A Terroristic Divorce

Denise,

I see you have not filed any appearance with the court.

The image that you sent had been sent to Brie Halfond. No copy here yet. I guess that’s Brie’s job as the named attorney.

Do you plan to file an appearance anytime? I know there has been an aggressive refusal to answer that question for several years. Perhaps, that explains why I am repeatedly called to the Call of the Trial List under threat of bench warrant. No one was doing anything with regard to my representation.

Now, where you were very adamant and determined about
– not meeting,
– not discussing anything,
– not planning anything,
– not preparing anything,
– not discussing the reasons available for pretrial motions,
– not reviewing the discovery materials with me,
– not preparing any witness list,
– not providing the witness list expected from the DA,
– not reviewing the Information which had been provided to me. When found to be very incomplete, the contact person in the DA’s office refused to address the missing items and pages. And no other contact would assist.
– did you receive any Information package. While you may not want to see what I had been sent, I DEFINITELY WOULD LIKE A CHANCE TO SEE WHAT YOU RECEIVED.
– The other day in the hallway, you insisted you sent me EVERYTHING which the PD had received. However you didn’t send me what I asked for, and you still have not.
But, if you sent me everything, where is the Information? And in a brief meeting with Dean Beer, after a bit of incredulous questioning Dean was able to find the transcripts and they stated just what I indicated. He just had to listen, and look.
You have already indicated your intentions with regard to my interest in my own defense.

Now, clearly when you read that list, you can’t claim to be representing me in any manner. That many issues refused in such a short hallway conversation.

When the issue of conflict counsel was suggested, your temper suggested you didn’t plan to explain why that wasn’t necessary.

Should I attempt to contact Brie as she is listed as counsel on that document andon the docket.

I recall Judge Carpenters was very concerned with representation. I think he had sought to quash the appeals because of hybrid representation. I suppose you could all just have filed appearances and left them in place pursuant to the judges order.

Were you neglecting to take any action until the appeal of the order was completed? If so, you’re still about half a year late.

When each of the appeals had been initiated, I was representing myself. However, after January 2016, two appeals were quashed for failure to file a brief. Would that have been PJ’s neglect, or Ray Roberts neglect?

When PJ withdrew in October 2016, Brie filed her appearance the same day.

Perhaps you think that treating me with disrespect, disdain, arrogance and contempt creates a Attorney-client relationship of trust and respect. Perhaps you think refusing to read anything about the case shows you have confidence in you ability to succeed. It does not.

Where it is clear that I did not request the Public Defender. I had the Public Defender removed from the matter in September 2016 after he usurped the case and began filing documents which were counter to my interests. How would he know, he never contacted me to discuss anything.

I understand your workflow. You work in a factory. You can jump into any situation because you have the experience to do so. You have been doing your job for years. I’ve seen you in action. You convince people to follow your script. That may work for the guilty pleas, but If there had been an Arraignment I would plead NOT GUILTY.

I did not commit the offense, or any element of the offense. Those elements might have been explained in the arraingment, which did not happen. Likely, the lack of jurisdiction prevented the court from addressing me. That would explain why since 2016, I have been excluded from any participation in my defense and all ‘proceedings’ are conducted in chambers.

Dean also made it clear when we met the other day that he wanted no meeting, no discussion, no planning, no preparing. He did challenge every word I said, and when he finally looked, he saw I was correct.

I know you would never do that. Even when your own words were show to you in the email we were discussing you insisted in maintaining your erroneous statement.

The Model Rules suggest “reasonable communication between the lawyer and cclient is necessary for the client to effectively participate in he representation.”
Clearly, the Montgomery County Public Defenders Office has a very different philosophy.

For these reasons listed and all of the other hundreds of emails ignored and disregarded for the last several years, hundreds because neglect which was found to be department wide and included The Chief Public Defender, I have no confidence in your representation and recognize your determination to undermine and ignore the issues which affect the defense.

The assistant district attorney aggressively went after my voice, by challenging my competence. She succeeded. It was clearly hers just for asking ( and $ 7718.25 for an inadmissable and very late report ). There was nothing I could do to stop it. There was something you could have done, BUT YOU CHOSE NOT TO. As did PJ D’Angelo. HE CHOSE NOT TO.

That demonstration of capitulation in violation of the law and constitutional rights justifies my efforts to communicate with you and to REMOVE you from the matter.
Not a person in the world would call it representation. Zealous representation? No.

But, its not your liberty and character and reputation and self-respect under attack.

Please. Respond at your first opportunity. Don’t forget that appearance. Send the Information, discovery… I will get you the list for subpeonas for documents and witnesses.

Oh, you might want to read up on Dorney Park.

Terance