“P/n/g”

Legalese puzzle: What is the meaning of “p/n/g,” which is sometimes used in case captions in Pennsylvania and occasionally New York?

I’m not asking about “PNG,” which sometimes stands for “p/n/g,” but more often for Papua New Guinea, the Professional Numismatists Guild, or other things.

UPDATE: Bleh and D.J., in the comments, were the first to get it right; see this Third Circuit opinion for a bit of context. Naturally, it’s not “persona non grata,” which is listed in the dictionary as “p.n.g.” Compare also ppa, which is mostly used in Connecticut but with a smattering of references in neighboring states.