2012
07.10

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

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

RESPONSE AND COUNTERPETITION

1. DEFENDANT DOES NOT WAIVE DUE PROCESS AND PROCEDURE REQUIREMENTS

2. PLAINTIFF HAS FAILED TO SERVE THIS PETITION UPON DEFENDANT
(Exhibit A)

3. DEFENDANT RESPONDS TO PLAINTIFF’S ‘PETITION’ TO REASSIGN THE MATTER
(Exhibit B)

4. DEFENDANT REQUESTS CORRECTION OF THE DOCKET FOR DUPLICATE ENTRY

5. DEFENDANT REQUESTS REMOVAL OF ANGST & ANGST FROM THE MATTER
– EX PARTE COMMUNICATION
– DELIBERATE AND MANIPULATIVE FAILURE OF DUE PROCESS AND PROCEDURE
– FRAUD UPON THE COURT
– EXTORTION
– FORGERY

6. DEFENDANT RESPONSE TO ISSUES LISTED IN THE DOCUMENT REFERENCED IN THE SCHEDULING ORDER

COUNTERPETITION

7. VOID – PETITION TO STRIKE JUDGEMENT / ORDER OF SEPTEMBER 23, 2011

8. VOID – PETITION TO STRIKE JUDGEMENT / ORDER OF JULY 18, 2011

9. VOID – PETITION TO STRIKE JUDGEMENT / ORDER OF MAY 9, 2011

10. DEFENDANT REQUESTS THE COURT SCHEDULE HEARINGS ON OUTSTANDING PETITIONS

11. DEFENDANT REQUESTS THE COURT PREPARE AND DELIVER THE APPEAL FILED AUGUST 15, 2011 TO THE SUPERIOR COURT OF PENNSYLVANIA

WHEREAS,

Defendant respectfully requests this Honorable Court schedule a protracted hearing on the above-listed matters which have been properly prepared, and filed with the Court, and served upon the Plaintiff.

Defendant respectfully requests the dismissal of the Plaintiff’s document(s) as this Honorable Court lacks jurisdiction to render any decision where the Plaintiff, by and through her attorneys, has neglected to properly deliver and serve the document upon the Defendant.

Respectfully Submitted,

Terance Healy
Defendant
Pro Se

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