A Terroristic Divorce

On September 14, 2007, Terance Healy was directed to pay  $ 990.51 per month to the Pennsylvania State Collection and Disbursement Unit. 

This value was based on the inaccurate and overstated determination of a monthly net income of $ 5928.68 for Terance Healy.  This value was based on information provided by Valerie Angst. 

Terance Healy has been kept from finding employment directly by the computer and phone intrusion, and indirectly by time required to respond to the legal chaos being generated by Angst & Angst.

The Effective Date of the Interim Order was August 14, 2007.  A copy of this Interim Order is attached as Exhibit B.

The balance was already in arrears by $ 553.60.  Additionally, $ 990.51 was ordered to be paid immediately.

While still at the conference, the value was immediately appealed.  An appeal date was scheduled for November 5, 2007.

Sara Armstrong, of Dischell, Bartle, Yanoff and Dooley, advised that it was evident that the legal expenses to respond to the volume of litigation involved in this divorce would result in serious financial difficulty and respectfully resigned  from representation of Terance Healy.

FINANCIAL HARDSHIP – SUPPORT (MOTIVE/INTENT)

On the evening of September 14, 2007, Sonya Healy indicated her reason for seeking Child Support.  “My lawyer said it would hinder you financially.”

The period of time for support is August 14, 2007 through August 7, 2009 – a period of less than 24 months.  When adjusted for legal fees incurred in the related litigation, petitioning for support is a financially irresponsible decision that will not benefit either party financially.

The grossly exaggerated financial figures assigned to Terance Healy, guaranteed further litigation and legal expense.  Those figures were provided by Valerie Angst.

SUPPORT ENFORCEMENT AS A WEAPON

Support balances which are not current subject the Payor to the following potential actions per PA 231 Rule 1910.20, PA 231 Rule 1910.22, PA 231 Rule 1910.23, PA 231 Rule 1910.24 :
– Income Attachment.
– Arrest
– Attachment/Seizure of assets in financial institutions
– Liens on real property
– Report to Credit agencies
– Contempt proceedings
– Suspension of Driver’s license

Immediately after the Conference in Support, Terance Healy began receiving notices from the Domestic Relations Office (DRO) and the Pennsylvania State Collection and Disbursement Unit (PA SDCU).

The activity of the Domestic Relations Office (DRO) and the Pennsylvania State Collection and Disbursement Unit (PA SDCU) occur without any additional legal expense to Sonya Healy.

Sonya Healy’s efforts to ‘hinder you financially” are handled without any additional legal expense to her by the Domestic Relations Office and the Pennsylvania State Collection and Disbursement unit.
SUPPORT APPEALS CONTINUED

Sara Armstrong had filed a Withdrawal of Appearance on September 27, 2007.

Terance Healy had filed an Entry of Appearance on September 27, 2007.

On October 9, 2007, Valerie Angst sent a letter requesting a continuance of the appeal conference to Sara Armstrong, who was no longer representing the defendant in this matter.  A copy of this letter is attached as Exhibit C.

The November 5, 2007 conference was continued without any opportunity to respond to the letter. 

The date for the appeal conference was re-scheduled for December 6, 2007.

The continuance, which extended the period of time during which the support arrears would increase based on the excessive amounts provided at the initial conference by Valerie Angst, subjected Terance Healy to the threat of enforcement actions by DRO and PA SDCU.

On November 13, 2007, the arrears balance was reported to the United States Department of the Treasury for Administrative Offset and or Federal Tax Refund Offset. A copy of this notice is attached as Exhibit D.

On November 30, 2007, the arrears balance was reported to the Pennsylvania State Tax Refund Offset Program.  A copy of this notice is attached as Exhibit E.

Effective December 7, 2007, the arrears balance was reported monthly to consumer credit bureaus.  A copy of this notice is attached as Exhibit F.

SUPPORT APPEAL – EXCEPTIONS

On December 10, 2007, an Order was issued which incorrectly indicated that it was for 2 children and increased the monthly support amount to $ 1300.70.  A copy of this order is attached as Exhibit G.

On December 10, 2007, A NOTICE OF PROCESS TO FILE EXCEPTIONS was sent to Terance Healy indicating:
“If you file exceptions, the recommendation will be a Interim Order of Court until the Court makes a decision in your case.”
A copy is attached as Exhibit H.

On December 26, 2007, Terance Healy filed his EXCEPTIONS TO RECOMMENDATION OF CONFERENCE OFFICER/MASTER a copy of which is attached as Exhibit I.

A Short List Proceeding was scheduled for February 6, 2008 before Judge DelRicci.

During the Short List Conference on February 6, 2008, Judge DelRicci refused to review any financial information or any document related to the income of the parties or the actions in this case. 

Judge Del Ricci issued an order on February 6, 2008 continuing the matter and placing it on the protracted family matters list, and
“ADDITIONALLY, the MCDRO Contempt hearing that was cancelled this day is to be rescheduled in front of Judge DelRicci ONLY.  Judge DelRicci will retain jurisdiction of this case and any and all contempt proceedings in this matter.”
A copy is attached as Exhibit J.

Terance Healy filed a request for an explanation of Judge DelRicci’s ExParte Order on December 19, 2008.  (attached as Exhibit K)

Judge DelRicci has not responded to that request.

SUPPORT APPEAL – COURT DATE SCHEDULED & CONTINUED

On February 26, 2008, a Notice of A Cancelled Event was received rescheduling a March 11, 2008 conference.  The new date for the conference was April 4, 2008 at 8:30AM.  A copy is attached as Exhibit L.

On February 29, 2008, an Order of Court was issued requiring an appearance on April 4, 2008 at 8:30AM.  A copy is attached as Exhibit M.

On March 31, 2008, the conference scheduled for April 4, 2008 was rescheduled for April 18, 2008.  A copy is attached as Exhibit N.

On March 31, 2008, an Order of Court was issued requiring an appearance on April 18, 2008 at 8:30AM.  A copy is attached as Exhibit O.

On April 9, 2008, the matter was scheduled on the Protracted Hearing list for May 19 – 26, 2008.

The April 18, 2008 appearance was not a conference as had been indicated on the paperwork.

April 18, 2008 was a hearing for Contempt of Court.  As such, the hearing was:
  – a separate matter from the Support Appeal and Exceptions.
  – a matter between the PA SDCU and Terance Healy.
  – based on the Interim Order which was under appeal.

CONTEMPT HEARING

On April 18, 2008, there was the appearance of an ex-parte communication having taken place immediately prior to the hearing with the Sonya Healy’s attorney, Robert Angst.  

Robert Angst had multiple conversations with the attorney representing the State/Support Enforcement

The Attorney representing the State/Support Enforcement had direct communication with each of the other defendant’s present in the courtroom that morning. 

The Attorney representing the State/Support Enforcement never spoke to Terance Healy.

Prior to the hearing, Terance Healy left the courtroom for a moment, Robert Angst immediately went to the courtroom door and peered out the window. 

Robert Angst then proceeded to go into the court’s chambers. 

Robert Angst did not return to the courtroom until just prior to the hearing, whereupon Judge DelRicci noticed his presence in the courtroom and invited him to join the prosecuting attorney.

Terance Healy petitioned the Court to be informed of the content of the apparent ex parte communication between Robert Angst and court staff on December 19, 2008.  (attached as Exhibit K)

Judge DelRicci has not yet responded to that request for information.

Judge DelRicci agreed to accept a document from Terance Healy as testimony.  A copy is attached as Exhibit P.

Judge DelRicci gave the eleven page document a cursory review neglecting to regard specific facts related to the case which were supported in the document by the relative state law. 

Judge DelRicci commented that he had been handed a copy of the state law and then ordered the Terance Healy to jail for six (6) months.

Terance Healy petitioned the Court for an explanation of Judge DelRicci’s actions in disregarding his testimony on December 19, 2008.  (attached as Exhibit K)

Judge DelRicci has not yet responded to that request for explanation.

Terance Healy was immediately, and unnecessarily, restrained by multiple officers of the court, shackled and handcuffed and removed from the courtroom. 

Terance Healy’s son was in the hallway of the courthouse to watch his shackled father hauled off to prison.

Terance Healy petitioned the Court for an explanation of why he was ordered to the county prison for a contempt issue regarding an Interim Order
  – which had never been signed by a Judge,
  – which was additionally the subject of a pending appeal,
  – and which had been repeatedly delayed by the rescheduling of the Court
on December 19, 2008.  (attached as Exhibit K)

Judge DelRicci has not yet responded to that request for explanation.

SUPPORT APPEAL

On May 19, 2008, during the protracted hearing Judge DelRicci realized that he had ordered the incarceration of Terance Healy for contempt based on an Interim Order.

Judge DelRicci confirmed that the appeal was regarding an Interim Order with his staff.

Judge DelRicci confirmed that the appeal was regarding an Interim Order with Robert Angst.

 Terance Healy was the only person to testify during the hearing.

At the end of the May 19, 2008 hearing, an Agreement was reached.  Whereupon Judge DelRicci issued an Order by reciting on the record.
“ I will leave it to the counsel for the Plaintiff to make sure that this order gets transmitted to the office of Domestic Relations so they can make the appropriate adjustment and credits. Okay. So Ordered.”

A copy of the Agreed Order from May 19, 2008,additionally orders the Court Reporter, Charles Holmberg, to provide a copy of the Transcript to MCDRO.  A copy is attached as Exhibit Q.

The Agreed Order indicated a reduced monthly payment and was retroactive to the August 14, 2007 initiation date. 

The adjusted amount for support resulted in the balance being current and prepaid for the next few months.

On June 27, 2008, Terance Healy notified the Court by letter of the failure of Robert Angst to act in accordance with the Court’s Order.  A copy is attached as Exhibit R.

On July 1, 2008, Angst & Angst sent a letter to Domestic Relations Division fulfilling their responsibility in regard to the Court Order.  Seven weeks had passed since the Judge had issued the Order. A copy is attached as Exhibit S.

The delay in responding to the Court Order ensured that there would not be a period where support arrears were not being reported to the collections unit, State and Federal agencies and the consumer credit reporting bureaus.

 Statements have never reflected the proper balance/payment due.

 Phone calls to resolve the proper information have never been successful.  Each contact indicates that they are not responsible for the data.

SUPPORT CONFERENCE

A conference was scheduled for November 17, 2008 regarding non-payment.  A copy is attached as Exhibit T.

The conference officer reviewed the issues involved in the case (Attached as Exhibit U), reasons for delays in payments, and provided a full statement of the support account (Attached as Exhibit V). 

Arrangements were made at the conference to resolve the outstanding balance, and it was explained how the continuing payments were going to be made.

On November 17, 2008, at the conference an Order was signed indicating that :
“The Deft is to pay $2355.07 by December 18, 2008 or the Deft is to appear in Domestic Relations on December 19, 2008 at 9:00 AM.  Failure to appear or comply will result in a Bench Warrant.”
A copy is attached as Exhibit W.

The November 17, 2008 Conference resolved all issues, indicated the resolution, and determined the payment schedule for the remaining 9 payments.

SUPPORT – ORDER TO RELEASE ASSETS

On November 18, 2008, without proceeding, without advance notice, and without explanation Judge Rhonda Daniele issued an order  for Wachovia bank to freeze assets.  A copy of this order was not sent to Defendant.  A copy of the order provided by Wachovia bank is attached as Exhibit X.

Pursuant to Judge Daniele’s order the bank account of my mother, Joan Healy, at Wachovia Bank was debited for $ 1855.07.
$ 1755.07  Ordered Amount
$   100.00 Processing Fee
A copy of the Wachovia transaction was sent to Joan Healy on November 26, 2008 and is attached as Exhibit Y.

 When the defendant’s mother suffered a stroke in 2006, the defendant’s name was added to her bank account while he was taking care of her and her household bills. 

The Account from which the funds were taken does not belong to the Defendant.

The funds were removed from the account as Joan Healy was preparing to host the family’s Thanksgiving dinner.

Joan Healy went to Wachovia Bank and on their advice closed the account to prevent any future occurrences of this type.

On November 20, 2008, Judge Daniele issued an Order to Release Assets.  The Order does not indicate to whom the fund were being released.  A copy of the Order is attached as Exhibit Z.

The Order to Release Assets additionally vacated an Order dated November 14, 2008.

Terance Healy has never received a copy of the Order which was issued on November 14 2008 and subsequently vacated by Judge Daniele.  As such he has no information about what Order was vacated.

Terance Healy stopped by the Domestic Relations Office on December 16, 2008 to obtain a copy of the Court Order from November 14, 2008 and was told by Rose that there was no such Order dated November 14, 2008.

In the course of the conversation with Rose, it was learned that the funds had been returned to the account without any notice and as such the support balance was still outstanding in the amount of $2355.07.

Terance Healy and Joan Healy went to the Wachovia Bank office in Warminster, PA to determine where the funds had been returned as the account from which they had been  taken was now closed.

There was no credit for the $100 processing fee charged by the bank and as such the Court has caused additional financial hardship to Terance Healy without basis or merit for which he will incur additional expense in any attempt to recoup.

Considering the payment was taken from the account, Terance Healy did not plan to make the payment as agreed on November 17, 2008 in the Support Conference.

Non-Payment would have resulted in a Bench Warrant being issued on December 19, 2008 in accordance with the Order.

December 19, 2008 was a Friday.

As the confusion had been caused by the conflicting Orders and the reversing entries on multiple Ex Parte Court Orders, Terance Healy believes and therefore avers that this was intentional and yet another part of the constant harassment he has received from the Court’s decisions which are apparently based on ex parte misinformation.

Terance Healy believes and therefore avers that the intent was that the Bench Warrant would result in his improper incarceration.

As the Bench Warrant would have been executed on a Friday, this unnecessary incarceration would have resulted in Terance Healy being further terrorized and harassed by spending the weekend before the Christmas Holiday in a jail cell until the matter could be resolved on Monday.

Terance Healy made a payment in person at the Domestic Relations Office in the Amount of $2355.07 on December 17, 2008.  A copy of the transaction is attached as Exhibit AA.

This is an example of another intimidating, harassing and terroristic effort by the Court against Terance Healy, whom the Court apparently feels has no credibility and as such no rights.

 The disrespect for the rule of law by this Court is appalling.

SUPPORT INTENT

Sonya Healy was advised by her attorneys to seek Child Support and has certainly  spent more on her legal fees related to Child Support than she will ultimately receive in support.

In seeking support, Sonya Healy was not considering what was in the best interests of her son, Brennan.

Sonya Healy was advised to seek support as her attorney’s had advised her that it would cause serious financial hardship for Terance Healy.

Sonya Healy was advised to seek support as her attorney’s had advised her that it would cause hardship for Terance Healy making it more difficult for him to obtain a loan, find employment, and recover financially from the divorce.

Sonya Healy was advised to seek support as her attorney’s had advised her that the Domestic Relations Office would be responsible for receiving and disbursing payments and also would staff and fund efforts to collect any over due amounts.

The Domestic Relations Office has certainly spent more funding on their efforts to manage the support payment than the total amount of support due for the entire period.

The Court has additionally spent more funding on the effort to hear appeals, schedule appeals, cancel appeals, continue conferences, continue court dates than the total amount of support due for the entire period.

Terance Healy requests information regarding the costs to process him to the County Prison on April 18, 2008 when the Court found him in contempt of a Court Order which had not been signed or reviewed by the Court and was the topic of an appeal delayed by the Court.

Terance Healy believes and therefore avers that the costs associated with processing his improper incarceration and subsequent release would likely exceed the total amount of support due for the entire period.

Terance Healy believes and therefore avers that the use of Child Support as a Weapon to harass and terrorize him was an irresponsible and improper action by  Angst & Angst who were aware of the excessive costs which would be incurred by the County/State as they were planning to provide inaccurate and fraudulent information at the initial conference in support.

The use of Child Support as a Weapon was financially improper on all accounts and as such Angst & Angst should be sanctioned for their improper counsel which has cost the County and State substantially.

Seeking Child Support was unnecessary as the minor child, Brennan Healy, had been splitting his time between his parents. 

In an effort to justify seeking child support, Angst & Angst advised Sonya Healy to remove Brennan Healy from the family home and prevent Brennan Healy from spending any time with his father or communicating with his father.