IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVANIA
CIVIL ACTION – LAW
SONYA HEALY : #2007-12477
EMERGENCY PETITION FOR MODIFICATION OF CUSTODY
The above named Defendant, Terance Healy, petitions the Honorable Court to issue an Emergency Ex Parte Order regarding the matter of the custody of his son, Brennan Healy, and present the following facts to support this request.
1. Terance Healy is the biological father of Brennan Healy.
2. Sonya Healy is the biological mother of Brennan Healy.
3. Brennan Healy was born on August 7, 1991 in Lansdale, Pennsylvania.
4. Brennan Healy graduated from North Penn High School on June 16, 2009.
5. Brennan Healy will be 18 years of age on August 7, 2009.
6. It is recognized and understood that there are less than 30 days remaining for this court to have jurisdiction regarding the child’s custody.
7. A petition to modify custody was filed by the Petitioner, Terance Healy, on December 26, 2007. Copy attached.
8. A protracted hearing on the matter had been scheduled to potentially begin on July 13, 2009 in the courtroom of the Honorable Judge Thomas Del Ricci.
9. On July 6, 2009, the Honorable Judge Thomas Del Ricci issued an order formally recusing himself from the case docketed as 07-12477 and 07-32114.
10. A new hearing date has not yet been set.
11. The current Agreed Order for Custody was issued on October 26, 2007. Copy attached.
12. Sonya Healy has failed to comply with the custody order in any responsible manner and has actively prevented any communication or visitation between father and son.
13. On December 26, 2007 the Defendant, Terance Healy, filed a petition for the modification of custody after being prevented from communication and visitation with his son for a period of 2 months.
14. The status quo of the Agreed Order has at no time been accepted by the Petitioner, Terance Healy, while continuing scheduling delays have prolonged the period of absence of communication or visitation between father and son.
15. As the deadline of the child’s eighteenth birthday approaches, the Petitioner, Terance Healy, respectfully requests the court’s immediate attention to the matter.
16. Petitioner, Terance Healy, recognizes that the information in this petition is extensive. It is not the intent of the Petitioner to overwhelm with the information provided.
17. The statements and associated exhibits are intended to corroborate and answer any questions the reader may have while reading through the petition. The issue of child custody is a serious matter and as such Petitioner hopes to provide the answers to any questions which will logically arise while reading this document.
18. Petitioner seeks an immediate determination on this matter.
RESPONSIBILITY FOR A DECISION
19. The Petitioner’s son, Brennan Healy, will turn 18 years of age on August 7, 2009.
20. In 2007, Brennan Healy was told of the illegal tactics and criminal actions of his mother and her attorneys, Angst & Angst.
21. The knowledge of the information provided has caused it to be necessary that Brennan Healy avoid any communication with his father, as even incidental information provides clues to the criminal activity.
22. It is not now, nor has it ever been, the intent of the Petitioner to cause his son to be responsible for providing the information leading to the prosecution of the child’s mother, Sonya Healy.
23. It has been the intention of the Petitioner to remove the responsibility for the child being placed into the situation voluntarily. The current Custody Agreement places the decision regarding physical custody on Brennan Healy.
24. If Brennan were to decide to spend time with his father, any revelation of information regarding the crimes would be ‘Brennan’s fault’ because Brennan has had the choice to avoid the situation.
25. Petitioner wishes the court to remove that burden of responsibility from the child so that if there were any ‘slip’ Brennan would at least be able to justify that he did not voluntarily place himself into the situation.
26. It is not unreasonable for a father to expect some visitation with his children. The current custody agreement and situation has prevented any visitation or regular contact between father and son. The current custody order does not restrict access.
27. Petitioner has not in any petition to this court attempted to remove the role of Brennan’s mother in his life.
28. Petitioner has never at any time requested a denial of all contact or communication between mother and son.
29. Sonya Healy has inexplicably responded to the petition to modify by petitioning the court for the complete exclusion of Petitioner from the child’s life.
30. Sonya Healy refuses to explain her actions.
31. Sonya Healy has been found in contempt of the Custody Agreement where she has not accepted her responsibilities as custodial parent.
32. Sonya Healy has been found in contempt of Court Orders and Agreements relating to property.
33. Sonya Healy has been instructed in writing by her attorney’s at Angst & Angst to commit criminal acts in direct violation of the Court’s Orders.
The petitions and actions of Sonya Healy, and Angst & Angst, are not in the best interest of the child.
This case is not about a divorce. Angst & Angst advised a client, Sonya Healy, to commit illegal acts while planning for divorce. Once those actions were discovered, the divorce was secondary to the cover-up and conspiracy.
Everyone in a position to resolve any issue has been manipulated into inaction or a decision which they cannot logically support. Once manipulated they are forced into protecting their own liabilities.
If Brennan Healy is not now granted the opportunity to re-connect with his father, the estrangement will likely be extended with the burden of silence remaining on Brennan Healy.
The only anticipated resolution to that burden of silence is the prosecution of Sonya Healy.
Once Sonya Healy is finally prosecuted for her crimes, Brennan Healy may have issues about his mother’s prosecution and be embarrassed for his actions in protecting her. As such, the estrangement between father and son will only continue.
An immediate correction, even if only for a period of one month is essential.
BEST INTERESTS OF THE CHILD
34. The resolution of child custody and visitation disputes requires divorcing parents to act rationally in their child’s best interests. Sonya Healy has failed to act rationally.
35. Petitioner has been permitted no visitation with his son.
36. Petitioner has awaited the hearing on this matter for over 18 months. A continued wait will result in the petition being moot as the child will be 18.
37. Sonya Healy has psychologically abused the child.
38. Sonya Healy has placed the child in dangerous situations.
39. Sonya Healy has illegally removed the child from the country.
40. Sonya Healy has denied any opportunity for visitation.
41. Sonya Healy has prevented Brennan from a continuing relationship with his paternal grandmother, and the entire extended Healy family.
42. Sonya Healy placed the burden on her child to notify petitioner when her father passed away in July 2008.
43. Sonya Healy placed the burden on her child to notify petitioner when her mother passed away in October 2008.
44. Petitioner has only been seen the child at court dates, in either the courthouse hallways, or the domestic relations offices.
45. Temporary custody is typically granted to the person who stays in the marital home. Petitioner, Terance Healy, continues to reside at the marital home.
46. Sonya Healy refused to cooperate during mediation over the issue of custody.
47. Terance Healy is the parent who would be considered the primary caretaker.
48. Terance Healy is the parent who transported the child to daycare/school each day.
49. Terance Healy attended parent conferences with teachers throughout grade school and middle school, and the first year of high school.
50. Terance Healy is the parent who was called to leave work to handle any immediate events at school or extra-curricular events.
51. Terance Healy is the parent who did the grocery shopping.
52. Terance Healy is the parent who did the laundry for the entire household.
53. Terance Healy is the parent who maintained the home.
54. Terance Healy is the parent who attended to the physical and emotional needs of the children.
55. After his mother had abandoned the home, Brennan Healy was spending 70% of his time at his home with his father.
56. Brennan Healy wished to maintain his relationship with his mother even after she abandoned the home. Petitioner has never interfered with that relationship.
57. Sonya Healy has provided the petitioner with no information regarding college selection.
58. Sonya Healy did not provide the petitioner with report cards or information from school for the child even after being directed by the court to do so.
59. Sonya Healy did not provide the petitioner with any information or tickets to the child’s high school graduation. Petitioner was able to watch the graduation ceremony on cable television.
60. Sonya Healy lied to the psychiatrist who had been ordered by the court to evaluate Brennan Healy.
61. Sonya Healy is a disaster of a parent who has placed her child squarely in the middle of the cover-up of her crimes and the conspiracy to prevent prosecution of those crimes.
62. Sonya Healy places all of the responsibility on the child.
63. Sonya Healy abandoned the family home on May 24, 2007.
64. Sonya Healy filed for divorce on May 25, 2007, after 5 months of planning and preparation with her lawyers at Angst & Angst.
65. Brennan Healy was spending 70% of his time at the family home until, on July 12, 2007, Brennan Healy was abducted from the family home by Sonya Healy and prevented from returning.
66. Since July 12, 2007, Terance Healy has been denied the father-son relationship with Brennan Healy that they had shared for the child’s entire lifetime.
67. Sonya Healy indicated that the family home was dangerous and unsafe, yet refused to explain her reasoning for such beliefs.
68. Sonya Healy removed Brennan Healy to a remote barn in Quakertown, Bucks County, Pennsylvania.
69. Sonya Healy prevented any communication by telephone between father and son.
70. There was no reliable cell phone service to the rural farm through which father could contact his son.
71. Even though father was paying for a cell phone for Brennan, he was prevented from speaking to him by Sonya Healy, and additionally by Colin Healy.
72. Sonya Healy prevented any visitation between father and son with threats of involving police should Brennan’s father make any attempt to visit him.
73. Sonya Healy has made numerous false reports to police in Montgomery Township.
74. Sonya Healy has made false reports to police in Upper Gwynedd Township including the preposterous allegation that a certified letter from the Defendant contained some sort of hazardous powdered toxin or poison.
75. Sonya Healy made the above mentioned false allegation against the defendant after receiving only a green card indicating she had a certified document to retrieve at the Post Office.
76. Terance Healy was promptly contacted by Upper Gwynedd Police investigating Sonya Healy’s report as they were concerned of the potential risk to the entire community and the possible need to shut down the local post office.
77. Sonya Healy would have had no reason to be surprised to receive the notice for the document which had been mailed from the Norristown Post Office on March 24, 2008.
78. The document was an Emergency Contempt Petition filed by the Defendant regarding Sonya Healy’s activities on March 23, 2008.
79. On March 23, 2008, at approximately 5:00 PM, Sonya Healy committed multiple crimes including breaking and entering, burglary, vandalism and poisoning of the family dog at the residence of the Defendant. The dog died 6 months later on October 2008.
80. Sonya Healy was in direct violation of two Court Orders dated September 6, 2007 which specifically indicated the process and schedule for distribution of marital assets.
81. The Court Orders of September 6, 2007 had been accepted, endorsed and signed by the Honorable Judge Toby Dickman, who had the insight to include a provision should anything arise and the schedule not be met.
82. Sonya Healy was assisted in loading the rented panel truck, an extended bed pick-up truck, multiple sport utility vehicles and automobiles by an estimated twelve other persons.
83. Among those photographed participating in the break-in, burglary, and vandalism were a former Montgomery Township Police Officer, a former Federal Employee, and two minor children.
84. One of the minor children taking part in the break-in, burglary and vandalism was the Defendant’s son Brennan Healy.
85. The criminal activity, in direct violation of two court orders, was authorized in writing by Sonya Healy’s legal counsel, Angst & Angst.
86. Sonya Healy was found to be in Contempt of Court on May 14, 2008.
87. The last photograph in the series of over fifty images of the crime clearly indicates Sonya Healy removing files from the residence which were prepared for the Custody Conciliation Conference with Sara Goren scheduled for Tuesday, March 25, 2008.
88. On March 21, 2008, Angst & Angst filed their “Response to Petition To Modify Custody and Counter Petition To Modify”. Copy Attached.
89. Their response opens with the outright fraudulent statement that Sonya Healy was not served a copy of the Petition to Modify Custody.
90. The Petition to Modify Custody was filed concurrently with a Protection From Abuse Order against Sonya Healy on December 26, 2007.
91. A copy of the Certificate of Service to Valerie Angst was signed by Michael Kehs. Docketed on December 28, 2007.
92. Valerie Angst has not appeared with her client Sonya Healy since the Protection From Abuse Order was filed. The Protection From Abuse Order includes a statement alleging Valerie Angst has direct involvement in the abuse by providing irresponsible counsel to her client.
93. I re-affirm and maintain the validity of every allegation included in four pages attached as part of the Protection From Abuse Order. Copy Attached.
94. On Tuesday, March 25, 2008, just minutes prior to the scheduled appointment, Petitioner was informed that the Custody Master, Sara Goren, had a family emergency and would not be available for the conference.
95. Petitioner was then informed that the conference had been cancelled on the previous day, March 22, 2008.
96. Petitioner was informed that the Court Administration had no telephone number at which to notify him though the phone number is clearly written on the ‘Family Court Cover Sheet’ attached to the petition and several other docketed documents.
97. Petitioner was informed that Angst & Angst had indicated they had no telephone number at which to contact him though there had been several previous telephone conversations between the parties.
98. Petitioner indicated that he understood that the cancellation was unfortunate, and that he understood that family emergencies arise at inopportune times. Petitioner did question the reasons provided for his not being informed in advance.
99. Petitioner had spent the greater part of Monday, March 24, 2008 at the Montgomery County Courthouse in the Family Court Administration office filing the Emergency Petition for Contempt.
100. Petitioner indicated that he was attending the conference without any of the files and information prepared for the meeting as those files which had been prepared were stolen by Sonya Healy over the previous weekend and there had been no time to re-prepare while securing and cleaning up the house, tending to a poisoned pet, preparing an emergency petition for the court to review, meeting with local police officers and having an extended meeting with Chief Brady of Montgomery Township Police.
101. Petitioner requested the next possible conference with ANY available Custody Master as 3 months had passed since the modification was requested and 9 months had passed since he had an opportunity to communicate and visit with his son.
102. Petitioner would learn in June 2008 from Court Administration staff that it was notated in the scheduling system that Angst & Angst requested the conference be rescheduled with Sara Goren even if it would mean an additional 6 week delay.
103. Angst & Angst’s request was granted without any consultation to myself, the Petitioner in that matter.
104. A later review of the court schedule on-line would indicate that Sara Goren was able to keep two other appointments on March 25, 2008 at 9:45 AM.
105. In October 2008, during an unnecessary Conciliation Conference, Sara Goren indicated that she had no recollection of any family emergency in March 2008.
106. The Custody Conciliation Conference had been rescheduled for May 19, 2008. 5 months had passed since the petition to modify was filed by Terance Healy during which time he was prevented from communication and visitation with his son.
107. During the Custody Conciliation Conference on May 19, 2008, Terance Healy presented a multi page list of items relating to his close relationship with his son and the erosion of that relationship since Brennan Healy was abducted by Sonya Healy from the family home on July 12, 2007.
108. During the Custody Conciliation Conference Terance Healy indicated the numerous occasions where Sonya Healy was not providing for Brennan Healy appropriately, and where she has clearly failed at being a responsible custodial parent.
109. The listing of occasions and events can be fully corroborated with collateral material and was not denied by Sonya Healy at any time during the conference.
110. The following larger issues were reported to Sara Goren by Terance Healy, in addition to others:
– Brennan had not seen his father over the 2007 holidays.
– Brennan had not seen any of his extended family over the 2007 holidays.
– A brief visit with Brennan was traded by Sonya Healy in exchange for stock certificates which were in the home.
– Brennan had participated in the break-in, burglary, and vandalism at his father’s home for which Sonya Healy was found in Contempt of the Court’s Orders
– Brennan had not seen, spoken or communicated with his father between January 2008 when he was exchanged for stock certificates until he arrived on May 24, 2008 to assist in the return of items stolen in the burglary.
– Brennan had destroyed and vandalized what remained in his bedroom during the burglary.
– Brennan knows of the seriousness of his mother’s criminal actions in harassing his father.
– Brennan has been prevented from contact with his father since July 12, 2007.
– Brennan was aware of instructions that police be called if Terance Healy attempted to visit him at the barn in rural Quakertown, Bucks County.
111. Sonya Healy was not represented at the conference by Robert Angst who had represented her that morning at an earlier child support appeal .
112. Sonya Healy was not represented by Valerie Angst, who has not appeared with her client in any court proceedings since allegations appeared in the Petition for Protection From Abuse filed by Terance Healy in December 2007.
113. Valerie Angst was also in Norristown that morning and met with her client briefly on the street in front of the building which includes the office of Sara Goren.
114. Sonya Healy spoke barely a word at the Custody Conciliation Conference on May 19, 2008. She did not comment on any statements.
115. After Terance Healy presented the litany of issues directly related to custody of his son Brennan Healy, Sara Goren suggested that Terance Healy might want reconsider his petition to modify custody and advised him to wait for three weeks and then notify her if he was still interested in pursuing the modification.
116. The suggestion of Sara Goren to delay any further action for an arbitrary period of three weeks defies all logic and explanation.
117. What possible explanation could Sara Goren have for her ridiculous suggestion? Or for her delay in filing her report? Or for her delay in filing the paperwork to list the matter for court?
118. A father petitioning the court has been prevented any relationship, communication, or visitation with his son for the preceeding 10 months. That father has filed a petition with the court on December 26, 2007 and waited three months until March 2007. He has then waited two additional months as the Custody Master has rescheduled due to a family emergency. What reason could there possibly be to suggest waiting an additional three weeks before deciding to proceed?
119. As unfathomable as the suggestion to reconsider proceeding to court from Sara Goren, her reaction to my response to not delay and schedule as quickly as possible was hostile and intimidating. I further explained to her that she was apparently having difficulty discerning between imaginary aggressiveness and this father’s passion to be reunited with his son and begin healing the damage caused by the divorce and separation of the family.
120. Sara Goren was displaying her ineptness, incompetence and complete lack of understanding of what is happening to the families that she sees in her position as Custody Master.
121. Sara Goren filed the paperwork to have the matter listed for court on May 27, 2008, over one week after the conference.
122. Sara Goren filed her Conciliation Report on the matter on May 27, 2008. No copies of the report were provided to the petitioner. A copy was obtained months later from the Prothonotary.
123. The Conciliation Report filed by Sara Goren on May 27, 2008 is a work of fraud and bias.
124. The Conciliation Report filed by Sara Goren on May 27, 2008 fails to mention ANY of the items listed by Terance Healy during the conference.
125. The Conciliation Report filed by Sara Goren on May 27, 2008 fails to accurately indicate anything which was discussed and stranger still includes items which were not raised at the conference.
126. The Conciliation Report filed by Sara Goren on May 27, 2008 represents a criminal act of fraud by someone in a position of authority and should result in her being prosecuted in the criminal courts.
127. Sara Goren has filed that same Conciliation Report on subsequent occasions with only minor edits.
128. On May 25, 2008, Terance Healy learned that Sonya Healy, with whom he shares equal legal custody, had made plans for Brennan Healy to travel outside of the United States.
129. Terance Healy expressed concerns about his son traveling outside the country without either parent and requested more information about the destinations and purpose of the trip.
130. Terance Healy heard reports through his family that Brennan was going along on a vacation to France so that he might mind the children of Kate & Arthur Schaeffer while they searched for a new location to live while on a prolonged work assignment outside the U.S..
131. Terance Healy heard from Brennan Healy on June 6, 2008 that Brennan was going to England and that Brennan had no idea where his father had gotten the idea of Ireland and France.
132. Brennan Healy would not provide any further information about the trip.
133. In a subsequent conversation with Sonya Healy, Terance Healy expressed his concerns at the confusion regarding the destination of the trip and the timing of the trip. He further indicated that as there had been no contact from Sonya Healy regarding the plans for the trip, Terance Healy preferred that Brennan not go as the timing of the trip would likely coincide with the scheduling of the pending Custody Hearing.
134. On June 4, 2008, Terance Healy again requested information regarding the trip.
135. On June 6, 2008, after hearing no further information or clarification to the confusing information regarding the trip, Terance Healy notified Sonya Healy, and Brennan Healy that he did not want Brennan to go on the trip.
136. On June 11, 2008, Terance Healy requested Sonya Healy provide Brennan’s passport and prevent any need to involve the court in the matter. The request was ignored.
137. On June 16, 2008, Terance Healy filed an emergency petition with the court to order the surrender of Brennan’s passport to his father and to end any further planning for the trip outside the U.S.
138. Judge Thomas Del Ricci ruled that the matter was not an emergency and the matter was scheduled for a July 10, 2008 Short list Conference.
139. On June 25, 2008, Terance Healy wrote to Judge Del Ricci requesting a review of the schedule as the proposed departure date for the trip was July 8, 2008.
140. Judge Del Ricci refused to reschedule the Short List Conference.
141. On June 24, 2008 at 4:22 PM, Angst & Angst electronically filed an Emergency Petition for Special Releif in Custody on behalf of Sonya Healy.
142. On June 25, 2008, the Honorable Arthur Tilson signed a Temporary Ex Parte Order For Relief ordering, decreeing and directing that Brennan Healy be permitted to leave the U.S.
143. The Temporary Ex Parte Order was issued without any proceeding, conference or hearing.
144. The Temporary Ex Parte Order was issued without Terance Healy having any opportunity to respond to the petition.
145. The Temporary Ex Parte Order was issued based on the fraudulent information provided by Angst & Angst and Sonya Healy.
146. The Temporary Ex Parte Order was immediately followed with another Emergency Petition after Terance Healy filed his response indicating the fraud in Sonya Healy’s petition.
147. That subsequent Emergency Petition threatened to have Terance Healy incarcerated should he voice any objection.
148. The Temporary Ex Parte Order issued by Judge Tilson would not have been upheld according to the Hague Convention because it was not issued following due process.
149. The Temporary Ex Parte Order denied Terance Healy his parental rights and completely disregarded his input in this decision directly affecting his son.
150. Terance Healy requested yet never received any explanation of why this petition, on a matter which had been deemed “not an emergency’ by the Honorable Thomas Del Ricci was read by the Honorable Arthur Tilson deemed an Emergency and the Temporary Ex Parte Order Issued.
151. There is nothing in the petition filed electronically by Angst & Angst on June 24, 2008 which would indicate that the matter was an emergency, or that the parental rights of the child’s father should be summarily denied and dismissed.
152. Terance Healy was in the courthouse on June 25, 2008 yet there was no discussion, no hearing, no conference, no short list and no teleconference on the matter.
153. The destination of the trip was misrepresented and no details of the destination, hotels, or flight were provided at any time to the child’s father, Terance Healy.
154. No responsible parent would permit their child to travel outside the United States without knowledge of the most basic of travel arrangements.
155. The US Department of State issues guidelines which indicate an international abduction may occur. The situation surrounding the aggressive actions to remove Brennan from the U.S. meets several of the indicators that are presented to parents of children of divorce.
156. In shared custody situations, international travel requires authorization of both parents.
157. Sonya Healy did not have the right or authority to transfer any custodial responsibilities to Kate & Arthur Schaeffer.
158. Kate & Arthur Schaeffer relocated to England and did not return from the ‘vacation.’
159. Brennan Healy was forced to travel alone. If he were to travel with Kate & Arthur Schaeffer and their two children, the Schaeffers could potentially face charges of international kidnapping.
160. Brennan Healy was not aware that he was being abducted from the family home when removed by his mother on July 12, 2007. It is within reason that he was additionally unaware of plans for his international abduction.
161. There has been no hearing at any time where Sonya Healy has had to testify under oath and penalty of perjury. Any hearing where witnesses may be called will indicate the criminal actions of Sonya Healy, and the attorneys at Angst & Angst.
162. A Custody hearing would require her to testify revealing her criminal actions, or her necessity to not respond to questions for fear of self-incrimination.
163. There has been no hearing with regard to the burglary, as police have repeatedly refused to permit Terance Healy to file charges in the matter. Copy of letter attached.
164. There has been no hearing with regard to the burglary, as the county detectives and the District Attorney’s office refuse to permit Terance Healy to file charges in the matter. Copy of letter attached.
165. There has been no hearing with regard to the burglary as the Honorable Thomas Del Ricci has announced ‘off the record’ from the bench on May 19, 2008 immediately before an appeal in support that he had spoken to Montgomery Township Police and County Detectives and assures Sonya Healy that she has no reason to worry.
166. Judge Del Ricci has refused to respond to requests for the rule of law which he is applying to the matter of protecting Sonya Healy and everyone involved in the break-in, burglary, vandalism and poisoning of the family pet from prosecution.
167. Judge Del Ricci has not issued any order which precludes or prevents Terance Healy from filing charges in the matter.
168. Judge Del Ricci has additionally not ruled on any item with regard to custody.
169. Judge Thomas Del Ricci has prevented the resolution of issues brought before his court including issues relating to custody where time is of the essence.
170. By refusing to rule and refusing to respond to inquiries, compounding each new matter into the eventual protracted hearing started with the Petition to Modify Custody filed on December 26, 2007, Judge Del Ricci has prevented his decisions from being appealed to a higher court.
171. By refusing to rule and refusing to hear arguments regarding the fraud presented in the petitions filed by Angst & Angst, Judge Thomas Del Ricci has prevented justice from being served and has denied the constitutional rights of Terance Healy.
172. There has been a pending custody modification during each of the contempt petitions brought before the court. As such, it has been within the court’s power to grant a modification to the custody agreement. The court has failed to grant so much as an hour of visitation between father and son in the last 2 years. Requests for an explanation have been ignored, and denied.
173. In denying the constitutional rights of Terance Healy, Judge Thomas Del Ricci has additionally denied the rights of Brennan Healy to have any relationship with his father.
174. Judge Thomas Del Ricci is directly involved in the obstruction of justice and conspiracy to conceal and prevent prosecution of the criminal actions resulting from the illegal, unethical and unconstitutional tactics used by Angst & Angst and their client Sonya Healy.
175. Judge Thomas Del Ricci has cause to be concerned that he will be presented with multiple petitions to higher courts and the Judicial Conduct Board regarding denial of due process and the disregard of the constitutional rights of Terance Healy without reason, cause or explanation.
176. A Petition Requesting Judge Thomas Del Ricci’s Recusal for Cause was being fiunalized when a letter was received from Judge Del Ricci indicating he would be recusing himself.
177. The petition was being filed due to the judge’s violations for the willful misconduct while in office, for his persistent failure to perform her duties, for his conduct that is prejudicial to the administration of justice and which brings the Pennsylvania judiciary into disrepute, for his engaging in unlawful and criminal acts, and for his engaging in acts in violation of federal law.
In consideration of the above, the Petitioner respectfully requests the Honorable Court recognize that this family is recovering from a very difficult period of complete estrangement and provide for the opportunity for healing of this family and the relationships with extended family by ordering the following effective immediately:
1. ) Terance Healy, father, shall have primary physical custody of Brennan Healy until such time as a hearing on the matter can be concluded.
2. ) Sonya Healy, mother, shall be permitted a strictly controlled visitation with Brennan Healy, not to exceed 1 hour per day, at the discretion of Brennan Healy. That meeting may take place anywhere they choose with the exception of the residence of Terance Healy.