2016
01.29
COMMONWEALTH OF PENNSYLVANIA # 3151-15
  #MJ-38118-CR-0000096-2015
v.  
  Superior Court
Terance Healy #3166 EDA 2015
  #3234 EDA 2015

NOTICE OF ERRORS AND OMISSIONS IN THE TRANSMITTED COURT RECORD

Appellant hereby notified the Superior Court that the Court record transmitted to the Appellate Court contains egregious ommissions and errors.

Appellant requests the Superior Court order an explanation by the Clerk of Courts who has already been notified of the errors with the docket.

Terance Healy

2016
01.29
COMMONWEALTH OF PENNSYLVANIA # 3151-15
  #MJ-38118-CR-0000096-2015
v.  
  Superior Court
Terance Healy #3166 EDA 2015
  #3234 EDA 2015

REQUEST FOR TRANSCRIPT

A Notice of Appeal having been filed in this matter, the official Court Reporter is hereby Ordered to produce, certify and file the transcripts and Exhibits and related documents in this matter in conformity with Rule 1922 of the Pennsylvania Rules of Appellate Procedure.

The “roll call” on January 27, 2016 includes the appearance by the defendant at the proceeding, the acknowledgement by the Court, and the statement from the District Attorney indicating their unpreparedness to proceed.

Terance Healy

2016
01.29
COMMONWEALTH OF PENNSYLVANIA # 3151-15
  #MJ-38118-CR-0000096-2015
v.  
  Superior Court
Terance Healy #3166 EDA 2015
  #3234 EDA 2015

NOTICE OF APPEAL

Notice is hereby given that Terance Healy, Defendant, Appellant named above hereby appeals to the Superior Court of Pennsylvania from the Order(s) entered in this matter on the 27th day of January 2016.

The order(s) of January 27, 2016 having been issued verbally in judge’s chambers without any proceeding while Defendant waited in the Courtroom for the scheduled proceeding to be called.

Defendant had filed a STATEMENT with the Court. Attached.

The Honorable Judge William Carpenter acknowledged the presence of the Defendant and the receipt of the filed statement during the 9:30 “roll call” in the courtroom.

Defendant was not provided any opportunity to address the court regading any issue or present any argument or defense.

Copies of the Order(s) have been requested and NOT PROVIDED to Defendant.

Defendant had filed a REQUEST FOR INVESTIGATION with the Court. Attached.

The Defendant hereby incorporates all prior Statements, in their entirety, filed regarding this matter:
STATEMENT OF DEFENDANT ON APRIL 9, 2015
Letter to District Attorney / PA Attorney General
STATEMENT OF DEFENDANT ON JUNE 10, 2015
Letter to PA Attorney General / District Attorney / Sheriff
STATEMENT OF DEFENDANT ON AUGUST 10, 2015
STATEMENT OF DEFENDANT ON SEPTEMBER 16, 2015
STATEMENT OF DEFENDANT ON OCTOBER 14, 2015
STATEMENT OF DEFENDANT ON NOVEMBER 18, 2015
STATEMENT OF DEFENDANT ON JANUARY 27, 2016
REQUEST FOR INVESTIGATION

Request for InvestigationThe REQUEST FOR INVESTIGATION was concurrently filed with
1) the Court of Common Pleas
2) The Superior Court of Pennsylvania
3) The US Attorney, Eastern District, Zane Memeger
4) Pennsylvania Attorney General Kathleen Kane
5) Pennsylvania Governor Tom Wolf
6) The Supreme Court of Pennsylvania, Disciplinary Board

As required by established procedure, Terance Healy, Defendant, Appellant above named, hereby appeals to the Superior Court of Pennsylvania. This procedural action should not be interpreted or misconstrued so as to provide jurisdiction to the Court of Common Pleas.

Pursuant to Pa R.A.P 904(c), I, Terance Healy certify that an order for transcripts is attached.

The subject verbal order(s) issued in chambers without hearings remain unentered on the docket.

Respectfully,

Terance Healy

2016
01.27
COMMONWEALTH OF PENNSYLVANIA # 3151-15
  #MJ-38118-CR-0000096-2015
v.  
  Superior Court
Terance Healy #3166 EDA 2015
  #3234 EDA 2015

STATEMENT OF DEFENDANT ON JANUARY 27, 2016

The criminal allegations are unfounded.

I have not previously and do not intend to waive any rights under Pennsylvania Law, the Pennsylvania Constitution or the Constitution of the United States.

I have not signed any Waiver of Counsel. There has been no colloquy. The inability to be represented by counsel is affected by an improperly enacted and collaterally unconstitutional Rule 1.6 Confidentiality of Information.

Rule 1.6 causes the complete and absolute denial of any protection of the law and all constitutionally protected rights ere ignored.

My appearance at this, or any, proceeding should not be misconstrued in any way to suggest or indicate any waiver of any protection of the law or the constitution of the Commonwealth of Pennsylvania which provide for the jurisdiction of the courts.

PENDING APPEALS

There are currently two pending appeals in this matter.

1) Filed on October 20, 2015, relating to the Order of October 14, 2015, seeking the full Statement of Jurisdiction for the Court in this matter.
– Opinion filed neglects to indicate or address jurisdiction.

2) Filed on October 27, 2015, relating to the Order of October 22, 2015, seeking IFP status for transcripts required for the prior Appeal relates to a verbal Order of the Court was made on
– Opinion filed fails to address ANY relevant issue.

The Court Record transmitted to the Superior Court is grossly inaccurate and incomplete.

Pursuant to Rule 521 of the Rules of Appellate Procedure, the Pennsylvania Attorney General has been notified that the Appeals relate to and challenge the constitutionality of a statute.

CLERK OF COURTS

Documents filed by the Defendant with the Clerk of Courts when provided to the Court (and not misrouted) have been modified with a cover sheet which identifies the Statements of the Defendant as PRISONER CORRESPONDENCE. An INCORRECT and slanderous MIS-CHARACTERIZATION of the Defendant.

Upon filing a document indicating the discrepancies on the Court Docket with this Court (and with the Superior Court of Pennsylvania), the Clerk of Courts has refused to provide the printed Court Docket to the Defendant.

Prior to noting the discrepancies in the Docket, the Clerk had provided the printed Docket when requested.

Since filing regarding the discrepancies, the Clerk has insisted upon payment of $1 per page suggesting the printed Court Docket is a ‘copy’ which is assessed a ‘per page copy fee’.

Defendant is currently In Forma Pauperis in this matter and cannot afford the fees for the printed Docket.

The Clerk of Courts has NOT RESPONDED to the discrepancies reported.

The District Attorney has NOT RESPONDED to the discrepancies reported.

The Clerk of Courts has been unable to identify the veracity of ANY document.

The Clerk of Courts has been unable to indicate the methods by which ANY document is authenticated or verified for inclusion on the Court Docket.

FAILURE TO PROVIDE INVESTIGATION DOCUMENTS

The District Attorney has neglected to provide documents secured in the investigation by search warrant which demonstrate the innocence of the Defendant.

Those documents further demonstrate and support the narrative of abuse of power under color of law by the District Attorney et al which dates back over 10 years.

Those documents demonstrate the erroneous nature of the investigation and criminal allegations and must be provided to the Defendant.

The Defendant has requested all investigative materials to prepare his defense. The Request for those documents which should have been included in the “INFORMATION” has been ignored.

Defendant requests to be provided with any emails, letters, documents, contracts or agreements between the District Attorney and any other person, party or organization which prevents the prosecution of crimes against the Defendant, including but not limited to fraud, theft, and threats to murder the Defendant or efforts which deny the Defendants rights protected by the Constitution of the United States.
DEFENDANT STATEMENTS

The Defendant hereby incorporates all prior Statements, in their entirety, filed regarding this matter:
STATEMENT OF DEFENDANT ON APRIL 9, 2015
Letter to District Attorney / PA Attorney General
STATEMENT OF DEFENDANT ON JUNE 10, 2015
Letter to PA Attorney General / District Attorney / Sheriff
STATEMENT OF DEFENDANT ON AUGUST 10, 2015
STATEMENT OF DEFENDANT ON SEPTEMBER 16, 2015
STATEMENT OF DEFENDANT ON OCTOBER 14, 2015
STATEMENT OF DEFENDANT ON NOVEMBER 18, 2015

The District Attorney has failed to respond to any issues raised in the statements including those which address the deliberate failure to adhere to the Rules of Criminal Procedure, and those actions which deny the constitutional rights of the Defendant.

FAILURE TO PROCEED WITH THE ISSUES OF THE MATTER

The proceeding on January 27, 2016, represents another effort by the District Attorney to harass the Defendant by requiring an appearance in Court for which the District Attorney is unprepared and has deliberately acted to prevent the proper defense preparation by the Defendant.

Since the Defendant was arrested from his mother’s home on March 13, 2015, the defendant has been prevented from freedom of movement, and any effort to return to his home is prevented by the bail arrangement.

During this time, the persons who have stolen the residence of the Defendant by fraudulent conveyance have collected the title insurance ($400,000.00); and improperly used his property as collateral in a loan for Over $375,000.00; provisioned planned and trained to murder the Defendant in a letter to the District Attorney; among the false testimony provided to police and the Court.

Defendant has been kept homeless and destitute while forced to defend himself in constant and unrelenting litigation in every level of state and Federal Courts.

A REQUEST FOR INVESTIGATION has been filed concurrently with this Statement with copies to the Pennsylvania Attorney General.

FAILURE TO FOLLOW THE RULES OF CRIMINAL PROCEDURE

There has been no effort demonstrated by the District Attorney to adhere to the Rules of Criminal Procedure.

FAILURE TO RESPECT CONSTITUTIONAL RIGHTS

There has been no effort to respect the Defendants rights which are protected by the US Constitution and the Pennsylvania Constitution.
IMPROPER CONDUCT BY PRIVILEGED DEPARTMENTS / PERSONS

There has been a repeated effort to utilize improper actions, and manipulative efforts and deeds by persons, and departments within the Courthouse, with whom the District Attorney has an attorney-client relationship and a mandate of confidentiality.

Those actions which neglect or directly violate the Rule of Law, and deny the constitutional rights of the Defendant are prevented from being addressed by the District Attorney pursuant to Rule 1.6 Confidentiality of Information – which is a broad confidentiality mandate which includes the attorney-client privilege.

The confidentiality mandate demonstrates the denial to the defendant of the protection of the Rule of Law and rights protected by Constitutions.

AFFECTING SUBSTANTIVE RIGHTS

As Rule 1.6 Confidentiality affects the substantive rights of a Defendant, the Supreme Court of Pennsylvania was without proper authority to enact the Rule pursuant to Article V Section 10(c).

IMPROPERLY ENACTED AND UNCONSTITUTIONAL

Rule 1.6 Confidentiality of Information has been improperly enacted and is unconstitutional. As such, it can provide no defense for those who deny, subvert or ignore the constitutional rights of the Defendant.

REALIZATIONS / EXPECTATIONS

The efforts of the District Attorney to prevent investigation and prosecution of crimes ANY AND EVERY crime reported by the Defendant while excusing and endorsing those who continue to commit crimes against the Defendant are well documented. Any explanation for those actions remains unanswered.

Whether unanswered due to attorney client privilege, or where information has been deliberately concealed by grand jury, the actions and inactions of the District Attorney have placed the life of the Defendant in immediate and constant jeopardy and created a situation from which the Defendant can find no relief or resolution.

Additionally, the actions which exacerbate the crimes committed against the Defendant provide for MOTIVE which is clearly established for

– those involved in the crimes involving the Defendants property face the risk of criminal prosecution for their false reports, fraud, the fraudulent conveyance, insurance fraud, death threats, etc.

– those involved in the improper, unlawful and corrupt actions within the Courthouse can be further intimidated and manipulated into further corrupt acts against the Defendant.
The continued use, intimidation and abuse of persons, departments, agencies, contractors and businesses deliberately selected for involvement where under the protection of attorney-client relationship and the unconstitutional confidentiality it accords threatens the life of the Defendant, and those around him.

These corrupt efforts undermine the Rule of Law and undermine the independence of the judiciary. They permit injustice to be ignored without regard for human life, human rights, constitutional rights, ethics or morality.

The Defendant would prefer resolution to facing the remainder of his life in fear and under threat. Every effort of the Defendant demonstrate that intention and preference.

Respectfully,

Terance Healy

2016
01.27
COMMONWEALTH OF PENNSYLVANIA # 3151-15
  #MJ-38118-CR-0000096-2015
v.  
  Superior Court
Terance Healy #3166 EDA 2015
  #3234 EDA 2015

REQUEST FOR INVESTIGATION

Defendant requests the Honorable Court refer this matter to the proper law enforcement organization for investigation of the crimes committed by the District Attorney, the Office of the District Attorney, and the various County departments and personnel with whom there exists an attorney-client privilege which mandates non-disclosure Plaintiffs and their representative counsel.

Defendant calls judicial notice where there exists various Attorney-Client relationships involving the Montgomery County District Attorney, the Office of the District Attorney staff, various organizations within the Montgomery County Courthouse, and their legal representatives, including Court Administration, the Clerk of Courts whose actions concealed by mandates of Confidentiality pursuant to Rule 1.6 Confidentiality of Information prevents information, investigation and prosecution while obstructing justice and denying constitutional rights.

Defendant calls judicial notice to the resultant denial of the Rule of Law and Constitutional protections which demonstrate Rule 1.6 Confidentiality of Information to be unconstitutional and improperly enacted by the Supreme Court of Pennsylvania pursuant to Article V Section 10 (c).

Defendant calls judicial notice where there may exist various Attorney-Client relationships involving the Office of the Attorney General of Pennsylvania by which the mandates of Confidentiality pursuant to Rule 1.6 Confidentiality of Information prevents investigation and prosecution while obstructing justice and denying constitutional rights.

Defendant requests the Court refer the matter to the proper lawful authority unencumbered by ANY privileged relationships or ANY improperly enacted and unconstitutional Confidentiality mandates which deny and prevent justice and interfere with and deny the constitutional rights of the Defendant.

Defendant suggests a Special Investigator, unencumbered by any Attorney-Client relationships mandated pursuant to Rule 1.6 Confidentiality of Information, be appointed to investigate and once completed refer the matter for prosecution by the proper law enforcement organization.

This is NOT unprecedented. Since December 1, 2015, Doug Gansler, as Special Attorney General, has been conducting an investigation on behalf of the Commonwealth where it is was deemed essential and necessary that his efforts be unencumbered by attorney-client relationships and Rule 1.6 mandates of confidentiality.

Respectfully,

Terance Healy
Defendant

2016
01.26

Jeffrey Trauger, Esq. of GRIM, BEIHN & THATCHER, filed a foreclosure action without having ANY loan documents on behalf of First Savings Bank of Perkasie.

Defendant responded requesting ‘the note’ and a full accounting from the bank of the ‘loan’.

Without ANY documentation, First Saving Bank and Trauger wanted out of their improper foreclosure action.

KTMT purchased the ‘zombie loan’ from First Savings Bank for One Dollar ($1) and have continued with vexatious, unsubsantiated and fraudulent litigation for the last 3+ years.

Protecting Grim Beihn & Thatcher & First Saving Bank of Perkasie by concealing the initial fraud, KTMT would be compensated through the theft of a property valued at $1.2 million for a $1 investment and the costs of litigation – which may include inducements for Court Administration to prevent hearings and obtain default judgments.

The following motions were filed as they attempt to take possession of the property.
MOTION TO DISMISS THE PLAINTIFF’S PETITION TO APPOINT NICOLE PLANK, ESQUIRE, RECEIVER
AND
MOTION TO DISMISS PLAINTIFF”S MOTION FOR DISPOSITION OF PLAINTIFF PETITION TO APPOINT NICOLE PLANK, ESQUIRE, RECEIVER

MOTION FOR INVESTIGATION

MOTION TO ADDRESS PLAINTIFF’S PURPORTED ‘JUDGMENT’

MOTION TO ADDRESS PLAINTIFF’S LACK OF STANDING

MOTION TO ADDRESS PLAINTIFF’S PURCHASE / ASSIGNMENT

2016
01.26

(Filed in Bucks County, PA)

MOTION TO DISMISS THE PLAINTIFF’S PETITION TO APPOINT NICOLE PLANK, ESQUIRE, RECEIVER
AND
MOTION TO DISMISS PLAINTIFF”S MOTION FOR DISPOSITION OF PLAINTIFF PETITION TO APPOINT NICOLE PLANK, ESQUIRE, RECEIVER

1. Nicole Plank, Esquire, has been attempting to conceal a ‘lack of standing’ in this matter for years, while generating excessive volumes of litigation which has been vexatious, fraudulent and determined to misinform and misdirect this Honorable Court. Her fraudulent efforts persist.

2. Ms. Plank’s deliberate negligence in failing to respond, indicate or demonstrate proper and lawful standing in this matter causes a lack of jurisdiction for the Court. The purported JUDGMENT she again fails to present is defective and void and issued without lawful jurisdiction.

3. There have been no hearings in this matter before the Court of Common Pleas, Bucks County.

4. The timely Reply and Responses by the Defendant to each step of litigation has challenged issues which relate to standing, jurisdiction, and lack of relevant documentation or signed paperwork which indicates the existence of the loan which they are attempting to foreclose.

5. The Plaintiff’s failure and neglect to respond to issues; address questions; avoidance of hearings, testimony and evidence; repeated seeking of improper default judgments; etc… Plaintiffs fraudulent actions demonstrates the motivation and participation in the fraudulent scheme.

Jeffrey Trauger, Esq. of GRIM, BEIHN & THATCHER, filed a foreclosure action without having ANY loan documents on behalf of First Savings Bank of Perkasie.

Defendant responded requesting ‘the note’ and a full accounting from the bank of the ‘loan’.

Without ANY documentation, First Saving Bank and Trauger wanted out of their improper foreclosure action.

KTMT purchased the ‘zombie loan’ from First Savings Bank for One Dollar ($1) and have continued with vexatious, unsubsantiated and fraudulent litigation for the last 3+ years.

Protecting Grim Beihn & Thatcher & First Saving Bank of Perkasie by concealing the initial fraud, KTMT would be compensated through the theft of a property valued at $1.2 million for a $1 investment and the costs of litigation – which may include inducements for Court Administration to prevent hearings and obtain default judgments.

AN INAPPROPRIATE RECEIVER

For those reasons set forth above, including but not limited to the fraud and deceptive practices and activities demonstrated and perpetrated by Nicole Plank, Esq;

and

Upon review and consideration of the following Motions filed concurrently and fully incorporated into this document which demonstrate the fraudulent and deceptive actions in this matter currently before the Court;

The Defendant STRONGLY OBJECTS to the appointment of Nicole Plank, Esq. As Receiver.

WHEREAS,

Defendant requests this Honorable Court DISMISS The Plaintiff’s Petition To Appoint Nicole Plank, Esquire, Receiver with prejudice.

UNDO HASTE TO APPOINT RECEIVER

For those reasons set forth above, including but not limited to the fraud and deceptive practices and activities demonstrated and perpetrated by Nicole Plank, Esq;

Where the Plaintiff”S Motion For Disposition Of Plaintiff Petition To Appoint Nicole Plank, Esquire, Receiver has been filed concurrently with a Petition seeking appointment, demonstrates an aggressive and vexatious effort by the Plaintiff seeking haste to prevent a careful review of the matter

and

Upon review and consideration of the following Motions filed concurrently and fully incorporated into this document which demonstrate the fraudulent and deceptive actions in this matter currently before the Court;

The Defendant STRONGLY OBJECTS to the undo haste requested in PLAINTIFF”S MOTION FOR DISPOSITION OF PLAINTIFF PETITION TO APPOINT NICOLE PLANK, ESQUIRE, RECEIVER.

WHEREAS,

Defendant requests this Honorable Court DISMISS PLAINTIFF”S MOTION FOR DISPOSITION OF PLAINTIFF PETITION TO APPOINT NICOLE PLANK, ESQUIRE, RECEIVER with prejudice.

Respectfully,

2016
01.26

(filed in Bucks County, PA)
Defendant requests the Honorable Court refer the matter to the proper law enforcement organization for investigation of the crimes committed by the Plaintiffs and their representative counsel.

Defendant calls judicial notice where there exists various Attorney-Client relationships involving the Bucks County District Attorney, the Plaintiffs, their legal representatives, and various organizations within the Bucks County Courthouse including Court Administration by which the mandates of Confidentiality pursuant to Rule 1.6 Confidentiality of Information prevents investigation and prosecution while obstructing justice and denying constitutional rights.

Defendant calls judicial notice where the resultant denial of the Rule of Law and Constitutional protections cause Rule 1.6 Confidentiality of Information to be unconstitutional and improperly enacted by the Supreme Court of Pennsylvania pursuant to Article V Section 10 (c).

Defendant calls judicial notice where there may exist various Attorney-Client relationships involving the Office of the Attorney General of Pennsylvania by which the mandates of Confidentiality pursuant to Rule 1.6 Confidentiality of Information prevents investigation and prosecution while obstructing justice and denying constitutional rights.

Defendant requests the Court refer the matter to the proper lawful authority unencumbered by ANY privilege or ANY improperly enacted and unconstitutional Confidentiality mandates which deny and prevent justice.

Defendant suggests a Special Investigator, unencumbered by any Attorney-Client relationships mandated pursuant to Rule 1.6 Confidentiality of Information, be appointed to investigate and once completed refer the matter for prosecution by the proper law enforcement organization.

This is NOT unprecedented. Since December 1, 2015, Doug Gansler has been conducting an investigation on behalf of the Commonwealth where it is was deemed essential and necessary that his efforts be unencumbered by attorney-client relationships and Rule 1.6 mandates of confidentiality.

Respectfully,

2016
01.26

(Filed in Bucks County PA)

1. The Plaintiff has failed to demonstrate a proper and lawful standing to bring this matter before the Court.

2 The Defendant has raised the issue of the Plaintiff’s lack of standing in every filing, response, petition and motion.

3. The Plaintiff has failed to demonstrate proper and lawful standing and has caused the Court to be without jurisdiction in this matter.

4. The Defendant STRONGLY CHALLENGES the jurisdiction of this Court with the responsibility on the Plaintiff to provide evidence which supports jurisdiction.

FRAUD UPON THE COURT

5. Nicole Plank, Esq. now presents a thirty-nine (39) page Motion for the purpose of becoming Receiver by referring to collateral documents; her extensive plans for disposing of the property; referring to her prior attempts to become Receiver; listing events which have occurred in other courts; … The logical fallacy suggesting that either she or her clients are the recipients of a judgment entered in their favor.

6. NICOLE PLANK, ESQ. HAS NEGLECTED TO INCLUDE THE “JUDGMENT” WHICH PROVIDES THE BASIS FOR HER ARGUMENT.

7. Nicole Plank, Esq. has neglected to provide the ‘judgment’ knowingly and in this deliberate manner attempts to mislead this Court.

8. Nicole Plank, Esq. has neglected to provide the ‘judgment’ to avoid sanctions, penalties, or criminal prosecution for presenting a fraudulent document to the Court.

9. The failure and negligence to provide the ‘judgment’ suggests that Nicole Plank Esq. is cognizant of the defective and void nature of the document which purportedly supports her Motions regarding her being appointed as Receiver.

10. Defendant believes the request to provide the document(s) alleged to support the plaintff’s motion is reasonable and timely and directly affect the matter before this Honorable Court.

WHEREAS, the Defendant respectfully requests this Honorable Court to IMMEDIATELY REQUIRE the attorney for the Plaintiff, Nicole Plank, Esquire, to present the ‘Judgment’ referred to in Plaintiff’s Paragraph 4 which is the basis for the Petition which Plaintiff has brought before the Court; with evidence of proper standing and jurisdiction.

Respectfully,

2016
01.26

(Filed in Bucks County PA)

1. The Foreclosure action, filed September 18, 2013, was brought to this Court by Jeffrey Trauger, Esq. of Grim, Beihn & Thatcher while it neglected to include or provide ANY supporting ‘mortgage documents’ which are necessary to demonstrate the proper and lawful standing of the Plaintiff to bring foreclosure litigation to the Court.

2. Defendant’s Response, filed October 10, 2013, raised the issue of the Plaintiff’s failure to present the mortgage or note, challenging the Plaintiff’s standing to bring the foreclosure action.

3. Plaintiff has failed to respond to requests for documentation.

4. In November 2013, Defendant met with Joe Sedlock and Kevin Cornwall at First Savings Bank. The paperwork was not provided.

5. Joe Sedlock and Kevin Cornwall indicated that the paperwork was not available.

6. On January 7, 2014, Defendant again met with Joe Sedlock and Kevin Cornwall at First Savings Bank. No paperwork was provided.

7. Defendant was provided a letter from Kelly Eberle of Grim, Beihn & Thatcher indicating “all related loan documents” had been sold or transferred to KMTM (sic) Newbury, LP.

8. A letter from Kevin R. Cornwall, Executive Vice President, First Savings Bank of Perkasie dated February 12, 2014 to Dana L. Price, an agent in the Office of the Attorney General (Pennsylvania) indicates
“On December 13, 2013 the bank sold that note and mortgage, along with all other documents evidencing the Debt to a note buyer.” –

9. As such, those documents and related transaction histories are no longer available to or in the possession of First Savings Bank of Perkasie.

10. As indicated in the letters from First Savings Bank of Perkasie, AND Grim, Biehn & Thatcher, the documents have been assigned sold and transferred to KTMT Newbury, LTD.

11. Defendant believes the request to provide the loan document(s) alleged to support the plaintff’s motion is reasonable and timely and directly affect the matter before this Honorable Court.

WHEREAS, the Defendant respectfully requests this Honorable Court to IMMEDIATELY REQUIRE the attorney for the Plaintiff, Nicole Plank, Esquire, to present

– the ‘Mortgage Note, Mortgage and all related loan documents” which demonstrate the existence of a loan and necessary to obtain any judgment, or default judgment;

– the related disbursement / payment transaction history and all other documentation which has been provided by First Savings Bank to KTMT Newbury as part of the ASSIGNMENT OF MORTGAGE.

Respectfully,

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