2010
08.12

I discovered a Court Order I had never seen before… and everything became very clear.

This order was never docketed, so there was no way to know it even existed unless you went to the courthouse. Even then, you could not find the order unless you requested to review the actual paper file for the case. I had done so about 6-8 times over the course of the last few years and never found this order.

BUT, on August 12, 2010, when I asked for the file I was told it was out. I was then offered the ‘accordion file’. This is something I had never been offered before. I had been told the file had been unavailable numerous times in the past as it was checked out by the judges in the days before any proceeding. But, I had never been offered another file in it’s place.

The ‘accordion file’ was different. Neatly organized. Papers stacked cleanly in the file. And there it was. Right on top.

There it was… the very first EMERGENCY. Emergency was granted to them by Judge Rhonda Danielle and never docketed. Another undocketed Ex Parte Order without any benefit of a hearing issued by Judge Rhonda Danielle summarily dismissed my parental rights, and granted me only supervised visitation. Six sentences drafted by Valerie Angst, lightly edited and signed by Judge Rhonda Danielle. THIS ORDER HAS UNDERMINED EVERYTHING FOR THE LAST THREE YEARS. And they were hiding it in another file. I had realized that there were ex parte communications surrounding every proceeding, but had no idea there was an ex parte order for them to ex parte talk about.

The Prothonotary staff immediately docketed the paperwork (# 215, #216). Three years late.

I began to unravel their SECRET Order issued by the Judge at the head of the family court. All the Judges and Masters reported up through Judge Rhonda Danielle, and reversing another Judge, let alone your boss, was no easy task. The order had affected not only every proceeding, but every aspect of the case, every police report, ever custody conference and hearing, everything was done to keep it a secret. And now I was looking at it. One page, with one signature… and so much conspiracy to cover it up.

WHY? What misinformation warranted these years of terror and allowed them to destroy my family and deny all my civil rights.

2010
08.12

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

SONYA HEALY
(Plaintiff) : #2007-12477

v. :

TERANCE HEALY :
(Defendant)

EMERGENCY PETITION FOR RELEIF (RE: MEDICAL BENEFITS)

Plaintiff has repeatedly failed to provide proof of medical and dental benefits to Defendant placing the health and welfare of the Defendant in extreme risk.

Defendant has been unable to seek medical attention for ongoing intestinal pain because of inability to pay for physician visits. Defendant has previously been hospitalized for a week in Intensive Care in February 2006 with intestinal pain and diverticulitis.

Defendant has also been unable to afford dental coverage over the last 4 years. His teeth have begun to crack and he has been experiencing severe pain related to the tooth decay. He cannot afford to pay for dental visits and is humiliated and embarrassed by the condition of his teeth.

Defendant has been denied any benefit through Montgomery County Assistance Office and the Pennsylvania Department of Public Welfare. The explanation for the denial of any benefit relates to the financial support he is receiving from his family.
– The agencies consider the monies being loaned to the defendant by his family to pay monthly
bills and the monthly mortgage to be income.
The financial affects of the Plaintiff’s divorce has caused severe financial difficulties for the Defendant’s entire family.

WHEREAS, Defendant requests the Court order the immediate production of the medical and dental benefits cards by the Plaintiff directly to the Defendant; and that the Plaintiff provide proof of the coverage which she claims to have been secretly providing for the last 3 years.

1. Plaintiff has failed to act in accordance with the Court’s Order of July 21, 2010 resulting in continuing financial hardship to the Defendant.

2. The Order issued on July 21, 2010, with exceptions filed by the Plaintiff on August 6, 2010, places the parties in great financial jeopardy and risks their coverage in regard to medical benefits. (Exhibit A)

3. The document filed by Valerie Angst on August 6, 2010 fails to indicate the nature of the Plaintiff’s exceptions to the order.

4. Defendant filed an emergency petition on August 10, 2010 responding with the his issues relating to the order.

5. Plaintiff has repeatedly failed to provide proof of medical and dental benefits to the Defendant to corroborate her testimony.

FIRST OPPORTUNITY (June 3, 2010)

6. Valerie Angst indicated at the June 3, 2010 Conference that her client was providing medical and dental benefits for the Plaintiff.

7. Valerie Angst further falsely indicated that insurance cards had been sent directly to the Defendant by the insurance company regularly over the last 3 years.

8. Plaintiff had not received any insurance cards during the preceding 3 years and was unaware of this benefit.

9. Plaintiff requested the insurance cards relating to his coverage. Mrs. Angst indicated she would send them.

10. Plaintiff did not receive the cards.

11. It should be noted that Valerie Angst made a false allegation that the Defendant threatened her and was escorted to the June 3, 2010 conference by a security guard. This false allegation was brought to the attention of the Support Officer, Jennifer Qawasmy, in a letter dated June 9, 2010. (Exhibit B)

SECOND OPPORTUNITY (July 15, 2010)

11. At the July 15, 2010 hearing before Mindy Harris, the insurance cards were once again requested.

12. Valerie Angst indicated that the cards were not delivered to the Defendant.

13. Valerie Angst indicated the cards were delivered to the Defendant’s brother, Brian.

14. Defendant’s brother, Brian, had not delivered the cards to him.

15. Defendant has no regular contact with his brother Brian.

16. Defendant asked why the cards were delivered to his brother instead of himself, further pointing out that to deliver the cards
– the Plaintiff had to drive past the Defendant’s home;
– the Plaintiff had to drive past the Defendant’s brother John’s home (with whom he has regular contact);
– the Plaintiff had to drive past the Defendant’s mother’s home (whom he sees regularly);
– to deliver the cards to the brother with whom he has no contact. (Map: Exhibit C)

17. Plaintiff further pointed out that the last time documents were delivered in this manner (Spring 2008), they were fraudulent documents delivered months after the date on the documents and created by Valerie Angst in an attempt to create chaos regarding property issues.

18. It has been suggested that by delivering the documents in this manner, the Plaintiff is attempting to avoid charges of mail fraud for providing fraudulent documents through the mail.

19. The Defendant was then instructed by Mindy Harris, to directly contact the insurance company to obtain the cards himself.

20. After contacting the Insurance company for copies of the cards, the Defendant was informed that the cards can only be sent to the insured at her address.

21. The Defendant has no way of obtaining the insurance cards himself.

THIRD OPPORTUNITY (August 3, 2010)

22. After a conference regarding equitable distribution on August 3, 2010, the Plaintiff and her attorney were AGAIN reminded of the situation and the inability to obtain the insurance cards.

23. Instead of offering to provide the benefit cards by mail at a cost of $ 0.44 (44 cents), the Plaintiff and her attorney indicated it would be necessary to petition the court regarding the matter.

WHEREAS, the Defendant requests this Honorable Court issue an Order as follows:

1. The Plaintiff shall immediately produce the medical and dental benefits cards for the Court, and file verified copies with the Prothonotary.

2. The Plaintiff shall immediately provide the medical and dental benefit cards DIRECTLY to the Defendant.

3. The Plaintiff shall provide proof of the coverage which she claims to have been secretly providing for the last 3 years.

4. The Plaintiff shall provide corroborative proof of previous mailings of the cards from the Insurance Company directly to the Defendant.

Respectfully Submitted,

Terance Healy
Pro Se

VERIFICATION

I verify that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of PA C.S. Section 4904, relating to unsworn falsification to authorities.

__________________________________________
Terance Healy

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