IN THE COURT OF COMMON PLEAS OF MONTGOMERY COUNTY, PENNSYLVANIA
CIVIL ACTION – LAW
SONYA HEALY : #2007-12477
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TERANCE HEALY :
PETITION REQUESTING AN IMMEDIATE STAY /RESCHEDULING REGARDING THE ORDER OF JULY 18, 2011 AS THE INCOMPLETE WRITTEN ORDER PLACES THE DEFENDANT IN JEOPARDY
1. The Order of July 18, 2011, as written, fails to authorize access to the marital home to the Defendant, Terance Healy. EXHIBIT A
2. The typed transcript of the Short List Conference on July 18, 2011 will not be available for up to 3 weeks. EXHIBIT B
3. The Prior Order indicates that the Defendant must vacate the home by June 9, 2011.
4. The situation places the Defendant in jeopardy of being falsely arrested for violating the prior Court Order.
5. The jeopardy situation was called to the attention of the Court during the Short List Conference. Judge Carolyn Carluccio refused to place her Order in writing.
6. The Plaintiff has acted with the Montgomery Township Police Department, specifically Officer Gerald Dougherty to assure the Defendant not be permitted at the Home since June 9, 2011.
5. The Courts failure to place the Order in writing requires the Defendant to pay $124.00 to obtain the transcript.
6. The transcript, the only document of record which would permit the Defendant to access the home, will not be available to Defendant prior July 22 at 7:00PM,
7. The partial written Order dated July 18, 2011 requires the actions of the Defendant’s brother, John Healy, over whom this court has no jurisdiction.
Where the Court has placed the Defendant in jeopardy and made it so that he is unable to act lawfully with true, complete and correct copies of the Court’s Orders which can only be found in the transcript.
AND
The Defendant faces improper arrest if he attempts to follow the verbal part of the Order of July 18, 2011.
AND
The Defendant would additionally face an entire weekend incarcerated until the Court could become involved to clarify their Order, or face weeks incarcerated until the transcript could be produced indicating the full Order.
AND
Judge Carolyn Carluccio has demonstrated by her Orders and actions the extreme bias, disrespect, and malice against the Defendant, while refusing to recuse herself from the matter when her improper actions were documented and respectfully requested.
AND
Judge Carolyn Carluccio has further acted with extreme malice in issuing Orders denying the Defendant the opportunity to be heard on the Petitions filed with the Court since the discovery, revelation and documentation of the gross injustice he has endured since commencement of the Divorce Action by the Plaintiff.
AND
The Court has failed to correct it’s prior ruling requiring Arbitration, which remains unscheduled by Bruce Goldenberg since May 17, 2011.
WHEREAS
The Defendant requests the Cancellation and Rescheduling of the Actions Ordered until such time as the Defendant can be assured of his protection from further harassment, abuse and inappropriate police involvement.
The Defendant requests the reinstatement, and enforcement, of the existing Court Orders preventing any dissipation of assets by the parties along with hearings and sanctions to the parties for violations of the Orders of the Court.
The Defendant requests the enforcement of the existing Court Orders and the scheduling of the petitions regarding enforcement of the Courts Orders since the origination of this matter where they Court has inexplicably granted impunity to the Plaintiff to violate every Court Order without sanction or retribution or any financial impact.
Respectfully,
Terance Healy
Defendant
Pro Se
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