2010
04.30

IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVANIA
CIVIL ACTION – LAW

SONYA HEALY : #2007-12477

v. :

TERANCE HEALY :

EMERGENCY PETITION FOR SPECIAL RELIEF

1. The Petitioner is Terance Healy, an adult individual residing at 110 Banbury Avenue, North Wales, Pa 19454 hereinafter referred to as Husband.

2. The Respondent is Sonya Healy, an adult individual residing at 811 Station Square Boulevard, Lansdale, PA 19446 hereinafter referred to as Wife.

3. A divorce complaint was filed by Wife on May 25, 2007 and an Answer and Counterclaim was filed by husband on July 23, 2007.

4. The parties are joint owners of a property located at 110 Banbury Avenue North Wales, PA 19454. Husband received sole and exclusive possession of the marital home on September 6, 2007.

5. Since May 2007, Husband has been paying all expenses associated with the marital home including the mortgage, taxes, and utilities in excess of one hundred thousand dollars ( $ 100,000.00). Husband has borrowed all monies to maintain the marital asset from family.

6. Wife has delayed the resolution of the divorce case resulting in financial hardship for husband, who is unemployed.

7. The parties were scheduled for an Equitable Distribution hearing on March 18, 2010. Husband’s Pre-Trial Memorandum was timely filed on or about March 8, 2010.

8. In anticipation of the equitable Distribution hearing and in compliance with this Honorable Court’s Discovery Order dated december 15, 2009, Husband served the respondent with resuests on or about January 30, 2010.

9. The Respondent failed to comply with the Order and has also failed to fully answer the requests.

10. Wife’s Pre-Trial Memorandum was NOT filed or prepared until March 17, 2010. Filed electronically Wife’s submission included information contained in Husband’s Memorandum.

11. The late filing of Wife’s Memorandum resulted in the delay in resolving the equitable distribution of the marital estate, thereby, forcing husband to incur additional financial hardship and loans from his family.

12. Husband, who has been representing himself Pro Se during the majority of the divorce process, hired legal counsel to represent his interests at Equitable Distribution in the interest of resolving any issues raised during the conference as quickly as possible.

13. The additional legal work required to compel discovery and to request sanctions quickly became excessive and it became financially necessary to resume self representation.

WHEREFORE, Husband requests this Honorable Court grant him all of the equitable releif deemed appropriate including but not limited to:

1. Order Wife to immediately pay all outstanding mortgage, utility, taxes, homeowners insurance, and or give Husband credit for same.

2. Awarding Husband reasonable counsel fees and any other releif deemed appropriate.

Respectfully Submitted,

Terance Healy, Defendant
Pro Se

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