Gregory Stenstrom, Pro Se Leah Hoopes, Pro Se

1541 Farmers Lane Glen Mills, PA 19342 241 Sulky Way

856-264-5495 Chadds Ford, PA 19317 610-608-3548
gregorystenstrom@gmail.com leahfreedelcopa@protonmail.com
gstenstrom@xmail.net

IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY

PENNSYLVANIA (CIVIL DIVISION)

JAMES SAVAGE, Case No. CV-2022-008511

et al, MOTION TO DISMISS and

Plaintiffs, MOTION FOR SANCTIONS

v. Note: Proposed Order attached last page

NEWSMAX MEDIA, INC.

et al, NOTICE TO PLEAD: To Plaintiffs:

You are hereby notified to file a written response to
Defendants within twenty (20) days from date of
Defendants service hereof or a judgement may be entered
against you. /s/ Gregory Stenstrom and Leah Hoopes

PRO SE DEFENDANT’S MOTION TO DISMISS AND

MOTION FOR SANCTIONS

1. Pro Se Defendants Stenstrom and Hoopes submit this Motion to Dismiss and Motion for
Sanctions for Plaintiffs’ failure to complete service and attend to their complaint pursuant to,
and in accordance with, 231 Pa. Code §§ 401(a), § 401(b)(4) and § 404.

BRIEF IN SUPPORT OF MOTION TO DISMISS AND MOTION FOR SANCTIONS

2. Plaintiff's attorney (J. Conor Corcoran) has not filed required Praecipe to Reinstate since
August 31, 2023, 176 days ago.

3. Plaintiffs have not completed proper service in the 470 days since their original Writ of
Summons naming multiple named Defendants, including Pro Se Defendants Gregory

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 Stenstrom and Leah Hoopes1; and Defendants Regina Manidis, Margot Cleveland, and The
Federalist; nor have Plaintiffs attended to their complaint.

4. J. Conor Corcoran, the attorney who originated the subject complaint on behalf of Plaintiffs
Savage and Allen, has entered a Motion to Withdraw from two other nearly identical,
frivolous defamation cases brought forward in the Philadelphia Court of Common Pleas, Case
Numbers 211002495 and 230500012 that he has dragged out for 850 days (Exhibit A).

5. Plaintiffs' attorney, J. Conor Corcoran, is the subject of serious complaints of misconduct, and
disbarment, brought forward by the Pennsylvania Disciplinary Board that Corcoran has
replicated in subject case, and defamation cases in Philadelphia. (Exhibit B).

6. Plaintiffs' attorney, J. Conor Corcoran, has stated he is closing his law practice in
Pennsylvania (see also Exhibit A).

7. James Savage, the former Delaware County Voting Machine Warehouse Custodian, is
Plaintiff in subject case in Delaware County (CV-2022-008511) and nearly identical cases on
Philadelphia County, has collectively sued:
a. President Donald Trump
b. Former New York City Mayor Rudy Giuliani
c. Former State of Kansas Attorney General Phil Kline
d. The Thomas More Society
e. Attorney Jenna Ellis
f. Newsmax Media, Inc.
g. America First, Inc.
h. The Federalist
i. Attorney Margot Cleveland
j. Former White House Deputy Press Secretary Hogan Gidley
k. Newsmax Journalist Luca Cacciatore
l. Fox News Journalist Rob Schmitt
m. Gregory Stenstrom
n. Leah Hoopes
o. Regina Miller Manidis

8. Attorney J. Conor Corcoran solicited Plaintiffs, filed frivolous, conjectural complaints

without any material facts, and failed to meet a majority of the most basic procedural
requirements in accordance with Pa.R.C.P., or meet Case Management Order deadlines in his

1
The December 20th, 2022, Affidavit of Service by Sheriff to Leah Hoopes is unsigned, vaguely states
served “S/A,” and she has not yet been properly served.

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 Philadelphia Court of Common Pleas action, or even perfect the subject case in the Delaware
County Court of Common Pleas in violation of Pa.R.P.C. (See Exhibit C).

9. All documentation regarding the November 2020 election necessary for Plaintiffs to provide
material facts to sustain their complaint have been unlawfully destroyed by Delaware County
former Solicitor William F. Martin (see Exhibit D).

10. All documentation and public records regarding the November 2020 election necessary for
Plaintiffs to sustain their complaint have been unlawfully withheld by current Delaware
County Solicitors Robert Scott and Jonathan Liechenstein (see Exhibit E).

11. American Bank & Trust Co. v. Ritter, Todd & Haayen, 418 A.2d 408 (Pa.Super. 1980).
Memory loss and the disappearance of witnesses and documents that prevent the
reconstruction of a defense are prejudicial to defendants. Jacobs v. Halloran, 1710 A.2d 1098,
1102 (Pa. 1998).

12. Substantial diminution of a defendant’s ability to present factual information in the event of
a trial that has been brought about by plaintiff’s delay is, likewise, prejudicial. American Bank
& Trust Co., 418 A.2d 4 at 410.

13. The Entry of Appearance by attorney John Rooney and Withdrawal by J. Conor Corcoran
without explanation which is concurrent to Corcoran’s currently contested withdrawal from
the like frivolous Philadelphia Court of Common Pleas defamation case is an obvious
contrivance to sustain the harassment of Defendants and abuse of the Honorable Court(s).
(see Exhibit F)

14. Plaintiffs Savage and Allen, and their attorney, J. Conor Corcoran, filed these frivolous suits
with the intent to harass and intimidate Pro Se Defendants Stenstrom and Hoopes, who are
Plaintiffs in other active litigation against Savage and Allen, including Stenstrom and Hoopes
v. Secretary of the Commonwealth Boockvar, Allen, Savage, et al (876 & 877 CD 2022
Commonwealth Court of Pennsylvania), which is scheduled to be heard in the April 8th, 2024
session of the Commonwealth Court, and are witnesses to election and criminal law violations
committed by Savage and Allen.

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 REMEDY

15. Lawsuits are serious matters which both Plaintiffs and their licensed attorneys have a duty to
diligently attend to, and not let languish with the intent of harassing and intimidating litigants
as strategic leverage to alter the trajectories of lawsuits in other jurisdictions.

16. Plaintiffs’ attorney J. Conor Corcoran has abused the Honorable Court for 470 days in the
subject case, and 850 days in nearly identical defamation actions in Philadelphia Court of
Common Pleas, without proper service, contemptuous disregard for any court ordered or
statutory deadlines, and clear malicious intent to harass Defendants.

17. The abuse of the Honorable Court in this regard is a serious matter that only severe, punitive
monetary sanctions can remedy, and also provide surface area for the Pennsylvania
Disciplinary Board to further act on.

18. Plaintiffs and Plaintiffs’ attorney Corcoran frivolous complaint(s) and callousness in
attacking Pro Se Defendants Stenstrom and Hoopes has stolen their time and peace of mind,
penalized them for fulfilling statutory duties as certified poll watchers, and caused them
substantial emotional harm.

19. Wherefore, Pro Se Defendants Stenstrom and Hoopes request the Honorable Court grant the
attached, proposed order.

Respectfully submitted,

LEAH HOOPES GREGORY STENSTROM

241 Sulky Way 1541 Farmers Lane
Chadds Ford, PA 19317 Glen Mills, PA, 19342
Telephone: 610-608-3548 Telephone: 856-264-5495
leahfreedelcopa@protonmail.com gstenstrom@xmail.net
23FEB2023 gregorystenstrom@gmail.com
23FEB2023

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 VERIFICATION

We, Gregory Stenstrom and Leah Hoopes, state that we are Pro Se Defendants in this

matter and are authorized to make this Verification on its behalf. We hereby verify that the

statements made in the foregoing Motion to Dismiss and Motion for Sanctions are true and correct

to the best of our knowledge, information, and belief. This verification is made subject to the

penalties of 19 Pa.C.S. § 4904 relating to unsworn falsification to authorities.

__________________________________
GREGORY STENSTROM
PRO SE

__________________________________
LEAH M. HOOPES
PRO SE

Dated: 23FEB2023

Page 5 of 7
Pro Se Defendants Gregory Stenstrom and Leah Hoopes

Gregory Stenstrom, Pro Se Leah Hoopes, Pro Se

1541 Farmers Lane 241 Sulky Way
Glen Mills, PA 19342 Chadds Ford, PA 19317
856-264-5495 610-608-3548
gstenstrom@xmail.net leahfreedelcopa@protonmail.com
gregorystenstrom@gmail.com

IN THE COURT OF COMMON PLEAS OF

DELAWARE COUNTY PENNSYLVANIA
(CIVIL DIVISION)

Case No. CV-2022-008511

JAMES SAVAGE
Plaintiff, MOTION TO DISMISS
v. MOTION FOR SANCTIONS

DONALD J. TRUMP,

et al, CERTIFICATE OF SERVICE

Defendants

The undersigned hereby certifies that, on this date, they caused the foregoing Motion to Dismiss
and Motion for Sanctions, to be filed electronically with the Court, where it is available for viewing
and downloading from the Court’s ECF system, and that such electronic filing automatically
generates a Notice of Electronic Filing constituting service of the filed document upon all counsel
of record.

/s/ Gregory Stenstrom and Leah Hoopes

Dated: 23FEB2023

Page 6 of 7
____________________________________________________________________________
IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY PENNSYLVANIA
(CIVIL DIVISION)

JAMES SAVAGE,
Case No. CV-2022-008511
et al,
MOTION TO DISMISS and
Plaintiffs,
MOTION FOR SANCTIONS
v.

NEWSMAX MEDIA, INC.

et al,

Defendants
____________________________________________________________________________

ORDER

AND NOW, this ______day of ____________ , 2024, upon consideration of Defendant’s Motion
to Dismiss with Prejudice, and Motion for Sanctions, and any response thereto, it is hereby
ORDERED and DECREED that said Motions are GRANTED.

Pro Se Defendants Stenstrom and Hoopes shall each be paid:

Fifty-thousand US dollars ($50,000) __________________ by Plaintiff Savage, and,

Fifty-thousand US dollars ($50,000) __________________ by Plaintiff Allen, and,

Fifty-thousand US dollars ($50,000) __________________ by Plaintiff’s attorney J.

Conor Corcoran,

for a total of $150,000 to each Pro Se Plaintiff Stenstrom and Hoopes, and total sanctions
in the amount of $300,000 _______________.

BY THE COURT

____________________

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