2011
09.20

IN THE SUPERIOR COURT OF PENNSYLVANIA

SONYA HEALY : 2007-12477
:
:
v. :
:
:
TERANCE HEALY :

EXTRAORDINARY PETITION TO PROCEED IN FORMA PAUPERIS
and to
PROCEED WITH THE APPEAL FILED AUGUST 15, 2011

1. The Court of Common Pleas of Montgomery County has neglected to act on a Petition to Proceed In Forma Pauperis filed on August 15, 2011 which has prevented the timely submission of the Appeal to the Superior Court of Pennsylvania.

2. Judge Carolyn Carluccio has intentionally and willfully issued a defective Final Order and has further has refused to conduct hearings and to hear evidence and testimony related to the defective issues.

3. The Defendant has filed a timely Appeal after attempting to resolve the defective matter in the Common Pleas Court.

4. Judge Carluccio issued her Order on May 9, 2011, and reaffirmed the Final Order and ended the Common Pleas Court jurisdiction on the matter on July 18, 2011 on the record and noted in the transcript.

5. Judge Carluccio has requested a Concise Statement of Errors Complained of on Appeal in accordance with Pa. R.C.P. 1925(b) and that statement has been provided timely.

6. Judge Carluccio has failed to act on the Petition to Proceed In Forma Pauperis filed concurrently with the Notice of Appeal. As such, the preparation of the Appeal paperwork and the transcription of the necessary transcripts has not yet begun.

7. Defendant respectfully requests the Superior Court of Pennsylvania accept this document in this matter, and approve the Petition to Proceed In Forma Pauperis so that the Appeal may proceed to the Superior Court.

8. Defendant respectfully requests the Superior Court of Pennsylvania issue a stay or injunction to prevent the execution of the defective Order as the continued actions being taken under that Order are causing irreparable harm to the parties involved.

TRANSMITTAL

The Following Documents are being provided in this package to the Superior Court of Pennsylvania:

APPEAL FILED

1. Notice Of Appeal filed August 15, 2011
Docket #2007-12477-326

2. Proof Of Service filed August 15, 2011
Docket #2007-12477-327

3. Proof of Service filed August 15, 2011
Docket #2007-12477-328

4. Request for Transcript filed August 15, 2011
Docket #2007-12477-330

5. Order dated August 22, 2011 filed August 25, 2011
Docket #2007-12477-330

6. 236 Notice filed August 25, 2011
Docket #2007-12477-334

7. Concise Statement of Errors Complained of on Appeal filed September 15, 2011
Docket #2007-12477-345

8. Certificate of Service to Plaintiff filed September 15, 2011
Docket #2007-12477-346

9. Certificate of Service to Judge Carluccio filed Septenber 15, 2011
Accepted by Court Administration – Cheryl Leslie
Docket# 2007-12477-347

10. Certificate of Service to Judge Carluccio filed September 15, 2011
Hand delivered by the Sherifff’s Department
Signed for and Accepted in the Judge’s Chambers by her law clerk.
Docket #2007-12477-348

DOCKET

11. Current Docket for Case # 2007-12477

TRANSCRIPT

12. Transcript Short List Conference on July 18, 2011

IN FORMA PAUPERIS

13. Petition to Proceed In Forma Pauperis filed August 15, 2011
Docket #2007-12477-329

14. RESUBMISSION: Petition to Proceed In Forma Pauperis filed September 19, 2011
Docket #2007-12477-350

15. Petition to Proceed In Forma Pauperis filed December 7, 2010
Docket #2007-12477-264

16. Petition to Proceed In Forma Pauperis filed December 14, 2010
Docket #2007-12477-266

17. In Forma Pauperis denied December 14, 2010 – Request too general in nature. Cost excessive to taxpayers.
Order dated December 14, 2010 by Judge Kelly C. Wall
UNDOCKETED

COURT REPORTER ESTIMATES

18. Invoice/Estimate Transcript of July 18, 2011

19. Invoice Transcript of July 18, 2011
** The number of pages in the transcript was 82 pages. 20 Pages over the initial estimate. This was due to the excessive number of interruptions in the testimony. The Defendant was not permitted to complete any sentence or thought without being interrupted by the Court.

20. Invoice Transcript of March 29, 2011

ATTEMPTS TO HAVE THE COURT HOLD HEARINGS AND RESOLVE ISSUES

21. Petition to Rescind/Cancel The Order of April 14, 2011 Which Violates Pennsylvania Law and the United States Constitution and Reschedule All Outstanding Petitions filed April 26, 2011
Docket #2007-12477-295

22. Petition for the Recusal of Judge Carolyn Tornetta Carluccio for Conspiracy, Corruption, Fraud, Intimidation, Conflict of Interest and Denial of Due Process / Procedure and Denial of Civil Rights filed March 16, 2011
Docket #2007-12477-289

23. Petition Requesting Scheduling of Unresolved Claims filed June 6, 2011
Docketed #2007-12477-307

23. Emergency Petition For Injunction to Stay / Vacate the Order of May 9, 2011 for Lack of Jurisdiction filed June 9, 2011
Docketed #2007-12477-311

24. Petition for the Recusal Of Judge Carolyn Carluccio filed September 2, 2011
Docketed #2007-12477-342
** This document summarizes the actions of Judge Carluccio as she fails to perform her responsibilities according to the Law and the Code of Ethical Conduct.

Respectfully Submitted,

Terance Healy
Pro Se

c/o Joan Healy
871 Mustang Road
Warrington, PA 18976

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