A Terroristic Divorce

MONTGOMERY COUNTY COURT OF COMMON PLEAS
NORRISTOWN, PA

TERANCE HEALY	NO. 2013-29976
v.
DAVID R. MILLER AND JENNIFER K. MILLER

MOTION TO STRIKE A DEFECTIVE AND VOID ORDER

1. Defendants have presented on October 22, 2013, as part of their Preliminary Objections in this matter, a defective and void order dated May 9, 2011. [#2013-29976-10 Defendants Exhibit 2]

2. Plaintiff respectfully requests this Honorable Court strike the defective and void order which has been used to defraud, misrepresent and misinform individuals, organizations, law enforcement and county departments.

3. To be valid and enforceable, a judgment must be supported by three elements:
(1) the court must have jurisdiction of the parties;
(2) the court must have jurisdiction of the subject matter; and
(3) the court or tribunal must have the power of authority to render the particular judgment.
If the requirements for validity are not met, a judgment may be subject to avoidance.

4. Any judgment rendered by a court which lacks jurisdiction, either of the subject matter of the parties, or lacks inherent power to enter the particular judgment, or entered an Order which violated due process or was procured through extrinsic or collateral fraud, is null and void, and can be attacked at any time, in any court, either directly or collaterally, provided that the party is properly before the court.

5. Such a judgment is void from its inception, incapable of confirmation or ratification, and can never have any legal effect.

6. A void judgment must be dismissed, regardless of timeliness if jurisdiction is deficient.

7. When providing relief from void judgments is applicable, relief is mandatory and is not discretionary.

8. The passage of time, however great, does not affect the validity of a judgment and cannot render a void judgment valid.

9. The limitations inherent in the requirements of due process of law extend to judicial, as well as political, branches of the government, so that a judgment may not be rendered in violation of those constitutional limitations and guaranties.

10. A court may not render a judgment which transcends the limits of its authority, and a judgment is void if it is beyond the powers granted to the court by the law of its organization, even where the court has jurisdiction over the parties and the subject matter.

DEFECTIVE AND VOID DIVORCE DECREE

11. In the matter of Healy v Healy #2007-12477, the docket for the matter demonstrates and supports that neither Sonya Healy, nor Terance Healy filed a Request for a Divorce Decree under 3301(c) or 3301(d) of the Divorce Code. [ Docket attached as Exhibit A ]

12. The parties in Healy v Healy #2007-12477 have never indicated by documentation or action any intention to request a divorce decree. As such there can be no divorce decree.

13. Additionally, in July 2009, Sonya Healy’s attorney, Robert Angst, filed a document with the court indicating the intention to NOT request a divorce decree until hearings had been held on unresolved claims.

14. In the matter of Healy v Healy #2007-12477, the Court does not have jurisdiction to issue a divorce decree where the parties have not consented to or made any such request.

DEFECTIVE AND VOID EQUITABLE DISTRIBUTION

15. “The Court has made it clear that ‘unless and until a valid decree in divorce has been entered, then there can be no equitable distribution of marital property.’” Reese v. Reese, 351 Pa.Super,521,506 A.2d 471, 473-474(1986)

16. The courts of common pleas are only empowered to make equitable distribution contemporaneously with or subsequent to a decree in divorce. Campbell v. Campbell, 357 Pa.Super, 483, 516 A.2d 363, 366 (1986)

17. This is because the settlement of economic and property claims is merely a part of the trial court’s broader power to terminate the marriage. Campbell, 516 A.2d at 366

18. Equitable distribution is an incident of divorce, not marriage.

19. As there is no valid divorce decree, there can be no equitable distribution order.

20. On June 6, 2011, the procedural defect of the void divorce decree was brought to the attention of the Court and ignored.

21. The issue of the defect has been raised in every subsequent court proceeding and ignored.

22. Sonya Healy, and her attorneys Robert Angst and Valerie Angst, have failed to take any action to address, correct or resolve the defective and void order of May 9, 2011.

PROPERLY BEFORE THE COURT

23. This issue is properly before this court as the defective and void order has been presented by the Defendants in defense of the Action in Ejectment filed on October 3, 2013.

24. The defective and void order of May 9, 2011 issued where the court lacked jurisdiction and authority is null and void, and can be attacked at any time, in any court, either directly or collaterally, provided that the party is properly before the court.

Whereas, Plaintiff respectfully requests this Honorable Court to adjudge, decree and strike the defective and void order of May 9, 2011 and prevent it from any future use to misrepresent and defraud.

Respectfully,
Terance Healy
Pro Se

( relating to Healy v Healy )

1. Since 2007, after years of seeking assistance from local, state and federal law enforcement and being summarily disregarded; and after years of requests seeking local, state and federal government involvement were completely ignored; and after years of filing documents exposing the deliberate injustice which were summarily dismissed without review or explanation. The failure of everyone in a position to address or resolve any legal issue was absolute and the failure to provide any explanation was unacceptable.

2. Those who were ignoring the clear and well-documented reports of the injustice were concealing the matter and enabling and causing further injustice.

3. Those who were deliberately failing to follow state law and documented court procedure excused their own misconduct without consequence and never explained, justified or addressed their actions.

4. The state court absolved without penalty the failure of others to follow court orders; to follow state law; and to follow court procedures. This ‘courtesy’ was not granted to plaintiff, Terance Healy. Never. Ever. EVERY false allegation against plaintiff, Terance Healy, was scheduled with the state court for immediate review and was required to be disproved. Plaintiff, Terance Healy, followed every state court order issued in the matter whether the order was valid, invalid, unjust, void, voidable, within or outside the jurisdiction of the court. Even where the order was unconstitutional. Even where the court order caused irreparable harm.

5. Plaintiff, Terance Healy, petitioned the state court to address and correct their improper, unlawful and unjust actions. The state court ignored and dismissed those pleadings. As a result of diligence and perseverance, the injustice is well-documented on the state court record.

6. Everyone acting, or not acting, in any regard failed to remedy or resolve any issue and each believed their actions were lawful.

7. Since 2007, a lack of jurisdiction was the most frequent reason given for inaction by law enforcement even where the law clearly indicated their proper jurisdiction for the situation.

8. Since 2007, no explanation was provided for the injustice of the state court. Eighteen judges have been assigned to the divorce matter. None have explained the injustice. Each subsequent judge sacrifices their integrity to deny, conceal and endorse the lack of integrity of the prior judges in the matter.

9. The injustice was inescapable. Any order could be raised in any court at any time by any party to cause an additional injustice which the court would not explain or justify. Appeals filed timely and served properly were prevented from being transmitted to the appellate court. The law, the truth, court procedures and jurisdiction were not a necessity or a concern to the state court.

10. It was necessary to determine the cause of the complete breakdown of the legal system and the state judiciary, and why each level of law enforcement and the judiciary believed their actions were lawful.

11. It was necessary to find, define, document and address a law that made deliberate injustice ‘lawful’.

12. Rule 1.6 is the unconstitutional law which mandates deliberate injustice.

13. Rule 1.6 must be followed by legal professionals, lawyers, law professors, district attorneys, attorneys general, the judiciary, a majority of each state legislature, a majority of the United States Congress, employees of the United States Department of Justice, the legal counsel consulted by law enforcement agencies, the legal counsel who advise the media, and many others.

14. Since 2007, every person and court to whom plaintiff, Terance Healy, pleaded for assistance and relief was mandated to follow Rule 1.6 – Confidentiality of Information. Non-legal professionals were advised to ignore the injustice by their legal counsel who is mandated to follow Rule 1.6. The mandated ‘confidentiality’ extends to any explanation for actions or inaction.

Filed November 26, 2013

UNITED STATES DISTRICT COURT
FOR THE
EASTERN DISTRICT OF PENNSYLVANIA

Terance Healy	)
Todd M. Krautheim	)
in the name of the United States	) Civil Action No# 13-4614
	)
v.	)
Kathleen Kane	)
Pennsylvania Attorney General;	)
and	)
The Attorneys General of the United States	)

MOTION FOR RECONSIDERATION

1. Plaintiffs respectfully request the Reconsideration of this Honorable Court regarding the Order of 29th day of October 2013.

2. The Court has written that the decision was based on the Rooker-Feldman doctrine which does not subject this matter to dismissal, and the Younger abstention which is not relevant to the constitutional matter before this Court, and Article III which grants judicial power to the District Court for cases which arise under the US Constitution.

3. Plaintiffs respectfully address the issues presented by the Court’s Memorandum dated October 29, 2013.

LAWFUL APPROACH

4. Plaintiffs have filed this Constitutional Challenge to address the denial of their civil rights and liberties which are guaranteed by the US Constitution.

5. The denial of their rights and liberties has been caused by an improperly and unlawfully enacted state law – Rule 1.6 Confidentiality of Information of the Rules of Professional Conduct.

ARTICLE V SECTION 10(c)

6. Pursuant to Pennsylvania Constitution of 1968, Article V, Section 10(c), “… the power to prescribe general rules governing practice, procedure, and conduct of all courts… if such rules are consistent with Constitution and neither abridge, enlarge or modify the substantive right of any litigant, nor affect the right of the General Assembly to determine the jurisdiction of any court or justice of peace, nor suspend nor alter any statute of limitation or repose. All laws shall be suspended to the extent that they are inconsistent with rules prescribed under these provisions.” As Rule 1.6 causes the denial of substantive rights of a litigant, the Pennsylvania Supreme Court lacks the authority required to properly and lawfully enact Rule 1.6 into law.

NECESSITY

7. The Plaintiffs have been directly harmed by the denial of their constitutionally protected rights. The harm suffered will continue until the law which mandates that the state courts ignore their rights is nullified and their rights and liberties are restored.

8. The Constitutional Challenge before this court is a NECESSITY. The Challenge presents the loss of constitutionally protected rights and liberties and the irreparable harm and inescapable injustice which occurs when basic rights and liberties are irretrievably denied and prevented.

ROOKER – FELDMAN DOCTRINE

9. While the plaintiffs have clearly stated their singular intention to present the constitutional challenge to this Honorable Court for review, the Court has inappropriately and incorrectly written “that plaintiffs seek review and rejection of decisions previously made by the Pennsylvania state courts.” The state court records are evidentiary for the purpose of demonstrating the unconstitutionality of actions mandated by the law being challenged.

10. The Court incorrectly writes that “it is clear that plaintiffs are, at bottom, asking the Court to consider and reverse determinations made in the state court divorce and mortgage foreclosure proceedings.”

11. The referenced footnote on page eight correctly indicates “To the extent that plaintiffs do “not, [in their complaint,] complain of injuries caused by a state court decision,” and instead raise “a direct challenge to the constitutionality” of Rule 1.6, their complaint is “not subject to dismissal under the Rooker-Feldman doctrine.” Gray v Yavil, 513 F. App’x 210,212(3d Cir. 2013)

12. Plaintiffs have not petitioned this Honorable Court to affirm or reject any decision or opinion of the state court. Plaintiffs concur with the Court that the constitutional challenge is “not subject to dismissal under the Rooker-Feldman doctrine.”

VENUE

13. This matter is properly placed in the US District Court as the proper court of first instance for a Constitutional Challenge. The underlying state court cases are not the subject of review. The state court actions and decisions are the evidence which demonstrates the constitutional issue and the necessity for this challenge.

YOUNGER ABSTENTION

14. The state court lacks jurisdiction to address a Constitutional Challenge where the rights guaranteed by the United States Constitution have been denied as a consequence of a state law. Additionally, the state court is prevented from a proper review of the matter as the law being challenged mandates and prevents any proceeding or remedy at the state level. The constitutionality of the law must be addressed at a federal level.

15. The state supreme court’s direct responsibility for authoring, enacting and enforcing the law in question represents an undeniable conflict of interest which would preclude the state supreme court from proper jurisdiction. The state supreme court is prevented by Rule 1.6 from acting sua sponte to address the unconstitutional law. Rule 1.6 resists lawful resolution of the constitutional issue further demonstrating the necessity of this matter before this Honorable Court.

16. The Younger Abstention does not apply to this constitutional issue as there can be no state proceeding which affords any opportunity to raise this federal/constitutional claim.

ATTORNEYS GENERAL

17. Pursuant to Federal Rules of Civil Procedure Rule 5.1(a)(2) Constitutional Challenge to a Statute – Notice, Certification, and Intervention, Pennsylvania Attorney General Kathleen Kane and the Attorneys General of the United States have been served with the Constitutional Challenge as “a party that files a pleading, written motion, or other paper drawing into question the constitutionality of a federal or state statute must promptly serve the notice and paper on the Attorney General of the United States if a federal statute is questioned – or on the state attorney general if a state statute is questioned.”

18. There has been no record on the Court docket regarding Certification by the Court with the Attorneys General that a statute has been questioned pursuant to Federal Rules of Civil Procedure Rule 5.1(b).

19. Attorney General Kathleen Kane and this Court have improperly understated and paraphrased the law being challenged in this matter with the implication that the plaintiffs are challenging ‘attorney-client privilege’. Plaintiffs are challenging the constitutionality of Rule 1.6 in it’s entirety.

20. Analysis of Rule 1.6 indicates it is not a necessity for justice. It was only after Rule 1.6 was enacted into law that the denial of Constitutional Rights became lawful and injustice was ignored.

CONSTITUTIONAL RIGHTS AND LIBERTIES

21. Once this Court has ruled on the constitutionality of the law, the litigants rights will be restored and state court will be lawfully permitted to hear, address and resolve the injustices experienced in the state courts. The Judiciary will have the ability and opportunity to correct injustices and restore their integrity through each judges own actions and rulings. The judiciary should never have been mandated to suffer the loss of integrity required to conceal injustice.

22. The evidence in support of the facts in the complaint demonstrate the denial of constitutionally protected rights by the state courts. Those civil rights and liberties have been denied and ignored as a mandate of the law being challenged.

23. The Plaintiffs have yet to present this Court with their experience in the state courts which clearly demonstrates the denial of their rights, the injustices experienced in their respective cases, and the inability of the courts and the government to permit due process and procedure to petition the government for redress of grievances.

24. The relief requested will not usurp state jurisdiction or authority, or overturn any state decision(s) or opinion(s). The remedy will permit the state court to address parties in an unbiased, unaffected and fully informed equal forum.

25. It is not appropriate or lawful for this Honorable Court to dismiss this Constitutional Challenge and further deny, delay and prevent the plaintiffs from their civil rights and liberties under the United States Constitution.

STANDING

26. Plaintiffs have presented their ‘injury in fact” and the causal connection between the injury and the law being challenged. A determination that Rule 1.6 is unconstitutional would permit the injury to be addressed by restoring their constitutional rights in the state courts.

27. The injury is defined, documented and evident upon review of the state court record.

28. The chance of future injury occurring is likely and demonstrated by the matter already indicated for inclusion in this matter. In Healy v Healy where a defective and void series of court orders has been used as the basis for a penalty in excess of $300,000 ordered in March 2013.

29. The chance of future injury occuring is actual and demonstrated in the matter of Healy v Miller, where a defective and void order from Healy v Healy has been improperly presented by Miller in November 2013 as a valid order of the court with statement that the validity of the order cannot be collaterally challenged in an Action for Ejectment.

RECONSIDERATION

30. The Court’s review of the pleadings indicates proper subject matter jurisdiction, a valid statement of a claim for which relief can be granted, proper authority and jurisdiction for this Court to proceed with the matter, and a concise statement of the case being presented to the Court.

31. As the Court is not required to dismiss the matter under Rooker-Feldman doctrine, or Younger abstention.

32. Article III of the US Constitution provides jurisdiction and authority to the Court for all cases which arise under the constitution.

Plaintiffs respectfully request the review and Reconsideration of this Honorable Court to address the improper and unsubstantiated dismissal of this matter in the Court’s Order of 29th day of October 2013.

Respectfully,
Terance Healy
Todd M. Krautheim

PDF Version

[ The Millers raised a defective and void divorce decree/court order as their evidence of ownership. NOW, they act like I brought it up. AND they ignore EVERYTHING I did bring up. The court lacked jurisdiction to issue the divorce order. The court cannot obtain jurisdiction retroactively. Their order is void and a nullity. It will always be void and a nullity. The deliberate malice of Carolyn Tornetta Carluccio will continue to destroy lives, and fill the pockets of the lawyers whom she served as President of the Montgomery County Bar Association. ]

ZARWIN BAUM DEVIT0 KAPLAN SCHAER TODDY P.C.
GARY A. DEVITO
PHILIP A. MAGEN
ATTORNEY ID Nos. 36421/202181
1818 Market Street
13th Floor
Philadelphia, PA 19103
Telephone: 215-569-2800
FAX: 215-569-1606

Attorneys for David R. Miller & Jennifer K. Miller

MONTGOMERY COUNTY COURT OF COMMON PLEAS CIVIL ACTION

	NO. 2013-29976
TERANCE HEALY
v.
DAVID R. MILLER AND JENNIFER K. MILLER

DEFENDANTS DAVID R. MILLER & JENNIFER K. MILLER’S
REPLY BRIEF IN SUPPORT OF PRELIMINARY OBJECTIONS TO PLAINTIFF’S
COMPLAINT

Defendants David R. Miller and Jennifer K. Miller (“Defendants”), by and through their attorneys, file the following Reply Brief in Support of Defendants’Preliminary Objections to the Complaint of Plaintiff Terance Healy (“Plaintiff’):

In response to Defendants’ preliminary objections, Plaintiff primarily argues two points. First, that the Honorable Carolyn Tornetta Carluccio lacked the authority to grant Plaintiff’s ex-wife, Sonya Healy (“Sonya”), a power of attorney to dispose of the residence located at 110 Banbury Avenue, North Wales, Pennsylvania, 19454, Montgomery County Parcel No. 46-0000467-11-7 (the “Property’t). Second, that Plaintiff’s appeal of the May 9,2011 divorce decree (the “Decree”) should have acted as a stay. For the reasons set forth below, neither of Plaintiffs arguments has merit and his Complaint should be dismissed with prejudice.

[ Plaintiff presented over a dozen points. 1. No Power of Attorney 2. Invalid Power of Attorney 3. Defective Divorce Decree 4. Void Divorce Decree 5. Pending Appeal 6. Efforts to Avoid Fraudulent Conveyance 7. Obstruction 8. Denial of Rights 9. Failure to Demonstrate Ownership 10. Fraud 11. Forgery 12. Bad Power of Attorney 13. Misrepresentation of Marital Status Oddly, they address NONE of those issues. ]

The May 9th Divorce Decree is Valid and Binding

[ Definitely selected the wrong argument for this one. They should ask and not assume… or read this web site.]

Though Plaintiff attempts to ground his argument regarding the power of attorney in the statutory requirements set forth in 20 Pa.C.S. § § 5601-5611, Plaintiff falls to address that these statutes only govern statutory powers of attorney concerning the appointment of a fiduciary. The court has both’inherent and statutory to grant a power of attorney to a spouse in the context of a divorce. The Divorce Code specifically provides:

A decree granting a divorce or an annulment shall include, after a full hearing, where these matters are raised in any pleadings, an order determining and disposing of existing property rights and interests between the parties, custody, partial custody and visitation rights, child support, alimony, reasonable attorney fees, costs and expenses and any other related matters, including the enforcement of agreements voluntarily entered into between the parties. In the enforcement of the rights of any party to any of these matters, the court shall have all necessary powers, including, but not limited to, the power of contempt and the power to attach wages. 23 Pa. C.S.§ 3323(b) (emphasis added).

Under § 3323(b), Judge Carluccio had the power to take all necessary actions and order all necessary remedies to ensure the swift disposition of the Property, including granting Sonya a power of attorney to transfer the Plaintiffs interest in the Property.

[ ONLY WHEN THE JUDGE HAS JURISDICTION. The Divorce Decree is a nullity. It cannot be presented in any court as valid. It doesn’t exist. ]

Moreover, Plaintiff is barred from attacking the validity of the Decree in this action. The Divorce Code further provides:
The validity of a divorce or annulment decree granted by a court having jurisdiction over the subject matter may not be questioned by a party who was subject to the personal jurisdiction of the court except by direct appeal provided or prescribed by law. A party who sought and obtained a decree, financed er agreed to its procurement, er accepted a. property settlement alimony pendente lite or alimony pursuant to the terms of the decree, or who remarries after the decree, or is guilty of laches, is barred from making a collateral
attack upon the validity of the decree unless, by clear and convincing evidence, it is established that fraud by the other party prevented the making of a timely appeal from the divorce er annulment decree. 23 Pa. C.S. § 3333.

[ They present void orders as evidence and suggest I cannot attack. Well, the order is void, there is nothing to attack. It is a nullity. ]

Now, more than two years after the date of the Decree, Plaintiff attempts to collaterally attack the validity of the Decree in this action. Pursuant to 23 Pa.C.S. § 3333, Plaintiff is clearly prohibited from questioning the validity in this forum. Plaintiffs efforts to declare the Decree invalid fail and the Complaint should be dismissed with prejudice.

Plaintiff’s Attempted Appeal Did Not Stay the Effect of the Decree

[ What about those Petitions to Stay the Order while under Appeal? ]

Plaintiff implies that his appeal should function as a stay of the Decree. Plaintiff is mistaken. Regardless of the current status of the appeal, an appeal is not an automatic stay. See Pennsylvania Pub. Util. Comm’n v. Process Gas Consumers Grp., 502 Pa. 545, 553, 467 A.2d 805, 809 (1983) (noting that an application for stay pending an appeal should only be granted when the applicant makes a strong showing in support of the stay). An application for a stay pending appeal always involves a situation in which the merits of the dispute have been fully considered in an adversary setting and a final decree rendered.

In cases involving more than a judgment for a payment of money, an appeal will “operate as a supersedeas only upon the filing with the clerk of the court below of appropriate security as prescribed in this ru1e.’ Pa.R,A,P. 1733(a). In such cases, an application for stay pending appeal must first be filed, See Pa.R.A.P. 1732. Since Plaintiff did not follow the procedures for obtaining a stay, the Decree remained in effect throughout the course of the sale of the Property.

[ A void nullity cannot be in effect. It was never effective. It never could be effective. It never can be effective. ]

For the foregoing reasons, together with the reasons Set forth in Defendants’ Preliminary Objections, Defendants respectfully request that this Honorable Court sustain Defendants’ Preliminary Objections and issue an order dismissing Plaintiffs Complaint with prejudice.

By Philip A. Magen

[ The issues here aren’t in the usual scripts offered by the ABA. It’s important to read the law. To understand the law. To follow the law. It is important for lawyers to be concerned with their clients liability and the effect these actions and statements may have when they go to prosecute the crime committed against them. ]

November 22, 2013
Gary Kline
Domestic Relations Office
P.O. Box 311
Norristown, PA 19404-0311

By facsimile (610) 239-9637.

Healy v Healy 2007-12477
PACSES 853111584

Dear Gary,

Arm of the Court? Seriously? If so, would you care to address the deliberately defective and void order as invalid? Or valid? Things which supercede the Court’s authority include the Law, Due Process, Procedure, etc… A Judge is required to have jurisdiction to issue an Order of the Court.

Carolyn Tornetta Carluccio did not have jurisdiction, therefore she was NOT acting as a judge when she knowingly issued her deliberately defective and void order of May 9, 2011.

The Domestic Relations Office has a responsibility to execute a Court Order when it is valid. When given an invalid and defective order the Domestic Relations Office has a responsibility to respond accordingly to address the defects in the order.

Your department can address the defect in the void order of May 9, 2011. Your department can schedule a hearing to address the defect. The defect is not a judgment, it is procedural. The judge lacked jurisdiction. There is no way to retroactively obtain jurisdiction. The void order is never going to be valid. Never. Ever.

You continue to evade the defect while you perpetrate the invalid order and are complicit in the deliberate corruption ordered and where the County is feigning an obligation to follow a void order while it continues to harass my life.

The Archdiocese of Philadelphia has additionally been served the void and defective order. The deliberate void and defective order continues to attack every aspect of my life.

If you wish to do the right honorable and lawful action, simply recognize the defective and void order and resume APL until the a proper and lawful order can be issued.

The Constitutional Challenge of Rule 1.6 exposes the inability of a litigant to get a hearing when an act of judicial misconduct or corruption is involved in a matter. This will explain why Court Administration has been so directly involved in denying access to the court to address the matter.

If you are an attorney who may not lawfully take any action to expose the criminal misconduct and corruption of the judiciary, you are welcome to respond that ‘Pursuant to Rule 1.6, I am unable to take the lawful actions required by my office.’

Another matter, Healy v Miller #2013-29976, also awaits scheduling by Court Administration. In that matter, the Millers are attempting to assert the same void order as a power of attorney instrument. They were the victims of fraud in an amount in excess of $400,000.00.

My personal property and possessions were disposed of as a result of the same defective and void order.

According to the information returned in Healy v Miller, there is support owed which has not been collected by the Domestic Relations Office.

You have not explained why my file is marked CONFIDENTIAL? I am aware that the file has been altered and electronic records have been deleted.

I asked for a meeting, conference or proceeding. None has been scheduled.

I asked for a review of the void and defective order. No review has been scheduled.

I asked for an explanation of the rudeness and false allegations of your staff. It has been ignored.

I am spending another Thanksgiving destitute and homeless because of the complicity of Montgomery County in concealing the corruption and defective order of May 9, 2011. I have persevered through this injustice and terror since the initial concealed act of misconduct in August 2007. The facts are clear. The law is clear. The corruption is clear.

I presume you wanted to be the Director of Domestic Relations, SO DO THE JOB… or resign.

Sincerely,
Terance Healy

cc: Montgomery County Commissioners
Josh Shapiro, Chair
Leslie S. Richards, Vice Chair
Bruce L Castor Jr, Commissioner

November 19, 2013

Dear Mr Healy,

I noted in my previous letter that the information you attempted to deliver was received. I looked through the case and the docket with the Courts. I want to assist you but I cannot find anything that would supersede the Courts’s Order. I did see that appeals have been filed.

My office is merely an arm of the Court charged with enforcing the Court’s Order. At such time as your appeals have been decided upon and an order is entered please let me know and I’ll immediately update our records if I haven’t already received the new order.

Sincerely,

Gary Kline
Director

---

Arm of the Court? Seriously? If so, you would address the defective and void order as a part of the judiciary.

Things which supercede the Court’s authority include THE LAW, DUE PROCESS and PROCEDURE. A Judge is required to have jurisdiction to issue an Order of the Court. Carolyn Tornetta Carluccio did not have jurisdiction, therefore she was NOT acting as a judge when she issued her deliberately defective and void order of May 9, 2011.

The Domestic Relations Office has a responsibility to execute a Court Order when it is valid. WHEN IT IS GIVEN AN INVALID AND DEFECTIVE COURT ORDER there is a responsibility to respond accordingly to address the defects in the order.

Your department can address the defect in the void order of May 9, 2011. Do your job, or resign and give it to someone who will do the job lawfully.

If you are an attorney who may not take any action to expose the criminal misconduct and corruption of the judiciary, or you have been advised by legal counsel, you are welcome to respond that ‘Pursuant to Rule 1.6, I am unable to take the lawful actions required by my office.”

Then write your resignation letter, before the County Commissioners must ask for it.

I asked for a meeting. None has been scheduled.

I asked for a review of the void and defective order. No review of the defects has happened.

I presume you wanted to be the Director of Domestic Relations, SO DO THE JOB.

November 21, 2013

Montgomery County Commissioners
Norristown, PA

Josh Shapiro
Leslie Richards
Bruce Castor

Commissioners.

I am writing to ask your intervention in expediting the actions documented in the following documents.

I have been surviving against tremendous injustice since 2007.

Litigation to obtain the home I was illegally removed from has been stalled without explanation and remains unscheduled. All evidence indicates the fraud involved and the lack of jurisdiction regarding the defective and void court order dated May 9, 2011.

Nancy Becker personally assisted in moving the criminal prosecution forward by introducing me to Det. Greg Henry who was already aware of the issues involved in the fraudulent conveyance of my home and property.

Additionally, Gary Kline has failed to respond to questions about the mistreatment by his staff. The Domestic Relations Office is violating my rights, the law and the responsibility of Domestic Relations by following a defective and void order while refusing to address the issues which demonstrate the defects of the order.

I has been destitute and homeless since 2011 and somehow find the ability to persevere awaiting justice. I ask your assistance to address the issues currently before the County.

I beg your intervention and action.

Sincerely,
Terance Healy

included:
Letter November 7, 2013 DRO
Letter November 7, 2013, Gary Kline
Letter November 8, 2013, Sheriff Behr
Response November 13, 2013, Gary Kline
Letter November 19, 2013, Gary Kline
Letter November 19, 2013, Sheriff Behr

November 19, 2013

Gary Kline, Director
Domestic Relations Section
P.O. Box 311
Norristown, PA 19404-0311

Dear Mr. Kline,

In response to your letter of November 13, 2013, the Order of the Court to which you refer is a void order issued where the court lacked jurisdiction. The order is a nullity.

The evidence of the defect and lack of jurisdiction is on the court record and listed in the court docket for the matter. Judge Carolyn Tornetta Carluccio lacked jurisdiction and authority to issue the Order of May 9, 2011.

Under Federal law which is applicable to all states, the U.S. Supreme Court stated that if a court is “without authority, it’s judgments and orders are regarded as nullities. They are not voidable, but simply void; and form no bar to a recovery sought, even prior to a reversal in opposition to them. They constitute no jurisdiction; and all persons concerned in executing such judgments or sentences, are considered, in law, as trespassers.”
[Elliot v. Piersol, 1 Pet. 328, 340, 26 U.S. 328, 340 (1828)]

The Domestic Relations Office by executing and continuing to execute a void order where informed that you are acting on a void order while refusing and denying the opportunity to address the defective order issued without jurisdiction is a violation of your responsibility, a violation of the law, and a violation of my rights.

Your reply also failed to address the behavior of your staff which demonstrates a complicity to deny justice and deliberately deny access and communication with the Domestic Relations Office. It was clearly not the first time a false allegation was used to remove a litigant from the office without recourse. I remind you I was attempting to simply deliver a letter to your office which your clerk refused.

Tampering with the administration of justice in the manner indisputably shown here involves far more than an injury to a single litigant. It is a wrong against the institutions set up to protect and safeguard the public, institutions in which fraud cannot complacently be tolerated consistently with the good order of society.

The public welfare demands that the agencies of public justice not be so impotent that they must always be the mute and helpless victims of deception and fraud. Surely it cannot be that preservation of the integrity of the judicial process must always wait on the diligence of litigants and demand excessive perseverance.

Take immediate action to review my letter of November 7, 2013. Review the data presented, the court record and issue a decision, or arrange a conference where the information may be presented formally to your office to arrive at a decision.

Thank you for your immediate attention to this matter. The corrupt actions have left me homeless and destitute since 2011. Should you have any questions, please do not hesitate to contact me.

Sincerely,

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

READ IT. The Gettysburg Address is only three paragraphs. It takes less than a few minutes to read. Give it a read.

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Four score and seven years ago our fathers brought forth on this continent, a new nation, conceived in Liberty, and dedicated to the proposition that all men are created equal.

Now we are engaged in a great civil war, testing whether that nation, or any nation so conceived and so dedicated, can long endure. We are met on a great battle-field of that war. We have come to dedicate a portion of that field, as a final resting place for those who here gave their lives that that nation might live. It is altogether fitting and proper that we should do this.

But, in a larger sense, we can not dedicate — we can not consecrate — we can not hallow — this ground. The brave men, living and dead, who struggled here, have consecrated it, far above our poor power to add or detract. The world will little note, nor long remember what we say here, but it can never forget what they did here. It is for us the living, rather, to be dedicated here to the unfinished work which they who fought here have thus far so nobly advanced. It is rather for us to be here dedicated to the great task remaining before us — that from these honored dead we take increased devotion to that cause for which they gave the last full measure of devotion — that we here highly resolve that these dead shall not have died in vain — that this nation, under God, shall have a new birth of freedom — and that government of the people, by the people, for the people, shall not perish from the earth.

Abraham Lincoln
November 19, 1863

KIDS FOR CASH is a riveting look behind the notorious judicial scandal that rocked the nation. Beyond the millions paid and high stakes corruption, KIDS FOR CASH exposes a shocking American secret. In the wake of the shootings at Columbine, a small town celebrates a charismatic judge who is hell-bent on keeping kids in line… until one parent dares to question the motives behind his brand of justice.

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Kids for cash scandal (From Wikipedia, the free encyclopedia)

Luzerne County Courthouse in Wilkes-Barre, Pennsylvania

The “kids for cash” scandal unfolded in 2008 over judicial kickbacks at the Luzerne County Court of Common Pleas in Wilkes-Barre, Pennsylvania. Two judges, President Judge Mark Ciavarella and Senior Judge Michael Conahan, were accused of accepting money from Robert Mericle, builder of two private, for-profit juvenile facilities, in return for contracting with the facilities and imposing harsh sentences on juveniles brought before their courts to increase the number of inmates in the detention centers.

For example, Ciavarella sentenced children to extended stays in juvenile detention for offenses as minimal as mocking a principal on Myspace, trespassing in a vacant building, and shoplifting DVDs from Wal-mart. Ciavarella and Conahan pled guilty on February 13, 2009, pursuant to a plea agreement, to federal charges of honest services fraud and conspiracy to defraud the United States (failing to report income to the Internal Revenue Service, known as tax evasion) in connection with receiving $2.6 million in payments from managers at PA Child Care in Pittston Township and its sister company Western PA Child Care in Butler County. The plea agreement was later voided by a federal judge, who was dissatisfied with the post-plea conduct of the defendants, and the two judges charged subsequently withdrew their guilty pleas, raising the possibility of a criminal trial.

A federal grand jury in Harrisburg, Pennsylvania returned a 48 count indictment against Ciavarella and Conahan including racketeering, fraud, money laundering, extortion, bribery and federal tax violations on September 9, 2009. Conahan entered a revised guilty plea to one count of racketeering conspiracy in July 2010. In a verdict reached at the conclusion of a jury trial, Ciavarella was convicted February 18, 2011 on 12 of the 39 counts he faced.

Following the original plea agreement, the Pennsylvania Supreme Court ordered an investigation of the cases handled by the judges and following its outcome overturned several hundred convictions of youths in Luzerne County. The Juvenile Law Center filed a class action lawsuit against the judges and numerous other parties, and the state legislature created a commission to investigate the wide-ranging juvenile justice problems in the county.

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So the question which is never asked is WHY DID IT TAKE SO LONG FOR SOMEONE TO REACT TO THE VOLUMINOUS REPORTS ABOUT THE CORRUPT JUDGES? The Judicial Conduct Board ignored EVERY complaint and usurped all responsibility to address the judicial crimes. THEY THEN DID NOTHING while the people were terrorized..

THE ANSWER: The law indicates it is not lawful to prosecute a corrupt judge. Not by a lawyer, prosecutor, district attorney or attorney general. Those who must follow Rule 1.6 of the Rules of Professional Conduct.

The same rule exists in every state. Same name. Same number. Same dead end for the victims of injustice.

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DELIBERATE OBSTRUCTION OF REMEDIES FOR THE INJUSTICE

The bigger question is WHY DID THE SHERIFFs who are by constitution and law the Chief Law Enforcement Officers in each County lose their power? It seems that judges and lawyers somehow reduced the Sheriffs responsibilities to prisoner taxi service, foreclosure sales and protection of the judges. Protecting the corrupt as well as the lawful.

The County Sheriff is not required to follow the Rules of Professional Conduct. The Sheriffs could have acted. The Sheriffs could act. The Sheriffs have a responsibility to act. Yet, somehow the Sheriffs have been convinced by the County District Attorneys that the Sheriff has no power.

The Constitutional Challenge, and the sedition it exposed, demonstrates why all of the law enforcement power was not placed under the one branch of government.

In order for the American Bar Association to conceal their sedition of every state government, and their continued protection of corrupt and criminal judges, it was necessary to disenfranchise the Sheriffs from law enforcement. AND THEY DID.

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This is not an issue of judicial immunity which can be viewed as occasionally unfair. The issue is deliberate unlawful actions by judges who refuse to address their errors, and the judges who are bound by law to ignore their corruption. Judges who must sacrifice their integrity to conceal the lack of integrity of the corrupt.

Judicial immunity protects judges from prosecution from unintentional errors in judgment. Immunity is a necessity for the courts to function. Judges are permitted to make bad decisions – as long as a judge follows the process and the law, the judge has jurisdiction to act.

When a judge fails to follow the process, the judge does not have jurisdiction to act as The Court. When a judge acts without jurisdiction, they are acting without the protection of judicial immunity. This is why they get multiple opportunities to fix their errors. Reconsideration, appeals, etc… Judge’s maintain their immunity even when they just don’t want to believe the testimony. So, if the judge doesn’t like you, YES THE JUDGE CAN RULE AGAINST YOU… as long as the proper process was followed for a hearing. A HUGE part of the job of being a judge is making certain that the judge has jurisdiction in the matter, otherwise the judge has no authority to order anyone to do anything.

When the court lacks jurisdiction… their actions, when documented and presented to the court, present the case for criminal prosecution against the judge. Any deliberate actions to destroy a litigant in the court subsequent to reports of judicial misconduct and crime are retaliatory and bring disgrace upon the entire judiciary. All the judge must do is follow the process, and then they have immunity for their malice.

For example:
1. When Judge Rhonda Daniele concealed her order in my family court matter for 3 years while it was used to leverage every proceeding against me.
No Hearing. No Jurisdiction. Not Valid.

2. When Judge Carolyn Tornetta Carluccio issued a deliberately defective and void order as a divorce decree. When raised to her immediate attention that she lacked jurisdiction to issue the order, she ignored it and issued another order compounding the error. When presented to the court, she again ignored the defect. When appealed to the Superior Court, she acknowledged the Appeal ordering a list of the errors involved in her order. She then prevented the appeal from being transmitted to the Superior Court.
No process. No Jurisdiction. Not valid.

3. When Judge Richard Haas was asked to conduct a penalty for a contempt that did not occur, he was set up to not have jurisdiction in that, AS WELL AS the penalty being part of a void order based on a void order based on a void order based on a defective order. Judge Haas never scheduled the hearing.
The only way to save the judge’s integrity was to do nothing.

4. When Judge Garrett Page conducted that hearing with the knowledge that jurisdication for the matter was with the Superior Court which was awaiting the Appeal paperwork, Judge Page ignored the pending Appeal. Judge Page ignored the nested void orders. Judge Page ignored the defective orders and the evidence on the court record and documented in testimony in his courtroom. Judge Page issued a contempt penalty without a finding of contempt. That penalty was over $300,000.00. This was done with deliberate intent. When a person fails to pay a contempt fine, they can be incarcerated until the amount is satisfied. Contempt penalties are unlike other monetary judgements.
No law. No process. No Jurisdication. Not valid.

5. When the Superior Court of Pennsylvania went to hear the appeal on Judge Page’s absurd order, Montgomery County did not send the exhibits or the documents for the matter.
No law. No process. No power to compel the Lower Court. Not valid.

6. Judge Garrett Page contacts Court Reporters to prevent transcripts from being produced and delivered. Judge Page cancelled the permission granted to proceed In FORMA PAUPERIS. All done without hearings, without explanations, without any regard for justice. All done to conceal the criminal actions of the 17 judges before him on the matter.. as the clear criminal actions by Judge Carolyn Tornetta Carluccio effectively voided all judicial immunity.
No Law. No process. Not valid.

7. When Judge Carolyn Tornetta Carluccio sent the sheriff to execute her void and defective order, the judge was expanding the liability for her criminal action to include the Sheriff’s department.
Actions by other parties based on void orders are subject to prosecution.

Those following a judge’s orders are responsible for making certain the orders are proper. THAT SIMPLY DOESN’T HAPPEN. No on ever confirms the jurisdiction or authority of a judge. Even when presented with the errors and defects, they ignore and act. It’s not a courtesy to ignore a judge’s corruption. It’s becomes a conspiracy.

There is a considerable amount of intimidation involved when it comes to concealing judicial corruption. Even the Montgomery County Employee Ethics rules immorally and unethically require silence. It is unlawful to be a whistleblower in Montgomery County.

For these reasons many counties have begun electing and appointing lawyers to the row officer and county management positions. Clerk of Courts, Controller, Coroner, District Attorney, Jury Commissioners, Prothonotary, Recorder of Deeds, Register of Wills, Sheriff, Treasurer, Court Administration, Domestic Relations. Where a Row officer is a lawyer, they must follow Rule 1.6 and must take no action to expose the corruption and crimes of the court.

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The Constitutional Challenge of Rule 1.6 of the Rules of Professional Conduct demonstrate the loss of civil rights and liberties. That was the primary issue. It was the information from Pennsylvania Attorney General Kathleen Kane which exposed the law improperly enacted by the Supreme Court of Pennsylvania. Their own act of judicial misconduct was immediately impossible to lawfully address – as they would expose their misconduct if they took action.

The conspiracy involved to get away with denying peoples rights has been very elaborate. Right in front of a distracted American Public, the American Bar Association – the lawyers and the judges – executed a plan which resulted in the loss of rights for American Citizens. They wrote themselves into a corner they could not lawfully escape.

1. Rule 1.6 is unconstitutional.

2. A Sheriff is the Chief Law Enforcement Officer in the County, NOT THE DISTRICT ATTORNEY. The reason for that is very clear. The reason everyone was convinced otherwise shows the extent of the conspiracy to avoid prosecution.

After Operation Graylord, the best way to protect the judiciary from losing their integrity was to have a judiciary with integrity… NOT to make it impossible to prosecute the corrupt judges. That is plain stupid and wrong on every level.

When you remove Rule 1.6 all of the other laws and aspects of immunities work. It’s how the system was designed.

Judges who commit crimes by not following due process, court procedures and the Law, are deliberately acting without jurisdiction and MUST be prosecuted.

The American Bar Association is the biggest and most corrupt racketeering organization ever to exist in the US. Their sedition and treason must be addressed. They deliberately destroyed the integrity of the judiciary nationwide. There is no excusing their crime.

The law is for the protection of the people…