2011
02.20

Terance Healy December 19, 2010
110 Banbury Avenue
North Wales, PA 19454
Docket# 2007-12477

Judge Carluccio,

My sincere thanks for your prompt attention and action to the case reassignment and the outstanding emergency issue you addressed.

The letter of December 13, 2010 from Valerie Angst included a paragraph containing incorrect references, speculation and distorted timelines. Please permit me to clarify and recap the outstanding issues on the case. (See Attached ‘Regarding second paragraph‘)

Sonya Healy has NOT provided the identification card for the Dental Benefit which had been approved by the court and ordered on December 14, 2007. Domestic Relations# 123109384

Sonya Healy had already complied with your Order of December 9, 2010. The medical card to which Valerie Angst refers was received in September 2010 after repeated attempts to obtain the medical and dental insurance identification cards. The medical card was a partial response intended to suggest their compliance. The dental insurance coverage information has never been provided. Coverage remains an emergency as my teeth began cracking and falling out in March of 2010. The pain has prevented me from being able to eat or drink for days at a time.

The Plaintiff, and her attorneys, have NEVER complied with any of the Orders of the Court since the origination of this case. The impunity granted to the plaintiff regarding enforcement of any order in this case is evident, yet it remains unexplained. The frequency of ex parte issues with regard to the plaintiff and her attorneys demonstrate their actions to manipulate and influence the court. It has been their direct actions or the results of their activities which has revealed the ex parte contact in each documented instance. I do not make these statements haphazardly or secretly. (See attached Ex Parte Listing)

While on the surface the case appears to be a divorce, when her lawyers inspired her to commit a crime, they put their careers on the line along with their client’s security. The lengths they will go to cover up their illegal actions, and avoid prosecution, know no boundaries.

Respectfully,

Terance Healy cc: Angst & Angst

Regarding the second paragraph from the Angst & Angst letter dated December 13, 2010.

1. There was no document titled Emergency Motion for Medical Cards filed by Defendant on August 12, 2010. The following Petitions and Orders relate to this issue.

– Plaintiff filed Exceptions to the Recommendation of the Conciliator on August 6, 2010 by filing only a cover sheet. (Docket# 2007-12477-210)

– Defendant filed an Emergency Appeal in Support (APL) on August 10, 2010 listing 8 issues which need to be addressed. (Docket# 2007-12477-211)

– Judge Bertin directed the Emergency Appeal to be listed along with the Plaintiff’s Exceptions. (Docket# 2007-12477-213)

– Defendant filed an Emergency Petition for Relief (Re: Medical Benefits) on August 12, 2010 singling out the insurance documents issue as he had been experiencing severe pain. (Docket# 2007-12477-214)

– Judge Coonahan indicated that the Emergency Petition could await the return of Judge Bertin. (Docket#2007-12477-218)

– Judge Bertin directed the issue be consolidated with the Exceptions which were now already on his schedule for September 22, 2010. (Docket# 2007-12477-224)

– Defendant filed Plaintiff’s Contempt of Court Order in Support dated August 24, 2010 on the medical and dental insurance card matter. (Docket# 2007-12477-227)

– Judge Bertin recused himself from the case on September 2, 2010.
(Docket# 2007-12477-234)

– Defendant received a medical insurance card from the Plaintiff’s attorney on September 2, 2010.

2. The Defendant has never denied receiving the medical insurance card on September 2, 2010.

3. The Defendant indicated to Court Administration that the Emergency Issue remained outstanding.
– This was brought to their attention prior to the assignment of any judge to the case.
– Judge Bertin had planned to address the issue in a timely manner on September 22, 2010, before he recused himself.
– Judge Barrett planned to address the issue on October 5, 2010, which was continued upon Plaintiff’s request to October 7, 2010.
– Judge Barrett decided to have a hearing on the matter in February 2011.
– Judge Barrett recused himself on November 30, 2010 and the issue remained unaddressed.

4. Why does it require over half a year of litigation for the Plaintiff to comply with the Court’s Order to provide medical and dental insurance?

5. Defendant filed an In Forma Pauperis petition on December 7, 2010.
-Those types of petitions go immediately before the signing judge for the day. It was brought before Judge Bertin who indicated he could not rule on the matter. It was then brought to Judge Wall.
– At the time, Judge Wall could potentially have been assigned this case.
– Judge Wall asked for more information about what necessitated the petition. I informed Judge Wall that as the case was currently without a Judge any further information could be considered ex parte should she be assigned the case.
– I researched the information and presented it to Judge Wall on December 14, 2010.
– The petition was denied by Judge Wall on December 14, 2010 indicating the “request was too general in nature” and “costs excessive to taxpayers.“

The Following Petitions remain to be addressed:

1. Plaintiff filed Exceptions to the Recommendation of the Conciliator
(Docket# 2007-12477-210 filed August 6, 2010)

2. Defendant filed Exceptions to the Recommendation of Conference Officer/Master in Support
(Docket# 2007-12477-211 filed August 10, 2010)

3. Defendant filed Emergency Petition for Relief (Re: Medical Benefits)
(Docket# 2007-12477-214 filed August 12, 2010)

4. Defendant filed Plaintiff’s Failure to Comply With Court Order Dated August 22, 2007
(Docket# 2007-12477-226 filed August 24, 2010)
Response and CounterPetition
(Docket# 2007-12477-250 filed October 6, 2010)

5. Defendant filed Plaintiff’s Contempt of Court Order in Support
(Docket# 2007-12477-227 filed August 24, 2010)
Response and CounterPetition
(Docket# 2007-12477-249 filed October 6, 2010)

6. Defendant filed Petition Regarding Plaintiff’s Ex Parte Communications
(Docket# 2007-12477-240 filed September 14, 2010)
Response and CounterPetition
(Docket# 2007-12477-248 filed October 5, 2010)

7. Defendant filed Petition Regarding Discrepancies/Errors on Invoice For Fees
(Docket# 2007-12477-241 filed September 14, 2010)
Response and CounterPetition
(Docket# 2007-12477-247 filed October 5, 2010)

8. Defendant filed Exceptions to Recommendation of Conference Officer/Master in Equitable Distribution
(Docket# 2007-12477-261 filed November 8, 2010)

No Comment.

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