2013
10.16

( PDF )

IN THE MONTGOMERY COUNTY COURT OF COMMON PLEAS
NORRISTOWN, PENNSYLVANIA

Terance Healy :
  : #2013-29976
v. :
  :
David R. Miller :
Jennifer K. Miller :

Emergency Praecipe for Immediate Eviction/Order of Possession (Addendum)

1. After service of the EMERGENCY PRAECIPE file with this Court on October 15, 2013, Plaintiff’s 80-year old mother was contacted by telephone multiple times by the Montgomery Township Police Department.

2. Montgomery Township Police Office Ruchkin has threatened the plaintiff with arrest if he approached his own property at 110 Banbury Avenue North Wales, PA 19454.

3. Plaintiff has taken no aggressive or violent action against the Defendants and as such, the threats to his freedom from Montgomery Township are unwarranted, unnecessary and unlawful.

4. Defendants have misrepresented ownership to Montgomery Township Police and have manipulated them into actions which are clearly an abuse of power under color of law.

5. As the Plaintiff is unaware of any allegation of criminal charges, the Montgomery Townnship Police have no jurisdiction in this civil matter.

6. THREATS TO THE SAFETY AND LIBERTY OF THE PLAINTIFF WARRANT THI COURTS IMMEDIATE ATTENTION.

WHEREAS, Plaintiff respectfully requests this honorable Court issue an EX PARTE ORDER FOR POSSESSION authorizing the Sheriff’s Department to take immediate action to remove, eject and prevent the Defendants from occupying the property and residence.

Respectfully,

Terance Healy



CASE DOCUMENTS
Civil Complaint – Action in Ejectment ( PDF )

Emergency Praecipe for Immediate Eviction / Order of Possession( PDF )

Emergency Praecipe for Immediate Eviction/Order of Possession (Addendum)( PDF )

Defendant’s Preliminary Objections and Defendant’s Memorandum of Law ( PDF )

Plaintiff Responds to Defendant’s Preliminary Objections and Defendant’s Memorandum of Law
( PDF )

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