MOTION FOR THE PRODUCTION OF DOCUMENTS

2011
02.20

IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVANIA
CIVIL ACTION – LAW

SONYA HEALY : #2007-12477

v. :

TERANCE HEALY :

MOTION FOR THE PRODUCTION OF DOCUMENTS

1. On December 20, 2010, while delivering a response to Angst & Angst’s letter to Judge Carluccio, the Defendant requested a copy of the letter from a member of Judge Carluccio’s staff. The request was not granted.

2. The Defendant then provided his copy of the letter and asked the staff member to compare the letter received by the Judge with the one he had received.

3. The staff member agreed to confirm the documents were the same indicating the Defendant could call back later in the day for the information.

4. Around 3:45 PM, the Defendant contacted the judge‘s staff member by phone. She immediately indicated that she “did not want to get involved“. She further indicated that she would neither confirm or deny the letter was the same.

5. Attorney’s for the Plaintiff have indicated in documents submitted to the court that they have engaged in various forms of ex parte communication with previous judge’ assigned to this case. A petition is currently before the court filed September 14, 2010 and titled PETITION REGARDING PLAINTIFF’S EX PARTE COMMUNICATIONS.

6. Additionally, the Defendant has documented the following ex parte issues with the court.

Request For Explanation of Ex Parte Rulings and Communications – Documents and requests an explanation from Judge DelRicci of events on February 6, 2008 – Child Support Short List; April 19, 2008 – Child Support Enforcement; May 22, 2008 – Immediately prior to a Protracted Child Support Hearing. (Docketed# 2007-12477-113)

Request for Explanation of Ex Parte Ruling – Documents and requests an explanation from Judge Tilson regarding his Temporary Ex Parte Order that my son be permitted to leave the country. No Hearing or Conference was held at the time, or within the time period indicated by state law regarding ex parte orders. (Docketed# 2007-12477-114)

Response to Conciliation Report – At a conference on May 19, 2008, Plaintiff was not represented by her attorney and she barely spoke, the Conciliation Report from Sara Goren reflects ONLY the Plaintiff’s distortions. Over 8 pages of topics presented by the Defendant were not included in the report. Most notably that Plaintiff used the minor child as part of a team that broke into and burglarized and vandalized the Defendant’s home in violation of Orders and Agreements. (Docketed# 2007-12477-112)

Motion for Reconsideration of Witness/Testimony – Sara Goren had presented and recommended a Custody Agreement which included 3 sentences, instead of the boiler plate document normally used which is 5 pages in length. A Motion was filed for her testimony in a Petition for Contempt against the Plaintiff. Judge Bertin denied the motion.
(Docketed# 2007-12477-155)

Notice of Discovery of Ex Parte Orders dated August 22, 2007 – Documenting the discovery of an Order issued by Judge Rhonda Daniele, never docketed or distributed to Defendant. The Order secretly removed the Defendant’s parental rights without benefit of any proceeding in violation of the Defendant’s civil rights. Additionally, it provided the Plaintiff a method by which the Court and law enforcement personnel could be influenced into ruling against the Defendant. (Docketed# 2007-12477-221)

Petition Regarding Plaintiff’s Ex Parte Communications – Plaintiff’s attorneys submit an invoice in regard to a hearing where Defendant was ordered to pay fees, inadvertently indicating ex parte communication with Judge Bertin. (Docketed# 2007-12477-240)

Petition Regarding Discrepancies/Errors on Invoice for Fees – Plaintiff’s attorneys submit an invoice in regard to a hearing where Defendant was ordered to pay fees, inadvertently billing for ex parte communication with Judge Bertin and revealing their dilatory actions and negligent misrepresentation. (Docketed# 2007-12477-241)

Request For Recusal of Judge R. Stephen Barrett – Defendant requests that Judge Barrett recuse himself after a hearing on October 7, 2010. (Docketed# 2007-12477-262)

WHEREAS, The Defendant requests a copy of all correspondence that the court has received regarding the case, or which in any way refers to the case or the parties to the case.

The Defendant requests the court provide copies of all documents regarding the case, or which in any way refers to the case, or the parties to the case, or their children, including but not limited to all correspondence, courtesy copies of pleadings, amicus briefs and documents from friends of the court which have been mailed, hand-delivered, transmitted electronically via email or fax, or received directly via fax.

Where multiple copies have been received in various formats, all duplicates shall be provided and include electronic date/time stamp information.

Any document not being provided shall be listed by the title, date and author of the document along with a statement indicating the nature of the document and the reason it is not being provided.

Additionally, ALL documents will be filed with the Prothonotary so they are available for review by any interested parties involved in the case.

A Terroristic Divorce