1. Judge Carolyn Carluccio issues orders and opinions with the clear purpose and intent to commit extrinsic fraud.

2. Judge Carolyn Carluccio issues false statements on her Orders with the intent to prevent testimony, to obstruct justice and to deny the rights of the parties to hearings and due process.

3. Judge Carolyn Carluccio secretly reschedules hearings without notifying the parties involved. She then purports to have heard the hearings. When exposed further, she lies. She then issues orders rescheduling the matters which she subsequently cancels to prevent testimony and evidence from being presented at those hearings.

4. Judge Carolyn Carluccio has engaged in frequent ex parte communications. When exposed, Judge Carluccio entertains, endorses and rewards the Plaintiff’s attorneys for the ethical violations. The Plaintiff’s attorneys recognizing the tenuous position of the judge who is ignoring their ethics violations, have leveraged that position to extort substantial financial benefits for their client.

5. As each procedural and ethical violation has been documented, Judge Carolyn Carluccio has been determined to ignore the evidence; and forced to act to further prevent the testimony of the Defendant in her courtroom as it exposes her violations AND the prior violations of the eight prior judges who have been involved in this case.

6. Judge Carolyn Carluccio has lied from the bench, in her words and in her orders.

7. Judge Carolyn Caroluccio is acting to subvert any justice from occuring in her courtroom. She has demonstrated her clear determination to prevent and deny any hearing on any petition file by the Defendant.

8. Judge Carolyn Carluccio has refused to recuse from the case, and has also refused to hold any hearing on multiple recusal petitions.

9. Judge Carolyn Carluccio has taken direct actions to prevent the Appeal of the matter to the Superior Court. She has lied about those actions in Court and on the record.

10. The entire Montgomery County Judiciary should have recused from the case when it was noticed that Judge Rhonda Daniele issued a secret ex parte order in August 2007 defaming the Defendant.

Ordered without benefit of any hearing, and not having been distributed to the Defendant, or docketed with the Prothonotary, that Order subverted justice at every proceeding until it was discovered three years after it was issued. Upon discovery of the secret ex parte order, all hearings on any matter filed by the Defendant were ignored. Additionally, the courts schedule was intentionally manipulated to permit immediate hearings on petitions filed by the Plaintiff where the Defendant was never permitted time to review the petitions, or prepare a complete response.

The judges were prevented from recusing themselves from the case as it would clearly indicate the wrongdoing of Judge Rhonda Daniele. Instead they acted to conceal the actions of Judge Rhonda Daniele and to submit to the extortion of the Plaintiff’s attorneys. This guaranteed the complete impunity for the Plaintiff to ignore any Court Order, and the dismissal of any petition filed by the Defendant to enforce the Court’s Orders. The Defendant was left with no alternative but to return to an unjust and corrupted court to seek justice which would never be served.

11. After 6 years, it has become quite clear that the ex parte actions of the judiciary have served to deny the defendant his rights to life, liberty and the pursuit of any happiness. Exposure of the corruption has only served to cause the Defendant to be treated to further injustice. The court has acted with malice and intent to destroy a man, using all of the resources at their disposal to obstructive and deny justice, and to manipulate and prevent law enforcement from taking appropriate action.

Their intent was to humiliate the Defendant and to annihilate every aspect of the Defendant’s life to the point where he would commit suicide. They were not successful in obtaining the Defendant’s suicide.

The victim of injustice lives only to be further victimized until justice is served.

Judge Carolyn Carluccio has abused the power of her position on the bench in her attempt to conceal her actions, and to conceal the prior unjust actions of the Montgomery County judiciary. The Judges were all compelled into the position to deny justice to protect the judiciary because of the inappropriate and unethical actions of Judge Rhonda Daniele.

Judge Carolyn Carluccio should be immediately removed from the bench.

Judge Rhonda Daniele should be immediately removed from the bench.

The remaining judges who have acted on the matter should be suspended pending a review of their degree of complicity in the obstruction of justice, their intentional denial of the civil rights of the Defendant, and their unethical behavior.

The Court documents demonstrate the complete failure of the Court to uphold their responsibility and oath of office.

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