2010
08.20

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

SONYA HEALY : #2007-12477

v. :

TERANCE HEALY :

NOTICE OF DISCOVERY OF EX PARTE ORDERS DATED AUGUST 20, 2007

The secretive actions of the Court which have influenced every court proceeding, repeatedly slandered the Defendant to law enforcement authorities, and destroyed his professional, financial and personal life are criminal.

Those improperly issued court orders have been used to manipulate and influence every court action in the case.

1. On August 12, 2010, Defendant visited the Prothonotary in Norristown and requested to view the case file for the above referenced case.

2. Defendant has been to the Prothonotary between 8 and 12 times over the last three years to review the case file.

3. Previously, on August 10, 2010, the case file had been unavailable and the Defendant was informed the file was with Gordon Mair regarding Equitable Distribution.

3. On August 12, 2010, though still checked out to Gordon Mair, the Defendant was instead offered the “accordion folder” for review.

4. The ‘accordion file’ had never before been available, or offered, during any prior visit when the file was checked out by masters and judges.

5. The “accordion file” was considerably different from the case file. It was immediately obvious that the file was not the file which had been presented to the Defendant at any time before. The file was cleanly stacked and organized, where usually the case file provided was overflowing with documents and completely lacking in any organization.

6. The first document in the file was an order issued by Judge Rhonda Daniele on August 22, 2007. (Copy Attached as Exhibit A)

7. The Defendant had no knowledge of the order and had not received a copy of the order.

8. The Order did not have the added distribution information to parties and attorneys which has been entered on orders received by the Defendant.

8. The Court Order had never been docketed by the Prothonotary.

9. Prothonotary staff was questioned about the Order.

10. Defendant requested, and was provided, a copy of the order by the Prothonotary staff.

11. Upon review by several persons in the Prothonotary, the Order was docketed as 2007-12477-216.

12. Additionally, the ‘emergency’ scheduling order was docketed as 2007-12477-215.

EX PARTE

13. As the order had not been docketed, there was no way for the Defendant to be aware of it’s existence.

14. As the order had not previously been in the case file, there was no way for the Defendant to be aware of it’s existence.

15. When the Defendant noticed the Order had not been docketed, he immediately acted and alerted Prothonotary staff.

16. The Prothonotary Check Out form (attached as Exhibit B) includes the following court personnel:
Judge Daniele (1 time)
Judge Dickman (1 time)
Misc (2 times )
Sara Goren ( 4 times )
Gordon Mair ( 3 times )
Judge DelRicci ( 9 times )
Sharron Rex ( 1 time )
Judge Bertin ( 6 times )
Mindy Harris ( 1 time )

17. In the 28 times that masters and judges had the file to review, not one person ever noticed or reported that the first order issued in the case had never been docketed and/or made any attempt to correct the filing error.

UNWARRANTED SUPERVISED CUSTODY

18. The Court Order of August 22, 2007 grants primary physical custody of our son to the Petitioner.

“D. Petitioner shall have primary physical custody of the parties’ minor child;”
19. The Court Order of August 22, 2007 further grants “supervised visitation only” to the Defendant.

20. Supervised Visitation is applicable when a parent has pleaded guilty or no contest to a crime, or been convicted of a crime on the following list:

Criminal Homicide
Kidnapping
Unlawful Restraint
Rape
Statutory Sexual Assault
Involuntary Deviate Sexual Intercourse
Sexual Assault
Aggravated Indecent Assault
Indecent Assault
Indecent Exposure
Incest
Endangering the Welfare of Children
Prostitution
Sexual Abuse of Children.

21. Supervised Visitation is also called for when a parent has been charged with a crime on the following list:
Criminal Homicide
Aggravated Assault
Terroristic Threats
Stalking
Kidnapping
Unlawful Restraint
False Imprisonment
Rape
Statutory Sexual Assault
Involuntary Deviate Sexual Intercourse
Sexual Assault
Aggravated Indecent Assault
Indecent Assault
Indecent Exposure
Arson
Incest
Endangering the Welfare of Children
Sexual Abuse of Children
Contempt of Court Orders

22. The Defendant has never been accused of any of the crimes listed in PA Custody Act ( 23 PCSA 5303).

23. Supervised Visitation is entirely inappropriate in this matter.

NO PROCEEDING

23. As the Defendant was unaware of this Order which was issued without any formal court proceeding, he was provided no opportunity to respond.

24. The Emergency Petition for Special Relief filed by the Plaintiff on August 16, 2007 resulted in a Short List Conference with Judge Dickman on September 6, 2007.

25. The Short List Conference on September 6, 2007, which did not make any custody determination, produced an Agreed Order (#22) granting the Defendant exclusive use and occupancy; and deemed the other counts in the Plaintiff’s petition as moot.

26. As a result of the Defendant’s Motion for a Conference in Custody on July 23, 2007, the parties were scheduled to meet with Custody Conciliation Master Sara Goren on October 26, 2007.

CUSTODY PROCEEDINGS DELAYED FOR YEARS

27. Family Court Judges and Masters are aware of what circumstances call for “Supervised Visitation” and would be incredibly biased against the Defendant by the Order of August 22, 2007 signed by Judge Daniele.

28. Judge Daniele is the Head of the Family Court Division. It is logical to presume that the Masters and Judge‘s in the Family Court Division would be unlikely to question or reverse her order in a matter of custody where Judge Daniele believed the Defendant only deserved “Supervised Visitation.”

29. Defendant has been denied any relationship with his son since the child was abducted by his mother from the family home on July 12, 2007.

30. Defendant has felt the sting of very strongly biased Masters and Judges in all proceedings but most certainly in those related to custody. They never explained their reasoning, or their actions, or the rule of law being applied to the situation. They couldn’t without revealing their ex parte communications and documents.

31. The conspiracy to conceal the court order issued on August 22, 2007 by Judge Rhonda Daniele has undermined every proceeding in the case.

While being attacked on all levels from every angle and receiving no justice from anyone, the defendant has been able to persevere for only one reason. The truth. He knew the truth. And while they could prevent the truth from being heard and could ignore the truth. They could not alter the truth.

WHEREAS, The Defendant alleges and hereby avers that:

a) Judge Rhonda Daniele has intentionally conspired to conceal her order issued on August 22, 2007;

b) Master Sara Goren has intentionally conspired to conceal the order issued on August 22, 2007 by Judge Rhonda Daniele;

c) Judge Thomas Del Ricci has intentionally conspired to conceal the order issued on August 22, 2007 by Judge Rhonda Daniele;

d) Judge Thomas Del Ricci has delayed or dismissed any efforts to enforce court orders against the Plaintiff.
Where court orders are disobeyed with impunity and respect for the law and the courts thereby weakened … it is the duty of the courts to see to it that every assistance is extended to the courts of the Commonwealth so that orders are meticulously carried out as otherwise the dignity of the judiciary, the majesty of the law, and its enforcement are clearly undermined.
– Beemer v. Beemer, 188 A.2d 475, 476 (Pa. Super. 1962).

e) Judge Thomas Del Ricci conspired with the Montgomery County District Attorney’s office to prevent any investigation, prosecution or remedy for criminal actions of the Plaintiff, and her attorneys, Valerie Angst and Robert Angst.

f) Judge Thomas Del Ricci conspired with the Montgomery County Detectives to prevent any investigation, prosecution or remedy for criminal actions of the Plaintiff, and her attorneys, Valerie Angst and Robert Angst.

g) Judge Thomas Del Ricci conspired with the Montgomery Township Police Department to prevent any investigation, prosecution or remedy for criminal actions of the Plaintiff, and her attorneys, Valerie Angst and Robert Angst.

Impunity – the impossibility, de jure or de facto, of bringing the perpetrators of violations to account – whether in criminal, civil, administrative or disciplinary proceedings – since they are not subject to any inquiry that might lead to their being accused, arrested, tried and, if found guilty, sentenced to appropriate penalties, and to making reparations to their victims.

Impunity arises from a failure to meet obligations to investigate violations; to take appropriate measures in respect of the perpetrators, particularly in the area of justice, by ensuring that those suspected of criminal responsibility are prosecuted, tried and duly punished; to provide victims with effective remedies and to ensure that they receive reparation for the injuries suffered; to ensure the inalienable right to know the truth about violations; and to take other necessary steps to prevent a recurrence of violations.

h) Judge Arthur Tilson has intentionally conspired to conceal the order issued on August 22, 2007 by Judge Rhonda Daniele;

i) Judge Emanuel Bertin has knowingly participated in the conspiracy to conceal the order issued on August 22, 2007 by Judge Rhonda Daniele;

j) Judge Emanuel Bertin has extended the impunity provided to the Plaintiff, and her attorneys,Valerie Angst and Robert Angst by Judge Del Ricci.

f) the Plaintiff and her attorneys, Valerie Angst and Robert Angst, have conspired to conceal the ex parte order issued on August 22, 2007 by Judge Rhonda Daniele;

g) the Plaintiff and her attorneys, Valerie Angst and Robert Angst, have knowingly and with intent to commit fraud presented the ex parte order issued on August 22, 2007 by Judge Rhonda Daniele in Emergency Petitions relating to Custody while failing to provide true and correct copies of their petitions to the Defendant;

h) the Plaintiff and her attorneys, Valerie Angst and Robert Angst, have knowingly and with intent to manipulate and commit fraud provided the ex parte order issued on August 22, 2007 by Judge Rhonda Daniele to Montgomery County Detectives;

i) the Plaintiff and her attorneys, Valerie Angst and Robert Angst, have knowingly and with intent to manipulate and commit fraud provided the ex parte order issued on August 22, 2007 by Judge Rhonda Daniele to Montgomery Township Police;

j) the Plaintiff and her attorneys, Valerie Angst and Robert Angst, have knowingly and with intent to manipulate and commit fraud provided the ex parte order issued on August 22, 2007 by Judge Rhonda Daniele to Upper Gwynedd Township Police;

k) the Plaintiff, at the direction of her attorneys, Valerie Angst and Robert Angst, has knowingly and fraudulently provided the ex parte order issued on August 22, 2007 by Judge Rhonda Daniele to Montgomery Township Police officers during the burglary and vandalism of the Defendant’s residence;

l) the Plaintiff has knowingly and fraudulently misrepresented the ex parte order issued on August 22, 2007 by Judge Rhonda Daniele as the valid and current custody order to Upper Gwynedd Police officers;

m) the Plaintiff has intentionally defamed and slandered the reputation of the Defendant by providing the ex parte order issued on August 22, 2007 by Judge Rhonda Daniele to Upper Gwynedd Police officers;

n) the Plaintiff has intentionally defamed and slandered the reputation of the Defendant by providing the ex parte order issued on August 22, 2007 by Judge Rhonda Daniele to Montgomery Township Police officers;

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