(Plaintiff) : #2007-12477

v. :



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.


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)


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


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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