SONYA HEALY : 2007-12477
v. :


1. Defendant respectfully requests copies of all documents executed by Plaintiff relating to the sale of his home at 110 Banbury Avenue, North Wales, PA 19454.

2. Defendant requests to be included in any correspondence, communications and distribution of information regarding the sale of the home.

3. Defendant requests the return of his personal property stored at the

4. Defendant requests the division of marital assets as Ordered on May 9, 2011.


5. An Order issued on May 9, 2011, directed Sonya Healy to immediately list the home for sale. She did not.

6. The Order of May 9, 2011, provides Sonya Healy with Power of Attorney to execute all necessary documents for the listing and sale of the marital residence.

7. The Order of May 9, 2011 requires the parties to divide the marital property with any disputes being resolved by the Montgomery County Masters Office.

8. On May 17, 2011, Angst & Angst immediately contacted The Montgomery County Masters Office in writing to schedule a hearing. Sonya Healy refused to get together with Defendant to divide assets.

9. On July 18, 2011, in a verbal order, Judge Carolyn Carluccio indicated that any items not removed from the home on the day of closing could be discarded.

10. Sonya Healy has refused to permit Terance Healy access to remove any personal property from the home.

11. Sonya Healy has been disposing of marital assets and personal property belonging to the Defendant.

12. On July 18, 2011, Judge Carluccio issued an unclear written Order which would have placed the Defendant in the position where he could be arrested for attempting to follow the verbal Order of the Court.

13. The transcript which included the judge’s verbal order would not be available for three weeks.

14. This issue was brought to the judge’s attention during the proceeding.

15. This issue was additionally brought to the Court’s attention in a petition filed on July 21, 2011. No hearing has been scheduled.

16. Defendant wrote to the Montgomery County Master in July questioning the delay and requesting the schedule date for the arbitration requested by Angst & Angst in May 2011.

17. The Montgomery County Masters Office scheduled a conference for September 8, 2011.

18. On August 15, 2011, The Defendant filed a Notice Of Appeal to the Superior Court of Pennsylvania. Copies were distributed to Angst & Angst, and also to Judge Carolyn Carluccio.

19. Angst & Angst wrote a letter to the Montgomery County Masters Office and cancelled the September 8, 2011 arbitration. This was done without contacting the Defendant with regard to the schedule.

20. Defendant wrote to the Montgomery County Master and indicated that the conference should not be cancelled, additionally pointing out the fraudulent, incorrect and misleading information provided in the Angst & Angst letter.

21. The Montgomery County Masters Office cancelled the conference prior to receiving the Defendant’s letter, and has not responded to the letter sent or phone messages left in their voicemail system.

22. On August 22, 2011, Judge Carolyn Carluccio issued an Order acknowledging the Appeal filed by the Defendant on August 15, 2011 and requested information required for her to respond to the Appeal to the Superior Court.

23. Judge Carolyn Carluccio has delayed the forwarding of the Appeal documents to the Superior Court by refusing to schedule a hearing regarding the Defendant’s Petition to Proceed In Forma Pauperis filed on August 15, 2011. This hearing is still not scheduled.

24. On August 28, 2011, Defendant witnessed his personal property being removed from the home. Some items being placed in Sonya Healy’s vehicle, and additional items being placed in a black SUV.

25. After Hurricane Irene had passed, Defendant returned and photographed his items which were being placed at the curb for trash pick-up the next morning.

26. On August 28, 2011, Defendant had no way of rescuing his possessions, and advised Sonya Healy that she was violating the Court Orders. Defendant went to the Montgomery Township Police who refused to get involved in a civil matter. Police took no action.

27. Chris Grucella, a neighbor and the Real Estate Agent who is selling the home, was present while the Defendant photographed the items.

28. The Defendant noticed the home was no longer in the active real estate listings. Chris Grucella denied having any information regarding the sale of the house.

29. Defendant wrote to Keller Williams regarding the sale of his home. Emails, letters and phone calls were not returned.

30. Defendant advised Keller Williams regarding the Appeal of the Order under which Sonya Healy was proceeding to sell the home, and provided copies of the Appeal Documents filed on August 15, 2011.

31. Plaintiff has failed to follow any court Orders in this case, including the one which grants her permission to sell the house out from under the defendant.

32. The Plaintiff’s consistent contempt for Court Orders has been inexplicably excused.

33. The Defendant recognizes the injustice committed over the last 6 years, however, there is no remedy for the enforcement of Court Orders except to return to the court for enforcement.

34. The Defendant, a victim of injustice, is forced to return to a court and expect justice.

The Plaintiff is rushing the sale of the home out from under the Defendant, which will additionally permit the Plaintiff an excuse to dispose of all of the Defendant’s possessions – which she has already done.
Judge Carluccio is intentionally delaying the Appeal from proceeding forward and transferred to the Superior Court. The Judge’s delays prevent the Superior Court from issuing an Injunction to Prevent the Irreparable Damage caused by the Order of May 9, 2011.

A Hearing is Requested.

Whereas, the Defendant respectfully requests the Court issue an Order as Follows:

a) Plaintiff shall return all items disputed by the Defendant, and submit to the arbitration as Ordered and requested

b) Plaintiff shall cease dissipation of marital assets.

c) Plaintiff shall permit the defendant to access the home to retreive his bedroom furniture, and other personal items which are not marital.

d) Plaintiff shall provide to the Defendant copies of all documents executed regarding the sale of the home.

e) Plaintiff shall additionally advise her Real Estate Agent(s) to share information regarding the sale of the defendants home with the Defendant.

f) The Court shall advise Keller Williams Real Estate Agent Chris Grucella, and managing Agent Daniel Smith, to provide available information as requested regarding the sale of the Defendant’s home to the Defendant.

d) The Plaintiff shall cease any actions with regard to the sale of the home as a valid Appeal has been filed and is in process. Proceeding with the sale of the home would represent considerable irreparable damage.

e) The Court shall issue an injunction blocking the sale of the home until such time as the Appeal can be heard.

____________________________ ______________________________
Date Terance Healy
Pro Se

No Comment.

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