SONYA HEALY : #2007-12477
v. :



1. Plaintiff has filed a praecipe requesting that any Divorce Decree be deferred until hearings have occurred on unresolved claims. (Exhibit A)

2. Plaintiff has not filed any subsequent affadavit requesting a Divorce Decree under 3301(c) or 3301(d) of the Divorce Code.

3. Plaintiff has not served upon Defendant any subsequent document requesting a Divorce Decree under 3301(c) or 3301(d) of the Divorce Code..

4. Plaintiff has continued to file petitions with the Court which is indicative that Plaintiff has not filed, or intended to file for or request a Divorce Decree.

5. Plaintiff has not withdrawn her Petition filed on February 24, 2011.

6. The Court has not had a full hearing on the Plaintiff’s Petition and the corresponding Response / Counterpetition filed by the Defendant.

7. Plaintiff’s Petition of February 24, 2011 represents an unresolved claim, and in accordance with the Praecipe filed with the Court, Plaintiff does not intend to request any Divorce Decree until there are hearings on unresolved claims.


8. Defendant has not filed any document relating to section 3301(c) or 3301(d).

9. Defendant does not intend to consent to a divorce, or request any Divorce Decree, or to file any document relating to 3301(c) or 3301(d) until there are hearings on all unresolved claims.


10. The Court does not have jurisdiction to issue a divorce decree when the parties have not consented to or made any such request.

11. “The Court has made it clear that ‘unless and until a valid decree in divorce has been entered, then there can be no equitable distribution of marital property.’” Reese v Reese, 351 Pa.Super.521,506 A.2d 471. 473-474(1986).

12. The courts of common pleas are only empowered to make equitable distribution contemporaneously with or subsequent to a decree in divorce. Campbell v. Campbell, 357 Pa.Super. 483, 516 A.2d 363, 366 (1986).

13. This is because the settlement of economic and property claims is merely a part of the trial court’s broader power to terminate the marriage. Campbell, 516 A.2d at 366.

14. Equitable distribution is an incident of divorce, not marriage.

15. The parties have not indicated by documentation or action any intention to request a divorce decree. As such there can be no divorce decree.

16. As there is no valid divorce decree, there can be no equitable distribution order.


17. As the Court is without jurisdiction to issue a divorce decree, the decree and order issued by Judge Carluccio cannot be appealed as the order is NOT a valid final order.

18. Defendant filed a Petition to Vacate the Order on June 6, 2011 and the court has not yet responded.


19. Plaintiff has previously presented Police with outdated Court orders while committing a
burglary of the marital residence where she was aware of, and had executed, a more recent
“exclusive use’ agreement granting the Defendant exclusive use of the residence.

20. The Burglary of the residence occurred on March 22, 2008 and included as many as twenty
(20) people assisting with 12 SUVs and a large Moving truck.


21. The failure of the court to respond leaves the Defendant homeless.

22. If the Defendant does not vacate his home, he could face contempt charges, arrest, etc.
Plaintiff, through her attorneys, has threatened these types of extreme actions in the past.

23. Defendant has suffered through a 4 years litigious divorce where each court order is only
enforced where the Defendant is responsible.

24. Plaintiff has been granted complete impunity to violate Court Orders and disobey the law.


25. Defendant has persevered through constant false legal allegations and petitions number over
300 entries on the docket.

26. Defendant has been repeatedly victimized by a court which has no explanation for the
impunity granted to the Plaintiff, or any explanation for the continued abuse the Defendant
has suffered while trying to resolve any issue.

Whereas, the Defendant respectfully requests that the Honorable Court

(1) issue an injunction vacating Order of May 9, 2011 which has not been issued in accordance with the laws and procedures of the Commonwealth of Pennsylvania, or The Divorce Code.


Terance Healy
Pro Se


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

Terance Healy


My name is Terance Healy. I am again begging for your assistance with the following:

This is happening in Montgomery County PA. The same county where detectives advised Lower Merion School District to use stealth software to activate web cams and secretly photograph school children withouth consent.

I noticed that my business computers were hacked in February 2007. Data was streaming from the machines and was not stoppable. I was forced to shut down client web storefronts to prevent the credit card data from being stolen. This went on for months until in May 2007 I discovered my wife had been planning a divorce. My wife abandoned the family home in May 2007 when she believed I had taken her cell phone. After packing 4 carloads of belongings, she realized she was mistaken. Thet phone she thought she misplaced was the phone she had been using to plan her divorce. She had obtained it in January 2007 after meeting with attorneys at Angst & Angst.

The software was determined to be WebWatcher from Awareness Technologies Inc of Marina Del Rey California. Awareness Technologies refused to remove their program or advise how it could be removed. In July 2007, I purchased the WebWatcher program myself on the advice provided by an attorney at Spector Software. He had indicated the software could only be installed once on a machine. When I went to install the WebWatcher program, the computer reported it was already installed. I shut down my network, backed up and removed all computer hard disks and have kept them secured.

I reported this to Police, who indicated they could do nothing.
I reported it to the FBI in Fort Washington, PA who indicated they wouldn’t get involved.
My attorney arranged a meeting with County Detective Ray Kuter in Norristown, PA. Ray handle computer crimes however he did not have the tools to detect or remove it. He asked me to bring the computer back at another time.

On August 8, 2007, Police acted on a tip from the person who was spying on my computer. They had noticed that I had written a note about my hard disk dying because of the software and misinterpreted the message.
Police Officer Gerald Dougherty arrived at my home 40 minutes after the message had been typed. The message was never saved, sent, printed, transmitted or emailed in any way. yet, Police arrived at my door. Officer Dougherty, the same officer who could do nothing when I reported the intrusion to police in July, had me involuntarily committed (302’d). He did this in violation of PA Law and procedure. I also was not mentally unstable in any way. That morning I had already been to the grocery store, and Commerce Bank where I had discussed the computer intrusions affect on my bank accounts with their manager and support staff.

Montgomery Township Police has refused to provide their reason for Officer Dougherty arriving at my doorstep. The Police Report for the event, which had been denied to me for years, indicates the Cheif asked officer Dougherty to check on me. the Police Report I received in 2010, indicates the Police Cheif asked Officer DOugherty to check on me. Officer Dougherty had just come off an all night shift that day. His police dog had recently died. And Cheif Brady was on vacation in Alaska at the time. No explanation has been provided.

County Detective Ray Kuter never returned any calls after this date.

Since that event, the Montgomery County Court has display extreme bias towards me. I found in August 2010, an undocketed order which was never provided to myself or my attorney in August 2007. The Order was signed by Judge Rhonda Daniele effectively slandered me to the officers of the Court. Custody proceedings were continually delayed or abruptly cancelled for years until my son turned 18. I have had no relationship with him since July 13, 2007 when his mother abducted him from the family home. The family home she abandoned in May 2007, when she accused me of having her cell phone. Her secret cell phone contains all of the contact with her lawyer, and also with Awareness Technologies Support team who helped her to reenable computer surveillance of my business machines.

To clarify, the business computers were in my home office. This was not a family computer. It was used exclusively for my web development business. I also have documentation relating to trouble tickets filed with Notrio Hosting. Over 200 trouble tickets betwen February and May 2007, where excessive traffic was causing outages at their serves and preventing access to my clients web sites. In May 2007, just before I doscovered the divorce plans, I was forced to migrate a client (JustinGuarini.com) to Hostgator Hosting. I did this because during the east coast airing of American Idol’s final show that season on which he was appearing, his site was being redirected to a lingerie site in China. His manager contacted me and I moved the site and had it operational before the West Coast air time of the broadcast.

What has continued since summer 2007 has been a constant shell game of surveillance and harassment. Affecting all computers and phones in my home at the time and additionally affecting any new computer and phones. I have repeatedly detected surveillance equipment and activity and requested the FBI to become involved. No one from FBI has ever looked at any of the evidence. One supposed agent, named Rose, had numerous phone calls with me in November 2007 and December 2007. Those calls ended when I tried to contact her at the general FBI number in Philadelphia and was told she did not exist. I reported this to FBI in Fort Washington, PA in January 2008. After receiving my information (phone bills and recorded voicemails), an Agent named Ken went into the office to check out the information. When he returned to the conference room he became irate. He told me that if I said another word he would put me on a plane to North Carolina and I would never see anyone I knew again. There was no explanation for his actions towards me. I left the the building petrified and unable to even think for hours. I had not done anything to warrant the extreme reaction. I was afraid to contact the FBI again until 2011.

In the meantime I have been harassed by constant litigation from Angst & Angst filed with the Montgomery County Courts. The docket is now over 300 entries, not because of frivolous actions by a Pro Se defendant. It is moresso because of the failure of the Montgomery County Courts to enforce its own court orders against my wife. I am not exaggerating this statement. The Courts have neglected to hold her accountable for any violation of any court order they have issued. The most extreme examples being her burglary of my home in violation of 3 Court Orders, and her failure to provide medical and dental benefits ordered in December 2007.

I have been documenting much of the litigation on a web site. www.Work2bDone.com/live Not so much for the purpose of advertising my situation as for storing the files in a secure location away from my computers which have been repeatedly hacked. The Computer and cell phone attacks continue to this day. It has made any effective communication via phone or email/internet unreliable at best and completely unreliable. I do not attempt to trick anyone into exposing their involvement. I am upfront and direct. the infdormation on the web site documents much of the case, and I can provide full explanations and documentation to back up any claims made on the site.

Since August 2010 and the discovery of the secret Order at the Prothonotary, I have requested a review of the ex parte conduct of the Judges assigned, or standing in, in my case. This include their failure to follow the rules of civil procedure and Pennsylvania Law, Constitutional Law, and even the Hague Convention. I know. In June 2008, they had filed litigation requiring me to permit my son, of whom I still had shared legal custody to leave the country travelling alone. When they refused to tell me where he was going on the trip, I petitioned the court to stop it. They however petitioned the Court and had an ExParte Order issued requiring me to permit the trip. This order violated the Hague Convention. Also, ExParte Orders call for a hearing within 10 days. That hearing never took place. Angst & Angst additionally responded to my objection with further pettions threatening to throw me in jail for attempting to stop the trip. Custody petitions had been pending since December 2007 and had been delayed by their direct actions. I had been denied any contact with my son, even though the existing custody order required daily communication. The communication never happened. The Court never enforced it. A brief custody hearing was held days before my sons 18th birthday. Enforcement/Contempt hearings were delayed and continued until long after that. My wife had by this time been granted complete impunity to violate the law and the court orders. I am not exaggerating here.

I went to Montgomery Township Police in early February 2011 to filed a civil rights complaint. While the documentation was complete, the officer indicated if he were to take a complaint against a judge and act on it, it would directly his ability to do his job. I understood. It was the same with every lawyer I have contacted. They can’t go up against or expose a corrupt judge and think it won’t affect their next client. Exposing the inappropriate actions and civil rights violations of 8 county judges would be career suicide.

After surviving 4 and a half years of divorce chaos, Judge Carolyn Carluccio was assigned to the case. She immediately permitted inappropriate ex parte communication with Angst & Angst and herself. When I requested copies, the petition was denied with any hearing.

Nine Other Petitions regarding enforcement of existing court orders have been rescheduled repeatedly since August 2010 through 3 Judges schedules. After rescheduling them herself in January 2011 for June 2011 hearing dates, judge carluccio granted an emergency hearing to Angst & Angst. The filing of their petition and the scheduling of the hearing within days were intedned to deny me any opportunity to respond. At the emergency hearing Judge Carluccio attempted to intimidate me through a variety of ridiculous statements. She had not read my response, yet indicated she had. For the record, my response was 126 pages (26 pages of paragraphs with 100 pages of supporting documentation). Judge Carluccio ended that hearing after 45 minutes and prevented the presentation of any exhibits or testimony.

I asked Judge Carluccio to recuse after this hearing. My recusal request included statements to relating to the hearing and outstanding petitions which were denied without hearings. The title of the document best summarizes the allegations. PETITION FOR THE RECUSAL OF JUDGE CAROLYN TORNETTA CARLUCCIO FOR CONSPIRCY, CORRUPTION, FRAUD, INTIMIDATION, CONFLICT OF INTEREST, DENIAL OF DUE PROCESS/PROCEDURE, AND DENIAL OF CIVIL RIGHTS.

Judge Carluccio then scheduled a Hearing in Equitable Distribution for March 29, 2011. It was noticed that the court calendar reflected all the June Hearings (9 of them) had additionally been rescheduled for the same date. Also, the paperwork provided for me to sign-in indicated the hearing was regarding the matter from the Emergency Hearing. When I questioned the purpose of the March 29, 2011 hearing at the beginning of the proceeding I was assured it was Equitable Distribution only and the other matters were not to be presented. They would be heard in due course. As related issues were raised, i was repeatedly reassured the discussion on that issue would happen at the respective hearings.

All of the June hearing dates had been quietly cancelled using praecipes (inter-office emails) to which I had not been included. I had found them on the County web site. The response from staff in Court administration and the Prothonotary was the same, “Where/How did you get that?”

At the end of the March 29, proceeding, Judge Carluccio again rescheduled the hearings for May 5, 2011. One day. The same nine petitions which had been scheduled for several days by Judge Bertin in August 2010 and then for several days by Judge Barrett in October 2010, and for two days by Judge Carluccio in January 2011. AND, Judge Carluccio was additionally including the huge 126 page counterpetition filed in March 2011. I was skeptical.

Judge Carluccio then proceeded to cancel the hearings, dismiss the hearings or otherwise dispose of the issues without any hearing occuring preventing any presentation of exhibits, evidence or testimony. However, they attempt to make it appear that there are some hearings as Judge Carluccio has renamed some petitions. On May 3, I go to the courthouse to confirm, the judge refuses to document the cancellation. On May 4, I receive a letter faxed to the Judge on May 2 indicating their beleif that there were hearings scheduled. On May 4, there is a late docket entry regarding the May 5 date. It appears there is too many suggestions that no one knows if the hearings are scheduled. If I do not appear for the hearings, the Judge would be permitted to dismiss the petitions for failure to appear. When I appear prepared for any number of the nine hearings, I am informed the hearings were cancelled and given a copy of the order issued on May 3rd and docketed on May 4th. I was never called regarding the late scheduling activity. AND I was in the courthouse on May 3 and the Judge made it clear to Court Administration that she woul dnot issue an order. AND the judge had already received a fax from Angst & Angst they they too did not know the schedule. Or did they?

I left the courtroom to go to Administration and let them know of what had occured. My 78 year old mother and I were then surrounded by 7 guards who said there had been a report that I threatened the Judge. they further indicated that if i had no business in the courthouse I should leave. When I showed them the Court Order indicating the May 5 hearings, they were confused. Why did the judge’s staff make a false report to them? Security Officer Cole and Officer Haas and I worked out an arrangement to avoid further false allegations. I suggested I contact them whenever I was coming to the courthouse. They appreciated the offer and we have done so ever since. They know I am battling corruption, but they have to respond to allegations. I can understand that. They now understand that my story of corruption and harassment appears to be very accurate.

When the violation of civil rights was called to her attention, she then issued a divorce decree and an order in equitable distribution designed to further destroy my financial situation and disrupt my life.

By design, and with malice, the divorce decree document was designed to be unappealable. As the order is not valid. Neither party has requested he divorce decree. Robert Angst had filed a document indicating he did not wasnt a divorce decree until the hearings had been held. I had not filed for the Divorce Decree. If there is no divorce decree, there can be no equitable distribution order. I discovered their tactic, documented the error and filed a petition with the court to have the order vacated on June 6, 2011. The Court has not responded.

I have been forced to quickly vacate my home, because the local police (who have been directly involved) have indicated to me that should I not submit to the order as issued, they would respond and act to enforce the order. For the record, local police have not enforced any court order on my behalf. Police had additionally been called to a Burglary at my home, by my wife and a team of 20 people with 12 SUVs and trucks and permitted the burglary to occcur. They then refused to take a complaint about the burglary. Immediately before a procceeding in May 2008, Judge DelRicci actually apologized to my wife if she was afraid that she would face charges for the burglary for which he had rewarded her by permitting her to retain items taken even though she had violated several court orders.

I sit this morning homeless and petrified that my remaining possessions in the home, which I could not get out of the house before the midnight deadline are at risk of being destroyed. I have survived the harassment, intrusions, surveillance, constant litigation, secret investigation by private investigators, multiple attempts by people trying to set me up to appear to be a criminal, only to be done in by paperwork. As they have aggressively enforced every court order against me, I have reason to fear their actions. While the court has intentionally issued this latest order to prevent any appeal to a higher court, and they have failed to respond to the petition to vacate the order for lack of jurisdiction, I anticipate they will aggressively attempt to enforce this order.

I went to police to adivse them of the latest documents before the court, and can only indicate I felt very intimidated when Officer Dougherty, yes, that Officer Dougherty indicated that he would enforce the order and arrest me if I was in contempt of the order.

I have been to the Philadelphia office of the FBI as recent as 2 weeks ago to update information provided on March 17 (in person) and March 11 on the phone.

I have attempted to survive, and have done so for over 4 years and constant litigation (over 300 entries in the docket). I have turned to law enforcement to help prosecute the crimes. They fail to do so without any response or explanation. I have been terrorized for years, and have persevered knowing the truth would come out eventually. But they have again attacked and now destroyed my only solace, my home. They have done so with malice and in full view of a world that doesn’t care. No one helped.

Please investigate my claims. I thinkl I am the only one who still believes in justice. I will be returning to the court today to try to get an injunction, but realistically it isn’t likely that the court which has denied me any justice for the last 4 years, will make any move to stay or vacate the order. No one is holding the court accountable. They are above law. They further victimize the victim as I discover their tactics. I have no choice but to continue and to persevere. There is no walking away. No one helps. No one investigates.

Please Help. Please Investigate.
Terance Healy

Web Site: www.work2bdone.com/live
The site does NOT list all the evidence. Or all the issues. It is too much to document which under constant litigation.

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