicated in Wayne County Case : 317-2015-CV.
Count II. Malicious Prosecution and Abuse of Process
6. Each of the foregoing paragraphs is hereby incorporated by reference as through set forth
in its entirety herein.
7. The Plaintiff/Respondents did willfully and with malice use the Court system to
prosecute a civil matter in which they knew or should have known that the claims
were false, the contracts voided and that they had no standing in the matter.
8. The Plaintiff/Respondents did willfully and with malice use the Court system to
prosecute a civil matter having full knowledge that according to Minutes - Borough
Council Minutes - 2015 - 06-08-15 Council Minutes Exhibit 9 they state that DCED
or the OIG “has sent them a letter to that fact”, thereby found them GUILTY of
Negligence in the Administration of the Loan and are demanding that the Borough of
Honesdale repay the Grant back as per the contract with DCED. If the Borough of
Honesdale has been required to repay the grant back to DCED as stated in Minutes -

13. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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Borough Council Minutes - 2015 - 06-08-15 Council Minutes Exhibit 9, then the
SAME Negligence in the administration of the loan nullifies the contracts, notes and
other documents as it was the direct cause of the failure of the project and will be
adjudicated fully in Wayne County Case : 317-2015-CV. This is further backed up
by the email from Cindy Campbell Exhibit 11. If DCED has not requested the money
back, and therefore not found them Guilty of Negligence of the Administration of the
loan, then in this case and with this case and with Wayne County Case : 317-2015-
CV all information through subpoena can be gathered and the cases properly
adjudicated.
Count III. Defamation
9. Each of the foregoing paragraphs is hereby incorporated by reference as through set forth
in its entirety herein
10. The Defendant the Borough of Honesdale on March 18th
2016 the local newspaper ran a
article (See Wayne IND Mar 18-2016 Exhibit 7) Anthony R Sherr who is the attorney
for Defendant the Borough of Honesdale stated that the personal guarantees by
Defendants/Petitioners are “valid and binding” when as an attorney who is fully
aware of the material facts of the case knows that these documents are or potentially
are null and void. Anthony R Sherr who is the attorney for Defendant the Borough of
Honesdale in that article stated that the Pennsylvania Inspector General’s Office is
investigating “on behest” of the Defendant the Borough of Honesdale. While
technically true, it was framed in such a way with the next sentence to imply “on
behalf” and that the Defendant the Borough of Honesdale did nothing wrong. This is
backed up by the next paragraph where Anthony R Sherr who is the attorney for
Defendant the Borough of Honesdale states in that article “Based upon the facts as
has been related to me…I am of the belief that there is absolutely no viable cause of
action against the borough”. This complaint proves otherwise and Anthony R Sherr
who is the attorney for Defendant the Borough of Honesdale was fully aware of its
contents prior to this statement. The statement also has some criminal legal issues.
According to Anthony R Sherr who is the attorney for Defendant the Borough of
Honesdale, to paraphrase, he has the facts of the investigation that is being conducted

14. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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by the Pennsylvania Inspector General. According to Katie Grady, the actual
Inspector investigating the case, NO ONE INCLUDING Defendant the Borough of
Honesdale is allowed to or will get a copy of the internal investigation. To say they
do implies that the information is false or obtained illegally. These statements were
told to the newspaper by Anthony R Sherr who is the attorney for Defendant the
Borough of Honesdale to garnish public opinion for eventual legal actions against the
Defendant the Borough of Honesdale in a willful conspiracy to “cover-up” the truth
of what had transpired in the Anchor Building Project.
11. This interview, March of 2016, is AFTER the Minutes - Borough Council Minutes -
2015 - 06-08-15 Council Minutes Exhibit 9 and therefore they knew that or should
have known that their statements were false including those made by an Officer of the
Court.
12. On August 13th
2016, the Borough once again publishes that they are seeking $300k from
Michael C. Morris and Stephen G. Smith when knowing or should have known that
this Judgment and complaint was false in substance based on the internal and external
information “in hand”.
Punitive Damages
The conduct of Plaintiff/Respondents described above is outrageous. Plaintiff/Respondents
conduct demonstrates a reckless disregard for the Law, the willful destruction inflicted on the
Defendants/Petitioners, their families and the Investors of the project and a conscious disregard
for public accountability and public funds used in this project. The acts and omissions described
above were willful and performed with actual or implied malice. The acts and omissions
described above were willful and performed with actual or implied malice using the “cover” of
immunity Under Color of Official Right. Treble, Punitive and Exemplary damages are therefore
appropriate and should be imposed in this instance.

15. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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PRAYER FOR RELIEF
WHEREFORE, Defendants/Petitioners respectfully pray for a judgment against Defendants for:
1. Injunctive and equitable relief as the Court deems appropriate including:
i. Requiring Plaintiff/Respondents to cease and desist all prosecutions,
foreclosures, debt collection, Sheriff’s Sale, Tax Sale, against
Defendants/Petitioners;
ii. Removal of all immunity protections of Government Officials; and
2. Compensatory damages to be paid by all Plaintiff/Respondents, according to proof at
trial;
3. Punitive damages, according to proof at trial;
4. Costs and attorneys fees of this lawsuit, with interest;
5. Any other relief as the court deems appropriate.
PLAINTIFFS DEMAND TRIAL BY JURY ON ALL ISSUES SO TRIABLE
WHEREFORE, the Defendants/Petitioners pray for judgment against the Defendants and each of
them, jointly and severally, in a sum in excess of $1,000,000.00, costs of this action, punitive
damages against the individual defendants in their individual capacities, attorney's fees, and such
other relief as the court deems proper.
Respectfully submitted,
Michael C. Morris, Pro Se

16. ANSWER OF COMPLAINT 400-CV-2016 and 401-CV-2016 AND COUNTERCLAIM, ADDITION OF DCED AND ADDITIONAL
INDISPENSABLE PARTIES AND REQUEST and REQUEST FOR TREBLE DAMAGES AND REQUEST FOR INJUNCTIVE RELIEF
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VERIFICATION
MICHAEL C. MORRIS , execute this Verification on behalf of the
Defendants/Petitioners. They further state that the statements of fact made in the foregoing are
true and correct upon personal knowledge, information and belief. The undersigned understand
that the statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating
to unsworn falsification to authorities.
Date: ______________ ____________________________________
MICHAEL C. MORRIS